DAQ-2024-007693

333 W. Center Street . North Salt Lake Utah 84054 ' 801.296.7700' wwwbigwestoil.com
March 14,2024
CERTIFIED MAIL
RETURN RECETPT NO. 9s89 0710 5270 0120 7651 45
Bryce Bird, Director
Division of Air Quality
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144820
Salt Lake City, Utah 84114-4820
RE: MACT Subpart CC Periodic Report -2d H;aJf 2023 (July
I,TAH DEPARTMENT OF
ENVIRONMENTAL CITJALITY
:i./lll L
., /l
DIVISION OF AIH QUALITY
15, 2023 - January 14, 2024)
Dear Mr. Bird,
In compliance with the reporting requirements of 40 CFR 63 Subpart CC, the following constitutes the
periodic report required by $63.655 applicable to Big West Oil, LLC (BWO). This submittal covers the
period from July 15,2023 -January 14,2024.
Should you have any questions regarding the contents of this report, please contact Faithe Schwartzengraber
at [phone].y*ffi
CC:CERTIFIED MAIL
RETURN RECETPT NO. 9589 07t0 5270 0120 7651 38
USEPA Region VIII
Mail Code 8ENF-AT
1595 Wynkoop Street
Denver, CO 80202-1129
Jeremy Marsigli, UDAQ - Electronic Copy
Sin
L
Fai
En,
th-e Schwartzengraber
vironmental Manager
B-2-10122
Mr. Bryce Bird
Department of Environmental Quality
March 14,2024
Page2ofll
$63.655(e) MACT CC Reporting Requirements
L Wastewater Provisions - $63.655(a)
In accordance with $63.655(a), BWO complies with the amual reporting requirements in $6 I .357(c). The total
annual benzene (TAB) quantity from facility waste is less than 10 Mg/yr., but equal to or greater than I Mg/yr. A
separate updated TAB report is submitted separately each year. There are no additional reporting requirements for
wastewater per 40 CFR 63.655(a) of Subpart CC.
II. Gasoline Loading Rack Provisions - S63.655(b)
In accordance with $63.428(h), excess emissions for the BWO bulk gasoline distribution are submitted in separate
Quarterly CEM Excess Emissions Report. The quarterly reports were submitted on October 27 , 2023, and January
29,2024. There were no deviations from temperature operating parameters ($63.428(h)(1)) during the reporting
period. BWO complies with the reporting requirements for equipment leak required in $63.428(h)(a) in a separate
semiannual report for equipment leaks. The 2'd Semiannual2023 MACT CC - Equipment Leaks Report was
submitted on January 15,2024.
BWO utilizes a terminal automation system to prevent gasoline cargo tanks that do not have valid cargo tank vapor
tightness documentation from loading (e.g., via a card lock-out system). In compliance with the periodic reporting
requirements of $63.655(b), the table directly below summarizes exceptions to the vapor tightness provision for bulk
gasoline distribution at the faciliry.
Eaeh Loadingxlo
Vapor Tightnesq,'
Ddcumentatiori {11,
:, .,,Repeat Loading of a
nonvapor-tight cargo Tank
t3I
tzl
Date Cqrgo
Tank I.D.$63.428(eXl)r $63.428(hX2)
tr ..,,
$63.42E(hX.3),1
NA Q.,lot Applicable)NA None to Report None to Report None to Report
ll) Each loading ofa gasoline cargo tankforwhichyapor tightness docunentalion had not becn previou.sly ohloined by lhcfacilily.
l2l lictch instonce of a nonvaporlight gasoline cargt tank loading ot the fdctltty in which the owner or operator failed to toke sleps to assure that
such cargo tank would not be reloadeel at the facility before yapor lighlness documentotion for thal cargo tonk was ohlqined.
[3) l')ach raloatling ofa nonvaporlight gasoline corgo tank ot thefacility before vapor tightncss docwnentation for that cargo tank is obtained by the
facility in accordancc with $63.J22(c)(2).
BWO does not include a loading rack in an emissions average therefore no additional reporting requirements for
gasoline loading racks are required under subpart CC.
III. Marine Tank Vessel Loading Operation Standards - $63.655(c)
Not applicable. BWO does not have a marine vessel loading operation regulated under 40 CFR 63 Subpart Y and
Subpart CC.
IV. Equipment Leaks Standards - S63.655(d)
BWO is an existing source subject to the provisions of 563.648 for equipment leaks and has elected to comply with
the provisions 40 CFR 60 Subpart VVa in lieu of complying with Subpart H. In accordance with the reporting
requirements of $63.655(dX1), BWO submits a separate semiannual report for equipment leaks subject to 40 CFR
63 Subpart CC. The 2nd Semiannu al 2023 MACT CC - Equipment Leaks Report was submitted on January 1 5,
2024.
