DAQ-2024-004445

Chevron
Troy Tortorich Salt Lake Refinery
Refinery Manager Chevron Products Company
685 S Chevron Way
North Salt Lake, UT 84054
Tel [phone]
Fax [phone]
January 29, 2024
CERTIFIED MAIL
RETURN RECEIPT NO. 7021 2720 0001 4083 6906
Director, Air Enforcement Division
Office of Regulatory Enforcement
U.S. Environmental Protection Agency
Mail Code 2242-A
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460-0001
Consent Decree, U.S. v. Chevron USA Inc.
Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report
Dear Sir or Madam:
Pursuant to Paragraph 115 of the Consent Decree, this letter, along with all of its attachments, constitutes
Chevron Salt Lake City Refinery's semi-annual progress report for the period ending December 31,2023.
The reporting requirements for each subject area outlined in Paragraph 115 of the Consent Decree are
provided as follows:
1. Progress report on the implementation of the requirements of Section V (Affirmative
Relief/Environmental Projects of the Consent Decree at the Salt Lake City Refinery): This
information is contained in Attachment I.
2. A summary of the emissions data for the Salt Lake City Refinery that is specifically required by
the reporting requirements of Section V of the Consent Decree for the period covered by the
report: The Salt Lake City Refinery is no longer required by the Consent Decree to report spec (tic
emissions data.
3. A description of any problems anticipated with respect to meeting the requirements of Section V
of the Consent Decree at the Salt Lake City Refinery: None.
4. A description of all SEPs being conducted at the Salt Lake City Refinery in accordance with
Paragraph 109 of the Consent Decree: The Salt Lake City Refinery has completed all SEPs
5. Any such additional mailers as Chevron believes should be brought to the attention of EPA and
UDAQ: None.
6. BWON materials required to be submitted by Paragraph 82 of the Consent Decree: This
information is provided in Attachment 2.
7. LDAR information required to be submitted by Paragraph 97 of the Consent Decree: None
Director, Air Enforcement Division
Office of Regulatory Enforcement
January 25, 2024
Page 2
If you have any questions or require additional information, please contact auren Vander Werifat (801)
539-7386 or lvanderwerff chevron.com.
CERTIFICATION
I certi1' under penalty of law that this information was prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my directions and my inquiry of the persons who manage the system, or
the persons directly responsible for gathering the information, the inforniation submitted is, to the best of
my knowledge and belief, true, accurate, and complete.
Sincerely,
fry
Troy Tortorich
Attachments
cc: Via E-Mail:
Refine CD ERG.com
marinathomas(agutah.aov
foley.patrick(Wepa.gov
CERTIFIED MAIL NO 7021 2720 0001 4083 6918
Bob Gallagher
U.S. EPA Region 8 Montana Office
10 West 15th Street, Suite 3200
Helena, MT 59626
CERTIFIED MAIL NO 7021 2720 0001 4083 6920
Marina V. Thomas, Utah Assistant Attorney General
Environment/Health & Human Services Division
Utah Attorney General's Office
195 North 1950 West
P0 Box 144820
Salt Lake City, UT 84114-0873
Attachment I
Affirmative Relief! Environmental Projects Implementation Progress Report
for the period of 7!1!2023 through 12!3112023
Section VA. - NOx Emissions Reductions from FCCUs
Item to be Reported
CD
Reference Status
Establishing NOx Emission Limits:
EPA will use the data collected during the ¶ 13.b. Other than during periods of startup, shutdown, or baseline period, the Optimization Period, and malfunction pursuant to ¶13.c., the Chevron Salt Lake the Demonstration Period, as well as all other City Refinery complied with the emission limits pursuant available and relevant information to establish to ¶13.b. limits for NOx emissions from the Salt Lake City
FCCU. EPA will establish a short term (i. e., 24-
hour or 7-day rolling average) and long term
(365-day rolling average) concentration-based
(ppmvd) NOx emission limit as measured at 0%
02. Chevron shall immediately (or within ninety
(90) days, if EPA's limit is more stringent than
the limit proposed by Chevron) operate the
FCCU so as to comply with the EPA-established
emission limits.
Demonstrating Compliance with FCCU NOx Emission Limits:
Chevron shall install, certify, calibrate, ¶ 15 The NOx and 02 CEMS continue to be calibrated,
maintain and operate NOx and 02 CEMS maintained and operated according to the CD
required by ¶15 in accordance with the requirements.
provisions of 40 C.F.R. § 60.13 that are
applicable to CEMs and Part 60 Appendices A
and F, and the applicable performance
specification test of 40 C.F.R. Part 60
Appendix B.
With respect to 40 C.F.R. Part 60, Appendix F,
in lieu of the requirements of 40 C.F.R. Part
60, Appendix F § 5.1.1,5.1.3 and 5.1.4,
conduct either a Relative Accuracy Audit
("RAA") or a Relative Accuracy Test Audit
("RATA") on each CEMS at least once every
three (3) years.
" Conduct Cylinder Gas Audits ("CGA") each
calendar quarter during which a RAA or a
RATA is not performed.
consent Decree, U.S. v. Chevron USA Inc., Case No. 003-04650 (ND. cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1, 2023 through December31, 2023
Attachment I Page 3 of 25
Section V.B. - S02 Emissions Reductions from FCCUs
Item to be Reported
I Co
Reference
I
Status
Compliance with Specific S02 Emission Limits
Chevron shall either: ¶ 16.d.i., Other than during periods of startup, shutdown, or
1. by no later than 12/31/2008 comply with a It 16.d.ii malfunction pursuant to ¶16.e., the Chevron Salt Lake
City Refinery complied with the emission limits of25
final 502 limit of 25 ppmvd @ 0% 02 on ppmvd @ 0% 02 on a 365-day rolling average and 50
a 365-day rolling average basis and 50 ppmvd @ 0% 02 on a 7-day rolling average.
ppmvd @ 0% 02 on a 7 day rolling
average basis through feed hydrotreating
and 502 reducing catalyst additives; or
2. by no later than 12/31/2010, comply with a
final 502 limit of 25 ppmvd @ 0% 02 on
a 365-day rolling average basis and 50
ppmvd @ 0% 02 on a 7 day rolling
average basis through installation and
operation of a wet gas scrubber.
Demonstrating Compliance with FCCU S02 Emission Limits
Chevron shall install, certify, calibrate, ¶ 20. The 502 and 02 CEMS continue to be calibrated,
maintain, and operate all 502 and 02 CEMS maintained and operated according to the CD
required by ¶20 in accordance with the requirements.
provisions of 40 C.F.R. § 60.13 that are
applicable to CEMs and Part 60 Appendices A
and F, and the applicable performance
specification test of 40 C.F.R. Part 60
Appendix B.
With respect to 40 C.F.R. Part 60, Appendix F,
in lieu of the requirements of 40 C.F.R. Part
60, Appendix F § 5.1.1, 5.1.3 and 5.1.4,
Chevron shall conduct either a Relative
Accuracy Audit ("RAA') or a Relative Accuracy
Test Audit ("RATK) on each CEMS at least
once every three (3) years.
Chevron shall Conduct Cylinder Gas Audits
("CGA") each calendar quarter during which a
RAA or a RATA is not performed.
Hydrotreater Outages ______________________________________________
No later than December31, 2004, Chevron
___________
¶ 21. To the extent that the Chevron Salt Lake City Refinery
experienced a Hydrotreater Outage during the reporting
shall submit to EPA and the appropriate period, the Chevron Salt Lake City Refinery complied
Plaintiff-Intervenor, for approval by EPA, a with the requirements of the approved Hydrotreater
plan for the operation of the FCCU (including Outage Plan dated November 20, 2007 and ¶21
associated air pollution control equipment) requirements.
during Hydrotreater Outages in a way that
minimizes emissions as much as practicable.
Chevron shall comply with the approved plan
at all times, including periods of Startup,
Shutdown, and Malfunction of the hydrotreater.
Consent Decree, U.S. v. chevron USA Inc., case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31, 2023
Attachment 1 Page 4 of 25
In the event that Chevron asserts that the
basis for a specific Hydrotreater Outage is a
shutdown (where no catalyst changeout
occurs) required by ASME pressure vessel
requirements or applicable state boiler
requirements, Chevron shall submit a report to
EPA that identifies the relevant requirements
and justifies Chevron's decision to implement
the shutdown during the selected time period.
¶ 21. Not applicable for this reporting period.
Section V.C. - PM Emissions Reductions from FCCUs
CD
Item to be Reported Reference Status
" Chevron shall continue to control and may Section V.C. Chevron Salt Lake City Refinery continues to operate
further reduce particulate matter ("PM") an electrostatic precipitator to control PM emissions.
emissions from its Refineries by the operation
and optimization of electrostatic precipitators _____________________________________________________ ______________
Final PM Emission Limits
" By no later than 4/10/2005, Chevron shall ¶ 23. The Chevron Salt Lake City Refinery verified
compliance with the emission limit of 1.0 pounds of PM
comply with an emission limit of 1.0 pounds of per 1000 pounds of coke burned on a 3-hour average
PM per 1000 pounds of coke burned on a 3 basis for the FCCU by stack test conducted August 16-
hour average basis. 17, 2023.
