DAQ-2024-007691

"/#henigwesitfih-333 W. Center Street . North Salt Lake Utah 84054 . 80L.296.77O0. www.bigwestoil.com
April9,2024
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RETURN RECETPT NO. 9589 0710 52701318 3711 00
r,lrt 2?;.:
Division of Air Quality
Utah Department of Environmental Quality
1e5 North 1950 Wesi - <__---r DtvlsloN OF AIR QUALITV
P.O. Box 144820
Salt Lake City, Utah 84114-4820
RE: EOL Sampling Plan Update for Approval
Reference DOJ Case Number: 90-5-2-1-07689
Civil Action Case Name: USA et al V. Big West Oil
Civil Action Case Number: 1:13-cv-0012I-BSJ
Pursuant to Paragraph 80.c, of the Consent Decree entered on November 14,2013, Big West Oil LLC is
submitting an update to the EOL Sampling Plan. Changes to routing of recovered slop oil from the Mini-
separator led to BWO to conclude that sampling location needed to be updated in the approved Plan to
provide an accurate estimation of the EOL benzene quantity. The attached revised EOL Sampling Plan is
being sent for your approval.
If you have any questions or require additional information, please contact me at [phone] or
Faithe. S chw artzengr aber@b i gwestoi l. com.
Sincerely,
L b*fugwarxrWMt
Faithe SchwartzengraS'er U U
Environmental Manager
Attachments
B-2-10122
CC: CERTIFIED MAIL RETIJRN RECEIPT NO. 9589 OTIO 5270I3I837II24
Director, Air Enforcement Division
Office of Civil Enforcement
U.S. Environmental Protection Agency
Mail Code 2241-A
I 200 Pennsylvania Avenue, N.W. Washington D.C. 20460-000 I
CERTIFIED MAIL RETURN RECEIPT NO. 9589 OIIO 52701318 3710 94
Director, Air Enforcement Division
Offrce of Civil Enforcement
Attn: Norrna Eichlin
c/o Mafix New World Eng. Inc.
26 Columbia Turnpike
Florham Park, NJ 07932-2213
CERTTFIED MAIL RETI'RN RECEIPT NO. 9589 OTIO 52701318 3711 17
Assistant Regional Administrator
Office ofEnforcement
Compliance and Environmental Justice
1595 Wynkoop Street
Denver, CO 80202-1129
Elecfronic copies to:
[e-mail]
kim.vounioo(deoa.sov
[e-mail]
BENZEI\TE WASTE OPERATIONS I\TESHAP
EI\TD-OF-LII\TE SAMPLING PLAN BIG WEST OIL, LLC
NORIE SALT LAKE, UTAII
LTTAH DEPARTMEiIT OF
ENURONMENIAL OI'AUTV
APR 23 Zr;Z4
DIVISION OF AIR QUALTTY
March 2512024
SIIBMITTED BY: Big West Oil LLC
333 W. Center Street
Norttr Salt Lake, UT
1.0
3.2
4.0
5-1
2.0
3.0
Table of Contents
J.J
3.4
4.1
4.2
4.3
5.0 HEALTH AIYD SAFETY CONSIDERATIONS
6.0 CONTINGENCY PLAN .................. 6-1
INTRODUCTION .....1.I
1.1 Compliance Option ............ 1-2
1-2 TAB Reportin9............... ....1-2
1.3 TAB Verification........... ....1-2
WASTEWATER COI\IVEYANCE AND TREATMENT SYSTEM... ......................2.1
SAMPLE LOCATIONS ...........3-t
3.1 End-of-Line Sampling..... ....................... 3-l
3.1.1 Crude API... ..........3-1
3.1.2 Mini Seperator................ ..........3-2
Waste Streams Contributing Greater than 0.05 Mg/yr Benzene...... ...................3-2
3.2.1 D-402 Desalter Effluent & Mudwashes................ ............3-2
3.2.2 Tank 33 Process Stripper Feed Tank Oil Layer.... ............3-3
3.2.3 Tank 43 Crude Oil Water Draw. ...................3-3
Non-Routine Samples ........3-3
Waste Stream Flow Estimates................ ....................3-4
6.1 Benzene Quantity Exceedance ...............6-1
Table of Contents (cont.)