Mr. Bryce Bird
Department of Environmental Quality
March 14,2024
Page3ofll
V. Storage Vessels Periodic Report - $63.655(g)(1)
The following section contains applicable storage vessel information required in Periodic Reports. BWO is an
existing source complying with the Storage Vessel Provisions of $63.646 or $63.660. Therefore, in accordance with
63.655(9)(l), information related to gaskets, slotted membranes, and sleeve seals is not required for storage vessels
that are part of existing sources and that are complying with $63.646.
a. 863.646 Internal tr'loatine Roof [F'R) Storaee Vessel Inspections - Q63.655(eX2)
i. IF'R Annual Ta I Hatch) I with Failures Detected -XrXA)
Ul Pttsuotfl with 563.655(9(2)(i)(A)(1), alailure is delned 6 dfly time invhich the inlernqlJl@ting r@J k not resthtg il the wr/ace olthe liquid inside lhe slorage
vewl @td is tol resing on lhe leg ilpporls; or lhere is liquid on lhe luting r@l: or lhe seal is del@hed frm ,he htenal Jl@tiLg r@l; q ,here qe holes, teqs, or
olher opening$ in rhe seal or valJqbric: or thre ue visible gaps between lhe seal md lhe wall oJthe sluage vessel.
l2l Ilqt ertension is utili*d in dccordonce with the provisions ol {63.120 (4(q olilbNfl G, lhe.erilry "Exlewion Uilired' is Nred in the Natne olRepqir Column.
The rext Peridic Report will ideilijy lhe vewl; include lhe d@mentatiu specifed it $63.120(a)(4) of ilbryrt G: and deeribe the date the stqage vesel |/6
emptied wilh the dale @td mlure of lhe repair of repqir.
In addition, details for any failures identified during the annual inspections, as applicable, can be found in
Attachment B - $63.655(gX2XiXA). See Attachment C for extension requests, if applicable -
$63.6ss(g)(2XD(AX3).
lll Pursmnt with 563.655(d@(r(B)(l), Afailure is defined as any time in which the intemal floating roof has defects; or the primary seal has
holes, tears, or other openings in the seol or the seal fabric; or the secondary seal (ifone has been installed) has holes, lears, or other openings
in the seal or the sealfobric; or,for a starage yessel that is part ofa nN source, the gaskets no longer close ofthe liquid surfacefrom the
atmosphere; or, for a storage yessel that is part ofa new source, lhe slolled membrane has mole than a l0 percenl open arm.
b. 863.646 External Floatine Roof Storaee Vessel Inspections - Q63.655(eX3)
i. EFR Primarv Seal Ga with Detected Failures -
Mr. Bryce Bird
Department of Environmental Quality
March 14,2024
Page4of11
c.
|lPrinarySeal Gapl;ailuresoccurwhenlheaccumulatedareaofgapsbet||eenlhevesselwallandlhcprimoryseal exceed2I2square
centimeters per meter ofve,ssel drameter and the wtdth of any portion of any gap shall exceeds 3.8 I centimeters (!6j. I 20(b) (j)) and where a
metallic shoe seal is in use, and one end ofthe metallic shoe does not extend into lhe stored liquid and the other end exlend a minimum verlical
distance of6l centimelers above lhe stored liquid sudace; orwhere otherfailures such as holes, tears, or other openings in lhe shoe, seal
fabric, or seal envelope were delected.
12) Ifan extension is uttlizcd in accordance with the provisions of$63.120(b)(7)(ir) or (b)(8) ofSubpart G, the entry "Lxtension Utilized' is
noted in the Nalure of llepair Oolumn. The next Periodic llepofl will idenlify the vessel; include lhe documenlalion spectfied in $63.120(Q(a) of
subparl G: and describe the dale lhe slorage vessel was emptiedwilh lhe dale and nature ofthe repair ofrepair.
lr. l-F R Secondary Seal Ga ions with Detected Failures -X
MACT CC - Group I Storrge Vessel complying with $63.646 - EFR Secondary Seal Inspections
t,: t, ;.,..,,,.; , in which a FdilU&-:icietected in,:tne-;loiiE0_L$liipmgnt* $63t655(gx3xi)
: : i :-' ''' -::-
. :...::::.:.::
Date ol..-'|,:::l::
Inspbctioii: :,.:rl
None to Report NA NA NA NA
11) Secondary Seal Gap Failttes occur when lhe accumilated area of gaps betueen lhe yessel wall antl lhe secondory seal exceeLl 2 L2 square
cenlimelers per meler ofvessel diameter and the width ofany portion ofany gap exceeds L27 centimetcrs (f63. I 20(b)(1)) an<l when secondary
seals are fitund thal do not completely cover the space between the roof edge or are found to hqve hole,s tears, or olher openings in the seal of
sea I fa b ric 6t 6 3. I 2 0 (b) (6) ).
l2l Ifon extension is utilized in accordance with the provisions ofS63.l20(b)(7)(ii) or (b)(8) ofSubporr G, the entry "Extension lltilized' is
noled in lhe Nature of llepair Column. T'he next l'eriodic Reporl will ident tJi the vessel; include the documenlalion spectfed in {63. I 20(a) (l) ttf
subpart G; and describe the dale the storage vessel was emptied wilh lhe dote and nature ofthe repair of repair.
In addition, the Seal Gap Calculations can be found in Attachment B, if applicable, when failures were
detected during the Seal Gap Measurements - $63.655(g)(3Xi)(A). See Attachment C for extension requests,
if applicable - $63.6ss(g)(3XD(B).
863.660 Floatine Roof (EFR & IFR) Inspections (initial fill. annual tank-top. internal) with
Detected F'ailures - Q63.655(eX2Xii) & (3Xii)
Date of
Inspeqlionr;
::::.......::..