PM Testing for FCCUs
" Chevron shall follow the stack test protocol ¶ 23A. See status for 1123.
specified in 40 C.F.R. § 60.I06(b)(2) to
measure PM emissions on the FCCU.
" Chevron shall conduct annual PM stack tests
at the FCCU.
" Upon demonstrating through at least three (3)
annual stack tests that the PM limits are not
being exceeded at the FCCU, Chevron may
request EPA approval to conduct tests less
frequently than annually at the FCCU.
Opacity Monitoring at FCCUs
" Chevron shall install, certify, calibrate, ¶ 25. The COMS continues to be calibrated, maintained, and
operated according to the CD requirements.
maintain, and operate all COMS required by
this Consent Decree in accordance with 40
C.F.R. § 60.11, 60.13 and Part 60 Appendix
A, and the applicable performance
specification test of40 C.F.R. Part 60
Appendix B.
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31, 2023
Attachment I Page 5 of 25
Section V.D. - CO Emissions Reductions from FCCUs
CD
Item to be Reported Reference Status
CO Emissions Limits for Salt Lake City FCCU
" By no later than April 10, 2005, Chevron shall ¶ 27. Other than periods of S/U, S/D, or malfunction pursuant
meet an emission limit of 500 ppmvd CO to ¶ 28, the Chevron Salt Lake City Refinery complied
corrected to 0% on a 1-hour average basis with the emissions limits in ¶ 27 with the exception of
the following.
On December 14,2023, CO emissions from the FCC
exceeded the emission limit due to the unit operating in
abnormal conditions to correct a sulfur issue.
Demonstrating Compliance with CO Emissions Limits
" Chevron shall install, certify, calibrate, ¶ 29. The CO and 02 CEMS continue to be calibrated,
maintain, and operate all CO and 02 CEMS maintained, and operated according to the CD
required by ¶29 in accordance with the requirements.
provisions of 40 C.F.R. § 60.13 that are
applicable to CEMs and Part 60 Appendices A
and F, and the applicable performance
specification test of 40 C.F.R. Part 60
Appendix B.
With respect to 40 C.F.R. Part 60, Appendix F,
in lieu of the requirements of 40 C.F.R. Part
60, Appendix F § 5.1.1, 5.1.3 and 5.1.4,
conduct either a Relative Accuracy Audit
("RAA") or a Relative Accuracy Test Audit
("RATA") on each CEMS at least once every
three (3) years.
Conduct Cylinder Gas Audits ("CGA") each
calendar quarter during which a RAA or a
RATA is not performed.
Section V.E. - NSPS Applicability to FCCU Regenerators
Item to be Reported
CD
Reference Status
" By June 30, 2006, Chevron's FCCU Catalyst ¶ 31. Chevron Salt Lake City Refinery is monitoring and
Regenerator shall be an affected facility under reporting under and as required by NSPS Subparts A
NSPS Subpart J for S02, and Chevron shall and J for PM, CD, S02 and Opacity.
comply with the applicable requirements of
NSPS Subparts A and J for S02.
" By April 10, 2005, Chevron's FCCU Catalyst
Regenerator shall be an affected facility under
NSPS Subpart J for PM, Ca, and Opacity and
Chevron shall comply with the applicable
requirements of NSPS Subparts A and J for
PM.
Consent Decree, U.S. v. Chevron USA /nc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31, 2023
Attachment 1 Page 6 of 25
Section V.F. - NOx Emissions Reductions from Heaters and Boilers
CD
Item to be Reported Reference Status
Installation of NOx Control Technology
" Chevron shall select one or any combination of ¶ 32. Refer to the NOx Control Plan previously submitted per
the following "Qualifying Controls" to satisfy ¶ 35 of the CD requirements.
the requirements oflJ33 and ¶37:
a. SCRorSNCR;
b. Current Generation or Next Generation
Ultra-Low NOx Burners;
c. other technologies which Chevron
demonstrates to EPA's satisfaction will
reduce NOx emissions to 0.040 lbs. per
mmBTU or lower; or
d. permanent shutdown of a heater or boiler
with revocation of its operating permit.
" On or before June 30, 2011, Chevron shall use ¶ 33. Complete.
Qualifying Controls to reduce NOx emissions
from the heaters and boilers listed in Appendix
B by at least 2777 tons per year, so as to satisfy
the inequality in ¶33.
" Chevron shall submit a detailed NOx control ¶ 35. The Annual NOx Control Plan update was submitted on
plan to EPA and Plaintiff-Intervenors for review June 27,2023.
and comment by June 30, 2004, with annual
updates (covering the prior calendar year) on
June 30 of each year thereafter until termination
of the Consent Decree.
" By no later than June 30, 2011, heaters and ¶ 37. Complete.
boilers with Qualifying Controls shall represent
at least 30% of the total maximum heat input
capacity or, if less, the allowable heat input
capacity, as shown in Appendix B, of all
heaters and boilers greater than 40 mmBTU/hr
at the Salt Lake City Refinery.
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31, 2023
Attachment 1 Page 7 of 25
Beginning no later than 180 days after ¶ 38. Not applicable for this reporting period.
installing Qualifying Controls on and
commencing operation of a heater and boiler
that will be used to satisfy the requirements of
¶33, Chevron shall monitor the heaters or
boilers as follows:
a. For heaters and boilers with a capacity
greater than 150 mmBTU/hr (HHV), install
or continue to operate a NOx CEMS;
b. For heaters and boilers with a capacity
greater than 100 mmBTU/hr (HHV) but less
than or equal to 150 mmBTU/hr (HHV),
install or continue to operate a NOx CEMS,
or monitor NOx emissions with a predictive
emissions monitoring system ("PEMS")
developed and operated pursuant to the
requirements of Appendix C of this Consent
Decree;
c. For heaters and boilers with a capacity of
less than or equal to 100 mmBTU/hr
(HHV), conduct an initial performance test
and any periodic tests that may be required
by EPA or by the applicable State or local
permitting authority under other applicable
regulatory authority. The results of the
initial performance testing shall be reported
to EPA and the appropriate Plaintiff-
Intervenor.
Chevron shall use Method 7E or an EPA-
approved alternative test method to conduct
initial performance testing for NOx emissions
required by subparagraph 38.c.
Monitoring with a PEMS that is required by
¶38 shall be conducted in accordance with the
requirements of Appendix C.
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1, 2023 through December31, 2023
Attachment 1 Page 8 of 25
Beginning no later than 180 days after ¶ 39. No exceptions to report.
installing Qualifying Controls and commencing
operation of a heater or boiler that will be
monitored by use of a NOx CEMS that is
required by ¶38, Chevron shall install, certify,
calibrate, maintain, and operate all CEMS in
accordance with the provisions of 40 C.F.R. §
60.13 that are applicable to CEMs and Part 60
Appendices A and F, and the applicable
performance specification test of 40 C.F.R.
Part 60 Appendix B.
With respect to 40 C.F.R. Part 60, Appendix F,
in lieu of the requirements of 40 C.F.R. Part
60, Appendix F § 5.1.1, 5.1.3 and 5.1.4,
conduct either a Relative Accuracy Audit
çR.AA") or a Relative Accuracy Test Audit
("RATA") on each CEMS at least once every
three (3) years.
Conduct Cylinder Gas Audits ("CGA") each
calendar quarter during which a RAA or a
RATA is not performed.
Units with Qualifying Controls installed before
Date of Entry that are subject to ¶39 shall
comply with ¶39 by June 30, 2004.
" Chevron shall retain all records required to ¶ 41. Chevron Salt Lake City Refinery continues to retain
support its reporting requirements under this required records regarding NOx emission reductions
Section V.F. until termination of this Consent from heaters and boilers.
Decree.
" If Chevron transfers ownership of the Salt ¶ 42. Not applicable for this reporting period.
Lake City Refinery before achieving all of the
NOx reductions required by ¶33, Chevron shall
notify EPA and the appropriate Plaintiff-
Intervenor of that transfer and shall submit an
allocation to EPA and the appropriate Plaintiff-
lntervenor for the Salt Lake City Refinery's
share of NOx reduction requirements ofJ33
that will apply individually to the Salt Lake City
Refinery after such transfer. If Chevron
chooses, such allocation may be zero.
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31, 2023
Attachment 1 Page 9 of 25
Section V.G. - 502 Emissions Reductions from and NSPS Applicability to Chevron
Heaters and Boilers and Other Specified Equipment
CD I
Item to be Reported Reference Status
NSPS Applicability to Heaters and Boilers and Other Specified Equipment
Upon Date of Entry, all heaters and boilers ¶ 43.a., The Chevron Salt Lake City Refinery is monitoring and
shall be affected facilities, under NSPS Appendix D. reporting under and as required by NSPS Subparts J
Subpart J, and shall comply with the applicable and A.
requirements of NSPS Subparts A and J for
fuel gas combustion devices, except for those
heaters and boilers listed in Appendix D, which
shall be affected facilities and shall be subject
to and comply with the applicable
requirements of NSPS Subparts A and J for
fuel gas combustion devices by the dates
listed in Appendix D.
By date listed in Appendix E, all equipment ¶ 43.b. The Chevron Salt Lake City Refinery is monitoring and
listed in Appendix F shall be affected facilities, Appendix E reporting under and as required by NSPS Subparts J
under NSPS Subpart J, and shall be subject to and A.
and comply with the applicable requirements
of NSPS Subparts A and J for fuel gas
combustion devices.
