DAQ-2024-004861

^i\\.*"r"y.
Dean P. Anderson
Vice President
Tesoro Refining & Marketing Company LLC
Tesoro Refining &
Marketing Company LLC
A subsidiary of Marathon Petroleum Corpomtion
i
January 8,2024
Mr. Bryce Bird, Director
Atbr: Jeremy Marsigli i
Utah Division of Air Quality i
195 North 1950 West
P.O. Box 144820 IN PERSON SI'BMITTAL
Salt Lake city, uI 841144820
Fourth Ouarter VOC Monitorins Report
Title V Ooeratins Permit 3500008001 Condition II.B.4.a.3 &
Aoproval Order: DAOE-AI\10335007$18
40 CFR60 Subpart GGGa Q60.487a
40 CFR 63 Suboart CC t63.655
Attached is the fourth ryarter 2023 VOC monitoring report for the Tesoro Refining & Marketing Company
LLC's (TMRC) Salt Lake City Refinery and Tesoro Logistics Operations, LLC (TLO). The information
contained herein is for the reporting period October | , 2023, through Dece'mber 31, 2023. This report is
required semiannually; however, TMRC Salt Lake City Refinery and TLO report quarterly.
Pursuant to 40 CFR $60.487a(c)(1-3) this report includes monitoring information pertaining to leaking
components, process rurit shutdowns, components placed on Delay of Repair (DOR), and applicable
revisions to component inventories. This information is contained in the attached Tables 1.1 through 4.
During routine monitoring and auditing, 28 valves were discovered as not being in the LDAR program.
These components were immediately added to the fugitive monitoring program, tagged, monitored, and
found to not be leaking.
If you have any questions regarding this matter, please contact James Beardall 801-521-4914.
I certify under penalty of law that this document and all attachments were prepared under my direction or
supervision in accordance with a syste,ur designed to asswe that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Sincere,ly, tt*-o/-
Dean P. Anderson
Vice President
Tesoro Refining & Marketing Company LLC
B-2-10335
Mr. Bryce Bird, Director
Iamary 8,2024
Attachments: Table 1.1- Monitoring Information for Hydrocarbon Processing Division - North
Table 1.2- Monitoring Information for Hydrocarbon Processing Division - South
Table 1.3- Monitoring Information for Oil Movements Division
Table 2.1- Revisions to InitiaUSemiannual Report - HPDN
Table2.2- Revisions to InitiaVSemiannual Report - HPDS
Table23- Revisions to InitiaVSemiannual Report - OMD
Table 3.1- Dates of Process Unit Shutdowns IIPDN
Table 3.2- Dates of Process Unit Shutdowns IIPDS
Table 3.3- Dates of Process Unit Shutdowns OMD
Table 4- Components on Delay of Repair
cc: Mr. Scott H. Patefield, Branch Chief Via USPS
USEPARegion 8
Enforcement and Compliance Assurance Division
SENF-AT- Air and Toxics Enforcement Branch
1595 Wynkoop Sffeet
Denver, Colorado 80202-1129
Hydrocarbon Processing Division - North (HPDN)
Iable {.1: Monitoring lnformation - S40 CFR 60.487a(c)(2)
Requirement ALKY FCCU GHT POLY VRU
Oet Nov Dec Oct Nov Dec Oct Nov Dec Oct NoY Dec Oct Nov Dec
y'alves - No. of leaks detected per
i60.482- 7a(b)5 I 0 0 0 2 0 0 0 0 0 2 1 0 0
y'alves - No. of leaks not repaired
:er $60.482-7a(d)(1 )0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
rumps - No. of leaks detected per
i60.482-2a(b), (d)(a)(iXA) or (B)0 0 0 0 0 0 0 0 0 I 1 0 0 0 0
,umps - No. of leaks not repaired
rr $60.482-2a(c)(1) and (d)(6)0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
SGGa Compressorsr - No. of
eaks detected per $60.482-3a(f)