. rDesafiptioil of ilie .,,,:'=
i.i,.r., " Irailuretrl ::. :l *t"*".rt$,frilrl,lllll.l..ll
None to Report NA NA NA NA
l\) Pursuont with 563.1063(4(l)(, through (t1.1(l)(iv) ofsubpart WW, inspectionfailures are defned as stored licluid on theflooting rorf; holes
or lears in lhe primary or secondary seal (if one is present): Jloqting roof deck, deck fittings, or rin seols that are not rttnctioning as desigVed;
failure to complywilh the operationql requiraments in {63.1063(b); Gaps o;[more than 0.i2 centimeters (t,t inch) benveen any dcckftting
gaskel, seal, or wiper and any sulface lhal il is inlended lo seal.
l2l Ifan extension is trtilized in accordance with the provisions of!63.1063(e)(2) ofsubpart l4/\ty', lhe enrry "lixtension Utilized' is notcd in the
Nature ofRepoir Ooltrntn. The next Periodic lleport will include the documenration spectfed in f63.1063(c)(2) ofsubpart WW.
In addition, a copy of the inspection record required by $63.1065(b)of subpart WW is included in
Attachment B, if applicable, when an inspection failure occurs in accordance with the reporting provision in
$63.6ss(gX2)(ii)(B) or (3XiiXA).
S63.655(gX5) - Storage Vessels complying by installing a Closed Vent System and Control Device
BWO does not utilize closed vent system and control devices for compliance with the Group 1 Storage
Vessel provisions of S63.646 or $63.660. Therefore, periodic reporting requirements for this provision are
not applicable for the current reporting period.
d.
Mr. Bryce Bird
Department of Environmental Quality
March 14,2024
Page5of11
VI. Miscellaneous Process Vents Periodic Report- $63.655(9)(6)
For miscellaneous process vents (MPVs) for which continuous parameter monitors are required by this subpart,
periods of excess emissions are identified in this section of the Periodic Report and are used to determine compliance
with the emission standards.
For purposes of 963.655(gX6XiiD, the following table provides the required information for which a Group I MPV
stream was detected in the bypass line or diverted from the required control device either directly to the atmosphere
or to a control device that does not comply with the requirements in $63.643(a).
For purposes of $63.655(9)(6), the following table provides the required information for Group I MPV excess
emissions events, if applicable, for the current reporting period. BWO complies with $63.6a3(a) for Group I MPVs
and voluntarily routes most Group 2 MPVs to a flare meeting the requirements of $$63.670 and 63.671. BWO
reports flare information as specified in $63.655(gX1l) in this periodic report. Therefore, excess emissions reporting
for a number of the operating parameters in Table l0 of subpart CC for Group 1 Miscellaneous Process Vents do not
apply to the facility.
qre within the ronge establislrcLl in thc N(lS or opcrdling pernil, q sldtentent lo thi.s effect can be recoreled in.stead oJ the doily ctveraga.
l2l An operating doy when all pilol flomes rl a Jlorc ara ohsent.
when nroniloring datd were nol colleclecl shctll be inclutlad in tha l'ariodic l?aport.
[4] For data cornpression systems under paragraph (h)(s)(iii) ofthis section, an operating day when the monitor operated for less than 75 percent ofthe operating
hours or a day when less than l8 rnonitoring values were recorded. When a period ofexcess emission is caused by insufficient monitoring data, as described
ir $63.655(g)(6)(i)(C) or (D), the duration ofthe period when monitoring data were not collected shall be included in the Periodic Report.
VII. Periodic Report of Performance Tests for Determination of Compliance - $63.655(9)(7)
No performance tests were conducted during the reporting period that demonstrated a change from Group 2 to
Group 1 nor for demonstrating compliance of a new emission point subject to Subpart CC.
MACT CC - Group 1 Miscelldgpgyi,Pine9ii,yVert * Diverted Flow from Required Controls - $63.651@)$){iil,.
Dete Time E3timate of the
Volume of Gas
Organic IIAP
Concentration
in the Gas
None to Reporl NA NA NA NA NA
': r,,,.,$-ACT.,CC-Group I MPV
Excess Emissions Periodic Reporting
$63.6ss(g)(6)(i) & {ii} ,,
l
For rniscellmeous process vents. excess emissions are
reported for &e operating parameters specifie{.g!1t!9.,!Q
ofsubpart CC unless other site-specific paramete(s) have
been approved by the operating pemit authority.
. I Ctii$lirlheApprbpdateBox
L
o-
TEOG!sE
.oo
q2o
tr6
6H(irl
a!e
d;
6A
.L ....
Oe
>r i:
L6
OG
iar-
>=
o6
91 tr
a..:
oq
G.-
L
O?
6i
L4
eo
B&
i.:9A
go
9:
E.=
d96i
,L
'c
o=G !.
. >;...a:a:t.a:..
H'o
.ou
oSza
. 1..,,, '
,a
Group l MPV
Identilication
Start
DBte
Strrt
Time
End
Date
End
I tme
$63.655
GX6)
(rXA)
$63.655
GXO)
(t(B)
$63.655
(gXo)
(iXC)
$63.655
(eX6)
(ixD)
$63.655
(e)(6)
(ii)
$63.655
(gX!)
(ii) '
$61.6ll
(o(s)
(1r.,
${3.0++
(cxz)'
None to Report NA NA NA NA NA NA NA NA NA NA NA NA
Mr. Bryce Bird
Department of Environmental Quality
March 14,2024
Page6ofll
VIII. Heat Exchange Systems Periodic Report - $63.655(9)(9)
The periodic reporting requirements for Heat Exchange Systems are summarized in the table below. Monitoring
is conducted monthly in accordance with $63.654(c)( )(i), therefore, the total strippable hydrocarbon leak
action level is 6.2 ppmv.