Elimination I Reduction of Fuel Oil Burning
Effective on the Date of Entry, Chevron shall ¶ 44. Chevron Salt Lake City Refinery has continued not to
burn fuel oil in any combustion units except that
not burn Fuel Oil in any combustion unit at its Chevron may burn HF polymer at the Alkylation Plant,
Salt Lake City Refinery except that Chevron fuel oil during natural gas curtailment and training, or
may burn HF polymer at the Alkylation Plant, torch oil in FCCU regenerators to assist in starting,
fuel oil during Natural Gas Curtailment and restarting, hot standby, or to maintain heat balance.
training, or Torch Oil in FCCU regenerators to
assist in starting, restarting, hot standby, or to
maintain regenerator heat balance.
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1, 2023 through December31, 2023
Attachment 1 Page 10 of 25
Section V.1-I. - Sulfur Recovery Plants NSPS Applicability
CD
Item to be Reported Reference Status
Sulfur Pit Emissions
" Chevron shall continue to route or re-route all
___________
¶ 46.
______________________________________________
With the exceptions noted below, sulfur pit emissions
sulfur pit emissions so that they are eliminated, were controlled and monitored during the reporting
controlled, or included and monitored as part period.
of the SRP's emissions subject to the NSPS
SubpartJ limit for 502, orto applicable On November15 and 16, a steam system leak repair
emissions limits under Paragraph 48 by no caused the SRU 1 sulfur pit emissions to be routed to
later than the first turnaround of the applicable the atmosphere for approximately 16 hours and 34
Claus train that occurs on or after June 30, minutes. On November21, SRU 1 sulfur pit emissions
2004 or by December31, 2006 (whichever first were routed to the atmosphere for approximately 7
occurs). hours due to the plant shutting down unexpectedly.
In several instances, the SRU 1 pit vent inadvertently
opened due to a plugged pressure indicator line, but in
no event was it the result of positive pressure in the pit.
Because the pit did not experience positive pressure
during these events, Chevron believes this
instrumentation issue did not result in any associated
emissions from the sulfur pit. Each event, which
typically lasted a few minutes was remedied by
unplugging the clogged pressure indicator line. These
events occurred on the following dates: July 8, July 13,
August11, September13, September 24, November
18, and December 4 for a total of 9 hours 33 minutes.
In several instances, the SRU 2 pit vent inadvertently
opened due to a plugged pressure indicator line, but in
no event was it the result of positive pressure in the pit.
Because the pit did not experience positive pressure
during these events, Chevron believes this
instrumentation issue did not result in any associated
emissions from the sulfur pit. Each event, which
typically lasted a few minutes was remedied by
unplugging the clogged pressure indicator line. These
events occurred on the following dates: July 23, August
10, August26, September 10, October16, October22,
November 10, November 17, November21, and
December29_fora_total_of5 4_minutes. _____________________________________________ ____________
Compliance with NSPS Emissions Limits at the Salt Lake City SRP
" Chevron shall be an affected facility under ¶ 47.a. The Chevron Salt Lake City Refinery SRPs are affected
NSPS Subpart J and shall comply with all facilities under NSPS Subpart Ja and have complied
applicable provisions of NSPS Subpart A and J. with all applicable provisions of NSPS Subparts A and
Such SRP shall comply with 40 C.F.R. Ja.
§60.104(a)(2) at all times except during periods
of startup, shutdown, or malfunction of the SRP
and SRU, or during malfunction of the TGU.
" Effective on the respective date on which the ¶ 47.b. The Chevron Salt Lake City Refinery monitored all
SRP becomes an affected facility pursuant to emissions and reported all excess emissions as
Paragraph 47.a, Chevron shall monitor all required by NSPS Subpart Ja.
emissions and shall report excess emissions
from the SRP under and as required by NSPS
Subpart J.
" At all times, including periods of startup,
___________
¶ 47.c.
_____________________________________________
The Chevron Salt Lake City Refinery, to the extent
shutdown and malfunction, Chevron shall, to the practicable, has operated and maintained its SRP,
extent practicable, operate and maintain its SRU, TGU, and incinerator in accordance with good air
SRPs, SRUs, and TGUs and any supplemental pollution control practices as required in 40 C.F.R.
control devices, in accordance with good air 60.l 1(d).
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31, 2023
Attachment I Page 11 of 25
pollution control practices as required in 40
CF.R. §60.11(d).
Optimization _________________________________________________
" Chevron shall continue to maintain its Best
____________
¶ 50 b Chevron Salt Lake City Refinery continues to use its
Practices Team as a means to optimize Sulfur Best Practices Team (now called a Business
Recovery Plant operations. Improvement Network (BIN)) to optimize Sulfur
Recovery_Plant_operations. _____________________________________________ ____________
Good Operation and Maintenance
" Chevron shall comply with the PMO Plan at all ¶ 51.a. Chevron Salt Lake City Refinery complied with the PMO
times, including periods of Startup, Shutdown Plan at all times, including periods of Startup,
and Malfunction of its SRPs. Chevron's Shutdown, and Malfunction of its SRPs. Chevron Salt
changes to a PMO Plan related to minimizing Lake City Refinery is complying with the most recent
Acid Gas Flaring and/or S02 emissions shall PMO Plan submittal dated March 2g, 2023.
be summarized and reported to EPA and the
appropriate Plaintiff-Intervenor on an annual
basis. _____________ _____________________________________________________
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1, 2023 through December31, 2023
Attachment 1 Page 12 of 25
Section Vi. - Flaring Devices - NSPS Applicability
CD
Item to be Reported Reference Status
Good Air Pollution Control Practices _________________________________________________
On and after the Date of Entry, Chevron shall ¶ 53. The Chevron Salt Lake City Refinery at all times and to
at all times and to the extent practicable, the extent practicable, including during periods of
including during periods of Startup, Shutdown, Startup, Shutdown, and/or Malfunction, implements
and/or Malfunction, implement good air good air pollution control practices for minimizing
pollution control practices for minimizing emissions.
emissions consistent with 40 C.F.R. §60.11(d). _____________________________________________ ___________
Refinery Fuel Gases
" By no later than December 31,2006, Chevron ¶ 54.a. As previously reported, Chevron has certified
shall: compliance with and accepted NSPS J applicability for
1. Certify compliance with applicable NSPS 26 of 26 Flaring Devices in Appendix F.
requirements and accept NSPS Subpart J
applicability for at least 50% of the Flaring
Devices identified in Appendix F; and
2. Submit a schedule of
activities that Chevron will undertake to ensure
continuous compliance with applicable NSPS
requirements as soon as practicable at all
other Flaring Devices. _____________________________________________________
" Except for a maximum of three flares, Chevron
_____________
¶ 54.a. See response in ¶54.a. above.
shall certify compliance with applicable NSPS
Subpart J requirements and accept NSPS
Subpart J applicability for all those Flaring
Devices not previously addressed under
Paragraph 54.a.i. by December31, 2008.
For any remaining flares, Chevron shall certify
compliance with applicable NSPS Subpart J
requirements and accept NSPS Subpart J
applicability for those Flaring Devices by
December 31, 2010.
Section V.J. - Control of Acid Gas Flaring Incidents and Tail Gas Incidents
CD
Item to be Reported Reference Status
Investigating and Reporting _________________________________________________
By no later than forty-five (45) days following
_____________
¶ 57. No acid gas flaring incidents occurred during this
the end of an Acid Gas Flaring Incident reporting period.
occurring after the Date of Entry, Chevron
shall submit to EPA and the appropriate
Plaintiff-Intervenor a report that sets forth the
information in ¶57. _____________________________________________________
" To the extent that completion of the
______________
¶ 57.viii. The Chevron Salt Lake City Refinery has met the
implementation of corrective action(s), if any, requirements of ¶ 57.vUi during the reporting period.
is not finalized at the time of the submission of
the report required under this Paragraph, then,
by no later than thirty (30) days after
completion of the implementation of corrective
actions(s), Chevron shall submit a report
identifying the corrective action(s) taken and
the dates of commencement and completion of
implementation. ______________
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1, 2023 through December31, 2023
Attachment 1 Page 13 of 25
Corrective Action
In response to an AG Flaring Incident ¶ 58.a. The Chevron Salt Lake City Refinery has met the
occurring after the Date of Entry, Chevron requirements of ¶ 58.a. during the reporting period.
shall take, as expeditiously as practicable,
such interim and/or long-term corrective
actions, if any, as are consistent with good
engineering practice to minimize the likelihood
of a recurrence of the Root Cause and all
Tail Gas Incidents
For Tail Gas Incidents, Chevron shall follow
the same investigative, reporting, corrective
action and assessment of stipulated penalty
procedures as those outlined in Paragraphs 57
through 64 for Acid Gas Flaring Incidents.
Those procedures shall be applied to TGU
shutdown, bypasses of a TGU, and
unscheduled shutdowns of a Sulfur Recovery
Plant or other miscellaneous unscheduled
Sulfur Recovery Plant events which result in a
¶ 66.a. The Salt Lake Refinery had a Tail Gas Incident on
November 21, 2023. The Refinery has met the
requirements of ¶ 57 for Tail Gas Incidents during the
reporting period.