6.2 Corrective Measures P1an............ ...........6-1
6.3 Third-Party Assistance... .....6-2
6.4 Sampling Plan Update ........6-2
List of Tables
1. Consent Decree End of Line Sampling Locations and Calculation Methodolory
2. Consent Decree POG Sampling Locations > 0.05 Mg/yr
List of Figures
1. Waste/Slop Oil Diagram2. Benzene Waste Operations NESHAP Sampling Form
1.0 INTRODUCTION
Big West Oil, LLC (BWO) operates a petroleum refinery located in North Salt Lake, Utah (Refinery). The Refinery
processes approximately 33,000 banels per day of crude oil, producing gasoline, diesel, and other intermediate and
refined products.
BWO entered into a Consent Decree (Consent Decree) with the U.S. Environmental Protection Agency (EPA) and the
State of Utah. The Consent Decree was entered by the court on November 14,2013. The Consent Decree requires
BWO to verify compliance with the Benzene Waste Operations NESHAP (BWON) regulation. In addition to
compliance with the federal BWON rule, there are several measures set forth in the Consent Decree Part V.L. In
accordance with Part V.L., Paragraph 80., of the Consent Decree, an end-of-line sampling plan (EOL Sampling Plan or
Plan) is required to be submitted to the EPA and Utah Department of Environmental Quality (UDEQ) for approval if
the total annual benzene (TAB) is greater than 1 megagram per year (Mgiyr) but less than l0 Mdyr. The Refinery
has reported a TAB quantity of less than 10 Mdyr, since the time that this plan was initially submitted in2014.
As set forth in Part V.L., Subparagraph 80.c. of the Consent Decree, the EOL Sampling Plan for the BWO Refinery
must include the proposed sampling locations and methods for flow calculations to be used in calculating projected
quarterly and annual benzene quantity under the terms of Part V.L., Paragraph 80. While not required to be a part of
the EOL Sampling Plan or calculations, the BWO Refinery is also required to perform sampling of all waste strearns
that contribute greater than 0.05 Mg/yr to the TAB at least annually.
This EOL Sampling Plan addresses the requirements of the Consent Decree, Part V.L., Paragraph 80. The objective of
this Plan is to provide procedures for obtaining benzene-containing waste samples that will be used to veri!
compliance with the BWON regulation and Consent Decree. The Plan includes procedures, quality assurance/quality
control (QA/QC) protocol, scheduling, and methodology to ensure accuracy of collected data. The EOL Sampling Plan
details the following:
. Sample locations and methods for flow calculations
. Sampling methodology
. Sample preservation and shipment
. QA/QC protocol
. Health and safety considerations
. Contingencyprocedures
Additionally, Part V.L., Paragraph 80 of the Consent Decree requires that the BWO Refinery implement sampling as
presented in this Plan during the first full calendar quarter after submittal (regardless of whether or not the EOL
Sampling Plan is approved at that time). The Consent Decree further specifies that BWO will continue to adhere to the
EOL Sampling Plan unless it is modified from the description below.
1.'I COMPLIANCE OPTION
The BWO Refinery is currently not required to comply with the compliance options outlined in Subpart FF (61.3a2 (c)
or (e)) because the Refinery's TAB has been estimated to be less than 10 Mg. If it is determined that the BWO
Refinery's TAB equals or exceeds 10 Mg, the Consent Decree requires that the Refinery act in accordance with the
compliance option promulgated under 40 CFR 61.342(e), otherwise known as the 6BQ (treat to atarget benzene
quantity) option. This compliance option allows the BWO Refinery to generate and manage up to 6 Mg per year of
uncontrolled benzene as waste.