S63.655(gXeXi)
The quqbCr. .qd!'iat,!itharg9. sy!1.9ms.af.i[ar'plarit site strbject to lie monitoring requirelng.t$,.11 'r63.6s4 | l
S63.6ss(gXeXii)
mqnSmulntliffirriit\ iiilitensitth€-tlantsitefouridtobeleakinzau"t. e*no$n8,.,,;.,,,.',,:,.:;..) 2nerind I
$6t.6ss(g)(e)(iii)
Monitorintirridtiiilill*H$f]*i]lN,il0!4 stripfable hydrocarbon concentration was determile_il:lp- i:e.\y.ll..:iy,::at
grester thdx'ih;t ,tiildllil{strd.efr"itionr speiilied in $63.654(c{Q @eak Definitioa;6;2,ppm. . } I
Date the Lek wrs
firet identified Monitoring Location
Total Strippable
Hydrocarbon Concentration
(ppmv)
if applicable, the Date ttd Leak
Source identified . .
9/26/2023 Alkv Cooling Tower 5724.0 NA
9/26/2023 MSCC Cooline Tower 8.1 NA
10/20/2023 MSCC Cooline Tower 77 NA
12t28t2023 Alky Coolins Tower ,1 NA
$6r;aia-s(sxe,(iv)For Hert Exchanger System Leaks that were Repaired during the Reporting Period (includirg delayed repairs)
Date the Leak was
first identified
Monitoring Location
I.D associated with the Repaired Leak
Total Strippable Hydrocarbon
Concentration {ppmi) during
re.monitoring to verify repair
the remonitoring date (i.e.,
the effective date of repair)
9/26/2023 Alky Cooling Tower 5.9 9t28/2023
912612023 MSCC Cooling Tower 33 9/28/2023
9t2712023 Alky Cooling Tower 5.9 9t28t2023
9/2',7 /2023 MSCC Cooling Tower JJ 9t28t2023
10t20t2023 MSCC Cooling Tower 01 1012612023
12t28t2023 Alky Cooling Tower t.7 I /3/2024
$63.6ss(eX9Xv)
For each delayed repair, identification of the monitoring location associated
with the leak for which repair is delayed, the date when the delay of repair
began, the date,th6 repair is expected to be completed (ifthe leak is not
repaired driring the reporting period), the rotal strippable hydrocarbon
concentration ind dite bfeach monitoring event conducted on the delayed
repair during the ieporting period, and an estimate of the potential strippable
hydrocarbon emiisions over the reporting period associated with the delayed
repair.
Not applicable, there were no
delayed repairs for the
reporting period.
IX. Quarterly Reports for Emission Points - $63.655(gX8)
Not applicable. BWO does not utilize the emissions averaging provisions of S63.652.
X. Pressure Relief Devices (PRD) Periodic Reporting - $63.655(gX10)
a. Q63.655(eX10Xi) - PRD with instrument readines of 500 ppm or sreater (Q63.648(iXl))
For pressure relief devices in organic HAP gas or vapor seryice, pursuant to 563.6480)( I ), BWO is required to
comply only with paragraphs $63.6480X I ) and $63.6480)(2) for the pilot discharge vents and bonnet vents that
are not routed through a closed vent system to a control device, back into the process or to the fuel gas system
as described in $63.6a8fi)(4). BWO did not detect any instrument reading of 500 ppm or greater during the
reporting period.
Mr. Bryce Bird
Department of Environmental Quality
March 14,2024
PageTofll
b. Q63.655(exl0xii) - PRD Monitorine Demonstratine Compliance (863.648(iX2))
BWO is compliant with the applicable operating requirements in $63.648O(1) and pressure relief requirements
in $63.6a8O(2) for potential leaks from pilot-operated PRD discharge vents and balanced bellows PRD bonnet
vents. Routine instrument monitoring is conducted as specified in $60.485@) or $63.180(c), and as applicable,
no later than 5 calendar days after the pressure relief device returns to organic HAP gas or vapor service
following a pressure release to demonstrate that the pressure relief device is operating with no detectable
emissions (instrument reading of less than 500 ppm).
c. $63.655(sxlOxiii) - Pilot-Operated PRDs Atmos. Release of 72 lbs. of VOC/day or ereater
For pilot-operated pressure relief devices in organic HAP service, there were no pressure releases to atmosphere
through the pilot vent that equals or exceeds 72 pounds ofVOC per day during the reporting period. The
duration of pressure releases through the pilot vent with the estimate of the mass quantity of each organic HAP
released will be reported if the limit is exceeded.
d. 863.655(eX10xiv) - PRDs Subiect to S63.648(iX3) - Release reportine w/ RCA & CA
The primary release valves for all applicable pilot-operated and balanced bellows PRDs at the facility are routed
through a closed vent system to a control device, back into the process, or to the fuel gas system as described in
$63.648CX4). Therefore, BWO is not required to comply with the new provisions for pressure release
management as provided in paragraph $63.6480X3).
XI. Periodic Report for Flares subject to $63.670 - $63.655(9)(11)
a. Q63.655(gXl lXi) - Each 15-minute block during which there was at least one minute when regulated
material is routed to a flare and no pilot flame is present.