Section V.K. - Control of Hydrocarbon Flaring Incidents
Item to be Reported
CD
Reference Status
For Hydrocarbon Flaring Incidents occurring ¶ 67. The Refinery has met the requirements of ¶1 67 for
after the Date of Entry, Chevron shall follow Hydrocarbon Flaring Incidents during the reporting
the same investigative, reporting, and period.
corrective action procedures as those outline
in paragraphs 57 and 58 for Acid Gas Flaring
Incidents; provided however, that in lieu of
analyzing possible corrective actions under
Paragraph 57.v and taking interim and/or long-
term corrective action under Paragraph 58.a
for a Hydrocarbon Flaring Incident attributable
to the Startup or Shutdown of a unit that
Chevron has previously analyzed under this
Paragraph, Chevron may identify such prior
analysis when submitting the report required
under this Paragraph. _____________ _____________________________________________________
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31, 2023
Attachment 1 Page 14 of 25
Section VL. - Benzene Waste NESHAP Program Enhancements
CD
Item to be Reported Reference Status
Current Compliance Status ____________________________________________
By no later than 12/31/2005, the Salt Lake City
____________
¶ 68.c. The Chevron Salt Lake City Refinery continues to
Refinery shall comply with the compliance comply with 40 C.F.R. §61.342(e), herein referred to
option set forth at 40 C.F.R. §61.342(e), herein as the 6BQ compliance option.
referred to as the GBQ compliance option.
One-Time Review and Verification of Each Refinery's TAB _______________________________________________
" Based on EPA's review of the BWON ¶70.b. Not applicable for this reporting period.
Compliance Review and Verification Report(s),
EPA may select up to 20 additional waste
streams at each Refinery for sampling for
benzene concentration. Chevron will conduct
the required sampling and submit the results to
EPA within sixty (60) days of receipt of EPA's
request. ___________________________________________________
" Chevron shall submit an amended BWON
______________
¶ 7Db. Not applicable for this reporting period.
Compliance Review and Verification Report
within ninety (90) days following the date of the
completion of the required Phase Two
sampling, if Phase Two sampling is required
by EPA.
Implementation of Actions Necessary to Correct Non-Compliance or to Come Into Compliance
" Within 60 days after receiving any notification ¶ 71.d. Not applicable for this reporting period.
of disapproval or request for modification from
EPA, Chevron shall submit to EPA and the
appropriate Plaintiff-Intervenor a revised plan
that responds to all identified deficiencies. ___________________________________________________ ______________
Carbon Canisters _______________________________________________
" By no later than seven (7) days after the
_____________
¶ 72.d. Chevron Salt Lake City Refinery monitors for
installation of each secondary carbon canister, breakthrough between primary and secondary carbon
Chevron shall start to monitor for breakthrough canisters at the frequency specified in 40 C.F.R.
between the primary and secondary carbon §61.354(d) and monitors at the outlet of the second
canisters at times when there is actual flow to canister on a monthly basis and is in compliance with
the carbon canister, in accordance with the this requirement for this reporting period.
frequency specified in 40 C.F.R. §61.354(d),
and shall monitor the outlet of the secondary
canister on a monthly basis or at its design
replacement interval (whichever is less) to
verify the proper functioning of the system.
" Chevron shall replace the original primary ¶ 72.e. Chevron Salt Lake City Refinery continues to replace
carbon canisters (or route flow to an the original primary carbon canister immediately
appropriate alternative control device) when breakthrough is detected between the primary
immediately when breakthrough is detected and secondary canister and is in compliance with this
between the primary and secondary canister, requirement for this reporting period.
The original secondary carbon canister (or a
fresh carbon canister) will become the new
primary carbon canister and a fresh carbon
canister will become the secondary canister.
" Beginning no later than January 1,2004, ¶ 72.f. Not applicable for this reporting period.
Chevron shall monitor for breakthrough from
single carbon canisters each business day
(Monday through Friday, excluding legal
holidays) there is actual flow to the carbon
canister. ______________ ___________________________________________________
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1, 2023 through December31, 2023
Attachment 1 Page 15 of 25
" Chevron shall replace the single carbon ¶ 72.f. Not apphcable for this reporting period.
canister with a fresh carbon canister,
discontinue flow or route the stream to an
alternate, appropriate device immediately
when breakthrough is detected. ___________________________________________________
" Chevron shall maintain a supply of fresh
______________
¶ 72.g. Chevron Salt Lake City Refinery maintains a supply
carbon canisters at each Refinery at all times. of fresh carbon canisters at the Salt Lake City
Refinery. _____________________________________________
" Records for the requirements of Paragraph 72
_____________
¶ 72.h. Records for the requirements of ¶ 72 are maintained
shall be maintained in accordance with 40 in accordance with 40 C.F.R. §61.356(j)(10).
C.F.R. §61.356(j)(10). ____________________________________________ ____________
Annual Program ____________________________________________
" By not later than June 30, 2004, Chevron shall
____________
¶ 73 Chevron Salt Lake City Refinery continues to
establish an annual program of reviewing annually review process information for the Salt Lake
process information for each Refinery, City Refinery to ensure all new benzene waste
including but not limited to construction streams are included in the Refinery's waste stream
projects, to ensure that all new benzene waste inventory.
streams are included in each Refinery's waste
stream inventory. ___________________________________________________ ______________
Laboratory Audits ____________________________________________
" Chevron shall conduct audits of all laboratories
____________
¶74. Chevron Salt Lake City Refinery has a program in
that perform analyses of Chevron's Benzene ¶ 74.c. place to audit any laboratory used for analysis of
Waste NESHAP samples to ensure that proper benzene samples prior to such use.
analytical and quality assurance/quality control
procedures are followed. The Chevron Technology Center conducted an audit
" During the life of this Consent Decree, of Micro-Methods laboratory on February 16,2023.
Chevron shall conduct subsequent laboratory
audits, such that each laboratory is audited The Chevron Technology Center conducted an audit
every two (2) years. of Chemtech-Ford laboratory on March 15, 2023.
Benzene Spills ____________________________________________
" Beginning on Date of Entry, for each spill at
____________
¶ 75, Spills continued to be reviewed to determine
each Refinery, Chevron shall review such whether the benzene quantity must be included in
spills to determine if more than 10 pounds of the refinery TAB and in the uncontrolled benzene
benzene waste was generated in any 24 hour quantity calculation.
period. Chevron shall include the benzene
generated by such spills in the TAB and in the
uncontrolled benzene quantity calculation for
each Refinery, as and to the extent required
by Subpart FE.
Training _______________________________________________
" By no later than January 1, 2004, Chevron
_____________
¶ 76.a. All employees asked to pull benzene waste samples
shall develop and begin implementation of between July 1 and December31, 2023 have
annual (i.e., once each calendar year) training completed annual computer-based training covering
for all employees asked to draw benzene proper sampling techniques.
waste samples. ___________________________________________________
" By no later than December31, 2005, Chevron
______________
¶ 76.b. Chevron Salt Lake City Refinery continues to train all
shall complete an initial training program operators assigned to operate BWON control
regarding procedures for operating control devices.
devices for all operators assigned to this
equipment. During the semi-annual period from July Ito
December 31, 2023, operators new to BWON control
Comparable training shall also be provided to devices received on-the-job training prior to their
any persons who subsequently become assumption of this duty.
operators, prior to their assumption of this
duty. ___________________________________________________
" 'Refresher" training in these control device
______________
¶ 76.b. Not applicable for this reporting period.
procedures shall be performed on a three year
cycle. _____________ _______________________________________________
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1, 2023 through December31, 2023
Attachment 1 Page 16 of 25
As part of Chevron's training program, ¶ 76.c. All employees of contractors asked to pull benzene
Chevron must ensure that the employees of waste samples between July ito December31,
any contractors hired to perform the 2023, have been properly trained during this semi-
requirements of this Paragraph are properly annual reporting period.
trained to implement all applicable provisions
of this Consent Decree.
Waste Slop/Off-Spec Oil Management _______________________________________________
" At a mutually agreed upon time, Chevron shall
____________
¶ 77.a. Not applicable for this reporting period.
submit revised schematics that reflect the
Parties' agreements regarding the
characterization of these oil streams and the
appropriate control standards, if necessary. ___________________________________________________
" All waste management units handling non-
_____________
¶ 77.b. All waste management units handling non-exempt,
exempt, non-aqueous benzene wastes, as non-aqueous waste met the applicable control
defined in Subpart FF, shall meet the standards during this reporting period.
applicable control standards of Subpart FF. ___________________________________________________
" Chevron shall include all aqueous
_____________
¶ 77.c. All WMU handling benzene waste at the Chevron Salt
waste/slop/off-spec oil streams in the TAB. All Lake City Refinery either meets the control standards
WMU handling benzene waste shall either of Subpart FF or count toward the 660 limit.
meet the control standards of Subpart EF or
count toward the 6B0 limit. ___________________________________________________ _____________
End of Line Sampling (6 Mg Compliance Option) ___________________________________________
" If changes in processes, operations, or other
___________
¶ 78.b. Not applicable for this reporting period.
factors lead Chevron to conclude that its
approved EOL Plan may no longer provide an
accurate measure of the refinery's quarterly
"end of line" benzene determination and/or its
uncontrolled waste stream, Chevron shall
submit a revised EOL Plan to EPA and the
appropriate Plaintiff-Intervenor for EPA
approval.