1.2 TAB REPORTING
The BWO Refinery's 2022TAB quantity was estimated to be 3.41 Mg. The TAB was estimated based on refinery
knowledge, maintenance practices, and waste stream sampling.
1.3 TABVERIFICATION
At the end of each quafter, BWO calculates a quarterly and projected annual benzene quantity for the Refinery based
on sampling results and approved flow calculations. As stipulated by Part V.L., Paragraph 80 of the Consent Decree,
BWO will use the average of the three or more representative samples collected in each calendar quarter for each EOL
sample in these calculations. If the quarterly EOL benzene quantity calculations identiff an estimated TAB to be 10
Mg or greater the Contingency Plan outlined in Section 6 of this Plan will be followed.
2.0 WASTEWATER CONVEYANCE AND TREATMENT SYSTEM
Essentially, wastewater from the Crude and Reformer Units flows through a typical gravity drain sewer to the "Crude
APl." The Crude API also receives wastewater from tank water draws, Finished Fuels Rack, lab drains, Natural
Gasoline Truck Unloading, VRU drains, Sour Water Stripper drains, 35 dike, and the crude oil unloading facility. Oil
is skimmed from the Crude API and is pumped to Tank lB. Water from the Crude API is sent to the "Mini
Separator."
Wastewater from the MSCC and Alkylation Units first drains to the "MSCC API." Oil is skimmed from the MSCC
API and is routed to the Crude API.
The wastewater from the MSCC API which is mixed with the wastewater from the MIDW, Amine/SRU and HDS
Units is routed to the Mini Separator. Oily wastewater from the Sweet Crude Unloading facility and tank water drains
are also routed to the Mini Separator. Oil is skimmed from the Mini Separator and pumped to Crude API. Water from
the Mini Separator is directed to either Tank 9 or Tank 90. From these tanks, wastewater is pumped to a dissolved air
floatation unit (DAF). Sludge and float removed from the DAF are sent to Tank 1A, which are eventually centrifuged
and the solids are shipped off site as solid waste. Water from the DAF is sent to a final skimmer. Oil from the final
skimmer is pumped back to the Crude API while water flows to a weir box prior to discharge to a publicly owned
treatment works (POTW).
A simplified wastewater conveyance and treatment flow diagram is included as Figure 1.
3.0 SAMPLE LOCATIONS
The purpose of a sampling plan is to verify and track the BWO Refinery's estimated benzene quantity in order to veri$
compliance with the BWON regulation and Consent Decree. This is accomplished through the quarterly collection and
analysis of aqueous and organic samples at the EOL desigrrated locations. EOL sampling points have been identified
that either quantify significant benzene-containing waste streams or will verifu the absence of benzene in waste
handling systems that receive high volumes of waste.
The BWO Refinery is also required by the Consent Decree to annually sample waste point of generation (POG)
streams that contribute greater than 0.05 Mg/yr of benzene to the Refinery's TAB.
3.1 END-OF-LINESAMPLING
As part of the quarterly calculation of the benzene quantity required by the Consent Decree, the BWO Refinery will use
the EOL sampling data to ensure continuing compliance with Subpart FF and to minimize or eliminate fugitive
benzene waste emissions. Figure 1 shows the EOL locations on a Waste/Slop Oil Diagram. Table I summarizes the
sample points and the methods for flow determination for each stream contributing to the BWO Refinery's benzene
calculation. The EOL locations are as follows:
. Crude API hydrocarbon effluent
. Mini-Separator aqueous effluent
Three or more representative samples are required to be collected from each EOL location on a quarterly basis. The
average of the samples taken during the current quarter will be used to calculate the quarterly benzene quantity. The
projected annual benzene quantity will be calculated using the average ofthe current quarter, and prior quarter's results
(as applicable). The calculation methodology is included in Table 1.