0 0 0
No Applicable
Compressors
No Appllcable
Compressors
No Applicable
Compressors
0 0 0
Sompressors - No. of leaks not
'epaired per $60.482-3a(gXl )
0 0 0 0 0 0
Tesoro Refining Marketing Company ttC Salt Lake City Refinery and Tesoro Logistics Operations LIC
Salt Lake City, UT
Subpart GGGa VOC Monitoring Report
Table 2.1: Revisions to lnitial / Semiannual Report - S40 CFR 60.487a(c)(4)
Requirement ALI(Y FCCU GHT POLY VRU
Valves2'7 subject to
$60.482-7a(a)
3159 1430 1048 810 1892
o Valves Added 6 6 0 I 0
. Valves Removed 1 0 0 0 0
Pumps3'7 subject to
$60.482-2a
35 1'l 5 4 't3
. PumpsAdded 0 0 0 0 0
. Pumps Removed 0 0 0 0 0
Compressons4 7 subject to
$60.482-3a
1 0 0 0 1
. Compressors Added 0 0 0 0 0
. Compr6sso6 Removed 0 0 0 0 0
able 3.1: Dates of Process Unit Shutdorrhs'- 540 CFR
Process Unit Dates of Shutdowns Scheduled (Y/N)
ALKY No Shutdowns N/A
FCCU No Shutdowns N/A
GHT 1227123 - 12128t23 N
POLY No Shutdowns N/A
VRU No Shutdowns N/A
Page 1 of4
Hydrocarbon Processing Division - South (HPDS)
Iable 1.2: Monitoring lnformation - $l40 CFR 60.a87a(c)(2)
Requirement BSU DDU FGR N2C UFU vNs
Oct Nov D6c Oct ilov Dec Oct Nov Dec Oct Nov tlec Oct Nov Erc Oct Nov D.c
Valves - No. of leaks detected
rer 560.482- 7a(b)0 1 0 1 0 0 0 0 0 0 0 0 0 11 0 0 ,|0
Valves - No. of leaks not
€paired per 560 .482-7 a(d\('l I 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Pumps - No. of leaks
detected per $60.482-2a(b),
(dX4Xii)(A) or (B)
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Pump.s . No. of leaks not
repaired per $60.482-2a(c)('1 )
and (d)(6)
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
GGGa Compressorsi - No. o1
leaks detected per 560.482-
3a(0 No Applicable
Compressors
0 0 0 0 0 0 0 0 0 0 0 0
No Applicable
CompressorsCompreasors . No. of leaks
not repaired per $60.482-
3a(sX1)
0 0 0 0 0 0 0 0 0 0 0 0
,Tesoro Refining Marketing Company LLC Salt Lake City Refinery and Tesoro Logistics Operations LLC
Salt Lake City, UT
Subpart GGGa VOG Monitoring Report
Shutdownss
Table 2.2: Revisions to lnitial / Semiannual Report - S40 CFR 60.487a(c)(a)
Requirement BSU DDU FGR N2C8 UFU VNS
Valves2'7 subject to
$60.482-7a(a)
1291 1431 275 1859 1919 747
. Valvs Added 0 0 0 7 0 16
. Valvss Remov6d 0 6 0 6 2 0
Pumpsl T subject to
S60.482-2a
11 5 2 11 12 't0
. PumpsAdded 0 0 0 0 0 0
. Pumps Removed 0 0 0 0 0 0
Compressors'' 7 subject to
S60.482-3a
0 3 3 1 3 0
. Compresso6Added 0 0 0 0 0 0
. Compressors Removed 0 0 0 0 0 0
Table 3.2: Dates of Process Unit Shutdowns" 540 CFR rs, qle^e,
Process Unit Dates of Shutdowns Scheduled (Y/N)
BSU 10t1123 - ',t2t3',\123
DDU 10128123 - 10130123 N
FGR No Shutdowns N/A
N2C No Shutdowns N/A
UFU No Shutdowns N/A
VNS No Shutdou,ns N/A
Page 2 ol 4
Oil Movements Division (OMD)
Iable 1.3: Monitoring lnformation - S40 CFR 60.487a(cX2)
Requirement BLR COGEN RTF SRU TKF TLR
Oct Nov Dec Oct Nov Dec Oct Nov D€c Oct Nov D.c Oct l{oY Dcc Oct Nov Dec
9alves - No. of leaks
lstectod per 560.482- 7a(b)0 1 0 0 0 0 0 0 0 0 0 2 0 0 5 0 0 0
y'alves - No. of leaks not
epaired per $60 .a82-7 a(d\(l )
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Pumps - No. of leaks
letected per $60.482-2a(b),
ldXaXiiXA) or (B)
0 0 0 No Applicable
Light Liquid
Pumps
0 0 0 0 0 0 0 0 0 0 0 0
Pumps - No. of leaks not
epaired per $60 .482-2a(c)(1 )
md (d)(6)
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
GGGa Gompreesorsr - No.