" Chevron shall commence sampling under its
____________
¶ 78.c. The Chevron Salt Lake City Refinery has taken and
EOL Plan during the second calendar quarter analyzed at least three representative samples from
of 2006. each proposed sampling location consistent with the
approved EOL Plan. The Lime Pond is out of service
Chevron shall take, and have analyzed, at and not sampled, per the EOL.
least three representative samples from each
approved sampling location.
Chevron shall use the average of all samples
and approved flow calculations to make its
quarterly "end of the line" benzene
determination and in estimating a calendar
year value for each Refinery. _______________________________________________
" If the quarterly benzene determination
_____________
¶ 78.d. Not applicable for this reporting period.
exceeds 1.5 Mgfyr or if the estimated calendar
year value exceeds 6 Mg/yr, Chevron shall
prepare and provide to EPA and the
appropriate Plaintiff-lntervenor a written
summary and schedule of activities necessary
to minimize benzene wastes at such Refinery
so as to ensure that it complies with the 6 BQ
compliance option that calendar year. This
summary and schedule are due no later than
sixty (60) days after the close of such quarter. ______________ ___________________________________________________
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1, 2023 through December31, 2023
Attachment I Page 17 of 25
After at least 8 quarters of sampling under an ¶ The. Not applicable for this reporting period.
approved EOL Plan, Chevron may submit a
report to EPA and the appropriate Plaintiff-
Intervenor that places uncontrolled aqueous
waste streams at a Refinery into three
categories: (a) consistently <0.05 Mg/yr
benzene that may not warrant continued
sampling; (ii) consistently >0.05 Mg/yr
benzene but with low variability that may
warrant less frequent sampling; and (Hi) all
others that are consistently >0.05 Mg/yr
benzene. _______________________________________________ ____________
Miscellaneous Measures ____________________________________________
" By December 31, 2005, Chevron shall:
___________
¶ 80 Chevron Salt Lake City Refinery continues to count
all groundwater remediation wastes toward its
Manage all groundwater remediation wastes at ¶ BOa. Benzene Quantity as required by the BWON.
each of its Refineries in appropriate waste
management units under and as required by Chevron performed monthly visual inspections of
the Benzene Waste NESHAP controlled drains subject to Subpart FE during this
reporting period.
Conduct monthly visual inspections of all ¶ BOb.
Subpart FE water traps within the Refinery's
individual drain systems _______________________________________________ ____________
Projects/Investigations _______________________________________________
" Chevron may conduct a study of the
____________
¶ 81.b. Not applicable for this reporting period.
effectiveness of the benzene and VOC limits
under Paragraph 72.c. This study shall last no
less than two (2) years and must be performed
in accordance with the guidelines established
in Appendix J.
Chevron shall submit a schedule and
statement of work to EPA at least 90 days
prior to beginning such work.
Chevron shall submit a report to EPA and the
appropriate Plaintiff-Intervenor summarizing
the results of the study within ninety (90) days
of completion and may request a revision of
the limits under Paragraph 72.c based upon
the results of that study and any other relevant
information, including similar studies that may
be performed by or for others. _______________________________________________ ____________
Recordkeeping and Reporting Requirements for Section V.L ____________________________________________
" Chevron shall submit, as and to the extent ¶ 82. See below.
required, the following materials in the
progress report(s) for the quarter in which the
following identified activities occurred or are
required: ___________________________________________________
" BWON Compliance Review and Verification
_____________
¶ 82.a. Not applicable for this reporting period.
Report as amended, if necessary ( lOb). ____________________________________________
" Schematics of waste slop/off-spec oil
___________
¶ 82g. Not applicable for this reporting period.
movements, as revised, if necessary ( 77.a.) _______________________________________________
" EOL Plans and revised EOL Sampling Plans, if
____________
¶ 82.i. Not applicable for this reporting period.
necessary (3jJ 78.a and 78.b) ____________________________________________
" Plan to ensure that uncontrolled benzene does
___________
¶ 82j. Not applicable for this reporting period.
not equal or exceed 6 Mg/yr-or is
minimized-based on projected calendar year
uncontrolled benzene quantities as determined
through EOL sampling (f78.d) _____________ ___________________________________________________
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December31, 2023
Attachment 1 Page 16 of 25
" Results of the study of breakthrough" in ¶ 82k. Not applicable for this reporting period.
carbon canisters (J8I .b) _______________________________________________
" Identify all laboratory audits completed during
____________
¶ 82.1. Not applicable for this reporting period.
the preceding calendar year under ¶74.a,
including the laboratory audited during that
quarter, a description of the methods used in
the audit and the results of the audit, in the
progress report for the 4th quarter of that year.
" Describe the measure taken that calendar ¶ 82.m. Refer to ¶ 76 for general information regarding
quarter to comply with the training provisions BWON training activities during the semi-annual
ofJ76 period.
" Provide all quarterly "end of line" benzene
____________
¶ 82.n. See Attachment 2.
determinations and a summary of supporting
sampling results for the preceding calendar
year under ¶78 in the progress report for the
4th quarter of that year. The report shall
include a list of all waste streams sample and
the results of the benzene analysis for each
sample ___________________________________________________
" Describe the actions that Chevron is taking to
_____________
¶ 82.o. Not applicable for this reporting period.
identify and correct the source of the
potentially elevated benzene quantities and/or
to ensure continuing compliance with the
Benzene Waste NESHAP under and as
provided in ¶78. ____________ _______________________________________________
Section V.M. - Leak Detection and Repair ("LDAR") Program Enhancements
CD
Item to be Reported Reference Status
Written Refinery-Wide LDAR Program ____________________________________________
" Chevron shall update each such program as
___________
¶ 83. Not applicable for this reporting period.
may be necessary to ensure continuing No update this reporting period.
compliance. ___________________________________________________ _____________
Training _______________________________________________
" For personnel newly-assigned to LDAR
____________
¶ 84.a. All personnel newly assigned to WAR responsibilities
responsibilities, Chevron shall require LDAR receive training prior to beginning LDAR work.
training prior to each employee beginning such
work _______________________________________________
" For all personnel assigned LDAR
____________
¶ 84.b. All personnel assigned to LDAR responsibilities
responsibilities, Chevron shall provide and receive annual training.
require completion of annual LDAR training or
require its LDAR contractor to provide such
training (initial annual LDAR training for all
such personnel will be completed not later
than December 31,2004) ___________________________________________
" "Refresher' training in LDAR shall be
___________
¶ 84.c. Refresher training was performed in 2023.
performed on a three-year cycle. ___________________________________________________ _____________
LDAR Audits ________________________________________
" Chevron shall retain a contractor(s) to perform
___________
¶ 85.b. Not applicable for this reporting period.
a third-party audit of the Refinery's LDAR
program at least once every four years.
Consent Decree, U.S. v. Chevron USA Inc., case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1, 2023 through December31, 2023
Attachment 1 Page 19 of 25
Chevron shall conduct internal audits of each ¶ 85.c. Not applicable for this reporting period.
Refinery's LDAR program by sending
personnel familiar with the LDAR program and
its requirements from one or more of
Chevron's other Refineries or locations to audit
another Chevron Refinery. _______________________________________________
" Chevron shall complete an internal LDAR audit
____________
¶ 85.c. The Salt Lake Refinery completed a third-party
by no later than two years from the date of the internal audit in January 2024. The audit report and
completion of the third-party audits required in corrective actions will be submitted in the semiannual
Paragraphs 85.a and 85.b. report covering January 1,2024 through June 20,
2024. _____________________________________________
" Chevron shall perform an internal audit of each
____________
¶ 85.c. The Salt Lake Refinery completed a third-party
Refinery's LDAR program at least once every internal audit in January 2024. The audit report and
four years. Chevron may elect to retain third- corrective actions will be submitted in the semiannual
parties to undertake the internal audit, report covering January 1, 2024 through June 20,
provided that an LDAR audit at each Refinery 2024.
occurs every two (2) years. _______________________________________________ ____________
Implementation of Actions Necessary to Correct Non-Compliance
" If the results of any of the audits conducted ¶ 86. Not applicable for this reporting period.
pursuant to Paragraph 85 identify any areas of
non-compliance, Chevron shall implement, as
soon as practicable, all steps necessary to
correct the area(s) of non-compliance and to
prevent, to the extent practicable, a recurrence
of the cause of such non-compliance. ___________________________________________________
" Chevron shall retain the audit reports
_____________
¶1 86. Chevron Salt Lake City Refinery is retaining the audit
generated pursuant to Paragraph 85 and shall reports generated pursuant to ¶ 85 and maintains a
maintain a written record of the corrective written record of the corrective actions Chevron Salt
actions that Chevron takes in response to Lake City Refinery has taken in response to
deficiencies identified in any audits. deficiencies identified in any audits.
