EPA Inspection Report - Page 1 of 1969 Lin-zed Stazrs VI Environmental Protection AJEHEV Region 6 Enforcement and Compliance Assurance Division INSPECTION REPORT i Inspection Date(s): 10/1- 4/2019 Media: Air Regulatory Program(s) SIP, Title v, NESHAP, NSPS {Company Name: Navajo Re?ning LLC Facility Name: Artesia Re?nery Facility Physical Location: 501 E. Main Street (city, state, zip code) Artesia, NM 88210 Mailing address: PO. Box 159 (city, state, zip code) Artesia, NM 88211-0159 Parish: Eddy County Facility Contact: Scott M. Denton Environmental Manager (575) 746-5487 FRS Number: 1100 0047 2630 Identification/Permit Number: NMED AI 198; Title Permit P051-R2 issued 5/6/15 NSR Permit PSD-NM-0195-M37 issued 8/12/16 Media Number: AFS 35-015-00010 NAICS: 324110 SIC: 2911 Personnel participating in inspection: Debbie Ford EPA ECDAT i Env. Scientist (214) 665?7235 James Haynes EPA ECDAT 1 Physical Scientist (214) 665-8546 Dan Roper ERG for EPA Inspector (571) 329?2067 Richard Helmich EPA NEIC Chemist (303) 462-9149 Martha Hamre EPA NEIC Chemical Engineer (303) 462-9271 Cindy Hollenberg NMED Air Quality Bureau Mgr, Compliance Inspections (505) 476-4356 Kate Hauer NMED Air Quality Bureau Inspector (505) 469-7531 Sherry Paul NMED Air Quality Bureau Inspector (505) 467-9457 Scott Denton Artesia Environmental Manager (575) 746-5487 Ray Smalts Artesia Environmental Specialist (575) 746?5490 Staci Hammond Artesia Environmental Specialist (575) 748-6770 Robert Combs Artesia Environmental Specialist (575) 746-5382 Sucheta Gokhale Corp. Env. Specialist (214) 790-3127 Theresa Wheeler Director Corp. Environmental (316) 305-0827 Parrish Miller - Artesia I Plant Manager (575) 748-6717 EPA Lead Inspector Signature/Date . 3% (?L/Ji/ff Debbie Ford Date Supervisor I if . .1 .1, Signature/ Date i 2/1; i I Margar Osbourne l_Date {2/15/2017} EPA Inspection Report - Page 2 of 1969 Section I – INTRODUCTION PURPOSE OF THE INSPECTION Environmental Protection Agency (EPA) Region 6 inspectors Debbie Ford and James Haynes, Environmental Resources Group (ERG) contractor for EPA Dan Roper, and New Mexico Environment Department (NMED) Air Quality Bureau staff Cindy Hollenberg, Kate Hauer, and Sherry Bell arrived at the HollyFrontier Navajo Refining LLC (HollyFrontier) / Artesia Refinery (facility or Artesia) at 8:00 a.m. on October 1, 2019 for an unannounced inspection. There was confusion at the main gate about the requirements for our entry. Inspectors initially were instructed to take computer training and testing, but when Mr. Denton was reached, he instructed the group to enter at the Administration Office where the environmental staff were located. We were not instructed to watch a safety video for the facility (see AOC # ). We were accompanied by facility personnel when we were onsite. At 9:10 a.m. we met with Mr. Denton, Artesia Environmental Manager, and Mr. Smalts, Artesia Environmental Specialist, for the opening conference. EPA and ERG inspectors presented their credentials to Mr. Denton. I informed Mr. Denton and Mr. Smalts that this was an EPA inspection triggered by the elevated benzene levels detected by the fenceline monitoring (FLM) required by National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart CC. The purpose of the inspection was to determine compliance with the facility’s Title V Air Permit and the Clean Air Act (CAA), which is authorized under Section 114(a) of the CAA. The scope of the inspection is a partial compliance evaluation (PCE) and includes an evaluation of the compliance of the facility with applicable New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAP), and NMED regulations in the State Implementation Plan (SIP). On Thursday, October 3, EPA’s National Enforcement Investigations Center (NEIC) inspectors Martha Hamre and Richard Helmich, arrived at the facility with the NEIC Geospatial Measurement of Air Pollutants (GMAP) vehicle. After presenting their credentials to Mr. Denton, Ms. Hamre and Mr. Helmich, accompanied by a HollyFrontier employee, began surveying within the refinery boundaries and the nearby community to identify sources of emissions. They continued throughout Thursday and until noon on Friday collecting meteorological and emission data with the GMAP as well as several canisters for analysis by the NEIC laboratory. The NEIC report of monitoring activities and results of canister sampling is separate from this report. During the inspection we took photographs using Nikon COOLPIX AW120 digital cameras and videos using FLIR Systems GF320 infrared cameras. The FLIR GF320 infrared camera is designed to visually detect hydrocarbons in the infrared spectrum that are typically emitted by facilities such as refineries, oil and gas sites, and other similar industries. At the end of the inspection, we shared copies with HollyFrontier of all videos and photographs taken. EPA Inspection Report - Page 3 of 1969 FACILITY DESCRIPTION The Artesia Refinery is owned by HollyFrontier Navajo Refining LLC. It began operation as the Navajo Refining Company in the 1930s by Continental Oil Company. Holly purchased the facility in 1969. Holly merged with Frontier in 2013 to create HollyFrontier Corporation, of which HollyFrontier Navajo Refining LLC is a subsidiary. The facility is a 40,000 barrels per day (bpd), fully-integrated petroleum refinery with crude distillation, vacuum distillation, Fluidized Catalytic Cracking (FCC), solvent deasphalter, hydrofluoric acid alkylation, catalytic reforming, hydrodesulfurization, isomerization, sulfur recovery, and product blending units. The Artesia Refinery receives crude oil via truck and pipeline. The facility has approximately 300 employees and averages 150 contractors per day. Although separate facilities, HollyFrontier considers the Lovington Refinery (Lovington), located approximately 70 miles from Artesia, to be a part of the Artesia Refinery. Lovington uses a crude distillation unit and associated vacuum distillation units to process approximately 74,000 bpd of crude into intermediates which are transported to Artesia via pipeline. Vacuum bottoms are transported to Artesia via tank truck. The combined capacity is 110,000 bpd. The Artesia refinery is a major source of hazardous air pollutants (HAPs) as well as a major source for volatile organic compounds (VOCs). As a major source, it is required to operate under a CAA Title V operating permit. The current New Source Review operating permit for the facility is PSD-NM-0195M37 issued August 12, 2016 and the current Title V operating permit is P051-R2M1 issued January 22, 2016. P051-R2M1 is an Administrative Amendment to P051-R2 for a name change of the company. The full Title V Permit with applicable conditions is P051-R2 issued May 6, 2015. The facility also has an active Consent Decree CIV-01 1422LH that was entered March 5, 2002 under EPA’s Refinery Consent Decree Initiative https://www.epa.gov/enforcement/petroleum-refinery-national-case-results. NESHAP Subpart CC Fenceline Monitoring Program for Benzene Emissions NESHAP Subpart CC requires biweekly sampling of benzene using passive monitors at fenceline sampling points. NESHAP Subpart CC also requires that the facility collect meteorological data to help determine sources of any elevated emissions detected by the fenceline monitors. After twenty-six (26) 2-week periods, Subpart CC requires the facility to calculate an annual average benzene concentration (∆c) and compare the results to the action level of 9 µg/m3. Artesia began the required FLM program January 30, 2018 and have 19 sampling locations (see Appendix 9, page 5). Prior to the start of the required monitoring, Artesia began 2-week sampling on October 4, 2016 (beginning date of the sampling period). Artesia reported that the initial annual average ∆c was 290 µg/m3, which was the highest reported concentration in the nation. HollyFrontier submitted the May 15, 2019 Corrective Action Plan (see Appendix 9) required by 40 C.F.R. § 63.658(h) to report the actions taken by the facility to determine the root cause of elevated benzene readings and the actions taken to address them. HollyFrontier submitted Amended Corrective Action EPA Inspection Report - Page 4 of 1969 Plans on July 3, 2019, September 3, 2019, and October 11, 2019 (see Appendices 10-12). The Corrective Action Plans detailed the use of temporary samplers and FLIR infrared camera to determine the source(s) of the elevated benzene emissions. HollyFrontier identified external floating roof (EFR) tanks T57, T-401, and T-450 as contributors to elevated benzene readings; in response, in December 2017, Artesia installed socks on the legs and vacuum breakers. The socks seemed effective for T-401 and T450, but not Tank-57. The refinery installed a more effective sock for the vacuum breaker of T-57 in July 2018. HollyFrontier also identified plugged tubes in a heat exchanger that is used to cool naphtha going to T-57. The heat exchanger should cool the material to 80oF, but HollyFrontier reported the temperature of the naphtha was 100oF going into T-57. HollyFrontier also reported T-11 maintenance activities and a T-106 overflow and damage as contributors to elevated benzene. Section II – OBSERVATIONS Mr. Denton stated that the facility has seven employees on the environmental staff. Currently, he said there are two employees who manage the air requirements: Ray Smalts and Staci Hammond. There was also one open position. Applicability and Inspections of Storage Vessels I asked about the inspections performed on the EFR and internal floating roof (IFR) tank and what regulations the facility is complying with for Group 1 storage vessels since the operating permit only stated that the tanks were subject to NESHAP Subpart CC. The original NESHAP Subpart CC Storage Vessel Provisions at 40 C.F.R. § 63.646 required compliance with the Hazardous Organic NESHAP (HON) tank requirements in NESHAP Subpart G. In 2015 NESHAP Subpart CC added new Storage Vessel Provisions at 40 C.F.R. § 63.660 which have different breakdowns of tank size, vapor pressure, and HAP content for identifying tanks as Group 1 or Group 2 and require compliance with NESHAP Subpart WW. Table 11 in Subpart CC provides which requirements apply to new or existing tanks. The table provides for transitioning to Subpart WW for existing tanks. Mr. Smalts stated that they are following NESHAP Subpart WW. I asked how long the facility had been following Subpart WW and he replied, “Forever.” He provided his book of Tank Applicability (see CBI Appendix A) which Mr. Smalts stated that he worked with a consultant to develop. I reviewed the details of the tanks, and it appears that the current applicability is based upon the 2015 changes to Subpart CC. Mr. Omar Dominquez from the Inspections Department at Artesia performs tank inspections which include the rooftop inspections for IFR tanks, primary and secondary seal gap measurements for EFR tanks, as well as the out-of-service inspections required for IFR tanks and the API 653 inspections required for IFR and EFR tanks. Mr. Dominguez keeps a spreadsheet to track when each inspection is due. The regulations (NSPS Subpart Kb, NESHAP Subpart G, and NESHAP Subpart WW) require that notification be made at least 30 days prior to the NSPS and NESHAP inspections to allow the regulatory EPA Inspection Report - Page 5 of 1969 agency to have an observer present. Artesia submits a schedule in December each year for the following year’s inspections. Artesia sent NMED the 2019 schedule in a letter dated December 12, 2018 (see Appendix 15). The letter begins by referencing the HON (40 C.F.R. § 63.120(b)(9)), “as applicable to Group 1 storage vessels subject to 40 C.F.R. § 63.660 (MACT Subpart CC storage vessel provisions).” EPA modified NESHAP Subpart CC in 2015. There are now two (2) sections for “storage vessel provisions”: • 40 C.F.R. § 63.646 which requires Group 1 tanks to follow the HON • 40 C.F.R. § 63.660, which requires Group 1 tanks to comply with NEHAP Subpart WW if the Max TVP < 11.1 psia, or SS if the Max TVP ≥ 11.1 psia. The definition of Group 1 tanks in NESHAP Subpart CC changed with the 2015 revision to the rule. Prior to February 1, 2016, the old Group 1 definition applied. On or after February 1, 2016, the new definition applies. NESHAP Subpart CC transitions tanks from complying with the HON to WW or SS as they are emptied and degassed or by January 30, 2026, whichever occurs first. The regulations require the use of probes to determine the width of gaps between the primary or secondary seal and the wall of the tank: • NSPS Subpart Kb and NESHAP Subpart G describe the measurement tool as a 1/8” uniform probe that identifies a measurable gap, and the use of varying width probes to calculate the area of the gap and to determine if any width exceeds 1/2” for secondary seals or 1.5” for primary seals. • NESHAP Subpart WW describes the measurement tools as 1/8” probe and additional probes at 1/8” increments. The maximum widths are the same as for NSPS Subpart Kb and NESHAP Subpart G. Mr. Dominguez informed us that he uses a 1/8” metal rod (carbon steel) initially. The other probes he uses are wooden dowels in 1/16” increments from 3/16” to 1/2” (3/16”, 1/4”, 5/16”, 3/8”, 7/16”, 1/2”). For primary seals greater than 1/2”, he uses a tape measure to determine the gap width (see AOC #23). The methodology for calculating the seal gap areas is also different from NSPS Subpart Kb or NESHAP Subpart G compared NESHAP Subpart WW. Under NSPS Subpart Kb and the HON, a gap area is the sum of a series of smaller gaps of varying widths (e.g. a gap may have 1/8” gaps at the edges, 1/4”, 3/8”, or 1/2” in the middle of a single long gap. Each segment is documented, and the areas of each of the segments are summed. Under NESHAP Subpart WW, the smallest and the largest gap width is determined within the single gap. The average of the 2 widths is then multiplied by the total gap length to determine the gap area. When Mr. Dominguez performs his inspections, he keeps notes in a notepad that he carries with him. He uses the notepad to prepare the inspection report that is submitted as part of the NESHAP Subpart CC Reports. The inspection reports do not specify which regulation is applicable for the tank. Mr. Dominguez categorizes gap shapes as triangular (T) or square (S) when he performs primary and secondary seal gap measurements. If the shape is a square, he calculates the area of the gap = length (L) X width (W). If the shape is a triangle, he calculates area of the gap =[ length (L) X width (W) ] / 2 (see AOC # 1). EPA Inspection Report - Page 6 of 1969 Facility Tour We toured the various tank areas at the facility (for Appendices 4-8 – green tanks are EFR tanks and yellow tanks are IFR tanks. Tanks with no color are fixed roof or pressure tanks). • West Tank Area (see Appendix 4) • North Center (Wastewater) Area (see Appendix 5) • East Tank Area (see Appendix 6) • South Tank Area (see Appendix 7) • Center Tank Area (see Appendix 8) James observed tanks and other equipment with the FLIR infrared GF320 camera to determine if any visible hydrocarbon emissions could be detected, which could indicate potential benzene sources. If he observed emissions, he recorded his observations. Below is a cross-reference table of location area, equipment, photos, and videos: Table 1 – Cross-reference Table Area West Tank West Tank West Tank North Center North Center North Center Equipment T-57 Control Room (for T-57 feed) T-737 SRU #2 DOR component 2720 API Separator Carbon Canisters Sump Lift Station Tank Type EFR Permitted Contents* Naphtha Capacity EFR Sour Water 20,000 (barrels) 50,400 Wastewater Photo # 1-6 23 63-66 60-62 19-22 20, 67-69 70-71 Wastewater Video # 32 2-7 33-34 (near API Separator) North Center North Center North Center North Center East Tank East Tank East Tank East Tank East Tank East Tank East Tank East Tank East Tank East Tank South Tank South Tank South Tank South Tank Bundle Cleaning Area New Sump New Carbon Canisters T-49 FLM Sample Pt. 7 T-11 T-12 T-108 T-109 T-401 T-401 Base #3 Blending Pit T-415 T-437 T-1225 T-124 T-417 T-431 T-432 Wastewater Wastewater Fixed Slop oil 667 IFR IFR IFR IFR EFR EFR Gasolines Gasolines Gasolines Gasolines Gasolines 32,600 32,300 22,900 22,300 53,000 IFR EFR EFR IFR IFR Fixed Fixed Gasolines Crude Oil Naphtha Gasolines Gasolines Distillates Distillates 29,900 85,000 100,000 6,200 9,300 56,500 55,000 76 72, 74 73, 75 16-18 24-25 26-28, 31 26, 29, 30 32, 35 34, 36 37-42 56-59 43-44 33 46 45-51 15 14, 55 52 53 35-36 8 9 10, 13 12 14-19 28-31 11 20-22 1 27 23 24-25 EPA Inspection Report - Page 7 of 1969 Area South Tank Equipment T-434 Y-11 Cooling Tower Tank Type Fixed Permitted Contents* Distillates Capacity (barrels) 78,400 Photo # 54 7-13 Video # 26 *HollyFrontier provided a Tank List with actual contents at the time of the inspection (see CBI Appendix B). T-57 Tank T-57 tank was originally built in 1955. HollyFrontier replaced the floating roof and put the tank into light naphtha service on February 12, 2012. HollyFrontier provided the construction drawings for the new floating roof (see CBI Appendix C) which had the latest revision date of October 25, 2011. The drawings included the primary mechanical shoe seal but did not include the secondary seal that the tank currently has installed (see AOC # 2). At the time of the inspection, I observed that the tank level was 8’ - 9/16”. James noted the vacuum breaker sock that was installed to control benzene emissions was damaged (see Appendix 1, photo 2). During the September 9, 2019 call with HollyFrontier, I asked at what level does the vacuum breaker engage or open on T-57. HollyFrontier stated that the vacuum breaker opens at 8.5 feet. The drawings for the T-57 bleeder vent, aka vacuum breaker, requires a 12-foot pipe and a notation to “field determine” the length (see CBI Appendix C, pg 7 – Drawing 8) (see AOC # 3). T-737 Tank T-737 was out of service (OOS) at the time of the inspection. The EFR tank is a sour water tank that was constructed in 2009 and according to the Tank Applicability book, the tank is a Group 2 tank under NESHAP Subpart CC. As a new tank, for overlapping regulations with NESHAP Subpart CC and NSPS Subpart Kb, the facility should follow NSPS Subpart Kb regulations. The annual secondary seal gap measurements have two criteria that must be met for the tank to pass inspection: 1) the accumulated gap area shall not exceed 1 in2/foot of tank diameter and 2) no single gap width shall exceed 1/2”. For primary seal gap measurements, 1) the accumulated gap area shall not exceed 10 in2/foot of tank diameter, 2) no tears or holes in the primary seal fabric, and 3) no single gap width shall exceed 1.5”. If a seal inspection fails to meet these criteria, the company is required to submit a report within 30 days of the inspection and provide specific information about the seal inspection in the report. The company is to make the repairs or empty the tank within 45 days of the inspection. If the repairs cannot be made within the 45 days, a 30-day extension may be requested if there is no alternate tank space available. T-737 was the subject of additional FLM sampling (Temporary Sampler TS8 in September 2017) to determine the source of the benzene at nearby sample points. Artesia determined that T-57 was likely the source of the benzene due to the predominant wind direction during the sample period. HollyFrontier provided the following inspection documents for T-737 (see CBI Appendix M): • January 30, 2019 – EPA Inspection Report - Page 8 of 1969 • March 27, 2019 – • July 9, 2019 – . The Corrective Action Plan Amendment dated July 3, 2019 (see Appendix 10) stated that on “March 18, 2019, during routine tank inspections, Navajo identified that Tank 737 (sour water tank) has a damaged seal that may be contributing to detected benzene fenceline concentrations on the west side of the refinery.” Artesia did not provide a report detailing the failed inspection within 30 days of the March 18, 2019 inspection as required by NSPS Subpart Kb (see AOC # 4). On July 16, 2019 Artesia provided a Notice of Seal Inspection and Refill (see Appendix 14) to NMED for Tanks T-106, T-107, T-451, and T-737. Artesia submitted the report of the failed inspection of T-737 beyond 30 days after the March 27, 2019 inspection (see AOC # 4). In the July 3, 2019 Corrective Action Plan Amendment, Artesia stated that cleaning and repair has required more than 45 days to complete. Artesia did not request a 30-day extension. Artesia’s letter did not detail the exact date when the tank was emptied, but if the June 16, 2019 roof landing date is conservatively used as the emptied date, that is 90 days after the March 18, 2019 inspection (see AOC # 5). Leak Detection and Repair (LDAR) – Delay of Repair (DOR) Components We asked for the current DOR list (see Appendix 23). One of the components, a 3/4” valve (Unit 30, Tag # 2720) had been on the DOR list since May 13, 2009. Since the LDAR programs under the Refinery Consent Decree Initiative requires companies to continue to monitor DOR components, I asked for the monitoring history to review. The history for Unit 30’s Tag # 2720 (see Appendix 24) noted that the valve has recorded readings as high as 127,700 ppm on July 26, 2017, and 500,000 ppm on April 20, 2018 (see AOC # 6). At the time of the inspection, James observed with the FLIR camera visible emissions from the plug (see Appendix 2 - Video 32, Appendix 1 – Photo 60-62). API Separator and Adjacent Sump Lift Station Artesia has an aboveground API separator (see Appendix 1 - Photos 19-22) in its wastewater unit that is comprised of a west separator tank (D-0829) and an east separator tank (D-0830) with a total capacity of 1,200 gallons/minute (gpm). The aboveground API Separator is subject to NSPS Subpart QQQ and emissions from the separator are permitted (see Appendix 13) to be controlled by a carbon canister system (D-808 and D-809) (see Appendix 1 – Photos 20, 67-69), referred to as the Old API Canisters by the facility. Under NSPS Subpart QQQ at 40 C.F.R. § 60.692-3 Standards: Oil-Water Separators, each oil-water separator tank shall be equipped with a fixed roof installed to completely cover the separator tank. Roof seals, access door, and other opening shall be checked visually initially and semiannually thereafter to EPA Inspection Report - Page 9 of 1969 ensure no cracks or gaps occur and that access doors and other openings are closed and gasketed properly. Oil-water separator tanks with a design capacity to treat more than 250 gpm of refinery wastewater shall also be equipped and operated with a closed vent system and control device. Standards for closed vent systems and control devices, specified at 40 C.F.R. § 60.692-5, state that the closed vent system shall be designed and operated with no detectible emissions, as indicated by an instrument reading of < 500 ppm above background, as determined during the initial and semiannual inspections using EPA Method 21. The standards also state that a flow indicator shall be installed on a vent stream to a control device to ensure that the vapors are being routed to the device. Monitoring for a carbon adsorber control using carbon canisters, as specified at 40 C.F.R. § 60.695, requires the facility to monitor the exhaust vent stream on a regular basis to detect breakthrough. The API Separator roof has a gasket to seal the roof to the separator tank, and I observed that the clamps holding the roof were spaced closer together on the north end as compared to the south end. Using the FLIR infrared camera, James observed visible hydrocarbon emissions at several locations on both the west and east separator tanks of the API separator (see Appendix 2 – Videos 2-7). I asked Mr. Denton if they monitor the API Separator gasket under their LDAR program. He stated that they only inspect it for visible gaps as required by NSPS Subpart QQQ . Artesia uses their LDAR contractor, Dexter, to perform daily monitoring of the U.S. Filter Westates Carbon Canister system (or the Old API Canister system) to detect breakthrough. Artesia previously performed the monitoring weekly but increased the frequency to daily. We observed the Dexter contractor monitor the carbon canisters, beginning at the outlet of the second (or lag) canister, progressing to between the canisters, then to the inlet of the first (or lead) canister. The following are the results of the monitoring: • Background Minimum: 4 ppm Maximum: 7 ppm • Lead canister Inlet: 286 ppm Outlet: 4 ppm • Lag canister Inlet: 4 ppm Outlet: 3 ppm I asked Mr. Smalts when the facility last changed out the carbon in the canisters and he replied, “Never.” He said they had reviewed records and could not locate when Artesia had purchased carbon to replace the old carbon. I asked if they had flow through the system, and he replied that they must have since the numbers got lower from the inlet to the outlet. James asked the Dexter contractor to monitor the edge of the API roof where he had observed hydrocarbon emissions with the FLIR camera. Using the TVA monitoring instrument, Dexter measured a concentration of 1,300 ppm. I reviewed the P&ID drawings for the API Separator (see CBI Appendix N) to determine if Artesia had designed and operated the closed vent system with a flow indicator. I could not locate one on the vent line to the carbon canisters (see AOC # 7). Just north of the aboveground API Separator was a sump lift station. I observed a lot of sealant around each of the two access hatches (see Appendix 1 – Photos 70-71). James observed the hatches with the FLIR camera and saw visible hydrocarbon emissions (see Appendix 2 – Videos 33-34) (see AOC # 8). Bundle Cleaning Area EPA Inspection Report - Page 10 of 1969 We looked at the bundle cleaning area where heat exchanger tube bundles are cleaned. The area slopes and the water routes to the wastewater system. The vacuum trucks that collect spills throughout the facility empty their trucks at this area. We observed a lot of oil staining at the junction box adjacent to the cleaning area (see Appendix 1, Photo 76). New Stormwater Lift Station and Carbon Canister System The facility provided records of daily carbon canister monitoring (see Appendices 25-26), and the refinery is monitoring a second canister system (D-8000 and D-8001) (see Appendix 1 – Photos 73 and 75). Artesia said it was installed in approximately 2012 (see CBI Appendix O) to control emissions from the new stormwater lift station (T-0846) (see Appendix 1 – Photos 72 and 74). Artesia designed and installed the equipment as part of a project to separate stormwater and prevent wastewater upset, surge flows, and air emissions. The project does include an oil skimmer. The facility’s current permit does not show the new carbon canister system which also appears to be subject to NSPS Subpart QQQ (see AOC # 9). James observed the hatches on the stormwater lift station with the FLIR camera and noted hydrocarbon emissions from two access hatches (see Appendix 2 – Videos 35-36) (see AOC # 8). When I asked when the carbon was last changed on the new system, Artesia representatives stated that since installation, they have not had breakthrough which would require replacement of the carbon. I reviewed the 2017-2019 daily monitoring data, and the inlet concentration was usually well below 50 ppm. In May 2018 (see Appendix 25) the concentration was 22,000 ppm and after that the concentration ranged typically from 2,000 to 6,000 ppm. In January 2019 (see Appendix 26), I noted a concentration of 37,916 ppm. In March 2019, I saw 20,100 ppm. The concentrations never returned to the pre-May 2018 levels. I later reviewed the P&ID for the new canister system (see CBI Appendix N) and could not locate a flow indicator as required by NSPS Subpart QQQ (see AOC # 7). T-49 Slop Oil Tank – NESHAP Subpart FF - Benzene Waste Organic NESHAP (BWON) Sampling I asked Artesia for the End of Line (EOL) Sampling Plan required by the BWON requirements under the 2002 Refinery Consent Decree. The facility provided the February 6, 2003 plan, to which EPA provided conditional approval in a letter dated January 23, 2004, and the March 31, 2004 plan (see Appendix 27), which has never been approved by EPA. The 2004 plan listed seven (7) sample points: Table 2 – EOL Sample Points Sample Point S-1 S-2 Description Oil from Surge Tank after Wastewater API Oil from Surge Tank after Alky API Consent Decree Reports* Artesia made changes to the wastewater system and the slop oil from the Alky API is diverted through the Wastewater API.** EPA Inspection Report - Page 11 of 1969 Sample Point S-3 S-4 S-5 S-6 S-7 Description Combined water lines from Wastewater and Alky API to Surge/Biological Treatment Tanks Sludge after Contractor Centrifuge/ Heating System – product is cement kiln fuel Aqueous waste from T-40 Caustic Tank Aqueous waste from T-41 Caustic Tank Skimmed hydrocarbon common line from T-40 and T-41 Caustic Tanks Consent Decree Reports* Artesia generated no sludge from 1Q 2016 – 1Q 2019 except for 4Q 2017 (see Appendix 30)*** Artesia has taken T-41 OOS permanently. Last sampling performed 5/9/2019 Samples have not been taken. Comments state that hydrocarbon layer was between the sample point draws on the tank. *Information on sampling is listed in Attachment 3 of the quarterly reports. The report generated for the 2Q 2019 (see Appendix 32) did not have the Attachment 3 included in the report. **At the time of the inspection, Mr. Denton stated that the facility no longer has an Alky API. ***Sample Point S-4 is for shipments of sludge after a contractor centrifuge/heating system. I requested the manifests for shipments for 2017 and 2018. Artesia provided a 15-page document (see Appendix 28) that detailed fifteen (15) shipments of sewer sludge to US Ecology in Robstown, TX from March 18, 2019 through May 15, 2019. Artesia did not provide a manifest for the generated sludge reported in the 4Q 2017 Consent Decree Report and did not include the EOL sampling records in the Consent Decree Quarterly Reports for 4Q 2017, 1Q 2019, and 2Q 2019 (see Appendices 30-32 respectively) (see AOC # 10). Artesia did not report any sludge waste for Sample Point S-4 in the 1Q 2019 Consent Decree Report (see Appendix 31), yet Artesia provided five manifests for March 2019. The calculation for Sample Point S-3 indicated the daily volume to the wastewater tanks was consistently 720,000 gal/day in every Consent Decree Quarterly Report since 1Q 2016 equivalent to 500 gpm. The wastewater system is rated at 1,200 gpm (see AOC # 11). We observed the NESHAP Subpart FF sampling that is performed at EOL Sampling Point S-3 which is the water phase from T-49 Slop Oil tank. T-49 receives material from two (2) sources: 1) oil from the aboveground API separator and 2) a stream that resulted from the 2012 improvements to the wastewater treatment system. Artesia uses a contractor, Aqua Microbics, for their NESHAP Subpart FF sampling. The Consent Decree (see Appendix 29) requires that if changes in processes, operations, or other factors lead Navajo (Artesia) to conclude that the sampling locations no longer provide an accurate measure of the EOL benzene quantity, the company shall submit a revised plan to EPA for approval. The wastewater improvements from 2012 were not a part of the original EOL Sampling Plan and Sample Point S-2 was EPA Inspection Report - Page 12 of 1969 modified. Artesia failed to submit a revised EOL Sampling Plan as required by the Consent Decree (see AOC # 21). Visible Hydrocarbon Emissions from Tanks Observed with FLIR Camera James noted visible hydrocarbon emissions when looking at the following tanks (refer to Table 1 for photos/videos): • IFR tanks T-11, T-12, T-108, T-109, T-415, T-124, and T-417. o T-124 and T-417 have reported Maximum True Vapor Pressure (Max TVP) > 11.0 pounds per square inch absolute (psia). • EFR tanks T-401, T-437, and T-1225. o T-401 and T-1225 had water on top of the floating roof. T-401’s roof did not appear to be floating completely on the liquid surface. The roof was tilted approximately one foot out of level. • Fixed Roof tanks T-431, T-432, T-434. o The Title V permit lists these tanks as storing low vapor pressure material. The presence of visible hydrocarbon emissions with the FLIR camera warrant a review of the actual conditions and operation to ensure the tanks are operating within permit limits (see AOC # 12). T-401 Emissions at the bottom of the tank The NEIC inspectors recorded benzene emissions near T-401 using the GMAP, and they observed and recorded hydrocarbon emissions from the base of the tank when using a FLIR camera to survey the area to locate the source of the benzene. They reported this to the field group, and we walked the circumference of T-401 with a FLIR camera (see Appendix 2 – Videos 28-31) and an MSA Sirius 4-gas meter with a photoionization detector (PID). We observed that the tank had a second floor that was installed. Mr. Denton explained that they had left the old floor in place, put a layer of compacted sand on top, and then installed the new floor on the sand layer. We also observed some small piping from the sand layer and below the original floor. Mr. Denton explained that the piping was a Praxair monitoring system used to detect leaks in the tank floor. The company can put a tracer chemical into the tank’s contents, then monitor at the sample piping for the tracer chemical. The emissions we observed using the FLIR did not appear to be emanating from the Praxair monitoring points. The following are the main areas where we observed issues: • On the north side of the tank, I detected 400 ppm VOCs. • At the water draw and roof drain on the southwest side, James observed emissions and an active drip from the water draw. The operator tightened all of the valves associated with the piping, but the leaks continued. I detected 360 ppm VOCs at the water draw. • At the south-southeast side (under the stairs), I detected 290 ppm VOCs. • On the east side and the left side of the manway, we observed a large stained area on the gravel. I detected 730 ppm VOCs and the LEL meter detected 13% LEL, calibrated to methane. Y-11 and Y-12 Cooling Towers Artesia has Y-1, Y-2, Y-8, Y-11, and Y-12 Cooling Towers that are subject to NESHAP Subpart CC which requires monthly sampling of Heat Exchange Systems using the modified El Paso Method to detect leaks of hydrocarbons into the cooling water. The leak action level is defined as a total strippable hydrocarbon EPA Inspection Report - Page 13 of 1969 HollyFrontier Navajo Refinery LLC / Artesia Refinery Inspection Dates 10/1-4/2019 concentration (as methane) in the stripping gas of 6.2 ppmv. The results of the sampling are included in the NESHAP Subpart CC Semi-annual Reports. We observed the monthly sampling for Cooling Tower (C/T) Y-11 (see Appendix 1 – Photos 7-13). I reviewed the NESHAP CC Reports and noted the following sampling in which the monitoring detected a leak: Table 3 – Heat Exchange System Sampling Cooling Tower Y-8 Y-12 Sample Date 5/16/18 2/26/18 2/28/18 3/1/18 3/6/18 3/9/18 3/27/18 4/2/18 4/3/18 4/19/18 5/7/18 5/16/18 6/22/18 7/12/18 8/6/18 9/20/18 10/25/18 11/26/18 12/28/18 1/9/19 FID concentration Cooling Tower Circulation Rate 31.40 13.43 8.81 12.46 8.74 5.34 13.87 15.00 23.35 30.48 108.50* 33.95 58.72 35.34 19.22 27.88 25.15 60.24 36.36 42.40 12,500 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 10,000 (ppmv) (gpm) Emission Rate (lb/hr) 2.5418 0.9043 0.5992 0.8444 0.5926 0.3507 0.9331 0.9509 1.5203 1.9873 6.7290 2.1823 3.7182 2.2264 1.2279 1.8123 1.4329 4.1033 2.5644 3.0143 Title V Permit Limit - Table 106.H (lb/hr) 6.5 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 0.4 Yellow-highlighted cells are over the permitted emission rate. *The 2018 Emission Inventory (EI) calculation data did not use the highest leak (108.5 ppmv) for May 2018. They used the only other May monitoring (33.95 ppmv). All of the other months that had multiple monitoring, the EI calculation data reflected the higher/highest of each month (see AOC # 13). Artesia had several leaks in Y-12 Cooling Tower beginning in February 2018 and one in Y-8 in May 2018. According to the facility, if they detect a leak and sample each of the HAP-containing heat exchangers, and none are the source of the leak, that is all they are required to do. The leak that started March 27, 2018 has never dropped below the leak definition of 6.2 ppmv through the January 9, 2019 monitoring. 13 EPA Inspection Report - Page 14 of 1969 HollyFrontier Navajo Refinery LLC / Artesia Refinery Inspection Dates 10/1-4/2019 The contractor, Dexter, is not recording the water circulation rate of the C/T at the time of sampling, but using the permitted water circulation rate, the VOC emissions have exceeded the permitted emission rate in Title V Permit P051R2 (see AOC # 14). Artesia did not report these permit rate exceedances in its Title V Annual Compliance Certification Deviation Reports (see AOC # 15). Table 4 – Cooling Tower Permit Limit Exceedance - VOCs Title V Permit Limit - Table 106.H C/T (tpy) Y-1 Y-2 Y-8 Y-11 Y-12 7.9 7.9 28.3 5.5 1.8 2016 EI (tpy) 2017 EI (tpy) 0.230 0.150 7.634 11.573 39.616 0.215 0.255 0.235 2.359 5.356 2018 EI (tpy) 0.028 0.029 0.964 0.314 8.168 Yellow-highlighted cells are permit limit exceedances. The Artesia Refinery exceeded their permitted VOC emission limit in 2016 for the Y-11 C/T and in 20162018 for the Y-12 C/T (see AOC # 16). The refinery did not report the Y-11 and Y-12 VOC permit exceedances in its Title V Annual Compliance Certifications (see AOC # 15). Emission Inventory According to Mr. Smalts, Artesia contracts with Leidos to prepare their annual EI required by NMED. The vapor pressure and chemical speciation of HAPs in the various refinery products used for calculating tank emissions is detailed in the Chemicals tab in the Tank Calcs spreadsheet (see CBI Appendices E, G, I, K) for each year’s Emission Inventory (EI). Most of the sources of the vapor pressure and speciation seemed to be from sources such as AP-42 or other technical sources. During the onsite inspection, we had a conference call with the primary Leidos employees who work on the project: Ms. Kirsten Bates, a Senior Environmental Engineer, and Mr. John Vierow, a Senior Chemical Engineer. Leidos began doing EI and other project for Artesia since the reporting year 2016. Ms. Bates visits the refinery each year to collect the data needed to prepare the EI, Mr. Vierow prepares the EI and enters it in the NMED website, and Artesia submits it. We asked if the chemical speciations were from actual sampling of materials in tanks at Artesia, and Mr. Vierow said he didn’t know. He stated that most of the speciations were historic from prior to 2016. We asked if the speciations were from American Petroleum Institute (API) or AP-42 tables, and Mr. Vierow stated that AP-42 doesn’t typically have speciations. He had not compared the products to API. We asked how they know which speciation to use when a product changes since some of the products have very similar names (e.g. naphtha, light cat naphtha, heavy naphtha). Ms. Bates stated that Leidos relies on the facility. According to HollyFrontier, that decision is made by the Environmental Department and Operations at the refinery. 14 EPA Inspection Report - Page 15 of 1969 I had obtained the reported 2015 through 2018 EI data from NMED prior to the inspection. I noted that in 2016, Artesia reported no benzene emissions. The benzene emissions for 2017 and 2018 were comparable to those reported in 2015. I asked Ms. Bates and Mr. Vierow why no benzene emissions had been reported for 2016, and they stated that they would need to look at their records. The Toxics Release Inventory data had 1,900 lbs emitted from stacks and 430 lbs emitted as fugitives. I asked if Leidos was aware of the FLM monitoring for benzene. Mr. Vierow stated he was not very aware of it, but Ms. Bates was aware of it. I asked if the results of the FLM had been incorporated into the EI data, and Ms. Bates stated that she didn’t believe it had been. Following the conference call with Leidos, we interviewed Ms. Jo Lynn Schneider, Laboratory Manager at the Artesia Refinery. She stated that they test the blend product tanks regularly for vapor pressure, gravity, and detailed hydrocarbon analysis (DHA). Recently they sampled field tanks due to sulfur issues. The data is stored in the LIMS system. Typical methods used at Artesia are as follows: • • • • • Modified ASTM Method D3606 – Benzene. This modified method was developed by Artesia to shorten the test time to 5 minutes duration since they analyze a large number of samples. ASTM Method D3710 – Simulated distillation of petroleum products ASTM Method D5134 – DHA ASTM Method D5453 – Total sulfur content ASTM Method D4052 – Density, relative density, and API Gravity Ms. Schneider stated that the lab tests the overhead stream from Unit 13 which feeds T-57. Also, she stated that each Thursday they sample the feed from T-57 to Unit 20 for benzene, sulfur, DHA, and API gravity. In the 2018 Tank Calcs spreadsheet, there is a notation for Isom Feed that it was changed per August 2018 lab tests for T-57. The notation stated that the molecular weight was changed to gasoline. We asked for those results and any other testing of the material in T-57. Subsequent to the inspection, we received information of testing of Isom Feed for various dates from August 10, 2018 through September 11, 2019. Only the August 10, 2018 analysis indicated it was from T-57 since the name of the sample was “57TK IF.” All of the other samples were named “ISOM FD,” “ISOMFEED,” or “IF,” but T-57 was filled with naphtha bottoms on September 7, 2019, and the VP remained the same. It is not clear where Artesia obtained the samples . For T-57 HollyFrontier has called the material stored since 2012 until late 2019 a “light naphtha stream” in its Corrective Action letters. The 2018 EI used the product titled “Isom Feed” for emission calculations. The Chemicals tab for Isom Feed shows HAPs, but the Tank Emission Summary tab doesn’t indicate HAP emissions from T-57. This is not accurate since the light naphtha stream is the feed for the BenFree unit which removes the benzene from the naphtha. Also, the speciation for Desalter Water doesn’t list any benzene. Desalter water is typically a significant source of benzene. The tank that does store desalter water is listed as storing Sour Water in the Tank Emission Summary. This material doesn’t have HAP emissions shown on the Chemicals tab. Artesia stated in the July 3, 2019 Amended Corrective EPA Inspection Report - Page 16 of 1969 Action Plan that T-737 may be contributing to benzene fenceline concentrations. The EI Tank Calcs files do not have any HAP speciation for T-737 Sour Water tank. I reviewed the tank landing information for the four years of EI calculations: • 2015 tank landing are on the Tank SSM tab of the EI file (see CBI Appendix D). Landings or Idle/degas loss (13 tanks): T-402, T-835, T-79, T-412, T-402, T-108, T-412, T-109, T-415, T-450, T-12, T-106, T-108 • 2016 tank landings are on the Tank SSM tab of the EI file (see CBI Appendix F). Landing (2 tanks): T-835 (diesel 0.02 lbs), T-56 (naphtha 57 lbs) • 2017 tank landings are on the Tank SSM tab of the EI file (see CBI Appendix H). Notes on the spreadsheet state that the data source used for 2016 is no longer maintained by the refinery, so the contractor reviewed individual event files and found no landing events. The contractor verified this with Ms. Staci Hammond. • 2018 EI file (see CBI Appendix J) did not have a Tank SSM tab. I am not able to determine if Artesia included tank landing data in the EI reporting. The accuracy of the reported emissions to the EI database is of concern (see AOC # 17). As part of the Emission Inventory preparation, the calculated emissions are compared to permitted limits and limits to operating conditions (e.g. temperature, maximum true vapor pressure) and the comparison is reflected as a percent of the allowable or with a notation “Max Over” if the Max TVP exceeded the limit in the permit, or “Both Over” if the Max TVP and Average TVP exceeded the limit in the permit. The following permit exceedances were noted in the EI and Tank Calcs data: Table 5 – Emission and Operational Permit Deviations noted in EI files Year 2015 Category Permit Throughput Sour Water Tank Temp – VP T-107 Max TVP T-411 Max TVP T-422 Max TVP T-423 Max TVP Hydrogen Plant Reformer Furnaces NOx Hydrogen Plant Reformer NOx Distillates Sour Water T-107 Max TVP T-411 Max TVP T-422 Max TVP T-423 Max TVP EI Summary 2016 Description Permit Throughput Tank Temp – VP Actual Permitted 45,051 bbl/yr Actual % of Allowable 11.05 psia 11.05 psia 0.95 psia 0.89 psia 21.43 tpy 11.0 psia 11.0 psia 0.5 psia 0.5 psia 18.4 tpy 116% 24.86 tpy 18.5 tpy 134% 11.86 psia 11.86 psia 1.04 psia 1.36 psia 55,076,590 bbl/yr** 45,051 bbl/yr** 11.0 psia 11.0 psia 0.5 psia 0.5 psia EPA Inspection Report - Page 17 of 1969 Year Category SSM SRU2-TGI SSM Flare Cap EI Summary 2017 Permit Throughput Tank Temp-VP EI Summary 2018 Permit Throughput Tank Emission Summary Tank Temp – VP Description Actual Permitted Actual % of Allowable T-435 Max TVP 11.21 psia 11.0 psia T-437 Max TVP 11.21 psia 11.0 psia T-452 Max TVP 1.91 psia 1.82 psia T-452 Avg TVP 0.82 psia (blank) T-1225 Max TVP 11.21 psia 11.0 psia SO2 1.76 tpy 0.4 tpy 440% VOC 27.79 tpy 13.2 tpy 211% SO2 15.92 tpy 14.9 tpy 107% North Flare VOCs 1.06 tpy 0.7 tpy 151% South Flare VOCs 0.26 tpy 0.2 tpy 132% Alky Flare VOCs 0.26 tpy 0.2 tpy 132% Y-11 Cooling 11.57 tpy 5.5 tpy 210% Tower VOCs Y-12 Cooling 39.62 tpy 1.8 tpy 2201% Tower VOCs Distillates 55,076,590 bbl/yr** Sour Water 45,051 bbl/yr** Not in file provided by HollyFrontier although it is referenced in the Tank Temp Entry tab. North Flare VOCs 1.06 tpy 0.7 tpy 151% South Flare VOCs 0.26 tpy 0.2 tpy 132% Alky Flare VOCs 0.26 tpy 0.2 tpy 132% Y-12 Cooling 5.36 tpy 1.8 tpy 298% Tower VOCs SRU3 SSM SO2 0.72 tpy 0.4 tpy 181% SRU2 SSM SO2 1.76 tpy 0.4 tpy 440% Flare SSM Cap 27.79 tpy 13.2 tpy 211% VOCs Flare SSM Cap 15.92 tpy 14.9 tpy 107% SO2 Sour Water 45,051 bbl/yr** Distillates 55,076,590 bbl/hr** Floating Roof Tank 104.9 tpy 87.6 tpy 119.7% VOCs T-49 Max TVP 2.58 psia 1.5 psia o T-57 Max Temp 107.8 F * 90oF (ambient) T-57 Max TVP 15.21 psia 11.0 psia T-106 Max TVP 11.38 psia 11.0 psia T-107a Max TVP 14.58 psia 11.0 psia EPA Inspection Report - Page 18 of 1969 Year Category EI Summary Description T-111 Max TVP T-124 Max TVP FUG-RLOASPHALT VOC Y-11 Cooling Tower VOC SSM Flare Cap VOC Flares Malfunction Cap SO2 Actual Permitted Actual % of Allowable 19.65 psia 12.97 psia 2.95 tpy 11.0 psia 11.0 psia 2.9 tpy 102% 8.17 tpy 1.8 tpy 454% 70.96 tpy 18.3 tpy 538% 14.43 tpy 10 tpy 144% * Artesia provided the PI data for T-57, including tank temperature (see CBI Appendix L). This data revealed that the maximum tank temperature was . **The permitted throughput of Sour Water and Distillates was increased to 15,030,000 bbl/yr and 158,185,540 bbl/yr, respectively, with the Permit PSD-NM-0195-M37 issued August 12, 2016 (see Appendix 21). The EI consultant continued to use the old limits. Maximum True Vapor Pressure The Tank Applicability file also has information about the Max TVP. According to the spreadsheet, Artesia obtained this information from the 2018 Emission Inventory. When a tank operated with more than one product during the year, the applicability of the tank for each operating scenario is denoted with a letter behind the tank name (e.g. T-57a for light naphtha operation and T-57b for heavy naphtha operation). For T-57a, we noted a Max TVP of There is a Tank Table tab in the Tanks Applicability file that lists tanks with a Max TVP > . T-101B is a tank at the Lovington Refinery. When reviewing each of the tank tabs, I noted an additional tank T-107a. The following table is a list of tanks with a Max TVP > from the individual tank worksheets in the Tank Applicability file: Table 6 – Tanks with Max TVP ≥ 11.1 psia Tank T-57a T-106 T-107a T-111 T-124 T-0411a T-417 Max TVP (psia) Tank Type Permitted Content Group EFR IFR IFR IFR IFR EFR IFR Naphtha Distillates Gasolines Naphtha Gasolines Gasolines Gasolines 1 2* 1 1 1 1 1 *T-106 is listed as a Group 2 tank because the HAP weight % is listed as 0 for this product. This tank actually stores desalter water, one of the highest benzene contributors in the NESHAP Subpart FF Total Annual Benzene (TAB) Report (see AOC # 18). EPA Inspection Report - Page 19 of 1969 For NESHAP Subpart CC Group 1 tanks subject to 40 C.F.R. § 63.646 and NESHAP Subpart G, if the Max TVP ≥ 11.1 psia, the tank must have a closed vent system with a control device to control emissions. For NESHAP Subpart CC Group 1 tanks subject to 40 C.F.R. § 63.660 and the Max TVP ≥ 11.1 psia, NESHAP Subpart CC requires compliance with NESHAP Subpart SS which requires a closed vent system and a control device. Artesia has several tanks that they document in the Tank Applicability file a Max TVP ≥ 11.1 psia (see Table 6) and in the EI files (see Table 5) that do no currently have a closed vent system and control device. (see AOC # 19). Tank 49 – Slop Oil Tank Information T-49 is permitted as a fixed roof tank that is permitted to store moderate vapor pressure material. In the Tank Applicability file, T-49 is described as being a pressure vessel (PRS Roof Type) and exempt from Subpart CC group applicability. In the 2018 Tank Calcs (see Appendix K) file for Emission Inventory reporting, T-49 is reflected as a fixed roof tank. T-49 is not included in the Tank List (see CBI Appendix B) that was provided as part of the records request during the inspection (see AOC #20). T-451 and T-452 Tank Information The construction date for T-451 and T-452 is 2015 and each have a capacity of 6,900 bbls. The permit is unclear about the applicability and operation of these tanks. The following table is a history of the applicability and operations to help identify the correct applicability: Table 7 – T-451 and T-452 history Title V Permit P051R2M1 (1/22/16) Modification with the renewal is to install 2 new tanks. Table 103.C Applicability Table 106.B(2) EFR Tanks Table 106.C Fixed Roof Tanks Table 106.D Storage Tank Throughput and Temperature Limits PSD-NM-0195-M37 (8/12/16) (see Appendix 21) Tanks constructed as IFR tanks rather than EFR and fixed roof. Added tank ID numbers. Table 103.C Applicability Table 106.B(1) IFR Tanks Table 106.D Storage Tank Throughput and Temperature Limits Tank Applicability spreadsheet Biodiesel Tank Ethanol Tank NSPS Subpart Kb TK-NEWETHANOL (high VP) TK-NEWBIODIESEL (low VP) Biodiesel: 949,000 bbl/yr NESHAP Subpart CC T-0451 Biodiesel (high VP) Biodiesel: 949,000 bbl/yr NSPS Subpart Kb T-0452 Ethanol (high VP) Ethanol: 142,350 bbl/yr T-0451 Biodiesel IFR Group 2 T-0452 Ethanol IFR Group 2 EPA Inspection Report - Page 20 of 1969 Title V Permit application (May 2019) (see Appendix 22) Table 2-A: Regulated Emission T-0451 IFR Sources (formerly TK-NEWETHANOL) Table 2-L: Tank Data Installed: 2016 Low VP IFR Floating Roof Tank SSM Not listed Potential to Emit Tank List (see CBI Appendix B) Not Listed T-0452 IFR (formerly TK-NEWBIODIESEL) Installed: 2016 High VP IFR Not listed Not listed Yellow-highlighting is used to document the inconsistency of information from earlier permits, within a permitting action, or from other documents from Artesia. Artesia has conflicting information about tanks T-49, T-451, and T-452, and in some cases, the tanks are not included in tank inventories (see AOC # 20). Title V Reporting of Permit Deviations I reviewed the Title V Annual Compliance Certifications (ACC) for the September – August periods ending in August 2016 – 2019 (see Appendices 17-20). The permit deviations detailed in the EI files for each year and compiled in Table 2 above, with the exception of the Distillates and Sour Water throughputs for 2016-2018, were not reported in the Deviation Reports that are submitted as part of each ACC (see AOC # 15). At the end of each of the ACC reports are Excess Emission Reports (EER). The 2016 ACC had six (6) EERs from November 2015. Those same EERs are also in the reports for 2017, 2018, and 2019. It is unclear why they continue to be reported. Closeout Conference EPA inspectors Debbie Ford, James Haynes, and Richard Helmich and ERG inspector Dan Roper held a closeout conference on Friday, October 4, 2019. Attendees representing the Artesia Refinery were Scott Denton, Ray Smalts, Staci Hammond, Theresa Wheeler, and Parrish Miller. Also, representing the facility via phone were Sucheta Gokhale, Ray Bagherian, HollyFrontier Corporation Counsel, and Tom Shetina, Senior Vice-President Refinery Operations. I reviewed twenty (20) preliminary Areas of Concern during the close-out conference. Afterward, I received a list of documents requested during the inspection which was color-coded to indicate the documents received and the documents that were still outstanding. Section III – AREAS OF CONCERN 1. Artesia is not calculating the gap areas correctly for primary and secondary seal gap measurements. 2. Artesia does not maintain a current drawing of T-57 and its floating roof fittings. EPA Inspection Report - Page 21 of 1969 3. At the time of the inspection, the tank was below the 8.5’ level that the company said triggers the opening of the vacuum breaker. 4. Artesia failed to provide a written report of within 30 days of the March 18 and 27, 2019 failed seal inspections of T-737. 5. Artesia took more than 45 days to empty tank T-737 to repair defects found during inspections on March 18 and 27, 2019. 6. Artesia has left DOR component Tag # 2720 in Unit 30 leaking for over 10 years. LDAR monitoring has detected VOCs as high as 500,000 ppm (50% in atmosphere). 7. Artesia did not design and operate the API Separator and New Stormwater Lift Station closed vent systems and control devices with a flow indicator to ensure that vapors are routed to the carbon canisters. 8. Artesia did not route emissions from the sump lift station near the aboveground API Separator and the New Stormwater Lift Station to the carbon canister systems. 9. Artesia designed and installed new equipment and a closed vent system with carbon canister controls in the wastewater system in 2012 that would be subject to NSPS Subpart QQQ but failed to include this information in their operating permits. 10. Artesia did not include the EOL sampling records for the sewer sludge disposed in 4Q 2017, 1Q 2019, and 2Q 2019 in the Consent Decree Quarterly Reports. 11. Artesia may not be including all information when calculating the quarterly benzene quantity and the estimated annual benzene quantity. 12. Artesia may have unauthorized emissions from some tanks at the facility. 13. The Artesia EI for 2018 did not correctly calculate VOC emissions for Y-12 Cooling Tower. 14. Artesia exceeded the permitted emission rate for the Y-12 Cooling Tower from February – January 2019. 15. Artesia failed to report in Title V Annual Compliance Certifications that the facility had exceeded the permitted VOC emission rate at Y-12 cooling tower, that the facility had exceeded the permitted VOC emission limit for Y-11 Cooling Tower in 2016 and Y-12 Cooling Tower in 2016, 2017, and 2018; and the permit limit exceedances that were detailed in the Emission Inventory data files. 16. Artesia failed to operate the Y-11 Cooling Tower in 2016 and the Y-12 Cooling Tower in 20162018 within its permitted annual VOC emission limit. 17. The Emission Inventory reporting may not be accurate. Artesia did not report any benzene emissions for 2016. Artesia did not report benzene emissions from T-57 tank, T-737 Sour Water tank, and the Desalter Water tank. Artesia did not report any emissions that would reflect the elevated benzene emissions detected by the FLM program. Artesia may not be including all of the tank maintenance or tank landing emissions. Artesia doesn’t use actual product sampling for calculating emissions from tanks. 18. Artesia did not accurately make group determinations for tanks as required by NESHAP Subpart CC. 19. Artesia has stored materials with maximum true vapor pressures ≥ 11.1 psia in tanks T-57, T106, T-107, T-111, T-124, T-411, T-417, T-435, T-437, T-1225 that are not controlled by a closed vent system and control device. EPA Inspection Report - Page 22 of 1969 20. Artesia provided conflicting information about T-49 (described as a pressure vessel and as a fixed roof tank but not included in the Tank List for the facility), T-451 (originally described as a biodiesel fixed roof tank with low VP material, later as a IFR high VP tank, then low VP, not included in permit application SSM potential to emit tables, not included in the Tank List for the facility), and T-452 (not included in permit application SSM potential to emit tables, not included in the Tank List for the facility). 21. Artesia failed to submit a revised EOL Sampling Plan when improvements were made to the wastewater system in 2012. 22. Artesia did not require inspectors to watch a safety videos or instruct inspectors on basic emergency procedures such as muster points or warning sirens. 23. Artesia is not performing gap measurements of EFR tanks properly for primary seal measurements greater than 1/2” and is not using the proper probes to measure gaps for tanks subject to NESHAP Subpart WW. Section IV – FOLLOW-UP Subsequent to the inspection, the outstanding documents were submitted to EPA on October 16, 2019 (HFNA-VOL02-10.16.2019.zip) and October 18, 2019 (HFNA-VOL03-10.18.2019.zip). The documents that were received on October 4, 2019 were re-submitted to EPA on October 25, 2019 (HFNA-VOL0110.04.2019.zip). On Friday, October 18, 2019, James Haynes and I held a video conference with HollyFrontier to interview Mr. Omar Dominguez, tank inspector for the Artesia Refinery. Mr. Bagherian participated in the call. Ms. Cheryl Barnett, EPA Office of Regional Counsel, participated in the call for EPA Region 6. At that time, I requested additional records which HollyFrontier provided on October 29, 2019 (HFNA-VOL0410.29.2019.zip). HollyFrontier provided records submitted to EPA subsequent to the inspection via Sidley sharefile and documents were Bates stamped. On October 11, 2019, HollyFrontier submitted a third amendment to the NESHAP Subpart CC Corrective Action Plan (see Appendix 12). Section V – LIST OF APPENDICES Appendix 1 – Photo Log – 76 photos taken 10/1-4/2019 Appendix 2 – Video Log – 36 FLIR videos taken 10/2-4/2019 Appendix 3 – Inspection sign-in sheet Appendix 4 – West Tank Area map Appendix 5 – North Center (Wastewater) Area map Appendix 6 – East Tank Area map Appendix 7 – South Tank Area map Appendix 8 – Center Tank Area map EPA Inspection Report - Page 23 of 1969   HollyFrontier Navajo Refinery LLC / Artesia Refinery  Inspection Dates 10/1‐4/2019    Appendix 9 – Corrective Action Plan dated 5/15/2019  Appendix 10 – Corrective Action Plan Amendment dated 7/3/2019  Appendix 11 – Corrective Action Plan Amendment 2 dated 9/3/2019  Appendix 12 – Corrective Action Plan Amendment 3 dated 10/11/2019  Appendix 13 – Title V Permit P051‐R2 issued 5/6/2015, selected pages  Appendix 14 – NESHAP Subpart CC Notice of Seal Inspections dated 7/16/2019  Appendix 15 – NESHAP Subpart CC Notice of 2019 Tank Inspections dated 12/12/2018  Appendix 16 – (not referenced in the inspection report)   Appendix 17 – Title V Annual Compliance Certification Aug 2016  Appendix 18 – Title V Annual Compliance Certification Aug 2017  Appendix 19 – Title V Annual Compliance Certification Aug 2018  Appendix 20 – Title V Annual Compliance Certification Aug 2019  Appendix 21 – Permit PSD‐NM‐0195‐M37 issued 8/12/2016, selected pages   Appendix 22 – Title V Permit P051‐R3 Application, selected pages  Appendix 23 – Leak Detection and Repair Delay of Repair Report  Appendix 24 – SRU #2 DOR Component 2720 Monitoring History  Appendix 25 – Carbon Canister Daily Monitoring 2018  Appendix 26 – Carbon Canister Daily Monitoring 2019  Appendix 27 – End‐of‐Line Sampling Plan dated 3/31/2004  Appendix 28 – Sewer Sludge Manifests for March – May 2019  Appendix 29 – Artesia Refinery Consent Decree, selected pages  Appendix 30 – Consent Decree Report for 4Q 2017  Appendix 31 – Consent Decree Report for 1Q 2019  Appendix 32 – Consent Decree Report for 2Q 2019    CBI Appendices – Do not publish    CBI Appendix A – Tank Applicability (HFNA‐5934)    CBI Appendix B – Tank List (HFNA‐5955)    CBI Appendix C – T‐57 Floating roof design (HFNA‐6141)    CBI Appendix D – 2015 Artesia EI.xlsx (HFNA‐0001)    CBI Appendix E – 2015 Tank Calcs.xls (HFNA‐0002)    CBI Appendix F – 2016 Artesia EI.xlsx (HFNA‐0003)    CBI Appendix G – 2016 Tank Calcs.xls (HFNA‐0004)    CBI Appendix H – 2017 Artesia EI.xlsx (HFNA‐0005)    CBI Appendix I – 2017 Tank Calcs.xls (HFNA‐0006)    CBI Appendix J – 2018 Artesia EI.xlsx (HFNA‐0007)    CBI Appendix K – 2018 Tank Calcs.xlsx (HFNA‐0008)    CBI Appendix L – T‐57 PI Data (HFNA‐6186)    CBI Appendix M – T‐737 Inspection Records (HFNA‐5949)    CBI Appendix N – Wastewater API drawings (HFNA‐6646)    CBI Appendix O – Wastewater system 2012 project (HFNA‐6642)    23  EPA Inspection Report - Page 24 of 1969 Appendix 1 Photograph Log EPA Inspection Report - Page 25 of 1969 1 DATE/TIME: 10/1/2019 FILENAME: DSCN0359-01.jpg DESCRIPTION: TAKEN BY: 3:26 p.m. T-57 roof and slotted gauge hatch. James Haynes EPA Inspection Report - Page 26 of 1969 2 DATE/TIME: 10/1/2019 FILENAME: DSCN0360.jpg DESCRIPTION: TAKEN BY: 3:27 p.m. T-57 roof. Note socks on legs. The sock on the vacuum breaker, indicated by the red arrow, was damaged when the roof was landed. James Haynes EPA Inspection Report - Page 27 of 1969 DATE/TIME: 10/1/2019 FILENAME: DSCN0361.jpg 3 DESCRIPTION: TAKEN BY: 3:27 p.m. T-57 roof. The bulge in the wall on the pontoon was to allow the automatic gauge cable to pass through the roof deck. At the time of the inspection, the cable was broken. James Haynes EPA Inspection Report - Page 28 of 1969 4 DATE/TIME: 10/1/2019 FILENAME: DSCN0362.jpg DESCRIPTION: TAKEN BY: 3:28 p.m. T-57 roof looking down the tank ladder. James Haynes EPA Inspection Report - Page 29 of 1969 5 DATE/TIME: 10/1/2019 FILENAME: DSCN0363.jpg DESCRIPTION: TAKEN BY: 3:29 p.m. T-57 roof, left side. James Haynes EPA Inspection Report - Page 30 of 1969 6 DATE/TIME: 10/1/2019 FILENAME: DSCN0364.jpg DESCRIPTION: TAKEN BY: 3:41 p.m. T-57 nameplate. James Haynes EPA Inspection Report - Page 31 of 1969 7 DATE/TIME: 10/2/2019 FILENAME: DSCN0392.jpg DESCRIPTION: TAKEN BY: 2:18 p.m. TVA 1000 and calibration gases for cooling tower sampling. Debbie Ford EPA Inspection Report - Page 32 of 1969 8 DATE/TIME: 10/2/2019 FILENAME: DSCN0393.jpg DESCRIPTION: TAKEN BY: 2:21 p.m. Return line from heat exchangers for CY-11 Cooling Tower. Debbie Ford EPA Inspection Report - Page 33 of 1969 9 DATE/TIME: 10/2/2019 FILENAME: DSCN0394.jpg DESCRIPTION: TAKEN BY: 2:22 p.m. Sample line being connected to heat exchanger return line for CY-11 Cooling Tower sampling. Debbie Ford EPA Inspection Report - Page 34 of 1969 10 DATE/TIME: 10/2/2019 FILENAME: DSCN0365.jpg DESCRIPTION: TAKEN BY: 2:55 p.m. Sampling apparatus for Modified El Paso Method. James Haynes EPA Inspection Report - Page 35 of 1969 11 DATE/TIME: 10/2/2019 FILENAME: DSCN0395-01.jpg DESCRIPTION: TAKEN BY: 2:56 p.m. Run #1 for CY-11 Cooling Tower. Debbie Ford EPA Inspection Report - Page 36 of 1969 12 DATE/TIME: 10/2/2019 FILENAME: DSCN0366.jpg DESCRIPTION: TAKEN BY: 3:09 p.m. CY-11 Cooling Tower sampling point on heat exchanger return line. James Haynes EPA Inspection Report - Page 37 of 1969 13 DATE/TIME: 10/2/2019 FILENAME: DSCN0367.jpg DESCRIPTION: TAKEN BY: 3:10 p.m. Close-up of Modified El Paso Method sampling apparatus. James Haynes EPA Inspection Report - Page 38 of 1969 Navajo Re?ning, LLC/Artesia Re?nery FRS 1100 0047 2630 501 E. Main Street, Artesia, NM 88210 Eddy County 10/2/2019 3:11 p.111. 14 T-4l7 tank. Visible emissions observed with FLIR infrared camera from tank DESCRIPTION: vents. TAKEN BY: Debbie Ford EPA Inspection Report - Page 39 of 1969 15 DATE/TIME: 10/2/2019 FILENAME: DSCN0402.jpg DESCRIPTION: TAKEN BY: 3:32 p.m. T-124 tank. Visible emissions observed with FLIR infrared camera. Debbie Ford EPA Inspection Report - Page 40 of 1969 16 DATE/TIME: 10/2/2019 FILENAME: DSCN0404.jpg DESCRIPTION: TAKEN BY: 4:00 p.m. T-49 Slop Oil Tank - BWON sampling in Wastewater Unit. Debbie Ford EPA Inspection Report - Page 41 of 1969 17 DATE/TIME: 10/2/2019 FILENAME: DSCN0405.jpg DESCRIPTION: TAKEN BY: 4:05 p.m. T-49 Slop Oil Tank BWON sampling in Wastewater Unit. Collection of sample after passing through the chiller. Debbie Ford EPA Inspection Report - Page 42 of 1969 18 DATE/TIME: 10/2/2019 FILENAME: DSCN0406.jpg DESCRIPTION: TAKEN BY: 4:08 p.m. T-49 Slop Oil Tank BWON sampling in Wastewater Unit. Collection of sample after passing through the chiller. Debbie Ford EPA Inspection Report - Page 43 of 1969 19 DATE/TIME: 10/2/2019 FILENAME: DSCN0407.jpg DESCRIPTION: TAKEN BY: 4:18 p.m. Aboveground API Separator – west side. Note the clamps for sealing the roof of the separator. Visible emissions observed with the FLIR infrared camera. Debbie Ford EPA Inspection Report - Page 44 of 1969 20 DATE/TIME: 10/2/2019 FILENAME: DSCN0408.jpg DESCRIPTION: TAKEN BY: 4:18 p.m. Aboveground API Separator (west side) with carbon canister system used as the control device. Note the clamps for sealing the roof of the separator. Visible emissions observed with the FLIR infrared camera. Debbie Ford EPA Inspection Report - Page 45 of 1969 21 DATE/TIME: 10/2/2019 FILENAME: DSCN0409.jpg DESCRIPTION: TAKEN BY: 4:23 p.m. Aboveground API Separator. West separator on the right. East separator on the left. Note the clamps for sealing the roof of the separator. Visible emissions observed with the FLIR infrared camera on both separators. Debbie Ford EPA Inspection Report - Page 46 of 1969 Navajo Re?ning, LLC/Artesia Re?nery FRS 1100 0047 2630 501 E. Main Street, Artesia, NM 88210 Eddy County )7 22 10/2/2019 4:36 p.m. FILENANIE: Abovegromid API Separator (east side). Note the clamps for sealing DESCRIPTION: the roof of the separator. Visible emissions observed with the FLIR infrared camera. TAKEN BY: Debbie Ford EPA Inspection Report - Page 47 of 1969 23 DATE/TIME: 10/2/2019 FILENAME: DSCN0369.jpg DESCRIPTION: TAKEN BY: 4:52 p.m. Control Room display of temperatures into and out of fin-fan cooler X-187 and heat exchangers X-571, X-572, X-172. The stream out of the coolers/heat exchangers is the feed to T-57. James Haynes EPA Inspection Report - Page 48 of 1969 24 DATE/TIME: 10/3/2019 FILENAME: DSCN0370.jpg DESCRIPTION: TAKEN BY: 9:45 a.m. Fenceline Monitoring System - Sample Point 7 on the east side of the facility near T-11. James Haynes EPA Inspection Report - Page 49 of 1969 25 DATE/TIME: 10/3/2019 FILENAME: DSCN0411.jpg DESCRIPTION: TAKEN BY: 9:43 a.m. Fenceline Monitoring System - Sample Point 7. Holder open to show the passive sample tubes. Debbie Ford EPA Inspection Report - Page 50 of 1969 26 DATE/TIME: 10/3/2019 FILENAME: DSCN0412.jpg DESCRIPTION: TAKEN BY: 9:49 a.m. T-11 tank (left). To the north is T-12 tank (right). Visible emissions observed with the FLIR infrared camera from both tanks. Debbie Ford EPA Inspection Report - Page 51 of 1969 DATE/TIME: 27 FILENAME: DESCRIPTION: TAKEN BY: 10/3/2019 9:52 a.m. DSCN0371.jpg T-11 vent. James Haynes EPA Inspection Report - Page 52 of 1969 28 DATE/TIME: 10/3/2019 FILENAME: DSCN0372.jpg DESCRIPTION: TAKEN BY: 9:53 a.m. T-11. James Haynes EPA Inspection Report - Page 53 of 1969 29 DATE/TIME: 10/3/2019 FILENAME: DSCN0373.jpg DESCRIPTION: TAKEN BY: 10:07 a.m. T-12 tank. Visible emissions observed with the FLIR infrared camera. James Haynes EPA Inspection Report - Page 54 of 1969 30 DATE/TIME: 10/3/2019 FILENAME: DSCN0374.jpg DESCRIPTION: TAKEN BY: 10:08 a.m. T-12 tank. James Haynes EPA Inspection Report - Page 55 of 1969 31 DATE/TIME: 10/3/2019 FILENAME: DSCN0375.jpg DESCRIPTION: TAKEN BY: 10:16 a.m. T-11 tank. James Haynes EPA Inspection Report - Page 56 of 1969 32 DATE/TIME: 10/3/2019 FILENAME: DSCN0376.jpg DESCRIPTION: TAKEN BY: 10:21 a.m. T-108 tank. Visible emissions observed with the FLIR infrared camera. James Haynes EPA Inspection Report - Page 57 of 1969 33 DATE/TIME: 10/3/2019 FILENAME: DSCN0377.jpg DESCRIPTION: TAKEN BY: 10:32 a.m. T-415 tank. Visible emissions observed with the FLIR infrared camera. James Haynes EPA Inspection Report - Page 58 of 1969 34 DATE/TIME: 10/3/2019 FILENAME: DSCN0378.jpg DESCRIPTION: TAKEN BY: 10:36 a.m. T-109 tank. Visible emissions observed with the FLIR infrared camera. James Haynes EPA Inspection Report - Page 59 of 1969 35 DATE/TIME: 10/3/2019 FILENAME: DSCN0379.jpg DESCRIPTION: TAKEN BY: 10:44 a.m. T-108 tank back. James Haynes EPA Inspection Report - Page 60 of 1969 36 DATE/TIME: 10/3/2019 FILENAME: DSCN0380.jpg DESCRIPTION: TAKEN BY: 10:46 a.m. T-109 tank. James Haynes EPA Inspection Report - Page 61 of 1969 37 DATE/TIME: 10/3/2019 FILENAME: DSCN0414.jpg DESCRIPTION: TAKEN BY: 10:52 a.m. T-401 tank. Visible emissions observed with the FLIR infrared camera from the top of the floating roof and the base of the tank. Debbie Ford EPA Inspection Report - Page 62 of 1969 38 DATE/TIME: 10/3/2019 FILENAME: DSCN0381.jpg DESCRIPTION: TAKEN BY: 11:03 a.m. T-401 tank left side. Roof not floating on liquid surface. Right side approximately 1 foot lower than the left side. Water observed on approximately ½ of the surface of the roof deck. Visible emissions observed with the FLIR camera. James Haynes EPA Inspection Report - Page 63 of 1969 39 DATE/TIME: 10/3/2019 FILENAME: DSCN0382.jpg DESCRIPTION: TAKEN BY: 11:03 a.m. T-401 tank center view. Roof not floating on liquid surface. Right side approximately 1 foot lower than the left side. Water observed on approximately ½ of the surface of the roof deck. Visible emissions observed with the FLIR camera. James Haynes EPA Inspection Report - Page 64 of 1969 40 DATE/TIME: 10/3/2019 FILENAME: DSCN0383.jpg DESCRIPTION: TAKEN BY: 11:03 a.m. T-401 tank right side. Roof not floating on liquid surface. Right side approximately 1 foot lower than the left side. Water observed on approximately ½ of the surface of the roof deck. Visible emissions observed with the FLIR camera. James Haynes EPA Inspection Report - Page 65 of 1969 41 DATE/TIME: 10/3/2019 FILENAME: DSCN0384.jpg DESCRIPTION: TAKEN BY: 11:04 a.m. T-401 tank right side. Roof not floating on liquid surface. Right side approximately 1 foot lower than the left side. Water observed on approximately ½ of the surface of the roof deck. Visible emissions observed with the FLIR camera. James Haynes EPA Inspection Report - Page 66 of 1969 42 DATE/TIME: 10/3/2019 FILENAME: DSCN0385.jpg DESCRIPTION: TAKEN BY: 11:17 a.m. T-401 tank slotted Guidepole on right side. Roof not floating on liquid surface. Right side approximately 1 foot lower than the left side. Water observed on approximately ½ of the surface of the roof deck. Visible emissions observed with the FLIR camera. James Haynes EPA Inspection Report - Page 67 of 1969 43 DATE/TIME: 10/3/2019 FILENAME: DSCN0386.jpg DESCRIPTION: TAKEN BY: 11:21 a.m. #3 Blending Pit. James Haynes EPA Inspection Report - Page 68 of 1969 44 DATE/TIME: 10/3/2019 FILENAME: DSCN0387.jpg DESCRIPTION: TAKEN BY: 11:21 a.m. #3 Blending Pit. James Haynes EPA Inspection Report - Page 69 of 1969 45 DATE/TIME: 10/3/2019 FILENAME: DSCN0415.jpg DESCRIPTION: TAKEN BY: 11:31 a.m. T-1225 Crude oil tank. Debbie Ford EPA Inspection Report - Page 70 of 1969 46 DATE/TIME: 10/3/2019 FILENAME: DSCN0416.jpg DESCRIPTION: TAKEN BY: 11:31 a.m. T-1225 Crude oil tank (foreground); T-437 Crude oil tank (background) Debbie Ford EPA Inspection Report - Page 71 of 1969 47 DATE/TIME: 10/3/2019 FILENAME: DSCN0388.jpg DESCRIPTION: TAKEN BY: 11:37 a.m. T-1225 Crude Oil Tank left side. Water observed on surface of roof deck. Visible emissions observed with the FLIR infrared camera. James Haynes EPA Inspection Report - Page 72 of 1969 48 DATE/TIME: 10/3/2019 FILENAME: DSCN0389.jpg DESCRIPTION: TAKEN BY: 11:37 a.m. T-1225 Crude Oil Tank left side. Water observed on surface of roof deck. James Haynes EPA Inspection Report - Page 73 of 1969 49 DATE/TIME: 10/3/2019 FILENAME: DSCN0390.jpg DESCRIPTION: TAKEN BY: 11:37 a.m. T-1225 Crude Oil Tank center view. Water observed on surface of roof deck. James Haynes EPA Inspection Report - Page 74 of 1969 50 DATE/TIME: 10/3/2019 FILENAME: DSCN0391.jpg DESCRIPTION: TAKEN BY: 11:38 a.m. T-1225 Crude Oil Tank right side. Water observed on surface of roof deck. James Haynes EPA Inspection Report - Page 75 of 1969 51 DATE/TIME: 10/3/2019 FILENAME: DSCN0392.jpg DESCRIPTION: TAKEN BY: 11:38 a.m. T-1225 Crude Oil Tank right side. Water observed on surface of roof deck. James Haynes EPA Inspection Report - Page 76 of 1969 52 DATE/TIME: 10/3/2019 FILENAME: DSCN0393.jpg DESCRIPTION: TAKEN BY: 12:01 p.m. T-431 tank. Visible emissions observed with the FLIR infrared camera at the staining on the right side of the tank. James Haynes EPA Inspection Report - Page 77 of 1969 53 DATE/TIME: 10/3/2019 FILENAME: DSCN0394.jpg DESCRIPTION: TAKEN BY: 12:09 p.m. T-432 tank. Visible emissions observed with the FLIR infrared camera from the tank vent on the right (at the tank staining) and possible emissions at the edge of the roof where the tank staining is on the left. James Haynes EPA Inspection Report - Page 78 of 1969 54 DATE/TIME: 10/3/2019 FILENAME: DSCN0395.jpg DESCRIPTION: TAKEN BY: 12:15 p.m. T-434 Raw Diesel tank. Visible emissions observed with the FLIR infrared camera. James Haynes EPA Inspection Report - Page 79 of 1969 55 DATE/TIME: 10/3/2019 FILENAME: DSCN0396.jpg DESCRIPTION: TAKEN BY: 12:21 p.m. T-417 tank (middle tank). Visible emissions observed with the FLIR infrared camera. James Haynes EPA Inspection Report - Page 80 of 1969 Navajo Re?ning, LLC/Artesia Re?nery FRS 1100 0047 2630 501 E. Main Street, Artesia, NM 88210 Eddy County 10/4/2019 9:46 a.m. FILENAME: T-401 Isom (gasoline) tank. Visible emissions observed with the 56 DES infrared camera. Praxair monitors to detect leaks located between the old tank ?oor and the new one as well as below the concrete foundation. Emissions detected were not ?om the installed monitors. TAKEN BY: Debbie Ford EPA Inspection Report - Page 81 of 1969 57 DATE/TIME: 10/4/2019 FILENAME: DSCN0398.jpg DESCRIPTION: TAKEN BY: 10:04 a.m. T-401 Isom (gasoline) tank. Water draw valves on the left allowing liquid to drip into drain. Visible emissions observed with the FLIR infrared camera. After tightening valves, the drip and visible emissions continued. James Haynes EPA Inspection Report - Page 82 of 1969 58 DATE/TIME: 10/4/2019 FILENAME: DSCN0399.jpg DESCRIPTION: TAKEN BY: 10:10 a.m. T-401 Isom (gasoline) tank. Praxair monitors to detect leaks located between the old tank floor and the new one as well as below the concrete foundation. Visible emissions observed with the FLIR camera. James Haynes EPA Inspection Report - Page 83 of 1969 59 DATE/TIME: 10/4/2019 FILENAME: DSCN0400.jpg DESCRIPTION: TAKEN BY: 10:14 a.m. T-401 Isom (gasoline) tank. Visible emissions observed with the FLIR infrared camera. Location of the highest readings with the MSA Sirius 4-gas with PID monitor: 730 ppm VOCs and 13% LEL. James Haynes EPA Inspection Report - Page 84 of 1969 60 DATE/TIME: 10/4/2019 FILENAME: DSCN0423.jpg DESCRIPTION: TAKEN BY: 11:18 a.m. Delay of Repair (DOR) component in SRU #2 unit. Tag 2720. Debbie Ford EPA Inspection Report - Page 85 of 1969 61 DATE/TIME: 10/4/2019 FILENAME: DSCN0401.jpg DESCRIPTION: TAKEN BY: 11:26 a.m. Delay of Repair (DOR) valve 2720 in SRU #2 Unit. Originally put on DOR list 5/13/09. Monthly monitoring records since 2016 document emissions from the valve as high as 127,700 and 500,000 ppm at times. James Haynes EPA Inspection Report - Page 86 of 1969 62 DATE/TIME: 10/4/2019 FILENAME: DSCN0402.jpg DESCRIPTION: TAKEN BY: 11:26 a.m. Back side of LDAR leak tag for DOR valve 2720 in SRU #2 Unit. Originally put on DOR list 5/13/09. Monthly monitoring records since 2016 show emissions from the valve as high as 127,700 and 500,000 ppm at times. James Haynes EPA Inspection Report - Page 87 of 1969 63 DATE/TIME: 10/4/2019 FILENAME: DSCN0424.jpg DESCRIPTION: TAKEN BY: 11:32 a.m. T-737 tank view through open doorsheet. Tank is out of service for new floor installation. Steel sheet panels being aligned and positioned under the wall of the tank prior to rewelding. Debbie Ford EPA Inspection Report - Page 88 of 1969 64 DATE/TIME: 10/4/2019 FILENAME: DSCN0425.jpg DESCRIPTION: TAKEN BY: 11:32 a.m. T-737 tank view of tank wall edge aligned with new steel sheet panels prior to rewelding. Debbie Ford EPA Inspection Report - Page 89 of 1969 65 DATE/TIME: 10/4/2019 FILENAME: DSCN0426.jpg DESCRIPTION: TAKEN BY: 11:34 a.m. T-737 tank view of underside of roof deck. Roof is on legs, but also cribbing is installed to hold roof. Debbie Ford EPA Inspection Report - Page 90 of 1969 66 DATE/TIME: 10/4/2019 FILENAME: DSCN0427.jpg DESCRIPTION: TAKEN BY: 11:35 a.m. T-737 tank view from open doorsheet to opposite side of tank. The equipment in the foreground is used to push the steel plates into position for welding. Debbie Ford EPA Inspection Report - Page 91 of 1969 67 DATE/TIME: 10/4/2019 FILENAME: DSCN0428.jpg DESCRIPTION: TAKEN BY: 2:02 p.m. Old carbon canister sampling at above ground API Separator. HollyFrontier uses their LDAR contractor Dexter to perform the daily sampling. Debbie Ford EPA Inspection Report - Page 92 of 1969 68 DATE/TIME: 10/4/2019 FILENAME: DSCN0429.jpg DESCRIPTION: TAKEN BY: 2:02 p.m. Hose and piping configuration at the old carbon canister sampling at above ground API Separator. The inlet canister is on the right. Debbie Ford EPA Inspection Report - Page 93 of 1969 Navajo Re?ning, LLC/Artesia Re?nery FRS 1100 0047 2630 501 E. Main Street, Artesia, NM 88210 Eddy County a 3? =3 Lead out 4 i N. ?a r, Lead in: 286 10/4/2019 2:12 p.m. FILENAME: Old Carbon Canisters used for control of emissions from the aboveground 69 API Separator. Inlet to the lead canister was 286 measured by Dexter DESCRIPTION: with a TVA 1000. Outlet from the lead canister was 4 and inlet to the lag canister was 3 ppm. Have never changed carbon in canisters ever. Leaks from the roof of the API Separator were 1700 measured by the same TVA. TAKEN BY: James Haynes EPA Inspection Report - Page 94 of 1969 70 DATE/TIME: 10/4/2019 FILENAME: DSCN0430.jpg DESCRIPTION: TAKEN BY: 2:18 p.m. North cover on sump at lift station north of aboveground API Separator near pump P-8005 Lift Basin Pump. Visible emissions observed with FLIR infrared camera. Debbie Ford EPA Inspection Report - Page 95 of 1969 71 DATE/TIME: 10/4/2019 FILENAME: DSCN0431.jpg DESCRIPTION: TAKEN BY: 2:20 p.m. West cover on sump at lift station north of aboveground API Separator near pump P-8005 Lift Basin Pump. Visible emissions observed with FLIR infrared camera. Debbie Ford EPA Inspection Report - Page 96 of 1969 72 DATE/TIME: 10/4/2019 FILENAME: DSCN0406.jpg DESCRIPTION: TAKEN BY: 2:41 p.m. Cover at new sump installed in 2012 for receipt of all wastewater from the facility. Visible emissions observed with the FLIR infrared camera from the sump cover. James Haynes EPA Inspection Report - Page 97 of 1969 73 DATE/TIME: 10/4/2019 FILENAME: DSCN0434.jpg DESCRIPTION: TAKEN BY: 2:47 p.m. New carbon canister system: Carbon Filter D-8001 on left and D-8000 on the right. Debbie Ford EPA Inspection Report - Page 98 of 1969 74 DATE/TIME: 10/4/2019 FILENAME: DSCN0407.jpg DESCRIPTION: TAKEN BY: 2:47 p.m. Cover at new sump installed in 2012 for receipt of all wastewater from the facility. Visible emissions observed with the FLIR infrared camera from the sump cover. James Haynes EPA Inspection Report - Page 99 of 1969 75 DATE/TIME: 10/4/2019 FILENAME: DSCN0408.jpg DESCRIPTION: TAKEN BY: 2:52 p.m. New carbon canisters that control the new sump installed in 2012. James Haynes EPA Inspection Report - Page 100 of 1969 76 DATE/TIME: 10/4/2019 FILENAME: DSCN0409.jpg DESCRIPTION: TAKEN BY: 3:04 p.m. Junction box at bundle cleaning area west of the wastewater system. Slight visible emissions observed with FLIR infrared camera from end of gooseneck pipe on the lid. James Haynes EPA Inspection Report - Page 101 of 1969 Appendix 2 Video Log EPA Inspection Report - Page 102 of 1969 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 1 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 2 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 3 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 4 10/02/2019 15:35 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 124 at vent 10/02/2019 16:21 James Haynes Hydrocarbon emissions observed with the FLIR camera from the west aboveground API separator at roof seals 10/02/2019 16:22 James Haynes Video from a different angle than Video No. 2 of hydrocarbon emissions observed with the FLIR camera from the west aboveground API separator 10/02/2019 16:26 James Haynes Additional view from a higher angle than Video Nos. 2 and 3 of hydrocarbon emissions observed with the FLIR camera from the west aboveground API separator EPA Inspection Report - Page 103 of 1969 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 5 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 6 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 7 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 10/02/2019 16:30 James Haynes Hydrocarbon emissions observed with the FLIR camera from the west side of the east aboveground API separator roof seals 10/02/2019 16:33 James Haynes Hydrocarbon emissions observed with the FLIR camera from the east side of the west aboveground API separator roof seals 10/02/2019 16:37 James Haynes Hydrocarbon emissions observed with the FLIR camera from the east side of the east aboveground API separator roof seals near the vapor collection system 8 10/03/2019 09:50 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 11 at vent EPA Inspection Report - Page 104 of 1969 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 9 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 10 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 11 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 12 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 13 10/03/2019 10:02 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 12 at vent 10/03/2019 10:20 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 108 at vent 10/03/2019 10:30 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 415 at vent 10/03/2019 10:36 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 109 at vent 10/03/2019 10:42 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 108 at vent EPA Inspection Report - Page 105 of 1969 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 14 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 15 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 16 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 17 10/03/2019 11:09 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 401 along secondary seal viewing right from the tank’s platform 10/03/2019 11:10 James Haynes Additional hydrocarbon emissions observed with the FLIR camera from Tank 401 along secondary seal viewing right from the tank’s platform 10/03/2019 11:11 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 401 along secondary seal across from the tank’s platform 10/03/2019 11:13 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 401 along secondary seal viewing left from the tank’s platform EPA Inspection Report - Page 106 of 1969 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 18 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 19 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 20 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 21 10/03/2019 11:14 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 401 along secondary seals below the tank’s platform 10/03/2019 11:16 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 401 along secondary seal below the tank’s platform 10/03/2019 11:47 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 1225 along secondary seal viewing left of the tank’s platform 10/03/2019 11:48 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 1225 along secondary seal below the tank’s platform EPA Inspection Report - Page 107 of 1969 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 22 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 23 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 24 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 25 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 26 10/03/2019 11:50 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 1225 along secondary seals below the tank’s platform 10/03/2019 12:00 James Haynes Hydrocarbon emissions observed with the FLIR camera from fixed roof Tank 431 at vent 10/03/2019 12:05 James Haynes Hydrocarbon emissions observed with the FLIR camera from fixed roof Tank 432 at vent 10/03/2019 12:07 James Haynes Potential hydrocarbon emissions observed with the FLIR camera from fixed roof Tank 432 at area to left of vent near stained insulation 10/03/2019 12:15 James Haynes Hydrocarbon emissions observed with the FLIR camera from fixed roof Tank 434 at vent EPA Inspection Report - Page 108 of 1969 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 27 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 28 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 29 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 30 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 31 10/03/2019 12:20 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 417 at vent 10/04/2019 09:46 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 401 along the base of the tank 10/04/2019 10:03 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 401 at the closed water draw valve 10/04/2019 10:09 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 401 along the base of the tank 10/04/2019 10:14 James Haynes Hydrocarbon emissions observed with the FLIR camera from Tank 401 along the base of the tank (without the Praxiar sample ports) EPA Inspection Report - Page 109 of 1969 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 32 10/04/2019 11:20 James Haynes Hydrocarbon emissions observed with the FLIR camera from LDAR Tag # 2720-000 in Unit 30 (Sulfur Recovery Unit #2); component has been on DOR since 2009 33 10/04/2019 14:20 James Haynes Hydrocarbon emissions observed with the FLIR camera from the north cover on the sump at the lift station north of the aboveground API separator (near pump P-8005 Lift Basin Pump) Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 34 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 35 10/04/2019 14:24 James Haynes Hydrocarbon emissions observed with the FLIR camera from the west cover on the sump at the lift station north of the aboveground API separator (near pump P-8005 Lift Basin Pump). 