3.1.1 GRUDE API
Wastewater from the Crude and Reformer Units flows through a gravity drain sewer to the "Crude API." The Crude
API also receives wastewater from Finished Fuels Rack, lab drains, Natural Gasoline Truck Unloading, VRU drains,
Sour Water Stripper drains, 35 dike, tank water draws and the crude oil unloading facility. Additionally, the Crude API
receives slop oil from the MSCC API, Mini Separator, and Effluent Skimmer. Oil is skimmed from the Crude API and
is pumped to Tank lB. Water from the Crude API is sent to the Mini Separator. The EOL hydrocarbon sample
location will be the skimmed hydrocarbon effluent that is sent to Tank 18, which verifies the organic benzene
concentration from the sources listed above.
3.1.2 MINISEPERATOR
Waste generated from the MSCC, and Alkylation Units drains to the "MSCC API." Oil is skimmed from the MSCC
API. Wastewater from the MSCC API is mixed with the wastewater from the MIDW, Amine/SRU and HDS Units
and is routed to the Mini Separator. Oil is skimmed from the Mini Separator and pumped to the Crude API. Water
from the Mini Separator is directed to either Tank 9 or Tank 90. The aqueous EOL sample will be collected on the
Mini Separator effluent aqueous stream that connects to Tanks 9 and 90.. This EOL sample will verify benzene
concentrations of the aqueous waste from the MSCC Sump, MIDW, Amine/SRU, and HDS Units, in addition to the
aqueous phase sent from the Crude API.
3.2 WASTE STREAMS CONTRIBUTING GREATER THAN O.O5 MG/YR BENZENE
Waste stream POGs that are determined to contribute greater than 0.05 Mdyr to the previous year's TAB are required
by the Consent Decree to be sampled on an annual basis. Because locations that may contribute greater than 0.05
Mg/yr may vary due to the number of tank water draws and other routine variations, the BWO Refinery will review
the TAB on an annual basis prior to the annual sampling event and make adjustments to this list of sampling locations
as appropriate.
Table 2 summarizes the sampling points and the method for flow rate determination for each stream contributing
greater than 0.05 Mdyr benzene to the TAB based upon the current TAB Report.
These POGs are as follows:
. D-402 Desalter Effluent & Mudwashes
. Tank 33 and 34 Process Stripper Feed Tank Oil Layer
. Tank 43 Crude Tank Water Draw
The basis of inclusion for each of these waste streams is provided in the following sections.
3.2.1 D4O2 DESALTER EFFLUENT & MUDWASHES
TheD-402 Desalter Effluent is located in the Crude Unit. The Desalter Effluent contributes approximately 2.03 Mdyr
of benzene to the TAB. This sample will be collected during normal desalter operation where the waste stream enters
the process sewer.
Desalter Mudwashes occur periodically when solids and debris accumulate during normal Desalter operation and
require removal. Desalter effluent is recycled to agitate and remove the solids, which are then drained to the sewer.
This operation occurs approximately once every 12 hours. The Desalter Mudwashes contribute approximately
0.52Mglyr of benzene to the TAB. The Desalter Mudwashes are listed as a sample location that is estimated to
contribute greater than 0.05 Mg of benzene to the TAB.
3.2.2 TANK 33 and 34 PROCESS STRIPPER FEED TANK OIL LAYER
Tank 33 and 34 contains sour water prior to being sent to the Sour Water Stripper. To reduce emissions, the tanks
contain a diesel blanket which requires periodic replacement. Approximately every three months the diesel blanket is
skimmed and replaced. This operation contributes 0.62 Mglyr of benzene to the TAB. A sample will be collected
from the skimmed diesel blanket following the skimming process and before disposal.
3.2.3 TANK 43 CRUDE OIL WATER DRAW
It is estimated that Tank 43 water draw contributes 0.05 Mdyr of benzene to the TAB. This sample will be collected
where the waste stream enters the process sewer. Both aqueous and organic phases (if available) will be analyzed for
benzene concentration.
A phase percent-weighted benzene content is required to be used to calculate the total benzene content ofthis waste
stream. The total benzene content of this stream will be based on the stream consisting of two percent hydrocarbon and
98 percent water. The flow rate will be based on operator interviews (how often the tank is de-watered). The total
benzene content and flow rate will be used to calculate the benzene contribution to the TAB from the Tank 43 water
draw.