" In the quarterly report submitted pursuant to ¶186. Not applicable for this reporting period.
the provisions of Section IX of this Consent
Decree (Recordkeeping and Reporting) for the
first calendar quarter of each year, Chevron
shall submit to EPA and the appropriate
Plaintiff-Intervenor the audit reports and
corrective action records for audits performed
and actions taken during the previous year. ___________________________________________________ _____________
Internal Leak Definition for Valves and Pumps ___________________________________________
" By no later than June 30, 2005, Chevron shall
___________
¶ 87.a Chevron Salt Lake City Refinery is using an internal
utilize an internal leak definition of no greater leak definition of 500 ppm VOC for valves.
than 500 ppm VOCs for each Refinery's
valves, excluding pressure relief devices. ___________________________________________________
" By no later than June 30, 2005, Chevron shall
_____________
¶ 87.b Chevron Salt Lake City Refinery is using an internal
utilize an internal leak definition of no greater leak definition of 2000 ppm VOC for pumps.
than 2000 ppm for each Refinery's pumps. ___________________________________________________ ______________
Reporting, Recording, Tracking Repairing and Remonitoring Leaks of Valves and Pumps Based on the Internal
Leak Definitions ____________________________________________
" Chevron shall record, track, repair and re-
____________
¶ 88.b. All leaks in excess of the internal leak definitions of ¶J
monitor all leaks in excess of the internal leak 87 are recorded and tracked using the LDAR
definitions of Paragraph 87 at such time as Monitoring Database.
those definitions become applicable.
" Except as provided otherwise in this Section LDAR Monitoring Database records indicate that first
V.M, Chevron shall make a first attempt at attempts at repair, remonitoring, and delay of repair
repair within five (5) calendar days and either requirements have been satisfied.
complete repairs and re-monitor leaks or place
such component on the Refinery's delay of
repair list within thirty (30) days. _____________ _______________________________________________
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31, 2023
Attachment 1 Page 20 of 25
" By no later than March 31,2004, Chevron ¶ 89. LDAR Monitoring Database records indicate that
shall promptly make an "initial attempt" to Chevron Salt Lake City Refinery made an initial
repair any valve that has a reading greater attempt at repair and remonitored within 5 calendar
than 100 ppm of VOCs, excluding control days on all valves with a reading greater than 100
valves and components that LDAR personnel ppm.
are not authorized to repair.
" Chevron or its designated contractor shall re-
monitor, within five (5) calendar days, all
valves that LDAR personnel attempted to
repair under this Paragraph. _______________________________________________ _____________
LDAR Monitoring Frequency ____________________________________________
" When the lower internal leak definition for
____________
¶ 90.a. Chevron Salt Lake City Refinery is monitoring pumps
pumps becomes applicable under Paragraph at the internal leak definition monthly.
87.b and unless more frequent monitoring is
required by applicable federal, state and/or
local requirements, Chevron shall monitor
pumps at the internal leak definition on a
monthly basis. ___________________________________________________
" Chevron shall monitor valves at the internal
______________
¶ 90.b. Chevron Salt Lake City Refinery is monitoring light
leak definition on a quarterly basis (other than liquid and gas/vapor valves at the internal leak
difficult to monitor or unsafe to monitor valves), definition on a quarterly basis, with the exception of
those in process units in which the Sustainable Skip
Period Monitoring Program of Consent Decree
Appendix K has been implemented and those
classified as difficult to monitor. _________________________________________________
" Chevron may implement the Sustainable Skip
______________
¶ 90.c. Chevron Salt Lake City Refinery has implemented
Period Program set forth in Appendix K of the skip monitoring for the qualifying process units as set
Consent Decree at the Salt Lake City Refinery, forth in ¶ 90.c. and Appendix K.
" Chevron shall have the option of monitoring
____________
¶ 90.d. Chevron Salt Lake City Refinery has not used this
affected valves and pumps within process option for turnaround or shutdowns during this
unit(s) after completing a documented reporting period.
maintenance, startup, or shutdown activity
without having the results of the monitoring
count as a scheduled monitoring activity,
provided that Chevron monitors according to
the following schedule: ___________________________________________________
" For events involving 1000 or fewer valves and
______________
¶ go.d.i. Not applicable for this reporting period.
pumps, monitor within one (I) week of the
documented maintenance, start-up, or
shutdown activity; ___________________________________________________
" For events involving greater than 1000 but
______________
¶ go.d.ii. Not applicable for this reporting period.
fewer than 5000 valves and pumps, monitor
within two (2) weeks of the documented
maintenance, start-up, or shutdown activity;
" For events involving greater than 5000 pumps
_____________
¶ 90.d.Ui.
_______________________________________________
Not applicable for this reporting period.
and valves, monitor within four (4) weeks of
the documented maintenance, start-up, or
shutdown activity. _______________________________________________ _____________
Electronic Monitoring, Storing and Report of LDAR Data ____________________________________________
" Chevron has and will continue to maintain an ¶ 91.a. Chevron Salt Lake City Refinery continues to use the
electronic database for storing and reporting Sky Bridge program for storing and reporting LDAR
LDAR data. data.
" By no later than January 1, 2004, Chevron
_____________
¶ 91.b. The required documentation is maintained on file.
shall maintain operational specifications for the
data logger, software and monitoring
equipment it elects to use under this Consent
Decree. _______________________________________________
" Chevron shall use dataloggers and/or
_____________
¶ 91 .b. Chevron Salt Lake City Refinery is utilizing
electronic data collection devices during all dataloggers for LDAR monitoring.
LDAR monitoring. ______________ ___________________________________________________
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1, 2023 through December31, 2023
Attachment 1 Page 21 of 25
Chevron, or its designated contractor, shall ¶ 91.b. Chevron Salt Lake City Refinery uses its best efforts
use its/their best efforts to transfer, by the end to transfer the data from the electronic data logging
of the next business day electronic data from device to the database system by the end of the next
electronic data logging devices to the business day. In cases where data transfer and/or
electronic database of Paragraph 91.a. For all other issues hinder transfer to the database system,
monitoring events in which an electronic data and manual entry of monitoring data into the Sky
collection device is used, the collected Bridge database is necessary, records of such entries
monitoring data shall include a time stamp and are maintained.
identify the operator/monitoring technician and
the monitoring instrument used ___________________________________________________
" Chevron may use paper logs where necessary
_____________
¶1 91.l. Chevron Salt Lake City Refinery has utilized paper
or more feasible (e.g., small rounds, re- logs only for instances of retesting, small rounds, or
monitoring, or when data loggers are not when data logger/serial data transfer difficulties are
available or broken), and shall record, at a encountered.
minimum, the identity of the technician, the
date, monitoring starting and ending times,
and an identification of the monitoring
equipment.
" Chevron shall use its best efforts to transfer
_____________
¶1 gl.b. Chevron Salt Lake City Refinery uses its best efforts
any manually recorded monitoring data to the to transfer manually recorded data to the electronic
electronic database of Paragraph 91.a within database within the seven-day timeframe.
seven days of monitoring. _______________________________________________ ____________
QA/OC of LDAR Data ______________________________________
" By no later than March31, 2004, Chevron (or
__________
¶ 92. Chevron Salt Lake City Refinery continues to
a third party contractor retained by Chevron) maintain procedures for QAQC reviews of all data
shall have developed and begun implementing generated by LDAR monitoring technicians. The
procedures for quality assurance/quality monitoring data is reviewed for QA/QC on a quarterly
control ("QA/QC") reviews of all data basis and includes number of components monitored
generated by LDAR monitoring technicians. per technician, time between monitoring events, and
" Chevron shall ensure that monitoring data abnormal data patterns.
provided by its contractors is periodically
reviewed for QA/QC by the contractors.
" At least once per calendar quarter, Chevron
shall perform a QA/QC review of each
contractor's monitoring data which shall
include, but not be limited to: number of
components monitored per technician, time
between monitoring events and abnormal data
patterns. ___________________________________________________ _____________
WAR Personnel ___________________________________________
" Chevron shall continue to maintain a position
___________
¶ 93. Chevron Salt Lake City Refinery continues to
at each Refinery that is responsible for LDAR maintain this position.
management and that has the authority to
implement LDAR improvements. ___________________________________________ ___________
Adding New Valves and Pumps ___________________________________________
" By no later than June 30, 2004, Chevron shall
___________
¶ 94. Chevron Salt Lake City Refinery continues to
establish a tracking program for maintenance maintain a tracking program for maintenance records
records (e.g., a Management of Change to meet CD requirements.
program) to ensure that valves and pumps
added to the Refinery during maintenance and
construction are integrated into each
Refinery's LDAR program. _______________________________________________ ____________
Calibration/Calibration Drift Assessment _______________________________________________
" Chevron shall conduct all calibrations of LDAR
_____________
¶ 95.a. Chevron Salt Lake City Refinery utilizes methane as
monitoring equipment using methane as the the calibration gas in accordance with 40 C.F.R. Part
calibration gas, in accordance with 40 C.F.R. 60, EPA Reference Test Method 21.
Part 60, EPA Reference Test Method 21. _____________ _______________________________________________
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (N.D. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report. July 1,2023 through December 31, 2023
Attachment 1 Page 22 of 25
" By no later than January 1, 2004, Chevron ¶ 95.b. Chevron Salt Lake City Refinery continues to:
shall conduct calibration drift assessments of
LDAR monitoring equipment at the end of I Conduct calibration drift assessments of LDAR
each monitoring shift, at a minimum, monitoring equipment at the end of each
" Chevron shall conduct the calibration drift monitoring shift, at a minimum.
assessment using a calibration gas with a 2. Conduct the calibration drift assessment using a
concentration approximately equal to the calibration gas with a concentration approximately
applicable internal leak definition, equal to the applicable internal leak definition.