10/04/2019 14:41 James Haynes Hydrocarbon emissions observed with the FLIR camera from the cover of the new sump installed in 2012 for receipt of all wastewater from the facility; emissions from the sump are controlled by the New Carbon Canister System EPA Inspection Report - Page 110 of 1969 Video Number: Video File Name: Date of Video: Time of Video: Videographer: Description: 36 10/04/2019 14:47 James Haynes Hydrocarbon emissions observed with the FLIR camera from a second new sump cover near the New Carbon Canister System EPA Inspection Report - Page 111 of 1969 Appendix 3 Sign-In Sheet EPA Inspection Report - Page 112 of 1969 *gD 7 g? Meeting with: Navajo Re?ning I Artesia Re?nery 6% Purpose of meeting: CAA Inspection October 1-4, 2019 3? Name mi" Title Reprosenti_ng_ e-Mail Phone 1 Debbie Ford Env. Scientist EPA R6 ford.debbie@epa.gov (214) 665-7235 2 James Haynes Env. Scientist EPA R6 haynes.james@epa.gov (214) 665-8546 3 2% 3mm W42 575 We 5?18]: 4 '20 154 1L6 Hal/(180 Emu. 56(60th AIME K6112 . rim/.45 eds 475 4?962 6 5m. Paul (2nd Salutf? Mam/1D sham Mlm?m nm 6 gawk-4&3 6 Cinch Hc/(enbos; InJ?Jtc?onb ('11;ch 5 619,ch NWAJO 121M m- 573-7% Mt" 3"(Xb cm SW EKLQ er EPA- 910?; row-@erq. Coy-1 -57l?32?1'2067 9 ?ta Goidtaaie Com? EMV. HFC c-uckefa @ol?hale?iI/LOHnyonhkr ?21.4- Wm 31?2?- 10 IS Wn.m_gu (rig-1cm mm? Who 11 b?U-cukws 1A H, Mean Wan?let ?me ?ung-03?? 12 an? fan/Zig?a?a?, W2, nor/"w (am 5} 75/7/3167, 13 Harvwe? Era Fff] - loch/m e. 3133* 14 X/?m M?m EPA NEIC: Y?Ah?mf?m? 15 Ma" f?i' [Dream-m A) Seknm?on - Ca HCM?Q/mi/g?m?ii?v' 5'75? 16 (?be Wm an ,9/4-262-2 736 71w r/ (2:15 Mammay 57? 7W1: 1:3 176666er ?iv/fern Mezzo-id .Cgm 19 yz/m/m/b Eel/>51 MMD name g6?? 20 4/ my? mac; ,uwg ?zf?Z 77M - feral] 21 /Z)4wf' 4.11,; v- 416%.? A644 ?ow. amt; a? ?r - 746 22 @egimrrw Cit/mu! 96 fL 126.}; {Basket-me. 23 8k chm-1 Sr 9&6me 093.1!on Hf "From w-Si-xe Li 1M 24 i. 25 EPA Inspection Report - Page 113 of 1969 Appendix 4 West Tank Area EPA Inspection Report - Page 114 of 1969 West Tank Area near Fenceline Monitoring Sites 13, 14, 15 EPA Inspection Report - Page 115 of 1969 Appendix 5 North Center (Wastewater) Area EPA Inspection Report - Page 116 of 1969 North Center (Wastewater) Area near Fenceline Monitoring Points 19, 1 EPA Inspection Report - Page 117 of 1969 Appendix 6 East Tank Area EPA Inspection Report - Page 118 of 1969 EPA Inspection Report - Page 119 of 1969 Appendix 7 South Tank Area EPA Inspection Report - Page 120 of 1969 South Tank Area near Fenceline Monitoring Sites 8, 9, 10, 11, 12 EPA Inspection Report - Page 121 of 1969 Appendix 8 Center Tank Area EPA Inspection Report - Page 122 of 1969 Center Tank Area near Fenceline Monitoring Points 13, 14, 5, 6 EPA Inspection Report - Page 123 of 1969 :34 ?1 i? Ir q-F; Iva-"ii" ?ll: intriiltyl - . *lJl May 15. 2019 Bureau Chief Certi?ed Maili?Return Receipt Air Quality Bureau T014 3490 mm sass 54m New Mexico Environmental Department 525 Cantino de los Marquez, Suite 1 Santa Fe, New Mexico 87505 RE: Con'ective Action Plan for Artesia Re?neryr Describing Fenceline Benzene Monitoring Root Cause Analyses and Corrective Actions Holinrontier Navajo Re?ning LLC {Navajo} is Submitting this letter for the Artesia, New Mexico Re?nery pursuant to the requirements of the National Emission Standards for Hazardous Air Pollutants ?'om Petroleum Re?neries (MAC-T CC) at 40 CFR 63.65801). The MACT CC compliance period for collecting fenceline benzene monitoring data began on January 30, 2018. In October 2016. Navajo proactively began collecting fanceline benzene monitoring data as part of a pilot study to evaluate site conditions prior to the beginning of applicable compliance period for CC. A site map providing the layout ofthe facility and the fenceline monitoring locations is provided as Figure 1 (attached). 40 CPR 63.65 Sif)(2) provides that the owner or operator shall calculate the annual average difference between highest and lowest benzene concentrations as measured at the fenceline based on the average of the 26 most recent 14-day sampling periods. (EPA refers to the difference between highest and lowest 2~week (14-day) benzene concentrations reported at the facility fenceline as "ditzf'l1 Navajo collected the 26th 14-day period sample needed to calculate the amtual average benzene concentration at the fenceline (tie, the annual average dc on January 29, 2019, and received the results on February 5, 2019. The results showed benzene concentrations above the annual average action level of 9 micrograms per cubic meter (uglm-l}. triggering the root cause analysis and corrective action requirements of 40 CFR Even prior to this, Navajo implemented a number of activities beginning in 201'? and 2018 to evaluate potential sources at the facility of the benzene detected during the pilot study, and implemented several corrective actions for the identified sources. including during the 2013 compliance period (January 30, 2D18 January 30, 2019). These activities. once implemented. reduced the 14-day benzene concentrations at the fenceline (dc) to below the level of 9 pgfmi during the latter portion of the 2018 compliance period, with one exception.2 The following provides a summary of the root cause analyses and corrective actions implemented. April 2017 Root Cause Analysis Data from March 2017, prior to the applicable compliance period under MACT CC. for fenceline monitoring locations 5 tlu?ough 10, and 13 through 16, indicated that the 14-day sampling period benzene concentrations were above 9 pgfmi. Navajo conducted a FLIR camera survey of storage tanks near these fenceline monitoring locations in April 2017, to assess the potential that any of these tanks might be a source of the monitored benzene. Specifically, the following were surveyed: the #3 Blender and Tanks 401. 450, 11. 417, 418, and 434. The loCation of Tank 57 correlated to benzene detected at fenceline monitoring locations 13 through In. The locations of Tanks 401 and 450 correlated to benzene detected at fenceline monitoring locations 5 though 7. The blending pit, and Tanks 1 l, 417. 418. and 434 were evaluated in the May 2017 root cause analysis 40 CPR 63.653illi1]; S3 Fed. Reg. 15453. 15466 (Apr. 10. 2018). 3 This was in January 2019 and correlated with maintenance work on one tank (Tank 11). Steps are being taken to minimize emissions during future tank maintenance. Navajo Re?ning LLC 501 East Main Artesia, NM 88210 (575) 748-3311 - httn; f/wygw. EPA Inspection Report - Page 124 of 1969 Bureau Chief May 15, 2019 Page 2 below. As a result of this root cause analysis, Navajo worked with TANGO Engineering, lnc. to install socks on the vacuum breakers and roof legs to reduce emissions from Tanks 57, 401, and 450 in December 2017. See corrective actions implemented in December 2017. May 2017 Root Cause Analysis To further evaluate potential sources of benzene emissions, Navajo set out four temporary sample locations through T84) for a 14-day period in the vicinity of the other units surveyed in April 2017. As noted above, these were the #3 Blender and Tanks 1 l, 417, 413, and 434 Benzene detection levels at were as follows: 19, T52 6.3, T83 15, T84 17 (in jig/1113). During the sampling period, however, wind direction was highly variable, making it difficult to validate that these units were contributing sources of the observed benzene detected at these sample locations. Benzene concentrations at fenceline monitoring locations 8 through ll], which may correlate to these units, dropped below 9 pgz?m" in subsequent 14-day sampling periods, from May 2, 201? through August 22, 2017, the hottest time of the year. Additionally, benzene concentrations for monitoring locations 8 and 9 continued to be below 9 ugfm3 tln'oughout most of 2017-201 8, with intermittent sampling data above this level. As a result, Navajo did not identify these tanks as primary sources of benzene concentration at the fenceliue. September 2017 Root Cause Analysis Navajo set out four additional temporary sample locations (T35 through TSS) for a 14-day period to undertake further evaluation of potential benzene sources, focusing on Tanks 56, 57, 802, and 737. The samples were placed adjacent to these tanks, and the resulting monitoring data was as follows: Tank 56 (T35 48 Tank 57 318 rig/mi), Tank 302 (T87 359 [lg/1113), and Tank 73? 248 pgfm"). The primary wind direction during this sample period was from the south-southeast. Taking into account wind direction, the detected benzene concentrations from these temporary sampling locations indicate that Tank 57 may be the primary source of benzene in this area. December 20] 7 Corrective Action As a follow-up to the April 2017 root cause analysis, described above, and to address hydrocarbons detected from Tanks 401, and 450, between June and November 2017, Navajo engaged TANGO to review the con?guration of the tanks to determine the number of socks needed, evaluate design options, complete fabrication of the selected design, and coordinate installation of the socks. In December 201?, TANCO installed socks on the vacuum breakers and roof legs to reduce potential emissions front Tanks S7, 401. and 450. Based on subsequent fenceline benzene sample results, these socks appear to have been effective in reducin benzene concentrations for Tanks 401 and 450, but not as similarly effective for Tank 57. July 2018 Corrective Action Subsequent to the December 2017 corrective action, Navajo worked with TANCO to design and install a more effective sock for the vacuum breaker on Tank 57. in July 2018, the newly designed sock was installed on Tank 57. Although data from the subsequent 14?day sample periods showed reduction in benzene concentrations associated with Tank 57, the difference in benzene concentrations at the fenceline toe} remained above 9 ugfmi?. August 2018 Corrective Action In determining potential further options for reducing benzene concentration near Tank 57, Navajo identi?ed that a heat exchanger intended to cool the product entering Tank 5? was not sufficiently cooling the incoming feed. This heat exchanger was repaired in August 2018, which resulted in reduction of the temperature entering Tank 57 from to approximately Over the next several 14-day sampling periods, benzene Navajo Re?ning LLC 501 East Main . Artesia, NM 88210 (535) 748-3311 - EPA Inspection Report - Page 125 of 1969 Bureau Chief May 15. 2019 Page 3 concentrations detected at monitoring location 14. which may correlate to Tank 57. reduced signi?cantly but were still above 9 jig/mi. November 2018 Root Cause Analysis Navajo set out three temporary sampling locations (TIJA, Tl 4A. and T143) in the vicinity of Tank 57 to evaluate the area for other potential benzene sources after the heat exchanger repair signi?cantly reduced benzene levels as described above. Detections from these locations indicated that Tank 57 may be the primary benzene source in this area. One additional temporary sample location was placed north of fenceiine sample location 10 to evaluate potential sources that may have intermittently been causing benzene detections at this fenceline sample location. The benzene detected at temporary sample location which is closer to Tank 57, showed approximately two times the numbers observed at sampling location 10. November 2018 Corrective Action In November 201 8. Navajo evaluated the possibility of removing Tank 57 from service. Tank 57 is a holding tank that serves as an important ?ow regulator for feed from the upstream Naphtha Hydrotreating units prior to the feed entering the "BenFreef? Unit (Unit 20), and there are no other tanks in line that could substitute for Tank 57. Unit 20 produces high-octane components and reduces the benzene content of light naphtha feed for the commercial gasoline pool. Removing Tank 5? from service would require running feed directly from the upstream NHT units to Unit 20 and would create operational challenges for the refmery because of the need to operate Unit 20 at a controlled rate, while the ?ow rate of units upstream that would feed directly into the ISOM unit ?uctuate. Notwithstanding this, on November 20, 2018, following steps to enable operation without Tank 57, (including steps that would show certain components to act as ?ow buffers). Navajo temporarily removed Tank 57 from service (leaving approximately 15 feet of product in the tank, short of landing the roof) to evaluate whether detected benzene levels would fall below 9 pgr?m". Since November 2018, and for the remainder of the 2018 compliance period, the 14-day fenceline benzene concentrations related to Tank 57 were below this level. Additionally, on November 26, 2018, Navajo inspected Tank 57 with a FLIR camera. After removing the tank from service, only minor vapors from one spot on the roof deck were observed. Results of Corrective Actions and Current Status of Benzene enceline Monitoring Navajo has implemented several root cause analyses and corrective actions as detailed in this document. Based on these root cause analyses, it is believed that Tank 5? was the primary source connibutin to an annual average benzene concentration above the action level of 9 pgtmi. Following corrective actions, Navajo's 14- day benzene concentration. Ac values, have been below 9 pgnn3 with the one exception previously described. hi addition to the corrective actions presented above. Navajo reviewed its Tank 57 inspection records for the period between 2017 and EDI 9. Inspections for Tank 57 were performed in compliance with MACT CC Group 1 external ?oating roof requirements. Inspection records show that Tank 57?s primary seal was inspected on January 4, 201?. and received a passing inspection. The next scheduled inspection for the primary seal is scheduled for January 4, 2022. The secondary seal on Tank was also inspected on January 4. 2017, and received a passing inspection. During this inspection. however, the vacuum breaker seal was observed to be damaged. Navajo replaced the vacuum breaker seal as well as the gasketed ?oat. As follow-up to the January 4. 2017 inspection, Tank 57?s secondary sea] was inspected again on January 18, 2018 and January 30, 2019. and received passing inspections. Long-Term Corrective Action Plan Navajo is planning to implement a long-term project {the 130M Project) that will result in the permanent removal of Tank 57 from its current service The ISOM Project entails changes that will improve operation of Unit 20 and further increase the octane content of the light naphtha feed and make operation of Tank 57' as a holding tank and ?ow regulator unnecessary. Tank will no longer be needed for this service because the Navajo Re?ning LLC 501 East Main - Artesia, NM 38210 {575'} 743?3311 - EPA Inspection Report - Page 126 of 1969 Bureau Chief May 15, 2019 Page 4 upgraded Unit 20 will be able to accommodate the variable feed rates from the upstream Naphtha Hydrotreating units without this tank. Capital expenditures for this project have been approved, and construction is currently anticipated to begin later in 2019 and to be complete in second or third quarter 2020. with startup shortly thereafter. Navajo plans to limit the use of Tank until the Project is implemented, at which time Tank 57 may he removed from its current service.3 Pursuant to 40 CFR 63.65801), Navajo is submitting this letter to the Agency as a long?term corrective action plan. because implementation of the ISDM project will require more than 45 days to implement. If you have questions regarding this corrective action plan, please contact me at or by phone at 575-746?5487. Sincerely. Scott M. DentOn Enviromnental Manager Enclosure". Figure 1: Map of Navajo Artesia Fenceline Monitoring Locations Cc: Chief Air. Toxics. and Inspections Coordination Branch Environmental Frolection Agency, Region 5 1445 Ross Avenue Dallas. TX HEB-251733 Electronic Navajo: P. Miller; B. Rominc. R. Smalls T. Wheeler . S. Gokhale; T. Jones, R. Baglrerian Morgan. Lewis 3; Bockius LLP: .1. Hunvitz 3 As previously noted. Tank 57 was temporarily taken out of service on November 20. ".510 1 8. It was necessary to put the tank back into service as a holding tank in early April 2019 in connection with replacement of the catalyst in the lead reactor in the BenFrce Unit. The catalyst was nearing the end of its useful life and replacement was undertaken in order to lower the benzene content of the light naphtha feed entering the gasoline pool. The catalyst replacement was completed in late April. and Tank 57 levels are being drawn dowrr so that it can again be taken out of service. This is expected to be completed as soon as practical, by end of June or earlier. Navajo Re?ning LLC 501 East Main - Artesia, NM 88210 (575) 748-3311 - ________ EPA Inspection Report - Page 127 of 1969 - 8. tr bEt r i. - 1%.. A --------- - - 4 1. (I C ——I F (;5 0 T-29 —I T-18 T9 T8 r1-•.:-: . 1’ w •0 I - - A . : (23 T42 7-81 I _I I’. 91 a - 5O ‘-5 -8 9,. r • -T-44 74T.73 114 ,01 t2 F A T415 T-107 T-l09 ‘ T.116 T-115 11 - 32 T-12 4 T•1OB1 ‘. 8—42-.;; I - T420T422 - T-423 4i !. •i: ;i’!”:: I ‘‘ - I “——i r 1.4 fA A ‘.—-• I- ‘8 IF-:. I FIGURE 1 EXPLANATION A N GPS LOCATION IrihL1dro FENCELINE MONITORING SAMPLING STATIONS 1252 Commerce Drive Laramie, WY 82070 www.trihydm.com (P) 3071745.7474 (F) 3071745.7729 HOLLYFRONTIER NAVAJO REFINING LLC ARTESIA, NEW MEXICO Drawn By: CF Sca(e: V CORPIRAFION SITE BOUNDARY (320.72 ACRES) 0 500 Checked By: JS = 500’ Date: 11/17/161 File: HF_NavaJo_FencelineMonitonng.mxd - — EPA Inspection Report - Page 128 of 1969 I . 9r} Fill?. ER. an 1.. warm it: July 3, 2019 Bureau Chiei? Certi?ed MailJ'Return Receigt Air Quality Bureau nus roan com 7923 581 I New Mexico Environmental Department 525 Camino de los Marquez, Suite 1 Santa Fe, New Mexico 87505 RE: Amendment to the May 15, 2019 Fenceline Benzene Monitoring Corrective Action Plan for the Artesia Re?nery Navajo Re?ning LLC (Navajo) previously submitted a letter on May 15, 2019 for the Anesia, New Mexico liter?trierjzr pursuant to the requirements of the National Emission Standards for Hazardous Air Pollutants from Petroleum Re?neries (MACT CC) at 40 CFR 63.65801). This letter summarized investigation activities and corrective actions implemented between April 2017 and November 2018. It also identi?ed a long-term corrective action plan (the ISOM Project} that will result in permanent removal of Tank 57 From its current service and a schedule for the implementation of the ISOM Project. A site map providing the layout of the facility and the fenceline monitoring locations is provided as Figure 1 (attached). Since submittal of the May 15, 2019 letter, 2-week sample event Ac values have exceeded 9 pgi?m3 for the Following sample periods: I 2126 to 31?1'2: sample event Ac =10.6 pgr?m3 Monitoring locations 13, 14, and 15 were above 9 - Bill to 3/26: sample event Ac 12.5 ugi?m3 Monitoring locations 7, 8. 9, and 10 were above 9 ug/n'rq - 3/26 to sample event Ac 54.2 rig/In3 Monitoring locations 13, 14, and 15 were above 9 rig/1n3 I 4(9 to 4x23: sample event do 66.2 jig/1113 Monitoring locations 7, 10, 14. 15, and 16 were above 9 pgi?m3 0 4/23 to 517: sample event the 203.5 pgfmi? Monitoring locations were above 9 ugfrn" 1- to 512] sample event do 99.0 uge?mi Monitoring locations 14, 15. and 16 were above 9 pgfm" 0 to GM: sample event Ac 28.5 pg/m3t Monitoring locations 14 and 15 were above 9 rig/m3 Navajo Re?ning LLC 501 East Main Artesia, NM 38210 (575) 748-3311 EPA Inspection Report - Page 129 of 1969 Bureau Chief July 3, 2019 Page 2 Because the sample event dc was less than 9 uge?m" before these events, an additional root cause analysis was completed to determine the source of the benzene detections. The result of evaluating these sample events indicate the above sample period he esceedances pertain to the temporary return of Tank 5? to service', combined with a damaged seal on Tank 737 and a release of hydrocarbons from Tank 106 that resulted in a damaged roofand seal. Below is a description of Tank 57/737 issues, Tank 106 issues, and corrective actions and schedules for correcting these issues. Pursuant to 40 CF 63.65801}, Navajo is submitting this letterto the Agency as a long?term corrective action plan, because the tank cleaning and repairs will require more than 45 days to implement. Tank 106 Issues and Corrective Actions On March 26, 2019, there was an over?ow of Tank 106, which contains a mixture of water and crude oil. The spilled hydrocarbons were excavated and removed upon discovery of the over?ow. On March 29, 2019, the tank seal was inspected and Found to be damaged. Planning and coordination for removing this tank from service for cleaning and repair has required more than 45 days. This tank has been isolated from service2 and is scheduled to be removed from service for cleaning and repairs no later than July 12, 2019. Tank 571?737 Issues and Corrective Actions Tank 57 was temporarily taken out of servicei on November 20, 2018. As explained in Navajo?s May 15, 2019 letter, it was necessary to put the tank back into service as a holding tank on April 4, 2019 in connection with replacement of the catalyst in the lead reactor in the BenFree Unit (Unit 20). The catalyst was nearing the end of its useful life and replacement was undertaken in order to lower the benzene content of the light naphtha feed entering the commercial gasoline pool. The catalyst replacement was completed in late April, and Tank 57 levels were drawn down and the tank was isolated from service on May 24. 2015, with no product being moved into or out of the tank. Navajo plans to continue to limit the use of Tank 57 until the ISOM Project is implemented, at which time Tank 57 will be permanently removed from service as a holding tank for the BenFree Unit. Capital expenditures for this project have been approved, and construction is currently anticipated to begin later in 2019 and to be complete in second or third quarter 2020, with startup shortly thereafter. On March 18, 2019, during routine tank inspections, Navajo identi?ed that Tank 737 (sour water tank) has a damaged seal that may be contributing to detected benzene fenceline concentrations on the west side of the re?nery. Fleming and coordination for removing this tank from service for cleaning and repair has required more than 45 days. Tank 737 was isolated from receiving material on April The tank contents were emptied and removed from service with the roof being landed on June 16, 2019. The tank cleaning has been completed. allowing the primary seal on the tank to be repaired. If you have questions regarding this corrective action plan, please contact tne at or by phone at 575-746-5437. Sincerely, Scott M. Denton Environmental Manager i As explained in our May 15, 2019 submittal. Tank 57 was taken out of service on November 20. 2018 by lowering the liquid level in the tank and leaving approximately 15 feet of product, short of landing the rooil. During this time, precinct was not moved into or out of the tank. 3 By isolation from service, we ntean that product retnains in Tank 106. but it is not being moved into or out of the Tank. Navajo Re?ning LLC 501 East Main . Artesia, NM 83210 (575) 743331 1 lJitiL' EPA Inspection Report - Page 130 of 1969 Bureau Chief JuneI 3, 2019 Page 3 EIIL?tnsurc: liigurc Map nl?Nuvuju Ancsiu Funcclinc Muniu?u?ing Lozzalions Cr: hiel? Air. Tuxics. and hmpeclinns Coordination Branch Environmental Pl'olcctian Agency. Ruginn 6 I445 Ave-nut: Dallas. TX 75201-1733 cc {Menu}: Navajo: P. Miller; B- anine. R. 51113115 Hollyanticr: T. Wheeler 5. Gnkhale; T. Juncs, R. Bagllerinn Morgam Lewis Bockius Hurwitz Navajo Re?ning LLC 501 East Main - Artesia. NM 88210 {575.} 743-3311 ML- ?x??wgh??l'uwggm EPA Inspection Report - Page 131 of 1969 I 133* 115.5.- -.2 . gamma? 1 GPS SITE BOUNDARY (320.72 -- . if 1. . ?f?1??u?mu 1.14? 141?i?u I. .J Hu . - ?at; .. mm2.FIGURE 1 - FENGELINE an onnonme SAMPLING STATIONS II REFINIHG ARTESIA. NEW MEKICD Etc-mm:- Dim Llrl?o. menu mwuw:m Ina-1115.14" maorrus m. mam Ely: CF Chum Er J5 I 1' 500' I Duo: mud EPA Inspection Report - Page 132 of 1969 September 3, 2019 Bureau Chief Certi?ed MgillReturn Receipt Air Quality Bureau 7018 1130 0000 9712 6671 New Mexico Environmental Department 525 Camino de los Marquez, Suite 1 Santa Fe, New Mexico 87505 RE: Amendment-2 to the May 15, 2019 Fenceline Benzene Monitoring Corrective Action Plan for the Artesia Re?nery: Plan for Removal of Tank 57 Navajo Re?ning LLC (Navajo) submits this letter to update the Fenceline Benzene Corrective Action Plan (CAP) for the Artesia, New Mexico re?nery pursuant to the National Emission Standards for Hazardous Air Pollutants from Petroleum Re?neries (MACT CC) at 40 CFR 63.65 Speci?cally, this letter describes Navajo?s plan to permanently remove Tank 57 from benzene-containing liquid service and follows our CAP letters of May 15, 2019 and July 3, 2019. We have identi?ed Tank 57 as the primary source contributing to an annual average benzene concentration above the MACT CC action level of 9 micrograms per cubic meter. Based on further technical evaluation, Navajo intends to remove benzene-containing material from Tank 57 no later than September 26, 2019 with a target removal timeframe of September 12, 2019, such that the tank will not store benzene-containing liquid in the future. The Company anticipates that this action will cause benzene concentrations at the fenceline to remain below the MACT action level on a permanent basis. In addition, Navajo will implement engineering controls, and other measures, outlined below in the event the facility?s BenFree Unit experiences any operational issues after Tank 57 is removed from current servrce. We appreciated the opportunity to discuss the plan for disabling Tank 57 from its current service as described in this letter and the Artesia fenceline data with the US. Environmental Protection Agency (USEPA) and New Mexico Environment Department (NMED) on our August 27, 2019 conference call. Navajo remains committed to proactively addressing the source of benzene emissions detected at the Artesia fenceline and working cooperatively with USEPA and NMED on these issues. Tank 57 Benzene Removal Plan and Timing As described in our July 3, 2019, CAP letter, Navajo isolated Tank 57 from service on May 24, 2019, with no product being moved into or out of the tank. Based on further assessment at the site, Navajo has determined that Tank 5 7 will no longer be needed to store benzene containing streams both prior to, and after, implementation of the ISOM Project. Navajo communicated on the August 27 call with NMED and EPA that Tank 57 will have all benzene containing material removed no later than 30 days from August 27 (September 26) with a target removal timeframe of 2 weeks (September 12). The re?nery is working to safely and expeditiously stop any further benzene emissions from Tank 57. Navajo began removing material from Tank 57 on August 27 in preparation for removing the tank from the service of storing benzene containing material. The re?nery intends to use a combination of nitrogen blanket and a thermal oxidizer (TO) to ensure safety and control emissions generated from emptying and re?lling the tank. The next steps and controls to fully implement removal of Tank 57 from its present service include the following measures: Navajo Re?ning LLC 501 East Main - Artesia, NM 88210 (575) 748-3311 0 hit 13 1'1 ontier.com EPA Inspection Report - Page 133 of 1969 Bureau Chief September 3, 2019 Page 2 Submit Permit Application (Administrative RevisionExpected submittal 9/3 The T0 is expected onsite 9/3 and to be available for use on 9/4 0 Pump remaining liquid out to blending tank 411 with the transfer pump until the pump loses suction begin the week of 9/ 3 Switch to temporary pump connected to the water draw to remove remaining liquid (sump draw) When the roof is set on its legs (landed), initiate a nitrogen blanket and TO controls 0 Nitrogen is used to ?ll the vapor space created when the roof is landed and emptied. This is to limit the amount of oxygen under the roof to eliminate the potential for a ?ammable atmosphere inside the tank. 0 The T0 will be used to control vapors that may be emitted during the emptying process and the vapors emitted during the ?lling process to minimize impact to the environment. a When removal of liquid from the water draw is complete (minimal product remains) introduce approximately 6? of Naphtha Splitter Bottoms (Hydrotreated Naphtha, which does not contain benzene) to sponge any light naphtha remaining in the tank Pump the sponge material out to Tank 411 Re?oat the roof with Naphtha Splitter Bottoms above the level for the vacuum breaker to seal. Operation of BenFree Unit without Tank 57 until ISOM Project Implementation In the event that there are operational issues with the BenFree Unit or hydrogen supply to the unit until implementation of the ISOM Project, the light naphtha stream will be routed to storage in blending tanks (typically, Tank 411). This is the current operational procedure at the re?nery. Tank 411 presently stores BenFree Unit material, and material from Tank 411 is blended with other re?nery products to make gasoline. Tank 57 Seal Assessment The call on August 27 also included a discussion of the seals on Tank 57 and assessment of the tank seals. As background, Navajo installed the current roof on Tank 57 prior to placing the tank in its current light naphtha service. Navajo intends to perform a primary seal inspection Within two weeks after the roof is ?oated pursuant to the above plan for removal of Tank 57 from benzene-containing liquid service. During the primary seal inspection, the secondary seal will be pulled back in order to allow the inspector to inspect the entire seal fabric material and measure any gaps between the tank wall and the seal shoe. We will review the results of the primary seal inspection performed after the roof is ?oated and initiate any appropriate follow-up measures based on the inspection. If you have any questions regarding this CAP update, please contact me at Scott.Denton- Hollx Frontiercom or by phone at 575-746-5487. Thank you again for your consideration. Sincerely, \sirw Scott M. Denton Environmental Manager Cc: Chief Air, Toxics, and Inspections Coordination Branch Enviromnental Protection Agency, Region 6 1445 Ross Avenue Dallas, TX 75202-2733 Navajo Re?ning LLC 501 East Main - Artesia, NM 88210 (575) 748-3311 - Imp EPA Inspection Report - Page 134 of 1969 Bureau Chief September 3. 2019 Page 3 Electronic cc (w/enc): Navajo: P. Miller; B. Romine, R. Smalts T. Wheeler S. Gokhale; T. Jones, R. Baghen'an Sidley Austin LLP: A. Stewart Navajo Re?ning LLC 501 East Main - Artesia, NM 88210 (575) 748-3311 - 11m? EPA Inspection Report - Page 135 of 1969 21?1: HOLLYF RON Tl ER. October. 1 1, 2019 Bureau Chief Certi?ed Mai/Rem Receip_t Air Quality Bureau 7018 1130 0000 9712 6725 New Mexico Environmental Department 525 Camino de los Marquez, Suite 1 Santa Fe, New Mexico 87505 RE: Amendment-3 to the May 15, 2019 Fenceline Benzene Monitoring Corrective Action Plan for the Artesia Re?nery: Plan for Removal of Tank 57 Navajo Refming LLC (Navajo) submits this letter to update the Fenceline Benzene Corrective Action Plan (CAP) for the Artesia, New Mexico re?nery pursuant to the National Emission Standards for Hazardous Air Pollutants from Petroleum Re?neries (MACT CC) at 40 CFR 63.65 Speci?cally, this letter describes Navajo?s plan to remove Tank 57 from liquid service and follows our CAP letters of May 15, 2019, July 3, 2019 and September 3, 2019. The tank will be emptied, de?gassed and cleaned in preparation for inspection during the 4th quarter. Going forward, Navajo intends to keep Tank 57 Out-of-Service (DOS) and thus follow our applicable OOS Procedure. Additionally, Navajo intends to ?air gap? the tank from process lines, which is the physical disconnecting of all process lines, such that there is a gap between the lines and the tank that can be seen visually. This will render Tank 57 fully nonoperational and will require a Management of Change (MOC) for the DOS and likewise, for any potential future use of Tank 57. We appreciated the opportunity to discuss our plan for Tank 57 with the US Environmental Protection Agency (USEPA) and New Mexico Environment Department (NMED) on our September 9, 2019 conference call. Navajo remains committed to proactively addressing the source of benzene emissions detected at the Artesia fenceline and working cooperatively with USEPA and NMED on these issues. Tank 57 Complete API 653 Inspection Pursuant to September 1 6, 2019 letter, Navajo will provide at least 30 calendar days advance notice to EPA and NMED of a complete API 653 inspection of Tank 57. Additionally, Navajo will submit the complete API 653 report to EPA and NMED within 15 days after completion of the inspection. Tank 57 Empty, De-Gas and Clean for Inpsection Navajo communicated on the September 9th call with NMED and EPA that Tank 57 was emptied of all benzene containing material on Friday September 6th, sponge material removed on September 7th and the roof was re?oated with Naphtha Splitter bottoms. The tank level was continuously raised high legs. Filling ended on September 10th. Pursuant to September 16, 2019 letter, while Tank 57 is emptied and degassed, Navajo will conduct a visual inspection of the ?oating roof deck, deck ?ttings, and rim seals from both the topside and underside of the roof deck, and provide at least 30 calendar days advance notice to EPA and NMED of the inspection. Additionally, within 15 calendar days after the completion of the inspection, Navajo will submit to EPA and NMED a report of all inspection results. Navajo Re?ning LLC 501 East Main - Artesia, NM 88210 (575) 748-3311 - EPA Inspection Report - Page 136 of 1969 Bureau Chief October 11. 2019 Page 2 The next steps to empty, de-gas and clean Tank 57 include the following measures: Mobilize thermal oxidizer (TO) to be onsite the week of 10/14. Pump remaining liquid out to blending tank 411 with the transfer pump until the pump loses suction begin the week of 10/ 14. Switch to temporary pump connected to the water draw to remove remaining liquid (sump draw). When the roof is set on its legs (landed), initiate a nitrogen blanket and TO controls. 0 Nitrogen is used to ?ll the vapor space created when the roof is landed and emptied. This is to limit the amount of oxygen under the roof to eliminate the potential for a ?ammable atmosphere inside the tank. 0 The T0 will be used to control vapors that may be emitted during the emptying process to minimize impact to the environment. A permit for this activity was received on September 20th. 0 When removal of liquid from the water draw is complete (minimal product remains) introduce a diesel ?ush to sponge the residual naphtha remaining in the tank. I The next ?ush will be water with Zyme?ow chemical to sponge any naphtha remaining in the tank Pump the sponge material out to frac tanks The tank atmosphere will be checked periodically for VOCs to verify the de-gas is complete. The T0 is in use until the de-gas is complete. Target is a lower explosive limit (LEL) concentration of less than 10%. Once the tank can be safely opened, entry will be made and cribbing installed Clean to remove any minor amount of liquids and solids remaining Tank will remain open for inspection 0 API 653 Inspection 0 Inspection of the ?oating rood deck, deck ?ttings, and rim seals As noted above, Navajo intends to keep Tank 57 DOS and nonoperational for the near future. We will follow our 008 Procedure and air gap the tank from process lines. This will require an MOC for the ODS and likewise, prior to any future use. Additionally, Navajo will provide at least seven (7) calendar days written notice to EPA and NMED prior to any re?lling of the tank. If you have any questions regarding this CAP update, please contact me at or by phone at 575-746?5487. Thank you again for your consideration. Sincerely, Scott M. Denton Environmental Manager Cc: Chief Air, Toxics, and Inspections Coordination Branch Environmental Protection Agency, Region 6 1201 Elm Street, Suite 500 Dallas, TX 75270-2102 Electronic cc: Navajo: P. Miller; B. Rornine, R. Smalts T. Wheeler S. Gokhale; T. Jones, R. Baghen'an Sidley Austin LLP: A. Stewart Navajo Re?ning LLC 501 East Main - Artesia, NM 88210 (575) 748-3311 EPA Inspection Report - Page 137 of 1969 New Mexico ENVIRONMENT DEPARTMENT 525 Camino de los Marquez Suite 1 Santa Fe, NM 87505-1816 Phone (505) 476-4300 Fax (505) 476-4375 M?Hl?i-t?. nmenv. 5m re. nm. as RYAN FL YNN CABINET SECRETARY 8 USA NA MA GOVERNOR BU TCH TONGA TE DEPUTY SECRETARY JOHN A. SANCHEZ LIEUTENANT GOVERNOR Air Quality Bureau TITLE OPERATING PERMIT Issued under 20.2.70 NMAC Certi?ed Mail No: 7013 2630 0000 9073 5525 Return Receipt Requested Operating Permit No: Facility Name: Permittee Name: P05 1 Artesia Re?nery Navajo Re?ning Company L.L.C. Mailing Address: PO Box 159 A?esia, NM 88211-0159 ID No: 198 - PRT20130002 AIRS No: 35?015?0010 Permitting Action: Renewal Source Classi?cation: Facility Location: County: Air Quality Bureau Contact Main AQB Phone No. Major?TV and PSD with BACT UTMH 557021 In, UTMV 3633819 m, UTMZ 13 Eddy Joseph Kimbrell (505) 476?4300 TV Permit Expiration Date: May 6. 2020 TV Renewal Application Due: May 6, 2019 i d\ I. 5 it?lr/ Li. May 6, 2015 Richard L. Goodyear, Bureau Chief Air Quality Bureau Date EPA Inspection Report - Page 138 of 1969 TABLE OF CONTENTS Part A FACILITY SPECIFIC REQUIREMENTS .....................................................................3 A100 Introduction ................................................................................................................. 3 A101 Permit Duration (expiration) ....................................................................................... 3 A102 Facility: Description.................................................................................................... 4 A103 Facility: Applicable Regulations and Non-Applicable Regulations ........................... 5 A104 Facility: Regulated Sources ........................................................................................ 7 A105 Facility: Control Methods ........................................................................................... 8 A106 Facility: Allowable Emissions .................................................................................. 10 A107 Facility: Allowable Startup, Shutdown, & Maintenance (SSM) and Malfunction Emissions .................................................................................................................................. 12 A108 Facility: Hours of Operation ..................................................................................... 15 A109 Facility: Reporting Schedules ................................................................................... 16 A110 Facility: Fuel and Fuel Sulfur Requirements (as required) ....................................... 16 A111 Facility: 20.2.36 NMAC ........................................................................................... 17 A112 Facility: 20.2.37 NMAC ........................................................................................... 18 A113 Facility: 20.2.38 NMAC ........................................................................................... 19 A114 Facility: Relocation Requirements – Not Required .................................................. 20 A115 Alternative Operating Scenario – Not Required ....................................................... 20 A116 Compliance Plan – Not Required ............................................................................. 20 A117 Reducing Facility Emissions – Not Required ........................................................... 20 A118 Facility: MACT Subpart UUU.................................................................................. 20 A119 40 CFR 61 Subpart FF, National Emission Standard for Benzene Waste Operations 20 EQUIPMENT SPECIFIC REQUIREMENTS ..............................................................................21 Oil and Gas Industry ......................................................................................................................21 A200 Oil and Gas Industry ................................................................................................. 21 A201 Engines ...................................................................................................................... 21 A202 Glycol Dehydrators – Not Required ......................................................................... 22 A203 Tanks ......................................................................................................................... 22 A204 Heaters/Boilers .......................................................................................................... 24 A205 Turbines not required ................................................................................................ 34 A206 Flares ......................................................................................................................... 35 A207 Sulfur Recovery Plant (SRP), Tail Gas Incinerator (TGI) ........................................ 36 A208 Amine Unit – Not Required ...................................................................................... 38 A209 Fugitives .................................................................................................................... 38 A210 Loading Racks .......................................................................................................... 40 A211 Fluid Catalytic Cracking Unit (FCC)........................................................................ 41 A212 Cooling Towers ......................................................................................................... 43 A213 Wastewater Systems ................................................................................................. 44 Part B GENERAL CONDITIONS ...........................................................................................47 B100 Introduction ............................................................................................................... 47 B101 Legal ......................................................................................................................... 47 B102 Authority ................................................................................................................... 49 EPA Inspection Report - Page 139 of 1969 B103 Annual Fee ................................................................................................................ 50 B104 Appeal Procedures .................................................................................................... 50 B105 Submittal of Reports and Certifications .................................................................... 50 B106 NSPS and/or MACT Startup, Shutdown, and Malfunction Operations ................... 51 B107 Startup, Shutdown, and Maintenance Operations ..................................................... 51 B108 General Monitoring Requirements ........................................................................... 51 B109 General Recordkeeping Requirements ..................................................................... 53 B110 General Reporting Requirements .............................................................................. 55 B111 General Testing Requirements .................................................................................. 57 B112 Compliance ............................................................................................................... 60 B113 Permit Reopening and Revocation............................................................................ 61 B114 Emergencies .............................................................................................................. 62 B115 Stratospheric Ozone .................................................................................................. 62 B116 Acid Rain Sources..................................................................................................... 63 B117 Risk Management Plan ............................................................................................. 63 Part C MISCELLANEOUS ......................................................................................................64 C100 Supporting On-Line Documents ............................................................................... 64 C101 Definitions................................................................................................................. 64 C102 Acronyms .................................................................................................................. 66 Part D ATTACHMENTS ..........................................................................................................67 PART A FACILITY SPECIFIC REQUIREMENTS A100 Introduction A. PSD-NM-0195-M31 issued August 01, 2011, contained permit limits and control methods based on Best Available Control Technology (BACT). B. The permittee is under a Consent Decree CIV-01 1422LH Lodged 12/20/2001, Entered 3/5/2002 and referenced throughout this document as the “Consent Decree” or “CD” with reference numbers from that document. A101 Permit Duration (expiration) A. The term of this permit is five (5) years. It will expire five years from the date of issuance. Application for renewal of this permit is due twelve (12) months prior to the date of expiration. (20.2.70.300.B.2 and 302.B NMAC) B. If a renewal permit is not issued prior to the expiration date, the permittee may continue to operate beyond the expiration date, provided that a timely and complete renewal application is submitted no later than twelve (12) months prior to the expiration date. (20.2.70.400.D NMAC) EPA Inspection Report - Page 140 of 1969 A103 Facility: Applicable Regulations and Non-Applicable Regulations A. The permittee shall comply with all applicable sections of the requirements listed in Table 103.A. Table 103.A: Applicable Requirements Applicable Requirements NSR Permit No: PSD 0195-M35 (Per 20.2.72 NMAC) 20.2.1 NMAC General Provisions 20.2.7 NMAC Excess Emissions Federally Enforceable X X Unit No. 20.2.33 NMAC Gas Burning Equipment -- Nitrogen Dioxide X 20.2.36 NMAC Petroleum Refinery - Sulfur 20.2.37 NMAC Petroleum Processing Facilities 20.2.38 NMAC Hydrocarbon Storage Facilities 20.2.70 NMAC Operating Permits 20.2.71 NMAC Operating Permit Emission Fees 20.2.72 NMAC Construction Permit 20.2.73 NMAC Notice of Intent and Emissions Inventory Requirements 20.2.74 NMAC Prevention of Significant Deterioration X X X X X X Entire Facility Entire Facility Entire Facility Affected sources in Table 103.E Entire Facility Entire Facility Entire Facility Entire Facility Entire Facility Entire Facility X Entire Facility X 20.2.77 NMAC New Source Performance X 20.2.78 NMAC Emission Standards for Hazardous Air Pollutants (HAPs) X 20.2.82 NMAC MACT Standards for Source Categories of HAPS X 40 CFR 50 National Ambient Air Quality Standards X 40 CFR 60, Subpart A, General Provisions X Entire Facility Units subject to 40 CFR 60 Units subject to 40 CFR 61 Units subject to 40 CFR 63 Entire Facility See Tables 103.B to 103.K See Tables 103.B to 103.J 40 CFR 60, Subpart Db “Standards of Performance for IndustrialCommercial-Institutional Steam Generating Units” 40 CFR 60, Subpart Dc “Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, Which Construction, Reconstruction, or Modification Commenced After June 9, 1989” 40 CFR 60, Subpart J, “Standards of Performance for Petroleum Refineries” 40 CFR 60, Subpart Ja, “Standards of Performance for Petroleum Refineries for which Construction, Reconstruction, or Modification Commenced After May 14, 2007” 40 CFR 60, Subpart K, “Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978” X X X X X X H-0464; H-3101 See Tables 103.B to 103.J See Tables 103.B to 103.J See Tables 103.B to 103.J EPA Inspection Report - Page 141 of 1969 Table 103.A: Applicable Requirements Applicable Requirements 40 CFR 60, Subpart Ka, “Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984” 40 CFR 60, Subpart Kb, “Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After January 23, 1984” 40 CFR 60, Subpart GGG, Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries for which construction, reconstruction, or modification commenced after January 4, 1983, and on or before November 7, 2006. 40 CFR 60, Subpart GGGa, Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries for which construction, reconstruction, or modification commenced after November 7, 2006. 40 CFR 60, Subpart QQQ, Standards of Performance for VOC Emissions From Petroleum Refinery Wastewater Systems 40 CFR 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Federally Enforceable X X X X X X 40 CFR 61, Subpart A, General Provisions X 40 CFR 61, Subpart FF, National Emission Standards for Benzene Waste Operations X Unit No. See Tables 103.B to 103.k See Tables 103.B to 103.K See Tables 103.B to 103.K See Tables 103.B to 103.K See Tables 103.B to 103.K See Tables 103.B to 103.K Entire Facility 40 CFR 63, Subpart A, General Provisions 40 CFR 63, Subpart Q, National Emission Standards for Hazardous Air Pollutants for Industrial Process Cooling Towers X Benzene Waste Operations Entire Facility X See Table 103.F 40 CFR 63, Subpart CC X 40 CFR 63 Subpart DDDDD X 40 CFR 63 Subpart UUU, Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units 40 CFR 63, Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines 40 CFR 68, (RMP), Section 112(r) Accidental Release Consent Decree CIV-01 1422LH Lodged 12/20/2001, Entered 3/5/2002 Note: Tables 103.B through 103.L are located in Attachment D. B. Table 103.B, Summary Applicability – Fugitives C. Table 103.C, Summary Applicability – Tanks X See Tables 103.B to 103.K See Tables 103.B to 103.K See Tables 103.B to 103.KJ See Tables 103.B to 103.KJ X Entire Facility X Entire Facility X EPA Inspection Report - Page 142 of 1969 D. Table 103.D, Summary Applicability – Loading E. Table 103.E, Summary Applicability – Heaters and Boilers F. Table 103.F, Summary Applicability – Cooling Towers G. Table 103.G, Summary Applicability – Wastewater H. Table 103.H, Summary Applicability – FCC-CCR I. Table 103.I, Summary Applicability – SRU J. Table 103.J, Summary Applicability – Engines K. Table 103.K, Summary Applicability – Flares L. Table 103.L lists requirements that are not applicable to this facility. This table only includes those requirements cited in the application as applicable and determined by the Department to be not applicable, or the Department determined that the requirement does not impose any conditions on a regulated piece of equipment. Table 103.L: Non-Applicable Requirements Non-Applicable Requirements (1) None None X (2) X Justification For Non-Applicability 1. Not Applicable For This Facility: No existing or planned operation/activity at this facility triggers the applicability of these requirements. 2. No Requirements: Although these regulations may apply, they do not impose any specific requirements on the operation of the facility as described in this permit. M. Compliance with the terms and conditions of this permit regarding source emissions and operation demonstrate compliance with national ambient air quality standards specified at 40 CFR 50, which were applicable at the time air dispersion modeling was performed for the facility’s NSR Permit 0195-M35. A104 Facility: Regulated Sources A. Table 104.A (attached, page 68) lists the emission units authorized for this facility. Emission units that were identified as NSR exempt or Title V Insignificant activities and/or equipment not regulated pursuant to the Act are not included. EPA Inspection Report - Page 143 of 1969 A105 Facility: Control Methods A. Table 105.A lists all the pollution control equipment required for this facility. Each emission point is identified by the same number that was assigned to it in the permit application. Table 105.A: Control Methods: Control Equipment Unit Control Description No. Fluid Catalytic FCC Regenerator Cracking Unit Scrubber Regenerator Cyclones + Wet Gas Scrubber Pollutant being controlled Control for Unit Number(s)1 NO PM & SO2 FCC Regenerator BACT Yes or No CCR Regenerator Vent Refinery process units Refinery process units Refinery process units Refinery process units Refinery process units CHLOR SORB® CCR Regenerator Vent Control NO Chloride FL-0400 North Plant Flare NO VOC & H2S FL-0401 South Plant Flare NO VOC & H2S FL-0402 FCC Flare NO VOC & H2S FL-0403 Alky Flare NO VOC FL-0404 GOH Flare NO VOC & H2S NO VOC Pipeline Pigging Operations NO Sulfur SRU1 and SRU2 YES NOx H-9851 YES Sulfur SRU3 YES SO2 SRU3 NO VOC MAIN API Portable Flare for Holly Energy Partners (HEP) FL-HEP-PORT Pipeline Pigging Operations Sulfur Recovery Units H-0473 No. 1 & 2 Tail Gas Incinerator Selective Catalytic SCR Reduction + ultra-low NOx burners Sulfur Recovery Unit SRU3-TGI No. 3 Tail Gas Incinerator Best Work Practices, SRU3/TGTU3/TGI3 A207.B (BACT) Main API Carbon D-0829/0830 Canisters EPA Inspection Report - Page 144 of 1969 Table 105.A: Control Methods: Control Equipment Unit Control Description No. Drift Eliminators on Y-0011, Y-0012 Cooling Towers (BACT) External Floating Roofs T-0737, T-1225 (BACT) External and Internal See Tables 106.B(1) Floating Roofs (Noneand (2) BACT) Energy Efficiency, B-0009 A204.N (BACT) H-2501, H-3402, H- ultra-low NOx burners 3101 (BACT) SRU-TGI, H-2501, H-3402, H-3101 1 Combust gaseous fuels only Pollutant being controlled Control for Unit Number(s)1 YES PM Y-0011, Y0012 YES VOC T-0737, T-1225 NO VOC See Tables 106.B(1) and (2) Yes Greenhouse Gases B-0009 Yes NOx Yes VOC, PM BACT Yes or No Control for unit number refers to a unit number from the Regulated Equipment List H-2501, H3402, H-3101 SRU-TGI, H2501, H-3402, H-3101 In accordance with the requirement that Navajo Refining prevent exceedances of the 24hour and 3-hour National Ambient Air Quality Standards (NAAQS) for SO2 during major refinery malfunctions, Navajo Refining shall only flare acid gas from existing Flare FL0403 according to Navajo Refining's "Phase Two" plan dated January 5, 1996 and received by the Department on January 8, 1996, or from Flare FL-0400. Navajo shall undertake the following measures for acid gas flaring from FL-0400 and FL-0403. C H A RT N O . 1 (1) Existing Flare FL-0400 shall be equipped SUPP FUEL FOR SO2 NAAQS COMPLIANCE, FL-400 with a flare tip or burners to supply 90.0 supplemental fuel gas to provide enough 80.0 heat to supplement the heat released by 70.0 combustion of the acid gas itself and the 60.0 heat provided by smoke-suppressing 50.0 40.0 steam. The minimum flow rate of 30.0 supplemental fuel gas to be supplied 20.0 during acid gas flaring such that 10.0 compliance with the NAAQS for SO2 is 0.0 0 10 20 30 40 50 60 assured shall be determined using Chart Supp Fuel Gas Flow (Mscfh) No. 1. The fuel gas used for this purpose shall be natural gas (see definition at C101.F). Acid Gas FLow (Mscfh) B. 70 EPA Inspection Report - Page 145 of 1969 (2) C. D. Existing Flare FL-0403 shall be equipped with a flare tip or burners to supply CHART NO. 2 supplemental fuel gas to provide enough SUPP. FUEL FOR SO2 NAAQS COMPLIANCE, FL-403 supplemental heat. The volume of 40 Supp. Fuel Gas supplemental fuel gas to be provided to 35 generate enough supplemental heat to 30 ensure compliance with NAAQS for SO2 25 20 shall be determined using Chart No. 2. 15 The supplemental heat to be provided 10 when flaring the maximum quantity of 5 acid gas has been determined to be 52.9 0 million BTU per hour which is generated 0 20 40 60 80 100 Supp. Fuel Gas (Thousand SCFH) by burning 96,200 SCFH of supplemental fuel gas. This assumption has been made to ensure compliance with the NAAQS for SO2. The fuel gas used for this purpose shall be natural gas (see definition at C101.F). Beginning December 20, 2001 no fuel oil shall be burned in combustion units except as follows: (CD ¶17.C) (1) Torch Oil may be burned in the FCC Regenerator during FCC start-ups; and. (2) Fuel Oil may be burned in combustion units after the establishment of FCC NOx emissions limits pursuant to permit condition A110.A, provided that emissions from any such combustion units are routed through the FCC Wet Gas Scrubber and Navajo demonstrates, with the approval of EPA, that the NOx emissions limits contained therein and the SO2 emissions limits stated in A106.A and A107.A will continue to be met. The Artesia Refinery FCC was initially limited to less than 20,000 BPD capacity. Following the December 2003 expansion of the Artesia refinery’s FCC as authorized by permit 195-M15, the catalyst regenerator for the FCC is subject to the minimum requirements for continuous emission monitoring and recording set forth in Appendix P to 40 CFR Part 51. Consent Decree Paragraph 15 required the FCC to be subject to NSPS Subpart J for opacity as of December 31, 2003. A wet gas scrubber was installed in 2003. An Alternative Monitoring Plan (AMP) request was submitted to EPA on December 31, 2003 because a continuous opacity monitoring system (COMS) will not work on a wet gas scrubber exhaust because of the interference from the water vapor. The AMP satisfies the requirements for both NSPS Subpart J and 40 CFR Part 51 Appendix P. A106 Facility: Allowable Emissions A. The following Section lists the emission units, and their allowable emission limits. (See Table 103.A for all applicable regulations) EPA Inspection Report - Page 146 of 1969 Table 106.A: Allowable Emissions (See Part D, and page 82) B. The permitted emission sources at the refinery shall consist only of the sources listed in Table 106.A and Tables 106.B through 106.I of this permit. C. Compliance with Allowable Emission Limits Requirement: The allowable mmBtu/hr, lb/mmBtu, lb/hr, and tpy emission limits for equipment listed in Table 106.A construction of which predates the effective date of 20.2.72 NMAC (August 31, 1972), and have not been modified since August 31, 1972, shall be the "potential emission rate" of that unit as defined in 20.2.72.107 NMAC and the potential to emit of that unit defined under 20.2.74 NMAC. The mmBtu/hr, lb/hr and lb/mmBtu limits are based on an hourly rolling 3-hour average. (NSR 0195M35, Condition A106.C and revised) Monitoring: For units with lb/mmBtu emission limits in Table 106.A, the Permittee shall monitor the lb/mmBtu to demonstrate compliance with the mmBtu/hr, lb/hr, and tpy emission limits. Recordkeeping: To demonstrate compliance, records shall be kept showing the correlation between lb/mmBtu and the mmBtu/hr and lb/hr, and the monthly rolling 12-month tpy totals. The records shall also document any non-compliance with emission limits. For each unit, a summary of the method used to determine compliance shall be recorded. The permittee shall maintain records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. D. BACT SO2 Limit – Fuel sulfur limit Refinery-Wide for all units burning refinery fuel gas (excluding units H-8801, H-8802 and H-9851 which burn only natural gas) shall not exceed 60 ppmv H2S on a daily rolling 365-day average. The ton/yr emission rates for SO2 in Table 106.A of this permit are based on this daily rolling 365-day average 60 ppmv H2S limit. Compliance with this limit shall be demonstrated per the methods described in Condition A110.A. E. BACT NOx Limit - In addition to the emission limits shown in Table 106.A, Boiler Unit B-0009 has a BACT NOx limit of 0.02 lb/MM Btu, and CO2 limit of 112.1 lb/MM Btu. F. BACT SO2 Limit – The Sulfur Recovery Unit No. 3 Tail Gas Incinerator (SRU3-TGI) is limited to 192 ppmvd SO2 at zero percent oxygen on a hourly rolling 12-hour average basis. In addition, SRU3-TGI is limited to 192 ppmvd SO2 at zero percent oxygen on a daily rolling 365-day average basis. G. BACT VOC Limit – The naphtha storage tank T-1225 and sour water storage tank T-0737 shall be equipped with an external floating roof using double seals to reduce VOC emissions to the atmosphere. The maximum true vapor pressure of any volatile organic EPA Inspection Report - Page 147 of 1969 liquid stored in either tank shall not exceed 11.0 psia. Demonstration of compliance is through the NSPS Kb and MACT emission limits. H. VOC – All fugitive piping components in VOC service associated with the process units proposed in Permit 195-M25 (Units FUG-25-ROSE-2, FUG-31-SRU3/TGI3/TGI3, and FUG-34-Hydorcracker) shall be monitored under the MACT subpart CC leak detection and repair program, or an approved equivalent program, to reduce VOC emissions. I. VOC – Consistent with MACT Subpart CC, the gasoline truck loading rack (TLO-4) shall be limited to 10 mg of VOC emissions per liter of gasoline loaded. J. PM10 – Cooling towers, Units Y-0011 and Y-0012, shall be equipped with high-efficiency drift eliminators to reduce PM10 emissions. Demonstration of compliance is through annual inspection in accordance with in Condition A212.B. A107 Facility: Allowable Startup, Shutdown, & Maintenance (SSM) and Malfunction Emissions A. The maximum allowable SSM and Malfunction emission limits for this facility are listed in Table 107.A and were relied upon by the Department to determine compliance with applicable regulations. Table 107.A: Allowable SSM and Malfunction Emissions Units, Activities, and Emission Limits (See Part D, and page 92) B. The authorization of emission limits for startup, shutdown, maintenance, and malfunction does not supersede the requirements to minimize emissions according to Conditions B101.C and B107.A. C. SSM Flaring and combustion Emissions Requirement: The permittee shall comply with the flaring and combustion SSM NOx, CO, VOC, SO2, TSP, PM10, PM2.5, and H2S emission limits at Table 107.A for the following SSM events: 1) 2) 3) 4) 5) SSM H-9851, Emissions during SCR downtime SSM SRU-TGI, Emissions from SRU3 startup and shutdown SSM FL-HEP-PORT, Temporary, portable flare for natural gas pipeline maintenance SSM SRU2-TGI (H-0473), Emissions from SRU2 startup and shutdown SSM Flare Cap, Emissions from venting SSM activity gases to FL-400, FL-401, FL-402, FL-403, or FL-404 6) SSM Misc 2, Low-Emitting Maintenance Activities such as de-inventorying small equipment, clearing piping associated with emission units, and routine maintenance activities such as heat exchanger repair. (NSR 0195M35, Condition A107.C and revised) EPA Inspection Report - Page 148 of 1969 Monitoring: The permittee shall monitor all flaring and combustion due to routine and predictable startups, shutdowns, and scheduled maintenance events. This shall be accomplished by collecting all the SSM flaring and combustion information specified in A107C. Recordkeeping. Recordkeeping: The permittee shall record the date, start and end times, and duration of every SSM flaring or combustion event. The NOx, CO, VOC, SO2, TSP, PM10, and H2S emissions shall be calculated for each event based on the volume of gas sent to the flare and the total sulfur content of the flared gas. Compliance with the hourly emission rates shall be demonstrated by calculating the hourly emission rates for each event and comparing the results to the hourly emission rate at Table 107.A. The annual emission rate shall be calculated as follows: 1) To demonstrate compliance during the first 12 months of monitoring, the permittee shall calculate and sum the monthly cumulative total of NOx, CO, VOC, SO2, TSP, PM10, PM2.5, and H2S emissions; and 2) After the first 12 months of monitoring, the permittee shall calculate and sum the total of NOx, CO, VOC, SO2, TSP, PM10, PM2.5, and H2S emissions on a monthly rolling 12 month basis. 3) The permittee shall maintain all records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. D. SSM VOC Emissions (Facility-Wide, Non-Combustion Sources) Requirement: The permittee shall comply with the SSM VOC emission limit at Table 107.A. Monitoring: The permittee shall monitor all VOC emission activities due to routine and predictable startups, shutdowns, and scheduled maintenance events. This shall be accomplished by collecting VOC emission calculation information for the following SSM VOC emission activities: 1) 2) 3) 4) 5) SSM T-0737, Emissions from roof landing SSM T-0078, Emissions from roof landing and tank refilling SSM T-0079, Emissions from roof landing and tank refilling SSM T-1225, Emissions from roof landing SSM Tanks Miscellaneous Recordkeeping: The annual SSM VOC emission rate shall be calculated as follows: 1) To demonstrate compliance during the first 12 months of monitoring the permittee shall calculate and sum the monthly cumulative total of VOC emissions; and 2) After the first 12 months of monitoring the permittee shall calculate and sum the total of VOC emissions on a monthly rolling 12 month basis, including the methodology and/or assumptions used in the calculation(s). The permittee shall keep records to demonstrate compliance in accordance with Condition B109C, except the requirement in B109.C(2) to record the start and end times of SSM events shall not apply to known quantities of VOC emissions. 3) The permittee shall maintain all records in accordance with Section B109. EPA Inspection Report - Page 149 of 1969 Reporting: The permittee shall report in accordance with Section B110. E. SSM Particulate Emissions (Unit SSM Misc 1) Requirement: The permittee shall minimize particulate emissions due to SSM events. Monitoring: The permittee shall monitor all particulate emissions due to routine and predictable startups, shutdowns, and scheduled maintenance events. For the event type of FCCU Catalyst Loading, the maximum material usage shall not exceed 1 hr-duration, 1 loading event/yr; and 237,048 lb/event/yr. Recordkeeping: For each event, the permittee shall maintain records of the duration in hours, events per year, and material usage for the particulate matter emitting SSM event - FCCU Catalyst Loading. The annual material usage shall be based on monthly rolling 12-month total. The permittee shall maintain all records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. F. SSM and Malfunction Flaring Emissions (SSM Flare Cap and Flares Malf Cap) Requirement: The permittee shall not exceed the pound per hour (pph) and ton per year (tpy) emission limits in Table A107.A and shall demonstrate compliance with these limits by calculating and summarizing these emission rates as required in recordkeeping. Monitoring: A gas flowmeter and flow totalizer, equipped with a chart recorder or electronic data logger, shall be installed in the flare line to measure and record the total standard cubic feet (scf) of all gas (process gas, purge gas, pilot gas, and supplemental fuel gas) sent to the flare during each hour and each month. The permittee shall measure the H2S content, the total sulfur content, the VOC content, and the heating value (Btu/scf) of the gas sent to the flare for combustion. H2S shall be measured at least once every 24-hours on each of the inlet gas types/streams using a stain tube of the appropriate size range or an inline H2S monitor. The total sulfur content, VOC content, and heating value (Btu/scf) of the natural gas sent to the flare shall be measured at least once annually with an extended gas analysis. The flow meter and flow totalizer shall be operated, calibrated, and maintained as specified by the manufacturer and as necessary to ensure correct and accurate readings. If used, the inline monitor shall be operated, calibrated, and maintained as specified by the manufacturer and as necessary to ensure correct and accurate readings. Recordkeeping: The following records shall be kept: • stain tube and/or inline H2S measurements • annual extended gas analysis • both the hourly and monthly volume (scf) of gas sent to the flare Each month, the permittee shall record and summarize in a table format the following. • H2S and the total sulfur content EPA Inspection Report - Page 150 of 1969 A109 Facility: Reporting Schedules A. A Semi-Annual Report of monitoring activities is due within 45 days following the end of every 6-month reporting period. The six month reporting periods start on September 1st and March 1st of each year. B. The Annual Compliance Certification Report is due within 30 days of the end of every 12month reporting period. The 12-month reporting period starts on September 1st of each year. C. In addition to the reports required by the applicable NSPS, NESHAP and MACT Subparts (including any voluntary programs referencing NSPS, NESHAP, or MACT Subparts) and by the applicable parts of 20.2 NMAC, the reporting required by the Consent Decree shall be submitted to the Department. The reports shall be submitted to the Air Quality Bureau within forty five (45) days of the end of each calendar quarter. If any reports indicate potential non-compliance with the terms of this permit, the Bureau may impose a more frequent reporting time-frame. The Department shall handle any confidential information in accordance with the provisions of 20.2.1.115 NMAC. D. Reporting required by the Consent Decree (not an exhaustive listing) (1) The permittee shall notify the Department’s Enforcement Section, Air Quality Bureau in writing of the annual progress of installation of NOx Control Technology required by Paragraph 16 of the Consent Decree. The report shall be submitted to the EPA and the NMED on or before December 31st of each calendar year commencing with the year 2002. (CD ¶16.E) (2) No later than forty-five (45) days following the end of an AG Flaring or TG Incident, the permittee shall submit to EPA and the NMED a report that sets forth the items detailed in the Consent Decree. (CD ¶20, CD¶21) A110 Facility: Fuel and Fuel Sulfur Requirements (as required) A. Fuel, Fuel Sulfur, and NSPS J, Ja Sulfur Requirements (See Tables 103.E, H, I, & K, Summary of Applicable Requirements) Requirement: (NSR 0195M35, Condition A110.A and revised) (1) To comply with NSPS Subpart J, NSPS Subpart Ja, and the PSD BACT requirements in Section 106, the permittee shall install, calibrate and maintain a continuous monitoring system (CMS) to continuously measure and record either the hydrogen sulfide (H2S) in the refinery fuel gas streams being burned in the Heaters and Boilers or the concentration of sulfur dioxide emissions to the atmosphere. (2) All stationary combustion equipment shall be fired with NSPS quality fuel gas with a maximum H2S content of 0.1 grains/dscf (approx. 162 ppmv), based on a hourly rolling 3-hour average. (3) All stationary combustion equipment shall not combust gas with an annual average sulfur EPA Inspection Report - Page 151 of 1969 content exceeding 60 ppmv (approx. 0.037 grains) as a daily rolling 365-day average. (4) All stationary combustion equipment shall be affected facilities, as defined in NSPS 40 CFR Part 60, Subparts A and J or Ja, if refinery-produced fuel gas is combusted in the heaters and boilers, and shall comply with all applicable requirements of NSPS Subparts A and J or Ja. (See Table 103.E, Summary of Applicable Requirements) Monitoring: (1) The permittee shall install, certify, calibrate, maintain and operate a fuel gas continuous monitoring system (CMS) at the fuel gas mix drum outlet in accordance with the requirements of 40 CFR §§ 60.11, 60.13, and Part 60 Appendix A, and the applicable performance specification of 40 CFR Part 60 Appendices B and F. (2) The following CMS shall be certified initially and recertified annually: • D-0019 Low Pressure Fuel Gas H2S CMS • D-0770 High Pressure Fuel Gas H2S CMS (3) As required by the EPA-approvable alternative monitoring procedure (AMP), CCR off-gas streams that enter the refinery fuel gas system downstream of the H2S CMS shall be monitored quarterly for H2S using gas detector tubes or an equivalent method as follows: (a) CCR stabilizer off gas stream, (b) H2 recycle gas stream, and c) CCR feed stream. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subparts A, J, and Ja. (1) Records of the quantity of the refinery fuel gas and the monthly average heating value of the refinery fuel gas. This is used to demonstrate compliance with lb/mmBTU and lb/hr limits shown in Table 106.A. (permit limit) (2) Records of repairs, maintenance, and calibrations performed for the instruments that measure flow or concentration for an applicable permit limit shall be kept. Examples include, but are not limited to, CMS, acid gas flow meters, and fuel gas flow meters. (40 CFR 60, Appendix F) (3) Records shall be kept of Alternative Monitoring Plan (AMP) H2S analyses of the CCR offgas streams that enter the refinery fuel gas system downstream of the fuel gas H2S CMS. (NSPS J or Ja) Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subparts A, J, and Ja, and Section B110. A111 Facility: 20.2.36 NMAC A. Facility: 20.2.36 NMAC Requirement: 20.2.36 NMAC (Petroleum Refinery - Sulfur, 11/30/95) applies to the refinery as a whole. Quarterly refinery-wide sulfur balance reports shall be filed in accordance with 20.2.36.113 NMAC. All flares and stacks shall meet the applicable height requirements of 20.2.36.114 NMAC as demonstrated through air dispersion modeling done at the time of unit EPA Inspection Report - Page 152 of 1969 installation. (NSR 0195M35, Condition A111.A) Monitoring: Quarterly monitoring of refinery-wide sulfur balance. Recordkeeping: The permittee shall keep record of a copy of the Facility-Wide Sulfur Balance Report and the actual height of flares and stacks. Reporting: The permittee shall report in accordance with 20.2.36.113A NMAC. A112 Facility: 20.2.37 NMAC A. 20.2.37 NMAC Requirement: (NSR 0195M35, Condition A112.A) (1) Section 200.A (Mercaptans) and section 200.B (Hydrogen Sulfide) apply to mercaptan and H2S emissions from the refinery. Section 200.C applies to FL-0400, FL-0401, FL-0402, FL0403, and FL-0404, and requires an alarm in good working order to signal non-combustion of the gas. (2) Section 201.A (CO), applies to the refinery's FCC regenerator stack. The owner or operator of an existing petroleum processing facility shall not permit, cause, suffer or allow carbon monoxide emissions to the atmosphere from a catalyst cracking recirculation or regeneration unit in excess of 20,000 ppm by volume in the undiluted effluent gas stream or streams. (3) Section 202.C(1) (PM), The owner or operator of a new petroleum processing facility shall not permit, cause, suffer or allow particulate matter emissions to the atmosphere from the catalytic cracking regenerator vessel in excess of 1.0 Kg/1000 Kg (1.0 lb/1000 lb) of coke burnoff or visible emissions of thirty percent (30%) opacity or greater except for one six-minute average opacity reading in any one-hour period. (4) Section 203 (Ammonia, undiluted emissions ≤ 25 ppmv) applies to all emission points of the refinery. The owner or operator of a petroleum processing facility shall not permit, cause, suffer or allow ammonia emissions to the atmosphere in excess of 25 ppm by volume in the undiluted effluent gas stream or streams. (5) Section 204 (Hydrocarbon Separation Facility) applies to all oil/water separators at the refinery. Compliance with this condition is met by complying with the applicable NSPS Subpart QQQ requirements. (6) Section 205 (Facilities - Storage - Handling - Pumping - Blowdown System) applies to certain of the following: storage tanks for organic compounds, loading and unloading of organic compounds, seals on pumps and compressors, and disposal (flaring) of hydrocarbon gases. The permittee shall not permit, cause, suffer or allow the operation of a blowdown system without disposing of the gases in a manner which will minimize hydrocarbon emission to the atmosphere. If combustion is the means of disposal, it shall be by: smokeless flare; or any other method that is equally effective to achieve complete combustion. (20.2.37.205.E NMAC) Monitoring: (1) For Units FL-0400, FL-0401, FL-0402, FL-0403, and FL-0404: The permittee shall install EPA Inspection Report - Page 153 of 1969 and maintain a flare pilot flame monitoring system. (20.2.37.200.A.2 NMAC) (2) A CO CMS has been installed to monitoring the emissions from the FCC. (3) The annual EPA Method 9 Opacity Test and annual Stack test on Unit FCC (lb/hr PM emissions) and the calculated Coke burn rate will be used for the annual determination of pounds of PM per 1000 pounds of Coke burned. (4) None (5) No additional monitoring since compliance is met by complying with the applicable NSPS Subpart QQQ requirements. See other conditions of this permit for applicable NSPS or MACT requirements. (6) Compliance is demonstrated through NSPS K, NSPS Ka, NSPS Kb, or MACT CC for Tanks; through MACT CC for Loading Racks; through NSPS GGG, NSPS GGGa or MACT CC for Pumps and Compressors; and through NSPS Subpart A for Blowdowns. Recordkeeping: (1) Pilot flame monitoring records (2) CO CMS measurements (3) Copy of annual coke burn rate determination, stack test report, and opacity test report (4) None (5) Applicable NSPS Subpart QQQ requirements (6) Applicable NSPS K, NSPS Ka, NSPS Kb, or MACT CC for Tanks; through MACT CC for Loading Racks; through NSPS GGG, NSPS GGGa or MACT CC for Pumps and Compressors; and through NSPS Subpart A for Blowdowns requirements Reporting: The permittee shall report in accordance with applicable NSPS or MACT requirements and Section B110. A113 Facility: 20.2.38 NMAC A. 20.2.38 NMAC Requirement: 20.2.38 NMAC (Hydrocarbon Storage Facilities, 11/30/95) applies to the refinery as follows: 1. Section 109 (Tank Storage Associated with Petroleum Production or Processing Facility [Sour Hydrocarbon Liquids]) applies to the loading and storing of hydrocarbons containing H2S. 2. Section 110 (Tank Battery or Storage Facility - Within Municipality [Sour Hydrocarbon Liquids]) applies to certain tanks storing sour hydrocarbon liquids whose vapors contain >24 ppm H2S. 3. Section 113 (New Tank Battery and the Pecos-Permian Interstate Air Quality Control Region [Sour Hydrocarbon Liquids]) applies to certain tanks storing sour hydrocarbon liquids whose EPA Inspection Report - Page 154 of 1969 vapors contain >24 ppm H2S. (NSR 0195M35, Condition A113.A) Monitoring: 1. None 2. and 3. Demonstrated through NSPS K, Ka, Kb, and MACT CC floating roof seal inspection. Recordkeeping: 1. Records of Tank design showing inlet piping connections. 2. and 3. No additional requirements other than applicable requirements of NSPS and MACT. Reporting: The permittee shall report in accordance with Section B110. A114 Facility: Relocation Requirements – Not Required A115 Alternative Operating Scenario – Not Required A116 Compliance Plan – Not Required A117 Reducing Facility Emissions – Not Required A118 Facility: MACT Subpart UUU A. 40 CFR 63, Subpart UUU FCC, FUG-70-CCR, SRUs 1, 2,and 3 Requirement: The permittee shall comply with all applicable requirements of 40 CFR 63, Subpart UUU, National Emission Standards for Hazardous Air Pollutants for Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units, for all affected sources shown in Tables 103H&I attached. (63.1560 and 63.1570). Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart UUU. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63, Subpart UUU. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 63, Subpart UUU. A119 40 CFR 61 Subpart FF, National Emission Standard for Benzene Waste Operations A. 40 CFR 61 Subpart FF, National Emission Standard for Benzene Waste Operations (Units subject in Table 103.C & G) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 61, Subpart FF, National Emission Standard for Benzene Waste Operations for the affected sources EPA Inspection Report - Page 155 of 1969 in Tables 103.C, G. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 61, Subpart FF. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 61.356. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 61.357. EQUIPMENT SPECIFIC REQUIREMENTS OIL AND GAS INDUSTRY A200 Oil and Gas Industry A. A201 A. This section has common equipment related to most Oil and Gas Operations. Engines Maintenance and Repair Monitoring (Units G-0100, G-0101, V-0543, V-0545, V-0546, E8010, E-0600W, E-0601M, E-0602E, E-0603, and E-0901; Units G-0100, G-0101, V-0543, V-0545, V-0546, E-8010, E-0600W, E-0601M, E-0602E, E-0603, and E-0901) Requirement: These units are subject to Title V since they are subject to NSPS and/or MACT requirements. No emission limits were established since their emissions are small. The permittee shall ensure these units are properly maintained and repaired. Monitoring: Maintenance and repair shall meet the minimum manufacturer's or permittee's recommended maintenance schedule. Activities that involve maintenance, adjustment, replacement, or repair of functional components with the potential to affect the operation of an emission unit shall be documented as they occur for the following events: (1) Routine maintenance that takes a unit out of service for more than two hours during any twenty-four hour period. (2) Unscheduled repairs that require a unit to be taken out of service for more than two hours in any twenty-four hour period. Recordkeeping: The permittee shall maintain records in accordance with Section B109, including records of maintenance and repairs activities and a copy of the manufacturer’s or permittee’s recommended maintenance schedule. Reporting: The permittee shall report in accordance with Section B110. EPA Inspection Report - Page 156 of 1969 B. 40 CFR 63, Subpart ZZZZ (Units G-0100, G-0101, V-0543, V-0545, V-0546, E-8010, E0600W, E-0601M, E-0602E, E-0603, and E-0901) (Units subject in Table 103.J) Requirement: The units listed as subject in Table 103.J are subject to 40 CFR 63, Subpart ZZZZ and the permittee shall comply with all applicable requirements of Subpart A and Subpart ZZZZ. Monitoring: The permittee shall comply with all applicable monitoring and testing requirements of 40 CFR 63, Subpart A and Subpart ZZZZ. Recordkeeping: The permittee shall comply with all applicable recordkeeping requirements of 40 CFR 63, Subpart A and Subpart ZZZZ, including but not limited to 63.6655 and 63.10. Reporting: The permittee shall comply with all applicable reporting requirements of 40 CFR 63, Subpart A and ZZZZ, including but not limited to 63.6645, 63.6650, 63.9, and 63.10. C. 40 CFR 60, Subpart IIII (Diesel Engines subject in Table 103.J) Requirement: The units listed as subject in Table 103.J are subject to 40 CFR 60, Subparts A and IIII and shall comply with the notification requirements in Subpart A and the specific requirements of Subpart IIII. Monitoring: The permittee shall comply with all applicable monitoring and testing requirements in 40 CFR 60, Subpart A and Subpart IIII, including but not limited to 60.4211. Recordkeeping: The permittee shall comply with all applicable recordkeeping requirements in 40 CFR 60, Subpart A and Subpart IIII, including but not limited to 60.4214. Reporting: The permittee shall comply with all applicable reporting requirements in 40 CFR 60, Subpart A and Subpart IIII, including but not limited to 60.4214. A202 Glycol Dehydrators – Not Required A203 Tanks A. NSPS Subpart K, Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978 (Tanks subject in Table 103.C) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A & K for the affected sources in Table 103.C. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart K. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart K. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart K. EPA Inspection Report - Page 157 of 1969 B. NSPS Subpart Ka, Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984 (Tanks subject in Table 103.C) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A & Ka for the affected sources in Table 103.C. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart Ka. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart Ka. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart Ka. C. NSPS Subpart Kb, "Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After January 23, 1984" (Tanks subject in Table 103.C) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A & Kb for the affected sources in Table 103.C. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart Kb. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart Kb. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart Kb. D. MACT Subpart CC, “National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries” (Tanks subject in Table 103.C) Requirement: The permittee shall comply with all applicable requirements of MACT Subpart CC, “National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries” for all affected sources shown in Table 103.C attached. (63.640). Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63.655. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 63.655. E. Tank Throughput, Temperature, and VOC and H2S Limits (Units shown in Tables 106.B & C) EPA Inspection Report - Page 158 of 1969 Requirement: Compliance with the allowable throughput limits and emission limits in Table 106.D & E shall be demonstrated by not exceeding the monthly rolling 12-month total throughput to the unit(s) of gallons per year (barrels/year) shown in Table 106.D and not exceeding the allowable vapor pressure listed in Tables 106.B & C. Monitoring: The permittee shall monitor the monthly total throughput, maximum temperature once per month and the vapor pressure of each tank. Recordkeeping: The permittee shall record the monthly total throughput of liquids and the vapor pressure of each tank. Each month, during the first 12 months of monitoring, the permittee shall record the cumulative total liquid throughput and vapor pressure and after the first 12 months of monitoring, the permittee shall calculate and record a monthly rolling 12month total liquid throughput and the vapor pressure of each tank. The permittee has calculated the VOCs and H2S annually based on the 12-month total. Tank breathing and working emissions were calculated using the USEPA Tanks program Version 4.0.9.d or more current. Emission rates computed using the same parameters, but with a different Department approved algorithm that exceed these values will not be deemed noncompliance with this permit. Records shall also be maintained in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. A204 Heaters/Boilers A. Operational Inspection (All heaters/boilers in Tables 103.E & 104.A) Requirement: Compliance with the allowable emission limits in Table 106.A shall be demonstrated by performing periodic inspections to ensure proper operations. Monitoring: The permittee shall conduct annual operational inspections to determine that the heater(s)/boiler(s) are operating properly. The operational inspections shall include operational checks for indications of insufficient excess air, or too much excess combustion air. These operational checks shall include observation of common physical indications of improper combustion, including indications specified by the heater/boiler manufacturer, and indications based on operational experience with the/these unit(s). Recordkeeping: The permittee shall maintain records of operational inspections, describing the results of all operational inspections noting chronologically any adjustments needed to bring the heater(s)/boiler(s) into compliance. The permittee shall maintain records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. Within ninety (90) days of permit issuance, the permittee shall submit for Department approval a procedure which the permittee will use to carry out the operational inspections. The permittee may at any time submit revisions for Department approval. EPA Inspection Report - Page 159 of 1969 B. Periodic Emissions Tests (Units Heaters H-0019, H-0020, H-0362, H-0363, H-0364, H2421, H-3402, and H-3403) Requirement: Compliance with allowable emission limits in Table 106.A shall be demonstrated by performing periodic emissions tests. (NSR 0195M35, Condition A204.A, revived) Monitoring: The permittee shall conduct annual periodic portable analyzer emission tests or EPA Reference Method Tests for NOx and CO. Test results that demonstrate compliance with the CO emission limits shall also be considered to demonstrate compliance with the VOC emission limits. Section B108 General Monitoring Requirements apply to this condition. The permittee shall meet the testing requirements in Section B111. Recordkeeping: Records of periodic emission tests shall include the flow rate and the stack gas exhaust temperature. If a combustion analyzer is used to measure NOx, CO, and/or excess air in the flue gas, records shall be kept of the make and model of the instrument and instrument calibration data. If an ORSAT apparatus or other gas absorption analyzer is used, the permittee shall record all calibration results. Records shall be kept of all raw data used to determine flue gas flow and of all calculations used to determine flow rates and emission rates. The permittee shall maintain records in accordance with Section B109, B110, and B111. Reporting: The permittee shall summarize in tabular form the results of the initial or subsequent periodic emissions tests for NOx and CO, specifying the mass emissions rates in pounds per hour. The table shall include the average concentration of all relevant pollutant species. The permittee shall report in accordance with Section B109, B110, and B111. C. Summary of Compliance Methods for Heaters and Boilers for Table 106.A, 20.2.33 NMAC, 20.2.37 NMAC (Boilers and Heaters in Tables 103.E and 104.A) Requirement: (NSR 0195M35, Condition A204.B) (1) Demonstrate compliance with Table 106.A Allowable Emissions. (2) 20.2.33 NMAC (Gas Burning Equipment – Nitrogen Dioxide, 10/31/02) applies to existing and new gas burning equipment having a heat input of greater than 1,000,000 million British Thermal Units per year. It applies to process heaters identified in Tables 103.E and 104.A. These units shall be equipped with burners emitting less than 0.2 lb NOx per MM Btu. Compliance with 20.2.33 NMAC is demonstrated by compliance with the NOx lb per MM Btu limits in Table A106.A. Monitoring: (1) The permittee shall monitor the fuel usage of the all boilers and heaters. The fuel usage shall be monitored for specific heaters and boilers subject to 20.2.33 NMAC. (2) For specific heaters and boilers subject to 20.2.33 NMAC, the permittee shall collect and analyze samples of the refinery fuel gas at least once per week. The refinery fuel gas analysis EPA Inspection Report - Page 160 of 1969 shall include the composition of the refinery fuel gas, the gross heating value, and the net heating value. (3) See Condition A110.A for H2S monitoring requirements. (4) All process heaters and boilers shall fire only refinery gas in accordance with Application, Section 2, Table 2-J. (5) For those combustion sources required to have a continuous monitoring system (CMS) (listed in (a) below), the permittee shall install, certify, calibrate, maintain, and operate the CMS for each required pollutant in accordance with the applicable requirements of 40 CFR 60 or 63. The hourly average CMS data, the refinery fuel gas usage data, and the refinery fuel gas composition data shall be used to estimate the actual emission rates. (a) • • • • • The following CMS shall be recertified annually: Boiler B-0007 NOx and O2 CMS Boiler B-0008 NOx and O2 CMS Boiler B-0009 NOx and O2 and CO2 CMS H-9851 NOx O2 CMS H-2501 NOx O2 CMS (6) For those combustion sources required to conduct periodic stack exhaust testing as stated in Condition A204.B, the test reports shall be used to demonstrate compliance with the NOx, CO, and VOC limits in Table 106.A. (7) For those units and pollutants that are not required to have a CMS or a periodic stack test, (Units H-009, H-0011, H-0018, H-0028, H-0030, H-0040, H-0303, H-0312, H-0352, H-0353, H-0354, H-0355, H-0421, H-0464, H-0473, H-0600, H-0601, H-8801, H-8802, and H-3101) the permit application emission factor, the fuel usage, and the refinery fuel gas analysis shall be used to calculate the emission rates of NOx, CO, VOC, and PM. (8) Compliance with the particulate emission limitation set forth in 20.2.37.202.A NMAC shall be determined as specified in 20.2.37.202.D(3) NMAC. Combustion of only gaseous fuel has been approved by the Department as the compliance method under 20.2.37.202.D(3) NMAC. Recordkeeping: The permittee shall maintain the following records: (1) By March 31, the annual fuel usage for all boilers and heaters for the previous calendar year. (2) By March 31, the average fuel composition and heating value for all boilers and heaters for the previous calendar year. (3) For those units required to have a CMS (B-0007, B-0008, B-0009, H-9851 and H-2501), the CMS hourly average data. (4) For those units required to conduct periodic stack exhaust testing, the periodic test report. (5) For all boilers and heaters, a summary spreadsheet shall be maintained comparing the actual annual emissions with the allowable emission limits expressed in tons per year and lb/MMBtu using the appropriate method of compliance demonstration. This spreadsheet shall EPA Inspection Report - Page 161 of 1969 be updated by March 31 of each year for the previous calendar year. Reporting: The permittee shall report in accordance with Sections B110. D. Consent Decree NOx Emission Limits for Boilers B-0007, B-0008, and B-0009 (new as of 2013) Requirement: (NSR 0195M35, Condition A204.C) (1) In accordance with the Consent Decree lodged December 20, 2001, NOx emissions from boilers B-0007 (no later than December 31, 2002), B-0008 (no later than December 31, 2003), and B-0009 (new as of 2013) shall not exceed the limit in Table 106.A during any hourly rolling 3-hour period. Demonstration of compliance with the NOx limit for B-0007, B-0008, and B-0009 shall be established by averaging the CMS Data over any 3-hour period and comparing the average concentration to the parametric limit of ≤ 42.1 ppm NOx, corrected to 6.1% O2 as determined by the CMS. (CD¶16.D) This also satisfies the requirement in 20.2.33.108.A NMAC that NOx emissions shall not exceed 0.2 lb/MMBTU. (2) Navajo is authorized to operate all three boilers (B-0007, B-0008, and B-0009) simultaneously as needed. Monitoring: For the Controlled Boilers (B-0007, B-0008) as listed in the Consent Decree and B-0009 (new as of 2013), continuous compliance with their respective NOx permit emissions limits shall be demonstrated by monitoring as follows: (CD¶16.C) (1) For boilers (B-0007, B-0008, and B-0009) with a heat input capacity greater than 150 MMBTU/hr of HHV, the permittee shall install or continue to operate CMS to measure NOx and O2. Each CMS shall be installed, certified, calibrated, maintained, and operated in accordance with the requirements of 40 CFR 60.11, 60.13, and Part 60 Appendix A and the applicable performance specification test of 40 CFR Part 60 Appendices B and F. These CMS shall be used to demonstrate compliance with emission limits. The permittee shall make CMS and process data available to the applicable Federal and State Agencies upon demand as soon as practicable; (CD¶16.C.i) Recordkeeping: The permittee shall keep records of the CMS recertification’s monitored in Condition A204.B, Summary of Compliance. Reporting: The permittee shall report in accordance with Section B110. E. NOx Monitoring and Testing for Controlled Heaters Subject to the Consent Decree (Units H-0020, H-0352, H-0353, H-0354, H-0600, and H-0601) Requirement: For the Controlled Heaters as listed in the Consent Decree, continuous compliance with all NOx emissions limits shall be demonstrated by monitoring as follows. (CD¶16.C) (NSR 0195M35, Condition A204.D) Monitoring: EPA Inspection Report - Page 162 of 1969 (1) For heaters with a heat input capacity of equal to or less than 150 MMBTU/hr (HHV) but greater than 100 MMBTU/hr (HHV), Navajo shall (a) install or continue to operate CMS to measure NOx and O2 by no later than the date of the installation of the applicable NOx Control Technology on the heater or boiler; or (b) submit for EPA approval, by no later than 60 days after the date of installation of the applicable NOx Control Technology on the heater or boiler, a proposal for monitoring based on operating parameters, including but not limited to, firebox temperature, air preheat temperature, heat input rate, and combustion O2. Navajo shall evaluate the necessity of using firebox or bridgewall temperatures and additional operating parameters and agrees to use such parameters as a means of monitoring performance where Navajo and EPA mutually-agree to their effectiveness. (CD¶16.C.ii). As of January 23, 2014 (notarized date of application), there are no heaters or boilers at the Artesia Refinery with a capacity of equal to or less than 150 MMBTU/hr (HHV) but greater than 100 MMBTU/hr (HHV) subject to Monitoring requirement (1). (2) For heaters with a heat input capacity of equal to or less than 100 MMBTU/hr of HHV, the permittee shall conduct an initial performance tests for NOx. The results of these tests shall be reported based upon an average of three (3) one-hour testing periods and shall be used to develop representative operating parameters for each unit, which will be used as indicators of compliance. (CD¶16.C.iii). This condition applies to the following heaters: Heaters H-0352, H-0353, and H-0354 Heater H-0020 • Heaters H-0600 and H-0601 The permittee has completed all of the initial performance tests. • • (3) For heater H-0601 compliance shall be demonstrated by continuously monitoring stack oxygen (O2) to maintain a 3-hour average below 6.0 vol%. As a further check of compliance, Navajo shall monitor stack NOx at least twice a month using a portable analyzer to assure that the measured NOx value does not exceed the compliance threshold of 38 ppmv NOx. (CD¶16.C.iii) Recordkeeping: (1) The permittee shall keep records of the Fuel firing rates and Sulfur limits monitored for Condition A110.A. (2) The permittee shall keep records of the initial performance tests. (3) The permittee shall keep records of the stack oxygen monitoring and the portable analyzer tests. Reporting: The permittee shall report in accordance with Section B110. B.111.D(7) does not apply to portable analyzer tests. Condition EPA Inspection Report - Page 163 of 1969 F. NOx Monitoring and Testing for Heaters permitted after the Consent Decree (Units Heaters H-0019, H-0362, H-0363, H-0364, H-2421, H-3402, H-3403, H-2501, H8801/8802, and H-9851) Requirement: For the Heaters permitted after the Consent Decree, continuous compliance with their respective NOx permit emissions limits in Table 106.A shall be demonstrated by monitoring as follows. (NSR 0195M35, Condition A204.E) Monitoring: (1) For heaters with a heat input capacity greater than 150 MM Btu/hr (LHV Basis), the permittee shall install and operate CMS to measure NOx and O2 by the startup date of each heater. Each CMS shall be installed, certified, calibrated, maintained, and operated in accordance with the requirements of 40 CFR 60.11, 60.13, and Part 60 Appendix A and the applicable performance specifications of 40 CFR Part 60 Appendices B and F. These CMS shall be used to demonstrate compliance with emission limits. The permittee shall make CMS and process data available to the applicable Federal and State Agencies upon demand as soon as practicable. Condition A204.F(1) applies to heater H-9851. (2) For heaters with a heat input capacity of equal to or less than 150 MM Btu/hr (LHV) but greater than 100 MM Btu/hr (LHV), Navajo shall: (a) install and operate CMS to measure NOx and O2 by the startup date of each heater; or (b) submit to the Permit Program Manager for NMED approval, by no later than 90 days after the startup date of each heater, a proposal for monitoring based on operating parameters. Operating parameters to consider include, but are not limited to, firebox temperature, air pre-heat temperature, heat input rate, and combustion O2. Navajo agrees to use such parameters as a means of monitoring performance. Condition A204.F(2) applies to heaters H-2501 and H-8801/8802 (3) For heaters with a heat input capacity of equal to or less than 100 MM Btu/hr (LHV basis), the permittee shall conduct an initial performance test by no later than 180 days after the startup date. The results of this test shall be reported based upon an average of three (3) onehour testing periods and shall be used to develop representative operating parameters for each unit, which will be used as indicators of compliance. This condition applies to the following heaters: • • • • Heaters H-0362, H-0363, H-0364, and H-2421 Heater H-0019 Heaters H-3402 (AMP approved by EPA, see (4)) , initial performance test completed on July 10, 2013 Heater H-3403, initial performance test completed on April 30, 2013 (4) US EPA has approved an Alternative Monitoring Plan (AMP) for Unit H-3402 for utilizing the oxygen monitor on the H-3402 Unit 34 Hydrocracker Reboiler 1 as a parametric means for demonstrating compliance with NSPS Ja, NOx monitoring via a CMS. In accordance with the AMP, the permittee shall accomplish the following: EPA Inspection Report - Page 164 of 1969 (a) Install flow indication on the fuel line to provide historical data of the fuel to the Mild Hydrocracker (Unit 34) by January 1st, 2015. (b) Monitor the process historical data of the HEP purchased natural gas pressure, and the high pressure fuel balance drum (D-0770). (c) Upgrade the existing the Mild Hydrocracker (Unit 34) Reboiler Heater (H-3402) oxygen monitor to perform daily calibrations as required in 40 CFR60.13(d)(1). (Note that the sample placement does not conform to CMS requirements for process reasons). (d) Conduct biennial performance tests according to the requirements in 40CFR 60.104a(i). (e) Establish a maximum or curve excess O2 operating limit – (MOPV) as required under 40 CFR60.107a(c)(6) utilizing the existing monitor. (f) Include Reboiler Heater (H-3402) hours of refinery fuel gas usage and any deviations during such time as required by 40 CFR 60.7 for periodic reporting. Recordkeeping: (1) The permittee shall keep records of the monitoring proposals submitted to the Permit Program Manager for approval and whether the submittal was approved. (2) The permittee shall keep records of the CMS data, calibration, and recertification’s monitored in Condition A204.A, Summary of Compliance. (3) The permittee shall keep records of the performance tests. (4) The permittee shall keep records of the implementation of the AMP and all required monitoring specified in the AMP. Reporting: The permittee shall report in accordance with Section B110. G. NSPS Subpart Db, Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units (Boilers and heater subject in Table 103.E) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A & Db (NOx-60.44b, SO2-60.42b, & PM-60.43b) for the affected sources in Table 103.E. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60.48b, Subpart Db. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60.49b, Subpart Db. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60.49b, Subpart Db. Compliance Test: The permittee shall comply with the methods and procedures stipulated in 40 CFR 60, Section 60.45b and 60.46b. EPA Inspection Report - Page 165 of 1969 H. NSPS Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units (Boilers and heater subject in Table 103.E) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A & Dc (NOx-60.44c, SO2-60.42c, & PM-60.43c) for the affected sources in Table 103.E. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60.47c, Subpart Dc. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60.48c, Subpart Dc. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60.48c, Subpart Dc. Compliance Test: The permittee shall comply with the methods and procedures stipulated in 40 CFR 60, Section 60.44c and 60.45c. I. NSPS Subpart J, Standards of Performance for Petroleum Refineries (Boilers and heater subject in Table 103.E) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A & J for the affected sources in Table 103.E. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart J. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart J. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart J. J. NSPS Subpart Ja, Standards of Performance for Petroleum Refineries for which Construction, Reconstruction, or Modification Commenced After May 14, 2007 (Boilers and heater subject in Table 103.E) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A & Ja for the affected sources in Table 103.E. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart Ja. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart Ja. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart Ja. K. BACT NOx Limit, Continuous Monitoring System (CMS) (Unit B-0009) EPA Inspection Report - Page 166 of 1969 Requirement: The permittee shall comply with the allowable emission limits in Table 106.A and Condition A106.E that represent NOx BACT limits for the BACT requirements. (NSR 0195M35, Condition A204.I and revised) Monitoring: (1) The Permittee shall comply with the CMS monitoring as detailed in Condition A204.D. (2) The permittee shall conduct an EPA Method test within six (6) months of permit issuance using EPA reference test methods in 40 CFR 60 for NOx and O2 and CO2. Data from the CMS RATA testing may be used to satisfy this testing requirement. Recordkeeping: (1) The permittee shall keep records of the CMS initial calibration and recertification monitored in Condition A204.B, Summary of Compliance. (2) Records of EPA Methods tests shall be maintained for the Boiler. Reporting: (1) The permittee shall report in accordance with Section B110, to include the CMS initial calibration and recertification. (2) The permittee shall summarize in tabular form the results of the EPA Methods tests for NOx and O2 and CO2, specifying the emissions rates in pounds per hour and lb/MMBtu. The table shall include the average concentration of all relevant pollutant species. L. MACT Subpart DDDDD, Industrial, Commercial, and Institutional Boilers and Process Heaters (Boilers and heater subject in Table 103.E) Requirement: The units are subject to 40 CFR 63, Subpart DDDDD and the permittee shall comply with the applicable requirements of 40 CFR 63, Subpart A and Subpart DDDDD. Monitoring: The permittee shall comply with all applicable monitoring and testing requirements of 40 CFR 63, Subpart A and Subpart DDDDD. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63, Subpart A and Subpart DDDDD. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 63, Subpart A and Subpart DDDDD. M. EPA Methods Test (Unit B-0009) Requirement: Compliance with CO BACT Limit and allowable emission limits in Table 106.A shall be demonstrated by emissions tests ensuring the unit is operating correctly and within desired parameters. (NSR 0195M35, Condition A204.K and revised) Monitoring: The permittee shall conduct an EPA Method test no later than 180 days after permit issuance using EPA reference test methods in 40 CFR 60. Emission testing is required for CO. Test results that demonstrate compliance with the CO EPA Inspection Report - Page 167 of 1969 emission limits shall also be considered to demonstrate compliance with the VOC emission limits. Recordkeeping: Records of EPA Methods tests shall be maintained for the Boiler. Reporting: The permittee shall report in accordance with the requirements of Section B111.D and summarize in tabular form the results of the EPA Methods test for CO, specifying the emissions rates in pounds per hour. The table shall include the average concentration of all relevant pollutant species. N. Verification of Energy Efficiency BACT Control Requirements (Unit B-0009) Requirement: The permittee shall comply with the allowable emission limits and the following BACT requirements. (NSR 0195M35, Condition A204.L and revised) 1. Operation and Maintenance (BACT #6): a. Periodic Boiler Tuning – The boiler shall be tuned annually to maintain optimal thermal efficiency. b. Periodic Boiler Inspection and Repair for air leakage – The boiler shall be inspected annually to maintain optimal thermal efficiency. c. Periodic Boiler Inspection and Cleaning for tube fouling – The boiler shall be inspected annually and necessary cleaning performed to prevent tube fouling. 2. Next Generation Ultra-low-NOx high efficiency burners (NGULNB) (#5) shall be installed in the boiler design. 3. Flue gas economizer (BACT #2) – A heat exchanger shall be installed to recover heat from the exhaust gas to preheat incoming boiler feedwater to attain industry standard performance (IMO) for thermal efficiency. 4. Boiler insulation (BACT #4) – The boiler shall be designed and installed with boiler insulation to an optimum insulation thickness and material to achieve maximum energy efficiency. The OMP shall include the insulation design and maintenance schedule. 5. Oxygen Trim Control (BACT #7) – An Oxygen Trim Control system shall be designed and installed on the boiler to monitor oxygen concentration in the flue gas, and the inlet air flow is adjusted to maximize thermal efficiency. 6. Boiler blowdown minimization using manual analysis (BACT #3) – The Operation and Maintenance Plan (OMP) shall include methods and procedures to minimize blowdowns from the boiler to keep emissions at a minimum. 7. Condensate recovery (BACT #8): Condensate shall be recovered as represented in the application to achieve maximum energy efficiency. Condensate recovery shall be maximized through annual steam trap inspections and repairs. Monitoring: The Permittee shall develop an Operation and Maintenance Plan (OMP) to include at least the requirements listed above within 12 months of commencement of operations. The Permittee shall review the OMP annually to ensure it’s effectiveness in EPA Inspection Report - Page 168 of 1969 meeting the requirements above and recommend changes. Recordkeeping: (1) Records demonstrating compliance with the energy efficiency requirement shall be recorded and summarized in the OMP. (2) The Permittee shall maintain a copy of the OMP onsite and available for inspection. Reporting: (1) The permittee shall notify the Department when the OMP has been prepared and available for review. (2) The permittee shall report in the semi-annual report a summary of actions covered in accordance with the OMP, and in accordance with Section B110. O. Periodic Emissions Tests (Unit B-009, CO BACT Limit) Requirement: Compliance with the CO BACT Limit and allowable emission limits in Table 106.A shall be demonstrated by performing periodic emissions tests. Monitoring: The permittee shall conduct periodic portable analyzer emission tests or EPA Reference Method Tests for CO at the intervals in the following schedule: First Test --- in accordance with the schedule in Section B111.A(2). Second Test --six (6) months after the first test is completed. All subsequent testing shall be done annually. Section B108 General Monitoring Requirements apply to this condition. The permittee shall meet the testing requirements in Section B111. Recordkeeping: Records of periodic emission tests shall include the boiler fuel flow rate and the stack gas exhaust temperature. If a combustion analyzer is used to measure CO, and/or excess air in the flue gas, records shall be kept of the make and model of the instrument and instrument calibration data. If an ORSAT apparatus or other gas absorption analyzer is used, the permittee shall record all calibration results. Records shall be kept of all raw data used to determine flue gas flow and of all calculations used to determine flow rates and emission rates. The permittee shall maintain records in accordance with Section B109, B110, and B111. Reporting: The permittee shall summarize in tabular form the results of the initial or subsequent periodic emissions tests for CO, specifying the mass emissions rates in pounds per hour. The table shall include the average concentration of all relevant pollutant species. The permittee shall report in accordance with Section B109, B110, and B111. A205 Turbines not required EPA Inspection Report - Page 169 of 1969 A206 Flares A. FL-0400, FL-0403 Requirement: (NSR 0195M35, Condition A206.A) (1) An alarm system in good working order shall be connected to Flare FL-0403 which will signal non-combustion of the gas. (2) The acid gas flow meter for flare FL-0400 or FL-0403 shall be operated and calibrated at a frequency and by the procedure specified by the manufacturer. A chart recorder or data logger (electronic storage) shall continuously record the amount of gas measured by the flow meter. Monitoring: The fuel gas required to provide supplemental heat to either Flare FL-0400 or FL-0403 as required under A105.B shall be monitored during flaring by a flow meter. The flow meter shall be operated continuously 24 hours per day, 365 days per year except for periods of flow meter maintenance or repair. The upper range of the flow meter shall be sufficient to record the highest expected flow rate of fuel gas sent to flare. The reading of this flow meter and the flow meter to measure acid gas flow as required under Condition A105.B shall be used to determine compliance with emission limits at A106.C. Recordkeeping: (1) Records of all periods of operation during which the flare pilot flame is absent as included in the MACT subpart CC semi-annual reports. (2) Records of the quantity of supplemental fuel used during each acid gas flaring incident to provide supplemental heat to flare FL-0400 or flare FL-0403. (3) The permittee shall maintain records from the flow meter of the amount of gas sent to the flare. Reporting: The permittee shall report in accordance with Section B110. B. MACT Subpart CC, “National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries” (Flares listed in Table 103.K) Requirement: The permittee shall comply with all applicable requirements of MACT Subpart CC, “National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries” for all affected sources shown in Tables 103.B. (63.640). Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63.655. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 63.655. EPA Inspection Report - Page 170 of 1969 A207 Sulfur Recovery Plant (SRP), Tail Gas Incinerator (TGI) A. Consent Decree Requirements for SRP and TGI Requirement: In addition to the applicable requirements of NSPS, 40 CFR 60, Subparts J and Ja, the permittee shall accomplish the following: 1. Navajo shall route all Sulfur Recovery Plant (SRP) sulfur pit emissions from the SRP so that sulfur pit emissions to the atmosphere either are eliminated or are included and monitored as part of the applicable Sulfur Recovery Plant's tail gas emissions that meet the NSPS Subpart J or Ja limit for SO2. (CD ¶18.C.ii) 2. The SRP and TGI (and any supplemental control devices) shall be operated and maintained, to the extent practicable, in accordance with the obligation to minimize SRP emissions through implementation of good air pollution control practices required by 40 CFR § 60.11(d), at all times, including periods of start-up, shutdown, and malfunction. (CD ¶18.C.iii) (NSR 0195M35, Condition A207.A) Monitoring: The permittee shall comply with the applicable monitoring requirements of NSPS Subpart J or Ja. Recordkeeping: The permittee shall maintain records in accordance with the applicable requirements of NSPS Subparts J and Ja. Reporting: The permittee shall report in accordance with the applicable requirements of NSPS Subparts J and Ja. B. The following BACT SO2 work practices and equipment shall apply to the SRP (SRU3/TGTU3/TGI3): (PSD-NM-0195-M25) (1) Maintain at least 98% SRP on-stream operations. This includes curtailing refinery operations as necessary when SRU capacity is limited during planned startup, shutdown, and maintenance events. (2) Maintain adequate SRP excess capacity to reduce the frequency and quantity of refinery excess SO2 emissions. After the refinery expansion project proposed units are constructed, the proposed SRU3 will provide at least 25% excess capacity. (3) Continue to maintain and use a sulfur shedding plan to prevent or reduce acid gas flaring events from refinery upsets. An acid gas flaring event is defined as excess SO2 emissions greater than 500 pounds in a 24-hour period. The plan shall state specific actions that may be taken to reduce or prevent acid gas flaring. The actions taken during any event will be based on the refinery operators’ discretion, considering safety and other factors related to prudent operation. This plan is subject to review by NMED or EPA, and shall be amended upon written request by NMED or EPA. EPA Inspection Report - Page 171 of 1969 The sulfur shedding plan may include, but is not limited to the following options: C. (a) Store sour water to reduce acid gas generation from the sour water strippers (b) Reduce the operating rate of one or more amine strippers to lower the acid gas generation rate (c) Reduce one or more hydrotreating unit throughput rates to lower acid gas generation rate (4) Use hydrogen, when available, as SRU fuel during startup and hot standby to minimize carbon deposits on the SRU catalysts. (5) During startup and shutdown and to the extent practicable, process vessels shall be depressurized into other process equipment rather than venting to a flare. The permittee shall document instances when this is not practicable. SRU1, SRU2, and SRU3 Requirement: (NSR 0195M35, Condition A207.C and revised) The permittee shall demonstrate compliance with the H2S, SO2, lb/hr, tpy emission limits by completing the following requirements, monitoring, recordkeeping and reporting: (1) A flow meter shall be installed, operated, calibrated, and maintained on the sour water stripper streams that go to the SRUs. (2) An SO2 CEMS and flow meter shall be installed on the SRU1/SRU2 and SRU3 incinerator stacks. In addition, these units shall be equipped with instruments to measure and record sulfur concentration and flow rates of the gas streams into SRU1, SRU2, and SRU3. The CEMS, flow meters, and data loggers shall be calibrated and maintained. In addition, the calibration of the SO2 CEMS shall follow the quality assurance and quality control procedures in 40 CFR 60 Subpart J or Ja and Appendix F. (3) The minimum acceptable level of data capture for all instruments measuring flow of sulfur streams into the SRU1, SRU2, and SRU3, as well as the CEMS and flow meters on the incinerator stacks, shall be at least 90% for each semi-annual period. The 10% lost data will include all periods when the concentration and corresponding flow are not being measured as a result of calibrations or breakdowns. Monitoring: The gas stream feeding SRU1, SRU2, and SRU3 from the amine regeneration units and the sour water stripper shall be tested at least monthly for H2S concentration. The permittee shall monitor the following: (1) Flow rate of sour water stream to SRUs, (2) SO2 concentration in SRU incinerator stacks and (3) Flow rate of the SRU incinerator stacks. Recordkeeping: The permittee shall maintain records in accordance with the applicable EPA Inspection Report - Page 172 of 1969 requirements of NSPS Subparts J or Ja and MACT Subpart UUU. The permittee shall also keep records of the following: (1) Flow rate of sour water stream to SRUs, (2) SO2 concentration in SRU incinerator stacks and (3) Flow rate of the SRU incinerator stacks. Reporting: The permittee shall report in accordance with the applicable requirements of NSPS Subparts J or Ja, MACT Subpart UUU, and Section B110. D. 40 CFR 60, Subpart J (Unit(s) SRU1 and SRU2) Requirement: The permittee shall comply with the applicable requirements of 40 CFR 60, Subpart J. Monitoring: The permittee shall install a continuous monitoring device to monitor compliance with the H2S limit. (40 CFR 60.105(a)(3-4)) Recordkeeping: The permittee shall maintain the continuous emission records. Reporting: The permittee shall comply with the reporting requirements of 40 CFR 60, Subpart J. E. 40 CFR 60, Subpart Ja (Unit SRU3) Requirement: The permittee shall comply with the applicable requirements of 40 CFR 60, Subpart Ja. Monitoring: The permittee shall install a continuous monitoring device to monitor compliance with the H2S limit. (40 CFR 60.105a(a)(3-4)) Recordkeeping: The permittee shall maintain the continuous emission records. Reporting: The permittee shall comply with the reporting requirements of 40 CFR 60, Subpart Ja. A208 Amine Unit – Not Required A209 Fugitives A. NSPS Subpart GGG, Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries for which construction, reconstruction, or modification commenced after January 4, 1983, and on or before November 7, 2006 (Fugitives subject in Table 103.B) Requirement: The permittee shall comply with all applicable requirements of NSPS Subpart GGG for all sources in Table 103.B (affected units and voluntarily units). This table also includes areas that are voluntarily following the NSPS Subpart GGG monitoring requirements. (See footnote 1 to Table 103.B) Monitoring: The permittee shall comply with all applicable monitoring requirements of 40 CFR 60, Subpart GGG. Recordkeeping: The permittee shall comply with all applicable recordkeeping requirements EPA Inspection Report - Page 173 of 1969 of 40 CFR 60, Subpart GGG. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart GGG. B. NSPS Subpart GGGa, Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries for which Construction, Reconstruction, or Modification Commenced After November 7, 2006 (Fugitives subject in Table 103.B) Requirement: The permittee shall comply with all applicable requirements of NSPS Subpart GGGa for all sources in Table 103.B (affected units and voluntarily units). This table also includes areas that are voluntarily following the NSPS Subpart GGGa monitoring requirements. Monitoring: The permittee shall comply with all applicable monitoring requirements of 40 CFR 60, Subpart GGGa. Recordkeeping: The permittee shall comply with all applicable recordkeeping requirements of 40 CFR 60, Subpart GGGa. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart GGGa. C. MACT Subpart CC, “National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries” (Fugitives subject in Table 103.B) Requirement: The permittee shall comply with all applicable requirements of MACT Subpart CC, “National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries” for all affected sources shown in Tables 103.B. (63.640). For all activities in Table 103.B that are not subject to MACT CC, the permittee voluntarily performs a LDAR program for those units and that program meets the requirements of MACT CC. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63.655. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 63.655. D. NSPS Subpart QQQ, Standards of Performance for VOC Emissions from Petroleum Refinery Wastewater Systems (Fugitives subject in Table 103.B) Requirement The permittee shall comply with all applicable requirements of NSPS, 40 CFR Part 60.690, Subpart QQQ. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart QQQ. (60.695) EPA Inspection Report - Page 174 of 1969 Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60.696. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60.697. E. Minor changes within the facility to piping and components that affect fugitive VOC emission source shall be updated and added during the next available Significant permit revision in accordance with 20.2.72 NMAC. The facility wide fugitive VOC emission limit shown above and in Table 106.A of this permit. A210 Loading Racks A. Truck and Rail Loading (Unit shown in Table 106.G) Requirement: Compliance with the allowable emission limits in Table 106.G shall be demonstrated by not exceeding the monthly rolling 12-month total throughput for each loading rack for each different product in gallons per year (barrels/year). Monitoring: The permittee shall monitor the throughput volumes on a monthly basis. Recordkeeping: The permittee shall record the monthly throughput volume for each loading rack for each different product. Each month during the first 12 months of monitoring the permittee shall record the cumulative condensate loadout volume and after the first 12 months of monitoring, the permittee shall calculate and record a monthly rolling 12-month total loadout volume. Records shall also be maintained in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. B. Fuel Truck Loading Rack (Units subject in Table 103.D) (40 CFR 63, Subpart CC) Requirement: The permittee shall comply with all applicable requirements of MACT Subpart CC, National Emission Standards for Hazardous Air Pollutants From Petroleum Refineries. Specially, the truck loading rack shall be equipped with a carbon adsorption system for compliance with the MACT requirements. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. Specifically 63.427(a)(2), where a carbon adsorption system is used, a continuous emission monitoring system (CEMS) capable of measuring organic compound concentration shall be installed in the exhaust air stream. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63, Subpart CC. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 63, Subpart CC. EPA Inspection Report - Page 175 of 1969 A211 Fluid Catalytic Cracking Unit (FCC) A. Continuous Monitor System (CMS) (Unit FCC REGEN) Requirement: (1) Consent Decree Limits on PM and SO2 emissions from the FCC: By no later than December 31, 2003, the Wet Gas Scrubber (WGS) on the FCC Regenerator shall comply with the following limits: (CD ¶12.B & ¶13.B) (a) SO2 concentration not to exceed 25 ppmvd on a daily rolling 365-day average basis and 50 ppmvd on a daily rolling 7-day average basis, each corrected to 0% oxygen. Compliance with this emissions limit shall be demonstrated on an ongoing basis through the use of CMS; and (b) a particulate matter (PM) emission limit of 1.0 pound of PM per 1000 pounds of coke burned on a 3-hour average basis (CD ¶13.B). To demonstrate compliance with this requirement, the Permittee shall conduct an annual EPA Method 5 Test for PM and weekly EPA Method 9, Opacity Test in accordance with their approved Alternative Monitoring Plan (AMP). (c) As the FCC Regenerator is subject to the provisions of 40 CFR 60.102 (NSPS Subpart J), it shall not discharge to the atmosphere gases exhibiting greater than 30 percent opacity, except for one six-minute average opacity reading in any one-hour period. (2) Consent Decree Limits on NOx and CO emissions from the FCC: The FCC shall comply with NOx and CO emission limits as follows: (a) The concentration-based (ppmvd) NOx emission limit based on daily rolling 7-day and daily rolling 365-day averages, corrected to 0% oxygen as established pursuant to the Consent Decree, unless EPA rejects the proposed limit and establishes a different NOx emission limit, in which case the FCC shall comply with EPA’s established limit. Under no circumstances shall this emission limit be greater than a concentration-based limit that would be equivalent to 34.9 lbs/hr. The 7-day FCC NOx emission limits, shall not apply during periods of Hydrotreater Outage provided that the FCC (including associated air pollution control equipment) is maintained and operated in a manner that minimizes emissions in accordance with an EPA-approved good air pollution control practices plan. Navajo shall comply with the plan at all times, including periods of startup, shutdown, and malfunction of the hydrotreater. The daily rolling 365-day average NOx emissions limit shall apply during periods of hydrotreater outages. The NOx limits are: (1) 87.3 ppmvd NOx, corrected to 0% O2 on a daily rolling 7-day average, and (2) 58.1 ppmvd NOx, corrected to 0% O2 on a daily rolling 365-day average (b) The NSPS Subpart J emission limit of 500 ppmvd CO corrected to 0% O2 on a 1-hour average basis and 100 ppmvd CO corrected to 0% O2 on a daily rolling 365-day average basis, by no later than December 31, 2003. EPA Inspection Report - Page 176 of 1969 Monitoring: (1) A continuous monitor system (CMS) for CO, O2, SO2 and NOx shall be installed, calibrated, maintained, and operated on the FCC Catalyst Regenerator vent stack(s) downstream of the scrubber in accordance with 40 CFR Part 60, §60.13, Appendix A, and the applicable performance specifications of Appendices B (Specifications 2 and 3) and F. The CMS shall be used to demonstrate compliance with CO, SO2 and NOx emissions limits and to report compliance with the terms and conditions of the Consent Decree. The CMS and process data shall be made available, by permittee, to applicable Federal and State Agencies (NMED) upon demand as soon as practicable. (CD ¶11.F, 12 D, and 14.C) (2) The FCC Regenerator Scrubber NOx, SO2, CO and O2 CMS shall be recertified annually. (3) The CMS data shall be monitored to ensure the CO, SO2 and NOx emission limits for the FCC are met. (4) The Permittee shall conduct an annual EPA Method 5 Test for PM and weekly EPA Method 9 Opacity test to demonstrate compliance with the particulate matter (PM) emission limit of 1.0 pound of PM per 1000 pounds of coke burned on a 3-hour average basis and opacity limit of 30%. Permittee shall meet testing requirements of B111. Recordkeeping: The permittee shall maintain the records of: (1) The certification and re-certification of the CMS. (2) Modifications to the FCC’s good air pollution control practice plan to minimize NOx emissions shall be summarized on an annual basis if any changes were made. ( CD ¶11.G) (3) The permittee shall keep records of CMS data monitoring NO2, SO2, PM10 and CO emissions from the FCC. (CD ¶11.F, CD ¶12.D & CD ¶14.C) (4) Records of NOx, CO, SO2 ppmvd, lb/hr, tpy; PM lb/hr, tpy and opacity. TPY shall be based on a monthly rolling 12-month total. (5) The permittee shall keep records of annual PM stack tests and weekly Method 9 observations conducted on the FCC. For any opacity observations conducted in accordance with the requirements of EPA Method 9, record the information on the form referenced in EPA Method 9, Sections 2.2 and 2.4. Reporting: The permittee shall report in accordance with Section B110 and testing requirements of B111. B. Performance Testing (Unit FCC REGEN) Requirements: (1) The permittee shall demonstrate compliance with the NSPS Subpart J particulate matter emission limit at Table 106.A by conducting an initial performance test in accordance with NSPS Subpart A, §60.8 and NSPS Subpart J, §60.106(b). The particulate matter stack test EPA Inspection Report - Page 177 of 1969 shall be repeated on an annual basis. (2) The permittee shall comply with all applicable performance testing requirements in accordance with MACT Subparts A and UUU. Monitoring: Testing shall be conducted in accordance with NSPS Subparts A and J, and in accordance with MACT Subparts A and UUU. Recordkeeping: The permittee shall maintain performance test records in accordance with NSPS Subparts A and J, MACT Subparts A and UUU, and in accordance with Section B109. Reporting: The permittee shall report performance test results in accordance with NSPS Subparts A and J, MACT Subparts A and UUU, and in accordance with Section B110. A212 Cooling Towers A. MACT Subpart CC, “National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries” (Cooling Towers subject in Table 103.F) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 63, Subpart CC for heat exchange systems for all affected sources shown in Table 103.F attached. (63.654(a), 63.640(h)(6)) Monitoring: The permittee shall comply with all applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. (63.654(c), (d), (e), (f)) Recordkeeping: The permittee shall comply with all applicable recordkeeping requirements of 40 CFR 63, Subpart CC. (63.654(g), 63.655(i)(4), (i)(5)) Reporting: The permittee shall comply with all applicable reporting requirements of 40 CFR 63, Subpart CC. (63.655(f), (f)(1)(vi), (g)(9), (h)(1), (7)) B. Cooling Tower Operations (Cooling Towers subject in Table 103.F) Requirement: Compliance with the allowable emission limits in Table 106.H shall be demonstrated by meeting the following requirements: 1) operate a maximum of six (6) recirculating pumps at any one time; 2) ensure that each pump capacity shown in Table 104.A are not exceeded gallons per minute for each cooling tower (65,500 gpm total maximum rate for 6 pumps); 3) limit the Total Dissolved Solids (TDS) content for the cooling tower recirculating water system to 3500 ppmw, based on a monthly rolling 12-month annual average; 4) ensure that the drift eliminator are rated by the manufacturer at 0.001% or 0.003 drift or less as shown in Table 104.A; and 5) ensure that the drift eliminator is present and in good working order. The permittee shall measure the Total Dissolved Solids (TDS) content of the recirculating water through direct laboratory analysis, or may use a conductivity meter on the recirculating water system for the cooling tower. The correlation between conductivity of the water and the EPA Inspection Report - Page 178 of 1969 TDS content shall be taken as 0.9 * conductivity (μmhos/cm) = TDS (ppmw) unless a new correlation is determined through laboratory analysis and submitted to the Permit Program Manager for approval. Monitoring: The permittee shall: 1) Monitor the recirculating water TDS content by direct laboratory analysis of the TDS or through use of conductivity meter values and correlated TDS on a monthly basis; and a. Any correlation other than the 0.9 value described above shall be developed by the permittee by independent laboratory measurement of at least 10 water samples with approximately evenly spaced measured TDS values that bracket the minimum and maximum values expected. The highest laboratory TDS sample used for the correlation shall be greater than the maximum allowable TDS of 3500 ppmw. 2) Perform an annual inspection of the drift eliminator and perform any maintenance necessary to ensure the device operates according to the manufacturer’s specifications. 3) The permittee shall monitor the cooling water inlet and outlet streams for hydrocarbons on an annual basis using either EPA Method 8015 with a large enough sample to achieve accurate quantification of hydrocarbon content, EPA Method 8260, EPA Method 8270 or a similar method as approved by the Department prior to testing. Recordkeeping: The permittee shall maintain the following records: 1) Manufacturer’s specifications demonstrating maximum capacities of the recirculating water pumps and the manufacturer’s specification for the drift eliminator specified drift rate; 2) Monthly TDS and monthly rolling 12-month average; 3) If a conductivity meter is installed, a record of the correlation between conductivity and TDS, any laboratory analyses used to determine the correlation, and all related calculations; 4) Annual drift eliminator inspection and any records of maintenance performed. The permittee shall maintain records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. A213 Wastewater Systems A. NSPS Subpart QQQ, Standards of Performance for VOC Emissions from Petroleum Refinery Wastewater Systems (Unit MAIN API) Requirement: Beginning December 31, 2003, all remaining and newly installed individual drain systems, oil-water separators, and aggregate facilities not previously specified shall be affected facilities, as the term is used in the NSPS, 40 CFR Part 60, Subpart QQQ, and shall be subject to and comply with the applicable requirements of 40 CFR Part 60, Subpart QQQ. EPA Inspection Report - Page 179 of 1969 (CD ¶29) The permittee shall comply with all applicable requirements of NSPS Subpart QQQ for the affected sources in Tables 103.B, C, G. (60.690) Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart QQQ. (60.695 and 60.696) Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60.697. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60.698. B. MACT Subpart CC, “National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries” Requirement: The permittee shall comply with all applicable requirements of MACT Subpart CC, “National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries” for all affected sources shown in Tables 103.B, C, G attached. (63.640). Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63.655. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 63.655. C. Wastewater Treatment System (Units shown in Table 106.I) Requirement: Compliance with the emission limits in Table 106.I shall be demonstrated by properly maintaining and repairing the units, and running the Wastewater Model annually to calculate the maximum VOC emissions generated. Monitoring: (1) Maintenance and repair shall meet the minimum manufacturer's or permittee's recommended maintenance schedule. Activities that involve maintenance, adjustment, replacement, or repair of functional components with the potential to affect the operation of an emission unit shall be documented as they occur for the following events: (a) Routine maintenance that takes a unit out of service for more than two hours during any twenty-four hour period. (b) Unscheduled repairs that require a unit to be taken out of service for more than two hours in any twenty-four hour period. (2) The permittee shall annually run the Waste-Water Model to determine the hourly and annual emission rates, based on Toxchem V4 Input Parameters. Recordkeeping: (1) The permittee shall maintain records in accordance with Section B109, including records of maintenance and repairs activities and a copy of the manufacturer’s or permittee’s EPA Inspection Report - Page 180 of 1969 recommended maintenance schedule. (2) The permittee shall maintain records of the Toxchem V4 Input Parameters and the emission calculation results compared to permit limits. Reporting: The permittee shall report in accordance with Section B110. EPA Inspection Report - Page 181 of 1969 PART B GENERAL CONDITIONS B100 Introduction A. Not Applicable B101 Legal A. Permit Terms and Conditions (20.2.70 sections 7, 201.B, 300, 301.B, 302, 405 NMAC) (1) The permittee shall abide by all terms and conditions of this permit, except as allowed under Section 502(b)(10) of the Federal Act, and 20.2.70.302.H.1 NMAC. Any permit noncompliance is grounds for enforcement action, and significant or repetitious noncompliance may result in termination of this permit. Additionally, noncompliance with federally enforceable conditions of this permit constitutes a violation of the Federal Act. (20.2.70.302.A.2.a NMAC) (2) Emissions trading within a facility (20.2.70.302.H.2 NMAC) (a) The Department shall, if an applicant requests it, issue permits that contain terms and conditions allowing for the trading of emissions increases and decreases in the permitted facility solely for the purpose of complying with a federally enforceable emissions cap that is established in the permit in addition to any applicable requirements. Such terms and conditions shall include all terms and conditions required under 20.2.70.302 NMAC to determine compliance. If applicable requirements apply to the requested emissions trading, permit conditions shall be issued only to the extent that the applicable requirements provide for trading such increases and decreases without a case-by-case approval. (b) The applicant shall include in the application proposed replicable procedures and permit terms that ensure the emissions trades are quantifiable and enforceable. The Department shall not include in the emissions trading provisions any emissions units for which emissions are not quantifiable or for which there are no replicable procedures to enforce the emissions trades. The permit shall require compliance with all applicable requirements. (3) It shall not be a defense for the permittee in an enforcement action to claim that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. (20.2.70.302.A.2.b NMAC) (4) If the Department determines that cause exists to modify, reopen and revise, revoke and reissue, or terminate this permit, this shall be done in accordance with 20.2.70.405 NMAC. (20.2.70.302.A.2.c NMAC) EPA Inspection Report - Page 182 of 1969 B. (5) The permittee shall furnish any information the Department requests in writing to determine if cause exists for reopening and revising, revoking and reissuing, or terminating the permit, or to determine compliance with the permit. This information shall be furnished within the time period specified by the Department. Additionally, the permittee shall furnish, upon request by the Department, copies of records required by the permit to be maintained by the permittee. (20.2.70.302.A.2.f NMAC) (6) A request by the permittee that this permit be modified, revoked and reissued, or terminated, or a notification by the permittee of planned changes or anticipated noncompliance, shall not stay any conditions of this permit. (20.2.70.302.A.2.d NMAC) (7) This permit does not convey property rights of any sort, or any exclusive privilege. (20.2.70.302.A.2.e NMAC) (8) In the case where an applicant or permittee has submitted information to the Department under a claim of confidentiality, the Department may also require the applicant or permittee to submit a copy of such information directly to the Administrator of the EPA. (20.2.70.301.B NMAC) (9) The issuance of this permit, or the filing or approval of a compliance plan, does not relieve the permittee from civil or criminal liability for failure to comply with the state or Federal Acts, or any applicable state or federal regulation or law. (20.2.70.302.A.6 NMAC and the New Mexico Air Quality Control Act NMSA 1978, Chapter 74, Article 2) (10) If any part of this permit is challenged or held invalid, the remainder of the permit terms and conditions are not affected and the permittee shall continue to abide by them. (20.2.70.302.A.1.d NMAC) (11) A responsible official (as defined in 20.2.70.7.AE NMAC) shall certify the accuracy, truth and completeness of every report and compliance certification submitted to the Department as required by this permit. These certifications shall be part of each document. (20.2.70.300.E NMAC) (12) Revocation or termination of this permit by the Department terminates the permittee's right to operate this facility. (20.2.70.201.B NMAC) (13) The permittee shall continue to comply with all applicable requirements. For applicable requirements that will become effective during the term of the permit, the permittee shall meet such requirements on a timely basis. (Sections 300.D.10.c and 302.G.3 of 20.2.70 NMAC) Permit Shield (20.2.70.302.J NMAC) (1) Compliance with the conditions of this permit shall be deemed to be compliance with any applicable requirements existing as of the date of permit issuance and EPA Inspection Report - Page 183 of 1969 identified in Table 103.A. The requirements in Table 103.A are applicable to this facility with specific requirements identified for individual emission units. C. (2) The Department has determined that the requirements in Table 103.B as identified in the permit application are not applicable to this source, or they do not impose any conditions in this permit. (3) This permit shield does not extend to administrative amendments (Subsection A of 20.2.70.404 NMAC), to minor permit modifications (Subsection B of 20.2.70.404 NMAC), to changes made under Section 502(b)(10), changes under Paragraph 1 of subsection H of 20.2.70.302 of the Federal Act, or to permit terms for which notice has been given to reopen or revoke all or part under 20.2.70.405 and 20.2.70.302J(6). (4) This permit shall, for purposes of the permit shield, identify any requirement specifically identified in the permit application or significant permit modification that the department has determined is not applicable to the source, and state the basis for any such determination. (20.2.70.302.A.1.f NMAC) The owner or operator of a source having an excess emission shall, to the extent practicable, operate the source, including associated air pollution control equipment, in a manner consistent with good air pollutant control practices for minimizing emissions. (20.2.7.109 NMAC). The establishment of allowable malfunction emission limits does not supersede this requirement. B102 Authority A. This permit is issued pursuant to the federal Clean Air Act ("Federal Act"), the New Mexico Air Quality Control Act ("State Act") and regulations adopted pursuant to the State and Federal Acts, including Title 20, New Mexico Administrative Code, Chapter 2, Part 70 (20.2.70 NMAC) - Operating Permits. B. This permit authorizes the operation of this facility. This permit is valid only for the named permittee, owner, and operator. A permit modification is required to change any of those entities. C. The Department specifies with this permit, terms and conditions upon the operation of this facility to assure compliance with all applicable requirements, as defined in 20.2.70 NMAC at the time this permit is issued. (20.2.70.302.A.1 NMAC) D. Pursuant to the New Mexico Air Quality Control Act NMSA 1978, Chapter 74, Article 2, all terms and conditions in this permit, including any provisions designed to limit this facility's potential to emit, are enforceable by the Department. All terms and conditions are enforceable by the Administrator of the United States Environmental Protection Agency ("EPA") and citizens under the Federal Act, unless the term or condition is specifically EPA Inspection Report - Page 184 of 1969 designated in this permit as not being enforceable under the Federal Act. (20.2.70.302.A.5 NMAC) E. The Department is the Administrator for 40 CFR Parts 60, 61, and 63 pursuant to the Modification and Exceptions of Section 10 of 20.2.77 NMAC (NSPS), 20.2.78 NMAC (NESHAP), and 20.2.82 NMAC (MACT). B103 Annual Fee A. The permittee shall pay Title V fees to the Department consistent with the fee schedule in 20.2.71 NMAC - Operating Permit Emission Fees. The fees will be assessed and invoiced separately from this permit. (20.2.70.302.A.1.e NMAC) B104 Appeal Procedures (20.2.70.403.A NMAC) A. Any person who participated in a permitting action before the Department and who is adversely affected by such permitting action, may file a petition for a hearing before the Environmental Improvement Board ("board"). The petition shall be made in writing to the board within thirty (30) days from the date notice is given of the Department's action and shall specify the portions of the permitting action to which the petitioner objects, certify that a copy of the petition has been mailed or hand-delivered, and attach a copy of the permitting action for which review is sought. Unless a timely request for a hearing is made, the decision of the Department shall be final. The petition shall be copied simultaneously to the Department upon receipt of the appeal notice. If the petitioner is not the applicant or permittee, the petitioner shall mail or hand-deliver a copy of the petition to the applicant or permittee. The Department shall certify the administrative record to the board. Petitions for a hearing shall be sent to: Secretary, New Mexico Environmental Improvement Board 1190 St. Francis Drive, Runnels Bldg. Rm N2153 Santa Fe, New Mexico 87502 B105 Submittal of Reports and Certifications A. Stack Test Protocols and Stack Test Reports shall be submitted electronically to Stacktest.AQB@state.nm.us or as directed by the Department. B. Excess Emission Reports shall be submitted as directed by the Department. (20.2.7.110 NMAC) C. Compliance Certification Reports, Semi-Annual monitoring reports, compliance schedule progress reports, and any other compliance status information required by this permit shall be certified by the responsible official and submitted to the mailing address below, or as directed by the Department: EPA Inspection Report - Page 185 of 1969 Manager, Compliance and Enforcement Section New Mexico Environment Department Air Quality Bureau 525 Camino de los Marquez Suite 1 Santa Fe, NM 87505-1816 D. Compliance Certification Reports shall also be submitted to the Administrator at the address below (20.2.70.302.E.3 NMAC): Chief, Air Enforcement Section US EPA Region-6, 6EN-AA 1445 Ross Avenue, Suite 1200 Dallas, TX 75202-2733 B106 NSPS and/or MACT Startup, Shutdown, and Malfunction Operations A. If a facility is subject to a NSPS standard in 40 CFR 60, each owner or operator that installs and operates a continuous monitoring device required by a NSPS regulation shall comply with the excess emissions reporting requirements in accordance with 40 CFR 60.7(c). B. If a facility is subject to a NSPS standard in 40 CFR 60, then in accordance with 40 CFR 60.8(c), operations during periods of startup, shutdown, and malfunction shall not constitute representative conditions for the purpose of a performance test nor shall emissions in excess of the level of the applicable emission limit during periods of startup, shutdown, and malfunction be considered a violation of the applicable emission limit unless otherwise specified in the applicable standard. C. If a facility is subject to a MACT standard in 40 CFR 63, then the facility is subject to the requirement for a Startup, Shutdown and Malfunction Plan (SSM) under 40 CFR 63.6(e)(3), unless specifically exempted in the applicable subpart. (20.2.70.302.A.1 and A.4 NMAC) B107 Startup, Shutdown, and Maintenance Operations A. The establishment of permitted startup, shutdown, and maintenance (SSM) emission limits does not supersede the requirements of 20.2.7.14.A NMAC. Except for operations or equipment subject to Condition B106, the permittee shall establish and implement a plan to minimize emissions during routine or predictable start up, shut down, and scheduled maintenance (SSM work practice plan) and shall operate in accordance with the procedures set forth in the plan. (20.2.7.14.A NMAC) B108 General Monitoring Requirements (20.2.70. 