rf leaks detected per 560.,+82,
la(0
0 0 0 0 0 0
No Applicable
Compressors
No Applicable
Compressors
No Applicable
Compressors
No Applicable
CompressorsGompressors - No. of leaks
not repaired per 560.482-
3a(g)(1 )
0 0 0 0 0 0
Tpsoro Refining Marketing Company LLG Salt Lake City Refinery and Tesoro Logistics Operations LLC
Salt Lake Caty, UT
Subpart GGGa VOC Monitoring Report
Table 2.3: Revisions to lnitial / Semiannual Report - S40 CFR 60.487a(cXa)
Requirement BLR COGEN RTF SRU TKFt TLR
Valves2'7 subject to
S60.482-7a(a)
1256 189 821 525 3367 1 591
. ValvesAdded 2 3 0 0 65 38
. ValvesRemoved 1 0 0 0 18 0
Pumpsr'7 subject to
560.482-2a
11 0 I 2 72 28
. PumpsAddod 0 0 0 0 0 0
. PumpsRomovad 0 0 0 0 0 o
Compressorsa'' subject to
S60.482-3a
2 I 0 0 0 0
. CompressorsAdded 0 0 0 0 0 0
. Compressors Removed 0 0 0 0 0 0
Table 3.3: Dates of Process Unit Shutdowns" - S40 CFR
Process Unit Dates of Shutdowns Scheduled (YN)
BLR No Shutdowns N/A
E COGEN 't0129123 - vru23 N
W COGEN 12t8t23 - 12i14123 N
SRU No Shutdowns N/A
TLR No Shutdowrs N/A
Page 3 of 4
. Tesoro Refining Marketing Company ttC Salt take City Refinery and Tesoro Logistics Operations LLC
Salt Lake City, UT
Subpart GGGa VOC Monitoring Report
Iable 4: Gomponents Added to Delay of Repair (DOR)6 -s40 CFR 6o.a87a(cX2Xxi)
Process Unit Component Type LDAR Tag #Monitoring Date Date Placed on
DOR Date Repaired Date Removed from DOR
None
Page 4 of 4
, Teso;o Refining Marketing Company LLG Salt Lake Gity Refinery and Tesoro Logistics Operations LLC
Salt Lake City, UT
Subpart GGGa VOG Monitoring Report
Table Notes
1 - Existing compressors in ALKY, COGEN, DDU, and N2C units were constructed prior to November 7,2006. Tesoro has not conducted any
construction, modification, or reconstruction activities that would trigger GGGa applicability for these compressors; however due to the Utah
State lmplementation Plan Section lX, Part H.11(gxiv) all affected equipment is required to comply with the provisions of 60.590a to 60.593a
no later than January 1,2016. The Utah SIP was adopted by the Air Quality Board on December 2,2015.
2 - Excluding those valves designated for no detectable emissions under the provisions of $60.482-7a(f),
3 - Excluding those pumps designated for no detectable emissions under the provisions of $60.482-2a(e) and those pumps compllng with
$60.482-2a(f).
4 - Excluding those compressors designated for no detectable emissions under the provisions of $60.482-3a(i), S60.482-3a(h), and
60.593a(bXl ). Tesoro demonstrates compressors are in hydrogen service per 60.593a(b)(3)(i).
5 - Process unit shutdown means a work practice or operational procedure that stops production from a process unit or part of a process unit
during which it is technically feasible to clear process material from a process unit or part of a process unit consistent with safety constraints
and during which repairs can be accomplished. The following are not considered process unit shutdowns:
(a) An unscheduled work practice or operational procedure that stops production from a process unit or part of a process unit for less than 24 hours.
(b) An unscheduled work practice or operational procedure that would stop production from a process unit or part of a process unit for a shorter period
of time than would be required to clear the process unit or part of the proce$s unit of materials and start up the unit, and would result in greater
emissions than delay of repair of leaking components until the next scheduled process unit shutdown.
(c) The use of spare equipment and technically feasible bypassing of equipment without stopping production.
6 - For leaking components that remain in VOC seMce the delay of repair designation will be removed once two consecutive monthly
monitoring instrument readings are below the leak definition.
7 - Component changes involving CLVS, PRVs, Heavy Liquids, or a Process Unit switch do not show up as "added" or "removed'because
they have been in service; only the component class or Unit identifier has been changed.
8-During routine monitoring and auditing, 28 valves were discovered as not being in the LDAR program. These components were immediately
added to the fugitive monitoring program, tagged, monitored, and found to not be leaking.
. Terofo Refining Marketing Gompany LLG Salt Lake Gity Refinery and Tesoro Logistics Operations LLG
Salt Lake Gity, UT
Subpart GGGa VOC Monitoring Report
The following is a list of codes to describe component types in the report:
AVO - Audio, Visual, Olfactory
COMP - Compressor
CLVS - Closed Vent Vapor Recovery System
DTM - Difficult to Monitor
GV - Components in Gas Vapor service
LL - Components in Light Liquid SeMce
PMP - Pump
PRV - Pressure Relief Valve
UTM - Unsafe to Monitor
VLV - Valve
OOS - Out of SeMce or not in VOC service.
OEL - Open Ended Line
"Heayy Liquid" or "HL" denotes components in heavy liquid service.
"Light Liquid" or'LL" denotes components in light liquid service.
Yapof or "G\f denotes components in gas vapor service.
The following is a list of codes used to describe process units in the report:
ALKY - Alkylation Unit
BSU - Benzene Saturation Unit
BLR - Butane Loading Rack
BP - Boiler Plant
COGEN - Cogeneration Unit (East and West)
DDU - Distillate Desulfurization Unit
FCCU - Fluid Catalytic Cracking Unit
FGR- Flare Gas Recovery Unit
GHT - Gasoline Hydrotreater Unit
N2C - Crude Unit #2
POLY - Polydebutanizer Unit
RTF - Remote Tank Farm
SRU - Sulfur Recovery Unit
TKF - Tank Farm
TLR - Transport Loading Rack
UFU - Ultraformer
VNS - Virgin Naphtha Stabilizer
VRU - Vapor Recovery Unit
UTAH DEPARTMENT OF
ENVIHONMENTAL QUAUTY
JAN 'l 1 2024
DIVISION OF AIR QUALIW