3.3 NON.ROUTINESAMPLES
During the reporting period, the need may arise to collect non-routine samples for benzene determination. Samples
may be collected as the result of process requirements, tumaround events, hydrocarbon spills, tank cleaning,
remediation activities, or waste disposal. BWO Refinery personnel will determine if additional data are needed to
characterize a waste. Samples may also be collected to characterize a waste prior to the waste being managed or
treated in a waste management unit.
3.4 WASTE STREAM FLOW ESTIMATES
Waste stream flow rates and volumes for the sample locations will be baped on one or more of the following:
. Engineeringestimates
. Operations personnel interviews
. Flow meter readings
. Direct measurements
Process knowledge
Vessel size
Pumping cycles
Waste manifests
Tables 1 and 2 summarize the method used to determine the waste stream flow rates for each sample location.
4.0 SAMPLINGPROCEDURES
Because of the variety of waste streams and locations, different sampling techniques are required. Each location's
sampling technique is listed in Tables 1 and2. The recommended sampling technique will be via a condensing cooler
in accordance with United States Environmental Protection Agency (USEPA) Method 25D. Where sampling through a
condensing cooler is deemed impractical, samples will be collected in a manner that minimizes volatilization of organic
compounds consistent with Method 25D. This procedure is referred to as "grab sampling" in the Plan. The BWO
Refinery will use the following techniques for each sample group:
. Cooler Sampling - Cooler samples will be collected in a condensing cooler equivalent to USEPA Method 25D.
The sample cooler consists of a stainless-steel cooling coil. Prior to sample collection, ice will be placed in the
cooler to chill the sample to less than 10 degrees Celsius (C).
. Grab Sampling - Where cooler sampling is not practicable, samples will be collected in a manner that minimizes
the loss of volatile organic compounds (VOCs). Some grab samples will be collected in a disposable bailer or
larger clean disposable container. The sample will then be transferred from the larger container or bailer to
40 milliliter (mL) Volatile Organic Analysis (VOA) vials. Other grab samples may not require the use of a bailer
or larger container. In this case, the sample container may be directly filled from a sample tap or valve.
. Non-Routine Samples - Non-routine samples will be collected in the appropriate container for the required
analysis. The samples will also be collected using the appropriate method (e.g., cooler or grab).
At a minimum, three representative samples of each identified EOL waste stream, spaced at least one month apart, will
be collected during each quarterly sampling event.
Individuals tasked with the collection of samples described in this Plan will be trained to collect BWON samples.
Individuals will complete annual refresher training.
4.1 GOOLER SAMPLING PROTOGOL
A cooling coil and condensing cooler will be used as the sampling device for select sample locations listed in
Tables I and2. As part of the sampling protocol, field procedures detailed in Section 4.3 will be used. The following
routine will be adhered to when using this sampling methodology:
. Notify operations in advance of anticipated sampling dates and times.
. Prior to sampling, stagnant wastewater will be purged from the enclosed process pipe.
. Field parameters will be recorded.
. The sample lines and cooling coil will be purged with at least four volumes of the waste stream.
. The coil will be blocked in and the waste stream will be allowed to cool to less than 10 degrees C.
. Prior to sample collection, the temperature of the waste stream exiting the condensing cooler will be recorded.
. Waste stream samples will be labeled and placed on ice for shipment to a qualified laboratory.
. Sampling equipment will be decontaminated.
. Sample labels and chain-of-custody (COC) forms will be prepared as described in Section 5.3.
The temperature of the waste stream will be recorded at the time of sample collection to demonstrate that the sample
was cooled to less than 10 degrees C. If the temperature of the sample is greater than 10 degrees C, the collector will
document why the sample could not be cooled to l0 degrees C. Any other discrepancies or occurences that may
impact sample integrity will be noted on the field forms similar to that shown on Figure 2.