302.A and C NMAC) EPA Inspection Report - Page 186 of 1969 A. These requirements do not supersede or relax requirements of federal regulations. B. The following monitoring and/or testing requirements shall be used to determine compliance with applicable requirements and emission limits. Any sampling, whether by portable analyzer or EPA reference method, that measures an emission rate over the applicable averaging period greater than an emission limit in this permit constitutes noncompliance with this permit. The Department may require, at its discretion, additional tests pursuant to EPA Reference Methods at any time, including when sampling by portable analyzer measures an emission rate greater than an emission limit in this permit; but such requirement shall not be construed as a determination that the sampling by portable analyzer does not establish noncompliance with this permit and shall not stay enforcement of such noncompliance based on the sampling by portable analyzer. C. If the emission unit is shutdown at the time when periodic monitoring is due to be accomplished, the permittee is not required to restart the unit for the sole purpose of performing the monitoring. Using electronic or written mail, the permittee shall notify the Department’s Enforcement Section of a delay in emission tests prior to the deadline for accomplishing the tests. Upon recommencing operation, the permittee shall submit any pertinent pre-test notification requirements set forth in the current version of the Department’s Standard Operating Procedures For Use Of Portable Analyzers in Performance Test, and shall accomplish the monitoring. D. The requirement for monitoring during any monitoring period is based on the percentage of time that the unit has operated. However, to invoke monitoring period exemptions at B108.D(2), hours of operation shall be monitored and recorded. E. (1) If the emission unit has operated for more than 25% of a monitoring period, then the permittee shall conduct monitoring during that period. (2) If the emission unit has operated for 25% or less of a monitoring period then the monitoring is not required. After two successive periods without monitoring, the permittee shall conduct monitoring during the next period regardless of the time operated during that period, except that for any monitoring period in which a unit has operated for less than 10% of the monitoring period, the period will not be considered as one of the two successive periods. (3) If invoking the monitoring period exemption in B108.D(2), the actual operating time of a unit shall not exceed the monitoring period required by this permit before the required monitoring is performed. For example, if the monitoring period is annual, the operating hours of the unit shall not exceed 8760 hours before monitoring is conducted. Regardless of the time that a unit actually operates, a minimum of one of each type of monitoring activity shall be conducted during the five year term of this permit. The permittee is not required to report a deviation for any monitoring or testing in a Specific Condition if the deviation was authorized in this General Condition B108. EPA Inspection Report - Page 187 of 1969 F. For all periodic monitoring events, except when a federal or state regulation is more stringent, three test runs shall be conducted at 90% or greater of the unit’s capacity as stated in this permit, or in the permit application if not in the permit, and at additional loads when requested by the Department. If the 90% capacity cannot be achieved, the monitoring will be conducted at the maximum achievable load under prevailing operating conditions except when a federal or state regulation requires more restrictive test conditions. The load and the parameters used to calculate it shall be recorded to document operating conditions and shall be included with the monitoring report. G. When requested by the Department, the permittee shall provide schedules of testing and monitoring activities. Compliance tests from previous NSR and Title V permits may be reimposed if it is deemed necessary by the Department to determine whether the source is in compliance with applicable regulations or permit conditions. H. If monitoring is new or is in addition to monitoring imposed by an existing applicable requirement, it shall become effective 120 days after the date of permit issuance. For emission units that have not commenced operation, the associated new or additional monitoring shall not apply until 120 days after the units commence operation. All preexisting monitoring requirements incorporated in this permit shall continue to apply from the date of permit issuance. All monitoring periods, unless stated otherwise in the specific permit condition or federal requirement, shall commence at the beginning of the 12 month reporting period as defined at condition A109.B. B109 General Recordkeeping Requirements (20.2.70.302.D NMAC) A. The permittee shall maintain records to assure and verify compliance with the terms and conditions of this permit and any applicable requirements that become effective during the term of this permit. The minimum information to be included in these records is as follows (20.2.70.302.D.1 NMAC): (1) Records required for testing and sampling: (a) equipment identification (include make, model and serial number for all tested equipment and emission controls) (b) date(s) and time(s) of sampling or measurements (c) date(s) analyses were performed (d) the qualified entity that performed the analyses (e) analytical or test methods used (f) results of analyses or tests (g) operating conditions existing at the time of sampling or measurement EPA Inspection Report - Page 188 of 1969 (2) Records required for equipment inspections and/or maintenance required by this permit: (a) equipment identification number (including make, model and serial number) (b) date(s) and time(s) of inspection, maintenance, and/or repair (c) (d) (e) (f) (g) (h) (i) date(s) any subsequent analyses were performed (if applicable) name of the person or qualified entity conducting the inspection, maintenance, and/or repair copy of the equipment manufacturer’s or the owner or operator’s maintenance or repair recommendations (if required to demonstrate compliance with a permit condition) description of maintenance or repair activities conducted all results of any required parameter readings a description of the physical condition of the equipment as found during any required inspection results of required equipment inspections including a description of any condition which required adjustment to bring the equipment back into compliance and a description of the required adjustments B. The permittee shall keep records of all monitoring data, equipment calibration, maintenance, and inspections, Data Acquisition and Handling System (DAHS) if used, reports, and other supporting information required by this permit for at least five (5) years from the time the data was gathered or the reports written. Each record shall clearly identify the emissions unit and/or monitoring equipment, and the date the data was gathered. (20.2.70.302.D.2 NMAC) C. If the permittee has applied and received approval for an alternative operating scenario, then the permittee shall maintain a log at the facility, which documents, contemporaneously with any change from one operating scenario to another, the scenario under which the facility is operating. (20.2.70.302.A.3 NMAC) D. The permittee shall keep a record describing off permit changes made at this source that result in emissions of a regulated air pollutant subject to an applicable requirement, but not otherwise regulated under this permit, and the emissions resulting from those changes. (20.2.70.302.I.2 NMAC) E. Unless otherwise indicated by Specific Conditions, the permittee shall keep the following records for malfunction emissions and routine and predictable emissions during startup, shutdown, and scheduled maintenance (SSM): (1) The owner or operator of a source subject to a permit, shall establish and implement a plan to minimize emissions during routine or predictable startup, EPA Inspection Report - Page 189 of 1969 shutdown, and scheduled maintenance through work practice standards and good air pollution control practices. This requirement shall not apply to any affected facility defined in and subject to an emissions standard and an equivalent plan under 40 CFR Part 60 (NSPS), 40 CFR Part 63 (MACT), or an equivalent plan under 20.2.72 NMAC - Construction Permits, 20.2.70 NMAC - Operating Permits, 20.2.74 NMAC - Permits - Prevention of Significant Deterioration (PSD), or 20.2.79 NMAC - Permits - Nonattainment Areas. (20.2.7.14.A NMAC) The permittee shall keep records of all sources subject to the plan to minimize emissions during routine or predictable SSM and shall record if the source is subject to an alternative plan and therefore, not subject to the plan requirements under 20.2.7.14.A NMAC. (2) If the facility has allowable SSM emission limits in this permit, the permittee shall record all SSM events, including the date, the start time, the end time, a description of the event, and a description of the cause of the event. This record also shall include a copy of the manufacturer’s, or equivalent, documentation showing that any maintenance qualified as scheduled. Scheduled maintenance is an activity that occurs at an established frequency pursuant to a written protocol published by the manufacturer or other reliable source. The authorization of allowable SSM emissions does not supersede any applicable federal or state standard. The most stringent requirement applies. (3) If the facility has allowable malfunction emission limits in this permit, the permittee shall record all malfunction events to be applied against these limits. The permittee shall also include the date, the start time, the end time, and a description of the event. Malfunction means any sudden and unavoidable failure of air pollution control equipment or process equipment beyond the control of the owner or operator, including malfunction during startup or shutdown. A failure that is caused entirely or in part by poor maintenance, careless operation, or any other preventable equipment breakdown shall not be considered a malfunction. (20.2.7.7.E NMAC) The authorization of allowable malfunction emissions does not supersede any applicable federal or state standard. The most stringent requirement applies. This authorization only allows the permittee to avoid submitting reports under 20.2.7 NMAC for total annual emissions that are below the authorized malfunction emission limit. (4) The owner or operator of a source shall meet the operational plan defining the measures to be taken to mitigate source emissions during malfunction, startup or shutdown. (20.2.72.203.A(5) NMAC) B110 General Reporting Requirements (20.2.70.302.E NMAC) A. Reports of required monitoring activities for this facility shall be submitted to the Department on the schedule in section A109. Monitoring and recordkeeping requirements that are not required by a NSPS or MACT shall be maintained on-site or (for unmanned EPA Inspection Report - Page 190 of 1969 sites) at the nearest company office, and summarized in the semi-annual reports, unless alternative reporting requirements are specified in the equipment specific requirements section of this permit. B. Reports shall clearly identify the subject equipment showing the emission unit ID number according to this operating permit. In addition, all instances of deviations from permit requirements, including those that occur during emergencies, shall be clearly identified in the reports required by section A109. (20.2.70.302.E.1 NMAC) C. The permittee shall submit reports of all deviations from permit requirements, including those attributable to upset conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. These reports shall be submitted as follows: (1) Deviations resulting in excess emissions as defined in 20.2.7.7 NMAC (including those classified as emergencies as defined in section B114.A) shall be reported in accordance with the timelines specified by 20.2.7.110 NMAC and in the semiannual reports required in section A109. (20.2.70.302.E.2 NMAC) (2) All other deviations shall be reported in the semi-annual reports required in section A109. (20.2.70.302.E.2 NMAC). D. The permittee shall submit reports of excess emissions in accordance with 20.2.7.110.A NMAC. E. Results of emission tests and monitoring for each pollutant (except opacity) shall be reported in pounds per hour (unless otherwise specified) and tons per year. Opacity shall be reported in percent. The number of significant figures corresponding to the full accuracy inherent in the testing instrument or Method test used to obtain the data shall be used to calculate and report test results in accordance with 20.2.1.116.B and C NMAC. Upon request by the Department, CEMS and other tabular data shall be submitted in editable, MS Excel format. F. At such time as new units are installed as authorized by the applicable NSR Permit, the permittee shall fulfill the notification requirements in the NSR permit. G. Periodic Emissions Test Reporting: The permittee shall report semi-annually a summary of the test results. H. The permittee shall submit an emissions inventory report for this facility in accordance with the schedule in subparagraph (5), provided one or more of the following criteria is met in subparagraphs (1) to (4): (20.2.73 NMAC) (1) The facility emits, or has the potential to emit, 5 tons per year or more of lead or lead compounds, or 100 tons per year or more of PM10, PM2.5, sulfur oxides, nitrogen oxides, carbon monoxide, or volatile organic compounds. EPA Inspection Report - Page 191 of 1969 I. (2) The facility is defined as a major source of hazardous air pollutants under 20.2.70 NMAC (Operating Permits). (3) The facility is located in an ozone nonattainment area and which emits, or has the potential to emit, 25 tons per year or more of nitrogen oxides or volatile organic compounds. (4) Upon request by the department. (5) The permittee shall submit the emissions inventory report by April 1 of each year, unless a different deadline is specified by the current operating permit. Emissions trading within a facility (20.2.70.302.H.2 NMAC) (1) For each such change, the permittee shall provide written notification to the department and the administrator at least seven (7) days in advance of the proposed changes. Such notification shall state when the change will occur and shall describe the changes in emissions that will result and how these increases and decreases in emissions will comply with the terms and conditions of the permit. (2) The permittee and department shall attach each such notice to their copy of the relevant permit. B111 General Testing Requirements A. Compliance Tests (1) Compliance test requirements from previous permits (if any) are still in effect, unless the tests have been satisfactorily completed. Compliance tests may be reimposed if it is deemed necessary by the Department to determine whether the source is in compliance with applicable regulations or permit conditions. (20.2.72 NMAC Sections 210.C and 213) (2) Compliance tests shall be conducted within sixty (60) days after the unit(s) achieve the maximum normal production rate. If the maximum normal production rate does not occur within one hundred twenty (120) days of source startup, then the tests must be conducted no later than one hundred eighty (180) days after initial startup of the source. (3) Unless otherwise indicated by Specific Conditions or regulatory requirements, the default time period for each test run shall be at least 60 minutes and each performance test shall consist of three separate runs using the applicable test method. For the purpose of determining compliance with an applicable emission limit, the arithmetic mean of results of the three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the three runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances, beyond the owner or operator's control, compliance may, upon the EPA Inspection Report - Page 192 of 1969 Department approval, be determined using the arithmetic mean of the results of the two other runs. B. (4) Testing of emissions shall be conducted with the emissions unit operating at 90 to 100 percent of the maximum operating rate allowed by the permit. If it is not possible to test at that rate, the source may test at a lower operating rate, subject to the approval of the Department. (5) Testing performed at less than 90 percent of permitted capacity will limit emission unit operation to 110 percent of the tested capacity until a new test is conducted. (6) If conditions change such that unit operation above 110 percent of tested capacity is possible, the source must submit a protocol to the Department within 30 days of such change to conduct a new emissions test. EPA Reference Method Tests (1) All compliance tests required by this permit, unless otherwise specified by Specific Conditions of this permit, shall be conducted in accordance with the requirements of 40 CFR 60, Subpart A, General Provisions, and the following EPA Reference Methods as specified by 40 CFR 60, Appendix A: (a) Methods 1 through 4 for stack gas flowrate (b) Method 5 for TSP (c) Method 6C and 19 for SO2 (d) Method 7E for NOX (test results shall be expressed as nitrogen dioxide (NO2) using a molecular weight of 46 lb/lb-mol in all calculations (each ppm of NO/NO2 is equivalent to 1.194 x 10-7 lb/SCF) (e) Method 9 for opacity (f) Method 10 for CO (g) Method 19 may be used in lieu of Methods 1-4 for stack gas flowrate upon approval of the Department. A justification for this proposal must be provided along with a contemporaneous fuel gas analysis (preferably on the day of the test) and a recent fuel flow meter calibration certificate (within the most recent quarter). (h) Method 7E or 20 for Turbines per 60.335 or 60.4400 (i) Method 29 for Metals (j) Method 201A for filterable PM10 and PM2.5 (k) Method 202 for condensable PM (l) Method 320 for organic Hazardous Air Pollutants (HAPs) (m) Method 25A for VOC reduction efficiency EPA Inspection Report - Page 193 of 1969 (n) (2) C. Method 30B for Mercury Alternative test method(s) may be used if the Department approves the change. Periodic Monitoring and Portable Analyzer Requirements (1) Periodic emissions tests (periodic monitoring) may be conducted in accordance with EPA Reference Methods or by utilizing a portable analyzer. Periodic monitoring utilizing a portable analyzer shall be conducted in accordance with the requirements of ASTM D 6522-00. However, if a facility has met a previously approved Department criterion for portable analyzers, the analyzer may be operated in accordance with that criterion until it is replaced. (2) Unless otherwise indicated by Specific Conditions or regulatory requirements, the default time period for each test run shall be at least 20 minutes. Each performance test shall consist of three separate runs. The arithmetic mean of results of the three runs shall be used to determine compliance with the applicable emission limit. D. (3) Testing of emissions shall be conducted in accordance with the requirements at Section B108.F. (4) During emissions tests, pollutant and diluent concentration shall be monitored and recorded. Fuel flow rate shall be monitored and recorded if stack gas flow rate is determined utilizing Method 19. This information shall be included with the test report furnished to the Department. (5) Stack gas flow rate shall be calculated in accordance with 40 CFR 60, Appendix A, Method 19 utilizing fuel flow rate (scf) determined by a dedicated fuel flow meter and fuel heating value (Btu/scf) determined from a fuel sample obtained preferably during the day of the test, but no earlier than three months prior to the test date. Alternatively, stack gas flow rate may be determined by using EPA Methods 1-4. Test Procedures: (1) The permittee shall notify the Department’s Program Manager, Compliance and Enforcement Section at least thirty (30) days before the test to afford a representative of the Department an opportunity to be present at the test. (40CFR 60.8(d)) (2) Equipment shall be tested in the "as found" condition. Equipment may not be adjusted or tuned prior to any test for the purpose of lowering emissions, and then returned to previous settings or operating conditions after the test is complete. (3) Contents of test notifications, protocols and test reports shall conform to the format specified by the Department’s Universal Test Notification, Protocol and Report Form and Instructions. Current forms and instructions are posted to NMED’s Air Quality web site under Compliance and Enforcement Testing. EPA Inspection Report - Page 194 of 1969 (4) The permittee shall provide (a) sampling ports adequate for the test methods applicable to the facility, (b) safe sampling platforms, (c) safe access to sampling platforms and (d) utilities for sampling and testing equipment. (5) The stack shall be of sufficient height and diameter and the sample ports shall be located so that a representative test of the emissions can be performed in accordance with the requirements of EPA Method 1 or ASTM D 6522-00 as applicable. (6) Where necessary to prevent cyclonic flow in the stack, flow straighteners shall be installed (7) Unless otherwise indicated by Specific Conditions or regulatory requirements, test reports shall be submitted to the Department no later than 30 days after completion of the test. B112 Compliance A. The Department shall be given the right to enter the facility at all reasonable times to verify the terms and conditions of this permit. Required records shall be organized by date and subject matter and shall at all times be readily available for inspection. The permittee, upon verbal or written request from an authorized representative of the Department who appears at the facility, shall immediately produce for inspection or copying any records required to be maintained at the facility. Upon written request at other times, the permittee shall deliver to the Department paper or electronic copies of any and all required records maintained on site or at an off-site location. Requested records shall be copied and delivered at the permittee’s expense within three business days from receipt of request unless the Department allows additional time. Required records may include records required by permit and other information necessary to demonstrate compliance with terms and conditions of this permit. (NMSA 1978, Section 74-2-13) B. A copy of the most recent permit(s) issued by the Department shall be kept at the permitted facility or (for unmanned sites) at the nearest company office and shall be made available to Department personnel for inspection upon request. (20.2.70.302.G.3 NMAC) C. Emissions limits associated with the energy input of a Unit, i.e. lb/MMBtu, shall apply at all times unless stated otherwise in a Specific Condition of this permit. The averaging time for each emissions limit, including those based on energy input of a Unit (i.e. lb/MMBtu) is one (1) hour unless stated otherwise in a Specific Condition of this permit or in the applicable requirement that establishes the limit. (20.2.70.302.A.1 and G.3 NMAC) D. The permittee shall submit compliance certification reports certifying the compliance status of this facility with respect to all permit terms and conditions, including applicable requirements. These reports shall be made on the pre-populated Compliance Certification Report Form that is provided to the permittee by the Department, and shall be submitted to the Department and to EPA at least every 12 months. For the most current form, please EPA Inspection Report - Page 195 of 1969 contact the Compliance Reports Group at email:reportsgroup.aqb@state.nm.us. For additional reporting guidance see http://www.nmenv.state.nm.us/aqb/enforce_compliance/TitleVReporting.htm. (20.2.70.302.E.3 NMAC) E. The permittee shall allow representatives of the Department, upon presentation of credentials and other documents as may be required by law, to do the following (20.2.70.302.G.1 NMAC): (1) enter the permittee's premises where a source or emission unit is located, or where records that are required by this permit to be maintained are kept; (2) have access to and copy, at reasonable times, any records that are required by this permit to be maintained; (3) inspect any facilities, equipment (including monitoring and air pollution control equipment), work practices or operations regulated or required under this permit; and (4) sample or monitor any substances or parameters for the purpose of assuring compliance with this permit or applicable requirements or as otherwise authorized by the Federal Act. B113 Permit Reopening and Revocation A. B. This permit will be reopened and revised when any one of the following conditions occurs, and may be revoked and reissued when A(3) or A(4) occurs. (20.2.70.405.A.1 NMAC) (1) Additional applicable requirements under the Federal Act become applicable to a major source three (3) or more years before the expiration date of this permit. If the effective date of the requirement is later than the expiration date of this permit, then the permit is not required to be reopened unless the original permit or any of its terms and conditions has been extended due to the Department's failure to take timely action on a request by the permittee to renew this permit. (2) Additional requirements, including excess emissions requirements, become applicable to this source under Title IV of the Federal Act (the acid rain program). Upon approval by the Administrator, excess emissions offset plans will be incorporated into this permit. (3) The Department or the Administrator determines that the permit contains a material mistake or that inaccurate statements were made in establishing the terms and conditions of the permit. (4) The Department or the Administrator determines that the permit must be revised or revoked and reissued to assure compliance with an applicable requirement. Proceedings to reopen or revoke this permit shall affect only those parts of this permit for which cause to reopen or revoke exists. Emissions units for which permit conditions have EPA Inspection Report - Page 196 of 1969 been revoked shall not be operated until new permit conditions have been issued for them. (20.2.70.405.A.2 NMAC) B114 Emergencies (20.2.70.304 NMAC) A. An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the permittee, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology-based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventive maintenance, or careless or improper operation. B. An emergency constitutes an affirmative defense to an action brought for noncompliance with technology-based emission limitations contained in this permit if the permittee has demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that: (1) An emergency occurred and that the permittee can identify the cause(s) of the emergency; (2) This facility was at the time being properly operated; (3) During the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or other requirements in this permit; and (4) The permittee submitted notice of the emergency to the Department within 2 working days of the time when emission limitations were exceeded due to the emergency. This notice fulfills the requirement of 20.2.70.302.E.2 NMAC. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. C. In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency has the burden of proof. D. This provision is in addition to any emergency or upset provision contained in any applicable requirement. B115 Stratospheric Ozone (20.2.70.302.A.1 NMAC) A. If this facility is subject to 40 CFR 82, Subpart F, the permittee shall comply with the following standards for recycling and emissions reductions: EPA Inspection Report - Page 197 of 1969 (1) Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices, except for motor vehicle air conditioners (MVAC) and MVAC-like appliances. (40 CFR 82.156) (2) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment. (40 CFR 82.158) (3) Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certification program. (40 CFR 82.161) B116 Acid Rain Sources (20.2.70.302.A.9 NMAC) A. If this facility is subject to the federal acid rain program under 40 CFR 72, this section applies. B. Where an applicable requirement of the Federal Act is more stringent than an applicable requirement of regulations promulgated under Title IV of the Federal Act, both provisions are incorporated into this permit and are federally enforceable. C. Emissions exceeding any allowances held by the permittee under Title IV of the Federal Act or the regulations promulgated thereunder are prohibited. D. No modification of this permit is required for increases in emissions that are authorized by allowances acquired pursuant to the acid rain program, provided that such increases do not require a permit modification under any other applicable requirement. E. The permittee may not use allowances as a defense to noncompliance with any other applicable requirement. F. No limit is placed on the number of allowances held by the acid rain source. Any such allowance shall be accounted for according to the procedures established in regulations promulgated under Title IV of the Federal Act. G. The acid rain permit is an enclosure of this operating permit. B117 Risk Management Plan (20.2.70.302.A.1 NMAC) A. If this facility is subject to the federal risk management program under 40 CFR 68, this section applies. B. The owner or operator shall certify annually that they have developed and implemented a RMP and are in compliance with 40 CFR 68. EPA Inspection Report - Page 198 of 1969 C. If the owner or operator of the facility has not developed and submitted a risk management plan according to 40 CFR 68.150, the owner or operator shall provide a compliance schedule for the development and implementation of the plan. The plan shall describe, in detail, procedures for assessing the accidental release hazard, preventing accidental releases, and developing an emergency response plan to an accidental release. The plan shall be submitted in a method and format to a central point as specified by EPA prior to the date specified in 40 CFR 68.150.b. PART C MISCELLANEOUS C100 Supporting On-Line Documents A. Copies of the following documents can be downloaded from NMED’s web site under Compliance and Enforcement or requested from the Bureau. (1) Excess Emission Form (for reporting deviations and emergencies) (2) Compliance Certification Report Form (3) Universal Stack Test Notification, Protocol and Report Form and Instructions (4) SOP for Use of Portable Analyzers in Performance Tests C101 Definitions A. “Daylight” is defined as the time period between sunrise and sunset, as defined by the Astronomical Applications Department of the U.S. Naval Observatory. (Data for one day or a table of sunrise/sunset for an entire year can be obtained at http://aa.usno.navy.mil/. Alternatively, these times can be obtained from a Farmers Almanac or from http://www.almanac.com/rise/). B. “Exempt Sources” and “Exempt Activities” is defined as those sources or activities that are exempted in accordance with 20.2.72.202 NMAC. Note; exemptions are only valid for most 20.2.72 permitting action. C. “Fugitive emission” means those emissions which could not reasonably pass through a stack, chimney, vent, or other functionally equivalent opening. (20.2.70.7M NMAC) D. “Insignificant Activities” means those activities which have been listed by the department and approved by the administrator as insignificant on the basis of size, emissions or production rate. (20.2.70.7Q NMAC) E. “Malfunction” for the requirements under 20.2.7 NMAC, means any sudden and unavoidable failure of air pollution control equipment or process equipment beyond the control of the owner or operator, including malfunction during startup or shutdown. A EPA Inspection Report - Page 199 of 1969 failure that is caused entirely or in part by poor maintenance, careless operation, or any other preventable equipment breakdown shall not be considered a malfunction. F. “Natural Gas” is defined as a naturally occurring fluid mixture of hydrocarbons that contains 20.0 grains or less of total sulfur per 100 standard cubic feet (SCF) and is either composed of at least 70% methane by volume or has a gross calorific value of between 950 and 1100 Btu per standard cubic foot. (40 CFR 60.331) G. “Natural Gas Liquids” means the hydrocarbons, such as ethane, propane, butane, and pentane, that are extracted from field gas. (40 CFR 60.631) H. “National Ambient Air Quality Standards” means the primary (health-based) and secondary (welfare-related) federal ambient air quality standards promulgated by the US EPA pursuant to Section 109 of the Federal Act. (20.2.72.7Q NMAC) I. “NO2” or "Nitrogen dioxide" means the chemical compound containing one atom of nitrogen and two atoms of oxygen, for the purposes of ambient determinations. The term "nitrogen dioxide," for the purposes of stack emissions monitoring, shall include nitrogen dioxide (the chemical compound containing one atom of nitrogen and two atoms of oxygen), nitric oxide (the chemical compound containing one atom of nitrogen and one atom of oxygen), and other oxides of nitrogen which may test as nitrogen dioxide and is sometimes referred to as NOx or NO2. (20.2.2.7U NMAC) J. “NOx” see NO2 K. “Paved Road” is a road with a permanent solid surface that can be swept essentially free of dust or other material to reduce air re-entrainment of particulate matter. To the extent these surfaces remain solid and contiguous they qualify as paved roads: concrete, asphalt, chip seal, recycled asphalt and other surfaces approved by the Department in writing. L. “Potential Emission Rate” means the emission rate of a source at its maximum capacity to emit a regulated air contaminant under its physical and operational design, provided any physical or operational limitation on the capacity of the source to emit a regulated air contaminant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored or processed, shall be treated as part of its physical and operational design only if the limitation or the effect it would have on emissions is enforceable by the department pursuant to the Air Quality Control Act or the Federal Act. (20.2.72.7Y NMAC) M. “Restricted Area-Non Military” is an area to which public entry is effectively precluded. Effective barriers include continuous fencing, continuous walls, or other continuous barriers approved by the Department, such as rugged physical terrain with a steep grade that would require special equipment to traverse. If a large property is completely enclosed by fencing, a restricted area within the property may be identified with signage only. Public roads cannot be part of a Restricted Area. N. "Shutdown" for requirements under 20.2.72.7BB NMAC, means the cessation of operation of any air pollution control equipment, process equipment or process for any purpose, except routine phasing out of batch process units. EPA Inspection Report - Page 200 of 1969 "SSM" for requirements under 20.2.7 NMAC, means routine or predictable startup, shutdown, or scheduled maintenance. O. P. (1) "Shutdown" for requirements under 20.2.7.7H NMAC, means the cessation of operation of any air pollution control equipment or process equipment. (2) "Startup" for requirements under 20.2.7.7I NMAC, means the setting into operation of any air pollution control equipment or process equipment. "Startup" for requirements under 20.2.72.7DD NMAC, means the setting into operation of any air pollution control equipment, process equipment or process for any purpose, except routine phasing in of batch process units. C102 Acronyms 2SLB ........................................................................................................ 2-stroke lean burn 4SLB ........................................................................................................ 4-stroke lean burn 4SRB ......................................................................................................... 4-stroke rich burn acfm........................................................................................... actual cubic feet per minute AFR .................................................................................................................... air fuel ratio AP-42 ...........................................................................EPA Air Pollutant Emission Factors AQB ........................................................................................................ Air Quality Bureau AQCR ....................................................................................... Air Quality Control Region ASTM ................................................................ American Society for Testing & Materials Btu .......................................................................................................... British thermal unit CAA ............................................................. Clean Air Act of 1970 and 1990 Amendments CEM ................................................................................. continuous emissions monitoring cfh ........................................................................................................... cubic feet per hour cfm ....................................................................................................... cubic feet per minute CFR ........................................................................................... Code of Federal Regulation CI ........................................................................................................ compression ignition CO .............................................................................................................. carbon monoxide COMS ...................................................................... continuous opacity monitoring system EIB ............................................................................... Environmental Improvement Board EPA .......................................................... United States Environmental Protection Agency gr/100 cf ........................................................................... grains per one hundred cubic feet gr/dscf .............................................................................. grains per dry standard cubic foot GRI.....................................................................................................Gas Research Institute H2S ..............................................................................................................hydrogen sulfide HAP................................................................................................... hazardous air pollutant hp ....................................................................................................................... horsepower IC .........................................................................................................Internal Combustion KW/hr ...................................................................................................... kilowatts per hour lb/hr ..............................................................................................................pounds per hour lb/MMBtu ............................................................... pounds per million British thermal unit MACT ............................................................. Maximum Achievable Control Technology MMcf/hr ...................................................................................... million cubic feet per hour EPA Inspection Report - Page 201 of 1969 MMscf ......................................................................................... million standard cubic feet N/A.................................................................................................................. not applicable NAAQS ................................................................. National Ambient Air Quality Standards NESHAP ................................. National Emission Standards for Hazardous Air Pollutants NG ....................................................................................................................... natural gas NGL ........................................................................................................ natural gas liquids NMAAQS ...................................................... New Mexico Ambient Air Quality Standards NMAC............................................................................ New Mexico Administrative Code NMED ..................................................................... New Mexico Environment Department NMSA .................................................................................New Mexico Statues Annotated NOx ............................................................................................................... nitrogen oxides NSCR .............................................................................. non-selective Catalytic Reduction NSPS ............................................................................. New Source Performance Standard NSR ....................................................................................................... New Source Review PEM .................................................................................. parametric emissions monitoring PM ................................ particulate matter (equivalent to TSP, total suspended particulate) PM10 ....................................................... particulate matter 10 microns and less in diameter PM2.5 ..................................................... particulate matter 2.5 microns and less in diameter pph................................................................................................................pounds per hour ppmv ......................................................................................... parts per million by volume PSD ......................................................................... Prevention of Significant Deterioration RATA................................................................................ relative accuracy test assessment RICE .................................................................... reciprocating internal combustion engine rpm .................................................................................................... revolutions per minute scfm ....................................................................................... standard cubic feet per minute SI ................................................................................................................... spark ignition SO2 .................................................................................................................. sulfur dioxide SSM................................................... Startup Shutdown Maintenance (see SSM definition) TAP ........................................................................................................ Toxic Air Pollutant TBD.............................................................................................................to be determined THC.......................................................................................................... total hydrocarbons TSP.......................................................................................... Total Suspended Particulates tpy ..................................................................................................................... tons per year ULSD ................................................................................................. ultra-low sulfur diesel USEPA ..................................................... United States Environmental Protection Agency UTM ..................................................... Universal Transverse Mercator Coordinate System UTMH ................................................................ Universal Transverse Mercator Horizontal UTMV .................................................................... Universal Transverse Mercator Vertical VHAP ................................................................................... volatile hazardous air pollutant VOC .......................................................................................... volatile organic compounds PART D ATTACHMENTS EPA Inspection Report - Page 202 of 1969 Table 103.B, Summary Applicability – Fugitives [return] Title V Permit Unit ID Description 20.2.37 MACT CC NSPS GGG NSPS GGGa NSPS QQQ NESHAP J NESHAP V NAV-195CC 1 FUG-02-SP CRUDE South Division Crude Unit YES YES NO YES YES NO NO NO FUG-05-KERO Kerosene HDS Unit NO NO NO NO YES NO NO NO FUG-06-NHDU JP8 Hydrodesulfurization NO YES NO NO YES NO NO NO FUG-07-N AMINE Amine Unit-Treating/Regen. YES NO YES NO YES NO NO YES FUG-07-SWS1 Sour Water Stripper YES NO YES NO YES NO NO NO FUG-08-TRUCK RK Loading Racks NO YES NO YES YES NO NO NO FUG-09-N ALKY North Alkylation Unit (New-Inside battery limits) YES YES YES NO YES NO NO NO FUG-10-FCC FCC w/CVS YES YES YES NO YES NO NO NO FUG-13-NHDU Naphtha HDS Unit YES YES YES NO YES NO NO NO FUG-18-LSR MEROX TRT Merox/Merichem Treating Units NO YES NO NO YES NO NO NO FUG-20-ISOM Powerformer/Penex Unit w/CVS NO YES NO NO YES NO NO NO FUG-21-SP VACUUM Flasher/Vacuum Unit NO NO NO YES YES NO NO NO FUG-25-ROSE-2 ROSE Unit YES YES NO YES YES NO NO NO FUG-29-BLENDER/TK FARM Light Oil Tankage NO YES NO YES YES NO NO NO FUG-31-SRU3/TGTU3/TGI3 SRU3 Unit YES YES NO YES YES NO NO NO FUG-33-DIST HDU Relocated Diesel HDS Unit w/CVS YES YES YES NO YES NO NO NO FUG-34-HYDROCRACKER WX Hydrocracker YES YES NO YES YES NO NO NO FUG-35-SAT GAS Saturates Gas Plant NO YES NO NO YES NO NO NO FUG-41-PBC PBC Unit NO NO NO NO YES NO NO NO FUG-43-S ALKY South Alky Unit (W-76) YES YES YES NO YES NO NO NO FUG-44-DIST-HDU Gas Oil Hydrotreater (incl. CVS) NO YES NO NO YES NO NO NO FUG-45-DIST-HDU Gas Oil Hydrotreater (incl. CVS) NO YES YES NO YES NO NO NO FUG-63-H2 PLANT-1 Hydrogen Plant NO NO NO NO YES NO NO NO FUG-64-H2 PLANT-2 Hydrogen Plant NO NO NO NO YES NO NO NO FUG-70-CCR CCR Reformer (w/in battery limits) YES YES YES NO YES NO NO NO FUG-73-SP UTIL Utilities NO NO NO NO YES NO NO NO EPA Inspection Report - Page 203 of 1969 Table 103.B, Summary Applicability – Fugitives [return] Title V Permit Unit ID Description 20.2.37 MACT CC NSPS GGG NSPS GGGa NSPS QQQ NESHAP J NESHAP V NAV-195CC 1 FUG-80-WWTP CVS Oil/Water Separator YES YES YES NO YES NO NO YES FUG-ASPHALT STG Asphalt/Heavy Oil Storage NO NO NO NO YES NO NO NO FUG-FUEL GAS Fuel Gas Distribution System NO YES NO NO YES NO NO NO FUG-LPG LPG Storage System NO NO NO NO YES NO NO YES FUG-RLO-ASPHALT Asphalt/Pitch Loading Rack NO NO NO NO YES NO NO NO FUG-SRU1/SRU2/TGTU SRU1/SRU2/SWS w/CVS YES NO YES NO YES NO NO YES NO NO NO NO YES NO NO NO Crude oil unloading system, closed loop system between railcars and trucks. 1 NAV-195-CC represents those units not subject to MACT CC, but Navajo has decided to voluntarily to follow the fugitive LDAR program consistent with MACT CC monitoring requirements. FUG-RRTOTRUCK EPA Inspection Report - Page 204 of 1969 Table 103.C, Summary Applicability - Tanks Tank No. RW-4 RW-5 RW-6 T-0001 T-0002 T-0003 T-0004 T-0011 T-0012 T-0013 T-0026 T-0028 T-0031 T-0040 T-0041 T-0042 T-0045 T-0046 T-0049 T-0055 T-0056 T-0057 T-0059 T-0061 T-0063 T-0064 T-0065 T-0071 T-0072 T-0073 T-0074 T-0075 NSPS K NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NSPS Ka NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO NO NO NO NO NO NO NO NO NO NSPS Kb NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO NO NO NO YES MACT CC Storage NO NO NO NO NO NO NO YES YES YES NO NO NO YES YES NO NO NO YES YES YES YES YES YES YES NO YES NO NO NO NO YES MACT CC Wastewater N/A N/A N/A YES YES YES YES N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NESHAP FF N/A N/A N/A YES YES YES NO N/A N/A YES N/A N/A N/A N/A N/A N/A N/A N/A YES N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NSPS QQQ N/A N/A N/A NO NO NO NO N/A N/A YES N/A N/A N/A N/A N/A N/A N/A N/A YES N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 20.2.37.205 20.2.38.109 20.2.38.110 20.2.38.112 20.2.38.113 NMAC NO NO NO NO NO NO NO YES YES NO NO NO NO NO NO YES YES YES NO YES YES YES NO NO NO NO YES YES YES YES YES YES NMAC NO NO NO NO NO NO NO YES YES NO NO NO NO NO NO YES NO NO NO NO YES YES NO NO NO NO NO NO NO NO NO NO NMAC YES YES YES NO NO NO NO YES YES NO NO NO NO NO NO YES NO NO NO NO YES YES NO NO NO NO NO NO NO NO NO NO NMAC NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES YES YES NO YES NO YES NO NO NO NO YES YES YES YES YES YES NMAC YES NO YES NO NO NO NO NO NO NO NO NO NO NO NO YES NO NO NO NO NO YES NO NO NO NO NO NO NO NO NO NO CAM NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO EPA Inspection Report - Page 205 of 1969 Table 103.C, Summary Applicability - Tanks Tank No. T-0076 T-0078 T-0079 T-0081 T-0082 T-0106 T-0107 T-0108 T-0109 T-0110 T-0111 T-0112 T-0114 T-0115 T-0116 T-0117 T-0119 T-0124 T-0400 T-0401 T-0402 T-0404 T-0405 T-0409 T-0410 T-0411 T-0412 T-0413 T-0415 T-0417 T-0418 T-0419 T-0420 T-0422 NSPS K NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NSPS Ka NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO YES YES NO NO NO NO NO NO NO NO NO NO NO NO NO NSPS Kb NO YES YES YES YES NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO MACT CC Storage NO YES YES YES YES YES YES YES YES YES YES YES NO NO NO YES NO YES YES YES YES YES YES YES YES YES YES YES YES YES YES YES YES YES MACT CC Wastewater N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NESHAP FF N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NSPS QQQ N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 20.2.37.205 20.2.38.109 20.2.38.110 20.2.38.112 20.2.38.113 NMAC YES YES YES YES YES YES YES YES YES NO YES YES YES YES YES YES YES YES YES YES YES NO NO NO NO YES YES YES YES YES NO NO NO NO NMAC NO YES YES NO NO YES YES YES YES NO YES YES NO NO NO YES NO YES NO YES YES NO NO NO NO YES YES YES YES YES NO NO NO NO NMAC NO YES YES NO NO YES YES YES YES NO YES YES NO NO NO YES NO YES NO YES YES NO NO NO NO YES YES YES YES YES NO NO NO NO NMAC YES YES YES YES YES NO NO NO NO NO NO NO YES YES YES NO YES YES YES YES YES NO NO NO NO NO NO NO NO NO NO NO NO NO NMAC NO YES YES NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO YES YES NO NO NO NO NO NO NO NO NO NO NO NO NO CAM NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO EPA Inspection Report - Page 206 of 1969 Table 103.C, Summary Applicability - Tanks Tank No. T-0423 T-0431 T-0432 T-0433 T-0434 T-0435 T-0437 T-0438 T-0439 T-0446 T-0447 T-0448 T-0449 T-0450 T-0453 T-0460 T-0465 T-0466 T-0467 T-0468 T-0600 T-0737 T-0802 T-0803 T-0804 T-0807 T-0809 T-0810 T-0814 T-0815 T-0816 T-0830 T-0834 T-0835 NSPS K NO NO NO NO NO NO YES NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NSPS Ka NO NO NO NO NO NO NO NO YES NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NSPS Kb NO NO NO NO NO YES NO NO NO NO NO NO NO YES NO NO NO NO NO NO NO YES YES NO NO NO NO NO YES YES NO YES NO NO MACT CC Storage YES YES YES YES YES YES YES YES YES NO NO NO NO YES NO NO NO NO NO NO NO YES YES NO NO NO NO NO YES YES NO NO YES YES MACT CC Wastewater N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES YES N/A YES N/A N/A N/A N/A YES N/A N/A NESHAP FF N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES YES N/A YES YES N/A N/A N/A YES N/A N/A NSPS QQQ N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NO NO N/A NO YES N/A N/A N/A YES N/A N/A 20.2.37.205 20.2.38.109 20.2.38.110 20.2.38.112 20.2.38.113 NMAC NO NO NO NO YES YES YES YES YES NO NO NO NO YES NO NO NO NO NO NO NO YES YES NO NO NO NO NO YES YES YES YES NO YES NMAC NO NO NO NO NO YES YES NO YES NO NO NO NO YES NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NMAC NO NO NO NO NO YES YES NO YES NO NO NO NO YES NO NO NO NO NO NO NO YES YES NO NO NO NO NO NO NO NO NO NO YES NMAC NO NO NO NO YES YES YES YES YES NO NO NO NO YES NO NO NO NO NO NO NO YES YES NO NO NO NO NO YES YES NO YES NO NO NMAC NO NO NO NO NO YES YES NO YES NO NO NO NO YES NO NO NO NO NO NO NO YES YES NO NO NO NO NO NO NO NO NO NO NO CAM NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO EPA Inspection Report - Page 207 of 1969 Table 103.C, Summary Applicability - Tanks Tank No. T-0838 T-0839 T-0840 T-0841 T-0891 T-0892 T-1221 T-1222 T-1223 T-1224 T-1225 T-1227 BioDiesel Ethanol NSPS K NO NO NO NO NO NO NO NO NO NO NO NO NO NO NSPS Ka NO NO NO NO NO NO NO NO NO NO NO NO NO NO NSPS Kb NO NO NO NO NO NO NO NO NO NO YES YES NO YES MACT CC Storage YES NO NO NO NO NO NO NO NO NO YES YES NO NO MACT CC Wastewater N/A N/A N/A N/A N/A N/A N/A N/A N/A YES N/A N/A N/A N/A NESHAP FF N/A N/A N/A N/A N/A N/A N/A N/A N/A YES N/A N/A N/A N/A NSPS QQQ N/A N/A N/A N/A N/A N/A N/A N/A N/A NO N/A N/A N/A N/A 20.2.37.205 20.2.38.109 20.2.38.110 20.2.38.112 20.2.38.113 NMAC YES NO NO NO NO NO NO NO NO NO YES YES NO NO NMAC NO NO NO NO NO NO NO NO NO NO YES NO NO NO NMAC NO NO NO NO NO NO NO NO NO NO YES NO NO NO NMAC NO NO NO NO NO NO NO NO NO NO YES YES NO NO NMAC NO NO NO NO NO NO NO NO NO NO YES NO NO NO Table 103.D, Summary Applicability – Loading Unit ID TL-4 TL-7 RLO-8 Description Fuels Truck Loading Rack CBO/LCO Truck Loading Rack Railcar Loading & Off-Loading Rack MACT CC YES NO NO 20.2.37.205.C NO NO NO MACT BBBBBB NO NO NO MACT CCCCCC NO NO NO CAM NO NO NO CAM NO NO NO NO NO NO NO NO NO NO NO NO NO NO EPA Inspection Report - Page 208 of 1969 Table 103.E, Summary Applicability – Heaters and Boilers Unit ID Description B-0007 B-0008 B-0009 Boiler 7 Boiler 8 Boiler 9 Unit 13 Naphtha Splitter Reboiler Unit 21 Vacuum Unit Heater Unit 06 HDS Reboiler South Crude Charge Heater South Crude Charge Heater H-0009 H-0011 H-0018 H-0019 H-0020 NSPS D NO NO NO NSPS Db YES YES YES NSPS Dc NO NO NO NO NO Yes MACT DDDDD YES YES YES 20.2.33.108 NMAC YES YES YES 20.2.36 NMAC YES YES YES 20.2.37 NMAC YES YES YES NO NO YES NO YES NO YES YES NO NO NO YES NO YES NO YES YES NO NO NO YES NO YES NO YES YES NO NO NO NO YES NO YES NO YES YES NO NO NO NO YES NO YES NO YES YES NO NSPS J NSPS Ja YES YES NO NO NO NO CAM NO NO NO H-0028 Unit 21 Heater H-28 NO NO NO YES NO YES NO YES YES NO H-0030 H-0040 H-0303 H-0312 Unit 06 Charge Heater Unit 13 Charge Heater Unit 05 Charge Heater Unit 10 FCC Feed Heater Unit 70 CCR Reformer Heater Unit 70 CCR Reformer Heater Unit 70 CCR Reformer Heater Unit 70 Stabilizer Reboiler Heater NO NO NO NO NO NO NO NO NO NO NO NO YES YES YES YES NO NO NO NO YES YES YES YES NO NO NO NO YES YES YES YES YES YES YES YES NO NO NO NO NO NO NO YES NO YES NO YES YES NO NO NO NO YES NO YES NO YES YES NO NO NO NO YES NO YES NO YES YES NO NO NO NO YES NO YES NO YES YES NO H-0362 Unit 70 CCR Heater NO NO NO YES NO YES NO YES YES NO H-0363 Unit 70 CCR Heater NO NO NO YES NO YES NO YES YES NO H-0352 H-0353 H-0354 H-0355 EPA Inspection Report - Page 209 of 1969 Table 103.E, Summary Applicability – Heaters and Boilers Unit ID Description NSPS D NSPS Db NSPS Dc NSPS J NSPS Ja MACT DDDDD 20.2.33.108 NMAC 20.2.36 NMAC 20.2.37 NMAC CAM H-0364 Unit 70 CCR Heater NO NO NO YES NO YES NO YES YES NO H-0421 Unit 44 Charge Heater NO NO NO YES NO YES NO YES YES NO H-0464 SRU Hot Oil Heater NO NO YES YES NO NO NO YES YES NO NO NO NO YES NO NO NO YES YES NO NO NO NO YES NO YES NO YES YES NO H-0473 H-0600 SRU1 and SRU2 Tail Gas Incinerator Unit 09 Depropanizer Reboiler Heater H-0601 Unit 33 Charge Heater NO NO NO YES NO YES NO YES YES NO H-2421 Unit 45 Charge Heater NO NO NO YES NO YES NO YES YES NO H-8801/ H-8802 Unit 63 Hydrogen Plant Reformer Unit 34 Hydrocracker Reboiler 1 Hydrocracker Reactor Charge Heater Unit 64 Hydrogen Plant Reformer Unit 25 ROSE® Unit No.2 Hot Oil Heater NO NO NO YES NO YES YES YES YES NO NO NO NO NO YES YES NO YES YES NO NO NO NO NO YES YES NO YES YES NO NO NO NO NO YES YES YES YES YES NO NO YES NO NO YES YES YES YES YES NO SRU3 Hot Oil Heater NO NO NO NO YES NO NO YES YES NO SRU3 Tail Gas Incinerator NO NO NO NO YES NO NO YES YES NO H-3402 H-3403 H-9851 H-2501 H-3101 (formerly SRU3HOH) SRU3-TGI EPA Inspection Report - Page 210 of 1969 Table 103.F, Summary Applicability – Cooling Towers Cooling Tower Y-0001 Description TCC Cooling Tower MACT Q YES MACT CC YES CAM NO Y-0002 YES YES NO Y-0008 S. Alky Cooling Tower (Marley Cooling Tower) North Alky Cooling Tower YES YES NO Y-0011 FCC & NP Cooling Tower NO YES NO Y-0012 Hydrogen Plants Cooling Tower NO YES NO CT TT-0006 Unit 07 Amine W-0745 Cooling Tower NO NO NO Table 103.G, Summary Applicability – Wastewater [return] Equipment ID MAIN API DAF-0896 DAF-0806 T-0801 T-0805 T-0829 T-0836 T-0897 Emission Point ID D-0829/0830 DAF-0896 DAF-0806 MACT CC Wastewater YES YES YES YES YES YES YES YES NESHAP FF YES YES YES YES YES YES YES YES NSPS QQQ YES NO NO NO NO NO NO NO CAM NO NO NO NO NO NO NO NO EPA Inspection Report - Page 211 of 1969 Table 103.H, Summary Applicability – FCC-CCR Unit ID FCCREGEN NSPS J YES NSPS Ja NO MACT UUU YES 20.2.37 NMAC YES CCR N/A N/A YES N/A CAM YES Satisfied by MACT UUU NO Table 103.I, Summary Applicability – SRU Source ID SRU1 Emission Point ID H-0473 SRU2 H-0473 SRU3 SRU3-TGI Description SRU1 and SRU2 Tail Gas Incinerator SRU1 and SRU2 Tail Gas Incinerator SRU3 Tail Gas Incinerator NSPS J YES NSPS Ja NO MACT UUU YES 20.2.36.113.A(1)(d) & 20.2.36.113.A(1)(e) YES 20.2.37.200B YES 20.2.37.202.A YES 20.2.39 NO YES NO YES YES YES YES NO NO YES YES YES YES YES NO CAM YES-Satisfied by MACT UUU YES-Satisfied by MACT UUU YES-Satisfied by MACT UUU EPA Inspection Report - Page 212 of 1969 Table 103.J, Summary Applicability – Engines [return] Source ID E-0600W Description Fire Water Pump Engine NSPS IIII YES MACT ZZZZ YES 20.2.61.109 NMAC YES 20.2.61.114 NMAC YES CAM NO E-0601M Fire Water Pump Engine YES YES YES YES NO E-0602E Fire Water Pump Engine YES YES YES YES NO E-0603 Fire Water Pump Engine YES YES YES YES NO E-0901 Fire Water Pump Engine YES YES YES YES NO G-0100 UPS backup generator NO YES YES YES NO G-0101 V-0543 V-0545 UPS backup generator Portable Air Compressor Portable Air Compressor NO YES YES YES YES YES YES YES YES YES YES YES NO NO NO V-0546 Portable Air Compressor YES YES YES YES NO E-8010 WWTP Emergency Engine YES YES YES YES NO Table 103.K, Summary Applicability – FLARES [return] Unit ID FL-400 FL-401 FL-402 FL-403 FL-404 Description North Plant Flare South Plant Flare FCCU Flare Alky Flare GOHT Flare NSPS A YES YES YES YES YES NSPS J NO NO NO NO NO NSPS Ja YES YES YES YES YES NESHAP A NO NO NO NO NO All flares are steam assisted. State of New Mexico requires that an exit gas velocity of 65 ft/sec for modeling. The heating value of the gas for all flares is < 1000 BTU/scf. MACT A YES YES YES YES YES 20.2.36.112 NMAC YES YES YES YES YES 20.2.36.113b NMAC YES YES YES YES YES 20.2.37.201B NMAC YES YES YES YES YES EPA Inspection Report - Page 213 of 1969 Table 104.A: Regulated Sources List [return to A104][return to A201Engines] Unit No. Unit Type Manufacturer B-0007 B-0008 B-0009 Boiler 7 Boiler 8 Boiler 9 Todd/John Zink burners Todd/John Zink burners Babcock & Wilcox E-8010 WWTP Diesel Pump Engine John Deere E-0600W Fire Water Pump Engine Clarke Diesel (John Deere) E-0601M Fire Water Pump Engine Clarke Diesel (John Deere) E-0602E Fire Water Pump Engine Clarke Diesel (John Deere) E-0603 Fire Water Pump Engine Clarke Diesel (John Deere) E-0901 Fire Water Pump Engine Clarke Diesel (John Deere) G-0100 G-0101 V-0543 V-0545 V-0546 H-0009 H-0011 H-0018 UPS backup generator UPS backup generator Portable Air Compressor Portable Air Compressor Portable Air Compressor Unit 13 Naphtha Splitter Reboiler Unit 21 Vacuum Flasher Heater Naphtha HDS Reboiler H-0019 South Crude Charge Heater Deutz Deutz Cummings, Inc. Cummings, Inc. Cummings, Inc. Zeeco burners Unknown Zeeco burners Callidus Technologies, burners Callidus Technologies, burners John Zink burners John Zink burners John Zink burners John Zink burners John Zink burners H-0020 H-0028 H-0030 H-0040 H-0303 H-0312 South Crude Charge Heater Unit 21 Heater H-28 (previously H-10) Unit 06 Charge Heater Unit 13 Charge Heater Unit 05 Charge Heater Unit 10 FCC Feed Heater H-0352 Unit 70 CCR Heater (previously 70-H1) H-0353 H-0354 H-0355 H-0362 Unit 70 CCR Heater (previously 70-H2) Unit 70 CCR Heater (previously 70-H3) Unit 70 Stabilizer Reboiler Heater H-355 (previously 70H-4) Unit 70 CCR Heater Callidus burners Callidus burners Callidus burners Model No. Unknown Unknown TBD 6090HF485/ RG6090L101484 JW6H-UFAD70/ RG6090L113548 JW6H-UFAD70/ RG6090L113561 JW6H-UFAD70/ RG6090L113574 JU6H-UFADX8/ PE6068L228486 JX6H-UF30’ RG6125A016118 Capacity 10/8/2001 * 2003 * TBD 215 MMBtu/hr (LHV Basis) 215 MMBtu/hr (LHV Basis) 220 MMBtu/hr (LHV Basis) 2/2011 400 hp 7/2012 7/2012 376 hp 376 hp 7/2012 376 hp 2012 305 hp 10/2007 430 hp QSC, 73104611 QSC, 73142120 QSC, 46917364 GSFW-12 burners Unknown GSFW-8 burners 1998 1999 8/30/2010 4/8/2011 11/19/2008 Unknown Unknown Unknown 52 hp 54 hp 260 hp 260 hp 240 hp 44 MMBtu/hr (LHV Basis) 38 MMBtu/hr (LHV Basis) 32 MMBtu/hr (LHV Basis) CUBL-8W burners New burners in 2005 54 MMBtu/hr (LHV Basis) CUBL-12W burners PSFG-12 burners PSFG-16R burners PSFG-16 burners HEVD-Q-18 burners VYD-18 burners New burners in 2005 Unknown 2000* 1990* 1982* 1990* 78 MMBtu/hr (LHV Basis) 12.3 MMBtu/hr (LHV Basis) 42 MMBtu/hr (LHV Basis) 42 MMBtu/hr (LHV Basis) 11 MMBtu/hr (LHV Basis) 35 MMBtu/hr (LHV Basis) CUBL-10W burners New burners in 2006 63 MMBtu/hr (LHV Basis) CUBL-10W burners New burners in 2006 81 MMBtu/hr (LHV Basis) CUBL-10W burners New burners in 2006 56 MMBtu/hr (LHV Basis) Unknown 1991* 24 MMBtu/hr (LHV Basis) CUBL-8W burners New burners in 2006 40 MMBtu/hr (LHV Basis) F4L912GEN/ Engine Family WDZXL05.7010 F4L 1011 F/ EI97-68CA00-000-0053 LLC LLC Technologies, LLC Technologies, LLC Technologies, LLC John Zink burners Callidus Technologies, burners Manufacture Date LLC EPA Inspection Report - Page 214 of 1969 Table 104.A: Regulated Sources List [return to A104][return to A201Engines] Unit No. H-0363 Unit Type Unit 70 CCR Heater H-0364 H-0421 Unit 70 CCR Heater Unit 44 Charge Heater (previously H-21) H-0464 SRU Hot Oil Heater Depropanizer Reboiler Heater (previously 3F-1) H-0600 H-0601 Unit 33 Charge Heater H-2421 Unit 45 Charge Heater H-8801 H-8802 H-2501 H-3403 H-3402 H-9851 Unit 63 Hydrogen Plant Reformer Furnace Unit 63 Hydrogen Plant Reformer Furnace ROSE2 Hot Oil Heater Hydrocracker Reactor Charge Heater Hydrocracker Fractionator Reboiler 1 Unit 64 Hydrogen Plant Reformer H-3101 H-0473 (SRU1/SRU2 TGI) SRU3 Hot Oil Heater SRU1 and SRU2 Tail Gas Incinerator SRU3-TGI FCC Regenerator CCRr FL-0400, North Plant Flare FL-0401, South Plant Flare FL-0402, FCC Flare SRU3 Tail Gas Incinerator FCC Regenerator Scrubber CCR Reformer North Plant Flare South Plant Flare FCC Flare FL-0403, Alky Flare FL-0404, GOHT Flare Y-0001 Alky Flare GOHT Flare TCC Cooling Tower S. Alky Cooling Tower (Marley Cooling Tower) North Alky Cooling Tower FCC & NP Cooling Tower Hydrogen Plants Cooling Tower Y-0002 Y-0008 Y-0011 Y-0012 Manufacturer Callidus Technologies, burners Callidus Technologies, burners John Zink burners Callidus Technologies, burners Callidus Technologies, burners Callidus Technologies, burners Model No. Manufacture Date Capacity LLC CUBL-8W burners New burners in 2006 50 MMBtu/hr (LHV Basis) CUBL-6W burners LNC-PC-18 burners New burners in 2006 1981* 35 MMBtu/hr (LHV Basis) 27 MMBtu/hr (LHV Basis) LE-CSG-4W burners 2003* 1991*, New burners in 2009 9.6 MMBtu/hr (LHV Basis) CUB-8P-CW burners GLSF-14 Round Flame "Free Jet" burners LE-CSG-12W-PSA burners LE-CSG-12W-PSA burners New burners in 2003 78 MMBtu/hr (LHV Basis) 2006* 27 MMBtu/hr (LHV Basis) 2006* 60 MMBtu/hr (LHV Basis) 2006* 60 MMBtu/hr (LHV Basis) COOLstar-18 burners 2009* 120 MMBtu/hr (LHV Basis) CUBL-10W burners TBD 32.0 MMBtu/hr (LHV Basis) LE-CSG-12W burners 2009* 52 MMBtu/hr (LHV Basis) CUBL-3WDF burners 2009* 337 MMBtu/hr (LHV Basis) Unknown Unknown 05/11/2009 * Unknown 9.6 MMBtu/hr (LHV Basis) NA Unknown Unknown Unknown Unknown Unknown Unknown 05/11/2009 * Unknown Unknown Unknown Unknown Unknown NA NA NA NA NA NA Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown NA NA 5,000 gpm, 0.003% drift Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown 5,000 gpm, 0.003% drift 12,500 gpm, 0.003% drift 30,000 gpm, 0.001% drift 10,000 gpm, 0.001% drift Zeeco, Inc. burners Callidus Technologies, burners Callidus Technologies, burners John Zink Company, burners Callidus Technologies, burners Callidus Technologies, burners Callidus Technologies, burners Callidus Technologies, burner Unknown Callidus Technologies, burners Unknown Unknown Unknown Unknown Unknown LLC LLC LLC CUBL-12W burners 84 MMBtu/hr (LHV Basis) LLC LLC LLC LLC LLC LLC LLC LLC LLC EPA Inspection Report - Page 215 of 1969 Table 104.A: Regulated Sources List [return to A104][return to A201Engines] Unit No. CT TT-0006 MAIN API T-0896 T-0801 T-0836 T-0829 T-0806 Fugitives (see Table 103.B) Loading (see Table 103.D) Tanks (see Table 103.C) * Installation date Unit Type Unit 07 Amine W-0745 Cooling Tower Above Ground API Oil-Water Separator DAF Unit T-0896 Enhanced Biodegradation Tank T-0801 Enhanced Biodegradation Tank T-0836 Equalization Tank T-0829 DAF Unit T-0806 Equipment component leaks (pump seals, valves, flanges, etc.) Bulk Loading/Unloading Racks Fixed Roof, External Floating Roof & Internal Floating Roof Tanks Manufacturer Model No. Manufacture Date Capacity Unknown Unknown Unknown Unknown Unknown Not yet installed Not yet installed Unknown Unknown Unknown Unknown Unknown Not yet installed Not yet installed Unknown Unknown Unknown Unknown Unknown Not yet installed Not yet installed 3,000 gpm, 0.003% drift 1,200 gpm 1,200 gpm 1,200 gpm 1,200 gpm 1,200 gpm Not yet installed NA NA NA NA Varies Varies NA Varies NA NA Varies Varies Note: Serial numbers are not used since most equipment consists of field erected parts that are assembled on site and may have several “serial numbers” for various components. Heaters are the best example because each of the burners has a serial number but the heater as a whole does not have a single serial number. The heater as a whole is typically identified by our equipment number. There may also be a “project number” or “job number” from the manufacturer, but that can change if a heater is revamped at a later date such as when they modify the convection section to improve energy efficiency. EPA Inspection Report - Page 216 of 1969 Table 106.A Allowable Emission Limits [return A106] 2 SO2 NOx B-0007 B-0008 B-0009 H-0009 H-0011 H-0018 H-0019 H-0020 H-0028 H-0030 H-0040 H0352/0353/0354 H-0355 H-0303 H-0312 H0362/0363/0364 H-0421 H-0464 H-0600 H-0601 H-2421 H-8801/8802 H-2501 H-3402 H-3403 H-9851 H-3101 H-0473 (SRU1/SRU2 TGI) SRU3-TGI 5 (lb/hr) (ton/yr) 7.3 24 11 35 40/50/35 5 5 (lb/hr) (ton/yr) 56.5 56.5 19.3 17.3 31.6 15.2 12.5 18.3 9.5 14.0 16.6 0.06 0.06 0.02 BACT 0.09 0.0527 0.0535 - 11.8 9.0 39.4 0.9 0.4 1.3 1.4 0.7 2.1 2.2 1.2 4.6 4.6 7.4 27 9.6 84 78 27 60/60 120 52 32.0 1.0 0.4 3.1 2.8 1.0 0.2 4.4 1.9 1.2 337 9.6 NA 215 215 220 44 38 32 54 78 12.3 42 42 63/81/56 NA PM VOC 5 MM Btu/hr Source ID 4 CO 3,5 5 (lb/hr) (ton/yr) 0.045 18.2 9.5 5.2 20.2 - 6.9 30.1 1.6 0.6 5.0 4.6 1.6 0.8 7.1 3.1 1.9 2.4 0.5 4.7 3.5 1.2 4.2 3.6 1.6 1.0 10.6 2.3 20.3 15.4 5.3 18.4 15.8 6.8 4.2 0.5 2.2 4.2 18.5 0.4 0.6 0.3 30.0 81.8 30.0 81.8 7.8 7.8 2.6 1.6 1.4 1.2 2.0 2.8 0.4 1.5 1.5 12.7 12.7 11.4 2.6 2.3 1.9 3.2 4.6 0.7 2.5 2.5 (lb/hr) (ton/yr) 79.7 1.7 2.2 1.0 3.2 9.6 4.4 14.0 0.055 11.4 1.3 0.09 0.05 0.045 0.045 0.035 0.03 0.03 0.03 0.0125 BACT 0.03 6.5 28.5 6.5 28.5 12.9 12.9 4.4 4.0 9.5 3.5 2.9 4.2 2.2 3.2 3.8 (lb/MM Btu) (lb/MM Btu LHV) 5 (lb/hr) (ton/yr) 7.2 1.2 5.2 0.2 0.1 0.3 0.9 0.4 1.3 0.1 0.1 0.2 0.6 0.3 0.9 49.8 1.0 4.5 0.7 3.3 2.5 0.9 7.6 7.1 2.5 10.9 7.2 4.7 2.9 10.8 3.8 33.5 31.1 10.8 47.8 31.5 20.7 12.8 0.2 0.1 0.7 0.6 0.2 1.0 1.0 0.4 0.3 1.0 0.4 3.03 2.8 1.0 4.3 4.3 1.9 1.2 0.2 0.1 0.5 0.5 0.2 0.7 0.7 0.3 0.2 0.7 0.3 2.2 2.0 0.7 3.1 3.1 1.4 0.8 20.2 88.6 0.06 BACT 2.8 12.2 2.0 8.8 0.9 3.8 0.09 BACT 0.1 0.4 0.1 0.3 N/A 27.7 121.2 0.5 2.2 0.1 0.6 N/A 15.0 65.7 0.5 2.2 0.1 0.6 19.6 19.6 8.1 4.0 3.5 2.9 4.9 7.1 1.1 3.8 3.8 85.7 85.7 35.7 17.5 15.2 12.8 21.5 31.1 4.9 16.8 16.8 0.09 BACT 0.09 BACT 1.8 1.8 1.6 0.4 0.3 0.3 0.4 0.6 0.1 0.4 0.4 7.8 7.8 7.2 1.6 1.4 1.2 2.0 2.8 0.4 1.5 1.5 1.3 1.3 0.9 0.3 0.2 0.2 0.3 0.5 0.1 0.3 0.3 5.6 5.6 3.9 1.2 1.0 0.8 1.4 2.0 0.3 1.1 1.1 EPA Inspection Report - Page 217 of 1969 Table 106.A Allowable Emission Limits [return A106] 2 SO2 NOx FCC Regenerator FL-0400, North Plant Flare FL-0401, South Plant Flare FL-0402, FCC Flare FL-0403, Alky Flare FL-0404, GOHT Flare Subtotal Tanks, Table 106.E Fugitives, Table 106.F Misc Sources, Table 106.G Cooling Towers, Table 106.H Oil/Water Separators, Table 106.I 6 SSM, Table 107 5 NA NA NA NA NA NA PM VOC 5 MM Btu/hr Source ID 4 CO 3,5 (lb/hr) (ton/yr) 0.2 5 (lb/hr) (ton/yr) 0.5 0.2 0.1 0.1 0.1 5 5 N/A (lb/hr) 121.9 (ton/yr) 0.8 N/A 1.0 <0.1 0.2 N/A 0.1 <0.1 0.2 <0.1 <0.1 <0.1 2.4 10.5 4.1 27.9 61.0 345.4 35.0 (lb/hr) (ton/yr) 4.3 0.0 0.2 1.1 N/A 0.2 <0.1 N/A 18.1 N/A 101.9 668.8 (lb/MM Btu) (lb/MM Btu LHV) 5 (lb/hr) (ton/yr) 0.0 0.2 0.7 0.0 0.0 <0.1 0.2 1.1 0.0 0.0 <0.1 0.2 <0.1 0.2 0.0 0.0 <0.1 <0.1 13.6 59.6 0.0 0.0 2.3 10.2 106.8 1156.2 25.0 109.5 - 196.0 - 70.2 322.4 994.6 16.6 2.5 9.0 56.2 5.3 27.4 31.6 97.6 0.4 TOTAL 1 NA 372.8 700.4 N/A 1256.3 205.3 1 Totals are for information and are not enforceable conditions. 2 Nitrogen dioxide emissions include all oxides of nitrogen expressed as NO2 3 lbs-NOX/MMBtu of heat input, calculated as a 3-hour average, when firing natural gas at 3% stack oxygen at full design load without air preheat. 4 All Particulate Matter emitted is assumed to be of aerodynamic diameter 10 microns or less. 5 Hourly emission limits and lb/MM Btu limits are based on a hourly rolling 3-hour average. 6 Maximum allowable emissions during maintenance, startup, or shutdown (SSM) and malfunction activities. “-“ indicates that in accordance with the application, emissions of this pollutant are not expected. “- -“ indicates that the emissions are less than 1.0 pph or 1.0 tpy and emission limits are not required for this permit, unless it’s for a control device. Unit 9851, the SCR exhaust has Ammonia Slip limit of 7 ppmv on a wet basis and 6.1 tpy (BACT). 9.5 46.2 1515.7 EPA Inspection Report - Page 218 of 1969 INTERNAL FLOATING ROOF STORAGE TANKS TABLE 106.B(1) VAPOR PRESSURE LIMITATIONS FOR REFINERY NONCOMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOC) Tank No. Typical Liquid Stored Most Volatile Category of Allowable Liquids to be Stored1 Max Vapor Pressure (psia) of Most Volatile Liquid at Max Temp. T-0056 T-0106 T-0107 Naphthas Distillates Gasolines High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 11.0 11.0 11.0 T-0108 Gasolines High Vapor Pressure2 11.0 Gasolines High Vapor Pressure 2 11.0 High Vapor Pressure 2 High Vapor Pressure 2 11.0 11.0 11.0 11.0 11.0 11.0 11.0 11.0 11.0 T-0109 T-0111 T-0112 T-0011 T-0124 T-0012 T-0413 T-0415 T-0417 T-0439 Naphthas Naphthas Gasolines Gasolines Gasolines Distillates Gasolines Gasolines Crude Oil High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 1 Liquids in lower volatility categories may also be stored (i.e., tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allowed to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). 2 High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub-grade, regular, premium, and other blends), Alkylate, Reformate, FCC Gasoline, Ethanol, Isomerate, Straight Run Gasoline, and other refinery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 11 psia or less under actual storage conditions. EPA Inspection Report - Page 219 of 1969 EXTERNAL FLOATING ROOF STORAGE TANKS TABLE 106.B(2) VAPOR PRESSURE LIMITATIONS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOC) Tank No. Typical Stored T-0057 T-0078 Naphthas Isomerates High Vapor Pressure2 High Vapor Pressure2 11.0 11.0 T-0079 T-0117 T-0401 T-0402 T-0411 T-0412 T-0435 T-0437 T-0450 T-0802 T-0830 T-0834 T-0835 T-1225 Isomerates Gasolines Gasolines Gasolines Gasolines Gasolines Crude Oil Crude Oil Naphthas Sour Water Slop Distillates Distillates Naphthas High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 Moderate Vapor Pressure3 High Vapor Pressure2 High Vapor Pressure2 11.0 11.0 11.0 11.0 11.0 11.0 11.0 11.0 11.0 11.0 11.0 1.5 11.0 11.0 T-0737 TK-NEWETHANOL Sour Water Ethanol High Vapor Pressure2 High Vapor Pressure2 11.0 2.32 1 2 3 Liquid Most Volatile Category of Allowable Liquids to be Stored1 Max Vapor Pressure (psia) of Most Volatile Liquid at Max Temp. Liquids in lower volatility categories may also be stored (i.e., tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allowed to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub-grade, regular, premium, and other blends), Alkylate, Reformate, FCC Gasoline, Ethanol, Isomerate, Straight Run Gasoline, and other refinery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 11 psia or less under actual storage conditions. Moderate Vapor Pressure Liquids include: Desulfurized Naphtha (Splitter Bottoms), Light Slop, and other refinery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 1.5 psia or less under actual storage conditions. EPA Inspection Report - Page 220 of 1969 FIXED ROOF STORAGE TANKS TABLE 106.C VAPOR PRESSURE LIMITATIONS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOCs) Tank No. Typical Liquid Stored Most Volatile Category of Allowable Liquids to be Stored1 Max Vapor Pressure (psia) of Most Volatile Liquid at Max Temp. T-0013 Slop Moderate Vapor Pressure3 1.5 T-0040 Distillates Low Vapor Pressure4 0.5 Distillates Low Vapor Pressure 4 0.5 4 0.5 T-0041 T-0110 Asphalt/Pitch Low Vapor Pressure T-0400 Gas Oils Low Vapor Pressure4 0.5 T-0404 Carbon Black Low Vapor Pressure4 Oil (CBO) 0.5 T-0405 CBO Low Vapor Pressure4 0.5 T-0409 Gas Oils Low Vapor Pressure4 0.5 4 0.5 T-0410 Asphalt/Pitch Low Vapor Pressure T-0418 Distillates Low Vapor Pressure4 0.5 T-0419 Distillates Low Vapor Pressure4 0.5 T-0420 CBO Low Vapor Pressure4 0.5 T-0422 Distillates Low Vapor Pressure4 0.5 T-0423 Distillates Low Vapor Pressure4 0.5 T-0431 Distillates Low Vapor Pressure4 0.5 T-0432 Distillates Low Vapor Pressure4 0.5 T-0049 T-0055 T-0058 T-0059 T-0061 T-0063 T-0065 T-0075 T-0433 T-0434 T-0438 T-0810 T-0814 T-0815 T-0838 T-1227 T-0081 Slop Distillates Distillates CBO Distillates CBO CBO CBO Gas Oils Distillates Gas Oils Slop Asphalt/Pitch Distillates Distillates Asphalt/Pitch Asphalt/Pitch Moderate Vapor Pressure3 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Moderate Vapor Pressure3 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 1.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 1.5 0.5 0.5 0.5 0.5 0.5 EPA Inspection Report - Page 221 of 1969 FIXED ROOF STORAGE TANKS TABLE 106.C VAPOR PRESSURE LIMITATIONS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOCs) Tank No. T-0082 RW-4 RW-5 RW-6 TKNEWBIODIES EL Typical Liquid Stored Asphalt/Pitch Recovery Well Hydrocarbons Recovery Well Hydrocarbons Recovery Well Hydrocarbons Biodiesel Most Volatile Category of Allowable Liquids to be Stored1 Max Vapor Pressure (psia) of Most Volatile Liquid at Max Temp. Low Vapor Pressure4 High Vapor Pressure2 0.5 11.0 High Vapor Pressure2 11.0 High Vapor Pressure2 11.0 Low Vapor Pressure4 0.022 Liquids in lower volatility categories may also be stored (i.e., tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allowed to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). 2 High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub-grade, regular, premium, and other blends), Alkylate, Reformate, FCC Gasoline, Ethanol, Isomerate, Straight Run Gasoline, and other refinery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 11 psia or less under actual storage conditions. 3 Moderate Vapor Pressure Liquids include: Desulfurized Naphtha (Splitter Bottoms), Light Slop, and other refinery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 1.5 psia or less under actual storage conditions. 4 Low Vapor Pressure Liquids include: Diesel (raw or finished), Kerosene (raw or finished), JP-8, CBO, LCO, Slurry, Heavy Slop, Cutback Asphalt, Cutter, VGO, AGO, and other refinery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure less than 0.5 psia under actual storage conditions. 1 EPA Inspection Report - Page 222 of 1969 TABLE 106.D – STORAGE TANK THROUGHPUT AND TEMPERATURE LIMITS Material Throughput (bbl/yr) Maximum Storage Temperature (ºF) Asphalt/Pitch 30,872,000 510 Carbon Black Oil (CBO) 1,291,610 250 Crude Oil 76,212,000 Ambient Distillate 55,076,590 310 Gas Oil 25,059,500 310 Gasoline (includes isomerates) 57,910,908 Ambient Naphtha 39,028,084 Ambient Slop 1,330,000 Ambient Sour Water 45,051 Ambient BioDiesel 949,000 Ambient Methanol 142,350 Ambient TABLE 106.E– STORAGE TANK VOC AND H2S EMISSION LIMITS1 (return to A203) 1 Tank Type VOC Emission Rate (tpy) H2S Emission Rate (tpy) Fixed-Roof 238.6 0.0 Floating-Roof 83.8 1.47 Total Tanks 322.4 1.47 The permittee shall demonstrate compliance with the above throughputs and emission limits through the annual emissions inventory process. Specific tank data (e.g. temperature & throughputs) shall be monitored and recorded weekly by the permittee. EPA Inspection Report - Page 223 of 1969 Table 106.F, 1EMISSIONS LIMITS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOC) FUGITIVE EMISSIONS FROM EQUIPMENT LEAKS 1 Process Unit ID Number Description FUG-02-SP CRUDE FUG-10-FCC FUG-20-ISOM FUG-21-SP VACUUM FUG-05-KERO FUG-06-NHDU South Division Crude Unit FCC w/CVS Powerformer/Penex Unit w/CVS Flasher/Vacuum Unit Kerosene HDS Unit JP8 Hydrodesulfurization 10.2 10.8 5.9 3.2 5.2 7.1 Average Annual VOC Emission Rate (tons/yr) 44.6 47.2 25.7 13.9 22.7 30.9 FUG-18-LSR MEROX TRT Merox/Merichem Treating Units 3.5 15.3 FUG-35-SAT GAS Saturates Gas Plant 18.3 80.0 FUG-29-BLENDER/TK FARM Light Oil Tankage 6.8 29.6 FUG-ASPHALT STG Asphalt/Heavy Oil Storage 3.5 15.3 FUG-FUEL GAS Fuel Gas Distribution System FUG-LPG LPG Storage System FUG-41-PBC PBC Unit FUG-70-CCR FUG-13-NHDU Maximum Hourly VOC Emission Rate (lb/hr) 4.2 18.2 21.6 94.4 3.4 14.7 CCR Reformer (w/in battery limits) 23.4 102.3 Naphtha HDS Unit 10.2 44.6 FUG-43-S ALKY FUG-09-N ALKY South Alky Unit (W-76) North Alkylation Unit (New-Inside battery limits) 1.7 12.0 7.5 52.5 FUG-44-DIST-HDU Gas Oil Hydrotreater (incl. CVS) 9.3 40.6 FUG-45-DIST-HDU Gas Oil Hydrotreater (incl. CVS) 2.6 11.2 FUG-07-N AMINE FUG-SRU1/SRU2/TGTU FUG-07-SWS1 FUG-80-WWTP CVS FUG-33-DIST HDU Amine Unit-Treating/Regen. SRU1/SRU2/SWS w/CVS Sour Water Stripper Oil/Water Separator Relocated Diesel HDS Unit w/CVS 6.3 2.4 1.6 1.3 12.9 27.5 10.4 7.0 5.5 56.4 FUG-08-TRUCK RK FUG-RLO-ASPHALT FUG-73-SP UTIL FUG-63-H2 PLANT-1 FUG-31-SRU3/TGTU3/TGI3 FUG-34-HYDROCRACKER FUG-25-ROSE-2 Loading Racks Asphalt/Pitch Loading Rack Utilities Hydrogen Plant SRU3 Unit WX Hydrocracker ROSE Unit 2.8 0.7 16.7 2.6 0.7 6.2 8.0 12.1 2.9 73.3 11.2 3.1 27.2 35.1 FUG-64-H2 PLANT-2 FUG-RRTOTRUCK Hydrogen Plant Crude oil unloading system, closed loop system between railcars and trucks 2.6 0.1 11.2 0.5 227.8 994.6 Subtotal Facility VOC CAP Minor changes within the facility to piping and components that affect fugitive VOC emission source shall be updated and added during the next available Significant permit revision in accordance with 20.2.72 NMAC. The facility wide fugitive VOC emission limit shown above and in Table 106.A of this permit. EPA Inspection Report - Page 224 of 1969 MISCELLANEOUS SOURCES Table 106.G EMISSION LIMITS FOR REFINERY NON-COMBUSTION SOURCES Of VOLATILE ORGANIC COMPOUNDS (VOCs) Loading Rack Loading Rack Description TL-4a Fuels Truck Loading Rack TL-7 CBO/LCO Truck Loading Rack RLO-8 FUGODOR Railcar Loading & Off-Loading Rack Odor Controlling Atomizer Material Loaded Gasoline Diesel Jet Fuel TOTAL VOC Carbon Black Oil Light Cycle Oil TOTAL VOC Carbon Black Oil Diesel Jet Fuel Asphalt TOTAL VOC Hourly Annual Throughput Throughput bbl/hr 1214 107100 35700 bbl/yr 1,600,696 3,650,000 1,021,718 30000 38100 500,808 20,119 30000 20000 20000 30000 365,000 1,144,000 1,144,000 2,628,000 1250 ml/hr 10950 liters VOC Emissions lb/hr 4.25 1.72 0.75 6.73 6.30 3.55 6.30 6.30 0.32 0.42 0.01 6.30 ton/yr 2.80 1.72 0.34 4.86 1.57 0.06 1.63 1.15 0.54 0.38 0.03 2.09 0.46 2.0 Note:1. Calculation method and factors per AP-42, Section 5.2, dated June 2008. a Controlled emission rate. The previous controlled rate was set by the terms of the consent agreement between Navajo Refining Co. and the Department executed January 28, 1994. The agreement required that the incinerator have a minimum 90% destruction efficiency for gasoline loading and a minimum 80% destruction efficiency for diesel fuel loading or Jet A fuel loading. This was achieved by a vapor combustor. This device has since been replaced with a carbon adsorption system compliant with MACT Subpart R, as subject per MACT Subpart CC. Emission limits changed in 195-M-17 to correspond to Title V permit values. EPA Inspection Report - Page 225 of 1969 COOLING TOWERS Table 106.H EMISSION LIMITS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUMDS and PM Source ID Y-0001 Y-0002 Y-0008a Y-0011 Y-0012 CT TT-0006 a Subtotal informational only) VOC lb/hr 1.8 1.8 6.5 1.3 0.4 1.1 (for 12.8 purposes VOC tons/yr 7.9 7.9 28.3 5.5 1.8 4.7 56.1 PM (lb/hr) 0.3 0.3 0.7 0.5 0.2 0.2 2.1 PM CO (tons/yr) (lb/hr) 1.2 1.2 2.9 0.58 2.3 0.8 0.7 9.1 CO (tons/yr) 2.54 Y-0008 cooling tower provides 100% control of any NH3 emissions from V-H2 and V-H2-2. Unit 64, Hydrogen Plant has de-aerator line that has dissolved CO that is connected to the cooling tower. API OIL/WATER SEPARATORS Table 106.I EMISSION LIMITS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOCs) Maximum Average Hourly VOC Annual VOC Equipment Emission Emission Emission ID Point ID Description Rate (lb/hr) Rate (tons/yr) Above Ground API Oil-Water Separators MAIN API D-0829/0830 and enclosed drain system. <0.1 <0.1 T-0896 DAF-0896 DAF Unit T-0896 <0.1 <0.1 T-0801 T-0801 Enhanced Biodegradation Tank T-0801 <0.1 <0.1 T-0836 T-0836 Enhanced Biodegradation Tank T-0836 0.1 0.5 T-0829 T-0829 Equalization Tank T-0829 5.1 8.9 T-0806 DAF-0806 DAF Unit T-0806 <0.1 <0.1 Subtotal (for informational purposes only) 5.3 9.4 EPA Inspection Report - Page 226 of 1969 Table 107.A MAINTENANCE STARTUP AND SHUTDOWN EMISSION LIMITS [return to A107] NOx Unit Description of Emissions SSM H-9851 SSM T-0737 Emissions during SCR downtime Emissions from roof landing SSM Misc 1 Emissions from catalyst handling SSM SRU3-TGI SSM T-0078 SSM T-0079 SSM T-1225 SSM FL-HEPPORT SSM SRU2-TGI (H-0473) 1 Emissions from SRU3 startup and shutdown Emissions from roof landing and tank refilling Emissions from roof landing and tank refilling SSM Misc 2 Emissions from roof landing Temporary, portable flare for natural gas pipeline maintenance Emissions from SRU2 startup and shutdown Emissions from venting SSM activity gases to FL-400, FL-401,FL-402, FL403, or FL-404. Upset and Malfunction Emissions Low-Emitting Maintenance Activities such as de-inventorying small equipment, clearing piping associated with emission units, and routine maintenance activities such as heat exchanger repair. SSM Tanks Misc Storage Tanks SSM Flare Cap Flares Malf Cap Subtotal SSM/M1 pph tpy pph CO tpy VOC pph tpy TSP/PM10/PM2.5 pph tpy 10.1 -- 1.2 -- 20.2 -- 2.4 -- 2.0 33.0 0.2 0.5 2.8 -- -- -- -- -- -- -- 6.5 <0.1 15.0 0.1 0.1 -- -- -- -- -- -- -- -- SO2 H2S pph tpy pph tpy 0.3 -- 0.5 -- 0.1 -- --- --- 1.5 <0.1 -- -- -- -- <0.1 -- -- 159.0 0.4 6.5 <0.1 177.0 2.7 -- -- -- -- 306.0 4.6 -- -- -- -- 187.0 2.8 173.4 0.1 943.5 0.5 160.7 0.1 -- -- 1.7 <0.1 0.02 <0.1 6.5 0.1 27.7 0.2 0.2 0.1 -- -- 159.0 0.4 6.6 0.1 162.9 -- 18.3 10.0 1243.0 -- 77.0 10.0 211.6 -- 13.2 10.0 --- --- 1133. 4 -- 14.9 10.0 0.4 -- 0.1 -- 17.0 1.9 127.1 7.8 21.2 1.4 -- -- 129.3 1.6 0.7 0.1-- -- -- -- -- 112.0 10.6 -- -- -- -- 0.1 0.1 31.6 98.0 46.2 0.4 27.4 0.4 1 During startup, shutdown, schedule maintenance or malfunction of the SCR control system, BACT for H-9851 shall be ultra-low NOx burners emitting no more than 0.03 lb per MMBtu (LHV) on a hourly rolling 3-hour average basis at 3% excess oxygen. Pound per hour and tons per year limits are based on the lb/MMBtu limits and were used to demonstrate compliance with the lb/MMBtu limits and the Ambient Air Quality Standards (AAQS). EPA Inspection Report - Page 227 of 1969 I a l: Receivers 419 hit. is an?; 7" Air Quality Bureau July]6.2019 CGR Lit?g guhgc?a} CL jut, 20)? Enforcement Manager New Mexico Environment Department Certi?ed MailtRetum Receipt Air Quality Bureau an asst} com 7923 5866 525 Camino de Los Marquez, Suite I Santa Fe, NM 87505-1816 Re: Notice of Sea] Inspection and Re?ll Tanks 0106, 0107, 0451, and 0737 Ho?yFronticr Navajo Re?ning LLC Artesia, NM Refinery Agency Interest No. 198 Dear Enforcement Manager: Pursuant to 40 CFR as applicable to Group 1 storage vessels subject to 40 CFR 63.646 (MACT Subpatt CC storage vessel provisions), Navajo is providing this advance notice of seal inspection to he made by Navajo?s inspection department. These tanks comply with MAC Subpatt CC, and only is subject to NSPS Subpart K, Ka or During the scheduled sea] inspections of tanks T-DlOti, T431107, T-0451, and T-0737, problems were identi?ed with the ?oating roofs. These tanks will be emptied and degassed to perform repairs. Once the tank repairs are completed, an inspection will be performed of the ?oating roof, primary seal, secondary seal, gaskets, slotted membranes, and sleeve seals. These tanks will be re?lled upon completion of the inspection and repairs. This noti?cation also fulfills the requirements of 40 CFR Roof MACT Primary Seal Secondary Seal Re?ll 3" Inspection Tank Type CC Group NSPS Inspection? Inspection?I scheduled On or After T-O 1 06 IFR 1 None Yes Yes 31? I 7120 None Yes Yes T-0451 IFR 2 None No Yes SKIW2019 EFR 1 Kb Yes Yes 8f 17/2019 The tanks inspection may require fresh air packs for safe access. Ii?you plan to observe the seal gap measurements for such tanks, please bring appropriate equipment and certi?ed personnel. Please contact me at (575) 746-548? or Ray Smalts at (575) 746-5490 if you have any additional questions. Ho?yFrontier Navajo Re?ning LLC 501 East Main - Attesia, NM 83210 [575) 748-3311 - EPA Inspection Report - Page 228 of 1969 Notice of Seal Inspections 8: Refill July 15. 2019 Page 2 Sincerely, Scett M. Denton Environmental Manager Navajo Re?ning RC). Box 159 Arleeia, New Mexico 88211-0159 Phone: (575} 7?46-5487 E-mail: cc: Navajo: P. Miller. B. anineq A. Ken: 0. Dmninguea K. Newlnn. W. Swnyer. D. Hammond. R. Smalls Environmental File: 2.6.4 Arlesie Tank Seal lnspeeticn'i and Re?ll Navaj? Refining LLC 501 East Main Artesia, NM 88210 (575) 748-3311 - http1/ EPA Inspection Report - Page 229 Nola? R/Iexico Environment Department . . Air Quality Bureau l] I'll: ii Compliance and Enforcement Section 525 Camino de los Marquez, Suite 1 r1- . Santa Fe, NM 87505 Phone (595) 416-4301] Fax {505) 416-4375 Version D5.i'.12.13 NMED USE ONLY NMED USE ONLY TEMPO REPORTING SUBMITTAL FORM Staff . . . . Admin Pttiur Home)- Indicates required field i" i= If If Lil: Eel; if i if v. 53; SECTION I - GENERAL COMPANY AND FACILITY INFORMATION A. ?31 Company Name: D. Facility Name: Navajo Refining LLC HolIyFrontier Navajo Re?ning LLC 3.1 Company Address: 5.1 it? Facility Address: PO Box159 501 E.Main St. 5.2 (E) lCity: 3.3 61 State: 3.4 (El Zip: E.2 City: E.3 State: E.4 Zip: Artesia Ariesia NM 33210 6.1 Company Environmental Contact: {3.2 Title: F.1 Facility Contact: F.2 it?) Title: Scott Denlon Environmental Manager Scott Benton Environmental Manager 0.3 to Phone Number: 575-?46-5437 (3.4 (ti) Fax Number: STE-T466451 F.3 Phone Number: 575-?45-5487 F.4 Fax Number: 0.5 ?t Email Address: Scott.Denton@hoilyfrontier.com F.5 (ii) Email Address: G. Resnonsibie Of?cial: iTitle ?ii' onlv?l: Robert K. O'Brien H. Title: Vice President 8: Re?nery Manager. Navajo Re?ning LLC Phone Number: 5?5-?48- 331 1 J. Fax Number: 5?5-745?5451 K. Al Number: L. Title Permit Number: M. Title Issue Date: N. NSR Permit Number: 0. NSR Permit Issua Date: 193 05i06i2015 95-M3TR2 11i14i2918 P. Reporting Period: From: NM To: Niel SECTION II -- TYPE OF SUBMITTAL {check one that applies] A Title Annual Compliance Permit Conditionis}: Description: l:l Certi?cation Title Semi-annual Permit Conditionlsi: Description: Monitoring Report Re I t' Sectionisi: t' NSPS Requirement no a ton escrio ion {worsen} Reoulation: Sectiontsl: Description: MACT Requirement . D. MAST Subpart CC 40 CFR MADT Slubpart CC Tank Seal lnepection Advance Notification NMAC Requirement Reoulation: Sectionis?i: Description: E. [j or NESHAP Requirement (4DCFRE1J Permit Moi]: or li?l Conditionlsj: Description: l:l Permit or Notice oflntent Requirement NOV lilo. or SFO No. El: Sectionjsj: Description: Re uirement of an . . El Action "mum SECTION IV - CERTIFICATION After reasonable inquiry. Scott M. Denton [name of reporting official} certify that the information in this submittal is true. accurate and complete. nature of Renorti Of?cial: Title: i5) Date Environmental Manager. Navajo 12i12i'2t?li1 Re?ning LLC Responsible D?iriui tor Tide Yes No Reviewed By: Date Reviewed: EPA Inspection Report - Page 230 of 1969 zl-F December 12, 2018 Enforcement Manager New Mexico Enviromnent Department Certi?ed MaiIrRerum Receipt Air Quality Bureau nus uses cent 1'923 5613 525 Camino de Los Marquez, Suite 1 Santa Fe, NM 875054816 Re: Notice of Seal Inspections EFR Tanks 79, 117, 401, 402, 411, 412, 435, 437, 450, 737, 802, 821, 830 and 1225 IFR Tanks 11,12, 56,106,107,108, 109,111,112,124, 415, 417, 439, 451 and 452 Navajo Re?ning LLC Artesia, NW1 Re?nery Agency Interest No. 198 Dear Enforcement Manager: Pursuant to 40 CF as applicable to lGroup 1 storage vessels subject to 40 CFR 63.660 Subpan CC storage vessel provisions), I am providing this advance notice of seal gap measurements to he made by Navajo?s inspection department. For external floating roof (EFR) tanks subject to either NSPS Subpart Ka or Kb, this advance notice also ful?lls the requirements of 40 CFR 60.] or 40 CFR respectively, Seals will be leapected on the following storage vessels as described in the table and text below. The inspection results will he provided to you with the applicable semi-annual periodic report required under 40 CFR . A CT Planned Inspection Planned Inspection Root . scheduled scheduled Tank CC NSPS Primary Seal . Secondary Sea] Type . fox week . fol week Group Inspection? 13 . . Inspection? . . egmning begImnng T-001 1 ER 1 None Measure for gaps 0110020 19 Visunl 031?0512019 T-0012 1 None Not at this time Visual 12? 04! 2019 T-0056 IFR 1 None Not at this time Visual 02K 1 81201 9 EFR Ka Not at this time Measure for gaps 013281?20] 9 EFR 1 Kb Measure for gaps 0380:9019 Measure for gaps 02/04f2019 IFR 1 None Not at this time Visual 071232019 T-0107 1 None Measure for gaps 07/22/2019 Visual 07f22l2019 T-0108 1 None Not at this time Visual 05t27l?20 9 T-0109 1 None Not at this time Visual 02! 1 803019 T?0l 11 IFR 1 None Not at this time Visual 02f25f2019 T-0112 1 None Not at this time Visual 0811219019 T-0117 EFR 1 None Not at this time Measure for gaps 02? 112019 TFR 1 Kat Not at this time Visual 0412210019 EFR Ka Not at this time Measure for gaps 0802:5101 9 EFR I-ia Not at this time Measure for gaps 03/11/2019 T-04ll EFR 1 None Not at this time Measure for gaps 090 629019 Navajo Re?ning LLC 501 East Main . Artesia, NM 88210 [575) 748-3311 http:wawho?vfrontiercom EPA Inspection Report - Page 231 of 1969 Notice of Seal Inspections December 12, 2013 Page 2 TM 1 2 EFR 1 None Not at this time Measure for gaps {1611712019 TFR 1 None Not at this time Visual 0212512019 113R 1 None Not at this time Visual 0210419019 T-0435 EFF. 1 Kb Not at this time Measure for ggp_s [191? 1 6126 1 9 EFR 1 Not at this time Measure for gaps 11211112019 141439 IFR 1 Ka Not at this time Visual EFR 1 Kb Not at this time Measure for gaps {15106111019 2 None Not at this time Visual {14/1 51220 1 9 2 Kb Not at this time Visual 0310512019 EFR 1 Kb Measure for gaps [1312512019 Measure for gaps (1119812019 T-DSDZ EFR 1 Kb Measure for gaps {17l15l2019 Measure for gaps 0211112019 EFR 1 Kb Not at this time Measure for gaps [1512012111 9 T418311 EFR 1 Kb Measure for gaps (171291201 9 Measure for gaps 06l03f21119 4225 EFR 1 Kb Not at this time Measure for gaps 0112112019 Seal gaps, if any, will be measured as required for Group 1 (EFR) storage vessels subject to 40 CFR 63.646 (Refinery MACT I storage vessel provisions), which references the requirements of 40 CFR 63.1 19 and 120- For EFR tanks, requires measurement of the gap between the vessel wall and the primary sea] at least once evely five years and requires measurement of the gap between the vessel wall and the secondary seal every year. The total seal gap surface area, if any. will be calculated in accordance with the provisions off-ll} CFR Although advance noti?cation is not required. please note that the visual seal inspection for the 113R tanks listed will be done during the same week. Visual inspections will be performed as required for Group 1 internal ?oating roof storage vessels subject to 40 CFR 63.646, which references the requirements of 40 CFR 63.119 and 120. For tanks. requires visual inspection of the primary seal at least once every ten years and requires visual inspection of the secondary seal every year. One or more of the tanks to be inspected may require fresh air packs for safe access. If you plan to observe the seal gap measurements for such tanks, please bring appropriate equipment and certi?ed personnel. Please call me at {5751 746-5487 or Ray Smalts at (575] 476-5490 if you have any questions. Sincerely, Scott M. Danton Environmental Manager Navajo Re?ning LLC PO. Box 159 Artesia. New Mexico 3821 1-0159 Phone: (575} 746-5487 E-mai]: Electronic cc: Navajo: P. Miller. B. Rominc. A. Kerr. 0. Dominguez. K. Newton. R. Smalls Envinmmental File: 2.6.4 $261342- 12112111 8-12?12 Anesia Notice of Seal Inspectionspdi? Navajo Re?ning LLC Sill East Main - Artesia, NM 83210 (575) 748-3311 - EPA Inspection Report - Page 232 of 1969 September 29. 2016 Enforcement Manager Air Quality Bureau - Enforcement Certi?ed MaillRetnrn Receipt NM Environment Department 7014 3490 {1000 6269 6021 525 Carnino de los Marquez, Suite 1 Santa Fe, New Mexico 87505-1316 Re: Navajo Re?ning Company. L.L.C. Artesia, NM Re?nery Title Operating Permits PDSI-RZMI Annual Compliance Certification Agency Interest No. 198 Reporting Period September 1. 2015 through August 31, 2016 On behalf of Navajo Re?ning Company: L.L.C. (Navajo). 