Mr. Bryce Bird
Department of Environmental Quality
March 14,2024
Page8ofll
b. Q63.655(eX1lxii) - Visible emission records as specified in Baraeraph (iX9XiiXC) of this section for each
period of 2 consecutive hours durins which visible emissions exceeded a total of 5 minutes.
c. Q63.655(eX1lYiii) The lS-minute block neriods for which the annlicable operatins limits
specifred in S63.670(d) throueh (0 are not met.
i. Flare Tip Velocity Limit Exceedances - Q63.670(d)
For purposes of $63.655(gxl lxiii), the following table provides periods when the Flare Tip Velocity
operating limits in $63.670(d) were not met.
ii. Combustion Zone Operatins Limit Exceedances - S63.670(e)
For purposes of the periodic reporting requirements of $63.655(gxl lxiii), the following table provides
periods when the combustion zone operating limits in $63.670(e) were not met.
Estimrted Vislble Emlsshur > 5
DIin for eh perlod of 2
consecutive hours
9/712023 13:00-15:00
121412023 9:58-10:07
Estimated Vfuill,cEolsslons > 5
Miu for eaeh p€rtod of2
cons€cutivo hours
1012612023 ll:00 1012612023 I I :00-13 :00
Erceedanee lhte & Tlue
(15 Mtr Blocks)
7110D023 14:45
7110/2023 15:00
7/1012023 15:15 9D5/2023 17:15
711412023 13:45
7D012023 17:45
Mr. Bryce Bird
Department of Environmental Quality
March 14,2024
Page9ofll
iii. Perimeter Air Assist Flare Dilution - 863.670(e)
BWO does not have a flare with perimeter air assist so the dilution operating limits and reporting
provisions in $63.670(f) do not apply to the facility.
d. 863.655(sxllxiv) For Flarine events meetine the criteria in S63.670(oX3)
i.,1lr1r11i11r1i1i1it atl;r,:;r..1;' r'':-r,.r :,:i:,::iiir.., .i..r, ir , MACT CC _ ReqUirements fOr ftaie Contf tp.{f&i$$iiiilil${r_f?,,0(e)
Exceedance Date & Time
(15 Min Blocks)
< 270 btu/scf
(15 Min Blocks)
Exceddance Date & Time
r,,;,;115,!{h llecks).r ..
< 270 btu/scf
(r5 Min Blocks)
07/1812023 10:30 r78 09/2712023 06:45 266
07/2012023 15:30 247 10/1112023 18:00 259
07/2012023 l5:45 256 10/ll/2023 18:15 260
0712112023 10:00 263 10/1112023 18:30 262
07/22/2023 t3:45 34 l0/ll/2023 18:45 262
07122t2023 4:00 72 l0lll12023 1900 262
0712312023 0:00 245 r0t 112023 19:15 263
07t23/2023 0:15 101 t0t 112023 1930 261
07t23t2023 0:30 133 t0t l/2023 20:30 263
07123/2023 ll:30 153 r0t 112023 20:45 228
0712312023 ll:45 l4l 10/2/2023 07:30 225
07/2312023 12:00 164 l0ll2/2023 07:45 200
07123/2023 12:15 130 l0ll2/2023 08:00 r65
0712312023 12:30 99 1011212023 08:15 2t3
07/2312023 12:45 220 l0/1212023 08:30 228
07/2312023 13:00 2s9 l0/1212023 08:45 r98
0712312023 13 15 228 l0/12/2023 09:00 200
0712312023 1330 I l0 l0/1212023 09:15 158
07/2312023 1345 102 l0/1212023 09:30 179
O7/2312023 14:00 85 l0/1212023 O9:45 166
0'712312023 14:15 94 1011212023 l000 t90
07123/2023 4:30 92 1011212021 l015 355
0712312023 4:45 94 l0/1212023 l030 346
07t23/2023 5:00 1t8 1011212023 l0:45 298
07t2st2023 4:45 251 1011212023 ll:00 259
07t2st2023 5:00 268 1011212023 ll 15 217
09114/2023 2'.00 229 NA NA
Flare Affected Start Date of Event End Date of Event Duration ofVisible
Emissions
Time Periods where
Vtin>Vmax Max Vtip
None to Report NA NA NA NA NA
Mr. Bryce Bird
Department of Environmental Quality
March 14,2024
Page 10 of 1 1
i. S63.655(eXllXivXD) Results of RCA and Corrective Action
e. Alternative Test Methods
BWO uses both ALT-124 and ALT-l3l for monitoring the net heating value on the monitoring systems
associated with both flares (X-913 and X-1800). These methods are included in Attachment A.
f. Performance Evaluation for Flare NHV:
Not applicable for the current reporting period.
XII. Delayed Coking Unit Periodic Report - $63.655(9)(12)
Not applicable; BWO does not operate a delayed coking unit.
XIII. Maintenance Vents Periodic Report - $63.655(g)(13)
Pursuant to the maintenance vents periodic reporting requirements in $63.643(c), the following table will provide
any releases during the reporting period exceeding the applicable limits in $63.6a3(cXl).
BWO has not utilized the options in $63.643(c)(l)(iv) or $63.643(c)(l)(v). Therefore, there are no additional
reporting requirements for the Maintenance Venting provisions.