" If any calibration drift assessment after the 3. Re-monitor all components that were monitored
initial calibration shows a negative drift of more after the initial calibration if the drift assessment
than 10% from the previous calibration, shows a negative drift of more than 10% from the
Chevron shall re-monitor all valves that were initial calibration.
monitored since the last calibration that had a
reading greater than 100 ppm and shall re-
monitor all pumps that were monitored since
the last calibration that had a reading greater
than_500_ppm. _______________________________________________ ____________
Delay of Repair _______________________________________________
" By no later than January 1,2004, Chevron
____________
¶ 96.a. See below.
shall take the following actions for any
equipment that it intends and is allowed to
place on the "delay of repair" list under
applicable regulations: _______________________________________________
" Require sign-off by the unit supervisor within
____________
¶ 96.a.i. Chevron Salt Lake City Refinery continues to require
thirty (30) days of identifying that a piece of sign-off by unit supervisor for equipment qualifying for
equipment is leaking at a rate greater than the delayed repair.
applicable leak definition) that such equipment
qualifies for delayed repair under applicable
regulations, ___________________________________________________
" Include equipment that is place on the "delay
_____________
¶ 96.a.ii. Chevron Salt Lake City Refinery has included
of repair" list in Chevron's regular LDAR equipment on the "delay of repair" list in Chevron's
monitoring, regular LDAR monitoring.
" Use its best efforts to isolate and repair pumps
____________
¶ 96.a.iH. Chevron Salt Lake City Refinery continues to use
identified as leaking at a rate of 2000 ppm or best efforts to isolate and repair pumps identified as
greater leaking at a rate of 2000 ppm or greater.
" By no later than June 30, 2004, Chevron shall
____________
¶ 96.b. See below.
take the following actions for any equipment
that it intends and is allowed to place on the
"delay of repair" list under applicable
regulations: ___________________________________________________
" For valves, other than control valves and
_____________
¶ 96.b.i. Chevron Salt Lake City Refinery has met this
pressure relief valves, that qualify to be on the requirement for the current reporting period.
"delay of repair" list, use the "drill and tap"
method (or an equivalent), rather than place a
valve on the "delay of repair" list, if it is leaking
at a rate of 50,000 ppm or greater unless
Chevron can demonstrate that there is a safety
or major environmental concern by attempting
to repairing the leak in this manner. ___________________________________________________
" Chevron shall perform the first "drill and tap"
_____________
¶ 96.b.i. Chevron Salt Lake City Refinery has met this
(or equivalent repair method) within fifteen requirement for the current reporting period.
days and a second attempt (if necessary)
within thirty (30) days after the leak is
detected.
" After two unsuccessful attempts to repair a
______________
¶ 96.b.i.
___________________________________________________
Chevron Salt Lake City Refinery has met this
leaking valve through the drill and tap (or requirement for the current reporting period.
equivalent) method, Chevron may place the
leaking valve on its "delay of repair" list. _____________ _______________________________________________
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1, 2023 through December31, 2023
Attachment 1 Page 23 of 25
For valves, other than control valves and ¶ 96.b.ii. Chevron Salt Lake City Refinery has met this
pressure relief valves, that qualify to be on the requirement for the current reporting period.
"delay of repair" list, use the "drill and tap"
method (or an equivalent), rather than place a
valve on the "delay of repair" list, if it is leaking
at a rate of 10,000 ppm or greater unless
Chevron can demonstrate that there is a safety
or major environmental concern by attempting
to repairing the leak in this manner. _______________________________________________
" Chevron shall perform a first and (if necessary)
_____________
¶ 96.b.ii. Chevron Salt Lake City Refinery has met this
a second "drill and tap" (or equivalent repair requirement for the current reporting period.
method) as soon as practicable but not later
than 90 days after such leak was detected.
" If a new valve repair method not currently in Chevron Salt Lake City Refinery has not used any
use by the refining industry is planned to be ¶ 96.c. new valve repair methods not currently in use by the
used by Chevron, Chevron will advise EPA refining industry.
prior to implementing such a method or, if prior
notice is not practicable, as soon as
practicable after implementation. ___________________________________________________ ______________
Recordkeeping and Reporting Requirements for this Paragraph _______________________________________________
" Consistent with the requirements of Section IX ¶ 97.a. See below
(Recordkeeping and Reporting), Chevron shall
include the following information in the
progress report(s) for the quarter in which the
identified activity occurred or was required: _______________________________________________
" An identification of the individual at the
_____________
¶97.a.iv. Chevron Salt Lake City Refinery has identified an
Refinery responsible for LDAR performance as individual responsible for LDAR performance. Kyle
required by ¶93 Drach (ElSE Manager) is the responsible individual
listed_in_the_LDAR_program. _________________________________________________
" A copy of each Refinery's LDAR program
______________
¶ 97.a.vfli. Not applicable for this reporting period.
under ¶83 ___________________________________________________
" Chevron shall identify each audit that was
______________
The Salt Lake Refinery completed a third-party audit
conducted under Paragraph 85 in the previous ¶ 97.b. in January 2024. The audit report and corrective
calendar year, including an identification of the actions will be submitted in the semiannual report
auditors, a summary of the audit results and covering January I, 2024 through June 20, 2024.
the actions that Chevron took or intends to
take to correct identified deficiencies. ___________________________________________________
" In Each Report due under 40 C.F.R. § 63.654,
______________
¶97.c. The information outlined in ¶97.c.i - ¶97.c.ix. has
Chevron shall include the information on LDAR been included in all MACT semi-annual reports and
monitoring outlined in ¶97.c.i -1J97.c.ix.
____________
was submitted January 15, 2024.
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1, 2023 through December31, 2023
Attachment 1 Page 24 of 25
Section V.N. - Incorporation of Consent Decree Requirements into Federally
Enforceable Permits
Item to be Reported
CD
Reference Status
Obtaining Permit Limits for Consent Decree Emission Limits that Become Effective After Date of Entry
" Except as set forth below in Paragraph 9Gb, ¶ 99.a. On January 7,2015, the Chevron Salt Lake City
as soon as practicable, but in no event later Refinery submitted a permit application for the final
than the later of ninety (90) days after the FCCU NOx limits. All other necessary applications
effective date or establishment of any emission have been submitted to Utah Division of Air Quality to
limits and standards under Section V of this incorporate applicable emission limits and standards.
Consent Decree or fifteen (15) days after the
Date of Entry of this Consent Decree, Chevron
shall submit applications to the appropriate The Chevron Salt Lake City Refinery does not have a
Plaintiff-Intervenor to incorporate those final Title V permit. A Title V application has been
emission limits and standards in federally submitted (a reapplication was submitted on January
enforceable minor or major new source review 31, 2020) and the incorporation of any emission limits
permits or other permits (other than Title V shall be in accordance with the State of Utah's Title V
permits) which are federally enforceable. Upon rules.
issuance of such permit or in conjunction with
such permitting, Chevron shall file any
applications necessary to incorporate the
requirements of the permit into the Title V
permit of the refinery. _____________ ___________________________________________________
Section XVIII. - Termination
Item to be Reported
CD
Reference Status
certification of Completion: Paragraph 236 ____________________________________________
Chevron may certify completion of the following
_____________
¶ 236 The Chevron Salt Lake City Refinery submitted a
Consent Decree (CD) Sections: certification of completion on December 17, 2008
" Section V.A.: FCCU for CD Section VIII. As of the conclusion of this
" Sections V.8 - V.E.: FCCU reporting period, EPA has not yet responded.
" Sections V.F - V.G.: Heaters and Boilers
" Section VIII: Supplemental Environmental The Chevron Salt Lake City Refinery submitted a
Projects termination package on July 16,2020. As of the
conclusion of this reporting period, EPA has not
yet responded.
Consent Decree, U.S. v. Chevron USA Inc., Case No. C 03-04650 (ND. Cal.)
Salt Lake City Refinery Semi-Annual Progress Report, July 1,2023 through December 31, 2023
Attachment I Page 25 of 25
Attachment 2
Attachments Related to Benzene Waste NESHAP Program Enhancements
The following BWON information required to be submitted per Paragraph 82 is included in this
Attachment:
" Summary of all EOL benzene determinations and a summary of supporting sample results for the
period of 1/1/23 through 12/31/23 (82n.) including:
o A list of all waste streams sampled
o The results of the benzene analysis for each sample
Salt Lake Refinery
BWON LOt Sampling Results
2023
The following table summarizes the results generated pursuant the NSR Consent Decree between Chevron USA and the United States of America. Supporting documents are available at the facility.
1st Quarter 2ndQuarter ___________ 3rd Quarter 4th Quarter __________
U Description
Avg.
Concentration'
(ppml Flow (Mg)
Benzene
lMgl
Avg.
Concentration'
(ppm) Flow (Mg)
Bensene
(Mg)
Avg.
Concentration'
(ppm) Flow lMgl
Benzene
(Mg)
Avg.