1 am submitting Navajo's annual compliance certification for the Artesia. NM Re?nery. Title Operating Permit Reporting Period: September 1: 2015 through January 21, 2016 Title Operating Permit 1 Reporting Period: January 22, 2016 through August 31, 2016 Consistent with the initial compliance certification. items identified during work practices. such as thgitive component monitoring inspections. that are corrected or repaired within the regulatory time?'ame and that are properly documented, do not comprise exceptions or deviations. Please feel free to contact me at {575'} 746-48? or Ray Smalts at {575} 7413-5490 if you have any questions or should require any further information. Sincerely, Scott M. Demon Enviromnental Manager Navajo Re?ning Company, P.O. Box l59 Artesia, New Mexico 38211?0159 Phone: {575} ?46-5487 E-mail: Enclosure cc: US EPA (wtencl: Chief. Air Permits. LLS. EPA Region 1445 Ross avenue. Suite [211111 Dallas. TX 75202?2733 Navain: R, O?Brien, R. Beans, S. Danton? ti. Combs, R. Smalts. A. IL?nntreras.1 S. Hammond Environmental Filc: Environmental Driver'litle Certi?entionrArtesia Certi?cation:?2tllti Anesia Artesia Title Annual Compliance Ccrti?cationndf Navajo Re?ning LLC 501 East Main - Artesia, NM 83211] (575) 743-3311 - EPA Inspection Report - Page 23318]: 19 CW Version 05.02.13 NMED USE ONLY 9 (lVIexico Environment Department Air Quality Bureau Compliance and Enforcement Section 525 Camino de los Marquez, Suite 1 Santa Fe, NM 87505 Phone (505) 476-4300 Fax (505) 476?4375 NMED USE ONLY TEMPO REPORTING SUBMITTAL FORM Staff Admin PLEASE NOTE: - Indicates required field SECTION I - GENERAL COMPANY AND FACILITY INFORMATION A. Company Name: D. Facility Name: Navajo Refining Company, L.L.C. Navajo Refining Company, L.L.C. B.1 Company Address: E.1 Facility Address: PO Box 159 501 E.Main St. 82 City: B.3 State: B.4 Zip: E.2 City: E.3 State: E.4 Zip: Artesia NM 88211-0159L Artesia NM 88210 C.1 Company Environmental Contact: C.2 Title: F.1 Facility Contact: F.2 Title: Scott Denton Environmental Manager Scott Denton Environmental Manager C.3 Phone Number: 575?746?5487 C.4 Fax Number: 575-746?5451 F.3 Phone Number: 575-746?5487 F.4 Fax Number: 575?746?5451 C.5 Email Address: F.5 Email Address: G. Responsible Official: (Title only): H. Title: Robert K. O?Brien Vice President Refinery Manager, Navajo Refining I. Phone Number: 575?748-3311 J. Fax Number: 575?746-5451 Company L.L.C. K. AI Number: L. Title Permit Number: M. Title VPermit Issue Date: N. NSR Permit Number: 0. NSR Permit Issue Date: 198 05/06/2015 05/06/2014 01/22/2016 08/12/2016 P. Reporting Period: From 09/01/2015 To 01/21/2016 01/22/2016 08/31/2016 SECTION II TYPE OF SUBMITTAL (check one that applies) A Title Annual Compliance Permit Condition(s): Description: Certification A109 Annual Compliance Certification El Titje Semi-annual Permit Condition(s): Description: Monitoring Report Regulation: Section(s): Description: El NSPS Requnrement (4OCFR60) Regulation: Section(s): Description: MACT Requrrement (4OCFR63) NMAC Requirement Regulation: Section(s): Description: E. (20.2.xx) or NESHAP Requirement (4OCFR61) Permit or NOI Condition(s): Description: Permit or Notice of Intent (NOI) Requirement NOV No. or SFO No. Section(s): Description: Re uirement of an . . Action or CD EL orOther SECTION IV - CERTIFICATION After reasonable inquiry, I Robert K. O'Brien (name of reporting official) certify that the information in this submittal is true, accurate and complete. Sign ture of Reporting Official: fl Title: Date Vice President Refinery Manager, Navajo Refining 09/29/2016 Company L.L.C Responsible Official for Title Yes No Reviewed By: Date Reviewed: EPA Inspection Report - Page 234 of 1969 Title Report Certi?cation Form I Annual Compliance Certi?cation Semi?Annual Monitoring Report Other Specif Facility Name: Artesia Re?nery Facility Address: PO Box 159, Artesia State: NM Zip: 88211-0159 Of?CIaMmyRObe? Phone: 575-748-3311 Fax: 575-746?5421 RO Title: Vice?President Re?nery Manager, Navajo Re?ning Co. L.L.C. Permit No.: Date Permit Issued: 05/06/2015 Report Due Date (as required by the 0/2016 Time period covered by this Report: From: 09/01/2015 To: 01/21/2016 RO e-mail: Permit Al number: 0198 I am the Responsible Of?cial indicated above. 1, Robert K. O?Brien, certify that I meet the requirements of 20.2.70.7.AD NMAC. I certify that, based on information and belief formed after reasonable inquiry, the statements and information contained in the attached Title report are true, accurate, and complete. 56/? 0 ff ,0 Signature 1&4: . i A Date: EPA Inspection Report - Page 235 of 1969 Title Report Certi?cation Form I Annual Compliance Certi?cation El Semi-Annual Monitoring Report 9 He fy Facility Name: Artesia Re?nery Facility Address: PO Box 159, Artesia State: NM Zip: 88211-0159 $1323:le Phone: 575-748-3311 Fax: 575?746-5421 RO Title: Vice-President Re?nery Manager, Navajo Re?ning Co. L.L.C. Permit No.2 P051 -R2M1 Date Permit Issued: 01/22/2016 Report Due Date (as required by the Time period covered by this Report: From: 01/22/2016 To: 08/31/2016 RO e-mail: Permit Al number: 0198 I am the Responsible Of?cial indicated above. 1, Robert K. O?Brien, certify that I meet the requirements of 20.2.70.7.AD NMAC. I certify that, based on information and belief formed after reasonable inquiry, the statements and information contained in the attached Title report are true, accurate, and complete. Signature y/ 0M Date: 9/29/2016 EPA Inspection Report - Page 236 of 1969 Title Annual Compliance Certi?cation for Permit R2M1 Title (TV) Permit Administration Amendment On January 22, 2016 NMED AQB issued an Administrative Amendment to Operating Permit P052-R2. The Administrative Amendment P051-R2M1 corrected the following: The Department acknowledges the Owner/Permittee name change from Navajo Re?ning Company, L.L.C. to Navajo Re?ning LLC. For this is an Administrative Amendment (P051-R2M1), the facility can use one Annual Compliance Certi?cation (ACC) Form which will cover both TV Permits. Although the facility is only required to submit one ACC Form, the facility shall submit two (2) separate TV Report Certi?cation Forms. Each form shall list the corresponding TV Permit number, TV Permit Issue Date and Reporting Period. Please note that this is a one-time authorization. Submittal forms for future Administrative Revisions will be evaluated on a case by case basis. This form can also be used for future submittal that cover only the P051-R2M1 permit. EPA Inspection Report - Page 237 of 1969 Part 1 - Permit Requirements Certi?cation Table 1. Permit Condition and Permit Condition: 2. Method(s)or other information orother facts used to 3 4: ?WaS?thISfaCIhln 5.2Werethere any determine the compliance status: frequency of data compliance with'this deviatiOns associated collection used to requirementduring the with this requirement determine reporting period? during the repOrting compliance? period? I FACILITY SPECIFIC '3 Continuous Yes Yes REQUIREMENTS Intermittent No No A101 Permit Duration (expirationThe term 0 this permi is ?ve (5) avaJo su m1 te tie app11cat10n for renewal on September 11, 2013. years. It W111 expire ?ve years from the date of issuance. Application for renewal of this permit is due twelve (12) months prior to the date of expiration. (202.70.300.32 and 302B NMAC) A101 Permit Duration (expiration) 1:1 Continuous Yes 1:1 Yes B. If a renewal permit is not issued prior Intermittent No to the ex iration date the ermittee ma . . . . . Navajo submitted the application for renewal on continue to operate beyond the expiratlon . eptember 11, 2013. date, prov1ded that a timely and complete renewal application is submitted no later than twelve (12) months prior to the expiration date. (20.2.70.400.D NMAC) A102 Facility: Description 1:1 Continuous Yes Yes . . . . . . . . This is the location of Nava'o re?ne . - B. This fac111ty is located in the c1ty11m1ts ry Intermittent No of Artesia, NM. Thispermit condition provides a list of theapplicable E1 Continuous Yes E1 Yes A103 Facility: Applicable Regulations requirements that are addressed in detail in other . . permit conditions but does not impose any speci?c Intermittent No No A- The permittee shall comply all standards, monitoring, recordkeeping, or reporting applicable sections of the requirements requirements. Therefore, no further response is listed in Table required. As instructed by the AQB, Navajo is completing the check box responses in columns 3, 4, EPA Inspection Report - Page 238 of 1969 Version 02.25.15 1. Permit Condition and Permit COndition: 2. Method(s) or other information or other facts used to determine the cOmpliance status: 3. What is? the frequency of data collection used to determine compliance? 4. Was this facility in compliance with this requirement during the reporting period? 5. Were there any deVia?tions associated with this requirement during the reporting period? and 5 of this form. Navajo continues to comply with all applicable requirements except for speci?c deviations as noted elsewhere in this document. (See the speci?c responses to the permit conditions that contain standards, monitoring, recordkeeping, or reporting requirements for more information). ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 3 of 144 EPA Inspection Report - Page 239 of 1969 Version 02.25.15 Table 103.A: Applicable Requirements Federally Applicable Requirements En forceable Unit No. NSR Permit No: PSD 0195 (Per 20.2.72 NMAC) Entire Facility 20.2.1 NMAC General Provisions Entire Facility 20.2.7 NMAC Excess Emissions Entire Facility . . . . . Affected sources 20.2.33 NMAC Gas Burning Equipment Nitrogen Diox1de in Table 103.13 20.2.36 NMAC Petroleum Re?nery - Sulfur Entire Facility 20.2.37 NMAC Petroleum Processing Facilities Entire Facility 20.2.38 NMAC Hydrocarbon Storage Facilities Entire Facility 20.2.70 NMAC Operating Permits Entire Facility 20.2.71 NMAC Operating Permit Emission Fees Entire Facility 20.2.72 NMAC Construction Permit Entire Facility 20.2.73 NMAC Notlce of Intent and Inventory Entire Facility Requirements 20.2.74 NMAC Prevention of Signi?cant Deterioration Entire Facility Units sub'ect to 20.2.77 NMAC New Source Performance 40 CFR 6JO 20.2.78 NMAC Emission Standards for Hazardous Air Pollutants Units subject to (HAPS) 40 CFR 61 . Units sub'ect to 20.2.82 NMAC MACT Standards for Source Categories of HAPS 40 CFR 6J3 40 CF 50 National Ambient Air Quality Standards Entire Facility 40 CFR 60, Subpart A, General Provisions f8: 40 CF 60, Subpart Db ?Standards of Performance for Industrial? See Tables Commercial?Institutional Steam Generating Units? 103B to 103.J 40 CF 60, Subpart Dc ?Standards of Performance for Small Steam Generating Units, Which H-3101 Construction, Reconstruction, or Modi?cation Commenced After June 9, 1989? 40 CF 60, Subpart J, ?Standards of Performance for Petroleum See Tables Re?neries? 103B to 103.] 40 CFR 60, Subpart Ja, ?Standards of Performance for Petroleum See Tables Re?neries for which Construction, Reconstruction, or Modi?cation 103B to 103,] Commenced After May 14, 2007? ACC Fonn Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 4 of 144 EPA Inspection Report - Page 240 of 1969 Version 02.25.15 40 CFR 60, Subpart K, ?Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modi?cation Commenced After June 1 1, 1973, and Prior to May 19, 1978? See Tables 103B to 103.J 40 CFR 60, Subpart Ka, ?Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modi?cation Commenced After May 18, 1978, and Prior to July 23, 1984? See Tables 1033 to 103k 40 CFR 60, Subpart Kb, ?Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modi?cation Commenced After January 23, 1984? See Tables 103.B to 103K 40 CFR 60, Subpart Standards of Performance for Equipment Leaks of VOC in Petroleum Re?neries for which construction, reconstruction, or modi?cation commenced after January 4, 1983, and on or before November 7, 2006. See Tables 1033 to 103K 40 CFR 60, Subpart Standards of Performance for Equipment Leaks of VOC in Petroleum Re?neries for which construction, reconstruction, or modi?cation commenced after November 7, 2006. See Tables 1033 to 103K 40 CFR 60, Subpart Standards of Performance for VOC See Tables Emissions From Petroleum Re?nery Wastewater Systems 1033 to 103K 40 CFR 60, Subpart Standards of Performance for_Stationary See Tables Compression Ignition Internal Combustion Engines 103.B to 103K 40 CFR 61, Subpart A, General Provisions Entire Facility 40 CFR 61, Subpart FF, National Emission Standards for Benzene Benzene Waste Waste Operations Operations 40 CFR 63, Subpart A, General Provisions Entire Facility 40 CFR 63, Subpart Q, National Emission Standards for Hazardous See Table Air Pollutants for Industrial Process Cooling Towers 1031:. See Tables 40 CFR 63, Subpart CC 1033 to 103K See Tables 40 CFR 63 Subpart 1033 to 103K See Tables 40 CFR 63 Subpart Petroleum Re?neries: Catalytic 103 Units, Catalytic Reforming Units, and Sulfur Recovery Units 103 IO 0 ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 5 of 144 EPA Inspection Report - Page 241 of 1969 Version 02.25.15 Ver 4.1 02/25/2015 40 CFR 63, Subpart National Emission Standards for See Tables Hazardous Air Pollutants for Stationary Reciprocating Internal t0 Combustion Engines 103-KJ 40 CFR 68, (RMP), Section 112(r) Accidental Release Entire Facility Consent Decree CIV-01 1422LH Lodged 12/20/2001, Entered . . . Entire FaCility 3/5/2002 Table 103B Summary Applicability?Fugitives Title Permit Description 20.2.37 MACT NSPS NSPS NSPS NESHAP NESHAP NAV-1195- Unit 1D CC CC CRUDE South Division Crude Unit YES YES No YES YES No NO NO FUG-OS-KERO Kerosene HDS Unit .IP8 Hydrodesulfurization AMIN Amine Unit?Treating/RegenYES Sour Water Stripper YES FUG-OB-TRUCK RK Loading Racks ALKY North Alkylation Unit (New-Inside battery limitsNaphtha HDS Unit YES YES YES NO YES NO No NO 8-LSR MEROX TRT Merox/Merichem Treating Units Powerformer/Penex Unit FUG-21-SP VACUUM Flasher/Vacuum Unit ROSE Unit YES YES NO YES YES No No NO FARM Light Oil Tankage SRU3 Unit YES YES NO YES YES NO No NO HDU Relocated Diesel HDS Unit YES YES YES NO YES NO NO NO FUG-34HYDROCRACKER WX Hydrocracker YES YES No YES YES No No NO FUG-35-SAT GAS Saturates Gas Plant PBC Unit FUG-43-S ALKY South Alky Unit (W-76Gas Oil Hydrotreater (incl. CVSACC Form Part 1 Permit P051-R2 R2M1 Page 6 of 144 EPA Inspection Report - Page 242 of 1969 Version 02.25.15 between railcars and trucks. FUG-45-DIST-HDU Gas Oil Hydrotreater (incl. CVSHydrogen Plant FUG-64-H2 Hydrogen Plant FUG-70-CCR CCR Reformer (w/in battery limitsUTIL Utilities FUG-80-WWTP CVS Oil/Water Separator YES YES YES NO YES NO NO YES PUG-ASPHALT STG Asphalt/Heavy Oil Storage GAS Fuel Gas Distribution System FUG-LPG LPG Storage System YES FUG-RLO-ASPHALT Asphalt/Pitch loading Rack YES Crude oil unloading system, closed loop system NO NO 0 YES NO NO ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 7 of 144 EPA Inspection Report - Page 243 of 1969 Version 02.25.15 Table 103.C, Summary Applicability - Tanks MACT NSPS NSPS NSPS CC MACT CC NESHAP NSPS 20.2.37.205 20.2.38.109 20.2.38.110 20.2.38.112 20.2.38.113 CA Tank No. Ka Kb Storage Wastewater FF NMAC NMAC NMAC NMAC NMAC T-0001 T-0002 T-0003 T-0012 T-T-0026 T-0028 T-0040 T-0041 T-0042 T-005 T-0056 T-0057 T-0061 T0064 T-0065 T-0072 T-0074 T-008 ACC Form Part 1 Permit P05 l?R2 R2M1 Page 8 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 244 of 1969 Version 02.25.15 T-OO8 T-0124 T-O4OO T-O402 T-O404 T-O409 T-O410 T-T-O415 T-041 T-T-O423 T-O43 T-O43 T-O43 T-O43 T-O43 T-O447 ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 9 of 144 EPA Inspection Report - Page 245 of 1969 Version 02.25.T-0460 T0465 T-0467 T-0802 T-0807 T-0834 T-0835 T-083 T-0839 T-0840 1222 T-1223 1224 T-1225 BioDiesel Ethanol ACC Form Part 1 Permit P051-R2 R2M1 Page 10 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 246 of 1969 Version 02.25.15 Table 103.D, Summary Applicability Unit ID Description MACT CC 20.2.37.205.C MACT MACT CAM Fuels Truck Loading Rack YES NO NO NO NO TL-7 Truck Loading Rack NO NO NO NO NO RLO-8 Railear Loading Off?Loading Rack NO NO NO NO NO Table 103E, Summary Applicability - Heaters and Boilers . . . NSPS NSPS NSPS MACT 20.2.33.108 20.2.36 20.2.37 Unit ID Db Dc NSPS NSPS CAM B0007 Boiler B-0008 Boiler B-0009 Boiler H-0009 13 Naphtha 8pmRebo?er H-0011 Umt 2 2:311H-0018 Unit 06 HDS Reboiler somh ESiZICharge H-0020 somh (fir::[:rCharge H-0028 Unit 21 Heater H-Unit 06 Charge Heater Unit 13 Charge Heater Unit 05 Charge Heater Unit 10 FCC Feed Heater Egieljefomer H-0353 Umt 7O ggielfefomer ?giefefomer Stablhzer RebOller Heater Unit 70 CCR Heater Unit 70 CCR Heater ACC Form Part 1 Permit R2M1 Ver 4.102/25/2015 Page 11 of 144 EPA Inspection Report - Page 247 of 1969 Version 02.25.15 H-03 64 Unit 70 CCR Heater H-0421 Unit 44 Charge Heater H-0464 SRU Hot Oil Heater S.RU1 and .SRU2 Ta11 Gas Incmerator H-0600 Umt 09 Depmpamzer Reb011er Heater Unit 33 Charge Heater H-2421 Unit 45 Charge Heater Hydrogen Plant H-8 802 Reformer Umt 34 HydrocraCker Reb011er 1 H-3403 HydrocraCker ReadCharge Heater Umt 64 Hydrogen Plant Reformer Unit 25 Unit H-2501 No.2 Hot Oil Heater 101 (formerly SRU3 Hot Oil Heater HOH) SRU3-TGI SRU3. Tall Gas Incmerator ACC Fonn Part 1 Pennit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 12 of 144 EPA Inspection Report - Page 248 of 1969 Version 02.25.15 Table 103.F, Summary Applicability Cooling Towers Cooling Tower Description MACT MACT CC CAM Y-0001 TCC Cooling Tower YES YES NO S. Alky Cooling Tower (Marley Cooling YES YES NO Tower) North Alky Cooling Tower YES YES NO FCC NP Cooling Tower NO YES NO Y-0012 Hydrogen Plants Cooling Tower NO YES NO CT Unit 07 Amine W-0745 Cooling Tower NO NO NO Table 103.G, Summary Applicability Wastewater Emission Point MACT CC Equipment ID ID Wastewater ESHAP FF SPS CAM MAIN API YES YES YES T-0801 YES YES NO NO T-0805 YES YES NO NO YES YES NO NO T-0836 YES YES NO NO YES YES NO NO Table 103.H, Summary Applicability FCC-CCR MACT 20.2.37 Unit ID SPS SPS a NMAC CAM CCREGEN YES NO YES YES YES Satis?ed by MACT CCR YES NO ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 13 of 144 EPA Inspection Report - Page 249 of 1969 Version 02.25.15 Table 103.1, Summary Applicability SRU Source Emission NSPS NSPS MACT ID Point ID Description Ja 20.2.37.200B 20.2.37.202.A 20.2.39 CAM SRU1 and SRU2 Tail YES NO YES YES YES YES NO YES?Satis?ed Gas Incinerator by MACT SRU2 and SRU2 Tail YES NO YES YES YES YES NO YES?Satis?ed Gas Incinerator by MACT SRU3 SRU3 Tail Gas YES-Satis?ed Incinerator by MACT Table 103.J, Summary Applicability Engines 20.2.61.109 20.2.61.114 Source ID Description NSPS MACT NMAC NMAC CAM E-0600W Fire Water Pump Engine YES YES YES YES NO E-0601M Fire Water Pump Engine YES YES YES YES NO E-0602E Fire Water Pump Engine YES YES YES YES NO Fire Water Pump Engine YES YES YES YES NO Fire Water Pump Engine YES YES YES YES NO G-0100 UPS backup generator NO YES YES YES NO G-0101 UPS backup generator NO YES YES YES NO V-0543 Portable Air Compressor YES YES YES YES NO Portable Air Compressor YES YES YES YES NO Portable Air Compressor YES YES YES YES NO 0 WWTP Emergency Engine YES YES YES YES NO ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 14 of 144 EPA Inspection Report - Page 250 of 1969 Version 02.25.15 Table 103.K, Summary Ap licability FLARES NESHAP 20.2.36.112 20.2.36.113b 20.2.37.201B Unit ID Description NSPS A NSPS NSPS a A MACT A NMAC NMAC NMAC North Plant Flare YES NO YES NO YES YES YES YES South Plant Flare YES NO YES NO YES YES YES YES FCCU Flare YES NO YES NO YES YES YES YES L-403 Alky Flare YES NO YES NO YES YES YES YES GOHT Flare YES NO YES NO YES YES YES YES A11 ?ares are steam assisted. State of New Mexico requires that an exit gas velocity of 65 ft/sec for modeling. The heating value of the gas for all ?ares is 1000 BTU/scf. This permit condition provides a list of the El Continuous applicable requirements that are addressed in detail A103 Fac1hty: Applicable Regulatlons in other permit conditions but does not impose any IXI Intermittent I:l No IXI No eciflc standards, monitorin recordkee in or Compllance the terms and rgporting requirements. Thergefore, no fuiiheii conditions 0fthi3 permit regarding source response is required. As instructed by the AQB, emissions and Operation demonstrate Navajo is completing the check box responses in compliance with national ambient air columns 3, 4, and 5 of this form. Navajo continues quality standards Speci?ed at 40 CFR 50, to comply with all applicable requirements except which were applicable at the time air for speci?c deviations as noted elsewhere in this dispersion modeling was performed for the document. (See the speci?c responsesito the permit facility? NSR Permit 5. conditions that contain standards, monitoring, recordkeeping, or reporting requirements for more information). This permit condition provides a list but does not Continuous IXI Yes Yes A104 Facility: Regulated Sources impose any standards, monitoring, recordkeeping, or reporting requirements. Therefore, no further IXI Intermittent I:l No IXI No A. Table 104.A lists the emission units response is required. AS instructed by the AQB, authorized for this facility. Emission units Navajo is completing the-Cheek box responses_in identi?ed as insigni?cant 0r trivial columns 3, 4, and 5 of this form. Navajo continues activities (as defined in 20270.7 NMAC) :90 comply .all.apphcable reqmrements. exc?pt . or speCI?c dev1ations as noted elsewhere in this and/0r equ1pment not regulated pursuant to document. (See the specific responses to the permit the Ad are not Included. conditions that contain standards, monitoring, recordkeeping, or reporting requirements for more ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 15 of 144 EPA Inspection Report - Page 251 of 1969 Version 02.25.15 I information). ACC Form Part 1 Permit R2M1 Page 16 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 252 of 1969 Version 02.25.15 Table 104.A: Regulated Sources List Unit No. Unit Type Manufacturer Model No. Mangiztlgure Capacity Boiler 7 Todd/John Zink burners Unknown 10/8/2001 215 MMBtu/hr (LHV Basis) Boiler 8 Todd/John Zink burners Unknown 2003 215 MMBtu/hr (LHV Basis) Boiler 9 Babcock Wilcox TBD TBD 220 MMBtu/hr (LHV Basis) WWTP Diesel Pump Engine John Deere RG6090L101484 2/2011 400 hp 600W Fire Water Pump Engine Clarke Diesel (John Deere) 7/201 2 376 hp Fire Water Pump Engine Clarke Diesel (John Deere) 7/2012 376 hp Fire Water Pump Engine Clarke Diesel (John Deere) 3: 70012 376 hp E-0603 Fire Water Pump Engine Clarke Diesel (John Deere) 2012 305 hp Fire Water Pump Engine Clarke Diesel (John Deere) Egg?23230016118 10/2007 430 hp G-0100 UPS backup generator 0th 5353333510 Eng? Filmy 1998 52 hp G-0101 UPS backup generator Deutz F4L 1011 EI97-68CA00-000-0053 1999 54 hp Portable Air Compressor Cummings, lnc. QSC, 73104611 8/30/2010 260 hp Portable Air Compressor Cummings, Inc. QSC, 73142120 4/8/201 1 260 hp V-0546 Portable Air Compressor Cummings, lnc. QSC, 46917364 1 1/19/2008 240 hp Unit 13 Naphtha Splitter Reboiler Zeeco burners GSFW-12 burners Unknown 44 MMBtu/hr (LHV Basis) H-0011 Unit 21 Vacuum Flasher Heater Unknown Unknown Unknown 38 MMBtu/hr (LHV Basis) H-0018 Naphtha HDS Reboiler Zeeco burners GSFW-8 burners Unknown 32 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-0019 South Crude Charge Heater burners CUBL-8W burners New burners in 2005 54 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-0020 South Crude Charge Heater burners burners New burners in 2005 78 MMBtu/hr (LHV Basis) H-0028 Unit 21 Heater H-28 (previously H-10) John Zink burners burners Unknown 12.3 MMBtu/hr (LHV Basis) H-0030 Unit 06 Charge Heater John Zink burners PSFG-16R burners 2000* 42 MMBtu/hr (LHV Basis) H-0040 Unit 13 Charge Heater John Zink burners PSFG-16 burners 1990* 42 MMBtu/hr (LHV Basis) Unit 05 Charge Heater John Zink burners burners 1982* 11 MMBtu/hr (LHV Basis) Unit 10 FCC Feed Heater John Zink burners burners 1990* 35 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-0352 Unit 70 CCR Heater (previously 70-H1) burners CUBL-10W burners New burners in 2006 63 MMBtu/hr (LHV Basis) Callidus Technologies, LLC Unit 70 CCR Heater (previously 70-H2) burners CUBL-10W burners New burners in 2006 81 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-0354 Unit 70 CCR Heater (previously burners CUBL-10W burners New burners in 2006 56 MMBtu/hr (LHV Basis) Unit 70 Stabilizer Reboiler Heater H-0355 (previously John Zink burners Unknown 1991* 24 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-0362 Unit 70 CCR Heater burners CUBL-8W burners New burners in 2006 40 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-0363 Unit 70 CCR Heater burners CUBL-8W burners New burners in 2006 50 MMBtu/hr (LHV Basis) ACC Fonn Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 17 of 144 EPA Inspection Report - Page 253 of 1969 Version 02.25.15 Callidus Technologies, LLC Unit 70 CCR Heater burners burners New burners in 2006 35 MMBtu/hr (LHV Basis) Unit 44 Charge Heater (previously H-21) John Zink burners burners 1981* 27 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-0464 SRU Hot Oil Heater burners burners 2003* 9.6 MMBtu/hr (LHV Basis) Depropanizer Reboiler Heater (previously Callidus Technologies, LLC 1991*, New burners in burners burners 2009 84 MMBtu/hr (LHV Basis) Callidus Technologies, LLC Unit 33 Charge Heater burners CUB-8P-CW burners New burners in 2003 78 MMBtu/hr (LHV Basis) Round Flame Unit 45 Charge Heater Zeeco, Inc. burners "Free Jet" burners 2006* 27 MMBtu/hr (LHV Basis) Callidus Technologies, LLC Unit 63 Hydrogen Plant Reformer Furnace burners burners 2006* 60 MMBtu/hr (LHV Basis) Callidus Technologies, LLC LE-CSG-12W-PSA Unit 63 Hydrogen Plant Reformer Furnace burners burners 2006* 60 MMBtu/hr (LHV Basis) ROSE2 Hot Oil Heater John Zink Company, LLC burners COOLstar?18 burners 2009* 120 MMBtu/hr (LHV Basis) Callidus Technologies, LLC Hydrocracker Reactor Charge Heater burners CU BL-10W burners TBD 32.0 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-3402 Hydrocracker Fractionator Reboiler 1 burners LE-CSG-12W burners 2009* 52 MMBtu/hr (LHV Basis) Callidus Technologies, LLC Unit 64 Hydrogen Plant Reformer burners CUBL-3WDF burners 2009* 337 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-3101 SRU3 Hot Oil Heater burner Unknown 05/11/2009 9.6 MMBtu/hr (LHV Basis) TGI) SRU1 and SRU2 Tail Gas Incinerator Unknown Unknown Unknown NA Callidus Technologies, LLC . SRU3-TGI SRU3 Tail Gas Incinerator burners Unknown 05/11/2009 NA FCC Regenerator FCC Regenerator Scrubber Unknown Unknown Unknown NA CCR Reformer Unknown Unknown Unknown NA North Plant Flare North Plant Flare Unknown Unknown Unknown NA FL-0401, South Plant Flare South Plant Flare Unknown Unknown Unknown NA FL-0402, FCC Flare FCC Flare Unknown Unknown Unknown NA FL-0403, Alky Flare Alky Flare Unknown Unknown Unknown NA FL-0404, GOHT Flare GOHT Flare Unknown Unknown Unknown NA TCC Cooling Tower Unknown Unknown Unknown 5,000 gpm, 0.003% drift 8. Alky Cooling Tower (Marley Cooling Y.0002 Tower) Unknown Unknown Unknown 5,000 gpm, 0.003% drift North Alky Cooling Tower Unknown Unknown Unknown 12,500 gpm, 0.003% drift Y-0011 FCC NP Cooling Tower Unknown Unknown Unknown 30,000 gpm, 0.001% drift Hydrogen Plants Cooling Tower Unknown Unknown Unknown 10,000 gpm, 0.001 drift CT TT-0006 Unit 07 Amine Cooling Tower Unknown Unknown Unknown 3,000 gpm, 0.003% drift MAIN API Above Ground API Oil-Water Separator Unknown Unknown Unknown 1,200 T40896 DAF Unit T-0896 Unknown Unknown Unknown 1,200 Enhanced Biodegradation Tank Unknown Unknown Unknown 1,200 T-0836 Enhanced Biodegradation Tank T-0836 Unknown Unknown Unknown 1,200 Equalization Tank T-0829 Not yet installed Not yet installed Not yet installed 1,200 T-0806 DAF Unit T-0806 Not yet installed Not yet installed Not yet installed Not yet installed Equipment component leaks (pump seals, Fugitives (see Table 1038) valves, flanges, etc.) NA NA Varies NA Loading (see Table 103.D) Bulk Loading/Unloading Racks NA NA Varies Varies Fixed Roof, External Floating Roof Tanks (see Table 103.C) Internal Floating Roof Tanks NA NA Varies Varies Installation date ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 18 of 144 EPA Inspection Report - Page 254 of 1969 Version 02.25.15 Note: Serial numbers are not used since most equipment consists of ?eld erected parts that are assembled on site and may have several ?serial numbers? for various components. Heaters are the best example because each of the burners has a serial number but the heater as a whole does not have a single serial number. The heater as a whole is typically identi?ed by our equipment number. There may also be a ?project number? or ?job number? from the manufacturer, but that can change if a heater is revamped at a later date such as when they modify the convection section to improve energy ef?ciency. A105 Facility: Control Methods A. Table 105A lists all the pollution control equipment required for this facility. Each emission point is identi?ed by the same number that was assigned to it in the permit application. This permit condition provides a list but does not impose any standards, monitoring, recordkeeping, or reporting requirements. Therefore, no further response is required. As instructed by the AQB, Navajo is completing the check box responses in columns 3, 4, and 5 of this form. Navajo continues to comply with all applicable requirements except for speci?c deviations as noted elsewhere in this document. (See the speci?c responses to the permit conditions that contain standards, monitoring, recordkeeping, or reporting requirements for more information). Continuous IXI Intermittent IXI Yes No Yes IXI N0 Table 105.A: Control Methods: Control . . . BACT Pollutant being Control for Equlpment Unlt Control Descriptlon Unlt Yes or No controlled 1 No. Number(s) Fluid Catalytic FCC Regenerator Cracking Unit FCC Scrubber Regenerator Cyclones NO PM SOZ Regenerator Wet Gas Scrubber CCR CHLOR CCR Regenerator Vent NO Chloride Regenerator Control Vent Re?nery North Plant Flare NO VOC HZS . process un1ts ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 19 of 144 EPA Inspection Report - Version 02.25.15 Page 255 of 1969 FL-O401 South Plant Flare NO voc st RC?nery . process un1ts Re?nery FCC Flare NO VOC H2S . process units Re?nery Alky Flare NO VOC . process units GOH Flare NO voc st Re?nery . process units Portable Flare for Holly Pipeline Energy Palm?? (HEP) NO voc Pigging P1peline . . Operations peratlons Sulfur Recovery Units H-O473 No. 1 2 Tail Gas No Sulfur and . SRU2 Incmerator Selective Catalytic SCR Reduction ultra-low YES NOX burners Sulfur Recovery Unit No. 3 Tail Gas YES Sulfur SRU3 Incinerator Best Work Practices, A207.B (B A CT) YES SOZ SRU3 M3111 API carbon No voc MAIN API Canlsters Drift Eliminators on Y-0011, Y-0012 Cooling Towers YES PM 1? (BACT) ACC Form Part 1 Permit P051 Ver 4.1 02/25/2015 MMI Page 20 of 144 EPA Inspection Report - Page 256 of 1969 Version 02.25.15 External Floating Roofs T-0737, T-l225 (BACT) YES VOC T-0737, T?l225 External and Internal See Tables Wm Floating Roofs (None? No voc and BACT) (2) Energy Ef?ciency, B-0009 A20 4.N (B ACT) Yes Greenhouse Gases H-2501, H-3402, ultra-low burners Ye Ox H-2501, H- 3101 (BACT) 3402, Combust gaseous fuels Yes C, PM 2501? H-3402, H-3402, H-3101 only 3101 1 Control for unit number refers to a unit number from the Regulated Equipment List B. In accordance With the requirement that Navajo Re?ning prevent exceedances of the 24?hour and 3?hour National Ambient Air Quality Standards (NAAQS) for 802 during major re?nery malfunctions, Navajo Re?ning shall only ?are acid gas from existing Flare FL-0403 according to Navajo Re?ning's "Phase Two" plan dated January 5, 1996 and received by the Department on January 8, 1996, or from Flare 0400. Navajo shall undertake the following measures for acid gas ?aring from and FL-0403. A RT O. 1 SUPP FUEL FOR 302 NAAQS COMPLIANCE, FL-400 90.0 800 270.0 60.0 a 50.0 0 400 U) 3 30.0 20.0 10Supp Fuel Gas Flow (1) Existing Flare shall be equipped With a ?are tip or burners to supply supplemental fuel gas to provide enough heat to supplement the ACC Form Part 1 Permit Page 21 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 257 of 1969 Version 02.25.15 heat released by combustion of the acid gas itself and the heat provided by smoke?suppressing steam. The minimum ?ow rate of supplemental fuel gas to be supplied during acid gas ?aring such that compliance with the NAAQS for $02 is assured shall be determined using Chart No. 1. The fuel gas used for this purpose shall be natural gas (see de?nition at C101 .F). (2) Existing Flare shall be equipped with a ?are tip or burners to supply supplemental fuel gas to provide enough supplemental heat. The volume of supplemental fuel gas to be provided to generate enough supplemental heat to ensure compliance with NAAQS for 802 shall be determined using Chart No. 2. The supplemental heat to be provided when ?aring the maximum quantity of acid gas has been determined to be 52.9 million BTU per hour which is generated by burning 96,200 SCFH of supplemental fuel gas. This assumption has been made to ensure compliance with the NAAQS for 802. The fuel gas used for this purpose shall be natural gas (see de?nition at C101.F). CHART NO. 2 SUPP. FUEL FOR 802 NAAQS COMPLIANCE, 4o 4 Supp. Fuel Gas Acid Gas Flow (Thousand SCFH100 Supp. Fuel Gas (Thousand SCFH) C. Beginning December 20, 2001 no fuel oil shall be burned in combustion units except as follows: (CD 1117C) Torch Oil may be burned in the FCC Regenerator during FCC start-ups; and. (2) Fuel Oil may be burned in combustion units after the establishment of FCC emissions limits pursuant to permit condition A110.A, provided that emissions from any such combustion units are routed through the FCC Wet Gas Scrubber and Navajo demonstrates, with the approval of EPA, that the emissions limits contained therein and the 802 emissions limits stated in A106.A and A107.A will continue to be met. D. The Artesia Re?nery FCC was initially limited to less than 20,000 BPD capacity. Following the December 2003 expansion of the Artesia re?nery?s FCC as authorized by permit l95-M15, the catalyst regenerator for the FCC is subject to the minimum requirements for continuous emission monitoring and recording set forth in Appendix to 40 CFR Part 51. Consent Decree Paragraph 15 required the FCC to be subject to NSPS Subpart for opacity as of December 31, 2003. A wet gas scrubber was installed in 2003. An Alternative Monitoring Plan (AMP) request was submitted to EPA on December 31, 2003 because a continuous opacity monitoring system (COMS) will not work on a wet gas scrubber exhaust because of the interference from the water vapor. The AMP satis?es the requirements for both NSPS Subpart and 40 CFR Part 51 Appendix ACC Form Part 1 Permit R2M1 Page 22 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 258 of 1969 Version 02.25.15 A106 Facility: Allowable Emissions 1:1 Continuous Yes 1:1 Yes A. The following Section lists the emission Nam? commas to comply Wlih all 313,131} cable Intermittent em1ss1on 11m1ts except for spec1?c dev1at10ns as umts, and the1r allowable em1ss1on 11m1ts. . (See Table 103 . A for all applicable noted elsewhere 1n document and events . reported per 20.2.7 NMAC. regulat1ons) Table 106.A: Allowable Emissions soZ CO 4PM VOC 3.5MM Btu/hr 5(lb/MM Btu Source ID 5 (lb/hr) (ton/yr) 5(lb/hr) (ton/yr) 5(lb/MM Btu) 5(lb/hr) (ton/yr) LHV) (lb/hr) (ton/yr) 5(lb/hr) (ton/yr) 215 7.8 12.7 12.9 56.5 0.06 19.6 85.7 1.8 7.8 1.3 5.6 B-0008 215 7.8 12.7 12.9 56.5 0.06 19.6 85.7 1.8 7.8 1.3 5.6 220 2.6 11.4 4.4 19.3 0.02 BACT 8.1 35.7 1.6 7.2 0.9 3.9 H-0009 44 1.6 2.6 4.0 17.3 0.09 4.0 17.5 0.4 1.6 0.3 1.2 H-0011 38 1.4 2.3 9.5 31.6 3.5 15.2 0.3 1.4 0.2 1.0 32 1.2 1.9 3.5 15.2 2.9 12.8 0.3 1.2 0.2 0.8 54 2.0 3.2 2.9 12.5 0.0527 4.9 21.5 0.4 2.0 0.3 1.4 78 2.8 4.6 4.2 18.3 0.0535 7.1 31.1 0.6 2.8 0.5 2.0 H-0028 121.5 2.5 3.2 14.0 3.8 16.8 0.4 1.5 0.3 1.1 H-0040 42 1.5 2.5 3.8 16.6 3.8 16.8 0.4 1.5 0.3 1.1 63/81/56 0352/0353/0354 7.3 11.8 9.0 39.4 0.045 18.2 79.7 1.7 7.2 1.2 5.2 24 0.9 1.4 2.2 9.5 2.2 9.6 0.2 0.9 0.1 0.6 H-0303 11 0.4 0.7 1.2 5.2 1.0 4.4 0.1 0.4 0.1 0.3 H?03l2 35 1.3 2.1 4.6 20.2 3.2 14.0 0.3 1.3 0.2 0.9 40/50/35 0362/0363/0364 4.6 7.4 6.9 30.1 0.055 11.4 49.8 1.0 4.5 0.7 3.3 27 1.0 1.6 2.4 10.6 0.09 2.5 10.8 0.2 1.0 0.2 0.7 9.6 0.4 0.6 0.5 2.3 0.9 3.8 0.1 0.4 0.1 0.3 H-0600 84 3.1 5.0 4.7 20.3 0.05 7.6 33.5 0.7 3.03 0.5 2.2 H-0601 78 2.8 4.6 3.5 15.4 0.045 7.1 31.1 0.6 2.8 0.5 2.0 H-2421 27 1.0 1.6 1.2 5.3 0.045 2.5 10.8 0.2 1.0 0.2 0.7 60/60 0.2 0.8 4.2 18.4 0.035 10.9 47.8 1.0 4.3 0.7 3.1 120 4.4 7.1 3.6 15.8 0.03 7.2 31.5 0.09 BACT 1.0 4.3 0.7 3.1 52 1.9 3.1 1.6 6.8 0.03 4.7 20.7 0.09 BACT 0.4 1.9 0.3 1.4 ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 23 of 144 EPA Inspection Report - Page 259 of 1969 Version 02.25.15 32.0 1.2 1.9 1.0 4.2 0.03 2.9 12.8 0.3 1.2 0.2 0.8 0.0125 H-985l 337 0.5 2.2 4.2 18.5 BACT 20.2 88.6 0.06 BACT 2.8 12.2 2.0 8.8 H-3101 9.6 0.4 0.6 0.3 1.3 0.03 0.9 3.8 0.09 BACT 0.1 0.4 0.1 0.3 H-0473 NA 30.0 81.8 6.5 28.5 27.7 121.2 0.5 2.2 0.1 0.6 TGI) SRU3-TGI NA 30.0 81.8 6.5 28.5 15.0 65.7 0.5 2.2 0.1 0.6 FCC Regenerator NA 27.9 61.0 35.0 101.9 121.9 106.8 25.0 109.5 - North NA 0.2 0.5 0.2 0.8 1.0 4.3 0.0 0.0 0.2 0.7 Plant Flare NA 0.1 0.1 <0.1 0.2 0.2 1.1 0.0 0.0 <0.1 0.2 Plant Flare 4 Flar: 02? CC NA 0.1 0.1 <0.1 0.2 0.2 1.1 0.0 0.0 <0.1 0.2 FL- 4 A Flar: 03? lky NA <0.1 <0.1 <0.1 <0.1 <0.1 0.2 0.0 0.0 <0.1 <0.1 4 4 OHT A Flarg 2.4 10.5 4.1 18.1 13.6 59.6 0.0 0.0 2.3 10.2 Subtotal 345.4 668.8 1156.2 196.0 70.2 Tanks, Table 106E 322.4 Fugitives, Table 106.F 994.6 Misc Sources, Table 106G 16'6 Cooling Towers, Table 106.H 2.5 9.0 56.2 Oil/Water Separators, Table 5.3 9.5 106.1 6SSM, Table 107 27.4 31.6 97.6 0.4 46.2 TOTAL 1 NA 372.8 700.4 1256.3 205.3 1515.7 1 Totals are for information and are not enforceable conditions. 2 Nitrogen dioxide emissions include all oxides of nitrogen expressed as N02 3 lbs?NOx/MMBtu of heat input, calculated as a 3?hour average, when ?ring natural gas at 3% stack oxygen at full design load without air preheat. 4 All Particulate Matter emitted is assumed to be of aerodynamic diameter 10 microns or less. 5 Hourly emission limits and lb/MM Btu limits are based on a hourly rolling 3-hour average. 6 Maximum allowable emissions during maintenance, startup, or shutdown (SSM) and malfunction activities. indicates that in accordance with the application, emissions of this pollutant are not expected. indicates that the emissions are less than 1.0 or 1.0 tpy and emission limits are not required for this permit, unless it?s for a control device. Unit 9851, the SCR exhaust has Ammonia Slip limit of 7 on a wet basis and 6.1 tpy (BACT). ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 24 of 144 EPA Inspection Report - Page 260 of 1969 Version 02.25.15 ACC Form Part 1 Permit P051-R2 R2M1 Page 25 of144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 261 of 1969 Version 02.25.15 A106 Facility: Allowable Emissions Yes EINO Yes No Continuous Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. B. The permitted emission sources at the Intermittent re?nery shall consist only of the sources listed in Table 106A and Tables 106B through 106.1 of this permit. 1 INTERNAL FLOATING ROOF STORAGE TANKS TABLE 106.3(1) VAPOR PRESSURE LIMITATIONS FOR REFINERY COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOC) Typical Liquid Most Volatile Category (815i? ank No. Stored of to 0 OSM:XaTleIenp.lqul a "110056 Naphthas High Vapor Pressure2 1 1.0 Distillates High Vapor Pressure2 1 1.0 "110107 Gasolines High Vapor Pressure2 1 1.0 "120108 Gasolines High Vapor Pressure2 1 1.0 "110109 Gasolines High Vapor Pressure2 1 1.0 1 1 Naphthas High Vapor Pressure2 1 1.0 1101 12 Naphthas High Vapor Pressure2 1 1.0 1 Gasolines High Vapor Pressure2 1 1.0 "110124 Gasolines High Vapor Pressure2 1 1.0 "110012 Gasolines High Vapor Pressure2 1 1.0 "110413 Distillates High Vapor Pressure2 1 1.0 "110415 Gasolines High Vapor Pressure2 1 1.0 "110417 Gasolines High Vapor Pressure2 1 1.0 "120439 Crude 011 High Vapor Pressure2 1 1.0 Liquids in lower volatility categories may also be stored tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allowed to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). 2 High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub?grade, regular, premium, and other blends), Alkylate, Reformate, FCC Gasoline, Ethanol, lsomerate, Straight Run Gasoline, and other re?nery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 1 1 psia or less under actual storage conditions. ACC Form Part 1 Permit P051-R2 R2M1 Page 26 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 262 of 1969 Version 02.25.15 EXTERNAL FLOATING ROOF STORAGE TANKS TABLE VAPOR PRESSURE LIMITATIONS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOC) - Tank No. Typical Liquid Most Volatile Category of Max Vapor Pressure Stored Allowable Liquids to be Stored1 (psia) of Most Volatile Liquid at Max Temp. 7 Naphthas High Vapor Pressure2 11.0 T-0078 Isomerates High Vapor Pressure2 11.0 T-0079 Isomerates High Vapor Pressure2 11.0 T-01 17 Gasolines High Vapor Pressure2 1 1.0 T-0401 Gasolines High Vapor Pressure2 1 1.0 T-0402 Gasolines High Vapor Pressure2 11.0 T-041 1 Gasolines High Vapor Pressure2 110 2 Gasolines High Vapor Pressure2 1 1.0 T0435 Crude Oil High Vapor Pressure2 11.0 Crude Oil High Vapor Pressure2 11.0 T-0450 Naphthas High Vapor Pressure2 11.0 Sour Water High Vapor Pressure2 11.0 T-083O Slop High Vapor Pressure2 11.0 T-0834 Distillates Moderate Vapor Pressure3 1.5 T-0835 Distillates High Vapor Pressure2 11.0 Naphthas High Vapor Pressure2 11.0 Sour Water High Vapor Pressure:2 11.0 Ethanol High Vapor Pressure2 2.32 1 Liquids in lower volatility categories may also be stored tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allowed to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). 2 High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub?grade, regular, premium, and other blends), Alkylate, Reformate, FCC Gasoline, Ethanol, Isomerate, Straight Run Gasoline, and other re?nery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of psia or less under actual storage conditions. 3 Moderate Vapor Pressure Liquids include: Desulfurized Naphtha (Splitter Bottoms), Light Slop, and other re?nery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 1.5 psia or less under actual storage conditions. ACC Form Part 1 Permit P051-R2 R2M1 Page 27 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 263 of 1969 Version 02.25.15 FIXED ROOF STORAGE TANKS TABLE 106.C VAPOR PRESSURE LIMITATIONS FOR REFINERY SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOCS) Tank No. Typical Liquid Most Volatile Category of Max Vapor Pressure (psia) of Stored Allowable Liquids to be Most Volatile Liquid at Max Stored1 Temp. T-0013 Slop Moderate Vapor Pressure3 1.5 T-0040 Distillates Low Vapor Pressure4 0.5 Distillates Low Vapor Pressure4 0.5 10 Asphalt/Pitch Low Vapor Pressure4 0.5 T-0400 Gas Oils Low Vapor Pressure4 0.5 Carbon Black Oil Low Vapor Pressure4 0.5 (CBO) CBO Low Vapor Pressure4 0.5 T-0409 Gas Oils Low Vapor Pressure4 0.5 T-0410 Asphalt/Pitch Low Vapor Pressure4 0.5 8 Distillates Low Vapor Pressure4 05 T-0419 Distillates Low Vapor Pressure4 0.5 T-0420 CBO LOW Vapor Pressure4 0.5 Distillates LOW Vapor Pressure4 0.5 Distillates Low Vapor Pressure4 0.5 T-0431 Distillates Low Vapor Pressure4 0.5 Distillates Low Vapor Pressure4 0.5 T-0049 Slop Moderate Vapor Pressure3 1.5 T-0055 Distillates LOW Vapor Pressure4 0.5 Distillates LOW Vapor Pressure4 0.5 CBO Low Vapor Pressure4 0.5 Distillates Low Vapor Pressure4 0.5 T-0063 CBO Low Vapor Pressure4 0.5 ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 28 of 144 EPA Inspection Report - Page 264 of 1969 Version 02.25.15 CBO Low Vapor Pressure4 0.5 CBO Low Vapor Pressure4 0.5 T-0433 Gas Oils Low Vapor Pressure4 0.5 T-0434 Distillates Low Vapor Pressure4 0.5 Gas Oils Low Vapor Pressure4 0.5 T-0810 Slop Moderate Vapor Pressure3 1.5 T-0814 Asphalt/Pitch Low Vapor Pressure4 0.5 1 5 Distillates Low Vapor Pressure4 0.5 8 Distillates Low Vapor Pressure4 0.5 T?l 227 Asphalt/Pitch Low Vapor Pressure4 0.5 T?008l Asphalt/Pitch Low Vapor Pressure4 0.5 82 Asphalt/Pitch Low Vapor Pressure4 0.5 Recovery Well High Vapor Pressure2 11.0 Hydrocarbons Recovery Well High Vapor Pressure2 11.0 Hydrocarbons Recovery Well High Vapor Pressure2 1 1.0 Hydrocarbons Biodiesel Low Vapor Pressure4 0.022 NEWBIODIES EL 3 TABLE 106.D STORAGE TANK THROUGHPUT AND TEMPERATURE LIMITS Material Throughput (bbl/yr) Maximum Storage Temperature (OF) Asphalt/Pitch 30,872,000 510 Carbon Black Oil (CBO) 1,291,610 250 Crude Oil 76,212,000 Ambient Liquids in lower volatility categories may also be stored tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allowed to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub?grade, regular, premium, and other blends), Alkylate, Reformate, FCC Gasoline, Ethanol, Isomerate, Straight Run Gasoline, and other re?nery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 1 1 psia or less under actual storage conditions. Moderate Vapor Pressure Liquids include: Desulfurized Naphtha (Splitter Bottoms), Light Slop, and other refinery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 1.5 psia or less under actual storage conditions. Low Vapor Pressure Liquids include: Diesel (raw or ?nished), Kerosene (raw or ?nished), JP-8, CBO, LCO, Slurry, Heavy Slop, Cutback Asphalt, Cutter, VGO, AGO, and other re?nery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure less than 0.5 psia under actual storage conditions. ACC Form Part 1 Permit P05 l?R2 Ver 4.1 02/25/2015 Page 29 of 144 EPA Inspection Report - Page 265 of 1969 Version 02.25.15 Distillate 55,076,590 310 Gas Oil 25,059,500 310 Gasoline (includes isomerates) 57,910,908 Ambient Naphtha 39,028,084 Ambient Slop 1,330,000 Ambient Sour Water 45,051 Ambient BioDiesel 949,000 Ambient Methanol 142,350 Ambient TABLE STORAGE TANK VOC AND HZS EMISSION LIMITS1 (return to A203) Tank Type VOC Emission Rate (tpy) HZS Emission Rate (tpy) ixed-Roof 238.6 0.0 Floating-Roof 83.8 1.47 Total Tanks 322.4 1.47 1 Table 106.F, LIMITS FOR REFINERY SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOC) FUGITIVE EMISSIONS FROM EQUIPMENT LEAKS Maximum Hourly Average Annual Process Unit ID Number Description VOC Emission Rate VOC Emission (lb/hr) Rate (tons/yr) CRUDE South Division Crude Unit 102 44.6 FCC 10.8 47.2 Powel'former/Penex Unit 5.9 25.7 FUG-21-SP VACUUM Flasher/Vacuum Unit 3.2 13.9 FUG-OS-KERO Kerosene HDS Unit 5.2 22.7 JP8 Hydrodesulfurization 7.1 30.9 MEROX TRT Merox/Merichem Treating Units 3.5 15.3 GAS Saturates Gas Plant 18.3 80.0 FARM Light Oil Tankage 6.8 29.6 PUG-ASPHALT STG Asphalt/Heavy Oil Storage 3.5 15.3 GAS Fuel Gas Distribution System 4.2 18.2 The permittee shall demonstrate compliance with the above throughputs and emission limits through the annual emissions inventory process. Speci?c tank data temperature throughputs) shall be monitored and recorded weekly by the permittee. ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 30 of 144 EPA Inspection Report - Page 266 of 1969 Version 02.25.15 LPG Storage System 21.6 94.4 PBC Unit 3.4 14.7 CCR Reformer (W/in battery limits) 23.4 102.3 PUG-1 Naphtha HDS Unit 10.2 44.6 FUG-43-S ALKY South Alky Unit (W-76) 1.7 7.5 ALKY North Alkylation Unit (New?Inside battery limits) 12.0 52.5 Gas Oil Hydrotreater (incl. CVS) 9.3 40.6 UG-45-DIST-HDU Gas Oil Hydrotreater (incl. CVS) 2.6 1.2 AMINE Amine Unit-Treating/Regen. 6.3 27.5 2.4 10.4 Sour Water Stripper 1.6 7.0 CVS Oil/Water Separator 1.3 5.5 HDU Relocated Diesel HDS Unit 12.9 56.4 FUG-O8-TRUCK RK loading Racks 2.8 12.1 FUG-RLO-ASPHALT Asphalt/Pitch Loading Rack 07 2.9 UTIL Utilities 16.7 73.3 Hydrogen Plant 2.6 1 1.2 SRU3 Unit 0.7 3.1 WX Hydrocracker 6.2 27.2 FUG-25-ROSE-2 ROSE Unit 8.0 35.1 PLANT-2 Hydrogen Plant 2.6 1.2 Crude oil unloading system, closed loop system 0.1 0.5 between railcars and trucks Subtotal Facility VOC CAP 227.8 994.6 Minor changes within the facility to piping and components that affect fugitive VOC emission source shall be updated and added during the next available Signi?cant permit revision in accordance with 20.2.72 NMAC. The facility wide fugitive VOC emission limit shown above and in Table 106A of this permit. MISCELLANEOUS SOURCES Table 106.G EMISSION LIMITS FOR REFINERY NON-COMBUSTION SOURCES Of VOLATILE ORGANIC COMPOUNDS (VOCs) Loadin Loadin Rack . Hourl Annual . . Rack Descrigption Material Loaded Through>put Throughput VOC bbl/hr bbl/yr lb/hr ton/yr Gasoline 1214 1,600,696 4.25 2.80 Fuels Truck Loading Diesel 107100 3,650,000 1.72 1.72 Rack Jet Fuel 35700 1,021,718 0.75 0.34 TOTAL VOC 6.73 4.86 TL-7 Truck Carbon Black Oil 500,808 6.30 1.57 ACC Form Part 1 Pennit Ver 4.1 02/25/2015 Page 31 of 144 EPA Inspection Report - Page 267 of 1969 Version 02.25.15 Loading Rack Light Cycle Oil 38100 20,1 19 3.55 0.06 TOTAL VOC 6.30 1.63 Carbon Black Oil 30000 365,000 6.30 1.15 . Diesel 20000 1,144,000 0.32 0.54 RLO-8 Jet Fuel 20000 1,144,000 0.42 0.38 Asphalt 30000 2,628,000 0.01 0.03 TOTAL VOC 6.30 2.09 FUG- Odor Controllin ODOR Atomizer 0'46 2'0 Note:1. Calculation method and factors per AP-42, Section 5.2, dated June 2008. a Controlled emission rate. The previous controlled rate was set by the terms of the consent agreement between Navajo Re?ning Co. and the Department executed January 28, 1994. The agreement required that the incinerator have a minimum 90% destruction ef?ciency for gasoline loading and a minimum 80% destruction ef?ciency for diesel fuel loading or Jet A fuel loading. This was achieved by a vapor combustor. This device has since been replaced with a carbon adsorption system compliant with MACT Subpart R, as subject per MACT Subpart CC. Emission limits changed in l95-M-l7 to correspond to Title permit values. COOLING TOWERS Table 106.H EMISSION LIMITS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUMDS and PM Source ID VOC VOC PM PM CO (lb/hr) CO lb/hr tons/yr (lb/hr) (tons/yr) (tons/yr) Y-0001 1.8 7.9 0.3 1.2 Y-0002 1.8 7.9 0.3 1.2 Y?0008a 6.5 28.3 0.7 2.9 0.58 2.54 Y?001l 1.3 5.5 0.5 2.3 Y-0012 0.4 1.8 0.2 0.8 CT 1.1 4.7 0.2 0.7 Subtotal (for informational 1 2_8 56.1 2_ 1 9. 1 purposes only) . a Y-0008 cooling tower provides 100% control of any NH3 emissions from and Unit 64, Hydrogen Plant has de?aerator line that has dissolved CO that is connected to the cooling tower. API SEPARATORS Table 106.1 EMISSION LIMITS FOR REF INERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOCs) Maximum Average Hourly VOC Annual VOC Equipment Emission Point Emission Emission ID ID Description Rate (lb/hr) Rate (tons/yr) MAIN API Above Ground API Oil-Water Separators <0.1 <0.1 ACC Form Part 1 Permit R2M1 Page 32 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 268 of 1969 Version 02.25.15 and enclosed drain system. DAF-0896 DAF Unit T-0896 <0.1 <0.1 T-080?l T-080?l Enhanced Biodegradation Tank <0.1 <0.1 Enhanced Biodegradation Tank T-0836 0.1 0.5 Equalization Tank T-0829 5.1 8.9 T-0806 DAF Unit <0.1 <0.1 Subtotal (for informational purposes only) 5.3 9.4 A106 Facility: Allowable Emissions Continuous El Yes Yes C. Compliance with Allowable Emission Xi Intermittent Xi N0 El N0 Limits Requirement: The allowable mthu/hr, lb/mthu, lb/hr, and tpy emission limits for equipment listed in Table 106A construction of which predates the Navajo continues to comply with all applicable effective date of 202.72 NM AC (August emission limits except for speci?c deviations as 319 1972)9 and have not been modi?ed noted elsewhere in this document and events since August 31, 1972, shall be the reported per 20'2'7 "potential emission rate" of that unit as defined in 20.2.72.107 NMAC and the potential to emit of that unit de?ned under 20.2.74 NMAC. The mthu/hr, lb/hr and lb/mthu limits are based on an hourly rolling 3?hour average. (NSR 0195M35, Condition A106.C and revised) ?Z/ijnli}: Navajo continues to comply with all applicable Xi Contlnuous Yes Xi Yes Permi tee Shall monitor the lb /mmB tu t0 em1ss1on 11m1ts except for speCI?c dev1at10ns as Intermittent N0 El N0 noted elsewhere 1n document and events demonstrate comphance With the reported er 20.2.7 NM AC. mthu/hr, lb/hr, and tpy emission limits. Nava'o continues to corn 1 with all a licable - Recordkeeping: To demonstrate emissJion limits except foiJ Speci?c devrigtions as Continuous Yes Yes compliance, records shall be kept showing noted elsewhere in this document and events Intermittent No No the correlation between lb/mthu and the reported per 2027 NM AC. ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 33 of 144 EPA Inspection Report - Page 269 of 1969 Version 02.25.15 mthu/hr and lb/hr, and the rolling 12?month tpy totals. The records shall also document any non- compliance with emission limits. For each unit, a summary of the method used to determine compliance shall be recorded. The permittee shall maintain records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous Intermittent Yes No Yes No A106 Facility: Allowable Emissions D. BACT SOZ Limit Fuel sulfur limit Re?nery?Wide for all units burning re?nery fuel gas (excluding units H-8801, and which burn only natural gas) shall not exceed 60 HZS on a daily rolling 365-day average. The ton/yr emission rates for 802 in Table 106.A of this permit are based on this daily rolling 365?day average 60 HZS limit. Compliance with this limit shall be demonstrated per the methods described in Condition A110.A. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous Intermittent Yes No Yes No A106 Facility: Allowable Emissions E. BACT Limit - In addition to the emission limits shown in Table 106A, Boiler Unit has a BACT limit of 0.02 lb/MM Btu, and C02 limit of 112.1 lb/MM Btu. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous Intermittent Yes No Yes No ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 34 of 144 EPA Inspection Report - Page 270 of 1969 Version 02.25.15 A106 Facility: Allowable Emissions F. BACT Limit - The Sulfur Recovery Unit No. 3 Tail Gas Incinerator is limited to I92 $02 at zero percent oxygen on a hourly rolling 12-hour average basis. In addition, SRU3- TGI is limited to 192 $02 at zero percent oxygen on a daily rolling 365-day average basis. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. IXI Continuous IXI Intermittent IXI Yes No Yes IXI No A106 Facility: Allowable Emissions G. BACT VOC Limit The naphtha storage tank T-1225 and sour water storage tank shall be equipped with an external ?oating roof using double seals to reduce VOC emissions to the atmosphere. The maximum true vapor pressure of any volatile organic liquid stored in either tank shall not exceed 11.0 psia. Demonstration of compliance is through the NSPS Kb and MACT emission limits. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. IXI Continuous Intermittent IXI Yes No Yes IXI No A106 Facility: Allowable Emissions H. VOC All fugitive piping components in VOC service associated with the process units proposed in Permit l95?M25 (Units PUG-3 l- and Hydorcracker) shall be monitored under the MACT subpart CC leak detection and repair program, or an approved equivalent program, to reduce VOC emissions. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous Intermittent XI Yes No Yes IXI No ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 35 of 144 EPA Inspection Report - Page 271 of 1969 Version 02.25.15 A106 Facility: Allowable Emissions Continuous Yes Yes Navajo continues to comply with all applicable I. VOC Consistent With MACT Subpart emission limits except for speci?c deviations as Intermittent NO No CC, the gasoline truck loading rack (TLO- noted elsewhere in this document and events 4) shall be limited to 10 mg of VOC reported Per 20-2-7 NMAC- emissions per liter of gasoline loaded. A106 Facility: Allowable Emissions Continuous Yes 1:1 Yes J- (3001ng towers, Units 1 Navajo continues to comply with all applicable IXI Intermittent NO NO and Y-0012, shall be equipped With high- emission limits except for speci?c deviations as ef?ciency drift eliminators to reduce noted elsewhere in this document and events emissions. Demonstration of compliance is reported Per 202-7 NMAC- through annual inspection in accordance with in Condition A212.B. A107 Facility: Allowable Startup, 1:1 Continuous Yes Yes Shutdown, Maintenance (SSM) and Malfunction Emissions '21 Intermittent '21 N0 N0 A. The maximum allowable SSM and Navajo continues to comply with all applicable . . . . . . em1ss1on 11m1ts except for spec1?c dev1ations as Malfunctlon em1s51ons l1m1ts for th1s . . noted elsewhere In th1s document and events fa01l1ty are l1sted 1n Table 107A and were reported er 20.2.7 NM AC. relied upon by the Department to determine compliance with applicable regulations. Table 107.A: Allowable SSM and Malfunction Units, Activities, and Emission Limits1 CO VOC 5 $02 H25 Unit Description of Emissions tpy tpy tpy tpy tpy tpy SSM Emissions during SCR downtime1 10.1 1 2 20SSM Emissions from roof landing -- 33.0 0.5 -- -- SSM Misc 1 Emissions from catalyst handling -- 1.5 <0.1 ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 36 of 144 EPA Inspection Report - Page 272 of 1969 Version 02.25.15 Emissions from SRU3 startup and 6.5 <0.1 15.0 0.1 0.1 <0.1 159.0 0.4 6.5 <0.1 SSM SRU3-TGI shutdown Emissions from roof landing and SSM tank re?lling -- 177.0 2.7 -- -- Emissions from roof landing and SSM T-0079 tank re?lling -- 306.0 4.6 -- SSM T-1225 Emissions from roof landing 187.0 2.8 SSM FL-HEP- Temporary, portable ?are for natural PORT gas pipeline maintenance 173.4 0.1 943.5 0.5 160.7 0.1 -- 1.7 <0.1 0.02 <0.1 SSM Emissions from SRU2 startup and (H-0473) shutdown 6.5 0.1 27.7 0.2 0.2 0.1 159.0 0.4 6.6 0.1 Emissions from venting SSM activity gases to FL-400, 1133. SSM Flare Cap FL-403, or FL-404. 162.9 18.3 1243.0 77.0 211.6 13.2 4 14.9 0.4 0.1 Flares Malf Cap Upset and Malfunction Emissions 10.0 10.0 -- 10.0 10.0 -- Low?Emittin Maintenance Activities such as de?inventorying small equipment, clearing piping associated with emission units, and routine maintenance activities such as heat SSM Misc 2 exchanger repair. 17.0 1.9 127.1 7.8 21.2 1.4 -- -- 129.3 1.6 0.7 0.1-- SSM Tanks Misc Storage Tanks -- -- -- 112.0 10.6 -- -- -- 0.1 0.1 Subtotal 31.6 98.0 46.2 0.4 27.4 0.4 During startup, shutdown, schedule maintenance or malfunction of the SCR control system, BACT for H-9851 shall be ultra?low burners emitting no more than 03 lb per (LHV) on a hourly rolling 3-hour average basis at 3% excess oxygen. Pound per hour and tons per year limits are based on the lb/MMBtu limits and were used to demonstrate compliance with the lb/MMBtu limits and the Ambient Air Quality Standards (AAQS). A107 Facility: Allowable Startup, Shutdown, Maintenance (SSM) and Malfunction Emissions B. The authorization of emission limits for startup, shutdown, maintenance, and malfunction does not supersede the requirements to minimize emissions according to Conditions B101.C and B107.A. Navajo complies with the conditions of B101 .C and 107.A. IE Continuous IE Intermittent Yes IE N0 IE Yes No ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 37 of 144 EPA Inspection Report - Page 273 of 1969 Version 02.25.15 A107 Facility: Allowable Startup, Shutdown, Maintenance (SSM) and Malfunction Emissions C. SSM Flaring and combustion Emissions Requirement: The permittee shall comply with the ?aring and combustion SSM NOX, CO, VOC, SOZ, TSP, and H28 emission limits at Table 107A for the following SSM events: 1) SSM H-9851, Emissions during SCR downtime 2) SSM Emissions from SRU3 startup and shutdown 3) SSM FL-HEP-PORT, Temporary, portable ?are for natural gas pipeline maintenance 4) SSM Emissions from SRU2 startup and shutdown 5) SSM Flare Cap, Emissions from venting SSM activity gases to FL- 400, FL-403, or 6) SSM Misc 2, Low-Emitting Maintenance Activities such as de-inventorying small equipment, clearing piping associated with emission units, and routine maintenance activities such Navajo obtains fuel gas analysis from New Mexico Gas Company. Navajo continues to comply with these requiremrents except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous IXI Intermittent I: Yes No Yes I: No ACC Form Part 1 Permit P05 l?R2 R2M1 Ver 4.1 02/25/2015 Page 38 of 144 EPA Inspection Report - Page 274 of 1969 Version 02.25.15 heat exchanger repair. revised) (NSR 0195M35, Condition A107.C and ?aring and combustion speci?ed in A107C. Recordkeeping. Monitoring: The permittee shall monitor all ?aring and combustion due to routine and predictable startups, shutdowns, and scheduled maintenance events. This shall be accomplished by collecting all the SSM information Navajo Environmental Department keeps an up?to? date events summary with emission units and pollutant. El Continuous El Intermittent El Yes N0 Yes El No Recordkeeping: The permittee shall record the date, start and end times, and duration of every SSM ?aring or combustion event. The NOX, CO, VOC, volume of gas sent to the ?are and the total sulfur content of the ?ared gas. Compliance with the hourly emission rates shall be demonstrated by calculating the hourly emission rates for each event and comparing the results to the hourly emission rate at Table 107A. The annual emission rate shall be calculated as follows: and 802, TSP, PMlo, and H28 emissions shall be calculated for each event based on the 1) To demonstrate compliance during the ?rst 12 months of monitoring, the permittee shall calculate and sum the cumulative total of NOX, CO, VOC, 802, TSP, PMlo, and H28 emissions; 2) After the ?rst 12 months of monitoring, the permittee shall Navajo keeps records of SSM events. Maintenance scheduling is based on engineering judgment and operating experience. El Continuous XI Intermittent Yes XI No XI Yes No ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 39 of 144 EPA Inspection Report - Page 275 of 1969 Version 02.25.15 calculate and sum the total of NOX, CO, VOC, S02, TSP, PMlo, PM25, and H2S emissions on a rolling 12 month basis. 3) The permittee shall maintain all records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. Reports required by Section B110 are submitted as necessary, except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. El Continuous Intermittent El Yes No Yes No A107 Facility: Allowable Startup, Shutdown, Maintenance (SSM) and Malfunction Emissions D. SSM VOC Emissions (Facility-Wide, Non-Combustion Sources) Requirement: The permittee shall comply with the SSM VOC emission limit at Table 107.A. Navajo complies with the requirements listed in table 107.A. El Continuous Intermittent El Yes No IE Yes No Monitoring: The permittee shall monitor all VOC emission activities due to routine and predictable startups, shutdowns, and scheduled maintenance events. This shall be accomplished by collecting VOC emission calculation information for the following SSM VOC emission activities: 1) SSM T-0737, Emissions from roof landing 2) SSM T-0078, Emissions from roof landing and tank re?lling 3) SSM T-0079, Emissions from Navajo complies with these requirements. El Continuous Intermittent El Yes No IE Yes No ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 40 of 144 EPA Inspection Report - Page 276 of 1969 Version 02.25.15 4) 5) roof landing and tank re?lling SSM Emissions from roof landing SSM Tanks Miscellaneous 1) 2) 3) Recordkeeping: The annual SSM VOC emission rate shall be calculated as follows: To demonstrate compliance during the ?rst 12 months of monitoring the permittee shall calculate and sum the cumulative total of VOC emissions; and After the ?rst 12 months of monitoring the permittee shall calculate and sum the total of VOC emissions on a rolling 12 month basis, including the methodology and/or assumptions used in the calculation(s). The permittee shall keep records to demonstrate compliance in accordance with Condition B109C, except the requirement in to record the start and end times of SSM events shall not apply to known quantities of VOC emissions. The permittee shall maintain all records in accordance with Section 1 09. Navajo complies with these requirements. Continuous Intermittent Yes N0 Yes IE N0 Reporting: The permittee shall report in accordance with Section B110. Navajo complies with these requirements, except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous IE Intermittent Yes N0 Yes IE N0 ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 41 of 144 EPA Inspection Report - Page 277 of 1969 Version 02.25.15 A107 Facility: Allowable Startup, Continuous XI Yes Yes Shutdown, Maintenance (SSM) and Malfunction Emissions Intermittent N0 N0 E. SSM Particulate Emissions (Unit SSM . . . . . Navajo complies With these requirements. Misc 1) Requirement: The permittee shall minimize particulate emissions due to SSM events. Monitoring: The permittee shall monitor Continuous XI Yes Yes all particulate em1ss10ns due to routine and predictable startups, shutdowns, and XI Intermittent N0 XI N0 scheduled maintenance events. For the event type of FCCU Catalyst Loading, the maximum material usage shall not exceed 1 hr-duration, 1 loading event/yr; and 237,048 lb/event/yr. Navajo complies with these requirements. Recordkeeping: For each event, the DContinuous DYes permittee shall maintain records of the duration in hours, events per year, and XI Intermittent N0 N0 material usage for the particulate matter emitting SSM event FCCU Catalyst Navajo complies with these requirements. Loading. The annual material usage shall be based on rolling 12-month total. The permittee shall maintain all records in accordance with Section B109. Reporting: The permittee shall report in Navajo complies with these requirements, except Continuous Yes Yes . . for dev1at10ns as noted elsewhere in this accordance Section B1 10' document and events reported per 20.2.7 NMAC. Intermittent N0 IE N0 ACC Form Part 1 Permit Page 42 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 278 of 1969 Version 02.25.15 A107 Facility: Allowable Startup, Shutdown, Maintenance (SSM) and Malfunction Emissions F. SSM and Malfunction Flaring Emissions (SSM Flare Cap and Flares Malf Cap) Requirement: The permittee shall not exceed the pound per hour (pph) and ton per year (tpy) emission limits in Table A107.A and shall demonstrate compliance with these limits by calculating and summarizing these emission rates as required in recordkeeping. Navajo complies With these requirements, except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous Intermittent DYes No IZI Yes No Monitoring: A gas ?owmeter and ?ow totalizer, equipped with a chart recorder or electronic data logger, shall be installed in the ?are line to measure and record the total standard cubic feet (sci) of all gas (process gas, purge gas, pilot gas, and supplemental fuel gas) sent to the ?are during each hour and each month. The permittee shall measure the H28 content, the total sulfur content, the VOC content, and the heating value (Btu/sci) of the gas sent to the ?are for combustion. HZS shall be measured at least once every 24?hours on each of the inlet gas types/streams using a stain tube of the appropriate size range or an inline HZS monitor. The total sulfur content, VOC content, and heating value (Btu/sci) of the Navajo complies with these requirements, except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. El Continuous IZI Intermittent Yes No Yes No ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 43 of 144 EPA Inspection Report - Page 279 of 1969 Version 02.25.15 natural gas sent to the ?are shall be measured at least once annually with an extended gas analysis. The ?ow meter and ?ow totalizer shall be operated, calibrated, and maintained as speci?ed by the manufacturer and as necessary to ensure correct and accurate readings. If used, the inline monitor shall be operated, calibrated, and maintained as speci?ed by the manufacturer and as necessary to ensure correct and accurate readings. Recordkeeping: The following records El Continuous Yes El Yes Shall be kept: El Intermittent No N0 0 stain tube and/or inline H28 measurements 0 annual extended gas analysis 0 both the hourly and volume (sci) of gas sent to the ?are Each month, the permittee shall record and summarize in a table format the following. Navajo complies with these requirements, except 0 H28 and the total sulfur content for specific deviations as noted elsewhere in this 0 percent VOC content document and events reported per 20.2.7 NMAC. 0 gas heating value (Btu/sci) the maximum hourly gas ?ow rate (scf/hr) that occurred during the month 0 each hourly gas ?ow rate (scf/hr) for any hour(s) that exceeded any emission limit during the month 0 the total month?s of gas sent to the ?are ACC Form Part 1 Permit P051-R2 Page 44 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 280 of 1969 Version 02.25.15 - the rolling 12-month total of gas sent to each ?are (scf/yr) Each month, the permittee shall record all routine and predictable startups, shutdowns, and scheduled maintenance events and shall also meet the recordkeeping requirements in General Condition B109 of this permit, except the requirement to record the start and end times of SSM events shall not apply. Records of ?owmeter, totalizer, and inline monitor certi?cations, calibrations, documentation of the manufacturer?s recommended calibration maintenance schedule, breakdowns, reasons for the breakdown, and corrective actions taken shall be maintained. Each month, to demonstrate compliance with both the SSM and malfunction emission limits, the permittee shall calculate and summarize the maximum emission rate, any emission rate exceeding the permitted limits, and the rolling 12-month total ton per year emission rates of CO, VOC, 802, and H28 for both SSM and mal?inction events, using the following information: 0 the H28 content, total sulfur content, VOC content, and the gas heating value (MMBtu/scf) from the most recent HZS measurements and gas analyses 0 the emission factors used to ACC Form Part 1 Permit R2M1 Page 45 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 281 of 1969 Version 02.25.15 calculate and CO 0 the maximum hourly gas ?ow rate (scf/hr) 0 each hourly gas ?ow rate (scf/hr) for any hour(s) that exceeded any emission limit during the month, including the dates and times of these occurrences the rolling 12?month total of gas sent to the ?are (scf/yr) For each event, the permittee shall record whether the emissions are due to SSM and/or malfunction. If the emissions are due to malfunction, the permittee shall indicate whether the emissions resulting from the event are included in the amount allowed by this permit? 5 malfunction limit or whether the event is reported under 20.2.7 NMAC. . . Navajo complies with these requirements, Navajo El Continuous El Yes Yes The shall report comphes With these requlrements, except for according to Condition B1 10. speci?c deviations as noted elsewhere in this Intermittent N0 0 document and events reported per 20.2.7 NMAC. A108 Facility: Hours of Operation Continuous Yes Yes A. This facility is authorized for lg] Intermittent No N0 continuous operation. Monitoring, recordkeeping, and reporting are not required to demonstrate compliance with continuous hours of operation. No requirement. A109 Facility: Reporting Schedules El Continuous Yes El Yes Navajo submitted the requested monitoring reports A. A Semi-Annual Report of monitoring as follows; Intermittent El N0 N0 activities is due within 45 days following 4/14/2016 the end of every 6?month reporting period. 10/14/2015 The six month reporting periods start on ACC Form Part 1 Permit Page 46 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 282 of 1969 Version 02.25.15 September and March of each year. A109 Facility: Reporting Schedules B. The Annual Compliance Certi?cation Report is due Within 30 days of the end of every 12?month reporting period. The 12? month reporting period starts on September 1St of each year. Navajo submitted the requested compliance certi?cation report as follows: 09/29/2015 Continuous IE Intermittent IE Yes No Yes IE N0 A109 Facility: Reporting Schedules C. In addition to the reports required by the applicable NSPS, NESHAP and MACT Subparts (including any voluntary programs referencing NSPS, NESHAP, or MACT Subparts) and by the applicable parts of 20.2 NMAC, the reporting required by the Consent Decree shall be submitted to the Department. The reports shall be submitted to the Air Quality Bureau Within forty ?ve (45) days of the end of each calendar quarter. If any reports indicate potential non-compliance with the terms of this permit, the Bureau may impose a more frequent reporting time?frame. The Department shall handle any con?dential information in accordance with the provisions of 20.2. 1.1 15 NMAC. The Department has not requested more frequent reporting time?frames. Continuous Intermittent Yes No Yes IE N0 A109 Facility: Reporting Schedules D. Reporting required by the Consent Decree (not an exhaustive listing) (1) The permittee shall notify the Department?s Enforcement Section, Air Navajo submitted the Annual NOX Control Technology report as follows: 12/3 1/2015 Continuous Intermittent IE Yes No Yes IE No ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 47 of 144 EPA Inspection Report - Page 283 of 1969 Version 02.25.15 Quality Bureau in writing of the annual progress of installation of NOX Control Technology required by Paragraph 16 of the Consent Decree. The report shall be submitted to the EPA and the NMED on or before December 31st of each calendar year commencing with the year 2002. (CD 1116B) (2) No later than forty-?ve (45) days following the end of an AG Flaring or TG Incident, the perrnittee shall submit to EPA and the NMED a report that sets forth the items detailed in the Consent Decree. (CD 1120, A110 Facility: Fuel and Fuel Sulfur El Continuous Yes El Yes Requirements (as Required) El Intermittent El N0 El No A. Fuel, Fuel Sulfur, and NSPS J, Ja Sulfur Requirements (See Tables 103.E, H, I, K, Summary of Applicable Requirements) Re?nery fuel gas is continously monitored for H2S content on a 3?hour rolling average. Excedances Requirement: (NSR 01951v1359 are reported on Navajo's Subpart A report. Condition A1 10.A and revised) (1) To comply With NSPS Subpart J, NSPS Subpart Ia, and the PSD BACT requirements in Section 106, the perrnittee ACC Form Part 1 Permit Page 48 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 284 of 1969 Version 02.25.15 shall install, calibrate and maintain a continuous monitoring system (CMS) to continuously measure and record either the hydrogen sul?de (H28) in the re?nery fuel gas streams being burned in the Heaters and Boilers or the concentration of sulfur dioxide emissions to the atmosphere. (2) All stationary combustion equipment shall be ?red with NSPS quality fuel gas with a maximum HZS content of 0.1 grains/ (approx. 162 ppmv), based on a hourly rolling 3?hour average. (3) All stationary combustion equipment shall not combust gas with an annual average sulfur content exceeding 60 (approx. 0.037 grains) as a daily rolling 365-day average. (4) All stationary combustion equipment shallbe affected facilities, as de?ned in NSPS 40 CFR Part 60, Subparts A and or a, if re?nery?produced fuel gas is combusted in the heaters and boilers, and shall comply with all applicable requirements of NSPS Subparts A and or a. (See Table 103.E, Summary of Applicable Requirements) 1) CMS has been installed and is certi?ed, El Continuous Yes Yes Monitoring: calibrated and maintained. (1) The permittee shall install, certify, Elntermittent calibrate, maintain and operate a fuel gas continuous monitoring system (CMS) at D-0019 Low Pressure Fuel Gas H28 2) CMS annual RATAS were completed as follows: ACC Form Part 1 Permit P051-R2 R2M1 Page 49 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 285 of 1969 Version 02.25.15 the fuel gas mix drum outlet in accordance 7/1 1/2016 with the requirements of 40 CFR 60.11, . 60.13, and Part 60 Appendix A, and the Pressure Fuel Gas H28 applicable performance speci?cation of 40 7/1 1/ 201 6 CFR Part 60 Appendlces and 3) The CCR stabilizer off gas, the H2 recycle gas (2) The following CMS shall be certi?ed and the CCR feed streams are analyzed a minimium initially and recerti?ed annually: 0f quarterly D-0019 Low Pressure Fuel Gas HZS CMS 0 High Pressure Fuel Gas HZS CMS (3) As required by the EPA?approvable alternative monitoring procedure (AMP), CCR off?gas streams that enter the re?nery fuel gas system of the H28 CMS shall be monitored quarterly for HZS using gas detector tubes or an equivalent method as follows: CCR stabilizer off gas stream, H2 recycle gas stream, and c) CCR feed stream. Recordkeeping: The perrnittee shall Continuous Yes El Yes comply with the applicable recordkeeping requirements of 40 CFR 60, Subparts A, J, Inter ?1??Fuel records are maintained in Pi. (1) Records ofthe quantity 0fthe re?nery 2) Repair, maintenance, and calibration records are fuel gas and the average heating maintained by Navajo Instrument and Electrical value of the re?nery fuel gas. This is Department. used to demonstrate compliance with 1b and lb/hr limits shown in 3) CCR off-gas stream analysis records are Table 106 A. (permit limit) maintained in the Navajo Environmental Department Files (REF.ART.3.J.05.A). (2) Records of repairs, maintenance, and calibrations performed for the instruments that measure ?ow or ACC Form Part 1 Permit R2M1 Page 50 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 286 of 1969 Version 02.25.15 concentration for an applicable permit limit shall be kept. Examples include, but are not limited to, CMS, acid gas ?ow meters, and fuel gas ?ow meters. (40 CFR 60, Appendix F) (3) Records shall be kept of Alternative Monitoring Plan (AMP) HZS analyses of the CCR off-gas streams that enter the re?nery fuel gas system of the fuel gas H28 CMS. (NSPS or Ja) Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subparts A, J, and a, and Section B110. Reports required by Subpart A are submitted semiannually. Reports required by Subparts and Ja, and Section B110 are submitted as necessary. Continuous Intermittent IX. Yes No Yes No A111 Facility: 20.2.36 NMAC A. Facility: 20.2.36 NMAC Requirement: 20.2.36 NMAC (Petroleum Refinery - Sulfur, 11/3 0/95) applies to the re?nery as a whole. Quarterly re?nery- wide sulfur balance reports shall be ?led in accordance with 20.2.36.113 NMAC. All ?ares and stacks shall meet the applicable height requirements of 20.2.36. 1 14 NMAC as demonstrated through air dispersion modeling done at the time of unit installation. (NSR 0195M3 5, Condition A111.A) Sulfur balance reports were submitted as follows: 1 1/12/2015 1/12/2016 5/16/2016 5/17/2016 Effective February 15, 2016, Navajo Refinery is no longer affected by the NMAC rule. No ?ares were installed this reporting period. I: Continuous Intermittent Yes No I: Yes N0 Monitoring: Quarterly monitoring of re?nery?wide sulfur balance. Sulfur balance reports were submitted as required. Following the end of the period Navajo Re?nery is no longer affected by the NMAC rule. Continuous IE Intermittent IX. Yes No Yes IX. N0 Recordkeeping: The permittee shall keep record of a copy of the Facility-Wide Sulfur Balance Report and the actual Records are maintained in the Navajo Environmental Department Files 3 .H.0 1). Continuous [Xi Intermittent Yes No Yes N0 ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 51 of 144 EPA Inspection Report - Page 287 of 1969 Version 02.25.15 height of ?ares and stacks. Requirement: (NSR 0195M35, Condition A1 12A) (1) Section 200A (Mercaptans) and section 200B (Hydrogen Sul?de) apply to mercaptan and H2S emissions from the re?nery. Section 200.C applies to FL- 0400, FL-0401, and and requires an alarm in good working order to signal non-combustion of the gas. (2) Section 201 .A (CO), applies to the refinery's FCC regenerator stack. The owner or operator of an existing petroleum processing facility shall not permit, cause, suffer or allow carbon monoxide emissions to the atmosphere from a catalyst cracking recirculation or regeneration unit in excess of 20,000 by volume in the undiluted ef?uent gas stream or streams. (3) Section 202.C(l) (PM), The owner or operator of a new petroleum processing facility shall not permit, cause, suffer or allow particulate matter emissions to the atmosphere from the catalytic cracking regenerator vessel in excess of 1.0 Kg/1000 Kg (1.0 lb/1000 lb) of coke 1) All ?ares have alarms indicating loss of ?ame that are in good working order. 2) The FCC catalyst regenerator exhaust is continously monitored for CO. 3) The catalytic cracking regenerator is tested annually for PM. Navajo has submitted an alternative monitoring plan (AMP) to comply with the FCC opacity monitoring requirement because the FCCU has a wet scrubber which prevents continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CFR 60 Appendix A Method 9. 4) There are no process vents to the atmosphere, so the refinery is not expected to emit ammonia. Any trace ammonia emissions are expected to comply with the 25-ppm limit. 5) Navajo continues to comply with the applicable requirements of NSPS Subpart at re?nery oil/water seperators. The oil/water separator is inspected at least semi?annually, and the carbon vapor control is tested at least 6) Blowdowns are accomplished by venting to ?ares that are designed to be operated smokelessly. . . . . Sulfur balance reports were submitted as required. Continuous Yes Yes Rep The Shall report 1n Following the end of the period Navajo Refinery is accordance w1th 20.2.36.l 13A NMAC. no longer affected by the NM AC rule. Intermittent No No A112 Facility: 20.2.37 NMAC Continuous Yes Yes A. 20.2.37 NMAC Intermittent 0 0 ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 52 of 144 EPA Inspection Report - Page 288 of 1969 Version 02.25.15 bumoff or visible emissions of thirty percent opacity or greater except for one six-minute average opacity reading in any one-hour period. (4) Section 203 (Ammonia, undiluted emissions 3 25 ppmv) applies to all emission points of the re?nery. The owner or operator of a petroleum processing facility shall not permit, cause, suffer or allow ammonia emissions to the atmosphere in excess of 25 by volume in the undiluted ef?uent gas stream or streams. (5) Section 204 (Hydrocarbon Separation Facility) applies to all oil/water separators at the re?nery. Compliance with this condition is met by complying with the applicable NSPS Subpart requirements. (6) Section 205 (Facilities Storage - Handling Pumping Blowdown System) applies to certain of the following: storage tanks for organic compounds, loading and unloading of organic compounds, seals on pumps and compressors, and disposal (?aring) of hydrocarbon gases. The permittee shall not permit, cause, suffer or allow the operation of a blowdown system without disposing of the gases in a manner which will minimize hydrocarbon emission to the atmosphere. If combustion is the means of disposal, it shall be by: smokeless ?are; or any other method that is equally effective to achieve complete ACC Form Part 1 Permit P051-1Q MMI Page 53 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 289 of 1969 Version 02.25.15 combustion. (20.2.3 7.205.E NMAC) Monitoring: (1) For Units 0402, L-0403, and The permittee shall install and maintain a ?are pilot ?ame monitoring system. (20.2.37.200.A.2 NMAC) (2) A CO CMS has been installed to monitoring the emissions from the FCC. (3) The annual EPA Method 9 Opacity Test and annual Stack test on Unit FCC (lb/hr PM emissions) and the calculated Coke burn rate will be used for the annual determination of pounds of PM per 1000 pounds of Coke burned. (4) None (5) No additional monitoring since compliance is met by complying with the applicable NSPS Subpart requirements. See other conditions of this permit for applicable NSPS or MACT requirements. (6) Compliance is demonstrated through NSPS K, NSPS Ka, NSPS Kb, or MACT CC for Tanks; through MACT CC for Loading Racks; through NSPS NSPS or MACT CC for Pumps and Compressors; and through NSPS Subpart A for Blowdowns. 