MACT CC - Requirem ents for Fl*rC' Control :.-iiid;)$t,|$6:3.6;7 0Qol
Date ofEYent Root Cause Analvsis & Corrective Action
9t7 /2023 The West Flare smokine event did not exceed the flare's smokeless capacitv. No root cause analvsis required.
t2t4/2023 The West Flare smoking event did not exceed the flare's smokeless capacity. No root cause analysis required.
10126/2023 The South Flare smokine event did not exceed the flare's smokeless caoacitv. No root cause analvsis required.
10t27t2023 The South Flare exceeded smokeless capacity at l9:45 and 20:00 and maintained compliant flare tip velocity. Presence ofvisible
emissions could not be determined due to lack of ambient lieht.
1012812023 The South Flare exceeded smokeless capacity at22:00 and22:15 and maintained compliant flare tip velocity. Presence ofvisible
emissions could not be determined due to lack of ambient light.
t0/30t2023 The South Flare smokine event did not exceed the flare's smokeless caoacitv. No root cause analysis required.
Only Requbed
If 5 psig option
was used
*47 Allhllrlli;l
$63.655
(e)(l:Xl)
$63.655
(exr:xi)
$63.655
(g)(13)(ii
)
$63.6ss
GXl3xii)
$63.65s
(g)(13)(iii
)
$63.655
(g)(t:)(iii)
$63.6ss
(gXl3xiv)
s63.65s
(g)(13)(iii)
E2
l9::.9 :
Eo
ri
oo
6<
=9E!9a
9.:.!<Lo
O6\r^x.I
E1 !d
Ll
t.:QE
orl
F
L {d)
nt 9tYI r
=!!-\E2aod33E>
o<Z
39
L-.o 1 =..!E! riEe E'5 3'ad t!= E uEI:5E.';HXE
oY-LCcZgE><Ee6
qs!!.i r'iR:i!{leSi d'E :i
=aY %sib:i.s PH.r€
None to Reporl NA NA NA NA NA NA NA
Mr. Bryce Bird
Department of Environmental Quality
March 74,2024
Page ll ofll
XfV. Notification of Compliance Status Changes - $63.655(9)(14) & $63.655(f)
t. Updated NOCS - Storaee Vessels Q63.655(fl(lXi)
For purposes of $63.655(f)(6) and $63.640(l)(3), BWO provides the following updates to the Notification
of Compliance Status report.
Updated NOCS - Miscellaneous Process Vents (MPV) 863.655(fl(lXii)
For purposes of $63.655(0(1XiD, BWO provides an updated Notification of Compliance Status for
Miscellaneous Process Vents if applicable for the reporting period in the following table,
ll) Group I miscellaneous process vent means a miscellaneous process vent for which the tolal organic HAP concentration is greater lhan or
equal to 20 parts per million by volume, and the total volatile organic compound emissions are grealer than or equal to 33 kilograms per dayfor
existingsources and 6.8 kilograms per dayfor nw sources dt the outlet ofthefinal recovery deilce (ifany) andprior to dny control device and
prior to discharge lo the atmosphere.
l2lGroup 2 miscellaneous process vent means a miscellaneous process yent that does not meet the defnilion ofa Group I miscellmeous
process vent.
b.
lll The date indicated is the month and year ofthe first degassing and cleming activityfor m existingJloating roof storage vessel not currently
compliant. These tanks will achieye complimce the next time the tank is removedfrom service prior to slartup.
AttachmentA
Attachments Related to Alternatlve Test Methods Annhed fot MACT CC Flare Comnliance
Copies of EPA approval lettersfar broadly-applicable-approved-alternative,test-methodsfor MACT CC Flare Compliance Provisions
if the alternative testing procedures a.re applied for each peiodic reporting period.
The followins information is included in this attachment:
o ALT-124
o EPA approval letter - Mass Spectometer - Determination of NlfVvg
o ALT-131
o EPA approval letter- GC and/orMS - Composition & Determination ofNHV for Combustion Efficiency
o+f,Eo
sr'rO
3 ff ao-
LYJ
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
RESEARCH TRIANGLE PABK, NC 27711
Mr. Chuck DeCarlo
Marketing Manager
ExtrelCMS. I-LC
575 Epsilon Drive, Suite 2
Pittsburg. PA I 5238-2838
Mr. Tony Slapikas
Product Manager for Mass Spectrometry
AMETEK. Energy & Process Division
150 Freeport Road
Pittsburgh, PA 15238
rrB 0 5 20i3
OFFICE OF
AIR OUALTTY PLANNING
AND STANDARDS
Dear Mr. DeCarlo and Mr. Slapikas.
I am writing in response to your letter dated August 18, 2017, requesting approval for use of
process mass spectrometers as part of an alternative to testing procedures utilizing calorimeters
or gas chromatographs to measure Net Heating Value (NHVvc) in flare vent gas as required
under 40 CFR Part 63, Subpart CC - National Emission Standards for Hazardous Air Pollutants
from Petroleum Refineries. The owner or operator of facilities subject to Subpart CC must
measure flare vent gas composition to determine NHVvc in units of British Thermal Units per
standard cubic foot (BTU/SCF). This BTU/SCF determination may be pertbrmed using a
calorimeter capable of continuously measuring. calculating, and recording NHVvc; at standard
conditions (40 CFR 63.670 (iX3)) or equipment that determines the concentration of individual
components in the flare vent gas (40 CFR 63.670 (iXl )), such as a gas chromatograph, and, if
desired. may directly measure the hydrogen concentration in the flare vent gas following the
methods provided in 40 CFR 63.670 0X4). All monitoring equipment must meet the applicable
minimum accuracy. calibration and quality control requirements specified in Table l3 and
$63.671 of Subpart CC.