Samples will be collected in 40 mL VOA vials with Teflon-lined caps supplied by the laboratory. In accordance with
SW-846, VOA vials will contain either an appropriate quantity of hydrochloric acid, as required for aqueous samples,
or will be unpreserved for hydrocarbon samples.
4.1.1 EQUIPMENT DECONTAMINATION
The sampling cooler will be decontaminated before each use. The decontamination procedure for the condensing
cooler will include the following stages:
' Steam Cleaning - Each sample device will be loosely connected to a low-pressure steam source and purged with
steam for at least 5 minutes. Steam ensures the volatilization of most hydrocarbons that may be contained within
the sampling train.
' Detergent Wash - Each sampling device will be connected to a reservoir containing a biodegradable detergent
solution (e.g., Simple Green) and de-ionized or distilled water. This solution will be circulated through the
sampling device using a peristaltic pump, or similar pump, for at least 5 minutes.
' Detergent Rinse - The detergent reservoir will be replaced with a de-ionized or distilled water rinse. Water will be
allowed to circulate through the sampling train for 5 minutes to remove any detergent residue.
' Acetone Rinse - Acetone will be pumped through the sampling train to remove any trace organic compounds. The
acetone will be circulated through the sampling device for at least 5 minutes.
. Final Rinse - A final distilled/de-ionized water rinse will be performed. The final rinse will be allowed to circulate
through the sampling train for at least 5 minutes.
As a check on the effectiveness of the decontamination procedure, an equipment blank will be collected from the
sampling device for each cooler sampling event.
A sampling cooler and tubing may be dedicated to one sample location. If the sampling cooler and tubing is dedicated,
decontamination is not required. In some cases, hard pipe connectors may be used to facilitate the connection of the
sampling cooler to the sample port. All hard pipe connectors will be dedicated or decontaminated prior to reuse.
4.2 GRAB SAMPLING PROTOCOL
The BWO Refinery may use grab sampling techniques for certain locations during each quarterly reporting period. As
part of the sampling protocol, field procedures detailed in Section 4.3 will be used. Samples will be collected via
disposable bailers or other appropriate disposable sampling equipment. Each sample will be transferred to 40 mL VOA
vials. Sampling equipment will be disposed of following the completion of each sampling event.
Sample locations listed in Tables I and2 may not require the use of disposable sample equipment. If this is the case,
the waste stream sample will be collected directly in the sample container in a manner that minimizes the exposure of
the waste stream to the atmosphere. Stagnant waste will be drained from the piping leg or block valve before filling the
sample containers.
4.3 F!ELD PROCEDURES
As part of the sample collection process (Sections 4.1 and 4.2),field procedures and sample handling protocol have
been instituted to ensure QA/QC, and to allow accurate determinations of benzene concentrations. These field
procedures include field documentation forms that allow the sample collector to document critical information on the
sampling procedure and the stream condition. The field procedures and sampling protocol also stipulate quality control
procedures that allow sample results to be examined for accuracy and data reliability.
4.3.1 SAMPLE HANDLING
Following sample collection, all sample containers will be labeled with the following information:
. Sample identification
. Name of collector
. Date and time of collection
. Place of collection
. Analysis to be performed
. Requiredpreservatives
The 40 mL VOA vials will be placed in coolers on ice at the time of sampling. Samples will be sent to a
BWO-approved laboratory. Sample-analysis-request and COC forms will accompany each sample set submitted to the
laboratory.
4.3.2 FIELD DOCUMENTATION
Field documentation during both cooler and grab sampling will be recorded on a form similar to the form presented on
Figure 2. Information highlighted on the form will include a qualitative sample description, process equipment number
and name, drain size, and other stream properties such as temperature, pressure, and flow rate.
4.3.3 LABORATORYANALYSIS
Waste stream samples will be analyzed by an approved laboratory. In accordance with the BWON regulation, waste
stream samples may be analyzed by USEPA Methods 8020, 8021 , 8240, 8260, 602, or 624.