1) All flares have alarms indicating loss of ?ame that are in good working order. 2) The FCC catalyst regenerator exhaust is continously monitored for CO. 3) The catalytic cracking regenerator is tested annually for PM. Navajo has submitted an alternative monitoring plan (AMP) to comply with the FCC opacity monitoring requirement because the CCU has a wet scrubber which prevents continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CF 60 Appendix A Method 9. 6) Navajo continues to comply with all applicable requirements except for speci?c deviations as noted elsewhere in this document. IXI Continuous IXI Intermittent IXI Yes No Yes IXI N0 Recordkeeping: (1) Pilot ?ame monitoring records (2) CO CMS measurements l) and 2) Records are maintaned in Pi. 3), 5) and 6) Stack test, MACT, and NSPS records are maintained by the Navajo Environmental Department. IXI Continuous IXI Intermittent IXI Yes No Yes IXI N0 ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 54 of 144 EPA Inspection Report - Page 290 of 1969 Version 0225.15 (3) Copy of annual coke burn rate determination, stack test report, and opacity test report (4) None (5) Applicable NSPS Subpart requirements (6) Applicable NSPS K, NSPS Ka, NSPS Kb, or MACT CC for Tanks; through MACT CC for Loading Racks; through NSPS NSPS or MACT CC for Pumps and Compressors; and through NSPS Subpart A for Blowdowns requirements Re ortin The ennittee shall NSPS A, and MACT CC reports are Contlnuous Yes Yes accordance With applicable NSPS or submitted semiannual] MACT requirements and Section B110. y. El Interm?ttent No XI N0 A113 Facility: 20.2.38 NMAC El Continuous Yes El Yes A. 20.2.38 NMAC Intermittent N0 N0 Requirement: 20.2.3 8 NMAC (Hydrocarbon Storage Facilities, 1 1/3 0/95) applies to the re?nery as follows: 1. Section 109 (Tank Storage Associated with Petroleum Production or Processing Facility [Sour Hydrocarbon Liquids]) applies to the loading and storing of hydrocarbons containing H2S. 2. Section 110 (Tank Battery or Storage Facility - Within Municipality [Sour Hydrocarbon LiquidS]) applies to certain tanks storing sour hydrocarbon liquids whose vapors contain 324 HZS. 1) The Artesia Re?nery includes storage vessels that store hydrocarbons containing hydrogen sul?de. The vessels comply with the requirements of 20238109 by using submerged fill. 2) and 3) The vessels comply with the requirements of 20238.1 10 and 113 by using internal or external ?oating roofs with the required seals. ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 55 of 144 EPA Inspection Report - Page 291 of 1969 Version 02.25.15 3. Section 113 (New Tank Battery and the Pecos?Perrnian Interstate Air Quality Control Region [Sour Hydrocarbon Liquids]) applies to certain tanks storing sour hydrocarbon liquids whose vapors contain 324 HZS. (NSR 0195M35, Condition A113.A) Monitoring: 1 None continuous Yes YES 2. and 3. Demonstrated through NSPS K, 2) and 3) Navajo Inspection Department performs ?oating roof seal seal inspections and maintains those records. 11 erml en 0 0 inspection. Recordkeeping: Continuous IE Yes Yes 1: Records Of Tank dCSIgn showmg Inlet 1) Records of tank designs are maintained in the No No c0nnect10ns. Navajo Engineering Library. Reports required by 2. and 3. No additional requirements other 3110 are submitted as 1160655307- than applicable requirements of NSPS and MACT. Reporting: The permittee Shall report in Reports required by Bl 10 are submitted as continuous Yes Yes accordance with Section Bl 10. necessary. Intermittent N0 No A118 Facility: MACT Subpart Continuous El Yes Yes A. 40 CFR 63, Subpart FCC, Intermittent No No 70-CCR, SRUs l, 2,and 3 Requirement: The permittee shall comply with all applicable requirements of 40 CFR 63, Subpart National Emission Standards for Hazardous Air Pollutants for Petroleum Re?neries: Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units, for all affected sources shown in Tables attached. For the FCC, Navajo monitors and records the daily average coke burn rate and of the continuously monitored CO emissions. For the CCR, Navajo monitors and records the weekly average ChlorSorb catalyst inlet and outlet chloride content, the ChlorSorb inlet and outlet temperatures, and the CCR ?rebox temperature. For the SRUs, Navajo monitors and records the S02 concentration from the tail gas incinerators. ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 56 of 144 EPA Inspection Report - Page 292 of 1969 Version 02.25.15 (63.1560 and 63.1570). Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CF 63, Subpart For the FCC, Navajo monitors and records the daily average coke burn rate and of the continuously monitored CO emissions. For the CCR, Navajo monitors and records the weekly average ChlorSorb catalyst inlet and outlet chloride content, the ChlorSorb inlet and outlet temperatures, and the CCR ?rebox temperature. For the SRUs, Navajo monitors and records the $02 concentration from the tail gas incinerators. XI Continuous Intermittent Yes I: No I: Yes IZI N0 Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CF 63, Subpart Process records are maintained in Pi. Continuous Intermittent Yes I: No I: Yes IZI N0 Reporting: The permittee shall comply with the applicable reporting requirements of40 CFR 63, Subpart Reports required by Subpart were submitted semiannually as follows: 1/28/2016 7/28/2016 I: Continuous XI Intermittent Yes I: No I: Yes IZI No A119 40 CFR 61 Subpart FF. National Emission Standard for Benzene Waste Operations A. 40 CFR 61 Subpart FF, National Emission Standard for Benzene Waste Operations (Units subject in Table 103.C G) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 61, Subpart FF, National Emission Standard for Benzene Waste Operations for the affected sources in Tables 103.C, G. The refinery complies with the applicable requirements of NESHAP Subpart FF. Because the re?nery?s total annual benzene (TAB) quantity is less than 10 Mg/yr, none of the standards in this regulation apply. Navajo submitted the annual TAB report as follows: 04/07/2016 I: Continuous Intermittent IZI Yes I: No I: Yes No Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 61 Subpart FF. The refinery complies with the applicable requirements of NESHAP Subpart FF. Because the re?nery?s total annual benzene (TAB) quantity is less than 10 Mg/yr, none of the standards in this I: Continuous IZI Intermittent Yes El No I: Yes No ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 57 of 144 EPA Inspection Report - Page 293 of 1969 Version 02.25.15 regulation apply. Navajo submitted the annual TAB report as follows: 04/07/20 1 6 Recordkeeping: The permittee shall comply With the applicable recordkeeping requirements Records are maintained by Navajo Environmental Department. Continuous Intermittent EYes N0 DYes No ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 58 of 144 EPA Inspection Report - Page 294 of 1969 Version 02.25.15 t' Th 11 - epor . a .comp Navajo submitted the annual TAB report. Continuous IZI Yes Yes w1th the applicable reporting requirements of 40 CFR 61.357. 04/07/2016 Intermittent No No A201 Engines Continuous Yes Yes A. Maintenance and Repair Monitoring XI Intermittent N0 XI N0 (Units G-0100, G-0101, V-0543, V-0545, E-0600W, E-0601M, E- 0602E, E-0603, and Units 0100, (3?0101, V-0543, V-0545, E-0600W, E-0601M, E-0602E, E- Unit M-8010 was installed 11/04/2013. The engine 0603, and E-0901) was operated a total 2.5 hours during the reporting period. Requirement: These units are subject to Title since they are subject to NSPS and/or MACT requirements. No emission limits were established since their emissions are small. The permittee shall ensure these units are properly maintained and repaired. Monitoring: Maintenance and repair Continuous Yes Yes shall meet the minimum manufacturer's Intermittent 1:1 0 El 0 or permittee's recommended maintenance schedule. Activities that involve maintenance, adjustment, replacement, or repair of functional components with the potential to affect the operation of an emission unit shall be documented as they occur for the following events: Unit operating hours are monitored (1) Routine maintenance that takes a unit out of service for more than two hours during any twenty-four hour period. (2) Unscheduled repairs that require a unit ACC Form Part 1 Permit R2M1 Page 59 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 295 of 1969 Version 02.25.15 to be taken out of service for more than two hours in any twenty?four hour period. Recordkeeping: The permittee shall ElContinuous Eyes DYes maintain records in accordance with 'tM 8010' 't1 b1 Section B109, including records of ls eqmpe W1 ianon?resea crun- glutem?ttent . . . . . time meter. Navajo keeps quarterly rolling annual maintenance and repairs act1v1t1es and a a a total hours on ?le. copy of the manufacturer or permittee 5 recommended maintenance schedule. Reporting: The permittee shall report in Reports required by B110 are submitted as Continuous El Yes Yes accordance with Section B110. necessary. El Intermittent 1:1 N0 Kl N0 A201 Engines Continuous Yes I: Yes B. 40 CFR 63, Subpart 2222 (Units Intermittent El N0 N0 0100, v-0545, E-8010, E-0601M, E-0602E, E- 0603, and E-0901) (Units subject in Table #103] Navajo complies with Subpart Requirement: The units listed as subject in Table 103.] are subject to 40 CFR 63, Subpart and the permittee shall comply with all applicable requirements of Subpart A and Subpart Monitoring: The permittee shall comply 1:1 Continuous El Yes 1:1 Yes all applicable monltorlng and Navajo complies with Subpart Intermittent No No testing requirements of 40 CFR 63, Subpart A and Subpart Recordkeeping: The permittee shall 1:1 Continuous Kl Yes 1:1 Yes comply with all applicable recordkeeping requirements of 40 CFR 63, Subpart A and Navajo complies with Subpart Intermittent El N0 El N0 Subpart including but not limited to 63.6655 and 63.10. ACC Form Part 1 Permit R2M1 Page 60 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 296 of 1969 Version 02.25.15 Reporting: The permittee shall comply with all applicable reporting requirements of 40 CFR 63, Subpart A and including but not limited to 63.6645, 63.6650, 63.9, and 63.10. Reports required by Subpart were submitted semiannually as follows: 1/29/2016 7/28/2016 Continuous XI Intermittent El Yes No Yes XI No A201 Engines C. 40 CFR 60, Subpart 1111 (Diesel Engines subject in Table 103.] Requirement: The units listed as subject in Table 103.] are subject to 40 CFR 60, Subparts A and 1111 and shall comply with the noti?cation requirements in Subpart A and the speci?c requirements of Subpart Navajo complies with Subpart IIH. Continuous XI Intermittent XI Yes No I: Yes No Monitoring: The permittee shall comply with all applicable monitoring and testing requirements in 40 CFR 60, Subpart A and Subpart 1111, including but not limited to 60.4211. Navajo complies with Subpart 1111. Continuous XI Intermittent EYes Yes XI No Recordkeeping: The permittee shall comply with all applicable recordkeeping requirements in 40 CFR 60, Subpart A and Subpart 1111, including but not limited to 60.4214. Navajo complies with Subpart 1111. El Continuous XI Intermittent XI Yes No Yes El No Reporting: The permittee shall comply with all applicable reporting requirements in 40 CFR 60, Subpart A and Subpart 1111, including but not limited to 60.4214. Navajo complies with Subpart IIH. Continuous XI Intermittent XI Yes No Yes No A203 Tanks A. NSPS Subpart K, Standards of Performance for Storage Vessels for Petroleum Liquids for Which Navajo continues to comply with the applicable requirements of NSPS Subpart K, as applicable to the affected storage tanks shown in Table 103C of this permit, except for inspections listed as deviations previously submitted reports. External Continuous El Intermittent XI Yes No Yes No ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 61 of 144 EPA Inspection Report - Page 297 of 1969 Version 02.25.15 Construction, Reconstruction, or Modi?cation Commenced After June 11, 1973, and Prior to May 19, 1978 (Tanks subject in Table Requirement: The permittee shall comply with all applicable requirements of 40 CF 60, Subparts A for the affected sources in Table 103C. and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CF 60, Subpart K. Navajo continues to comply with the applicable requirements of NSPS Subpart K, as applicable to the affected storage tanks shown in Table 103C of this permit, except for inspections listed as deviations previously submitted reports. External and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. Continuous Intermittent Yes No Yes No Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart K. External and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. Continuous Intermittent Yes No Yes No Reporting: The permittee shall comply with the applicable reporting requirements of 40 CF 60, Subpart K. Navajo submits notifications of seal inspections to the Department. Continuous Intermittent Yes No Yes No A203 Tanks B. NSPS Subpart Ka, Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984 (Tanks subject in Table 103C) Navajo continues to comply with the applicable requirements of NSPS Subpart Ka, as applicable to the affected storage tanks shown in Table 103C of this permit, except for inspections listed as deviations previously submitted reports. External and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. Continuous Intermittent Yes BNO Yes No ACC Form Part 1 Permit P05 l?R2 R2M1 Ver 4.1 02/25/2015 Page 62 of 144 EPA Inspection Report - Page 298 of 1969 Version 02.25.15 Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A Ka for the affected sources in Table 103C. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart Ka. Navajo continues to comply with the applicable requirements of NSPS Subpart Ka, as applicable to the affected storage tanks shown in Table 103C of this permit, except for inspections listed as deviations previously submitted reports. External and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. Continuous IXI Intermittent IXI Yes El No Yes N0 Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart Ka. External and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. Continuous IXI Intermittent Yes No El Yes N0 Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart Ka. Navajo submits notifications of seal inspections to the Department. Continuous Intermittent IXI Yes El No Yes IXI N0 A203 Tanks C. NSPS Subpart Kb, "Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modi?cation Commenced After January 23, 1984" (Tanks subject in Table Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A Kb for the affected Navajo continues to comply with the applicable requirements of MACT Subpart CC as applicable to the processes shown in Table 103 B, C, D, G, except for deviations noted in semi?annual reports. Fugitive components subject to these rules are included in the Leak Detection and Repair (LDAR) program. Navajo uses a third?party contractor for the LDAR monitoring and recordkeeping. Navajo continues to comply with the applicable requirements of MACT Subpart CC as applicable to the affected storage tanks, except for inspections listed as deviations in this report. External and Continuous Intermittent ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Yes No El Yes N0 Page 63 of 144 EPA Inspection Report - Page 299 of 1969 Version 02.25.15 Ver 4.1 02/25/2015 sources in Table 1030 internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The loading rack subject to portions of MACT Subpart incorporated by reference into MACT CC is equipped with a carbon adsorption system monitored by a CMS. Fugitive components subject to these rules are El Continuous El Yes El Yes included in the Leak Detection and Repair (LDAR) program. Navajo uses a third?party contractor for IE Intermittent N0 N0 Monitoring: The permittee Shall comply the LDAR monitoring and recordkeeping. with the applicable monitoring and testing requirements of 40 CFR 60? Subpart Kb. The loading rack subject to portions of MACT Subpart incorporated by reference into MACT CC is equipped with a carbon adsorption system monitored by a CMS. cor dk 6 pin g: The permittee shall Navajo maintalns records at the Env1ronmental . El Continuous El Yes El Yes comply With the applicable recordkeeping of?ce, w1th the on-s1te LDAR contractor, and w1th . Holly Energy Partners (HEP) for the gasoline N0 IE N0 requirements of 40 CFR 60, Subpart Kb. loading rack. Reporting: The permittee shall comply Nag/aljlo submited Subpart CC reports semiannually El Continuous El Yes El Yes with the applicable reporting requirements as 23/122216 El Intermittent El NO No of 40 CFR 60, Subpart Kb. 8/29/2016 A203 Tanks Continuous Yes Yes Navajo maintains records at the Environmental D. MACT Subpart CC, ?National of?ce, with the on?site LDAR contractor, and with El Intermittent No IE N0 Emission Standards for Hazardous Air Holly Energy Partners (HEP) for the gasoline Pollutants from Petroleum Re?neries? loading YaCk- (Tanks subject in Table 103C) Requirement: The permittee shall comply El Continuous Yes El Yes With all applicable requirements Navajo maintains records at the Environmental Subpart CC, ?National Emission Standards of?ce, with the on?site LDAR contractor, and with El Intermittent No El No for Hazardous Air Pollutants from Holly Energy Partners (HEP) for the gasoline Petroleum Re?neries? for all affected loading raCk- sources shown in Table 103.C attached. ACC Form Part 1 Permit P051-R2 R2M1 Page 64 of 144 EPA Inspection Report - Page 300 of 1969 Version 02.25.15 (63.640). Monitoring: The permittee shall comply . . . . El Continuous Yes Navajo mamtams records at the Env1ronmental W1 app 10a mom oring an of?ce, with the on?site LDAR contractor, and with El Intermittent I: No El No testing requ1rements 0f 40 CFR 63 9 Holly Energy Partners (HEP) for the gasoline Subpart CC- loading rack. Recordkeeping: The permittee shall Navajo maintains records at the Environmental I: Continuous XI Yes Yes comply With the applicable of?ce, with the on-site LDAR contractor, and with recordkeeping requirements of 40 CFR HOUY Energy Partners (HEP) for the gasoline XI Intermittent No XI No 63.655. loading rack. Reporting: The permittee shall comply submited Subp art CC reports semiannually Continuous El Yes Yes with the applicable reporting requirements as 2/18/2016 IXI Intermittent I: No IXI No of 40 CFR 63.655. 8/29/2016 A203 Tanks IXI Continuous IXI Yes I: Yes IXI Intermittent I: IXI No E. Tank Throughput, Temperature, and VOC and H28 Limits (Units shown in Tables 106B C) Requirement: Compliance with the allowable throughput limits and emission Navajo complies thrOllgh Pi data. limits in Table 106D shall be demonstrated by not exceeding the rolling 12?month total throughput to the unit(s) of gallons per year (barrels/year) shown in Table 106D and not exceeding the allowable vapor pressure listed in Tables 106B C. Monitoring: The permittee shall monitor XI Continuous El Yes El Yes the total throughput, maximum Nava'o com lies throu Pi data. - temperature once per month and the vapor XI Intethtent I: N0 XI N0 pressure of each tank. Recordkeeping: The permittee shall Navajo complies through Pi data. XI Continuous XI Yes Yes record the total throughput of ACC Form Part 1 Permit Page 65 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 301 of 1969 Version 02.25.15 liquids and the vapor pressure of each IXI Intermittent tank. Each month, during the ?rst 12 months of monitoring, the permittee shall record the cumulative total liquid throughput and vapor pressure and after the ?rst 12 months of monitoring, the permittee shall calculate and record a rolling 12-month total liquid throughput and the vapor pressure of each tank. The permittee has calculated the VOCs and H28 annually based on the 12?month total. Tank breathing and working emissions were calculated using the USEPA Tanks program Version 4.0.9.d or more current. Emission rates computed using the same parameters, but with a different Department approved algorithm that exceed these values will not be deemed non-compliance with this permit. Records shall also be maintained in accordance with Section B109. Reporting: The permittee shall report in . . . 12' Continuous 12' Yes Yes . . Navajo comphes through P1 data. accordance w1th Section B110. IXI Intermittent El N0 IXI N0 ACC Form Part 1 Permit R2M1 Page 66 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 302 of 1969 Version 02.25.15 A204 Heaters/Boilers Continuous le Yes Yes Testing was performed as follows: A. Operational Inspection (All 01/07/2016 IXI Intermittent No IXI N0 heaters/boilers in Tables 103.E 104A) 01/07/2016 03/08/2016 03/08/2016 . . . H-0364 03/08/2016 Requirement: Compllance With the H-2421 08/16/2016 allowable emission limits in Table 106.A 03/09/2016 shall be demonstrated by performing H-3403 03/10/2016 periodic inspections to ensure proper All heaters were within allowable emission limits. operations. Monitoring: The permittee shall conduct Continuous IXI Yes Yes annual operational inspections to determine that the are . IXI Intermittent No IXI N0 . esting was performed as follows. operatmg properly. The operatlonal 01/07/2016 inspections shall include operational H-0020 01/07/2016 checks for indications of insufficient H-03 62 03/08/2016 excess air, or too much excess combustion 63 03/08/2016 air. These operational checks shall include H-03 64 03/08/2016 observation of common physical 08/16/2016 indications of improper combustion, H6402 03/09/2016 including indications specified by the H3403 03 /10/2,01,6 heater/boiler manufacturer, and indications All heaters were Within allowable em1ss1on limits. based on operational experience with the/these unit(s). Recordkeeping: The permittee shall Continuous El Yes Yes maintain records of operational IXI Intermittent No No inspections, describing the results of all operatlonal 1nspect10ns nOtmg Test reports are maintained by Navajo chronologlcally any adjustments needed to Environmental Department. bring the into compliance. The permittee shall maintain records in accordance with Section B109. ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 67 of 144 EPA Inspection Report - Page 303 of 1969 Version 02.25.15 Reporting: The permittee shall report in Continuous Yes Yes accordance w1th Sectlon B110. Intermittent N0 No Within ninety (90) days of permit issuance, the permittee shall submit for Department All testing reports were submitted to the approval a procedure which the permittee Department, will use to carry out the operational inspections. The permittee may at any time submit revisions for Department approval. A204 Heaters/Boilers {3 Continuous Yes Yes B. Periodic Emissions Tests (Units Heaters Intermittent N0 N0 H-0019, H-OOZO, H-0362, 0364, H-2421, H-3402, and H-3403) All testing reports were submitted to the De artment. Requirement: Compliance With allowable emission limits in Table 106.A shall be demonstrated by performing periodic emissions tests. (NSR 0195M35, Condition A204.A, revived) Monitoring: The permittee shall conduct (30110111110115 Yes Yes annual periodic portable analyzer emission Intermittent 0 0 tests or EPA Reference Method Tests for and CO. Test results that demonstrate compliance with the CO emission limits Shall also be Navajo complies with the requirements of Section considered to demonstrate compliance B111- with the VOC emission limits. Section B108 General Monitoring Requirements apply to this condition. The permittee shall meet the testing requirements in Section B1 1 1. ACC Form Part 1 Permit P051-R2 R2M1 Page 68 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 304 of 1969 Version 02.25.15 Recordkeeping: Records of periodic XIContinuous XlYes DYes emission tests shall include the ?ow rate IXI Intermittent No No and the stack gas exhaust temperature. If a combustion analyzer is used to measure NOX, CO, and/or excess air in the ?ue gas, records shall be kept of the make and model of the instrument and instrument calibration data. If an ORSAT apparatus Navajo complies with the requirements of Section or other gas absorption analyzer is used, 3103, 13110, and B111. the permittee shall record all calibration results. Records shall be kept of all raw data used to determine ?ue gas ?ow and of all calculations used to determine ?ow rates and emission rates. The permittee shall maintain records in accordance with Section B109, B110, and B111. Reporting: The permittee shall summarize Continuous Yes Yes in tabular form the results of the initial or subsequent periodic emissions tests for IZI Intermittent No No NOX and CO, specifying the mass . . . . Navajo complies w1th the requirements of Section em1ss1ons rates in pounds per hourB103, B110, and B111. All reports were ta a inc average submitted to the Department. concentration of all relevant pollutant species. The permittee shall report in accordance with Section B109, B1 10, and B111. A204 Heaters/Boilers XI Continuous El Yes IXI Yes IE Intermittent IXI No No C. Summary of Compliance Methods for Heaters and Boilers for Table 106. A, Navajo complies with these requirements, except 20.2.33 NM AC, 20.2.37 NM AC (Boilers f?r deviatiotrlis previously reported or identi?ed at and Heaters in Tables 103.E and 104A) 6 end 0ft ls report. Requirement: (NSR 0195M35, ACC Form Part 1 Permit R2M1 Page 69 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 305 of 1969 Version 02.25.15 Condition A204.B) (1) Demonstrate compliance with Table 106A Allowable Emissions. (2) 20.2.33 NMAC (Gas Burning Equipment Nitrogen Dioxide, 10/31/02) applies to existing and new gas burning equipment having a heat input of greater than 1,000,000 million British Thermal Units per year. It applies to process heaters identi?ed in Tables 103.E and 104A. These units shall be equipped with burners emitting less than 0.2 lb NOX per MM Btu. Compliance with 20.2.33 NMAC is demonstrated by compliance with the NOX lb per MM Btu limits in Table A106.A. Monitoring: Continuous Yes El Yes (1) The permittee shall monitor the fuel usage of the all boilers and heaters. The IXI Intermittent El N0 El N0 fuel usage shall be monitored for speci?c heaters and boilers subject to 20.2.33 1) Fuel use measured by pi. NMAC. 2) Re?nery fuel gas is analyzed at least once per (2) For speci?c heaters and boilers subject gel-31:3 to response for Section A1 00. A to 20'2?33 the Shall 4) No combustion sources ?re only purchased gas. collect and analyze samples ofthe re?nery 5) The following combustion sources have CMS fuel gas at least once per week. The that are recerti?ed annually as follows: re?nery fuel gas analysis shall include the 07/ 13/2016 composition of the re?nery fuel gas, the B-0008 07/ 13/2016 07/14/2016 gross heating value7 and the net heating 13-0009 10/07/2015 (Initial compliance Test) value. H-9851 07/14/2016 03/10/2016 (3) See Condition A110.A for HZS monitoring requirements. (4) All process heaters and boilers shall ?re only re?nery gas in accordance with ACC Form Part 1 Permit Page 70 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 306 of 1969 Version 02.25.15 Application, Section 2, Table 2-1. (5) For those combustion sources required to have a continuous monitoring system (CMS) (listed in below), the permittee shall install, certify, calibrate, maintain, and operate the CMS for each required pollutant in accordance with the applicable requirements of 40 CFR 60 or 63. The hourly average CMS data, the re?nery fuel gas usage data, and the re?nery fuel gas composition data shall be used to estimate the actual emission rates. The following CMS shall be recerti?ed annually: 0 Boiler NOX and 02 CMS - Boiler NOX and O2 CMS 0 Boiler NOX and O2 and CO2 CMS 0 H-9851 NOX O2 CMS - H-2501 NOX O2 CMS (6) For those combustion sources required to conduct periodic stack exhaust testing as stated in Condition A204.B, the test reports shall be used to demonstrate compliance with the NOX, CO, and VOC limits in Table 106A. (7) For those units and pollutants that are not required to have a CMS or a periodic stack test, (Units H-009, 1, H- 0018, H-0030, H-0040, H-0312, H-0352, H-0353, H-0354, H- 0355, H-0600, ACC Form Part 1 Permit R2M1 Page 71 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 307 of 1969 Version 02.25.15 H-0601, H-8802, and H-3101) the permit application emission factor, the fuel usage, and the re?nery fuel gas analysis shall be used to calculate the emission rates of NOX, CO, VOC, and PM. (8) Compliance with the particulate emission limitation set forth in 20.2.37.202.A NMAC shall be determined as speci?ed in NMAC. Combustion of only gaseous fuel has been approved by the Department as the compliance method under NMAC. Recordkeeping: The permittee shall maintain the following records: (1) By March 3 the annual fuel usage for all boilers and heaters for the previous calendar year. (2) By March 31, the average fuel composition and heating value for all boilers and heaters for the previous calendar year. (3) For those units required to have a CMS B-0009, H-9851 and H-2501), the CMS hourly average data. (4) For those units required to conduct periodic stack exhaust testing, the periodic test report. (5) For all boilers and heaters, a summary spreadsheet shall be maintained comparing the actual annual emissions with the allowable emission limits expressed in 1) Fuel usage records are maintained in Pi. 2) Fuel composition records are maintained in Pi. 3) CMS data is maintained on Pi. 4) Test reports are maintained by Navajo Environmental Department. 5) The summary spreadsheet is included in the Emission Inventory. Continuous Intermittent Yes No El Yes No ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 72 of 144 EPA Inspection Report - Page 308 of 1969 Version 02.25.15 tons per year and lb/MMBtu using the appropriate method of compliance demonstration. This spreadsheet shall be updated by March 31 of each year for the previous calendar year. . . . . Continuous Yes Yes Rep The shall report 1n Reports required by B110 are submitted as accordance w1th Sectlons B110. necessary. Intermittent N0 N0 A204 Heaters/Boilers IE Continuous Yes Yes Intermittent No No D. Consent Decree NOX Emission Limits for Boilers B-0007, and B-0009 (new as of 2013) Requirement: (N SR 0195M3 5, Condition A204.C) (1) In accordance with the Consent Decree lodged December 20, 2001, NOX emissions from boilers (no later than December 31, 2002), (no later than December 31, 2003), and B-0009 (new as of 2013) shall not exceed the limit in Table 106A during any hourly rolling 3?hour period. Demonstration of compliance with the NOX limit for B-0008, and 0009 shall be established by averaging the CMS Data over any 3-hour period and comparing the average concentration to the parametric limit of 42.1 corrected to 6.1% as determined by the CMS. (CD1116.D) This also satis?es the requirement in 20.2.33 . 1 08A NMAC that emissions 1) No heaters or boilers subject to this requirement. 2) Initial performance testing completed. 3) NOX is measured in weekly using a portable analyzer. ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 73 of 144 EPA Inspection Report - Page 309 of 1969 Version 02.25.15 shall not exceed 0.2 (2) Navajo is authorized to operate all three boilers (B-0007, and 0009) simultaneously as needed. Monitoring: For the Controlled Boilers as listed in the Consent Decree and B-0009 (new as of 2013), continuous compliance with their respective permit emissions limits shall be demonstrated by monitoring as follows: (1) For boilers B-0008, and B- 0009) with a heat input capacity greater than 150 of HHV, the permittee shall install or continue to operate CMS to measure and 02. Each CMS shall be installed, certi?ed, calibrated, maintained, and operated in accordance with the requirements of 40 CFR 60.11, 60.13, and Part 60 Appendix A and the applicable performance speci?cation test of 40 CFR Part 60 Appendices and F. These CMS shall be used to demonstrate compliance with emission limits. The permittee shall make CMS and process data available to the applicable Federal and State Agencies upon demand as soon as practicable; 1) No heaters or boilers subject to this requirement. 2) Initial performance testing completed. 3) NOX is measured in weekly using a portable analyzer. Continuous Intermittent IXI Yes No Yes IXI No Recordkeeping: The permittee shall keep records of the CMS recertification?s monitored in Condition A204.B, Summary of Compliance. Navajo complies with A204.B, Continuous Intermittent Yes No Yes IXI No ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 74 of 144 EPA Inspection Report - Page 310 of 1969 Version 02.25.15 Reporting: The permittee shall report in accordance with Section B110. Navajo complies with A204.B. IXI Continuous Intermittent XI Yes No Yes No A204 Heaters/Boilers E. NOX Monitoring and Testing for Controlled Heaters Subject to the Consent Decree (Units H-0020, H-0352, H-0353, H-0600, and Requirement: For the Controlled Heaters as listed in the Consent Decree, continuous compliance with all NOX emissions limits shall be demonstrated by monitoring as follows. (NSR 0195M35, Condition A204.D) Refer to the Monitoring section below. El Continuous Intermittent Yes No Yes No Monitoring: (1) For heaters with a heat input capacity of equal to or less than 150 (HHV) but greater than 100 (HHV), Navajo shall install or continue to operate CMS to measure NOX and Oz by no later than the date of the installation of the applicable NOX Control Technology on the heater or boiler; or submit for EPA approval, by no later than 60 days after the date of installation of the applicable NOX Control Technology on the heater or boiler, a proposal for monitoring based on operating parameters, including but not limited to, ?rebox 1) H-9851 is equipped with and O2 CMS that is certi?ed, calibrated, maintained and operated in accordance with the referenced requirements. 2) is equipped with NOX and 02 CMS. Navajo discovered that while the operating parameters of ?rebox temperature and combustion 02 where monitored for Heaters these parameters have not been used as a means of monitoring performance. 3) Referenced heaters were initially tested and are tested annually. is monitored weekly using a handheld portable analyzer. XI Continuous XI Intermittent XI Yes No Yes No ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 75 of 144 EPA Inspection Report - Page 311 of 1969 Version 02.25.15 temperature, air preheat temperature, heat input rate, and combustion 02. Navajo shall evaluate the necessity of using ?rebox or bridgewall temperatures and additional operating parameters and agrees to use such parameters as a means of monitoring performance Where Navajo and EPA mutually-agree to their effectiveness. (CD111 6.C.ii). As of January 23, 2014 (notarized date of application), there are no heaters or boilers at the Artesia Re?nery with a capacity of equal to or less than 150 (HHV) but greater than 100 (HHV) subject to Monitoring requirement (1). (2) For heaters With a heat input capacity of equal to or less than 100 of HHV, the permittee shall conduct an initial performance tests for NOX. The results of these tests shall be reported based upon an average of three (3) one?hour testing periods and shall be used to develop representative operating parameters for each unit, which will be used as indicators of compliance. (CD111 This condition applies to the following heaters: 0 Heaters and 0 Heater 0 Heaters H-0600 and The permittee has completed all of the initial performance tests. ACC Form Part 1 Permit R2M1 Page 76 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 312 of 1969 Version 02.25.15 (3) For heater H-0601 compliance shall be demonstrated by continuously monitoring stack oxygen (02) to maintain a 3-hour average below 6.0 vol%. As a further check of compliance, Navajo shall monitor stack at least twice a month using a portable analyzer to assure that the measured value does not exceed the compliance threshold of 38 dk . Continuous IXI Yes Yes ecor eeplng: IXI Intermittent No IXI No (1) The permittee shall keep records of the Fuel ?ring rates and Sulfur limits monitored for Condition Al 10 A 1) Fuel ?ring rate records are maintained in Pi. 2) and 3) Test records are maintained by the Navajo Environmental Department. (2) The permittee shall keep records of the initial performance tests. (3) The permittee shall keep records of the stack oxygen monitoring and the portable analyzer tests. Reporting: The permittee shall report in g] Continuous g] Yes Yes accordance With Section B1 10. Condition Reports required by B110 are submitted as does not apply to portable applicable. Kl Interm?ttent No IE N0 analyzer tests. A204 Heaters/Boilers IE Continuous IE Yes Yes F. Monitoring and Testing for Ellntermittent DNO EINO Heaters permitted after the Consent Decree (Units Heaters H-0019, H-0362, H-0363, H-0364, H'3403v Navajo complies with these requirements. 2501, and H-9851) Requirement: For the Heaters permitted after the Consent Decree, continuous compliance with their respective ACC Form Part 1 Permit P051-R2 R2M1 Page 77 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 313 of 1969 Version 02.25.15 permit emissions limits in Table 106.A shall be demonstrated by monitoring as follows. (NSR 0195M35, Condition A204.E) Monitoring: Continuous Yes El Yes (1) For heaters with a heat input capacity Intermittent El 0 No greater than 150 MM Btu/hr (LHV Basis), the permittee shall install and operate CMS to measure and 02 by the startup date of each heater. Each CMS shall be installed, certi?ed, calibrated, maintained, and operated in accordance with the requirements of 40 CFR 60.11, 60.13, and Part 60 Appendix A and the applicable performance speci?cations of 40 CFR Part 60 Appendices and F. These CMS shall be used to demonstrate compliance with emission limits. The permittee Shall make CMS and process 1), 2), 3), and 4) Navajo complies with these data available to the applicable Federal and requirements. State Agencies upon demand as soon as practicable. Condition 1) applies to heater (2) For heaters with a heat input capacity of equal to or less than 150 MM Btu/hr (LHV) but greater than 100 MM Btu/hr (LHV), Navajo shall: install and operate CMS to measure NOX and 02 by the startup date of each heater; or submit to the Permit Program Manager for NMED approval, by no later than 90 days after the startup date of each heater, a proposal for ACC Form Part 1 Permit P051-R2 Page 78 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 314 of 1969 Version 02.25.15 monitoring based on operating parameters. Operating parameters to consider include, but are not limited to, ?rebox temperature, air pre?heat temperature, heat input rate, and combustion Oz. Navajo agrees to use such parameters as a means of monitoring performance. Condition applies to heaters and (3) For heaters with a heat input capacity of equal to or less than 100 MM Btu/hr (LHV basis), the permittee shall conduct an initial performance test by no later than 180 days after the startup date. The results of this test shall be reported based upon an average of three (3) one-hour testing periods and shall be used to develop representative operating parameters for each unit, which will be used as indicators of compliance. This condition applies to the following heaters: . Heaters H-0362, H-0363, 0364, and H-2421 0 Heater H-0019 0 Heaters H-3402 (AMP approved by EPA, see initial performance test completed on July 10, 2013 0 Heater H-3403, initial performance test completed on April 30, 2013 (4) US EPA has approved an Alternative ACC Form Part 1 Permit Page 79 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 315 of 1969 Version 02.25.15 Monitoring Plan (AMP) for Unit for utilizing the oxygen monitor on the Unit 34 Hydrocracker Reboiler as a parametric means for demonstrating compliance with NSPS Ja, monitoring Via a CMS. In accordance with the AMP, the permittee shall accomplish the following: Install ?ow indication on the fuel line to provide historical data of the ?le] to the Mild Hydrocracker (Unit 34) by January 2015. Monitor the process historical data of the HEP purchased natural gas pressure, and the high pressure ?Jel balance drum (D-0770). Upgrade the existing the Mild Hydrocracker (Unit 34) Reboiler Heater oxygen monitor to perform daily calibrations as required in 40 (Note that the sample placement does not conform to CMS requirements for process reasons). Conduct biennial performance tests according to the requirements in 40CFR Establish a maximum or curve excess 02 operating limit (MOPV) as required under 40 utilizing the existing monitor. Include Reboiler Heater (H-3402) ACC Form Part 1 Permit R2M1 Page 80 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 316 of 1969 Version 02.25.15 hours of re?nery fuel gas usage and any deviations during such time as required by 40 CFR 60.7 for periodic reporting. dk . IZI Continuous IZI Yes El Yes eeplng: IZI Intermittent No No The permittee shall keep records of the monitoring proposals submitted to the Permit Program Manager for approval and whether the submittal was approved. (2) The permittee shall keep records of the CMS data, calibration, and recerti?cation?s monitored in Condition A204.A, Summary of Compliance. Navajo complies with these requirements. (3) The permittee shall keep records of the performance tests. (4) The permittee shall keep records of the implementation of the AMP and all required monitoring speci?ed in the AMP. Reporting: The permittee shall report in Reports required by B110 are submitted as IE Continuous IE Yes Yes accordance with Section Bl 10. applicable- IE Intermittent No No A204 Heaters/Boilers IE Continuous IE Yes El Yes Intermittent No IZI No G. NSPS Subpart Db, Standards of Performance for Industrial-Commercial- (Boilers and heater subject in Table 103E) 0009 each have a NOX CEMS as required by NSPS Subpart Db. Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A Db SOz-60.42b, for the ACC Form Part 1 Permit Page 81 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 317 of 1969 Version 02.25.15 affected sources in Table 103.E. :Th 'tt - :n (12:3:an Heater H-2501 and Boilers 13?0007, and B- Contlnuous Yes requirements of 40 CFR 60. 4 8b, Subpart 0009 each have a CEMS as required by NSPS Intermittent N0 No Subpart Dbecor eeplng . permi ee .21 NOX records are maintained in Pi. Test records are Continuous Yes Yes comply the app 11cable recordkeeping maintained the Nava'o Environmental requirements of 40 CFR 60.49b, Subpart No N0 epartment. Db. - .The permittee all. comply Subpart Db reporting is in the Navajo Subpart A Continuous Yes Yes w1th the applicable reporting requirements re or ts of 40 CFR 60.49b, Subpart Db. Intermittent N0 '2 N0 Compliance Test: The permittee shall El Continuous El Yes El Yes comply with the methods and procedures Navajo complies with the requirements of the stipulated in 40 CFR 60, Section 60.45b Compliance Testing. El Intermittent El N0 N0 and 60.46b. A204 Heaters/Boilers El Continuous Yes El Yes H. NSPS Subpart Dc, Standards of Intermittent El N0 N0 Performance for Small Industrial- Commercial - Institutional Steam Generating Units (Boilers and heater subject in Table 103.13,) Navajo complies with the requirements of steam generating units. Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A Dc S02-60.42c, for the affected sources in Table 103.E. Monitoring: The permittee shall comply El Continuous Yes El Yes with the applicable monitoring and testing Navajo complies with the requirements of steam Intermittent N0 N0 requirements of 40 CFR 60.47c, Subpart generating unitS~ Dc. ACC Form Part 1, Permit Ver 4.1 02/25/2015 Page 82 of 144 EPA Inspection Report - Page 318 of 1969 Version 02.25.15 A204 Heaters/Boilers I. NSPS Subpart J, Standards of Performance for Petroleum Re?neries (Boilers and heater subject in Table 103 .E) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A for the affected sources in Table 103.E. recovery units, and the FCC shown in Table 103E. The re?nery fuel gas is continuously monitored for H28 content on a 3?hour rolling average basis. The ?ares met the minimum heating value, tip velocity, and visible requirements as documented by the compliance testing detailed in previous responses. The two sulfur recovery unit tail gas incinerators are continuously monitored for $02 content, corrected to 0% 02, on a 12-hour rolling average basis. The FCCU Catalyst Regenerator Scrubber exhaust is continuously monitored for $02 and CO. PM is monitored annually. Navajo has submitted an alternative monitoring plan (AMP) to comply with the FCC opacity monitoring requirement because the FCCU has a wet scrubber which prevents ACC Form Part 1 Permit Ver 4.1 02/25/2015 Recordkeeping: The permittee shall Continuous Yes Yes comply With the applicable recordkeeping Navajo complies with the requirements of steam requirements of 40 CFR 60.480, Subpart generating units. El N0 N0 D0. Reporting: The permittee shall comply Continuous Yes Yes reportmg Navajo complies with the requirements of steam Intermittent No No requ1rements of 40 CFR 60.480, Subpart generating units. Dc. Compliance Test: The permittee shall Continuous Yes El Yes comply with the methods and procedures Navajo complies with the requirements of steam . . . . . Int tt nt stipulated in 40 CFR 60, Sectlon 60.440 generatmg unltS- em? 6 El 0 0 and 60.450. Navajo continues to comply with the applicable El Continuous El Yes El Yes monitoring requirements of NSPS Subparts and Ja as applicable to the affected heaters, boilers, sulfur El Intermittent No El No Page 83 of 144 EPA Inspection Report - Page 319 of 1969 Version 02.25.15 continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CFR 60 Appendix A Method 9. Monitoring: The permittee shall comply IE Continuous IE Yes Yes the monltorlng and All of the continuous monitors are operated, IE Intermittent No IE N0 requ1rements Of 40 CFR 60? maintained, and certi?ed as required. Subpart J. Recordkeeping: The permittee shall IE Continuous IE Yes Yes comply With the applicable Records are maintained by Navajo Environmental . . I tt recordkeepmg requlrements of 40 CFR Department and 011 Pl60, Subpart J. Re ortin The ermittee shall com 1 - . . . . Reports required by Subpart and A are submitted Contmuous IE Yes Yes With the applicable reporting requirements as necessa of 40 CFR 60, Subpart J. Intermittent N0 No ACC Form Part 1 Permit Page 84 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 320 of 1969 Version 02.25.15 A204 Heaters/Boilers J. NSPS Subpart a, Standards of Performance for Petroleum Re?neries for which Construction, Reconstruction, or Modi?cation Commenced After May 14, 2007 (Boilers and heater subject in Table Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A a for the affected sources in Table 103.E. Navajo continues to comply with the applicable monitoring requirements of NSPS Subparts and a as applicable to the affected heaters, boilers, sulfur recovery units, and the FCC shown in Table 103E, except for deviations included in this report. The refinery fuel gas is continuously monitored for H2S content on a 3?hour rolling average basis. The ?ares met the minimum heating value, tip velocity, and visible requirements as documented by the compliance testing detailed in previous responses. The two sulfur recovery unit tail gas incinerators are continuously monitored for 802 content, corrected to 0% 02, on a 12?hour rolling average basis. The FCCU Catalyst Regenerator Scrubber exhaust is continuously monitored for 802 and CO. PM is monitored annually. Navajo has submitted an alternative monitoring plan (AMP) to comply with the FCC opacity monitoring requirement because the FCCU has a wet scrubber which prevents continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CFR 60 Appendix A Method 9. Continuous Intermittent Yes No Yes No Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart a. All of the continuous monitors are operated, maintained, and certified as required. Continuous Intermittent Yes No Yes No Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart a. Records are maintained by Navajo Environmental Department and on Pi. Continuous Intermittent Yes No Yes No Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart a. Reports required by Subpart a are submitted as necessary. Continuous Intermittent Yes No Yes No ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 85 of 144 EPA Inspection Report - Page 321 of 1969 Version 02.25.15 A204 Heaters/Boilers Continuous Yes Yes El Intermittent No El No K. BACT Limit, Continuous Monitoring System (CMS) (Unit Navajo complies with the BACT requirements for except for deviations previously reported Requirement: The perrnittee shall comply or identi?ed at the end of this report. . with the allowable emission limits in Table 106A and Condition A106.E that represent BACT limits for the BACT requirements. (NSR 0195M3 5, Condition A2041 and revised) Monitoring: Continuous El Yes Yes (1) The Perrnittee shall comply with the Intermittent IE No No CMS monitoring as detailed in Condition went into service on 4/14/2015. The initial (2) The permittee shall an EPA RATA compliance test was completed on Method test Within six (6) months of 11/06/2015, except for deviations previously permit issuance using EPA reference test reported or identi?ed at the end of this report. . methods and C02. Data from the CMS RATA testing may be used to satisfy this testing requirement. Recordkeeping: continuous Yes Yes . I 'tt (1) The permittee shall keep records CMS initial calibration and recerti?cation Navajo complies With A2043. The initial monitored in Condition A204.B, Summary compliance test was completed on 11/06/2015. of Compliance. (2) Records of EPA Methods tests shall be maintained for the Boiler. Reporting: Navajo complies with B110. The initial compliance Continuous Yes Yes test was completed on 11/06/2015, except for The permittee shall report in deviations previously reported or identi?ed at the Intermittent N0 El N0 accordance with Section B110, to include end of this report. . ACC Form Part 1 Permit P051-R2 R2M1 Page 86 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 322 of 1969 Version 02.25.15 the CMS initial calibration and recerti?cation. (2) The permittee shall summarize in tabular form the results of the EPA Methods tests for and 02 and C02, specifying the emissions rates in pounds per hour and lb/MMBtu. The table shall include the average concentration of all relevant pollutant species. ACC Form Part 1 Permit P05 l?R2 Page 87 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 323 of 1969 Version 02.25.15 A204 Heaters/Boilers IXI Continuous IXI Yes Yes IXI Intermittent No IXI No L. MACT Subpart Industrial, Commercial, and Institutional Boilers and Process Heaters (Boilers and heater subject in Table 103.13) Navajo performs the annual tune up required by MACT Subpart published 1/31/2013. Requirement: The units are subject to 40 CFR 63, Subpart and the permittee shall comply with the applicable requirements of 40 CFR 63, Subpart A and Subpart Monitoring: The permittee shall comply . Continuous IXI Yes Yes with all applicable monitoring and testing NaVajO perfOrmS the annual tune up reqmred by IXI . . Intermittent No IXI No requirements Of40 CFR 63, Subpart A and MACT Subpart published 1/31/2013. Subpart Recordkeeping: The permittee shall El Continuous IXI Yes El Yes comply with the applicable recordkeeping Records are maintained by Navajo Environmental requirements of 40 CFR 63, Subpart A and Department. IXI N0 IXI N0 Subpart Reporting: The permittee shall comply Subpart reports were submitted semi- Continuous Yes Yes with the applicable reporting requirements annually as follows: of 40 CFR 63, Subpart A and Subpart 01/28/2016 Intermittent No No 07/28/2016 A204 Heaters/Boilers IXI Yes Yes Intermittent No IXI No M. EPA Methods Test (Unit B-0009) . Navajo complies with A204.K. The initial Requirement: Compllance CO compliance test was completed on 11/06/2015. BACT Limit and allowable emission limits in Table 106A shall be demonstrated by emissions tests ensuring the unit is operating correctly and within desired ACC Form Part 1 Permit R2M1 Page 88 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 324 of 1969 Version 02.25.15 parameters. (NSR 0195M35, Condition A204.K and revised) Monitoring: The pennittee shall conduct [3 IXI Yes Yes an EPA Method test no later than 180 days IXI Intermittent [3 N0 IXI N0 after permit issuance us1ng EPA reference testmethods 1_n 49 CFR .60? Navajo complies with A204.B. The initial testing 15 requ1red for CO- Test compliance test was completed on 11/06/2015. results that demonstrate compliance with the CO emission limits shall also be considered to demonstrate compliance with the VOC emission limits. Recordkeeping: Records of EPA Methods Navajo complies with A204.B. The initial [3 continuous IXI Yes Yes tests shall be maintained for the Boiler. compliance test was completed on 11/06/2015. [Xi Intermittent [3 No No Reporting: The permittee shall report in [3 Continuous Yes I: Yes accordance with the requirements of Section B111.D and summarize in tabular form the results of the EPA Methods test Reports required by B111.D are submitted as for CO, specifying the emissions rates in applicable. pounds per hour. The table shall include the average concentration of all relevant pollutant species. Intermittent No IXI No A204 Heaters/Boilers [3 Continuous XI Yes [3 Yes N. Veri?cation of Energy Ef?ciency IXlIntermittent BACT Control Requirements (Unit B- 0009) Navajo complies with these conditions. The initial Requirement: The permittee Shall comply compliance test was completed on 11/06/2015. with the allowable emission limits and the following BACT requirements. (NSR 0195M35, Condition A204.L and revised) 1. Operation and Maintenance (BACT ACC Form Part 1 Permit P051-R2 R2M1 Page 89 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 325 of 1969 Version 02.25.15 a. Periodic Boiler Tuning The boiler shall be tuned annually to maintain optimal thermal ef?ciency. b. Periodic Boiler Inspection and Repair for air leakage The boiler shall be inspected annually to maintain optimal thermal ef?ciency. 0. Periodic Boiler Inspection and Cleaning for tube fouling The boiler shall be inspected annually and necessary cleaning performed to prevent tube fouling. Next Generation Ultra?low-NOX high ef?ciency burners (NGULNB) shall be installed in the boiler design. Flue gas economizer (BACT A heat exchanger shall be installed to recover heat from the exhaust gas to preheat incoming boiler feedwater to attain industry standard performance (IMO) for thermal ef?ciency. Boiler insulation (BACT The boiler shall be designed and installed With boiler insulation to an optimum insulation thickness and material to achieve maximum energy ef?ciency. The OMP shall include the insulation ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 90 of 144 EPA Inspection Report - Page 326 of 1969 Version 02.25.15 design and maintenance schedule. 5. Oxygen Trim Control (BACT An Oxygen Trim Control system shall be designed and installed on the boiler to monitor oxygen concentration in the ?ue gas, and the inlet air ?ow is adjusted to maximize thermal ef?ciency. 6. Boiler blowdown minimization using manual analysis (BACT The Operation and Maintenance Plan (OMP) shall include methods and procedures to minimize blowdowns from the boiler to keep emissions at a minimum. 7. Condensate recovery (BACT Condensate shall be recovered as represented in the application to achieve maximum energy ef?ciency. Condensate recovery shall be maximized through annual steam trap inspections and repairs. Monitoring: The Permittee shall develop an Operation and Maintenance Plan (OMP) to include at least the requirements listed above within 12 months of commencement of operations. The Permittee shall review the OMP annually to ensure it?s effectiveness in meeting the requirements above and recommend changes. Navajo complies with these conditions. The initial compliance test was completed on 11/06/2015. El Continuous Intermittent KI Yes No Yes No Recordkeeping: (1) Records demonstrating compliance with the energy ef?ciency requirement Navajo complies with these conditions. Continuous Intermittent IXI Yes No Yes IXI N0 ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 91 of 144 EPA Inspection Report - Page 327 of 1969 Version 02.25.15 shall be recorded and summarized in the OMP. (2) The Permittee shall maintain a copy of the OMP onsite and available for inspection. Reporting: Continuous IXI Yes El Yes (1) The permittee shall notify the Intermittent NO No Department when the OMP has been prepared and available for review. Navajo complies with these conditions. Reports (2) The permittee shall report in the semi- required by B110 are submitted as applicable. annual report a summary of actions covered in accordance with the OMP, and in accordance with Section B110. A204 Heaters/Boilers Continuous Yes Yes 0. Periodic Emissions Tests (Unit B-009, Intermittent N0 N0 co BACT Limit) Navajo complies with these conditions. The initial com liance test was com leted on 1 1/06/2015. Requirement: Compliance With the CO BACT Limit and allowable emission limits in Table 106A shall be demonstrated by performing periodic emissions tests. Monitoring: The permittee shall conduct El Continuous Yes Yes periodic portable analyzer emission tests Intermittent NO No or EPA Reference Method Tests for CO at the intervals in the following schedule: First Test in accordance with the schedule in Section Bl Navajo complies with these conditions. The initial Second Test ??six (6) months after the compliance test was completed on 1 1/06/2015. ?rst test is completed. All subsequent testing shall be done annually. Section B108 General Monitoring Requirements apply to this condition. ACC Form Part 1 Permit P051-R2 Page 92 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 328 of 1969 Version 02.25.15 The permittee shall meet the testing requirements in Section B111. Recordkeeping: Records of periodic DCOHtm?lous .Yes emission tests shall include the boiler fuel Intermittent 0 0 ?ow rate and the stack gas exhaust temperature. If a combustion analyzer is used to measure CO, and/or excess air in the ?ue gas, records shall be kept of the make and model of the instrument and instrument calibration data. If an ORSAT Navajo complies with these conditions. The initial apparatus or other gas abSOrptiOD analyzer compliance test was completed on 11/06/2015. is used, the permittee shall record all calibration results. Records shall be kept of all raw data used to determine ?ue gas ?ow and of all calculations used to determine ?ow rates and emission rates. The permittee shall maintain records in accordance with Section B109, B110, and B111. Reporting: The permittee shall summarize Continuous Yes Yes in tabular form the results of the initial or subsequent periodic emissions tests for CO, specifying the mass emissions rates in pounds per hour. The table shall include the average concentration of all relevant pollutant species. The permittee shall report in accordance with Section B109, B110, and B111. Intermittent 0 No Reports required by B109, B110, and B111 are submitted as applicable. ACC Form Part 1 Permit R2M1 Page 93 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 329 of 1969 Version 02.25.15 A206 Flares IE Continuous IE Yes Yes A. Intermittent No No Requirement: (N SR 0195M3 5 Condition A206, A) 1) FL-0403 is equipped with a ?are . . alarm. (1) An alarm system in good working order Shall be 00111160th Flare FL-0403 2) The fuel gas required to provide supplemental Which will signal non-combustion of the heat to either Flare or is gas. monitored during acid gas ?aring by a ?ow meter. (2) The acid gas ?ow meter for ?are No acid gas ?aring has occurred since September 5, 0400 or shall be operated and 2006' calibrated at a frequency and by the procedure speci?ed by the manufacturer. A chart recorder or data logger (electronic storage) shall continuously record the amount of gas measured by the ?ow meter. Monitoring: The fuel gas required to Continuous Yes El Yes provide supplemental heat to either Flare El Intermittent No N0 FL-0400 or FL-0403 as required under A105.B shall be monitored during ?aring by a ?ow meter. The ?ow meter shall be operated contlnuously 24 hours per day, 3 65 days The fuel gas required to provide supplemental heat Payee? except for P?rlods Of ?ow meter to either Flare FL-0400 or FL-O403 is monitored malntenance Of repalr. during acid gas ?aring by a ?ow meter. The upper range of the ?ow meter shall be suf?cient to record the highest expected ?ow rate of fuel gas sent to ?are. The reading of this ?ow meter and the ?ow meter to measure acid gas ?ow as required under Condition A105.B shall be ACC Form Part 1 Permit Page 94 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 330 of 1969 Version 02.25.15 used to determine compliance with emission limits at A106.C. Recordkeeping: (1) Records of all periods commuous Yes Yes of operation during which the ?are pilot Intermittent No No ?ame is absent as included in the MACT subpart CC semi-annual reports. 1) Flare pilot outages are included in the MACT CC semiannual reports dated as follows: (2) Records of the quantity of 02/18/2016 supplemental fuel used during each acid 08/29/2016 gas ?aring incident to provide 1) and 2) Records of supplemental fuel use and supplemental heat to ?are or ?are ?are ?am? are maintained in Pi- FL-0403. (3) The permittee shall maintain records from the ?ow meter of the amount of gas sent to the ?are. 1 Flare ilot outa es are included in the MACT - Reporting: The permittee shall report in semiannual rejgaorts dated as follows: Continuous Yes Yes accordance with Section B110. 02/18/2016 Intermittent No No 08/29/2016 A206 Flares Continuous Yes Yes B. MACT Subpart CC, ?National El Intermittent N0 N0 Emission Standards for Hazardous Air Pollutants from Petroleum Refineries? Navajo complies with all the requirements of (Flares listed in Table 103K) MACT CC as shown for all affected sources in table 103B. Navajo uses a third party LDAR Requirement; The permittee shall comply contractor, except for deviations previously With all applicable requirements ACT reported or identi?ed at the end of this report. Subpart CC, ?National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries? for all affected sources shown in Tables 103B. (63.640). Monitoring: The permittee shall comply Navajo complies w1th all the requirements of . El Continuous Yes MACT CC as shown for all affected sources 1n w1th.the monltorlng and table 103B. Navajo uses a third party LDAR Intermittent No No requirements of 40 CFR 63, Subpart CC. contractor. ACC Form Part 1 Permit P051-R2 R2M1 Page 95 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 331 of 1969 Version 02.25.15 Recordkeeping: The permittee Sh all Navajo complies with all the requirements of . Continuous MACT CC as shown for all affected sources in comp W1 16 app ca 6 recor eep ng table 103B. Navajo uses a third party LDAR XI Intermittent No XI N0 requ1rements of 40 CFR 63.655. contractor. Reporting: The ermittee Shall comply Navajo complies with all the requirements of . Continuous X1 Yes Yes with the a li able re rt'n i MACT CC as shown for all affected sources in PP 0 PO 1 requ rem 5 table 103.13. Navajo uses a third party LDAR Intermittent No No of 40 CFR 63.655. contractor A207 Sulfur Recovery Plant (SPR), Tail XI Continuous XI Yes Yes Gas Incinerator (TGI) IXI Intermittent 0 1X1 No A. Consent Decree Requirements for SRP and TGI Requirement: In addition to the applicable requirements of NSPS, 40 CFR 60, Subparts and a, the permittee shall accomplish the following: 1. Navajo shall route all Sulfur Recovery Plant (SRP) sulfur pit emissions from the SRP so that sulfur pit emissions to the atmosphere either are eliminated or are included and monitored as part of the applicable Sulfur Recovery Plant's tail gas emissions that meet the NSPS Subpart or Ja limit for 802. (CD 1118.C.ii) 2. The SRP and TGI (and any supplemental control devices) shall be operated and maintained, to the extent practicable, in accordance with the obligation to minimize SRP emissions through implementation of good air pollution control practices required by 40 CFR at all times, including periods of start?up, shutdown, and malfunction. (CD 1) Sulfur Recovery Plant (SRP) sulfur pit emissions are routed to the Tail Gas Incinerators and are continuously monitored as part of the applicable Sulfur Recovery Plant's tail gas emissions that meet the NSPS Subpart limit for S02. 2) The SRP and TGU are operated and maintained, to the extent practicable, in accordance with the obligation to minimize SRP emissions through implementation of good air pollution control practices required by 40 CFR at all times, including periods of start?up, shutdown, and malfunction. ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 96 of 144 EPA Inspection Report - Page 332 of 1969 Version 02.25.15 (NSR 0195M35, Condition A207.A) Monitoring: The permittee shall comply with the applicable monitoring requirements of NSPS Subpart or a. All of the continuous monitors are operated, IXI Continuous Yes Yes maintained, and certi?ed as required. Intermittent El No 0 Recordkeeping: The permittee shall lg Continuous lg Yes Yes maintain records in accordance with the Records are maintained by Navajo Environmental applicable requirements of NSPS Subparts Department and on Pi. and Ja. IXI Intermittent No N0 Reporting: The permittee shall report in . accordance with the applicable Reports required by Subpart and a are submitted . as . . requirements of NSPS Subparts and a. '2 Intermttent No Kl No Continuous IXI Yes Yes A207 Sulfur Recovery Plant (SPR), Tail El Continuous IE Yes El Yes Gas Incinerator (TGI) IXI Intermittent No No B. The following BACT 802 work practices and equipment shall apply to the SRP Ol 95-M25) Maintain at least 98% SRP on? stream operations. This includes curtailing re?nery operations as necessary when SRU capaCIty ls Navajo has installed BACT, and implemented the limited during planned startup, work practices, as described in this permit shutdown, and maintenance condition, events. Maintain adequate SRP excess capacity to reduce the frequency and quantity of re?nery excess emissions. After the re?nery expansion project proposed units are constructed, the proposed SRU3 will provide at least 25% excess capacity. Continue to maintain and use a ACC Form Part 1 Permit P05 R2M1 Page 97 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 333 of 1969 Version 02.25.l5 (C) sulfur shedding plan to prevent or reduce acid gas ?aring events from re?nery upsets. An acid gas ?aring event is de?ned as excess SOZ emissions greater than 500 pounds in a 24-hour period. The plan shall state speci?c actions that may be taken to reduce or prevent acid gas ?aring. The actions taken during any event will be based on the re?nery operators? discretion, considering safety and other factors related to prudent operation. This plan is subject to review by NMED or EPA, and shall be amended upon written request by NMED or EPA. The sulfur shedding plan may include, but is not limited to the following options: Store sour water to reduce acid gas generation from the sour water strippers Reduce the operating rate of one or more amine strippers to lower the acid gas generation rate Reduce one or more hydrotreating unit throughput rates to lower acid gas generation rate Use hydrogen, when available, as ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 98 of 144 EPA Inspection Report - Page 334 of 1969 Version 02.25.15 SRU fuel during startup and hot standby to minimize carbon deposits on the SRU During startup and shutdown and to the extent practicable, process vessels shall be depressurized into other process equipment rather than venting to a ?are. The permittee shall document instances when this is not practicable. A207 Sulfur Recovery Plant (SPR), Tail Gas Incinerator (TGI) C. SRU2, and SRU3 Requirement: SR 0195M3 5, Condition A207.C and revised) The permittee shall demonstrate compliance with the H28, 802, lb/hr, tpy emission limits by completing the following requirements, monitoring, recordkeeping and reporting: (1) A ?ow meter shall be installed, operated, calibrated, and maintained on the sour water stripper streams that go to the SRUs. (2) An $02 CEMS and ?ow meter shall be installed on the and SRU3 incinerator stacks. In addition, these units shall be equipped with instruments to measure and record sulfur concentration l) A ?ow meter is in place on the sour water stripper streams into Units SRU2, and SRU3. 2) The $02 CEMS and ?ow meter on the and SRU3 incinerator stacks, and the instruments used to measure sulfur concentration and ?ow rates of the gas streams into SRU2, and SRU3, are calibrated and maintained at a frequency and method speci?ed by the manufacturer, or as dictated by operating conditions. The $02 CEMS follow the quality assurance and quality control procedures in 40 CFR 60 Subpart and Appendix F. 3) The minimum acceptable level of data capture for all instruments measuring ?ow and concentration of sul?ir streams into the SRU2, and SRU3 including the CEMS and ?ow meters on the incinerator stacks shall be at least 90% for each month. The 10% lost data includes periods when the concentration and corresponding ?ow are not being measured. as a result of calibrations or breakdowns. The data capture is reported in the semi?annual NSPS Subparts and Ja reports. Continuous Intermittent Yes N0 Yes No ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 99 of 144 EPA Inspection Report - Page 335 of 1969 Version 02.25.15 and ?ow rates of the gas streams into SRUI, SRU2, and SRU3. The CEMS, ?ow meters, and data loggers shall be calibrated and maintained. In addition, the calibration of the 802 CEMS shall follow the quality assurance and quality control procedures in 40 CFR 60 Subpart or a and Appendix F. (3) The minimum acceptable level of data capture for all instruments measuring ?ow of sulfur streams into the SRU2, and SRU3, as well as the CEMS and ?ow meters on the incinerator stacks, shall be at least 90% for each semi-annual period. The 10% lost data will include all periods when the concentration and corresponding ?ow are not being measured as a result of calibrations or breakdowns. Monitoring: The gas stream feeding El Continuous Yes El Yes SRU2, and SRU3 from the amine Intermittent No No regeneration units and the sour water stripper shall be tested at least for H28 concentration. The permittee shall monitor the . 1 1- . followmg: 2), and 3) Navajo comp 1es With the requirements of this permit condition. (1) Flow rate of sour water stream to SRUs, (2) 802 concentration in SRU incinerator stacks and (3) Flow rate of the SRU incinerator stacks. ACC Form Part 1 Permit R2M1 Page 100 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 336 of 1969 Version 02.25.15 IXI Continuous IXI Yes Yes Recordkeeping: The permittee shall maintain records in accordance with the Intermittent NO No applicable requirements Subparts or a and MACT Subpart The permittee shall also keep records of the following: . 1), 2), and 3) Records are maintained by Navajo Environmental Department and on Pi. (1) Flow rate of sour water stream to SRUs, (2) $02 concentration in SRU incinerator stacks and (3) Flow rate of the SRU incinerator stacks. Reporting: The permittee shall report in El Continuous Yes Yes accordance With the applicable Reports required by NSPS Subpart and Ja, MACT requirements of NSPS Subparts or a, and section B110 are submitted as necessary. Intermittent El N0 N0 MACT Subpart and Section B110. A207 Sulfur Recovery Plant (SPR), Tail El Continuous Yes El Yes Gas Incinerator (TGI) Intermittent No No D. 40 CFR 60, Subpart (Unit(s) and SRU2) Navajo complies With the requirements of Subpart J. Requirement: The permittee shall comply with the applicable requirements of 40 CFR 60, Subpart J. Monitoring: The permittee shall install a Continuous Yes Yes continuous monitoring device to monitor Navajo complies with the requirements of Subpart compliance with the H28 limit. (40 CFR J. Interm?ttent N0 No Recordkeeping: The permittee shall Records are maintained by Navajo Environmental IZI Continuous IZI Yes Yes maintain the continuous emission records. Department and OH Intermittent NO No ACC Form Part 1 Permit P051-R2 R2M1 Page 101 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 337 of 1969 Version 02.25.15 Reporting: The permittee shall comply with the reporting requirements of 40 CFR 60, Subpart J. Navajo complies with the requirements of Subpart J. XI Continuous IE Intermittent El Yes No Yes IE No A209 Fugitives A. NSPS Subpart Standards of Performance for Equipment Leaks of VOC in Petroleum Re?neries for which construction, reconstruction, or modi?cation commenced after January 4, 1983, and on or before November 7, 2006 (Fugitives subject in Table 103B) Navajo continues to comply with the applicable requirements of NSPS Subpart as applicable to the process fugitive areas shown in Table 103B, except for deviations noted in semiannual reports. Fugitive components subject to either of these rules are included in the Leak Detection and Repair (LDAR) program. Navajo uses a third-party contractor for the LDAR monitoring and recordkeeping. Continuous XI Intermittent Yes XI No Yes No Requirement: The permittee shall comply with all applicable requirements of NSPS Subpart for all sources in Table 103.B (affected units and voluntarily units). This table also includes areas that are voluntarily following the SPS Subpart monitoring requirements. (See footnote 1 to Table 103B) Navajo continues to comply with the applicable requirements of NSPS Subpart as applicable to the process fugitive areas shown in Table 103B, except for deviations noted in semiannual reports. Fugitive components subject to either of these rules are included in the Leak Detection and Repair (LDAR) program. Navajo uses a third?party contractor for the LDAR monitoring and recordkeeping. Continuous XI Intermittent Yes No Yes No Monitoring: The permittee shall comply with all applicable monitoring requirements of 40 CFR 60, Subpart Navajo uses a third-party contractor for the LDAR monitoring and recordkeeping. Continuous IE Intermittent IE Yes No Yes IE No Recordkeeping: The permittee shall comply with all applicable recordkeeping requirements of 40 CFR 60, Subpart Navajo uses a third?party contractor for the LDAR monitoring and recordkeeping. Continuous XI Intermittent IE Yes No Yes IE No Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart Subpart reports were submitted semi? annually as follows: 02/18/2016 08/29/2016 El Continuous XI Intermittent Yes No Yes No A209 Fugitives B. NSPS Subpart Standards of Performance for Equipment Leaks in Petroleum Re?neries for which Construction, Reconstruction, or Navajo continues to comply with the applicable requirements of NSPS Subparts and as applicable to the process fugitive areas shown in Table 103B, except for the deviations noted in semiannual reports and for not applying in Units 34, 25, 21, 10, and 2. Fugitive components Continuous XI Intermittent Yes El No El Yes No ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 102 of 144 EPA Inspection Report - Page 338 of 1969 Version 02.25.15 Modi?cation Commenced After subject to either of these rules are included in the November 7, 2006 (Fugitives subject in Leak and Repair (LDAR) ngram- Table 103B) Navajo uses a third?party contractor for the LDAR monitoring and recordkeeping. Requirement: The permittee shall comply with all applicable requirements of NSPS Subpart for all sources in Table 103.B (affected units and voluntarily units). This table also includes areas that are voluntarily following the NSPS Subpart monitoring requirements. Monitoring: The permittee shall comply El Continuous IXI Yes El Yes With all applicable monitoring Navajo uses a third-party contractor for the LDAR requirements of 40 CFR 60, Subpart monitoring and recordkeeping. Intermittent El N0 IXI N0 Recordkeeping: The permittee shall El Continuous Yes El Yes comply with all applicable recordkeeping Navajo uses a third-party contractor for the LDAR requirements of 40 CFR 60, Subpart monitoring and recordkeeping. IXI Intermittent El N0 IXI N0 Reporting: The permittee Sh all comply Subpart reports were submitted semi? El Continuous Yes El Yes annually as follows: WET repomng reqmrements 02/18/2016 Intermittent No No A209 Fugitives Continuous El Yes Yes C. MACT Subpart CC, ?National Intermittent Emission Standards for Hazardous Air Pollutants from Petroleum Refineries? (Fugitives subject in Table 103.B) The Gasoline Loading Rack is equipped with a carbon adsorption system. Requirement: The permittee shall comply with all applicable requirements of MACT Subpart CC, ?National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries? for all affected sources shown in Tables 103.B. (63.640). ACC Form Part 1 Permit Page 103 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 339 of 1969 Version 02.25.15 For all activities in Table 103.B that are not subject to MACT CC, the permittee voluntarily performs a LDAR program for those units and that program meets the requirements of MACT CC. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. The Gasoline Loading Rack carbon absorption has a VOC CEMS installed in the exhaust air stream. IZI Continuous Intermittent IE Yes El N0 Yes No Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63.655. Records are kept by Holly Energy Partners (HEP) either at the Gasoline Loading Rack or at the HEP Artesia Of?ce. IZI Continuous Intermittent Yes N0 IE Yes No Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 63.655. Navajo submitted MACT CC semiannual reports dated as follows: 02/18/2016 08/29/2016 Continuous IE Intermittent Yes No Yes No A209 Fugitives D. NSPS Subpart Standards of Performance for VOC Emissions from Petroleum Re?nery Wastewater Systems (Fugitives subject in Table 103B) Requirement The permittee shall comply with all applicable requirements of NSPS, 40 CFR Part 60.690, Subpart Navajo continues to comply with the applicable requirements of NSPS Subparts throughout the re?nery, except for deviations noted in semiannual reports. Oily water sewer drain hubs are inspected at least Junction boxes, and the oil?water separator are inspected at least semi- annually. Compliance reports were submitted as follows: 0 1 2 8/Continuous IXI Intermittent Yes IXI No Yes El N0 Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart (60.695) Navajo continues to comply with the applicable requirements of NSPS Subparts throughout the re?nery, except for deviations noted in semiannual reports. Oily water sewer drain hubs are inspected at least Junction boxes, and the oil?water separator are inspected at least semi? annually. El Continuous Intermittent Yes No Yes No Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60.696. Records are maintained by Navajo Environmental Department. Continuous Intermittent Yes No Yes No Reporting: The permittee shall comply Subpart reports were submitted semi?annually as follows: Continuous Yes Yes ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 104 of 144 EPA Inspection Report - Page 340 of 1969 Version 02.25.15 With the applicable reporting requirements Of 40 CFR 60.697. 01/28/2016 07/28/2016 Intermittent EINO EINO ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 105 of 144 EPA Inspection Report - Page 341 of 1969 Version 02.25.15 A209 Fugitives El Continuous XI Yes El Yes E. Minor changes within the facility to Intermittent No XI N0 piping and Components that affect fugitive Navajo understands that minor changes to the VOC emission source shall be updated and facility piping and components that affect fugitive added during the next available Signi?cant emissions will be added during the next permit permit revision in accordance with 20.2.72 mOdi?caiton' NMAC. The facility wide fugitive VOC emission limit shown above and in Table 106A of this permit. A210 Loading Racks IXI Continuous Yes XI Yes A. Truck and Rail Loading (Unit shown in XI Intermittent XI N0 El N0 Table 106.G) The Gasoline Loading Rack is equipped with a . . . carbon adso tion 5 stem. The Rail Loadin Rack Requlrement: Compilance the does not excrged theylZ?month total throughiut, but allowable 11m1ts 1n Table 106G records are not tracked as required by permit. shall be demonstrated by not exceeding the rolling 12-month total throughput for each loading rack for each different product in gallons per year (barrels/year). Monitoring: The permittee shall monitor The Gasoline Loading Rack carbon absorption has g] Continuous Yes Yes the throughput volumes on a a VOC CEMS installed in the exhaust air stream. basis. The Rail Loading Rack volumes are tracked daily. Xi Intermittent El N0 N0 Recordkeeping: The permittee shall Kl contlnuous El Yes XI Yes record the throughput volume for XI Intermittent No N0 each loading rack for each different product. Each month during the ?rst 12 Records are kept by Holly Energy Partners (HEP) months 0 monitoring the permittee shall at the Gasoline Loading Rack or at the HEP . Arte51a Of?ce. Records are not tracked as required record the cumulatlve condensate loadout by the permit. volume and after the ?rst 12 months of monitoring, the permittee shall calculate and record a rolling 12-month total loadout volume. ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 106 of 144 EPA Inspection Report - Page 342 of 1969 Version 02.25.15 Records shall also be maintained in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. Navajo submitted MACT CC semiannual reports dated as follows: 02/1 8/2016 08/29/2016 El Continuous IXI Intermittent Yes IXI N0 IXI Yes No A210 Loading Racks B. Fuel Truck Loading Rack (Units subject in Table 103.D) (40 CFR 63, Subpart CC) Requirement: The permittee shall comply with all applicable requirements of MACT Subpart CC, National Emission Standards for Hazardous Air Pollutants From Petroleum Re?neries. Specially, the truck loading rack shall be equipped with a carbon adsorption system for compliance with the MACT requirements. The Truck Loading Rack has a carbon absorption system installed. Continuous IXI Intermittent IXI Yes No Yes IXI N0 Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. Speci?cally where a carbon adsorption system is used, a continuous emission monitoring system (CEMS) capable of measuring organic compound concentration shall be installed in the exhaust air stream. The Truck Loading Rack has a CEMS installed. IXI Continuous Intermittent Yes No Yes IXI N0 Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63, Subpart CC. Records are kept by Holly Energy Partners (HEP) either at the Gasoline Loading Rack or at the HEP Artesia Of?ce. IXI Continuous El Intermittent IXI Yes No Yes IXI N0 Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 63, Subpart CC. Navajo submitted MACT CC semiannual reports dated as follows: 02/18/2016 08/29/2016 Continuous Intermittent Yes N0 IXI Yes No ACC Form Part 1 Permit P05 l?R2 R2M1 Ver 4.1 02/25/2015 Page 107 of 144 EPA Inspection Report - Page 343 of 1969 Version 02.25.15 A211 Fluid Catalytic Cracking Unit (FCC) A. Continuous Monitor System(CMS) (Unit FCC REGEN) Requirement: (1) Consent Decree Limits on PM and SO2 emissions from the FCC: By no later than December 3 1, 2003, the Wet Gas Scrubber (WGS) on the FCC Regenerator shall comply with the following limits: (CD 11128 1113.8) 80;; concentration not to exceed 25 on a daily rolling 365? day average basis and 50 on a daily rolling 7?day average basis, each corrected to 0% oxygen. Compliance with this emissions limit shall be demonstrated on an ongoing basis through the use of and a particulate matter (PM) emission limit of 1.0 pound of PM per 1000 pounds of coke burned on a 3-hour average basis (CD 1113B). To demonstrate compliance with this requirement, the Permittee shall conduct an annual EPA Method 5 Test for PM and weekly EPA Method 9, Opacity Test in accordance with their approved 1d) The FCC catalyst regenerator exhaust is continously monitored for SO2. 16) The catalytic cracking regenerator is tested annually for PM and was tested on the following date: 0 1 /0 6/20 1 6 1i) Navajo has submitted an alternative monitoring plan (AMP) to comply with the FCC opacity monitoring requirement because the CCU has a wet scrubber which prevents continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CFR 60 Appendix A Method 9. 2) The FCC exhaust is continously monitored for and CO. Deviations were reported to the Department as excess emission events and on the Subpart A report. XI Continuous Intermittent XI Yes No Yes No ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 108 of 144 EPA Inspection Report - Page 344 of 1969 Version 02.25.15 (0 Alternative Monitoring Plan (AMP). As the FCC Regenerator is subject to the provisions of 40 CFR 60.102 (NSPS Subpart J), it shall not discharge to the atmosphere gases exhibiting greater than 30 percent opacity, except for one six-minute average opacity reading in any one?hour period. (2) Consent Decree Limits on and CO emissions from the FCC: The FCC shall comply with and CO emission limits as follows: The concentration?based emission limit based on daily rolling 7?day and daily rolling 365-day averages, corrected to 0% oxygen as established pursuant to the Consent Decree, unless EPA rejects the proposed limit and establishes a different emission limit, in which case the FCC shall comply with established limit. Under no circumstances shall this emission limit be greater than a concentration-based limit that would be equivalent to 34.9 lbs/hr. The 7-day FCC emission limits, shall not apply during periods of Hydrotreater Outage provided that the FCC ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 109 of 144 EPA Inspection Report - Page 345 of 1969 Version 02.25.15 (including associated air pollution control equipment) is maintained and operated in a manner that minimizes emissions in accordance with an EPA- approved good air pollution control practices plan. Navajo shall comply with the plan at all times, including periods of startup, shutdown, and malfunction of the hydrotreater. The daily rolling 365-day average NOX emissions limit shall apply during periods of hydrotreater outages. The NOX limits are: (1) 87.3 NOX, corrected to 0% 02 on a daily rolling 7?day average, and (2) 58.1 NOX, corrected to 0% 02 on a daily rolling 365-day average The NSPS Subpart emission limit of 500 CO corrected to 0% 02 on a 1-hour average basis and 100 CO corrected to 0% 02 on a daily rolling 365-day average basis, by no later than December 31, 2003. Monitoring: 1) The FCCU Catalyst Regenerator Scrubber El Continuous El Yes Yes exhaust is continuously monitored for CO, 02, (1) A continuous monitor system (CMS) $02, and NOX. PM is monitored annually. XI Intermittent N0 El No for CO, 02, $02 and NOX shall be installed, calibrated, maintained, and 2) The FCC regenerator CMS were recerti?ed on ACC Form Part 1 Permit Page 110 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 346 of 1969 Version 02.25.15 operated on the FCC Catalyst Regenerator vent stack(s) of the scrubber in accordance with 40 CFR Part 60, ?60.13, Appendix A, and the applicable performance speci?cations of Appendices (Speci?cations 2 and 3) and F. The CMS shall be used to demonstrate compliance with CO, S02 and NOX emissions limits and to report compliance with the terms and conditions of the Consent Decree. The CMS and process data shall be made available, by permittee, to applicable Federal and State Agencies (NMED) upon demand as soon as practicable. (CD 111 1F, 12 D, and 14C) (2) The FCC Regenerator Scrubber NOX, S02, CO and 0; CMS shall be recerti?ed annually. (3) The CMS data shall be monitored to ensure the CO, S02 and NOX emission limits for the FCC are met. (4) The Permittee shall conduct an annual EPA Method 5 Test for PM and weekly EPA Method 9 Opacity test to demonstrate compliance with the particulate matter (PM) emission limit of 1.0 pound of PM per 1000 pounds of coke burned on a 3?hour average basis and opacity limit of 30%. Permittee shall meet testing requirements of B11 1. the following dates: CO 01/05/2016 01/06/2016 SOZ 01/05/2016 01/06/2016 NOX 01/05/2016 01/06/2016 3) CMS data is used to ensure emissions limits are met. 4) The catalytic cracking regenerator is tested annually for PM and was tested on the following date: 0 1 /0 6/20 1 6 Navajo has submitted an alternative monitoring plan (AMP) to comply with the FCC opacity monitoring requirement because the FCCU has a wet scrubber which prevents continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CFR 60 Appendix A Method 9. ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 111 of 144 EPA Inspection Report - Page 347 of 1969 Version 02.25.15 Recordkeeping: The permittee shall maintain the records of: (1) The certi?cation and re-certi?cation of the CMS. (2) Modi?cations to the good air pollution control practice plan to minimize NOX emissions shall be summarized on an annual basis if any changes were made. CD 111 LG) (3) The permittee shall keep records of CMS data monitoring N02, S02, PM10 and CO emissions from the FCC. (CD 1111.F, CD CD ?ll4.C) (4) Records of NOX, CO, S02 lb/hr, tpy; PM lb/hr, tpy and opacity. TPY shall be based on a rolling 12- month total. (5) The permittee shall keep records of annual PM stack tests and weekly Method 9 observations conducted on the FCC. For any opacity observations conducted in accordance with the requirements of EPA Method 9, record the information on the form referenced in EPA Method 9, Sections 2.2 and 2.Records are maintained by Navajo Environmental Department and on Pi. El Continuous El Intermittent Reporting: The permittee shall report in accordance with Section B110 and testing requirements of B1 1 l. Reports required by NSPS Subpart and a are included in the Subpart A report. Section B110 reports are submitted as necessary. El Continuous El Intermittent ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 112 of 144 EPA Inspection Report - Page 348 of 1969 Version 02.25.15 A211 Fluid Catalytic Cracking Unit Continuous DYes (FCC) IXI Intermittent No IXI No B. Performance Testing (Unit FCC REGEN) Requirements: (1) The permittee shall demonstrate compliance with the NSPS Subpart particulate matter emission limit at Table NaVajO complies With the requirements 0f NSPS 106.A by conducting an initial Subpart J, Ja, MACT Subpart A, and performance test in accordance with NSPS Subpart A, ?60.8 and NSPS Subpart J, The particulate matter stack test shall be repeated on an annual basis. (2) The permittee shall comply with all applicable performance testing requirements in accordance with MACT Subparts A and Monitoring: Testing shall be conducted in El Continuous IE Yes Ci Yes accordance with NSPS Subparts A and J, Navajo complies with the requirements of NSPS and in accordance with MACT Subparts A Subpart J, a, MACT Subpart A, and IE Intermittent N0 '2 N0 and Recordkeeping: The permittee shall Continuous IE Yes DYes aintain perfo ance test records in Navajo complies with the requirements of NSPS IE El IE Intermittent N0 N0 accordance With NSPS Subparts A and J, Subpa rt J, Ja, 5 CT Subpa rt 5 and MACT Subparts A and and 1n accordance with Section B109. Reporting: The permittee shall report El Continuous : Yes performance test results in accordance Navajo complies with the requirements of NSPS with NSPS Subparts A and J, MACT Subpart J, Ja, MACT Subpart A, and glntem?ttent 5N0 g1?) Subparts A and and in accordance ACC Form Part 1 Permit R2M1 Page 113 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 349 of 1969 Version 02.25.15 with Section B110. A212 Towers Continuous Yes El Yes A. MACT Subpart CC, ?National Intermittent N0 Cl N0 Emission Standards for Hazardous Air Pollutants from Petroleum Re?neries? . . (Cooling Towers subject in Table 1031:) Navajo complies With the applicable requirements for heat exchange systems, except for dev1ations 1 td 'd t'fd fth' Requirement: The permittee shall comply 13:52:? repor with all applicable requirements of 40 CFR 63, Subpart CC for heat exchange systems for all affected sources shown in Table 103.F attached. Monitoring The permittee shall comply Navajo complies with the applicable requirements Continuous Yes Yes W1th all monitoring and testing for heat exchange systems, except for deviations requirements of 40 CFR 63, Subpart CC, previously reported or identi?ed at the end of this Intermittent N0 1:1 N0 (63-65403), (6), (0) report Recordkeeping: The permittee shall 1:1 Continuous Yes 1:1 Yes comply with all applicable recordkeeping Navajo complies with the applicable requirements requirements of 40 CFR 63, Subpart CC. for heat exchange systems. Intermittent :1 NO N0 Reporting: The permittee shall comply Navajo submitted MACT CC semiannual reports Continuous Yes Yes with all applicable reporting requirements dated as follows: of 40 CFR 63, Subpart CC. 02/18/2016 Intermittent N0 NO (00101), 08/29/2016 l) Navajo operates with less than six (6) 1:1 ont?nuous 1:1 Yes 1Z1 Yes A212 Coollng Towers recirculating pumps per heat exhange system. 1 . . . Intermittent No El No 13- C001mg Tower Operatlons (Coolmg 2) The pump capacity is less than 65,500 Towers subject in Table 103.F) 3) The Total Dissolved Solids (TDS) is tracked but Requirement; Compliance with the records are not kept per the requirements. allowable emission limits in Table 106.H shall be demonstrated by meeting the 4) Drift eliminators are not inspected for 0.001% or . . . 0.003 drift. followmg requirements. ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 114 of 144 EPA Inspection Report - Page 350 of 1969 Version 02.25.15 5) Drift eliminators are inspected on an annual l) operate a maximum of six (6) basis. recirculating pumps at any one time; 2) ensure that each pump capacity shown in Table 104A are not exceeded gallons per minute for each cooling tower (65,500 total maximum rate for 6 pumps); 3) limit the Total Dissolved Solids (TDS) content for the cooling tower recirculating water system to 3500 ppmw; based on a rolling 12-month annual average; 4) ensure that the drift eliminator are rated by the manufacturer at 0.001% or 0.003 drift or less as shown in Table and 5) ensure that the drift eliminator is present and in good working order. The permittee shall measure the Total Dissolved Solids (TDS) content of the recirculating water through direct laboratory analysis; or may use a conductivity meter on the recirculating water system for the cooling tower. The correlation between conductivity of the water and the TDS content shall be taken as 0.9 conductivity (umhos/cm) TDS (ppmw) unless a new correlation is determined through laboratory analysis and submitted to the Permit Program Manager ACC Form Part 1 Permit Page 115 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 351 of 1969 Version 02.25.15 for approval. Monitoring: The permittee shall: 1) Monitor the recirculating water TDS content by direct laboratory analysis of the TDS or through use of conductivity meter values and correlated TDS on a basis; and a. Any correlation other than the 0.9 value described above shall be developed by the permittee by independent laboratory measurement of at least 10 water samples with approximately evenly spaced measured TDS values that bracket the minimum and maximum values expected. The highest laboratory TDS sample used for the correlation shall be greater than the maximum allowable TDS of 3500 ppmw. 2) Perform an annual inspection of the drift eliminator and perform any maintenance necessary to ensure the device operates according to the manufacturer?s speci?cations. 1) The TDS is monitored but records are not tracked per the permit requirements. 2) Drift eliminators are inspected on an annual basis. 3) The Cooling Towers are monitored for VOC breakthrough via the El Paso Method described in Appendix P. Continuous IXI Intermittent Yes XI No XI Yes No ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 116 of 144 EPA Inspection Report - Page 352 of 1969 Version 02.25.15 3) The permittee shall monitor the cooling water inlet and outlet streams for hydrocarbons on an annual basis using either EPA Method 8015 With a large enough sample to achieve accurate quanti?cation of hydrocarbon content, EPA Method 8260, EPA Method 8270 or a similar method as approved by the Department prior to testing. t. Recordkeeping: The permittee shall El 0? es 95 maintain the following records: Intermittent 0 El No l) Manufacturer?s speci?cations demonstrating maximum capacities of the recirculating water pumps and the manufacturer?s speci?cation for the drift eliminator speci?ed drift rate; 1), 2), 3) and 4) Recordingkeeping is tracked, but not kept per the permit requirements. 2) TDS and rolling 12-month average; 3) If a conductivity meter is installed, a record of the correlation between conductivity and TDS, any laboratory analyses used to determine the correlation, and all related calculations; 4) Annual drift eliminator inspection and any records of maintenance performed. ACC Form Part 1 Permit P051-R2 R2M1 Page 117 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 353 of 1969 Version 02.25.15 The permittee shall maintain records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B1 10. Navajo submitted MACT CC semiannual reports dated as follows: 02/18/2016 08/29/2016 El Continuous IE Intermittent IE Yes No Yes N0 A213 Wastewater Systems A. NSPS Subpart Standards of Performance for VOC Emissions from Petroleum Re?nery Wastewater Systems (Unit MAIN API) Requirement: Beginning December 31, 2003, all remaining and newly installed individual drain systems, oil?water separators, and aggregate facilities not previously speci?ed shall be affected facilities, as the term is used in the NSPS, 40 CFR Part 60, Subpart and shall be subject to and comply with the applicable requirements of 40 CFR Part 60, Subpart (CD 1129) The permittee shall comply with all applicable requirements of NSPS Subpart for the affected sources in Tables 103B, C, G. (60.690) Navajo continues to comply with the applicable requirements of NSPS Subparts throughout the re?nery, except for deviations noted in semiannual reports. Oily water sewer drain hubs are inspected at least Junction boxes, and the oil-water separator are inspected at least semi- annually. Compliance reports were submitted as follows: 01/28/2016 07/28/2016 El Continuous IE Intermittent El Yes IE N0 Yes No Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart (60.695 and 60.696) Navajo continues to comply with the applicable requirements of NSPS Subparts throughout the re?nery, except for deviations noted in semiannual reports. Oily water sewer drain hubs are inspected at least Junction boxes, and the oil-water separator are inspected at least semi- annually. Continuous IE Intermittent El Yes IE No @Yes No Recordkeeping: The permittee shall comply with the applicable recordkeeping Records are maintained by Navajo Environmental Department. El Continuous Yes El Yes ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 118 of 144 EPA Inspection Report - Page 354 of 1969 Version 02.25.15 requirements of 40 CFR 60.697. Intermittent DNO ENO Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60.698. Subpart reports were submitted semi?annually as follows: 01/28/2016 07/28/2016 Continuous Intermittent Yes No Yes No A213 Wastewater Systems B. MACT Subpart CC, ?National Emission Standards for Hazardous Air Pollutants from Petroleum Re?neries? Requirement: The permittee shall comply with all applicable requirements of MACT Subpart CC, ?National Emission Standards for Hazardous Air Pollutants from Petroleum Re?neries? for all affected sources shown in Tables 103B, C, attached. (63.640). Navajo complies with the requirements of MACT CC. Continuous Intermittent Yes No Yes No Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. Navajo complies with the requirements of MACT CC. Continuous Kl Intermittent IZI Yes No Yes No Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63.655. Records are maintained by Navajo Environmental Department. El Continuous IZI Intermittent IZI Yes No Yes No Reporting: The permittee shall comply with the applicable reporting requirements of40 CFR 63.655. Navajo submitted MACT CC semiannual reports dated as follows: 02/1 8/2016 08/29/2016 El Continuous IZI Intermittent Yes No El Yes No A213 Wastewater Systems C. Wastewater Treatment System (Units shown in Table 106.1) Requirement: Compliance with the emission limits in Table 106.1 shall be demonstrated by properly maintaining and Navajo complies with this requirement. Continuous Kl Intermittent Yes No Yes El No ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 119 of 144 EPA Inspection Report - Page 355 of 1969 Version 02.25.15 repairing the units, and running the Wastewater Model annually to calculate the maximum VOC emissions generated. ACC Form Part 1 Permit P051-R2 R2M1 Page 120 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 356 of 1969 Version 02.25.15 Monitoring: Continuous IXI Yes Yes 1) Maintenance and repair shall meet the minimum manufacturer's or permittee's recommended maintenance schedule. Activities that involve maintenance, adjustment, replacement, or repair of functional components with the potential to affect the operation of an emission unit shall be documented as they occur for the following events: IXI Intermittent No IXI No Routine maintenance that takes a 1) and 2) Navajo complies with this requirement. unit out of serv1ce for more than two hours during any twenty-four hour period. Unscheduled repairs that require a unit to be taken out of service for more than two hours in any twenty? four hour period. (2) The permittee shall annually run the Waste-Water Model to determine the hourly and annual emission rates, based on Toxchem V4 Input Parameters. Recordkeeping: El Contlnuous IXI Yes Yes (1) The perrnittee shall maintain records in El Intermittent No No accordance with Section B109, including records of maintenance and repairs activities and a copy of the manufacturer? or permittee?s recommended maintenance schedule. (2) The permittee shall maintain records of the Toxchem V4 Input Parameters and the emission calculation results compared to permit limits. 1) and 2) Navajo complies with this requirement. ACC Form Part 1 Permit Page 121 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 357 of 1969 Version 02.25.15 Reporting: The permittee shall report in accordance with Section B110. Navajo complies with the requirement of section B1 10. Continuous Intermittent Yes No El Yes N0 ACC Form Part 1 Permit P05 l?R2 Ver 4.1 02/25/2015 Page 122 of 144 EPA Inspection Report - Page 358 of 1969 PART 1 General Conditions 1. Have these General Conditions been met during this reporting period? 2. Was this facility in 3. Does compliance with this not apply If the section Heading is marked as no remarks are required. requirement during Check only one box per subiect heading. the reporting penOd? Explain answers in remarks row under subiect heading. Yes B100 Introduction Explain Explain Explain A. A Below Below Below REMARKS: 13101 Legal Yes No Explain Explain Explain Below Below Below A. Permit Terms and Conditions (20.2.70 sections 7, 201B, 300, 301B, 302, 405 NMAC) (1) The permittee shall abide by all terms and conditions of this permit, except as allowed under Section 502(b)(10) of the Federal Act, and 20.2.70.302.H.1 NMAC. Any permit noncompliance is grounds for enforcement action, and signi?cant or repetitious noncompliance may result in termination of this permit. Additionally, noncompliance with federally enforceable conditions of this permit constitutes a violation of the Federal Act. (20.2.70.302.A.2.a NMAC) (2) Emissions trading within a facility (20.2.70.302.H.2 NMAC) The Department shall, if an applicant requests it, issue permits that contain terms and conditions allowing for the trading of emissions increases and decreases in the permitted facility solely for the purpose of complying with a federally enforceable emissions cap that is established in the permit in addition to any applicable requirements. Such terms and conditions shall include all terms and conditions required under 20.270.302 NMAC to determine compliance. If applicable requirements apply to the requested emissions trading, permit conditions shall be issued only to the extent that the applicable requirements provide for trading such increases and decreases without a case-by?case approval. The applicant shall include in the application proposed replicable procedures and permit terms that ensure the emissions trades are quanti?able and enforceable. The Department shall not include in the emissions trading provisions any emissions units for which emissions are not quanti?able or for which there are no replicable procedures to enforce the emissions trades. The permit shall require compliance with all applicable requirements. (3) It shall not be a defense for the permittee in an enforcement action to claim that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. (20.2.70.302.A.2.b NMAC) (4) If the Department determines that cause exists to modify, reopen and revise, revoke and reissue, or terminate this ACC Form Part 1 B, Deviation Summary permit Ver 4.0 01/22/2015 Page 123 of 144 EPA Inspection Report - Page 359 of 1969 PART 1 General Conditions permit, this shall be done in accordance with 20.2.70.405 NMAC. (20.2.70.302.A.2.c NMAC) (5) The permittee shall furnish any information the Department requests in writing to determine if cause exists for reopening and revising, revoking and reissuing, or terminating the permit, or to determine compliance with the permit. This information shall be furnished within the time period speci?ed by the Department. Additionally, the permittee shall furnish, upon request by the Department, copies of records required by the permit to be maintained by the permittee. (6) A request by the permittee that this permit be modi?ed, revoked and reissued, or terminated, or a noti?cation by the permittee of planned changes or anticipated noncompliance, shall not stay any conditions of this permit. (20.2.70.302.A.2.d NMAC) (7) This permit does not convey property rights of any sort, or any exclusive privilege. (20.2.70.302.A.2.e NMAC) (8) In the case where an applicant or permittee has submitted information to the Department under a claim of con?dentiality, the Department may also require the applicant or permittee to submit a copy of such information directly to the Administrator of the EPA. (20.2.70.301.B NMAC) (9) The issuance of this permit, or the ?ling or approval of a compliance plan, does not relieve the permittee from civil or criminal liability for failure to comply with the state or Federal Acts, or any applicable state or federal regulation or law. (20.2.70.302.A.6 NMAC and the New Mexico Air Quality Control Act NMSA 1978, Chapter 74, Article 2) (10) If any part of this permit is challenged or held invalid, the remainder of the permit terms and conditions are not affected and the permittee shall continue to abide by them. (20.2.70.302.A.1.d NMAC) (l l) A responsible of?cial (as de?ned in 20.2.70.7.AE NMAC) shall certify the accuracy, truth and completeness of every report and compliance certi?cation submitted to the Department as required by this permit. These certi?cations shall be part of each document. (20.2.70.300.E NMAC) (12) Revocation or termination of this permit by the Department terminates the permittee's right to operate this facility. (20.2.70.201.B NMAC) (13) The permittee shall continue to comply with all applicable requirements. For applicable requirements that will become effective during the term of the permit, the permittee shall meet such requirements on a timely basis. (Sections 300.D.10.c and 302GB of 20.2.70 NMAC) B. Permit Shield (20.2.70.302.J NMAC) (1) Compliance with the conditions of this permit shall be deemed to be compliance with any applicable requirements existing as of the date of permit issuance and identi?ed in Table 103.A. The requirements in Table 103.A are applicable to this facility with speci?c requirements identi?ed for individual emission units. (2) The Department has determined that the requirements in Table 103.B as identi?ed in the permit application are not ACC Form Part 1 Permit P05 l?R2 R2M1 Ver 4.1 5/6/2015 Page 124 of 144 EPA Inspection Report - Page 360 of 1969 PART 1 General Conditions applicable to this source, or they do not impose any conditions in this permit. (3) This permit shield does not extend to administrative amendments (Subsection A of 20.2.70.404 NMAC), to minor permit modi?cations (Subsection of 20.2.70.404 NMAC), to changes made under Section 502(b)(10), changes under Paragraph 1 of subsection of 20.2.70302 of the Federal Act, or to permit terms for which notice has been given to reopen or revoke all or part under 20270405 and 20.270302] (6). (4) This permit shall, for purposes of the permit shield, identify any requirement speci?cally identi?ed in the permit application or signi?cant permit modi?cation that the department has determined is not applicable to the source, and state the basis for any such determination. (20.2.70.302.A.1.f NMAC) C. The owner or operator of a source having an excess emission shall, to the extent practicable, operate the source, including associated air pollution control equipment, in a manner consistent with good air pollutant control practices for minimizing emissions. (20.2.7.109 NMAC). The establishment of allowable malfunction emission limits does not supersede this requirement. REMARKS: Except for deviations reported on the semi-annual reports and/or this report. 3102 Authority Yes No Explain Explain Explain Below Below Below A. This permit is issued pursuant to the federal Clean Air Act ("Federal Act"), the New Mexico Air Quality Control Act ("State Act?) and regulations adopted pursuant to the State and Federal Acts, including Title 20, New Mexico Administrative Code, Chapter 2, Part 70 (20.2.70 NMAC) - Operating Permits. B. This permit authorizes the operation of this facility. This permit is valid only for the named permittee, owner, and operator. A permit modi?cation is required to change any of those entities. C. The Department speci?es with this permit, terms and conditions upon the operation of this facility to assure compliance with all applicable requirements, as de?ned in 20.2.70 NMAC at the time this permit is issued. (20.2.70.302.A.1 NMAC) D. Pursuant to the New Mexico Air Quality Control Act NMSA 1978, Chapter 74, Article 2, all terms and conditions in this permit, including any provisions designed to limit this facility's potential to emit, are enforceable by the Department. All terms and conditions are enforceable by the Administrator of the United States Environmental Protection Agency and citizens under the Federal Act, unless the term or condition is speci?cally designated in this permit as not being enforceable under the Federal Act. (20.2.70.302.A.5 NMAC) ACC Form Part 1 Permit P05 l-R2 Ver 4.1 5/6/2015 Page 125 of 144 EPA Inspection Report - Page 361 of 1969 PART 1 General Conditions E. The Department is the Administrator for 40 CFR Parts 60, 61, and 63 pursuant to the Modi?cation and Exceptions of Section 10 of 20.2.77 NMAC (NSPS), 20.2.78 NMAC WESHAP), and 20.2.82 NMAC (MACT). REMARKS: B103 Annual Fee Yes No The permittee shall pay Title fees to the Department consistent with the fee schedule in 20.2.71 NMAC - Operating Permit Explain Explain g/A1 . Emission Fees. The fees will be assessed and invoiced separately from this permit. (20.2.70.302.A.1.e NMAC) OW OW 133303511 REMARKS: B104 Appeal Procedures Yes No (20.2.70.403.A NMAC) Explain Explain Explain Below Below Below A. Any person who participated in a permitting action before the Department and who is adversely affected by such permitting action, may file a petition for a hearing before the Environmental Improvement Board ("board"). The petition shall be made in writing to the board within thirty (30) days from the date notice is given of the Department?s action and shall specify the portions of the permitting action to which the petitioner objects, certify that a copy of the petition has been mailed or hand?delivered, and attach a copy of the permitting action for which review is sought. Unless a timely request for a hearing is made, the decision of the Department shall be final. The petition shall be copied simultaneously to the Department upon receipt of the appeal notice. If the petitioner is not the applicant or permittee, the petitioner shall mail or hand?deliver a copy of the petition to the applicant or permittee. The Department shall certify the administrative record to the board. Petitions for a hearing shall be sent to: Secretary, New Mexico Environmental Improvement Board 1 190 St. Francis Drive, Runnels Bldg. Rm N2153 Santa Fe, New Mexico 87502 REMARKS ACC Form Part 1 Permit R2M1 Ver 4.1 5/6/2015 Page 126 of 144 EPA Inspection Report - Page 362 of 1969 PART 1 General Conditions A. B105 Submittal of Reports and Certi?cations Stack Test Protocols and Stack Test Reports shall be submitted electronically to Stacktest.AQB@statenmus or as directed by the Department. Excess Emission Reports shall be submitted as directed by the Department. (20.2.7.110 NMAC) Compliance Certi?cation Reports, Semi?Annual monitoring reports, compliance schedule progress reports, and any other compliance status information required by this permit shall be certi?ed by the responsible of?cial and submitted to the mailing address below, or as directed by the Department: Manager, Compliance and Enforcement Section New Mexico Environment Department Air Quality Bureau 525 Camino de los Marquez, Suite 1 Santa Fe, NM 87505?1 816 Compliance Certi?cation Reports shall also be submitted to the Administrator at the address below (20.2.70.302.E.3 NMAC): Chief, Air Enforcement Section US EPA Region?6, 6EN-AA 1445 Ross Avenue, Suite 1200 Dallas, TX 75202?2733 Yes Explain Below No Explain Below Explain Below REMARKS Except for deviations reported on the semi-annual reports and/or this report. ACC Form Part 1 Permit R2M1 Ver 4.1 5/6/2015 Page 127 of 144 EPA Inspection Report - Page 363 of 1969 PART 1 General Conditions B106 NSPS and/or MACT Startup. Shutdown. and Malfunction Operations Yes No Explain Explain Explain A. If a facility is subject to a NSPS standard in 40 CFR 60, each owner or operator that installs and operates a Below Below Below continuous monitoring device required by a NSPS regulation shall comply with the excess emissions reporting requirements in accordance with 40 CF B. If a facility is subject to a NSPS standard in 40 CFR 60, then in accordance with 40 CFR operations during periods of startup, shutdown, and malfunction shall not constitute representative conditions for the purpose of a performance test nor shall emissions in excess of the level of the applicable emission limit during periods of startup, shutdown, and malfunction be considered a violation of the applicable emission limit unless otherwise specified in the applicable standard. C. If a facility is subject to a MACT standard in 40 CFR 63, then the facility is subject to the requirement for a Startup, Shutdown and Malfunction Plan (SSM) under 40 CFR unless speci?cally exempted in the applicable subpart. (20.2.70.302.A.1 and A4 NMAC) REMARKS: Except for deviations reported on the semi-annual reports and/or this report. B107 Startup, Shutdown. and Maintenance Operations XI Yes No Explain Explain Explain Below Below Below A. The establishment of permitted startup, shutdown, and maintenance (S SM) emission limits does not supersede the requirements of20.2.7.14.A NMAC. Except for operations or equipment subject to Condition B106, the permittee shall establish and implement a plan to minimize emissions during routine or predictable start up, shut down, and scheduled maintenance (S SM work practice plan) and shall operate in accordance with the procedures set forth in the plan. (20.2.7.14.A NMAC) REMARKS: Except for deviations reported on the semi-annual reports and/or this report. ACC Form Part 1 Permit Ver 4.1 5/6/2015 Page 128 of 144 EPA Inspection Report - Page 364 of 1969 PART 1 General Conditions B108 General Monitoring Requirements XI Yes No (20.2.70. 302A and NMAC) Explain Explain Explain Below Below Below A. (1) (2) (3) These requirements do not supersede or relax requirements of federal regulations. The following monitoring and/or testing requirements shall be used to determine compliance with applicable requirements and emission limits. Any sampling, whether by portable analyzer or EPA reference method, that measures an emission rate over the applicable averaging period greater than an emission limit in this permit constitutes noncompliance with this permit. The Department may require, at its discretion, additional tests pursuant to EPA Reference Methods at any time, including when sampling by portable analyzer measures an emission rate greater than an emission limit in this permit; but such requirement shall not be construed as a determination that the sampling by portable analyzer does not establish noncompliance with this permit and shall not stay enforcement of such noncompliance based on the sampling by portable analyzer. If the emission unit is shutdown at the time when periodic monitoring is due to be accomplished, the permittee is not required to restart the unit for the sole purpose of performing the monitoring. Using electronic or written mail, the permittee shall notify the Department?s Enforcement Section of a delay in emission tests prior to the deadline for accomplishing the tests. Upon recommencing operation, the permittee shall submit any pertinent pre-test noti?cation requirements set forth in the current version of the Department?s Standard Operating Procedures For Use Of Portable Analyzers in Performance Test, and shall accomplish the monitoring. The requirement for monitoring during any monitoring period is based on the percentage of time that the unit has operated. However, to invoke monitoring period exemptions at hours of operation shall be monitored and recorded. If the emission unit has operated for more than 25% of a monitoring period, then the permittee shall conduct monitoring during that period. If the emission unit has operated for 25% or less of a monitoring period then the monitoring is not required. After two successive periods without monitoring, the permittee shall conduct monitoring during the next period regardless of the time operated during that period, except that for any monitoring period in which a unit has operated for less than 10% of the monitoring period, the period will not be considered as one of the two successive periods. If invoking the monitoring period exemption in the actual operating time of a unit shall not exceed the monitoring period required by this permit before the required monitoring is performed. For example, if the ACC Form Part 1 Permit P05 R2M1 Ver 4.1 5/6/2015 Page 129 of 144 EPA Inspection Report - Page 365 of 1969 PART 1 General Conditions monitoring period is annual, the operating hours of the unit shall not exceed 8760 hours before monitoring is conducted. Regardless of the time that a unit actually operates, a minimum of one of each type of monitoring activity shall be conducted during the ?ve year term of this permit. E. The permittee is not required to report a deviation for any monitoring or testing in a Speci?c Condition if the deviation was authorized in this General Condition B108. F. For all periodic monitoring events, except when a federal or state regulation is more stringent, three test runs shall be conducted at 90% or greater of the unit?s capacity as stated in this permit, or in the permit application if not in the permit, and at additional loads when requested by the Department. If the 90% capacity cannot be achieved, the monitoring will be conducted at the maximum achievable load under prevailing operating conditions except when a federal or state regulation requires more restrictive test conditions. The load and the parameters used to calculate it shall be recorded to document operating conditions and shall be included with the monitoring report. G. When requested by the Department, the permittee shall provide schedules of testing and monitoring activities. Compliance tests from previous NSR and Title permits may be re-imposed if it is deemed necessary by the Department to determine whether the source is in compliance with applicable regulations or permit conditions. H. If monitoring is new or is in addition to monitoring imposed by an existing applicable requirement, it shall become effective 120 days after the date of permit issuance. For emission units that have not commenced operation, the associated new or additional monitoring shall not apply until 120 days after the units commence operation. All pre? existing monitoring requirements incorporated in this permit shall continue to apply from the date of permit issuance. All monitoring periods, unless stated otherwise in the speci?c permit condition or federal requirement, shall commence at the beginning of the 12 month reporting period as de?ned at condition A109.B. REMARKS: Except for deviations reported on the semi?annual reports and/or this report. ACC Form Part 1 Permit R2M1 Page 130 of 144 Ver 4.1 5/6/2015 EPA Inspection Report - Page 366 of 1969 PART 1 General Conditions B109 General Recordkeeping Requirements (20.2.70.302.D.1 NMAC) A. The permittee shall maintain records to assure and verify compliance with the terms and conditions of this permit and any applicable requirements that become effective during the term of this permit. The minimum information to be included in these records is (20.2.70.302.D.1 NMAC): (1) Records required for testing and sampling: equipment identi?cation (include make, model and serial number for all tested equipment and emission controls); date(s) and time(s) of sampling or measurements; date(s) analyses were performed; the company or entity that performed the analyses; (6) analytical or test methods used; results of analyses or tests; and operating conditions existing at the time of sampling or measurement. (2) Records required for equipment inspections and/ or maintenance required by this permit: equipment identi?cation number (including make, model and serial number) date(s) and time(s) of inspection, maintenance, and/ or repair date(s) any subsequent analyses were performed (if applicable) name of the person or quali?ed entity conducting the inspection, maintenance, and/or repair copy of the equipment manufacturer?s or the owner or operator?s maintenance or repair recommendations (if required to demonstrate compliance with a permit condition) description of maintenance or repair activities conducted all results of any required parameter readings a description of the physical condition of the equipment as found during any required inspection results of required equipment inspections including a description of any condition which required Yes Explain Below No Explain Below Explain Below ACC Form Part 1 Permit Ver 4.1 5/6/2015 Page 131 of 144 EPA Inspection Report - Page 367 of 1969 PART 1 General Conditions adjustment to bring the equipment back into compliance and a description of the required adjustments B. The permittee shall keep records of all monitoring data, equipment calibration, maintenance, and inspections, Data Acquisition and Handling System (DAHS) if used, reports, and other supporting information required by this permit for at least ?ve (5) years from the time the data was gathered or the reports written. Each record shall clearly identify the emissions unit and/or monitoring equipment, and the date the data was gathered. (20.2.70.302.D.2 NMAC) C. If the permittee has applied and received approval for an alternative operating scenario, then the permittee shall maintain a log at the facility, which documents, contemporaneously with any change from one operating scenario to another, the scenario under which the facility is operating. (20.2.70.302.A.3 NMAC) D. The permittee shall keep a record describing off permit changes made at this source that result in emissions of a regulated air pollutant subject to an applicable requirement, but not otherwise regulated under this permit, and the emissions resulting from those changes. (202.70.302.12 NMAC) E. Unless otherwise indicated by Speci?c Conditions, the permittee shall keep the following records for malfunction emissions and routine and predictable emissions during startup, shutdown, and scheduled maintenance (SSM): The owner or operator of a source subject to a permit, shall establish and implement a plan to minimize emissions during routine or predictable startup, shutdown, and scheduled maintenance through work practice standards and good air pollution control practices. This requirement shall not apply to any affected facility de?ned in and subject to an emissions standard and an equivalent plan under 40 CFR Part 60 (NSPS), 40 CFR Part 63 (MACT), or an equivalent plan under 20.2.72 NMAC Construction Permits, 20.2.70 NMAC Operating Permits, 20.2.74 NMAC Permits Prevention of Signi?cant Deterioration (PSD), or 20.2.79 NMAC Permits - Nonattainment Areas. (20.2.7.14.A NMAC) The permittee shall keep records of all sources subject to the plan to minimize emissions during routine or predictable SSM and shall record if the source is subject to an alternative plan and therefore, not subject to the plan requirements under 20.2.7.14.A NMAC. (2) If the facility has allowable SSM emission limits in this permit, the permittee shall record all SSM events, including the date, the start time, the end time, a description of the event, and a description of the cause of the event. This record also shall include a copy of the manufacturer?s, or equivalent, documentation showing that any maintenance quali?ed as scheduled. Scheduled maintenance is an activity that occurs at an established frequency pursuant to a written protocol published by the manufacturer or other reliable source. The authorization of allowable SSM emissions does not supersede any applicable federal or state standard. The most stringent requirement applies. (3) If the facility has allowable malfunction emission limits in this permit, the permittee shall record all malfunction ACC Form Part 1 Permit P051-R2 Page 132 of 144 Ver 4.1 5/6/2015 EPA Inspection Report - Page 368 of 1969 PART 1 General Conditions events to be applied against these limits. The permittee shall also include the date, the start time, the end time, and a description of the event. Malfunction means any sudden and unavoidable failure of air pollution control equipment or process equipment beyond the control of the owner or operator, including malfunction during startup or shutdown. A failure that is caused entirely or in part by poor maintenance, careless operation, or any other preventable equipment breakdown shall not be considered a malfunction. (20.2.7.7.E NMAC) The authorization of allowable malfunction emissions does not supersede any applicable federal or state standard. The most stringent requirement applies. This authorization only allows the permittee to avoid submitting reports under 20.2.7 NMAC for total annual emissions that are below the authorized malfunction emission limit. (4) The owner or operator of a source shall meet the operational plan de?ning the measures to be taken to mitigate source emissions during malfunction, startup or shutdown. NMAC) REMARKS: Except for deviations reported on the semi-annual reports and/or this report. B110 General Reporting Requirements Yes 0 [3 (20.2.70.302.E NMAC) Explain Explain Explain Below Below Below A. Reports of required monitoring activities for this facility shall be submitted to the Department on the schedule in section A109. Monitoring and recordkeeping requirements that are not required by a NSPS or MACT shall be maintained on?site or (for unmanned sites) at the nearest company of?ce, and summarized in the semi-annual reports, unless alternative reporting requirements are speci?ed in the equipment speci?c requirements section of this permit. B. Reports shall clearly identify the subject equipment showing the emission unit ID number according to this operating permit. In addition, all instances of deviations from permit requirements, including those that occur during emergencies, shall be clearly identi?ed in the reports required by section A109. (20.2.70.302.E.l NMAC) C. The permittee shall submit reports of all deviations from permit requirements, including those attributable to upset conditions as de?ned in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. These reports shall be submitted as follows: (1) Deviations resulting in excess emissions as de?ned in 20.2.7.7 WAC (including those classi?ed as emergencies as de?ned in section Bl l4.A) shall be reported in accordance with the timelines speci?ed by 20.2.7.1 10 WAC and in the semi?annual reports required in section A109. (20.2.70.302.E.2 NMAC) (2) All other deviations shall be reported in the semi-annual reports required in section A109. (20.2.70.302.E.2 ACC Form Part 1 Permit Page 133 of 144 Ver 4.1 5/6/2015 EPA Inspection Report - Page 369 of 1969 PART 1 General Conditions (1) (2) (3) (4) (5) l. (1) NMAC). The permittee shall submit reports of excess emissions in accordance with 20.2.7.110.A NMAC. Results of emission tests and monitoring for each pollutant (except opacity) shall be reported in pounds per hour (unless otherwise speci?ed) and tons per year. Opacity shall be reported in percent. The number of signi?cant ?gures corresponding to the full accuracy inherent in the testing instrument or Method test used to obtain the data shall be used to calculate and report test results in accordance with 20.2.1.116.B and NMAC. Upon request by the Department, CEMS and other tabular data shall be submitted in editable, MS Excel format. At such time as new units are installed as authorized by the applicable NSR Permit, the permittee shall ful?ll the noti?cation requirements in the NSR permit. Periodic Emissions Test Reporting: The permittee shall report semi?annually a summary of the test results. The permittee shall submit an emissions inventory for this facility annually. The emissions inventory shall be submitted by the later of April 1 or within 90 days after the Department makes such request. (20.2.73 NMAC and 20.2.70.302.A.l NMAC) The facility emits, or has the potential to emit, 5 tons per year or more of lead or lead compounds, or 100 tons per year or more of PMI 0, PM2.5, sulfur oxides, nitrogen oxides, carbon monoxide, or volatile organic compounds. The facility is de?ned as a major source of hazardous air pollutants under 20.2.70 NMAC (Operating Permits). The facility is located in an ozone nonattainment area and which emits, or has the potential to emit, 25 tons per year or more of nitrogen oxides or volatile organic compounds. Upon request by the department. The permittee shall submit the emissions inventory report by April 1 of each year, unless a different deadline is speci?ed by the current operating permit. Emissions trading within a facility (20.2.70.302.H.2 NMAC) For each such change, the permittee shall provide written noti?cation to the department and the administrator at least seven (7) days in advance of the proposed changes. Such noti?cation shall state when the change will occur and shall describe the changes in emissions that will result and how these increases and decreases in emissions will comply with the terms and conditions of the permit. (2) The permittee and department shall attach each such notice to their copy of the relevant permit. ACC Form Part 1 Permit P051-R2 Ver 4.1 5/6/2015 Page 134 of 144 EPA Inspection Report - Page 370 of 1969 PART 1 General Conditions REMARKS Except for deviations reported on the semi-annual reports and/or this report. B111 General Testing Requirements Yes No El Explain Explain Explain A. Compliance Tests Below Below Below (1) (2) (3) (4) (5) (6) Compliance test requirements from previous permits (if any) are still in effect, unless the tests have been satisfactorily completed. Compliance tests may be re?imposed if it is deemed necessary by the Department to determine whether the source is in compliance with applicable regulations or permit conditions. (20.2.72 NMAC Sections 210C and 213) Compliance tests shall be conducted within sixty (60) days after the unit(s) achieve the maximum normal production rate. If the maximum normal production rate does not occur within one hundred twenty (120) days of source startup, then the tests must be conducted no later than one hundred eighty (1 80) days after initial startup of the source. Unless otherwise indicated by Speci?c Conditions or regulatory requirements, the default time period for each test run shall be at least 60 minutes and each performance test shall consist of three separate runs using the applicable test method. For the purpose of determining compliance with an applicable emission limit, the arithmetic mean of results of the three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the three runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances, beyond the owner or operator's control, compliance may, upon the Department approval, be determined using the arithmetic mean of the results of the two other runs. Testing of emissions shall be conducted with the emissions unit operating at 90 to 100 percent of the maximum operating rate allowed by the permit. If it is not possible to test at that rate, the source may test at a lower operating rate, subject to the approval of the Department. Testing performed at less than 90 percent of permitted capacity will limit emission unit operation to 1 10 percent of the tested capacity until a new test is conducted. If conditions change such that unit operation above 110 percent of tested capacity is possible, the source must submit a protocol to the Department within 30 days of such change to conduct a new emissions test. ACC Form Part 1 Permit Ver 4.1 5/6/2015 Page 135 of144 EPA Inspection Report - Page 371 of 1969 PART 1 General Conditions B. C. EPA Reference Method Tests (1) All compliance tests required by this permit, unless otherwise speci?ed by Speci?c Conditions of this permit, shall be conducted in accordance with the requirements of 40 CFR 60, Subpart A, General Provisions, and the following EPA Reference Methods as specified by 40 CFR 60, Appendix A: (C) (1) (1n) Methods 1 through 4 for stack gas flowrate Method 5 for TSP Method 6C and 19 for 802 Method 7E for NOX (test results shall be expressed as nitrogen dioxide (N02) using a molecular weight of 46 lb/lb-mol in all calculations (each of is equivalent to 1.194 10?7 Method 9 for opacity Method 10 for CO Method 19 may be used in lieu of Methods 1-4 for stack gas flowrate upon approval of the Department. A justification for this proposal must be provided along with a contemporaneous fuel gas analysis (preferably on the day of the test) and a recent fuel flow meter calibration certificate (within the most recent quarter). Method 7E or 20 for Turbines per 60.335 or 60.4400 Method 29 for Metals Method 201A for filterable PM10 and PM25 Method 202 for condensable PM Method 320 for organic Hazardous Air Pollutants (HAPs) Method 25A for VOC reduction efficiency Method 30B for Mercury (2) Alternative test method(s) may be used if the Department approves the change. Periodic Monitoring and Portable Analyzer Requirements (1) Periodic emissions tests (periodic monitoring) may be conducted in accordance with EPA Reference Methods or by utilizing a portable analyzer. Periodic monitoring utilizing a portable analyzer shall be conducted in accordance with the requirements of ASTM 6522?00. However, if a facility has met a previously approved ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 5/6/2015 Page 136 of144 EPA Inspection Report - Page 372 of 1969 PART 1 General Conditions (2) (3) (4) (5) Department criterion for portable analyzers, the analyzer may be operated in accordance with that criterion until it is replaced. Unless otherwise indicated by Speci?c Conditions or regulatory requirements, the default time period for each test run shall be at least 20 minutes. Each performance test shall consist of three separate runs. The arithmetic mean of results of the three runs shall be used to determine compliance with the applicable emission limit. Testing of emissions shall be conducted in accordance with the requirements at Section B108.F. During emissions tests, pollutant and diluent concentration shall be monitored and recorded. Fuel ?ow rate shall be monitored and recorded if stack gas ?ow rate is determined utilizing Method 19. This information shall be included with the test report furnished to the Department. Stack gas ?ow rate shall be calculated in accordance with 40 CFR 60, Appendix A, Method 19 utilizing fuel ?ow rate (scf) determined by a dedicated fuel ?ow meter and fuel heating value (Btu/scf) determined from a fuel sample obtained preferably during the day of the test, but no earlier than three months prior to the test date. Alternatively, stack gas ?ow rate may be determined by using EPA Methods l-4. D. Test Procedures: (1) (2) (3) (4) (5) (6) (7) The permittee shall notify the Department?s Program Manager, Compliance and Enforcement Section at least thirty (30) days before the test to afford a representative of the Department an opportunity to be present at the test. (40CFR Equipment shall be tested in the "as found" condition. Equipment may not be adjusted or tuned prior to any test for the purpose of lowering emissions, and then returned to previous settings or operating conditions after the test is complete. Contents of test noti?cations, protocols and test reports shall conform to the format speci?ed by the Department?s Universal Test Noti?cation, Protocol and Report Form and Instructions. Current forms and instructions are posted to Air Quality web site under Compliance and Enforcement Testing. The permittee shall provide sampling ports adequate for the test methods applicable to the facility, safe sampling platforms, safe access to sampling platforms and utilities for sampling and testing equipment. The stack shall be of suf?cient height and diameter and the sample ports shall be located so that a representative test of the emissions can be performed in accordance with the requirements of EPA Method 1 or ASTM 6522? 00 as applicable. Where necessary to prevent cyclonic ?ow in the stack, ?ow straighteners shall be installed Unless otherwise indicated by Speci?c Conditions or regulatory requirements, test reports shall be submitted to the Department no later than 30 days after completion of the test. ACC Form Part 1 Permit Ver 4.1 5/6/2015 Page 137 of 144 EPA Inspection Report - Page 373 of 1969 PART 1 General Conditions REMARKS Except for deviations reported on the semi-annual reports and/or this report. B112 Compliance Yes No '3 Explain Explain Explain Below Below Below A. E. The Department shall be given the right to enter the facility at all reasonable times to verify the terms and conditions of this permit. Required records shall be organized by date and subject matter and shall at all times be readily available for inspection. The permittee, upon verbal or written request from an authorized representative of the Department who appears at the facility, shall immediately produce for inspection or copying any records required to be maintained at the facility. Upon written request at other times, the permittee shall deliver to the Department paper or electronic copies of any and all required records maintained on site or at an off?site location. Requested records shall be copied and delivered at the permittee?s expense within three business days from receipt of request unless the Department allows additional time. Required records may include records required by permit and other information necessary to demonstrate compliance with terms and conditions of this permit. (NMSA 1978, Section 74~2?1 3) A copy of the most recent permit(s) issued by the Department shall be kept at the permitted facility or (for unmanned sites) at the nearest company of?ce and shall be made available to Department personnel for inspection upon request. (20.2.70.302.G.3 NMAC) Emissions limits associated with the energy input of a Unit, i.e. lb/MMBtu, shall apply at all times unless stated otherwise in a Speci?c Condition of this permit. The averaging time for each emissions limit, including those based on energy input of a Unit lb/MMBtu) is one (1) hour unless stated otherwise in a Speci?c Condition of this permit or in the applicable requirement that establishes the limit. (20.2.70.302.A.1 and G.3 NMAC) The permittee shall submit compliance certi?cation reports certifying the compliance status of this facility with respect to all permit terms and conditions, including applicable requirements. These reports shall be made on the pre?populated Compliance Certi?cation Report Form that is provided to the permittee by the Department, and shall be submitted to the Department and to EPA at least every 12 months. For the most current form, please contact the Compliance Reports Group at For additional reporting guidance see (20.2.70.302.E.3 NMAC) The permittee shall allow representatives of the Department, upon presentation of credentials and other documents ACC Form Part 1 Permit P051-R2 Ver 4.1 5/6/2015 Page 138 of 144 EPA Inspection Report - Page 374 of 1969 PART 1 General Conditions as may be required by law, to do the following (20.2.70.302.G.1 NMAC): (1) enter the permittee?s premises where a source or emission unit is located, or where records that are required by this permit to be maintained are kept; (2) have access to and copy, at reasonable times, any records that are required by this permit to be maintained; (3) inspect any facilities, equipment (including monitoring and air pollution control equipment), work practices or operations regulated or required under this permit; and (4) sample or monitor any substances or parameters for the purpose of assuring compliance with this permit or applicable requirements or as otherwise authorized by the Federal Act. REMARKS: Except for deviations reported on the semi?annual reports and/0r this report. B113 Permit Reopening and Revocation A. This permit will be reopened and revised when any one of the following conditions occurs, and may be revoked and reissued when or occurs. (20.2.70.405.A.1 NMAC) (1) (2) (3) (4) Additional applicable requirements under the Federal Act become applicable to a major source three (3) or more years before the expiration date of this permit. If the effective date of the requirement is later than the expiration date of this permit, then the permit is not required to be reopened unless the original permit or any of its terms and conditions has been extended due to the Department's failure to take timely action on a request by the permittee to renew this permit. Additional requirements, including excess emissions requirements, become applicable to this source under Title IV of the Federal Act (the acid rain program). Upon approval by the Administrator, excess emissions offset plans will be incorporated into this permit. The Department or the Administrator determines that the permit contains a material mistake or that inaccurate statements were made in establishing the terms and conditions of the permit. The Department or the Administrator determines that the permit must be revised or revoked and reissued to assure compliance with an applicable requirement. KI Yes Explain Below No Explain Below Explain Below ACC Form Part 1 Permit Ver 4.1 5/6/2015 Page 139 of 144 EPA In spection Report - Page 375 of 1969 PART 1 General Conditions B. Proceedings to reopen or revoke this permit shall affect only those parts of this permit for which cause to reopen or revoke exists. Emissions units for which permit conditions have been revoked shall not be operated until new permit conditions have been issued for them. (20.2.70.405.A.2 NMAC) REMARKS: Except for deviations reported on the semi?annual reports and/or this report. B114 Emergencies (20.270304 NMAC"emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the permittee, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology?based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventive maintenance, or careless or improper operation. An emergency constitutes an affirmative defense to an action brought for noncompliance with technology?based emission limitations contained in this permit if the permittee has demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that: An emergency occurred and that the permittee can identify the cause(s) of the emergency; This facility was at the time being properly operated; During the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or other requirements in this permit; and The permittee submitted notice of the emergency to the Department within 2 working days of the time when emission limitations were exceeded due to the emergency. This notice ful?lls the requirement of 20.2.70.302.E.2 NMAC. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency has the burden of proof. XI Yes Explain Below No Explain Below Explain Below ACC Form Part 1 Permit P05 l?R2 Ver 4.15/6/2015 Page 140 of 144 EPA Inspection Report - Page 376 of 1969 PART 1 General Conditions D. This provision is in addition to any emergency or upset provision contained in any applicable requirement. REMARKS Except for deviations reported on the semi-annual reports and/or this report. B115 Stratospheric Ozone A. (20.2.70.302.A.l NMAC) If this facility is subject to 40 CFR 82, Subpart F, the permittee shall comply with the following standards for recycling and emissions reductions: Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices, except for motor vehicle air conditioners (MVAC) and MVAC-like appliances. (40 CFR 82.156) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment. (40 CFR 82.158) Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certi?cation program. (40 CFR 82.161) Yes Explain Below I: No Explain Below El Explain Below REMARKS Except for deviations reported on the semi?annual reports and/or this report. B116 Acid Rain Sources A. B. (20.2.70.302.A.9 NMAC) If this facility is subject to the federal acid rain program under 40 CFR 72, this section applies. Where an applicable requirement of the Federal Act is more stringent than an applicable requirement of regulations promulgated under Title IV of the Federal Act, both provisions are incorporated into this permit and are federally enforceable. Emissions exceeding any allowances held by the permittee under Title IV of the Federal Act or the regulations promulgated thereunder are prohibited. Yes Explain Below No Explain Below Explain Below ACC Form Part 1 Permit Ver 4.1 5/6/2015 Page 141 of144 EPA Inspection Report - Page 377 of 1969 PART 1 General Conditions D. No modi?cation of this permit is required for increases in emissions that are authorized by allowances acquired pursuant to the acid rain program, provided that such increases do not require a permit modi?cation under any other applicable requirement. E. The permittee may not use allowances as a defense to noncompliance with any other applicable requirement. F. No limit is placed on the number of allowances held by the acid rain source. Any such allowance shall be accounted for according to the procedures established in regulations promulgated under Title IV of the Federal Act. G. The acid rain permit is an enclosure of this operating permit. REMARKS: B117 Risk Management Plan (20.2.70.302.A.1 NMAC) If this facility is subject to the federal risk management program under 40 CFR 68, this section applies. The owner or operator shall certify annually that they have developed and implemented a RMP and are in compliance with 40 CFR 68. If the owner or operator of the facility has not developed and submitted a risk management plan according to 40 CFR 68.150, the owner or operator shall provide a compliance schedule for the development and implementation of the plan. The plan shall describe, in detail, procedures for assessing the accidental release hazard, preventing accidental releases, and developing an emergency response plan to an accidental release. The plan shall be submitted in a method and format to a central point as specified by EPA prior to the date specified in 40 CFR 68.150.b. IXI Yes Explain Below No Explain Below Explain Below REMARKS Except for deviations reported on the semi-annual reports and/or this report. ACC Form Part 1 Permit P051-R2 Ver 4.1 5/6/2015 Page 142 of 144 EPA Inspection Report - Page 378 of 1969 Part 2 ACC Deviation Summary Report for Permit P051-R2 R2M1 (IncludeRujle-Citation) . - A106.C, Al O7.C, Allowable Flare monitoring implemented to meet NSPS a Navajo is working on evaluating the data and will SSM and Malfunction Emissions. requirements has resulted in data that is being address any reporting of excess emissions that may 1 evaluated with respect to potential exceedences of be necessary with the NMED. permit limits. Thus, any excess emissions have not been reported to date. 2 3 4 5 ACC Part 2, Deviation Summary Title?V Permit Page 143 of 144 EPA Inspection Report - Page 379 of 1969 No. Date . Time Date :Time - Pollutant Mon1tor1ng MGthOd Amount Of Emissions 1 8/31/2016 Data Unknown Yes [ACC Part 2, Deviation Summary Title?V Permit P05 R2M1 Page 144 of 144 EPA Inspection Report - Page 380 of 1969 New Mexico Environment Department - Air Quality Bureau Compliance and Enforcement Section 525 Camino de Los Marquez - Suite 1 - Santa Fe, NM 87505 Phone (505) 476?4300 - Email: Excess Emissions Reporting Form AlNu'mberig 198 "Emission? UnitNo; A Unit 55 1 Activity _N_q'mber3fi 000198-09292016-01 _-Emission Unit'Desc: ?ngeneral Plant, Racks, and Flares FacilityName; Navajo Refining Company LLC 1 Release PointNo; FL-O4OO ,CompanyiName: Navajo Refining Artesia Refinery Release Point_Des_c.: North Plant Flare Sourceis; StationarySource??y Yes 00:00 ,yP?irtable Source? N0 [Start Date/Time; r11/o1/201500:oo Portable Locationz'l'ni 4 UTM EndDate/Time 3* Lat: . Long: 51st Business bayafter 11/02/2015 - - ?y Discovery: TitleVPermitNo.51]; P051-R2M1 r. _y Status; lnitialEER PSD0195-M37 7 Raymond Smalts =o?iceph?he3 575-746?5490 i?Exth-Po' EemailAddkresyrs?: L, Cell Phone]; Reporting Regru'rgme? Malfunction 20.2.70NMAC (Title v) ,1 Shadow? 60(Nses) I, ?y . I. ,1 ?isExplain: Emergency (MACT) Schedule MaintenanCe Title VDeViation Af?rmative DefenseClaim: Yes Page 1 of 2 EPA Inspection Report - Page 381 of 1969 Detailed? Description: It was discovered that on approximately 11/01/2015, Navajo had potentially exceeded the permitted TPY limits for 802, CO, and VOC. By clicking on the Certify i ComplianceTesting, g. a .- - ?After reasonable inguiry,lcertifythis reportastrue, a?ocurate and com?lete'. I Continuous Emissron Monitor - a p, CalcUlation r, . Reporting Of?cial: Raymond Smalts . Operating Log(?s) Title: I Environmental Specialist Other: {Date} I 09/29/2016 Page 2 of 2 EPA Inspection Report - Page 382 of 1969 New Mexico Environment Department - Air Quality Bureau Compliance and Enforcement Section 525 Camino de Los Marquez - Suite 1 - Santa Fe, NM 87505 Phone (505) 476-4300 - Email: Excess Emissions Reporting Form Al Numben: f, 198 EmissionUnit?Noiz: Unit55 ActivityNumbergm 7000198-09292016-02 {General Plant, Racks, and Flares Facility Nana; Navajo Refining Company LLC ?Releas?ePointNo Company Name: ?Navajo Refining - Artesia Refinery 3 ReleasePoint peso; South Plant Flare Source is;? 1 Stationary: Source? Yes _r,rpisooyaryDate/nine: 2 11/01/2015 00:00 Pwab?eswme? N0 ,7 Start Date/Time: '11/01/2015 00:00 ?Portablelaocationiy ,5 UT EndDate/Timer; I Lat: ?Long: I ?y1stBusmess Day after 11/02/2015 . .- 7 Discovery: 9 TitleVPermitNoan" 1 a 3 [SubmiSSionStatmz 'y Initial EER NSRPermitNo; - FrirStnaryneP/ La?tnarne: Raymond Smalts Office Pnonei _575-746-5490 gEXt?T-i EjmailAddress:_y, 2 1' :7 Repom?ng Requ'rement {malfunction ?g 2027NMAC Stamp I, Datezk- shutdown 20 .2. 70 (Title V) I 40 CFR 60 (NSPS) _y Explain; 7 [Emergency 35:1 Schedule Maintenance 0 TitleVDeVIation 'y Affirmative Defense Claim: DYes Page 1 of 2 EPA Inspection Report - Page 383 of 1969 Detailed Description; It was discovered that on approximately 11/01/2015, Navajo had potentially exceeded the permitted TPY limits for 802, CO, and VOC, Detailed Description: a on theCertify button,lagree to thefollowing? Compliance Testing, ,1 . AfterlreasOnable inquiry,,l certify thisrepdrt as true, accurate and complete. Continuous Emissmn Monitor a Calculation 1 . I Reporting Of?mal: Raymond Smalts Operating Log(s) I :Title: ., Environmental Specialist 1 Other: :Date?i I 09/29/2016 Page 2 of 2 EPA Inspection Report - Page 384 of 1969 New Mexico Environment Department - Air Quality Bureau Compliance and Enforcement Section 525 Camino de Los Marquez - Suite 1 Santa Fe, NM 87505 Phone (505) 476?4300 - Email: Excess Emissions Reporting Form AI Number: 3' - 198 my Em?iSSiOnUIiit?N?-g, 0 Unit 55 Activity Number: 000198?09292016-03 al'j?ceneral Plant, Racks, and Flares Facility Name 3' Navajo Refining Company LLC 4? 1 I FL-O402 Company Name: 3, if Navajo Refining Artesia Refinery 1 ReleasePomtDesc FCC Flare So?urcelsiir Source? 3 Yes 1, {Discovery Date/T irne'j} ffr11/O1/2015 00:00 Pertable Source? N0 yr sia?vpai?mme; 11/01/2015 00:00 ~33 I 7 y'Lat; Long: 3 737151 Business Day after?) 41/02/2015 Discovery TitleVPermitNoi-z' PO51-R2M1 ,1 ?1 x, - gSuxmeSSTonStatusr77;l Initial EER NSR Permit No.: PSDO195-M37 First?name/nL?astname: I Raymond mealts C?Qf?cephonezM 575-746?5490 ?Ex?tnsyi ,E?mall Addressq?pl Reporting Requrrement 'MalfunCtionC,Startyup 5 Datezyzeii 20. 2. 70 NMAC (Title V) Shutdown a 40 6O (NSPS) Emergency El 40 CFR 63 (MACT) FSchedule Maintenance ,yle?eVDeVIathl'l LAf?fma?tiVe?Def?ns?e? Claim: ~Yes Page 1 of 2 EPA Inspection Report - Page 385 of 1969 Detailed LDeScription: It was discovered that on approximately 11/01/2015, Navajo had potentially exceeded the permitted TPY limits for 802, CO, and VOC. on the'Certify button,lagreetothe following: Compliance Testing . - I i After reaSOna?ble inquiry, certify this report as true, accurate and completerT' a Continuous Emission Monitor . I i Calculation . - 7 Reportinngf?cial: Raymond Smalts 3 Operating Log(s) V?Titlezy' Environmental Specialist Other: L?Date: [09/29/2016 Page 2 of 2 EPA Inspection Report - Page 386 of 1969 New Mexico Environment Department - Air Quality Bureau Compliance and Enforcement Section 525 Camino de Los Marquez Suite 1 - Santa Fe, NM 87505 Phone (505) 476-4300 Email: Excess Emissions Reporting Form Al Number: 198 EmiSSi0n__UnitNo;; Unit 55 000198-09292016-04 Emissie?u'nyitpe?se: ?General Plant, Racks, and Flares 'FacilityName: Navajo Refining Company LLC ?leeleaseonlnitNo; company/Name? 2 Navajo Refining Artesia Refinery ?"Release?Point Desc Alky Flare seereels? 4' ET-Statlonary Source? Yes i essee?yloaenm} 41/01/2015 00:00 "Portable Source? N0 - 11/01/2015 00:00 Location: UTM '2 Lat: Long: 1stBusmess Day after 11/02/2015 - I?Drsoovery - - PO51-R2M1 'ySubmisysiton Status," Initial EER NSR Firs'tnya/me/ rLaStname: Raymond :Smalts :OfficePh?onie: 575-746-5490 Eth.: Eama?ilAddres/yssiyf cell Phone Startup 1 Date 20. 2 70 NMAC (Title V) ShutdoWn I 40 on? 66 (NSPS) Explain: I Emergency I 340 V'schedule Maintenance Title DeVIatlon 'Af?irmati?vekbefe?nse Cir-3W? Yes Page 1 of 2 EPA Inspection Report - Page 387 of 1969 Detailed DescrIptIon y? lt was discovered that on approximately 11/01/2015, Navajo had potentially exceeded the permitted TPY limits for 802, CO, and VOC. Detailed Descriptionf Detailed Description: 7 I I By clicking onythe Ceitifyibutton,? i agree to the following: I, A I ComplIanceTestIng a ,y . After reasonable inqui, ,lcertify this re ort as true, accurate and com Wlete. i ContInuous Emission Monitor xry - up Calculation Reportmg OftICIal: Raymond Smalts W. OperatIng Log(s) - Titles Environmental Specialist Other: "Date; 09/29/2016 Page 2 of 2 EPA Inspection Report - Page 388 of 1969 New Mexico Environment Department - Air Quality Bureau Compliance and Enforcement Section 525 Camino de Los Marquez - Suite 1 - Santa Fe, NM 87505 Phone (505) 476-4300 Email: Excess Emissions Reporting Form 'A?lNum?ber.? 198 Unit 55 Activity Number) '2 5 000198?09292016-05 ?5 IEmis'sionlunitnyesc: General Plant, Racks, and Flares FraCilityN'a'me; 4, 5 Navajo Refining Company LLC Vol?Relea'se Potho 1' 5 FL-O404 compy?enyk?Namesr '1 Navajo Refining-Artesia Refinery GOHT Flare Source Yes 11/01/2015 00:00 N0 11/01/2015 00:00 I Portable Location; 5 UTM I End Date/Time ?5 I Lat: Long: ?1stBusmess Day after, 11 /02/2015 T'TDIscovery . .Tltle'VPermit [No.1, SubmissionStatuSL InitialEER Permit'No; ?Firstnameyyl' Lastname; Raymond Smalts of?ce Phonezr 2 575-746-5490 fExtn; VE-VmailAddr?ss: cellphone SS orSM/Noti?cation: 2027NMAC Startup I 'j?feae; 5'51 5 Shutdown (NSPS) I Emergency I 20. 2. 70 (Title v) 15:3 40 CFR 53 (MACT) Schedule Maintenance :5 Title Deviation I. Af?rmativeDyefenseClaim: Yes Page 1 of 2 EPA Inspection Report - Page 389 of 1969 Detailed .DeScription: lt was discovered that on approximately 11/01/2015, Navajo had potentially exCeeded the permitted TPY limits for 802, CO, and voc- Detailed Description; 3 Detailed: Description: ?By Clicking on't?heVCertifyy buttonglyagree to the following: ComplianceTeSting . i, . Afterreasonableinqui ,lcertl this re Ortastrue,accurate and com ?let?i E) Continuous Emission Monitor f_y calculation HI y' Reporting, Official; Raymond Smalts "3 operating Lyog(s) y? I I I I Titles Environmental Specialist I Other: Date: 2 09/29/2016 Page 2 of 2 EPA Inspection Report - Page 390 of 1969 New Mexico Environment Department - Air Quality Bureau Compliance and Enforcement Section 525 Camino de Los Marquez - Suite 1 Santa Fe, NM 87505 Phone (505) 476-4300 - Email: Excess Emissions Reporting Form AlNumbeh _r 198 ":Emission Ur?iiyt?Negf Unit55 Activity N?umgberzk 000198?09292016-06 itemissioniuet?pese General Plant, Racks, and Flares Facility Name: Navajo Refining Company LLC Release Point No} A'Flare Malf Cap CompanyName: I Navajo Refining - Artesia Refinery ,5 y?ReleasePomtDesc ?5 Upset and Malfunction Emissions yaStationary SoUrce? Yes DiscoveryDate/Time: 11/01/2015 00:00 N0 :z11/o1/2o15oo:oo Lat; 5 A Long; 7 yy1stBusmess Day after 11/02/2015 Discovery Titlev Permit?No; PO51-R2M1 - ,i I if 'Su?bmissionStatus; Initial EER NSR PermitNo; IPSDO195-M37 7 Firstname/yLastname: Raymond ySmalts Of?cePhone?r 575-746-5490 ,Exth; EemailAddress;_ y' Reporting Requiremen. Malfunction StartUp My, Date Ly?y" 20 7O NMAC (Title V) A Shutdown I I. It 40 CFR 60 (NSPS) Emergency Explain ?i ?40 CFR53 (MACT) ,1 Schedule Maintenance A TitleVDevration A VV'Af?yrmative? Defense Claimi? Yes Page of 2 EPA Inspection Report - Page 391 of 1969 DetailedDescription; I 1 it was discovered that on approximately 11/01/2015, Navajo had potentially exceeded the permitted TPY limits for 802, CO, and Detailed Deseriptioni, Detailed Description: By clicking on the Certifyibuitton,? i agree to they?followingzy I ft? {Compliance Testing 1, 1 . 'AfterreaSOnable in ?ui ,rlv'certi this re ortaStrue,aocurate and com'leten Continuous Emission Monitor Iqr?yp 3 ~p i Caloulationr . Reporting OffiCIalzRaymond Smalts 3 Operatih?toglsiTitlei?: Environmental eciali ."Other: 5 Date: '7 09/29/2016 Page 2 of 2 EPA Inspection Report - Page 392 of 1969 Version 05.02.13 17" Compliance and New Mexico Environment Department Air Quality Bureau .fl Enforcement Section iilfT 525 Camino de los Marquez, Suite 1 Santa Fe, NM 87505 Phone {505) 476-4300 Fax [505} 4T?r431'5 i-z'ii NMED USE ONLY 5:ng PLEASE NOTE: tii- Inditutes renuiretl field REPORTING SUBMITTAL FORM NMED USE ONLY Staff eta/m TV Ace. ?uagom SECTION I - GENERAL COMPANY AND FACILITY INFORMATION Admin gee/mp0: A. IE Company Name: HoilyFrontier Navajo Re?ning LLC D. FacilitiiI Name: Holinrontier Navajo Refining LLC 3.1 (E) Company Address: 3.1 CD Facility Address: PO Box 159 501 E.Main St. 3.2 City: 3.3 13 State: 3.4 (E) Zip: E2 (0 City: [5.3 Ci} State: E.4 Zip: Arlesia NM 318211-0159J Artesia NM 33210 (2.1 Company! Environmental Contact: 0.2 it!) Title: F.1 Facility Contact: F.2 IE Title: Scott Denton Environmental Manager Scott Denton Environmental Manager 0.3 Phone Number: (2.4 Fax Number: F.3 Phone Number: Fax Number: 515346-543? 5?5-?43-5451 EYE-T4 6?5451 0.5 iD Email Address: F.5 Email Address: G. Resonneiblebf?cial: [Title onlvi: Robert K. O'Brien H. Title: Vice President 8t Re?nery Manager. Navajo Re?ning LLC I. Phone Number: 5?5-?48-3311 J. Fax Number: 575-?4 6?5451 K. Al Number: L. Title if Permit Number: M. Title Permit Issue Date: N. NSR Permit Number: D. NSR Permit Issue Date: 198 FDS1-R2M1 01i22i2013 08i12i2015 P. Reporting Period: From: 09i01i201? To: 08i31i?201?? SECTION II TYPE OF SUBMITTAL (check one that applies) A Title Annual Compliance Permit Conditionis): Description: Codification A109 Annual Compliance Certi?cation Title Semi-annual Permit Conditionts?l: Description: Monitoring Report Reoulation: Sectionisl: t' I: NSPS Requirement m" Reuulation: t' t' MACT Requirement eo ton at camp ion (enemas) NMAC Requirement Reoulation: Sectionisl: Description: E. {20.21:} or NESHAP Requirement . Permit No.l:l: or NDI Hal]: Conditionis}: Description: Permit or Notice of intent Requirement NOV ?Until No.l:I: Sectionis]: Description: Re uirement of an . . I: Action orDthar SECTION IV - CERTIFICATION After reasonable inquiry. Robert it. O'Brien that the information in this submittal is true. accurate and complete. [name of reporting official] ure of Reporting Official: 6M (D Title: Date President 8. Re?nery Manager, 09i28i2017 Navajo Re?ning LLC 31 Responiihle Official for Title it? Yes No Reviewed By: Date Reviewed: EPA Inspection Report - Page 393 of 1969 September 28, 2017 Enforcement Manager Air Quality Bureau Enforcement Certi?ed Mail/Return Receipt NM Environment Department 7014 3490 0000 626.9 6908 525 Camino de los Marquez, Suite 1 Santa Fe, New Mexico 87505?1816 Re: Navajo Re?ning LLC Artesia, NM Re?nery Title Operating Permits P051-R2M1 Annual Compliance Certi?cation Agency Interest No. 198 Reporting Period September 1, 2016 through August 31, 2017 On behalf of Navajo Re?ning LLC (Navajo), I am submitting Navajo?s annual compliance certi?cation (ACC) for the Artesia, NM Re?nery. Title Operating Permit Reporting Period: September 1, 2016 through August 31, 2017 Consistent with the initial compliance certi?cation, items identi?ed during work practices, such as fugitive component monitoring inspections, that are corrected or repaired within the regulatory timeframe and that are properly documented, do not comprise exceptions or deviations. Please feel free to contact me at (575) 746-5487 or Ray Smalts at (575) 746?5490 if you have any questions or should require any further information. Sincerely, Scott M. Denton? Environmental Manager Navajo Refining LLC PO. Box 159 Artesia, New Mexico 88211-0159 Phone: (575) 746-5487 Email: Enclosure cc: US EPA (W/enc): Chief, Air Permits, US EPA Region 6 (6PD-R), 1445 Ross avenue, Suite 1200, Dallas, TX 75202-2733 Navajo: R. O?Brien, W. Romine, G. Combs, R. Smalts, S. Hammond Environmental File: 2.10 Annual Compliance Certi?cations (Title V)\A1tesia Certi?cation\2017 Artesia Certi?cation\2017?09- 29 Artesia Title Annual Compliance Certi?cationpdf Navajo Re?ning LLC 501 East Main Artesia, NM 88210 (575) 748?3311 - EPA Inspection Report - Page 394 of 1969 i?ev afar .33 Q: an? sea/swat Tea.? 1912 Version 05.02.13 NMED use ONLY New Mexico Environment Department Air Quality Bureau Compliance and Enforcement Section 525 Camino de los Marquez, Suite 1 Santa Fe, NM 87505 Phone (505) 476?4300 Fax (505) 476-4375 NMED USE ONLY TEMPO REPORTING SUBMITTAL FORM Staff Admin PLEASE NOTE: - Indicates required field SECTION I - GENERAL COMPANY AND FACILITY INFORMATION A. Company Name: D. Facility Name: Navajo Refining LLC HoIIyFrontier Navajo Refining LLC B.1 Company Address: E.1 Facility Address: PO Box 159 501 E.Main St. 8.2 City: 3.3 State: 8.4 Zip: E.2 City: E.3 State: EA Zip: Artesia 88211-01591- Artesia NM 88210 C.1 Company Environmental Contact: C.2 Title: F.1 Facility Contact: F.2 Title: Scott Denton Environmental Manager Scott Denton Environmental Manager C.3 Phone Number: 5757466487 C.4 Fax Number: 575?746-5451 F.3 Phone Number: 575-746-5487 F.4 Fax Number: 575-746?5451 C.5 Email Address: Scott.Denton@hoilyfrontier.com F.5 Email Address: Scott.Denton@holiyfrontiercom G. Responsible Official: IT itle onle: Robert K. O'Brien H. Title: Vice President 8 Refinery I. Phone Number: Manager, HoIIyFrontier Navajo Refining LLC 575?748?331 1 J. Fax Number: 575-745-5451 K. Al Number: L. Title Permit Number: M. Title Permit Issue Date: N. NSR Permit Number: 0. NSR Permit Issue Date: 198 P051-R2M1 01/22/2016 08/12/2016 P. Reporting Period: From: 09/01/2016 To: 08/31/2017 SECTION ii TYPE OF SUBMITTAL (check one that applies) A Title Annual Compliance Permit Conditionts): Description: Certification A109 Annual Compliance Certification Title Semi-annuai Permit Condition/s): Description: Monitoring Report Reuulation: Section(s): Description: NSPS ReqUIrement (40CFR60) Section(s): Description: MACT Reqmrement (4OCFR63) NMAC Requirement Regulation: SectionISl: Description: E. (20.2.xx) or NESHAP Requirement (4OCFR61) Permit or Condition(s): Description: Permit or Notice of Intent (NOI) Requirement NOV No. or SFO No. D: Section(s): Description: Re uirement of an Action orCD EL orOther SECTION IV - CERTIFICATION After reasonable inquiry, I Robert K. O'Brien (name of reporting official) certify that the information in this submittal is true, accurate and complete. a ure of Reporting Official: Title: Date Vice President Refinery Manager, HolIyFrontier 09/28/2017 Navajo Refining LLC Responsible Official for Title Yes No Reviewed By: Date Reviewed: EPA Inspection Report - Page 395 of 1969 Title Report Certi?cation Form I Annual Compliance Certi?cation Semi?Annual Monitoring Report Facility Name: Artesia Re?nery Facility Address: PO Box 159, Artesia State: NM Zip: 8821 '1~0159 R?Sp?.??51ble Of?cml (R0): Reba? Phone: 575-748-3311 Fax: 575-746?5421 Brien R0 Title: Vice President Re?nery Manager, Navajo Re?ning R0 e?mail: LLC Permit No.: P051-R2M1 Date Permit Issued: 01/22/2016 Report Due Date (as required by the Time period covered by this Report: From: 09/01/2016 To: 08/31/2017 Permit AI number: 0198 I am the Responsible Of?cial indicated above. Robert K. O?Brien, certify that 1 meet the requirements of 20.2.70.7.AD NMAC. I certify that, based on information and belief formed after reasonable inquiry, the statements and information contained in the attached Title report are true, accurate, and complete. ?1 2- 1 Signature 0% Date: 09/28/2017 EPA Inspection Report - Page 396 of 1969 Title Annual Compliance Certi?cation for Permit P95 1sz Title (TV) Permit Administration Amendment On January 225 2016 NMED AQB issued an Administrative Amendment to Operating Permit The Administrative Amendment corrected the following: a The Department acknowledges the aner/Permittee name change from Navajo Refining Company7 LLC. to Navajo Refining LLC, For this is an Administrative Amendment the facility can use one Annual Compliance Certi?cation (ACC) Form which will cover both TV Pennits. Although the facility is only required to submit one ACC 01111, the facility shall submit two (2) separate TV Report Certi?cation Forms. Each form shall list the corresponding TV Permit number, TV Permit Issue Date and Reporting Period. Please note that this is a one-time authorization. Submittal fonns for future Administrative Revisions will be evaluated on a case by case basis. This form can also be used for future submittal that cover only the permit. EPA Inspection Report - Page 397 of 1969 Part 1 Permit Requirements Certi?cation Table 1. Permit Condition and Permlt Condition: 2. ethod(s) or other information or other facts used to determine the compliance status: 3. What :5 the frequency of data collection used to determine compliance? . 