In your letter. you propose to use a process mass spectrometer analyzer and the follou,ing
measurement approach as an alternative to measure NHVv<;:
I ) The owner or operator of the affected facility will perform a pre-survey to determine the list
and concentration of components that are present in flare vent gas feed. This pre-survey will
be used in part to:
a) Determine an appropriate analysis method for the site-specific refinery flare vent gas;b) Create a list of vent gas components to be included in calibration gas cylinders to be used
to evaluate the quality of the measurement procedure used to determine NHVvc;c) Define calibration standards to be prepared by a vendor at a certified accuracy of 2
percent and traceable to NIST; and
d) Perfornt an initial calibration to identiff mass fragment overlap and response factors for
the target compounds.
lntemet Address (URL) o htts://www.epa.gov
Recycle<UBecyclable o Pdnled wnh Vegdable Oil Based lnks on Recycled Paper (Mhhum 25% Postconsurner)
2)
3)
4)
2
The process mass spectrometer will be calibrated using calibration gas standards consisting
of a.mix of the compounds identified in the site specift flare gas pre-survey.
During flare gas analysis. compounds that are not identified during the pre-survey and that
have mass fragments. identical to the compounds found during the*pre-survey will beincluded in the calculation of NHVvr;.
Calibration enor (CE) lbr each component in the calibration blend will be calculated using
the following equation:
ss - t:" x 1oo
where , to
Cn,: Average instrument response, (ppm)
Cr: Cylinder gas value or tag value, (ppm)
5) The average instrument CE for each calibration compound at any calibration concentration
must not diff'er by more than l0 percent from the cylinder gu. uulu" or tag value.6) For each set of triplicate injections at each calibration concentration for each calibration
compound. any one introduction shall not deviate more than 5 percent from the average
concentration measured at that level.
Your supporting infonnation included Method 301 calculations that showed acceptable bias and
precision when you measured a mixture of gases trom a vendor certified gas cylinder. your
request also includes reference to facilities needing to monitor flare gas composition
continuously to effectively maintain flare efliciency while compensating for changes in the flare
gas composition.
With this letter, we are approving your request to substitute continuous process mass
spectrometry for continuous gas chromatography as allowed in 40 cFR 6 3.670 and 63.671predicated on both your proposed use of thise pio".r, mass spectrometers as described aboveand the additional provisos listed below:
I ) You must meet the requirements in 40 cFR 63.671 (eXl) and (2) including Table l3requirements for Net Heating varue by Gas chromaiograph.2) You may use the altemative sampling line temperature-aliowed in 40 CFR 63, Subpart CC,Table 13. under Net l{eating Value by Gas Chromarograph.3) You must meet applicable Performance Specification-9 (+O Cfn part 60, appendix B)requirements for initial continuous monitoring system acceptance including, but not limitedto:
o Perfbrming a multi-point calibration check at three concentrations fbllowing theprocedure in Section l0.l; ando Performing periodic process mass spectrometer calibrations as directed for gas
chromatographs in 40 CFR 63, Subpart CC, Table 13.4) You may augment the minimum list of calibration gas components found in 40 CFR
63 '671 (e) with compounds found during the pre-survey as needed to develop a site-specificanalysis method.
-t
5) For unknown gas components that have similar analytical mass fragments to calibrationcompounds. you may repo( the unknowns as an inciease in the ovi"rlapped tdibrution gu,compound.
6) For unknown compounds that do not produce mass fragments that overlap calibrationcompounds, you may use the response factor for the ne-arest molecular *.igrrt hydrocarbon inthe calibration mi,x to quantify the unknown component's NHVvc. This req"uirement parallelsthe requirements in 40 cFR part 63.6Tr (ex3) foi gas chromatographs.7) You may use the response factor for n-pentane to quantify any ,nt no*n componentsdetected with a higher molecular weight than n_pentun". '
8) You must meet all,other applicable generic ,"quir...nts of gg63.670 and 63.671 formeasurement of NHVvc (i.e., measurement requirements not specifically targeted to gaschromatographs).
9) A copy'of this approval letter must be included in the report for each testing program wherethese alternative testing procedures are applied.
Since this altemativeJest method approval under 40 CFR 63.7 (f) is appropriate for use at allfacilities subject to 40 cFR 63, Subpart cc, we will announce on EpA,s web site(https://wt!v'.epa.go'v/emc/hroadly-applicoble-approved-allernutive-test-methotl,s) that thealternative method is broadly applicable to determination of NHVvc under this subparr.
If you have any questions regarding this approval or need f'urther assistance, please contact RayMerrill at [phone] or [e-mail],or Robin Segall ut iqrq) 541-0g93 or
s e ga I l. rob i n@epa. gov.