4.3.4 FIELD QA/QC PROTOCOL
The BWON regulation does not speciff QA/QC protocol. However, the BWO Refinery will establish a rudimentary
QA/QC protocol and will consist of the following:
. The collection of one blind duplicate sample quarter. Quality control samples will provide an evaluation of the
analysis and precision of sample collection.
, The collection of one field blank per quarter.
. The collection of equipment blanks if non-dedicated cooler sampling equipment is used.
. Request laboratory analysis per the CoC form.
4.3.5 LABORATORYPROTOCOL
The BWO contract laboratory will have adequate QA/QC procedures in place to ensure the validity of analytical
results. The Quality Assurance program will include management oversight of QA/QC procedures, internal accuracy
and precision checks, extemal audits, and written guidelines and procedures conceming sample handling,
recordkeeping, analytical methods, including calibration and maintenance of analytical equipment. Each laboratory's
Quality Control program will detail procedures used to evaluate the accuracy and precision of analytical results.
5.0 HEALTH AND SAFETY GONSIDERATIONS
Sample collection personnel must meet all current safety requirements of the BWO Refinery. The BWO Refinery
requires site-specific health and safety training before individuals are allowed on site. This training is conducted
initially and requires refresher training to be completed as needed.
Individuals collecting samples must complete a safe work permit with the appropriate unit operators prior to sample
collection. The collector must inform the operators of the sampler's task, locations of sampling points, and sampling
procedures. The collector must not commence work until an authorized unit operator gives permission and a work
permit has been issued as required.
Hazards associated with sample collection can include exposure to benzene, rotating equipment, noise, eye and face
exposure to hazardous chemicals, high temperatures and pressures, and exposure to hydrogen sulfide. Appropriate
personal protective equipment (PPE), as required by the BWO Refinery safety procedures, will be used. Examples of
PPE and personal exposure monitors to be worn by the sampler include:
. Fire-retardantclothing
. Hard hat with safety goggles attached
' Safety glasses
. Protective gloves
. Personal HzS monitor
. Hearing protection
. Appropriate footwear
6.0 CONTINGENCY PLAN
The BWO Refinery is required to use the quarterly EOL sampling results to ensure continqing compliance with
Subpart FF and to minimize or eliminate fugitive benzene waste emissions. The sample results and flow estimates
will be used to calculate aquarterly portion ofthe benzene quantity and aprojected calendaryearbenzene quantity.
6.1 BENZENE QUANTITY EXCEEDANCE
In the event that sample analysis indicates a higher benzene concentration than anticipated during normal operations,
the following steps will be taken to ensure that the affected waste stream is properly represented in the quarterly
benzene calculation.
Review the sampling location to determine if the sample is representative of the waste stream.
Review sample handling to assess the potential for contamination.
Review the laboratory QA/QC to identify lab errors or results outside of method/analytical limits.
Review other factors that may influence the validity of the measured concentration.
Analyze one or more additional samples to establish a representative benzene concentration. If more than one
sample is analyzed, the average benzene concentration will be used.
6.2 CORRECTIVE MEASURES PLAN
If the quarterly EOL benzene quantity exceeds 2.5 Mg, BWO shall submit an explanation of the excess benzene waste
generated to the EPA and UDEQ. BWO is required to submit this explanation within 30 days after the end of the
quarter which resulted in an EOL benzene quantity greater than 2.5 Mg.
If the projected calendar year TAB calculation meets or exceeds 10 Mg, then the BWO Refinery will submit a
Corrective Measures Plan to the EPA and UDEQ. The Corrective Measures Plan will be submitted no later than
30 days after the end ofthe calendar quarter that resulted in a projection ofthe calendar year TAB that equals or
exceed 10 Mg. The Corrective Measures Plan will include (in accordance with Part V.L., Subparagraph 80.d.(2), of
the Consent Decree):
. Identification of the actions that BWO will take to ensure that the calendar year TAB for the Refinery does not
equal or exceed 10 Mg.