Concentration'
(ppm) Flow (Mg)
Bensene
(Mg)
EOL Samples _______________ _________ __________ ______________ _________ _________ _______________ _________ _________
1 Sour water Stripper Effluent
_______________
0.005
__________
73,813
__________
0.00 0.0025 79,716 0.00 0.0025 82,925 0.00 0.0005 67,673 0.00
4 volatilization Calculation5 0.00 0.13 0.00 0.00 0.12 0.00 0.00 0.12 0.00 0.00 0.12
5 Ume Pond 0.001
__________
0 0.00 0.003 - 0.00 0.003 - 0.00 -- -- 0.00
6
Biological Contractors (controlled) to Clarifiers
(uncontrolled) 0.01 488,447 0.00 0.00 457,403 0.00 0.00 469.256 0.00 0.00 480,511 0.00
7 Spent Caustic Tank Effluent 2.35 19 0.00 1.40 12.58 0.00 3.45 18 0.00 1.86 27 0.00
8 LACTSump 0.148 35 0.00 0.012 54 0.00 0.103 SO 0.00 0.644 42 0.00
9
Miscellaneous Uncontrolled Waste Shipped
0ff-site From Waste Group Records 0.00 From Waste Group Records 0.00 From Waste Group Records 0.00 From Waste Group Records 0.00
10
Miscellaneous Uncontrolled Waste into
Process (Slop bA) or Collection Box (lOB) 4.55 454 0.00 0.86 454 0.00 2.31 363 0.00 1.05 2449 0.00
11 Uncontrolled Wastes to Collection Box4 0.00 __________ 0.09 0.00 0.00 0.50 0.00 0.00 0.00 0.00 0.00 0.00
12 Coker Drill Water 0.01 8,505 0.00 0.00 8.600 0.00 0.00 8,694 0.00 0.00 8,694 0.00
13 North Tank Field Remediation5 0.02 22,871 0.00 0.01 7.656 0.00 0.00 22,871 0.00 0.01 143,338 0.00
14 Desalter 7.0 45,08S 0.31 9.3 46,47a 0.43 17.3 44,414 0.77 21 43,726 0.90
Collection Box 2.2 529,428 1.16 2.0 495,276 0.99 1.9 504,011 0.97 2.3 518,647 1.19 - - EOL Total1 0.23 0.62 0,12 0.13
Notes
1. Average Concentration is the mean bencene concentration of at least three samples taken in accordance with BWON regulations. For line items that are a combination of multiple streams, the average
concentration is weighted by flow.
2. Total EOL Bencene Quantity for the refinery is the sum of EOL points 1,4,5,6,7,8,9, 10, 11, and 12.
3. This sample is not counted in the EOL total because it is represented in the collection box sample (EOL 11). It is sampled because it has the potential to add more than 0.05 Mg/yr to the GBQ.
4. Per the EPA letcer dated November 5,2007 concerning approval of the Salt Lake Refinery's EOL Plan, EOL 11 is calculated by subtracting the amount of benzene from the Desalter Effluent, EOL 14, from
the quantity of bencene measured at sample point EOL 11, the collection box.
5. volatilization Calculation - Henry's Law equilibrium calculation is performed on a quarterly basis. nenzene emissions are estimated at 6.3% of bencene flowing through the collection box.
1st QTR 2023
EOL # EOL sampte location
benzene
concentration I
benzene
concentration 2
benzene
concentration 3
avg benzene
concentration
Pt tag if
needed flow (gpm) quantity (Mg)
benzene
quantity notes:
Point lb SWS #2 effluent <0005 <0.005 <0.005 0.005 67FC122 151 73,813 0.0004
Point 4 volitalization calcualtion 0.1263
Point 5 lime pond 0.002 <0.001 <0.001 0.001 0.00 0 0.0000
The True pond was taken
out of service with the Alky
plant retrofit
Point 6 RBCISBC to outfall <0.005 <0.005 <0.005 0.005 09F1430 996 488.447 0.0024
Point? spent caustic effluent 2.61 1.11 3.34 2.35 19.03 0.0000
Point 8 LACT sump 0.05 0.30 0.09 0.15 35.11 0.0000
Point 9 uncontrolled waste off site 0.0000
Point 10 uncontrolled waste into process 1.82 9.96 1.86 4.55 453.60 0.0021
COSC pump out of service
in January
Point 11 uncontrolled Collection Box Wastes 0.0940
Collection box minus
desalter and accounting for
RTO downtime
Point 12 caller drill water <0.005 <0.005 0.092 0.005 8505.00 0.0000
Point 13 t4or1h Tank Field Remediation 0.016 0.017 0.019 0.017 0.00 22,871 0.0004
Point 14 desalter 5 10 6 7
21 FC 533
21FC539 91.96 45,085 0.3140
cotection box 2.45 2.03 2.13 2.19 09FC104 1079.86 529,428 1.1601 total 0.225
2nd QTR 2023
benzene benzene benzene avg benzene P1 tag if benzene
EOL # EOL sample location concentration I concentration 2 concentration 3 concentration needed flow (gpm) quantity (Mg) quantity notes:
Point lb SWS #2 effluent <0.005 <0.005 <0.005 0.003 67FC122 161 79.716 0.0004
volitalization
Poinl4 calcuattion 0.1169
The lime pond was
taken out of service with
Point 5 lime pond <0.005 <0.005 <0.005 0.003 0.00 0 0.0000 the Alky plant retrofit
Point 6 RBC/SBC to outfall <0.005 <0.005 <0.005 0.003 09F7430 923 457,403 0.0011
Point 7 spent caustic effluent 1.49 1.36 1.35 1.40 12.58 0.0000
Point 8 LACT sump 0.00 0.02 0.02 0.01 53.93 0.0000
uncontrolled waste off
Paint 9 site 0.0000
uncontrolled waste
Point 10 into process 2.03 0.31 0.25 0.86 453.60 0.0004 COSC dewatering
Collection box minus
Uncontrolled desalter and accounting
Point 11 Collection Box Wastes 0.499 far RIO downtime
Point 12 coker drill water <0.005 <0.005 <0.005 0.003 8599.50 0.0000
North Tank Field
Point 13 Remediatian 0.012 <0.005 0.005 0.009 0.00 7,656 0.0001
21FC533
Point 14 desalter 6 10 12 9 21FC539 93.76 46,478 0.4319
collection box 2.09 2,09 1.85 2.00 09FC104 999.09 495,276 0.9924 total 0.618
3rd QTR 2023
EOL It EOL sample location
benzene
concentration I
benzene
concentration 2
benzene
concentration 3
avg benzene
concentration
Fl tag if
needed flow (gpm) quantity (Mg)
benzene
quantity notes:
Point lb SWS #2 effluent <0.005 <0.005 <0.005 0.003 67FC122 166 62.925 0.0002
Point 4
volitalization
calcualtion 0.1189
Point 5 lime pond <0.005 <0.005 <0.005 0.003 0.00 0 0.0000
The lime pond was
taken out of service with
the Alky plant retrofit
Point 6 RBCISBC to outfall <0.005 <0.005 <0.005 0.003 09F1430 936 469.256 0.0012
Point? spent caustic effluent 3.90 2.82 3.62 3.45 17.88 0.0001
Point B LACT sump 0.11 0.11 0.10 0.10 50.13 0.0000
Point 9
uncontrolled waste off
site 0.0000
Point 10
uncontrolled waste
into process 2.41 2.30 2.21 2.31 362.88 0.0008 COSC dewatering
Point 11
Uncontrolled
Collection Box Wastes 0.0020
Collection box minus
desalter and accounting
for RTO downtime
Point 12 coker drill water <0.005 <0005 <0.005 0.003 8694.00 0.0000
Point 13
North Tank Field
Remediation - - - 0.000 0.00 22,671 0.0000
Point 14 desalter 16 24 13 17 21 P1536 342,429.29 44,414 0.7678
collection box 1.76 2.32 1.70 1.93 09FC104 1005.67 504,011 0.9728 total 0.123
4th QTR 2023
EOL # EOL sample location
benzene
concentration 1
benzene
concentration 2
benzene
concentration 3
avg benzene
concentration
P1 tag if
needed flow (gpm) quantity (Mg)
benzene quantity
(Mg) notes:
Point lb SWS#2 effluent <0.005 <0.005 <0.005 0.001 67FC122 135 67,673 0.0000
Point 4
volitalization
calcualtion 0.1 224
PointS lime pond 0.000 0.000 0.000 - 0.00 0 0.0000
The lime pond was taken out
of service with the Atky plant
retrofit
Point 6 RBCISBC to outfall <0.005 <0.005 <0.005 0.003 09FT430 936 480.511 0.0012
Point? spent caustic effluent 2.350 1.470 1.750 1.857 27.22 0.0001
PointS LACT sump 0.68 0.50 0.75 0.64 42.15 0.0000
PointS
uncontrolled waste off
site 0.0000
Point 10
uncontrolled waste
into process 0.55 0.18 2.42 1.05 2449,42 0.0026 COSC dewatering
Point 11
Uncontrolled
Collection Box Wastes 0.0020
Collection box minus desalter
and accounting for RTO
downtime
Point 12 coker drill waler <0.005 <0.005 <0.005 0.003 8694.00 0.0000
Point 13
North Tank Field
Remediation 0.011 0.011 0.012 0.011 0.00 143,336 0.0016
Point 14 desalter 21 21 20 21 21Fl536 0,00 43,726 0.9037
collection box 2.72 2.06 2.14 2.30 09FC104 1034.87 518,647 1.1911 Total 0.128