Sincerely,
,A a 1'/-ii:514"fr t*. sl,t-r
Steffan M. Johnson, Group Leader
Measurement Technology Group
Gerri Garwood, EPA/OAepS/SppD
Maria Malave, EPAiOECA/OC
Brenda Shine, EPA/OAepS/SppD
EPA Regional Testing Contacts
s"*X\"-tYj UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
RESEARCH TRIANGLE PARK, NC 27711
Mr. Tim Goedeker
Senior Principal Environmental Consultant
Phillips 66
2331 CityWest Blvd. 5685
Houston. TX77042
Dear Mr. Goedeker:
OFFICE OF
AIFI QUALITY PLANNING
AND STANDARDS
I am writing in response to your letter dated September 26,2018, requesting approval fbr
altematives to requirements in 40 CFR 63, Subpart CC - National Emission Standards fbr
Hazardous Air Pollutants from Petroleum Refineries (Subpart CC), and by refbrence.40 CFR 60.
Appendix B, Performance Specification 9 (PS 9) for determining Net Heating Value (NHV).
You request using *10 percent agreement of the total calibration cylinder NHV as an alternative
to the PS 9 requirement that specifies calibration and calibration check individual compound
agreement of * l0 percent with cylinder certified tag values. You are requesting this alternative
fbr broad application to atTected tbcilities which use Gas Chromatograph (GC) and/or Mass
Spectrometer (MS) technology for composition and corresponding NHV determinations required
under Subpart CC.
In your letter, you request the following specific altematives to the quality assurance procedures
required in PS 9 and $$63.671(e)(2) and (eX3) when you demonstrate compliance with Subpart
CC:
I ) Single daily mid-level calibration check error to be calculated based on the total NHV of
a certihed calibration gas mixture. The instrument response for NHV shall not varv by
more than l0 percent from the total NHV of the cenified calibration gas mixture.
2) Quarterly rnulti-point calibration (see Table 13 of Subpart CCI) error to be calculated
against the total NHV of the certified calibration gas mixtures (i.e.. low-. mid-. high-
level). The average instrument response fbr total NHV shall not vary by more than l0
percent from the total NHV of any of the certitied gas mixtures.
Your rationale fbr proposing these alternative procedures is based on the tenant that NHV is the
factor utilized to determine compliance with the Subpart CC flare combustion efficiency
requirement. These alternative procedures also simplify the calibration procedures for sites that
elect to use them. You provided calibration check data for both GC and MS NHV determinations
that show the comparability of quality control on a per compound basis with quality control on a
total NHV basis.
lntemet Address (URL) o h@://www'epa'gov
R6cycted/Recyclable . printed wlth Vegetabh Oll Based lnks on Recycled Paper (Mlnimum 25% Poslconsurner)
2
You request these alternative procedures for use at Phillips 66 BP facilities subject to Subpart
CC and provide example facilities including: Billings Refinery located at 401 S 23'd Street,
Billings. I\,1T, 59101; Ponca City Refinery located at 1000 S Pine Street, Ponca City, OK, 74601;
and the Wood River Refinery located at 900 S. Central Avenue, Roxana, [L,62084.
With this letter. we are approving your request to use the relative percent error of total NHV
measured versus the certified cylinder tag value for total NHV as the measure of agreement fbr
both the daily calibration and quarterly multi-point audits when using GC or MS for flare fuel
fbed NHV requirements in Subpart CC with the following provisos:
I ) Certified gas standards must be prepared consistent with the requirements in
$63.671(eX2).
2) You must use certified calibration gases that meet the requirement in Section 7.1 of PS 9
for daily calibration checks.
3) You must use performance audit gases that meet the requirements in Section 7.2 of PS 9
tbr your quarterly multi-point calibration audits.
4) The measured NHV relative error for quarterly multi-point calibration audits must be
within l0 percent of the certified cylinder gas tag value for NHV. NHV calculations must
be based on the individual component properties in Table l2 of Subpart ClC. This
requirement replaces the compound-specific relative error requirement for performance
audits in Section 7.2 of PS 9.
5) Mid-leveldaily calibration standard measurements must also be within l0 percent of the
certit'ied of the cylinder gas tag value fbr NHV. This requirement replaces the compound-
specific relative error requirement for daily calibration in Section 10.2 of PS 9.
You ntust include a copy of this approval letter in the report for each testing program or periodic
reporting period u,here these alternative testing procedures are applied.
Since this alternative test method approval under 40 CFR 63, Subpart CC, is appropriate fbr use
at all facilities subject to Subpart CC that must determine flare combustion efficiency, we will
announce on EPA's website (at hups://vtvtw.epa.gory'emc/broadly-applicable-approved-
ahernalite-test-methods) that our approval of this alternative is broadly applicable to 40 CFR 63,
Subpart CC. Should the alternative approvals authorized in this letter be superseded by formal
actions to revise 40 CFR 63, Subpart CC, this approval may be rescinded.
Ifyou have any questions regarding this approval or need further assistance. please contact Ray
Menill at [phone] or [e-mail],.
Steflhn M. John^fon, Group
Measurement Technology Group
3
Cc: Jennifer Ahlskog, Phillips 66 Rodeo Refinery
Geni Garqrood, EPA/OAQPS/SPPD
Sri Kanukolanu" Phillips 66 Wood River Refinery
Maria Malaveo EPA/OECA/OC
Dave Pavlich, Phillips 66 Principal Environmental Consultant
Ray Pilapil, ffinois Environmental Protection Agency
Brenda Shine, EPA/OAQPS/SPPD
EPA Regional Testing Contacts
I,TAH DEPARTMENT OF
E}URONMEI.ITAL OI.|.AI.JTY
l\/lAR 2 5 2A2-1.
DI\4SION OF AIR QUALIT\"