. The schedule of actions that will be taken to ensure that BWO complies with the BWON regulation for the
calendar year.
6.3 THIRD.PARTYASSISTANCE
If BWO cannot take appropriate actions to ensure that the Refinery maintains a TAB less than 10 Mg/yr, then BWO
shall retain a third-party contractor to undertake a comprehensive TAB study and compliance review ("Third-Party
TAB Study"). Within 60 days of submitting the plan required in subparagraph 80.d.(2), BWO shall submit a proposal
to EPA and UDEQ identiffing the following for the Third-Parry TAB Study:
. Contractor
Scope of work
Schedule
Unless EPA disapproves or requests modification of the proposal, BWO will authorize the contractor to commence
work within 30 days of the receipt of the proposal. No later than 30 days after receipt of the results of the Third-Parfy
TAB Study, BWO will submit the results to EPA and UDEQ, and initiate informal discussions regarding the results.
No later than 120 days after receipt of the results of the Third-Parfy TAB Study, or such other time as EPA and BWO
may agree, BWO will submit a plan to EPA and UDEQ identifying the compliance strategy and schedule that BWO
will implement to ensure the Refinery either does not have a TAB greater than 10 Mg for that calendar year or will
comply with the 6BQ compliance option as soon as practicable. The EPA and UDEQ will review and approve the plan
in accordaxce with Part V.L., Subparagraph 75.c, of the Consent Decree. BWO will certify compliance in accordance
with Part V.L., Subparagraph 75.d, of the Consent Decree.
6.4 SAMPL!NG PLAN UPDATE
If changes in process, operations, or other factors lead the BWO Refinery to conclude that the sampling plan no longer
provides an accurate basis for estimating the EOL benzene quantity, then the Refinery will submit a Revised Sampling
Plan for EPA and UDEQ approval. Process changes include, but are not limited to, new construction, process
elimination, and process alterations. When new construction occurs, benzene-containing waste streams will be
evaluated for BWON applicability. If a process is eliminated, then those waste streams affected by the elimination will
no longer be sampled. If a process is altered, then those waste streams affected by the alteration will be evaluated for
sampling applicability with respect to the Consent Decree. Additionally, the sample frequency for non-routine sample
locations may be altered.
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FIGURE 2
BENZENE WASTE OPERATIONS NESHAP
SAMPLING FORM
UTAH DEPARTMENT OF
ENVIRONMENTAL QUAUry
DIViSION OF AIR OUALITV
Name of Sampler:
Equipment Type:
Process Unit:
Time:
Sample lD.
Grab Sample:_Cooler Sample_
Grab Sample Collected From: (Circle one)
Valve Sample Point Open Channel
Equipment Number:
Equipment Name:
Stream Fluid:
_ Hydrocarbon
Water
Other (describe):
(Check one, complete hydrocarbon name if applicable)
_Hydrocarbon Water Mix Hydrocarbon name:
Other:
(Check as many as apply)
_ Turnaround
_ Planned Maintenance
_ Unplanned Maintenance
_ Unit Upset
_ Unit Down Time
Cooler Samole: (Fill in as applicable)
Cooler:
Purge Volume:
Sample Collection Time:_
Tubing Connection Point lEiElebn!valve Sample Tap drain line
Stream Frequencv:
_ Continuous
_ lntermittent
_ x Per Shift
_ Daily
_ Weekly
_ Monthly Other (describe):
Sample Collected <'l0C:_Yes No
Comments: (Note sample color, OilMater Percentage and any observations - if a duplicate note the duplicate sample lD)
Stream Properties: (Fill in as
Gallons per minute (operating)
Gallons per minute (turnaround)
Gallons total (drainage)
_ Operating Temperature (F)
_ Turnaround Temp (F)
_ Operating Pressure (psig)
_ Turnaround Pressure (psig)
_ Specific Gravity
Use Back of Form lf Necessary - lnitial and Date Back if Used.