4. Was this in compliance with this requirement during the reporting period? 5. Were there any deviations associated with this requirement during the repo?ing period? FACILITY SPECIFIC REQUIREMENTS A101 Permit Duration (expiration) A. The term of this permit is ?ve (5) years. It will expire ?ve years from the date of issuance. Application for renewal of this permit is due twelve (12) months prior to the date of expiration. (202.70.300.32 and 302B NMAC) Navajo submitted the application for renewal on September 11, 2013. El Continuous Intermittent Yes El N0 El Yes No A101 Permit Duration (expiration) B. If a renewal permit is not issued prior to the expiration date, the permittee may continue to operate beyond the expiration date, provided that a timely and complete renewal application is submitted no later than twelve (12) months prior to the expiration date. (20.2.70.400.D NMAC) Navajo submitted the application for renewal on September II, 2013. El Continuous El Intermittent Yes No Yes No A102 Facility: Description B. This facility is located in the city limits of Artesia, NM. This is the location ofNavajo re?nery. El Continuous Intermittent Yes El N0 El Yes No A103 Facility: Applicable Regulations A. The permittee shall comply with all applicable sections of the requirements listed in Table 103.A This permit condition provides a list of the applicable requirements that are addressed in detail in other permit conditions but does not impose any speci?c standards, monitoring, recordkeeping, or reporting requirements. Therefore, no further response is required. As instructed by the AQB, Navajo is completing the check box responses in columns 3, 4, El Continuous Intermittent Yes El No El Yes No EPA Inspection Report - Page 398 of 1969 Version 02.25.15 1. Permit Condition and Permit Condition: 2. Method(s) or other information or other facts used to determine the compliance status: 3. What is the frequency of data coiiection used to .- determine compliance? - 4. Was this facility in compliance with this - requirement during the reporting period? 5. Were there any deviations associated . with this requirement during the reporting period? and 5 of this form. Navajo continues to comply with all applicable requirements except for specific deviations as noted elsewhere in this document. (See the speci?c responses to the permit conditions that contain standards, monitoring, recordkeeping, or reporting requirements for more information). ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 3 of 144 EPA Inspection Report - Page 399 of 1969 Version 02.25.15 Table 103.A: Applicable Requirements Federally Applicable Requlrements Enforceable Unlt No. NSR Permit No: PSD (Per 20.2.72 NMAC) Entire Facility 20.2.1 NMAC General Provisions Entire Facility 20.2.7 NMAC Excess Emissions Entire Facility . . . . . Affected sources 20.2.33 NMAC Gas Burning Equipment Nitrogen DioXIde in Table 103E 20.2.36 NMAC Petroleum Refinery Sulfur Entire Facility 20.2.37 NMAC Petroleum Processing Facilities Entire Facility 20.2.38 NMAC Hydrocarbon Storage Facilities Entire Facility 20.2.70 NMAC Operating Permits Entire Facility 20.2.71 NMAC Operating Permit Emission Fees Entire Facility 20.2.72 NMAC Construction Permit Entire Facility 20.2.73 NMAC Notice of Intent and Emissions Inventory . . . . Entire Facrlity Requirements 20.2.74 NMAC Prevention of Signi?cant Deterioration Entire Facility Units subject to 20.2.77 NMAC New Source Performance 40 CFR 60 20.2.78 NMAC Emission Standards for Hazardous Air Pollutants Units subject to (HAPsUnits sub?ect to 20.2.82 NMAC MACT Standards for Source Categories of HAPS 40 CFR 633 40 CFR 50 National Ambient Air Quality Standards Entire Facility 40 CFR 60, Subpart A, General Provisions if): 40 CFR 60, Subpart Db ?Standards of Performance for Industrial? See Tables Commercial?lnstitutional Steam Generating Units? 1033 to 103.J 40 CFR 60, Subpart Dc ?Standards of Performance for Small Steam Generating Units, Which H-3101 Construction, Reconstruction, or Modi?cation Commenced After June 9, 1989? 40 CFR 60, Subpart J, ?Standards of Performance for Petroleum See Tables Refineries? 103.8 to 103.J 40 CFR 60, Subpart Ja, ?Standards of Performance for Petroleum See Tables Refineries for which Construction, Reconstruction, or Modification 1033 to 103,] Commenced After May 14, 2007? ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 4 of 144 EPA Inspection Report - Page 400 of 1969 Version 02.25.15 40 CFR 60, Subpart K, ?Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978? See Tables 1038 to 103.] 40 CFR 60, Subpart Ka, ?Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984? See Tables 103.B to 103k 40 CFR 60, Subpart Kb, ?Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modi?cation Commenced After January 23, 1984? See Tables 1033 to 103K 40 CFR 60, Subpart Standards of Performance for Equipment Leaks of VOC in Petroleum Re?neries for which construction, reconstruction, or modification commenced after January 4, 1983, and on or before November 7, 2006. See Tables 103.B to 103K 40 CFR 60, Subpart Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries for which construction, reconstruction, or modification commenced after November 7, 2006. See Tables 1033 to 103K 40 CFR 60, Subpart Standards of Performance for VOC See Tables Emissions From Petroleum Re?nery Wastewater Systems 1033 to 103K 40 CFR 60, Subpart Standards of Performance forwStationary See Tables Compression Ignition Internal Combustion Engines 1033 to 103K 40 CFR 61, Subpart A, General Provisions Entire Facility 40 CFR 61, Subpart FF, National Emission Standards for Benzene Benzene Waste Waste Operations Operations 40 CFR 63, Subpart A, General Provisions Entire Facility 40 CFR 63, Subpart Q, National Emission Standards for Hazardous See Table Air Pollutants for Industrial Process Cooling Towers 103.F See Tables 40 CFR 63, Subpalt CC 103B to 103K See Tables 40 CFR 63 Subpart 103B to 103K . . . See Tables 40 CFR 63 Subpart Petroleum Re?neries: Catalytic 103 to Units, Catalytic Reforming Units, and Sulfur Recovery Units 103:6 ACC Form Part 1 Permit P051-R2 Ver4.1 02/25/2015 Page 5 of 144 EPA Inspection Report - Page 401 of 1969 Version 02.25.15 40 CF 63, Subpart National Emission Standards for See Tables Hazardous Air Pollutants for Stationary Reciprocating Internal 103B to Combustion Engines 103.KJ 40 CFR 68, (RMP), Section 1 12(r) Accidental Release Entire Facility 3/5/2002 Consent Decree 1422LH Lodged 12/20/2001, Entered Entire Facility Table 103.B Summary Applicability-Fugitives Title Permit Description 20.2.37 MACT NSPS NSPS NSPS NES-HAP NESHAP Unit 11) CC CC CRUDE South Division Cmde Unit YES YES NO YES YES NO NO NO Kerosene HDS Unit Hydrodesul?lrization AMINE Amine Unit-Treating/RegenYES Sour Water Stripper YES Loading Racks ALKY North Alkylation Unit (New?Inside batteiy limitsNaphtha HDS Unit YES YES YES NO YES NO NO NO S-LSR MEROX TRT Merox/Merichem Treating Units Poweifonner/Penex Unit VACUUM Flasher/Vacuum Unit FUG-25-ROSE-2 ROSE Unit YES YES NO YES YES NO NO NO FARM Light Oil Tankage SRU3 Unit YES YES NO YES YES NO NO NO l-lDU Relocated Diesel HDS Unit YES YES YES NO YES NO NO NO FUG-34-HYDROCRACKER WX Hydi'ocracker YES YES NO YES YES NO NO NO GAS Saturates Gas Plant PBC Unit ALKY South Alky Unit (W-76Gas Oil Hydrotreater (incl. CVSACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 6 of 144 EPA Inspection Report - Page 402 of 1969 Version 02.25 .15 between railcars and trucks. Gas Oil Hydrotreater (incl. CV5Hydrogen Plant PLANT-2 Hydrogen Plant FUG-70-CCR CCR Refonner (w/in battery limitsUTIL Utilities CVS Oil/Water Separator YES YES YES NO YES NO NO YES FUG-ASPHALT STG Asphalt/Heavy Oil Storage GAS Fuel Gas Distribution System NO YESLPG Storage System YES FUG-RLO-ASPHALT Asphalt/Pitch Loading Rack YES Crude oil unloading system, closed loop system ACC Form Part 1 Permit PO5I-R2 R2M1 Ver 4.1 02/25/2015 Page 7 of 144 EPA Inspection Report - Page 403 of 1969 Version 02.25.15 Table 103.C, Summary Applicability - Tanks Ver 4.1 02/25/2015 MACT NSPS NSPS NSPS CC MACT CC NESHAP NSPS 20.2.37.205 20.2.38.'109 20.238.2110 20.2.38.112 20.2.38.113 CA Tank No. Ka Kb Storage Wastewater FF NMAC MAC NMAC NMAC NMAC T-0003 "110004 T-0013 T-0026 T-0031 T-0046 T-0056 T-0059 T-0061 T0065 T?007l T-0073 T-0076 T-0078 T-OO79 T-0081 ACC Form Part 1 Permit P051-R2 R2MI Page 8 of 144 EPA Inspection Report - Page 404 of 1969 Version 02.25.15 T-0082 T-0106 110107 T-0108 T-0112 T-O4OO T-0404 NOT-0405 T-0409 NCT-O410 12041 110412 1-0415 T-0417 T-O418 T-0419 T-O433 T-0434 T-O437 YES T-0446 T-0447 T-0448 ACC Form Part 1 Permit P05 1-112 Page 9 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 405 of 1969 Version 02.25.T-0453 T-0460 T-0737 "[0802 T-0807 T-0814 T-0834 T-0840 T-1221 T-1222 T-1224 T-1227 BiODiesel Ethanol ACC Form Part 1 Permit P051-R2 R2M1 Page 10 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 406 of 1969 Version 02.25.15 Table 103D, Summary Applicability Unit ID Description MACT CC 20.2.37.205.C MACT MACT CAM Fuels Truck Loading Rack YES NO NO NO NO Truck Loading Rack NO No NO NO NO RLO-8 Railcar Loading Off?Loading Rack NO NO NO NO NO Table 103E, Summary Applicability - Heaters and Boilers . . . NSPS NSPS NSPS MACT 20.233.108 20.2.36 20.2.37 Unit ID Description Db Dc NSPS NSPS Ja NMAC NMAC NMAC CAM Boiler Boiler Boiler Naphiha Rebeller Umt H-0018 Unit 06 HDS Reboiler H-0019 smith Ergatfharge smith iirg?rcmge H-OOZS Unit 21 Heater H-OO30 Unit 06 Charge Heater H-0040 Unit 13 Charge Heater H-0303 Unit 05 Charge Heater H-0312 Unit 10 FCC Feed Heater H-0352 70 ggieliefomer ggielfemmer H-O3 54 Um 70 ggielj?omer H-O355 Um 7.0 Stablhzer Rebo?er Heater Unit 70 CCR Heater Unit 70 CCR Heater ACC Form Part 1 Permit P051-R2 R2M1 Page 1 1 of 144 Ver 4.102/25/2015 EPA Inspection Report - Page 407 of 1969 Version 02.25.15 H-0364 Unit 70 CCR Heater Unit 44 Charge Heater SRU Hot Oil Heater H-0473 S.RU1 and .SRU2 Ta11 Gas Incmerator H-0600 09 Pepmpamzer Rebo11er Heater H-0601 Unit 33 Charge Heater Hn2421 Unit 45 Charge Heater Hydrogen Plant 802 Reformer Rebo?er 1 H3403 HydrocraCker ReamCharge Heater H9 851 64 Hydrogen Plant Reformer Unit 25 Unit H-2501 N02 Hot Oil Heater 11-3101 (formerly SRU3- SRU3 Hot Oil Heater HOH) SRU3-TGI SRU3. Tall Gas I11c1nerator ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 12 of 144 EPA Inspection Report - Page 408 of 1969 Version 02.25.15 Table 103.F, Summary Applicability - Cooling Towers Cooling Tower Description MACT MACT CC CAM TCC Cooling Tower YES YES NO Y-0002 S. Alky Cooling Tower (Marley Cooling YES YES NO Tower) Y-0008 North Alky Cooling Tower YES YES NO 1 FCC NP Cooling Tower NO YES NO Hydrogen Plants Cooling Tower NO YES NO CT TT-0006 Unit 07 Amine Cooling Tower NO NO NO Table 103.G, Summary Applicability Wastewater Emission Point MACT CC Equipment ID ID Wastewater NESHAP FF SPS CAM. MAIN APT YES YES YES NO BAP-0896 96 YES YES NO NO DAF-0806 YES YES NO NO T-0801 YES YES NO NO T-0805 YES YES NO NO T-0829 YES YES NO NO T-0836 YES YES NO NO T-0897 YES YES NO NO Table 103.H, Summary Applicability MACT 20.2.37 Unit SPS NSPS a NMAC CAM FCCREGEN YES NO YES YES YES - Satis?ed by MACT CCR YES NO ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 13 of 144 EPA Inspection Report - Page 409 of 1969 Version 02.25.15 Table 103.1, Summary Applicability SRU Source Emission SPS SPS MACT ID Point ID Description Ja 20.2.37.200B 20.2.37.202.A 20.2.39 CAM H-0473 SRUI and SRU2 Tail YES NO YES YES YES YES NO YES-Satis?ed Gas Incinerator by MACT SRUZ Hw0473 and SRU2 Tail YES NO YES YES YES YES NO YES-Satis?ed Gas Incinerator by MACT SRU3 SRU3-TGI SRU3 Tail Gas YES-Satis?ed Incinerator by MACT Table 103.J, Summary Applicability Engines 20.2.61.109 20.2.61.114 Source ID Description SPS 1111 MACT NMAC NMAC CAM E-0600W Fire Water Pump Engine YES YES YES YES NO E-OGOIM Fire Water Pump Engine YES YES YES YES NO Fire Water Pump Engine YES YES YES YES NO Fire Water Pump Engine YES YES YES YES NO E-0901 Fire Water Pump Engine YES YES YES YES NO 00 UPS backup generator NO YES YES YES NO 01 UPS backup generator NO YES YES YES NO V-0543 Portable Air Compressor YES YES YES YES NO Portable Air Compressor YES YES YES YES NO V-0546 Portable Air Compressor YES YES YES YES NO WWTP Emergency Engine YES YES YES YES NO ACC Form Part 1. Permit Page 14 of 144 Ver? 4. 1. 02/25/2015 EPA Inspection Report - Page 410 of 1969 Version 02.25.15 Table 103.K, Summary Ap licability FLARES NESHAP 20.2.36.112 20.236113!) 20.2.37.201B Unit ID Description NSPS A . NSPS NSPS .13 A MACT A NMAC NMAC NMAC Fla?400 North Plant Flare YES NO YES NO YES YES YES YES South Plant Flare YES NO YES NO YES YES YES, YES FL-402 FCCU Flare YES NO YES NO YES YES YES YES FL-403 Alky Flare YES NO YES NO YES YES YES YES FL-404 GOHT Flare YES NO YES NO YES YES YES YES All ?ares are steam assisted. State of New Mexico requires that an exit gas velocity of 65 ft/sec for modeling. The heating value of the gas for all ?ares is 1000 BTU/scf. This permit condition provides a list of the El Continuous Yes El Yes . . applicable requirements that are addressed in detail A103 Faculty: Applicable Regulations in other permit conditions but does not impose any El Intermittent No No . speci?c standards, monitoring, recordkeeping, or Compliance Wlth' the terms and reporting requirements. Therefore, no further conditions permlt regarding source response is required. As instructed by the AQB, emissions and Operation demonstrate Navajo is completing the check box responses in compliance with national ambient air columns 3, 4, and 5 of this form. Navajo continues quality standards speci?ed at 40 CFR, 50, to comply with ali applicable requirements except which were applicable at the time air for speci?c deviations as noted elsewhere in this dispersion modeling was perfonned for the document. (See the speci?c responsesto the permit facilitv?s NSR Permit 0195uM35. conditions that contain standards, monitoring, recordkeeping, or reporting requirements for more information). This permit condition provides a list but does not El Continuous Yes Yes A104 Facility: Regulated Sources impose any standards, monitoring, recordkeeping, or reporting requirements. Therefore, no further El Intermittent No No A. Table 104 A lists the emission units response is required. As instructed by the AQB, authorized for this facility. Emission units Navajo is completing the?heck box TesPonseS?n identi?ed as insigni?cant 0r trivial columns 3, 4, and 5 of this form. Navajo continues activities (as de?ned in 2.0.2.707 NMAC) tfo comply all-applicable requirements except . or spec1?c dev1ations as noted elsewhere in this and/or equipment nOt regulated pursuant to document. (See the speci?c responses to the permit the Ad are ?Qt Included. conditions that contain standards, monitoring, recordkeeping, or reporting requirements for more ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 15 of 144 EPA Inspection Report - Page 411 of 1969 Version 02.25.15 I information). ACC Form Part 1 Permit P051-R2 Page 16 of144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 412 of 1969 Version 02.25.15 Table 104A: Regulated Sources List Unit No. Unit Type Manufacturer Model No. Mangiagure Capacity B-0007 Boiler 7 Todd/John Zink burners Unknown 10/8/2001 215 MMBtu/hr (LHV Basis) Boiler 8 Todd/John Zink burners Unknown 2003 215 MMBtu/hr (LHV Basis) 13-0009 Boiler 9 Babcock Wilcox TBD TBD 220 MMBtu/hr (LHV Basis) WWTP Diesel Pump Engine John Deere R66090L101484 2/2011 400 hp E-GBOOW Fire Water Pump Engine Clarke Diesel (John Deere) 7/201 2 376 hp E-0601 Fire Water Pump Engine Clarke Diesel (301m Deere) 7/2012 376 hp Fire Water Pump Engine Clarke Diesel (John Deere) 7/2012 376 hp E-O 60 3 Fire Water Pump Engine Ciai?ke Diesel (John Deere) 2012 305 hp Fire Water Pump Engine Clarke Diesel (.lohn Deere) 18 10/2007 430 hp (3-0100 UPS backup generator Dem Iiile?g?ilimo Eng? Pam 1998 52 hp (3-0101 UPS backup generator Deutz F4L 1011 EI97-68CA00-000-0053 1999 54 hp V-0543 Ponable Air Compressor Cummings, .Ine. QSC, 7310461 1 8/30/2010 260 hp Poztable Air Compressor Cummings, lne. QSC, 73142120 4/8/2011 260 hp Postable Air Compressor Cummings, Inc. QSC, 469173 64 1 1/19/2008 240 hp H-0009 Unit 13 Naphtha Splitter Reboiler Zeeco burners GSFW-12 burners Unknown 44 MMBtu/hr (LHV Basis) H-0011 Unit 21 Vacuum Flasher Heater Unknown Unknown Unknown 38 MMBtu/hr (LHV Basis) H-0018 Naphtha HDS Reboiler Zeeco burners GSFW-8 burners Unknown 32 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-0019 South Crude Charge Heater burners CUBL-8W burners New burners in 2005 54 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-0020 South Crude Charge Heater burners CUBL-12W burners New burners in 2005 78 MMBtu/hr (LHV Basis) 3?1?0028 Unit 21 Heater H-28 (previousty H-10) John Zink burners burners Unknown 12.3 MMBtu/hr (LHV Basis) Unit 06 Charge Heater John Zink burners burners 2000* 42 MMBtu/hr (LHV Basis) H-0040 Unit 13 Charge Heater John Zink burners PSFG-16 burners 1990* 42 MMBtu/hr (LHV Basis) H-0303 Unit 05 Charge Heater John Zink burners HEVD-Q-18 burners 1982* 11 MMBtu/hr (LHV Basis) Unit 10 FCC Feed Heater John Zink burners burners 1990* 35 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-0352 Unit 70 CCR Heater (previously burners CUBL-10W burners New burners in 2006 63 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-0353 Unit 70 CCR Heater (previously burners burners New burners in 2006 81 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-0354 Unit 70 CCR Heater (previously 70-H3) burners CU BL-1 0W burners New burners in 2006 56 MMBtu/hr (LHV Basis) Unit 70 Stabilizer Reboiler Heater H-355 H-0355 (previously 70H-4) John Zink burners Unknown 1991 24 MMBtu/hr (LHV Basis) Callidus Technologies, LLC Unit 70 CCR Heater burners burners New burners in 2006 40 MMBtu/hr (LHV Basis) Caliidus Technoiogies, LLC H-0363 Unit 70 CCR Heater burners CUBL-8W burners New burners in 2006 50 MMBtu/hr (LHV Basis) ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 17 of 144 EPA Inspection Report - Page 413 of 1969 Version 0225.15 Callidus Technologies, LLC H-0364 Unit 70 CCR Heater burners CUBL-6W burners New burners in 2006 35 MMBtu/hr (LHV Basis) H-0421 Unit 44 Charge Heater (previously H-21) John Zink burners LNC-PC-18 burners 1981* 27 MMBtu/hr (LHV Basis) Caliidus Technofogies, LLC H-0464 SRU Hot Oil Heater burners LE-CSG-4W burners 2003* 9.6 Basis) Depropanizer Reboiler Heater (previously Caliidus Technoiogies, LLC 1991*, New burners in H-0600 burners CUBL-12W burners 2009 84 MMBtu/hr (LHV Basis) Callidus Technoiogies, LLC H-0601 Unit 33 Charge Heater burners burners New burners in 2003 78 MMBtu/hr (LHV Basis) GLSF-14 Round Flame H-2421 Unit 45 Charge Heater Zeeco, Inc. burners "Free Jet" burners 2006* 27 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-8801 Unit 63 Hydrogen Plant Reformer Furnace burners burners 2006* 60 MMBtu/hr (LHV Basis) Callidus Technologies, LLC LE-CSG-12W-PSA H-8802 Unit 63 Hydrogen Plant Reformer Furnace burners burners 2006* 60 MMBtu/hr (LHV Basis) H-2501 ROSE2 Hot Oil Heater John Zink Company, LLC burners COOLstar?18 burners 2009* 120 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-3403 Hydrocracker Reactor Charge Heater burners CUBL-10W burners TBD 32.0 MMBtu/hr Basis) Callidus Technologies, LLC Hw3402 Hydrocracker Fractionator Reboiler 1 burners burners 2009* 52 MMBtu/hr (LHV Basis) Callidus Technologies, LLC H-9851 Unit 64 Hydrogen Plant Reformer burners CUBL-3WDF burners 2009* 337' MMBtu/hr (LHV Basis) Caltidus Technologies, LLC H-3101 SRU3 Hot Oil Heater burner Unknown 05/11/2009 9.6 MMBtu/hr (LHV Basis) SRU1 and SRU2 Tail Gas incinerator Unknown Unknown Unknown NA Callidus Technologies, LLC SRU3 Tail Gas Incinerator burners Unknown 05/11/2009 NA FCC Regenerator FCC Regenerator Scrubber Unknown Unknown Unknown NA CCR Reformer Unknown Unknown Unknown NA North Ptant Flare North Plant Flare Unknown Unknown Unknown NA FL-0401, South Plant Flare South Plant Flare Unknown Unknown Unknown NA FL-0402, FCC Flare FCC Flare Unknown Unknown Unknown NA Alky Flare Alky Flare Unknown Unknown Unknown NA GOHT Flare GOHT Flare Unknown Unknown Unknown NA Y-0001 TCC Cooling Tower Unknown Unknown Unknown 5,000 gpm, 0.003% drift S. Aiky Cooling Tower (Marley Cooling Tower) Unknown Unknown Unknown 5,000 gpm, 0.003% drift Y-0008 North Alky Cooling Tower Unknown Unknown Unknown 12,500 gpm, 0.003% drift FCC NP Cooling Tower Unknown Unknown Unknown 30,000 gpm, 0.001% drift Y-0012 Hydrogen Plants Cooiing Tower Unknown Unknown Unknown 10,000 gpm. 0.001% drift CT Unit 07' Amine W-0745 Cooling Tower Unknown Unknown Unknown 3,000 gpm, 0.003% drift MAIN API Above Ground API Cit-Water Separator Unknown Unknown Unknown 1,200 T-0896 DAF Unit T-0896 Unknown Unknown Unknown 1,200 T-080?l Enhanced Biodegradation Tank T-0801 Unknown Unknown Unknown 1,200 Enhanced Biodegradation Tank Unknown Unknown Unknown 1,200 T-0829 Equalization Tank T-0829 Not yet instatled Not yet instalied Not yet installed 1,200 DAF Unit T-0806 Not yet instailed Not yet installed Not yet installed Not yet installed Equipment component leaks (pump seals, Fugitives (see Tabie 103.B) vatves, flanges, etc.) NA NA Varies NA Loading (see Table 103D) Bulk Loading/Unloading Racks NA NA Varies Varies Fixed Roof, External Floating Roof Tanks (see Table 103.0) Internal Floating Roof Tanks NA NA Varies Varies Instatlation date ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 18 of 144 EPA Inspection Report - Page 414 of 1969 Version 02.25.15 Note: Serial numbers are not used since most equipment consists of ?eld erected parts that are assembled on site and may have several ?serial numbers? for various components. Heaters are the best example because each of the burners has a serial number but the heater as a whole does not have a single serial number. The heater as a whole is typically identi?ed by our equipment number. There may also be a ?project number? or ?job number? from the manufacturer, but that can change if a. heater is revamped at a later date such as when they modify the convection section to improve energy ef?ciency. A105 Facility: Control Methods A. Table 105A lists all the pollution control equipment required for this facility. Each emission point is identi?ed by the same number that was assigned to it in the permit application. This permit condition provides a list but does not impose any standards, monitoring, recordkeeping, or reporting requirements. Therefore, no further response is required. As instructed by the AQB, Navajo is completing the check box responses in. columns 3, 4, and 5 of this form. Navajo continues to comply with all applicable requirements except for speci?c deviations as noted elsewhere in this document. (See the speci?c responses to the permit conditions that contain standards, monitoring, recordkeeping, or reporting requirements for more information). Continuous Intermittent Yes No Yes XI No Table 105A: Control Methods: Control . . . BACT Pollutant being Control for Equipment Unit Control Description Unit Yes or 0 controlled 1 o. umber(s) Fluid Catalytic FCC Regenerator Cracking Unit FCC Scrubber Regenerator Cyclones NO PM 802 Regenerator Wet Gas Scrubber CCR CHLOR CCR Regenerator Vent NO Chloride Regenerator Control Vent Re?nery FL-0400 North Plant Flare NO VOC H28 . process unlts ACC Form Part 1. Permit Ver 4.1 02/25/2015 Page 19 of 144 EPA Inspection Report - Page 415 of 1969 Version 02.25.15 FL-0401 South Plant Flare NO voc HZS Re?nery . process units . Re?nery FCC Flare NO VOC H2S . process units Refinery FL-0403 Alky Flare NO VOC . process units Re?nery FL-0404 GOH Flare NO VOC H2S . process units Portable Flare for Holly Pipeline Ef?gy Pa?ntrs (HEP) NO voc Pigging Plpellne Plgging . Operat1ons Operations Sulfur Recovery Units No. 2 Tail Gas NO Sulfur SRUI and . SRU2 Inc1nerator Selective Catalytic SCR Reduction ultra-low YES NOX NOX burners Sulfur Recovery Unit No. 3 Tail Gas YES Sulfur SRU3 Incinerator Best Work Practices, A207.B (BACT) YES SRU3 Mal? API carbon NO voc MAIN API Canisters Drift Eliminators on 37?001 1, Y-0012 Cooling Towers YES PM 250?; 1 1? (BACT) ACC Form Part 1 Permit Ver4.l 02/25/2015 Page 20 of 144_ EPA Inspection Report - Page 416 of 1969 Version 02.25.15 External Floating Roofs T-0737, T-l225 (B A CT) YES VOC T-1225 External and Internal See Tables Wm Floating Roofs (None? NO voc and BACT) (2) Energy Ef?ciency, B-0009 A2 0 4N (B A CT) Yes Greenhouse Gases 13-0009 H6402, H- ultra-low NOX burners Yes NO H- 3101 (BACT) 3402, . SRU-TGI, H-2501, Combust gaseous fuels Yes C, PM 2501? 11?3402, only 3101 B. 1 Control for unit number refers to a unit number from the Regulated Equipment List In accordance with the requirement that Navajo Re?ning prevent exceedances of the 24?hour and 3-hour National Ambient Air Quality Standards (NAAQS) for 802 during major re?nery malfunctions, Navajo Re?ning shall only ?are acid gas from existing Flare according to Navajo Re?ning?s "Phase Two" plan dated January 5, 1996 and received by the Department on January 8, 1996, or from Flare 0400. Navajo shall. undertake the following measures for acid gas ?aring from and L-0403. A RT 0. 1 SUPP FUEL FOR 502 NAAQS COMPLIANCE, FL-400 90.0 80.0 :700 E60.0 50.0 0 Ed 400 In 8 30.0 7E 20.0 10Supp Fuel Gas Flow (1) Existing Flare FL-0400 shall be equipped with a ?are tip or burners to supply supplemental fuel gas to provide enough heat to supplement the ACC Form Part 1 Permit P05 l-R2 Page 21 of 144 Ver 4 .1 02/25/2015 EPA Inspection Report - Page 417 of 1969 Version 02.25.15 heat released by combustion of the acid gas itself and the heat provided by smoke-suppressing steam. The minimum ?ow rate of supplemental fuel gas to be supplied during acid gas ?aring such that compliance with the NAAQS for 802 is assured shall be determined using Chart No. 1. The fuel gas used for this purpose shall be natural gas (see de?nition at C101 .F). (2) Existing Flare FL-0403 shall be equipped with a ?are tip or burners to supply supplemental fuel gas to provide enough supplemental heat. The volume of supplemental fuel gas to be provided to generate enough supplemental heat to ensure compliance with NAAQS for 802 shall be determined using Chart No. 2. The supplemental heat to be provided when ?aring the maximum quantity of acid gas has been determined to be 52.9 million BTU per hour which is generated by burning 96,200 SCF of supplemental fuel gas. This assumption has been made to ensure compliance with the NAAQS for 802. The fuel gas used for this purpose shall be natural gas (see de?nition at C101 .F). CHART NO. 2 SUPP. FUEL FOR 802 NAAQS COMPLSANCE, FL-403 40 Supp. Fuel Gas um 001 U'l _s Acid Gas Flow (Thousand SCFH) 001 20 40 60 80 100 Supp. Fuef Gas (Thousand SCFH) C. Beginning December 20, 2001 no fuel oil shall be burned in combustion units except as follows: (CD ?ll7.C) (1) Torch Oil may be burned in the FCC Regenerator during FCC start-ups; and. (2) Fuel Oil may be burned in combustion units after the establishment of FCC emissions limits pursuant to permit condition A110.A, provided that emissions from any such combustion units are routed through the FCC Wet Gas Scrubber and Navajo demonstrates, with the approval of EPA, that the emissions limits contained therein and the emissions limits stated in A106.A and A107.A will continue to be met. D. The Artesia Re?nery FCC was initially limited to less than 20,000 BPD capacity. Following the December 2003 expansion of the Artesia re?nery?s FCC as authorized by permit the catalyst regenerator for the FCC is subject to the minimum requirements for continuous emission monitoring and recording set forth in Appendix to 40 CFR Part 51. Consent Decree Paragraph 15 required the FCC to be subject to NSPS Subpart for opacity as of December 31, 2003. A wet gas scrubber was installed in 2003. An Alternative Monitoring Plan (AMP) request was submitted to EPA on December 31, 2003 because a continuous opacity monitoring system (COMS) will not work on a wet gas scrubber exhaust because of the interference from the water vapor. The AMP satis?es the requirements for both NSPS Subpart and 40 CFR Part 51 Appendix ACC Form Part 1 Permit P051-R2 R2M1 Page 22 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 418 of 1969 Version 02.25.15 A106 Facility: Allowable Emissions Continuous Yes IE Yes A. The following Section lists the emission Nail/81? to comply all 39p 1,1 cable Intermittent emiss10n limits except for Spec1?c deV1ations as units, and their allowable emiss10n limits. (See Table 103.A for all applicable noted elsewhere in this document and events . reported per 20.2.7 NMAC. regulations) Table 106.A: Allowable Emissions so2 2Moi co voc Btu/hr Btu Source in 5 (lb/lir) (ton/yr) 5(lb/lir) (ton/yr) 5(lb/MM Btu) 5(lb/hr) (ton/yr) LHV) (lb/hr) (ton/yr) 5(lb/hr) (ton/yr) 13?0007 215 7.8 12.7 12.9 56.5 0.06 19.6 85.7 1.8 7.8 1.3 5.6 B-0008 215 7.8 12.7 12.9 56.5 0.06 19.6 85.7 1.8 7.8 1.3 5.6 B-0009 220 2.6 11.4 4.4 19.3 0.02 BACT 8.1 35.7 1.6 7.2 0.9 3.9 H-0009 44 1.6 2.6 4.0 17.3 0.09 4.0 17.5 0.4 1.6 0.3 1.2 H-0011 38 1.4 2.3 9.5 31.6 3.5 15.2 0.3 1.4 0.2 1.0 H-0018 32 1.2 1.9 3.5 15.2 2.9 12.8 0.3 1.2 0.2 0.8 H-0019 54 2.0 3.2 2.9 12.5 0.0527 4.9 21.5 0.4 2.0 0.3 1.4 78 2.8 4.6 4.2 18.3 0.0535 7.1 31.1 0.6 2.8 0.5 2.0 12.3 0.4 0.7 2.2 9.5 - 1.1 4.9 0.1 0.4 0.1 0.3 H-0030 42 1.5 2.5 3.2 14.0 3.8 16.8 0.4 1.5 0.3 1.1 42 1.5 2.5 3.8 16.6 3.8 16.8 0.4 1.5 0.3 1.1 63/81/56 0352/0353/0354 7.3 11.8 9.0 39.4 0.045 18.2 79.7 1.7 7.2 1.2 5.2 24 0.9 1.4 2.2 9.5 2.2 9.6 0.2 0.9 0.1 0.6 H-0303 11 0.4 0.7 1.2 5.2 1.0 4.4 0.1 0.4 0.1 0.3 Hw0312 35 1.3 2.1 4.6 20.2 3.2 14.0 0.3 1.3 0.2 0.9 0262/0363/0364 40/50/35 4.6 7.4 6.9 30.1 0.055 11.4 49.8 1.0 4.5 0.7 3.3 H-0421 27 1.0 1.6 2.4 10.6 0.09 2.5 10.8 0.2 1.0 0.2 0.7 H-0464 93.1 5.0 4.7 20.3 0.05 7.6 33.5 0.7 3.03 0.5 2.2 78 2.8 4.6 3.5 15.4 0.045 7.1 31.1 0.6 2.8 0.5 2.0 27 1.0 1.6 1.2 5.3 0.045 2.5 10.8 0.2 1.0 0.2 0.7 60/60 0.2 0.8 4.2 18.4 0.035 10.9 47.8 1.0 4.3 0.7 3.1 120 4.4 7.1 3.6 15.8 0.03 7.2 31.5 0.09 BACT 1.0 4.3 0.7 3.1 H-3402 52 1.9 3.1 1.6 6.8 0.03 4.7 20.7 0.09 BACT 0.4 1.9 0.3 1.4 ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 23 of 144 EPA Inspection Report - Page 419 of 1969 Version 02.25.15 11?3403 32.0 1.2 1.9 1.0 4.2 0.03 2.9 12.8 0.3 1.2 0.2 0.8 0.0125 H-9851 337 0.5 2.2 4.2 18.5 BACT 20.2 88.6 0.06 BACT 2.8 12.2 2.0 8.8 11?3101 9.6 0.4 0.6 0.3 . 1.3 0.03 0.9 3.8 0.09 BACT 0.1 0.4 0.1 0.3 11?0473 NA 30.0 81.8 6.5 28.5 27.7 121.2 0.5 2.2 0.1 0.6 TGI) NA 30.0 81.8 6.5 28.5 15.0 65.7 0.5 2.2 0.1 0.6 FCC Regenerator NA 27.9 61.0 35.0 101.9 121.9 106.8 25.0 109.5 North NA 0.2 0.5 0.2 0.8 1.0 4.3 0.0 0.0 0.2 0.7 Plant Flare south <01 0.2 Plant Flare FCC NA 0.1 0.1 <01 0.2 0.2 1.1 0.0 0.0 <01 0.2 Flare Alk Flare A <01 <01 <01 <01 <01 0.2 0.0 0.0 <01 <01 FL-0404 NA 2.4 10.5 4.1 18.1 13.6 59.6 0.0 0.0 2.3 10.2 Flare Subtotal 345.4 668.8 1156.2 196.0 70.2 Tanks, Table 106.13 32? Fugitives, Table 106.F 994.6 Misc Sources, Table 1.06.G 16?6 Cooling Towers, Table 106.11 2.5 9.0 56.2 Oil/Water Separators, Table 5.3 9.5 106.1 6SSM, Table 107 27.4 31.6 97.6 0.4 46.2 TOTAL 1 NA 372.8 700.4 1256.3 205.3 1515.7 1 Totals are for information and are not enforceable conditions. 2 Nitrogen dioxide emissions include all oxides of nitrogen expressed as N02 3 of heat input, calculated as a 3-hour average, when ?ring natural gas at 3% stack oxygen at full design load without air preheat. 4 All Particulate Matter emitted is assumed to be of aerodynamic diameter 10 microns or less. 5 Hourly emission limits and lb/MM Btu limits are based on a hourly rolling 3-hour average. 6 Maximum allowable emissions during maintenance, sta1tup, or shutdown (SSM) and malfunction activities. indicates that in accordance with the application, emissions of this pollutant are not expected. indicates that the emissions are less than. 1.0 or 1.0 tpy and emission limits are not required for this permit, unless it?s for a control device. Unit 9851, the SCR exhaust has Ammonia Slip limit of 7 on a wet basis and 6.1 tpy (BACT). ACC Form Part 1 Permit P051-R2 R2M1 Page 24 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 420 of 1969 Version 02.25.15 ACC Form Part 1. Permit Page 25 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 421 of 1969 Version 02.25.15 A106 Facility: Allowable Emissions B. The permitted emission sources at the re?nery shall consist only of the sources listed in Table 106A and Tables 106B through of this permit. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous El Intermittent Yes No El Yes No INTERNAL FLOATING ROOF STORAGE TANKS TABLE VAPOR PRESSURE LIMITATIONS FOR REFINERY NON- COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOC) Typical Liquid Most Volatile Category (1215133 ank No. Stored of Allowable L1qu1ds to 0 05M 0 .lqu a be Stored 33? T..0056 Naphthas High Vapor Pressure2 1 1.0 Distillates High Vapor Pressure2 1 1.0 T0107 Gasolines High Vapor Pressure2 1 1.0 T-0108 Gasolines High Vapor Pressure2 1 .0 "110109 (3330111195 High Vapor Pressure2 1 1.0 T..01 1 1 Naphthas High Vapor Pressure2 1 1.0 12 Naphthas High Vapor Pressure2 1 1.0 "12001 1 Gasolines High Vapor Pressure2 1 1.0 120124 Gasolines High Vapor Pressure2 1 1.0 T-0012 Gasolines High Vapor Pressure2 1 1.0 "13-0413 Distillates High Vapor Pressure2 1 1.0 T-0415 Gasolines High Vapor Pressure2 1 1.0 Gasolines High Vapor Pressure2 1 1.0 Crude Oil High Vapor Pressure2 1. 1.0 less under actual storage conditions. Liquids in lower volatility categories may also be stored tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allowed to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub?grade, regular, premium, and other blends), Alkylate, Reformate, FCC Gasoline, Ethanol, Isomerate, Straight Run Gasoline, and other re?nery feedstocks, intermediates, products byproducts, and wastes having a max vapor pressure of psia or ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 26 of 144 EPA Inspection Report - Page 422 of 1969 Version 02.25.15 EXTERNAL FLOATING ROOF STORAGE TANKS TABLE VAPOR PRESSURE LIMITATIONS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOC) - Tank No. Typical Liquid Most Volatile Category of Max Vapor Pressure Stored Allowable Liquids to be Stored1 (psia) of Most Volatile Liquid at Max Temp. 7 Naphthas High Vapor Pressure2 11.0 T-0078 lsomerates High Vapor Pressure2 11.0 Isomerates High Vapor Pressure2 11.0 r-0117 7 Gasolines High Vapor Pressurez 1 1.0 T0401 Gasolines High Vapor Pressure2 11.0 Gasolines High Vapor Pressure2 11.0 T-041 1 Gasolines High Vapor Pressure2 1 1.0 Gasolines High Vapor Pressure2 11.0 T-0435 Crude Oil High Vapor Pressure2 1 1.0 Crude Oil High Vapor Pressure2 1 1.0 T-0450 Naphthas High Vapor Pressure2 1.1.0 Sour Water High Vapor Pressure2 1 1.0 Slop High Vapor Pressure2 11.0 130834 Distillates Moderate Vapor Pressure3 1.5 Distillates High Vapor Pressure2 11.0 Naphthas High Vapor Pressure2 11.0 T0737 Sour Water High Vapor Pressure2 1 1.0 Ethanol High Vapor Pressure2 2.32 Liquids in lower volatility categories may also be stored tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks a11owed to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub?grade, regular, premium, and other blends), Alkylate, Refonnate, FCC Gasoline, Ethanol, lsomerate. Straight Run Gasoline, and other re?nery feedstocks, intermediates products. byproducts, and wastes having a max vapor pressure of 1 1 psia or less under actual storage conditions. 3 Moderate Vapor Pressure Liquids include: Desulfurized Naphtha (Splitter Bottoms), Light Slop, and other re?nery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 1.5 psia or less under actual storage conditions. ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 27 of 144 EPA Inspection Report - Page 423 of 1969 Version 02.25.15 FIXED ROOF STORAGE TANKS TABLE 106.C VAPOR PRESSURE LIMITATIONS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOCS) Tank No. Typical Liquid Most Volatile Category of Max Vapor Pressure (psia) of Stored Allowable Liquids to be Most Volatile Liquid at Max Stored1 Temp. T-0013 Slop Moderate Vapor Pressure3 1.5 T-004O Distillates Low Vapor Pressure4 0.5 Distillates Low Vapor Pressure4 0.5 T-0110 Asphalt/Pitch Low Vapor Pressure4 0.5 T-0400 Gas Oils Low Vapor Pressure4 0.5 Carbon Black Oil Low Vapor Pressure4 0.5 (CBO) CBO Low Vapor Pressure4 0.5 T-0409 Gas Oils Low Vapor Pressure4 0.5 0 Asphalt/Pitch 'Low Vapor Pressure4 0.5 T0418 Distillates Low Vapor Pressure4 0.5 T-0419 Distillates Low Vapor Pressure4 0.5 T-0420 CBO Low Vapor Pressure4 0.5 T-0422 Distillates Low Vapor Pressure4 0.5 T-0423 Distillates Low Vapor Pressure4 0.5 T0431 Distillates Low Vapor Pressure? 0.5 T0432 Distillates Low Vapor Pressure4 0.5 Slop Moderate Vapor Pressure3 1.5 T-0055 Distillates Low Vapor Pressure4 0.5 T-0058 Distillates Low Vapor Pressure4 0.5 CBO Low Vapor Pressure4 0.5 T-0061 Distillates Low Vapor Pressure4 0.5 T-0063 CBO Low Vapor Pressure4 0.5 ACC Form Part 1 Permit R2M1 Ver 02/25/2015 Page 28 of 144 EPA Inspection Report - Page 424 of 1969 Version 02.25.15 T-0065 CBO Low Vapor Pressure4 0.5 120075 CBO Low Vapor Pressure4 0.5 T-0433 Gas Oils Low Vapor Pressure4 0.5 T-0434 Distillates Low Vapor Pressure4 0.5 T-0438 Gas Oils Low Vapor Pressure4 0.5 T-0810 Slop Moderate Vapor Pressure3 1.5 T-0814 Asphalt/Pitch Low Vapor Pressure4 0.5 T-0815 Distillates Low Vapor Pressure4 0.5 Distillates Low Vapor Pressure4 0.5 Asphalt/Pitch Low Vapor Pressure4 0.5 T-0081 Asphalt/Pitch Low Vapor Pressure4 0.5 Asphalt/Pitch Low Vapor Pressure4 0.5 Recovery Well High Vapor Pressure2 11.0 Hydrocarbons Recovery Well High Vapor Pressure2 1 1.0 Hydrocarbons RWM6 Recovery Well High Vapor Pressure2 11.0 Hydrocarbons Biodiesel Low Vapor Pressure4 0.022 NEWBIODIES EL TABLE 106.D STORAGE TANK THROUGHPUT AND TEMPERATURE LIMITS Material Throughput (bbl/yr) Maximum Storage Temperature (T) Asphalt/Pitch 30,872,000 5 10 Carbon Black Oil (CBO) 1,291,610 250 Crude Oil 76,212,000 Ambient Liquids in lower volatility categories may also be stored tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allowed to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub?grade, regular, premium, and other blends), Alkylate, Reformate, FCC Gasoline, Ethanol, Isomerate, Straight Run Gasoline, and other re?nery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of psia or less under actual storage conditions. Moderate Vapor Pressure Liquids include: Desulfurized Naphtha (Splitter Bottoms), Light Slop, and other re?nery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 1.5 psia. or less under actual storage conditions. Low Vapor Pressure Liquids include: Diesel (raw or ?nished), Kerosene (raw or ?nished), CB O, LCO, Slurry, Heavy Slop, Cutback Asphalt, Cutter, VGO, AGO, and other re?nery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure less than 0.5 psia under actual storage conditions. ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 29 of 144 EPA Inspection Report - Page 425 of 1969 Version 02.25.15 Distillate 55,076,590 310 Gas Oil 25,059,500 310 Gasoline (includes isomerates) 57,910,908 Ambient Naphtha 39,028,084 Ambient Slop 1,330,000 Ambient Sour Water 45 ,051 Ambient BioDiesel 949,000 Ambient Methanol 142,350 Ambient TABLE STORAGE TANK VOC AND HZS EMISSION LIMITSI (return to A203) Tank Type VOC Emission Rate (tpy) H28 Emission Rate (tpy) Fixed?Roof 238.6 0.0 Floating?Roof 83 .8 .47 Total Tanks 322.4 1.47 Table 106.F, 1EMISSIONS LIMITS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOC) FUGITIVE EMISSIONS FROM EQUIPMENT LEAKS Maximum Hourly Average Annual Process Unit ID Number Description VOC Emission Rate VOC Emission (lb/hr) Rate (tons/yr) CRUDE South Division Crude Unit 10.2 44.6 FCC 10.8 47.2 FUG-ZU-ISOM Powerformer/Penex Unit 5.9 25.7 VACUUM Flasher/Vacuum Unit 3.2 13.9 Kerosene HDS Unit 5.2 22.7 JP8 Hydrodesulfurization 7.1 30.9 MEROX TRT Merox/Merichem Treating Units 3.5 1.5.3 GAS Saturates Gas Plant 18.3 80.0 FARM Light Oi! Tankage 6.8 29.6 FUGWASPHALT Asphalt/Heavy Oil Storage 3.5 i5 .3 GAS Fuel Gas Distribution System 4.2 18.2 The pennittee shall demonstrate compliance with the above throughputs and emission limits through the annual emissions inventory process. Speci?c tank data (eg. temperature throughputs) shall be monitored and recorded weekly by the permittee. ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 30 of 144 EPA Inspection Report - Page 426 of 1969 Version 02.25.15 LPG Storage System 216 94.4 PBC Unit 3.4 14.7 CCR Reformer (w/in batte1y limits) 23.4 102.3 Naphtha HDS Unit 10.2 44.6 ALKY South Aiky Unit 1.7 7.5 ALKY North Alkylation Unit (New-Inside battery limits) 12.0 52.5 Gas Oil Hydrotreater (incl. CVS) 9.3 40.6 Gas Oil Hydrotreater (incl. CVS) 2.6 1 1.2 FUG-O7-N AMINE Amine Unit~Treating/Regen. 6.3 27.5 2.4 10.4 Sour Water Stripper 1.6 7.0 CVS Oil/Water Separator 1.3 5.5 HDU Relocated Diesel HDS Unit 12.9 56.4 RK Loadng Racks 2.8 12.1 FUG-RLO-ASPHALT Asphal??itch Loading Rack 0.7 2.9 UTIL Utilities 16.7 73.3 PUG-63112 Hydrogen Plant 26 11.2 PUG-3 SRU3 Unit 0.7 3.1 WX Hydrocracker 6.2 27.2 ROSE Unit 8.0 35.1 PUG-64412 Hydrogen Plant 2.6 1 1.2 FUGRRTOTRUCK Crude oil unloading system, closed loop system 0.1 0.5 between railcars and trucks Subtotal Facility VOC CAP 227.8 994.6 Minor changes within the facility to piping and components that affect fugitive VOC emission source shall be updated and added during the next available Signi?cant permit revision in accordance with 202.72 NMAC. The facility wide fugitive VOC emission limit shown above and in Table 106A of this permit. MISCELLANEOUS SOURCES Table 106.G EMISSION LIMITS FOR REF INERY NON-COMBUSTION SOURCES Of VOLATILE ORGANIC COMPOUNDS (V OCS) Loadin Loadin Rack . Hourl Annual . . Rack Descrigption Materlal Loaded Throughiput Throughput VOC Em1ss1ons bbl/hr bbi/yr lb/hr ton/yr Gasoline 1214 1,600,696 4.25 2.80 TM. Fuels Truck Loading Diesel 107100 3.650000 1.72 1.72 Rack Jet Fuel 35700 1 021,718 0.75 0.34 TOTAL voc 6.73 4.86 Truck Carbon Black Oil 6.30 1.57 ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 31 of 144 EPA Inspection Report - Page 427 of 1969 Version 02.25.15 Note:1. Calculation method and factors per AP-42, Section 5.2, dated June 2008. a Controlled emission rate. The previous controlled rate was set by the terms of the consent agreement between Navajo Re?ning Co. and the Department executed January 28, 1994. The agreement required that the incinerator have a minimum 90% destruction ef?ciency for gasoline loading and a minimum 80% destruction ef?ciency for diesel fuel loading or let A ?iel loading. This was achieved by a vapor combustor. This device has since been replaced with a carbon adsorption system compliant with MACT Subpart R, as subject per MACT Subpart CC. Emission limits changed in 195?M-l7 to correspond to Title permit values. Loading Rack Light Cycle 011 38100 20.1 19 I 3.55 0.06 TOTAL voc 6.30 1.63 Carbon Black 011 30000 365.000 6.30 1.15 . . Diesel 20000 1.144000 0.32 0.54 RLO-8 083?8861833883; Jet Fuel 20000 1,144,000 0.42 0.38 Asphalt 30000 2,628,000 0.01 0.03 TOTAL voc 6.30 2.09 FUG- Odor Controllin ODOR Atomizer . 0'46 2'0 COOLING TOWERS Table 106.H EMISSION LIMITS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUMDS and PM Source (lb/hr) CO lb/hr tons/yr (lb/hr) (tons/yr) (tons/yr) 1.8 7.9 0.3 1.2 1.8 7.9 0.3 1.2 Y-0008'3l 6.5 28.3 0.7 2.9 0.58 2.54 1.3 5.5 0.5 2.3 Y-0012 0.4 1.8 0.2 0.8 CT 1.1 4.7 0.2 0.7 Subtotal (for informational 5 2_1 9.1 purposes only) API SEPARATORS Table 106.1 EMISSION LIMITS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOCS) Maximum Average Hourly VOC Annual VOC Equipment Emission Point Emission Emission ID ID Description Rate (Ib/hr) Rate (tons/yr) MAIN API Dw0829/0830 Above Ground API Oil?Water Separators <0.1 <0.1 a Y-0008 cooling tower provides 100% control of any NH3 emissions from and V-H2-2. Unit 64, Hydrogen Plant has de?aerator line that has dissolved CO that is connected to the cooling tower. ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 32 of 144 EPA Inspection Report - Page 428 of 1969 Version 02.25.15 and enclosed drain system. T-0896 DAF-0896 DAF Unit <01 <01 Enhanced Biodegradation Tank <0.1 <0.1 Tw0836 Enhanced Biodegradation Tank 0.1 0.5 T-0829 Equalization Tank T-0829 5.1 8.9 DAF Unit Subtotal (for inform ationai purposes only) 5.3 9.4 A106 Facility: Allowable Emissions El Continuous Yes El Yes C. Compliance with Allowable Emission Intermittent El N0 El N0 Limits Requirement: The allowable mthu/hr, lb/mthu, lb/hr, and tpy emission limits for equipment listed in Table 106A construction of which predates the NaVajo to comply With all applicable effective date of 20.272 NM AC (August emission limits except for speci?c deviations as 31? 1972), and have not been modi?ed noted elsewhere in this document and events since August 31, 1972, shall be the reported per 20'2'7 "potential emission rate" of that unit as de?ned in 202.72.107 NMAC and the potential to emit of that unit de?ned under 20.2.74 NMAC. The inttu/hr, lb/hr and lb/mthu limits are based on an hourly rolling 3-hour average. (NSR 0195M3 5, Condition A106.C and revised) Navajo continues to comply with all applicable El Continuous El Yes Yes Permittee shall monitor the lb/mthu to em1ss1on limits ercep't for speCI?c dev1ations as Intermittent g] No No noted elsewhere in document and events demonstrate compllance With the reported er 20.2.7 NM AC. mthu/hr, lb/hr, and tpy emission limits. Nava'o continues to com 1 with all a licable . Recordkeeping: TO demonstrate emissJion limits except fol: Speci?c devpiitions as Continuous Yes El Yes compliance, records Shall be kept showing noted elsewhere in this document and events El Intermittent No the correlation between lb/mthu and the reported per 2027 NM AC. ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 33 of 144 EPA Inspection Report - Page 429 of 1969 Version 02.25.15 mthu/hr and lb/hr, and the rolling 12-month tpy totals. The records shall also document any non? compliance with emission limits. For each unit, a summary of the method used to determine compliance shall be recorded. The permittee shall. maintain records in accordance with Section 3109. Reporting: The permittee shall report in accordance with Section B1 10. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. El Continuous El Intermittent El Yes No Yes No A106 Facility: Allowable Emissions D. BACT SOZ Limit Fuel sulfur limit Re?nery-Wide for all units burning re?nery fuel gas (excluding units H-8801, and which burn only natural gas) shall not exceed 60 H28 on a daily rolling 365?day average. The ton/yr emission rates for $02 in Table 106A of this permit are based on this daily rollingr 365~day average 60 H28 limit. Compliance with this limit shall be demonstrated per the methods described in Condition A110.A. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous Intermittent Yes No Yes I: No A106 Facility: Allowable Emissions E. BACT Limit - In addition to the emission limits shown in Table 106A, Boiler Unit B-0009 has a BACT limit of0.021b/MM Btu, and C02 limit of 1 12.1 Btu. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous Intermittent Yes No Yes No ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 . Page 34 of. 144 EPA Inspection Report - Page 430 of 1969 Version 02.25.15 A106 Facility: Allowable Emissions F. BACT S02 Limit The Sulfur Recovery Unit No. 3 Tail Gas Incinerator (SRU3-TGI) is limited to 192 S02 at zero percent oxygen on a hourly rolling 12-hour average basis. In addition, SRU3- TGI is limited to 192 S02 at zero percent oxygen on a daily rolling 365?day average basis. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous Intermittent Yes No Yes El No A106 Facility: Allowable Emissions G. BACT VOC Limit The naphtha storage tank and sour water storage tank T-0737 shall be equipped with an external ?oating roof using double seals to reduce VOC emissions to the atmosphere. The maximum true vapor pressure of any volatile organic liquid stored in either tank shall not exceed 1 1.0 psia. Demonstration of compliance is through the NSPS Kb and MACT emission limits. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous Intermittent .Yes El Yes No A106 Facility: Allowable Emissions H. VOC All fugitive piping components in. VOC service associated with the process units proposed in Permit (Units l- and PUG-34- Hydorcracker) shall be monitored under the MACT subpart CC leak detection and repair program, or an approved equivalent program, to reduce VOC emissions. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted. elsewhere in this document and events reported per 20.2.7 NMAC. Continuous Intermittent Yes El No El Yes No ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 35 of 144 EPA Inspection Report - Page 431 of 1969 Version 02.25.15 A106 Facility: Allowable Emissions Continuous Yes Yes Navajo continues to comply with all applicable I. VOC Consistent with MACT Subpart emission limits except for speci?c deviations as El Intermittent N0 No CC, the gasoline truck loading rack noted elsewhere in this document and events 4) shall be limited to 10 mg of VOC 20?2-7 NMAC- emissions per liter of gasoline loaded. A106 Facility: Allowable Emissions Continuous g] Yes i:i Yes J- PM10 (3001ng Units Y-001 1 Navajo continues to comply with all applicable Inter mittent N0 N0 and Y-0012, shall be equipped with high? emission limits except for Speci?c deviations as ef?ciency drift eliminators to reduce PM10 noted elsewhere in this document and events emissions. Demonstration of compliance is reportEd per 20-2-7 NMAC- through annual inspection in accordance with in Condition A212.B. A107 Facility: Allowable Startup, DContinuous DYes EYes Shutdown, Maintenance (SSM) and Malfunction Emissions Intermittent N0 Ci No A. The maximum allowable SSM and Navajo continues to comply with all applicable . . . . . . limits except for Spec1?c dev1at10ns as Malfunction em1s31ons 11mits for this . . 1, bl 107 noted elsewhere in this document and events aci ity are iste in Ta 6 .A an were reported per 2027 NMAC. relied upon by the Department to determine compliance with applicable regulations. Table 107.A: Allowable SSM and Malfunction Units, Activities, and Emission Limits1 NOX CO VOC 5 502 H25 Unit Description of Emissions tpy tpy tpy tpy tpy tpy SSM H-9851 Emissions during SCR downtime1 10.1 1.2 20.2 2.4 2.0 0.2 2.8 0.3 0.5 0.1 SSM Emissions from roof landing -- -- -- 33.0 0.5 -- SSM Misc 1 Emissions from catalyst handling -- -- -- -- 1.5 <0.1 -- ACC Form Part 1 Permit Page 36 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 432 of 1969 Version 02.25.15 Emissions from SRU3 stamp and 6.5 <0.1 15.0 0.1 0.1 <0.1 .. 159.0 0.4 6.5 <0.1 SSM SRU3-TGI shutdown Emissions from roof Eanding and SSM T-0078 tank re?lling -- 177.0 2.7 -- -- -- Emissions from roof landing and SSM tank re?lling -- -- -- 306.0 4.6 -- SSM T-1225 Emissions from roof landing 187.0 2.8 SSM Temporary, portable ?are for natural PORT gas pipeiine maintenance 173.4 0.1 943.5 0.5 160.7 0.1 -- -- 1.7 <0.1 0.02 <0.1 SSM Emissions from SRU2 startup and (H-0473) shutdown 6.5 0.1 27.7 0.2 0.2 0.1 -- 159.0 0.4 6.6 0.1 Emissions from venting SSM activity gases to FL-400, 1133. SSM Flare Cap or 162.9 18.3 1243.0 77.0 211.6 13.2 -- -- 4 14.9 0.4 0.1 Flares Malf Cap Upset and Malfunction Emissions 10.0 -- 10.0 10.0 -- 10.0 Low?Emitting Maintenance Activities such as de-inventorying small equipment, clearing piping associated with emission units, and routine maintenance activities such as heat SSM Misc 2 exchanger repair. 17.0 1.9 127.1 7.8 21.2 1.4 -- 129.3 1.6 0.7 0.1-- SSM Tanks Misc Storage Tanks -- 112.0 10.6 -- -- -- 0.1 0.1 Subtotal 31.6 98.0 46.2 0.4 27.4 0.4 During startup, shutdown, schedule maintenance or malfunction of the SCR control system, BACT for H-985l shall be ultra?low burners emitting no more than 03 lb per (LHV) on a hourly rolling 3?hour average basis at 3% excess oxygen. Pound per hour and tons per year limits are based on. the lb/MMBtu limits and were used to demonstrate compliance with the lb/MMBtu limits and the Ambient Air Quality Standards (AAQS). A107 Facility: Allowable Startup, Shutdown, Maintenance (SSM) and Malfunction Emissions Yes IZI N0 IZI Yes No Continuous Intermittent Navajo complies with the conditions of and B107.A. Except for specific deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. B. ?The authorization of emission limits for startup, shutdown, maintenance, and malfunction does not supersede the requirements to minimize emissions according to Conditions and B107.A. ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 37 of 144 EPA Inspection Report - Page 433 of 1969 Version 02.25.15 A107 Facility: Allowable Startup, g] Continuous El Yes Yes Shutdown, Maintenance (SSM) and Malfunction Emissions Intermittent N0 0 C. SSM Flaring and combustion Emissions Requirement: The permittee shall comply with the ?aring and combustion SSM NOX, CO, VOC, $02, TSP, PM25, and H28 emission limits at Table 107A for the following SSM events: 1) SSM Emissions during SCR downtime 1,2,3,4,5,.d6N by fu] 2) SSM Emissions from )an ?3300 ams 5? gas analysis from New Mexico Gas Company. SRU3 startup and Shutdown Navajo continues to comply with these 3) SSM requirements except for speci?c deviations as noted '3 elsewhere in this document and events reported per Temporary, portable ?are for natural gas pipeline maintenance 4) SSM (H-0473), Emissions from SRU2 startup and shutdown 5) SSM Flare Cap, Emissions from venting SSM activity gases to L- 400, FL-401, FL-402, or 6) SSM Misc 2, Low-Emitting Maintenance Activities such as de?inventorying small equipment, clearing piping associated with emission units, and routine maintenance activities such as 20.2.7 NMAC. ACC Form Part 1 Permit Page 38 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 434 of 1969 Version 02.25.15 heat exchanger repair. revised) (NSR 0195M35, Condition and ?aring and combustion Speci?ed in A107C. Recordkeeping. Monitoring: The permittee shall monitor all ?aring and combustion due to routine and predictable startups, shutdowns, and scheduled maintenance events. This shall. be accomplished by collecting all the SSM information Navajo Environmental Department keeps an up-to? date events summary with emission units and pollutant. IZI Continuous IZI Intermittent Yes IXI No IXI Yes No Recordkeeping: The permittee shall record the date, start and end times, and duration of every SSM ?aring or combustion event. The NOX, CO, VOC, volume of gas sent to the ?are and the total sulfur content of the ?ared gas. Compliance with the hourly emission rates shall be demonstrated by calculating the hourly emission rates for each event and comparing the results to the hourly emission rate at Table The annual emission rate shall be calculated as follows: and 802, TSP, and H28 emissions shall be calculated for each event based on the 1) To demonstrate compliance during the ?rst 12 months of monitoring, the permittee shall calculate and sum the cumulative total of CO, VOC, $02, TSP, PM25, and H28 emissions; 2) After the ?rst 12 months of monitoring, the permittee shall Navajo keeps records of SSM events. Maintenance scheduling is based on engineering judgment and operating experience. Continuous IZI Intermittent Yes IXI No IXI Yes El No ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 39 of 144 EPA Inspection Report - Page 435 of 1969 Version 02.25.15 calculate and sum the total of NOX, CO, VOC, S02, TSP, and H2S emissions on a rolling 12 month basis. 3) The permittee shall maintain all records in accordance with Section routine and predictable startups, shutdowns, and scheduled maintenance events. This shall be accomplished by collecting VOC emission calculation information for the following SSM VOC emission activities: 1) SSM T-073 7, Emissions from roof landing 2) SSM Emissions from roof landing and tank re?lling 3) SSM T-0079, Emissions from Navajo complies with these requirements, except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. B109. . Reports required by Section Bl 10 are submitted as El Continuous El Yes IE Yes Reporting: The permittee Shall report 1n necessary, except for speci?c deviations as noted accordance with Section 10, elsewhere in this document and events reported per IE Intermittent N0 El No 20.2.7 A107 Facility: Allowable Startup, El Continuous El Yes IE Yes Shutdown, Maintenance (SSM) and Malfunction Emissions Intermittent IE N0 D. SSM VOC Emissions (Facility?Wide, Navajo complies with the requirements listed in Non-Combustion Sources) table 107 .A. Requirement: The permittee shall comply with the SSM VOC emission limit at Table 107.A. Monitoring: The permittee shall monitor El Continuous Yes Yes all VOC emission activities due to El Intermittent IE N0 El 0 ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 40 of144 EPA Inspection Report - Page 436 of 1969 Version 02.25.15 4) 5) roof landing and tank re?lling SSM T4225, Emissions from roof landing SSM Tanks Miscellaneous 1) 2) 3) Recordkeeping: The annual SSM VOC emission rate shall be calculated as follows: To demonstrate compliance during the ?rst 1.2 months of monitoring the permittee shall calculate and sum the cumulative total of VOC emissions; and After the first 12 months of monitoring the permittee shall calculate and sum the total of VOC emissions on a rolling 12 month basis, including the methodology and/or assumptions used in the calculation(s). The permittee shall keep records to demonstrate compliance in accordance with Condition B109C, except the requirement in to record the start and end times of SSM events shall. not apply to known quantities of VOC emissions. The permittee shall maintain all records in accordance with Section B109. Navajo complies with these requirements, except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. E, Continuous Intermittent Yes No Yes No Reporting: The permittee shall report in accordance with Section B1 10. Navajo complies with these requirements, except for speci?c deviations as noted elsewhere in, this document and events reported per 20.2.7 NMAC. [3 Continuous Intermittent Yes No El Yes No ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 41 of 144 EPA Inspection Report - Page 437 of 1969 Version 02.25.15 A107 Facility: Allowable Startup, El Continuous Yes El Yes Shutdown, Maintenance (SSM) and Malfunction Emissions Intermittent No Ne E. SSM Particulate Emissions (Unit SSM Navajo complies vvith these requirements, except . for speCI?c dev1ations as noted elsewhere in this MISC 1) document and events reported per 2027 NMAC. Requirement: The pennittee shall minimize particulate emissions due to SSM events. Monitoring: The permittee shall monitor El Continuous Yes El Yes all particulate emissions due to routine and predictable startups, shutdowns, and Intermittent El N0 N0 Navajo complies with these requirements, except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. scheduled maintenance events. For the event type of FCCU Catalyst Loading, the maximum material usage shall not exceed 1 hr?duration, 1 loading event/yr; and 237,048 lb/event/yr. Recordkeeping: For .each event, the EIContinuous EYES :IYes permittee shall maintain records of the duration in hours, events per year, and Intermittent El Ne Ne material. usage for the particulate matter Catalyst loading data collected on a daily basis and emitting SSM event - FCCU Catalyst maintained by the Navajo Process Engineering Loading. The annual material usage shall Department- be based on rolling 12-month total. The permittee shall maintain all records in accordance with Section 8109. - Reporting: The permittee Shall report in Navajo complies with these requirements, except Continuous Yes Yes . . for spec1?c dev1ations as noted elsewhere in this accordance Section B1 10? document and events reported per 20.2.7 NMAC. El Intermittent El N0 N0 ACC Form Part 1 Permit P051-R2 mm Page 42 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 438 of 1969 Version 02.25.15 A107 Facility: Allowable Startup, Shutdown, Maintenance (SSM) and Malfunction Emissions F. SSM and Malfunction Flaring Emissions (SSM Flare Cap and Flares Malf Cap) Requirement: The permittee shall not exceed the pound per hour (pph) and ton per year (tpy) emission limits in Table A107.A and shall demonstrate compliance with these limits by calculating and summarizing these emission rates as required in recordkeeping. Navajo complies with these requirements, except for specific deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. El Continuous- Intermittent El Yes No Yes No Monitoring: A gas ?owmeter and ?ow totalizer, equipped with a chart recorder or electronic data logger, shall be installed in the ?are line to measure and record the total standard cubic feet (sci) of all gas (process gas, purge gas, pilot gas, and supplemental fuel gas) sent to the ?are during each hour and each month. The permittee shall measure the H28 content, the total. sulfur content, the VOC content, and the heating value (Btu/sci) of the gas sent to the ?are for combustion. H28 shall be measured at least once every 24?hours on each of the inlet gas types/streams using a stain tube of the appropriate size range or an inline HQS monitor. The total sulfur content, VOC content, and heating value (Btu/sci) of the Navajo complies with these requirements, except for specific deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. 1: Continuous El Intermittent IXI Yes El No Yes No ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 43 of 144 EPA Inspection Report - Page 439 of 1969 Version 02.25.15 natural gas sent to the ?are shall be measured at least once annually with an extended. gas analysis. The ?ow meter and ?ow totalizer shall be operated, calibrated, and maintained as speci?ed by the manufacturer and as necessary to ensure correct and accurate readings. If used, the inline monitor shall be operated, calibrated, and maintained as speci?ed by the manufacturer and as necessary to ensure correct and accurate readings. Recordkeeping: The following records Continuous Yes Yes Shall be kept: . Intermittent El No No 0 stain tube and/or 1n11ne HZS measurements 0 annual extended gas analysis 0 both the hourly and volume (set) of gas sent to the ?are Each month, the permittee shall record and summarize in a table format the following. Navajo complies with these requirements, except H23 and the total $111fo CODtel?lt for speci?c deviations as noted elsewhere in this a percent VOC content document and events reported per 20.2.7 NMAC. a gas heating value (Btu/sci) the maximum hourly gas ?ow rate (scf/hr) that occurred during the month 0 each hourly gas ?ow rate (scf/hr) for any hour(s) that exceeded any emission limit during the month. 0 the total month?s of gas sent to the ?are ACC Form Part 1 Permit R2M1 Page 44 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 440 of 1969 Version 02.25.15 0 the rolling 12~month total of gas sent to each ?are (scf/yr) Each month, the permittee shall record all routine and predictable startups, shutdowns, and scheduled maintenance events and shall also meet the recordkeeping requirements in General Condition B109 of this permit, except the requirement to record the start and end times of SSM events shall not apply. Records of ?owmeter, totalizer, and inline monitor certi?cations, calibrations, documentation of the manufacturer?s recommended calibration maintenance schedule, breakdowns, reasons for the breakdown, and corrective actions taken shall be maintained. Each month, to demonstrate compliance with both the SSM and malfunction emission limits, the permittee shall calculate and summarize the maximum emission. rate, any emission rate exceeding the permitted limits, and the rolling 12-month total ton per year emission rates of CO, VOC, 802, and H28 for both SSM and malfunction events, using the following information: the H28 content, total sulfur content, VOC content, and the gas heating value (MMBtu/scf) from the most recent HZS measurements and gas analyses 0 the emission factors used to ACC Form Part 1 Permit Page 45 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 441 of 1969 Version 02.25.15 calculate NOX and CO the maximum hourly gas ?ow rate (scf/hr) 0 each hourly gas ?ow rate (scf/hr) for any hour(s) that exceeded any emission limit during the month, including the dates and times of these occurrences the rolling 12?month total of gas sent to the ?are (scf/yr) For each event, the permittee shall record whether the emissions are due to SSM and/or malfunction. If the emissions are due to malfunction, the permittee shall indicate whether the emissions resulting from the event are included in the amount allowed by this permit? malfunction limit or whether the event is reported under 20.2.7 NMAC. . Navajo complies with these requirements, Navajo El Continuous Yes Yes Reporting: The shall report complies with these requirements, except for according to Condition B1 10, speci?c deviations as noted elsewhere in this El Intermittent No No document and events reported per 20.2.7 NMAC. A108 Facility: Hours of Operation Continuous Yes Yes A. This facility is authorized for Inter?mittent '3 N0 Xi N0 continuous operation. Monitoring, recordkeeping, and reporting are not required to demonstrate compliance with continuous hours of operation. No requirement. A109 Facility: Reporting Schedules El Continuous Yes Yes Navajo submitted the requested monitoring reports A. A Semi??Annual Report of monitoring as follows; Intermttent N0 N0 activities is due within 45 days following 10/13/2016 the end of every 6?month reporting period. 04/13/2017 The six month reporting periods start on ACC Form Part 1 Permit R2M1 Page 46 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 442 of 1969 Version 02.25.15 September 151 and March of each year. A109 Facility: Reporting Schedules B. The Annual Compliance Certi?cation Report is due within 30 days of the end of every 12-month reporting period. The 12?. month reporting period starts on September 1St of each year. Navajo submitted the requested compliance certi?cation report as follows: 09/29/2016 Continuous Intermittent Yes No Yes No A109 Facility: Reporting Schedules C. .In addition to the reports required by the applicable NSPS, NESHAP and MACT Subparts (including any voluntary programs referencing NSPS, NESHAP, or MACT Subparts) and by the applicable parts of 20.2 NMAC, the reporting required by the Consent Decree shall be submitted to the Department. The reports shall be submitted to the Air Quality Bureau within forty ?ve (45) days of the end of each calendar quarter. If any reports indicate potential non-compliance with the terms of this permit, the Bureau may impose a more frequent reporting time-frame. The Department shall handle any con?dential information in accordance with the provisions of20.2. 1.1 15 NMAC. The Department has not requested more frequent reporting time?frames. Continuous IE Intermittent Yes No Yes No A109 Facility: Reporting Schedules D. Reporting required by the Consent Decree (not an exhaustive listing) (1) The permittee shall notify the Department?s Enforcement Section, Air Navajo submitted the Annual. NOX Control Technology report as follows: 12/3 0/201 6 El Continuous IZI In termittent El Yes I: No Yes No ACC Form Part 1 Permit P05 l?R2 Ver 4.1 02/25/2015 Page 47 of 144 EPA Inspection Report - Page 443 of 1969 Version 02.25.15 Quality Bureau in writing of the annual progress of installation of NOX Control Technology required by Paragraph 16 of the Consent Decree. The report shall be submitted to the EPA and the NMED on or before December 3 1 st of each calendar year commencing with the year 2002. (CD 1116.13) (2) No later than forty-five (45) days following the end of an AG Flaring or TG Incident, the pennittee shall submit to EPA and the NMED a report that sets forth the items detailed in the Consent Decree. (CD 1120, A110 Facility: Fuel and Fuel Sulfur Continuous Yes Yes Requirements (as Required) El Intermittent El No No A. Fuel, Fuel Sulfur, and NSPS J, Ja Sulfur Requirements (See Tables 103E, H, I, K, Summary of Applicable Requirements) Refinery fuel gas IS contlnously mon1tored for H28 content on a 3?hour rolling average. Excedances are reported on Navaj o's Subpart and Subpart Ja Requirement: (NSR 0195M35, reports. Condition A1 10A and revised) (1) To comply with NSPS Subpart J, NSPS Subpart la, and the PSD BACT requirements in Section 106, the permittee ACC Form Part 1 Permit Page 48 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 444 of 1969 Version 02.25.15 shall install, calibrate and maintain a continuous monitoring system (CMS) to continuously measure and record either the hydrogen sul?de (H28) in the re?nery fuel gas streams being burned in the Heaters and Boilers or the concentration of sulfur dioxide emissions to the atmOSphere. (2) All stationary combustion equipment shall be ?red with NSPS quality fuel gas with a maximum H28 content of 0.1 grains/dscf (approx. 162 ppmv), based on a hourly rolling 3?hour average. (3) All stationary combustion equipment shall not combust gas with an annual average sulfur content exceeding 60 (approx. 0.037 grains) as a daily rolling 365-day average. (4) All stationary combustion equipment shall be affected facilities, as de?ned in NSPS 40 CFR Part 60, Subparts A and or a, if re?nery?produced fuel gas is combusted in the heaters and boilers, and shall comply with all applicable requirements of NSPS Subparts A and or .la. (See Table 103.E, Summary of Applicable Requirements) . . Continuous El Yes Yes Monltormg: . (1) The permittee shall install, certify, Intermttem CMS has been Installed and 18 certi?ed, callbrate, ma1nta1n and operate a fuel gas . . . calibrated and maintained. continuous momtormg system (CMS) at ACC Form Part 1 Permit R2M1 Page 49 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 445 of 1969 Version 02.25.15 the fuel gas mix drum outlet in accordance with the requirements of 40 CFR 60.1 1, 60.13, and Part 60 Appendix A, and the applicable performance speci?cation of 40 CFR Part 60 Appendices and F. (2) The following CMS shall be certi?ed initially and recerti?ed annually: 0 Low Pressure Fuel Gas H28 CMS 9 D-0770 High Pressure Fuel Gas H28 CMS (3) As required by the EPA-approvable alternative monitoring procedure (AMP), CCR off~gas streams that enter the re?nery fuel gas system of the H28 CMS shall be monitored quarterly for HZS using gas detector tubes or an equivalent method as follows: CCR stabilizer off gas stream, recycle gas stream, and c) CCR feed stream. 2) CMS annual RATAs were completed as follows: 9 Low Pressure Fuel Gas H28 6/21/2017 High Pressure Fuel Gas H28 6/20/2017 3) The CCR stabilizer off gas, the H2 recycle gas and the CCR feed streams are analyzed a minimium of quarterly. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subparts A, J, and a. (1) Records of the quantity of the re?nery fuel gas and the average heating value of the re?nery fuel gas. This is used to demonstrate compliance with lb/mmBTU and lb/hr limits shown in Table 106A. (permit limit) (2) Records of repairs, maintenance, and calibrations performed for the instruments that measure ?ow or 1) Fuel records are maintained in Pi. 2) Repair, maintenance, and calibration records are maintained by Navajo Instrument and Electrical Department. 3) CCR off?gas stream analysis records are maintained in the Navajo Environmental Department Files (REF .ART.3.J .05 .A). Continuous Intermittent Yes No I: Yes No ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 50 of 144 EPA Inspection Report - Page 446 of 1969 Version 02.25.15 concentration for an applicable permit limit shall be kept. Examples include, but are not limited to, CMS, acid gas ?ow meters, and fuel gas ?ow meters. (40 CFR 60, Appendix F) (3) Records shall be kept of Alternative Monitoring Plan (AMP) H28 analyses of the CCR off?gas streams that enter the re?nery fuel gas system of the fuel gas H28 CMS. (NSPS or Ja) Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subparts A, J, and a, and Section Bl 10. Reports required by Subpart A are submitted El Continuous IXI Yes Yes semiannually. Reports required by Subparts I and. Xi Intermittent :1 0 0 Ia, and Section Bl 10 are submitted as necessary. A111 Facility: 20.2.36 NMAC Continuous Yes Yes A. Facility: 20.2.36 NMAC Intermittent No No Requirement: 20.2.36 NMAC (Petroleum Re?nery Sulfur, 11/30/95) applies to the re?nery as a Whole. Quarterly re?nery~ Navajo Re?nery is no longer affected by 20.2.36 Wide sulfur balance reports shall be ?led in NMAC. This rule was repealed on February 15 accordance with 20.236.113 NMAC. All 2016. ?ares and stacks shall meet the applicable height requirements of 20236.1 14 NMAC as demonstrated through air dispersion modeling done at the time of unit installation. (NSR 0195M35, Condition Al .A) Monitoring: Quarterly monitoring 0 Navajo Re?nery 15 no longer affected by 20.2.36 Continuous Yes yes . NMAC. This rule was repealed on February 15, re?nery?Wide sulfur balance. 2016 Internn'ttent 1:1 N0 XI N0 Recordkeeping: The permittee shall keep Navajo Re?nery is no longer affected by 20.2.36 Continuous Yes Yes record of a copy of the Facility?Wide NMAC. This rule was repealed on FebruarylS, Sulfur Balance Report and the actual 2016- IXI Intermittent No IXI N0 ACC Form Part 1 Permit R2M1 Page 51 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 447 of 1969 Version 02.25.15 height of ?ares and stacks. Requirement: (NSR 0195M35, Condition A112.A) (1) Section 200A (Mercalptans) and section 200.B (Hydrogen Sul?de) apply to mercaptan and H28 emissions from the re?nery. Section 200C applies to FL- 0400, .FL-0402, and and requires an alarm in good working order to signal non-combustion of the gas. (2) Section 201.A (CO), applies to the re?neiy's FCC regenerator stack. The owner or operator of an existing petroleum processing facility shall not permit, cause, suffer or allow carbon monoxide emissions to the atmosphere from a catalyst cracking recirculation or regeneration unit in excess of 20,000 by volume in the undiluted ef?uent gas stream or streams. (3) Section 202.C(l) (PM), The owner or operator of a new petroleum processing facility shall not permit, cause, suffer or allow particulate matter emissions to the atmosphere from the catalytic cracking regenerator vessel in excess of 1.0 Kg/1000 Kg (1.0 lb/1000 lb) of coke 2) The FCC catalyst regenerator exhaust is continously monitored for CO. 3) The catalytic cracking regenerator is tested annually for PM. Navajo has submitted an alternative monitoring plan (AMP) to comply with the FCC Opacity monitoring requirement because the FCCU has a wet scrubber which prevents continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CF 60 Appendix A Method 9. 4) There are no process vents to the atmosphere, so the refinery is not expected to emit ammonia. Any trace ammonia emissions are expected to comply with the 25~ppm limit. 5) Navajo continues to comply with the applicable requirements of NSPS Subpart at refinery oil/water seperators. The oil/water separator is inspected at least semi?annually, and the carbon vapor control is tested at least 6) Blowdowns are accomplished by venting to ?ares that are designed to be operated smokelessly. Navajo Refinery is no longer affected by 20.2.37 NMAC. This rule was repealed on September 12, 2016. . . . Navajo Refinery is no longer affected by 20.2.36 Continuous Yes Yes The permittee Shall report In NMAC. This mle was repealed on February 15, accordance With 20.2.36.113A NMAC. 2016. Intermittent No No A112 Facility: 20.2.37 NMAC . Continuous Yes Yes 1) All ?ares have alarms indicating loss of ?ame A. 20.2.37 NMAC that are in good working order. El Intermittent No No ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 52 of 144 EPA Inspection Report - Page 448 of 1969 Version 02.25.15 bumoff or visible emissions of thirty percent (3 opacity or greater except for. one six?minute average opacity reading in any one?hour period. (4) Section 203 (Ammonia, undiluted emissions 25 ppmv) applies to all emission points of the re?nery. The owner or operator of a petroleum processing facility shall not permit, cause, suffer or allow ammonia emissions to the atmosphere in excess of 25 by volume in the undiluted ef?uent gas stream or streams. (5) Section 204 (Hydrocarbon Separation Facility) applies to all oil/water separators at the re?nery. Compliance with this condition is met by complying with the applicable NSPS Subpart requirements. (6) Section 205 (Facilities - Storage Handling Pumping Blowdown System) applies to certain of the following: storage tanks for organic compounds, loading and unloading of organic compounds, seals on pumps and compressors, and disposal (?aring) of hydrocarbon gases. The permittee shall not permit, cause, suffer or allow the operation of a blowdown system without disposing of the gases in a manner which will minimize hydrocarbon emission to the atmosphere. 1f combustion is the means of disposal, it shall be by: smokeless ?are; or any other method that is equally effective to achieve complete ACC Form Part 1 Permit P051-R2 R2M1 Page 53 of 144 Ver 02/25/2015 EPA Inspection Report - Page 449 of 1969 Version 02.25 .15 combustion. (20.2.37.205.E NMAC) Monitoring: IZI Continuous IE Yes Yes (1) For Units Intermittent No IE No 0402 and The 1) All ?ares have alarms indicating loss of ?ame permittee shall install and maintain a that are gOOd working order. flare pilot flame monltoring system. 2) The FCC catalyst regenerator exhaust is (20'2'3 NMAC) continously monitored for CO. (2) A CO CMS has been installed to monitoring the emissions from the FCC. 3) The catalytic cracking regenerator is tested annually for PM. Navajo has submitted an (3) The annual EPA Method 9 Opacity alternative monitoring plan (AMP) to comply with Test and annual Stack test on Unit FCC the FCC opacity monitoring requirement because (lb/hr PM emissions) and the calculated the FCCU has a wet scrubber which prevents Coke burn rate Will be used for the continuous opacity monitoring. Under the AMP, annual determination of pounds of PM opacity is monitored weekly using 40 CFR 60 per 1000 pounds of Coke burned. App 611le A MathOd 9' 4) None 4) Not monitorin re uirement. Cl (5) NO. additional monitoring .Smcg 5) Navajo continues to comply with all compllance 15 met by complying the requirements except for speci?c deviations as noted NSPS Subpart elsewhere in this document. requirements. See other conditions of this permit for applicable NSPS 0r MACT 6) Navajo continues to comply with all applicable requirements. requirements except for speci?c deviations as noted (6) Compliance is demonstrated through elseWhere in this document- NSPS K, NSPS Ka, NSPS Kb, or MACT . 1kg, th 11 h. MACT CC for avajo inery IS no onger a . .ecte . . .0 I 3 . to . NMAC. This rule was repealed on September 12, Loadmg Racks, through NSPS 2016 NSPS or MACT CC for Pumps and Compressors; and through NSPS Subpart A for Blowdowns. 1) Records are maintaned in Pi. t' Recordkeeping: A on es es (1) Pilot flame monitoring records 2) Records are maintained in Pi. IE Intermittent No No (2) CO CMS measurements 3) Stack test reports are maintained by the Navajo ACC Form Part 1 Permit P051-R2 RZMI Ver 02/25/2015 Page 54 of 144 EPA Inspection Report - Page 450 of 1969 Version 02.25.15 (3) Copy of annual coke burn rate determination, stack test report, and opacity test report (4) None (5) Applicable NSPS Subpart requirements (6) Applicable NSPS K, NSPS Ka, NSPS Kb, or MACT CC for Tanks; through MACT CC for Loading Racks; through NSPS NSPS or MACT CC for Pumps and Compressors; and through Environmental Department. 4) No recordkeeping requirement. 5) NSPS reports are maintained by the Navajo Environmental Department. 6) NSPS K, NSPS Ka, NSPS Kb, NSPS NSPS J, NSPS .la, and MACT CC reports are maintained by the Navajo Environmental Department. Navajo Re?nery is no longer affected by 20.2.37 NMAC. This rule was repealed on September 12, Requirement: 20.2.3 8 NMAC (Hydrocarbon Storage Facilities, 1 1/ 3 0/ 95) applies to the re?nery as follows: 1. Section 1.09 (Tank Storage Associated With Petroleum Production or Processing Facility [Sour Hydrocarbon Liquids]) applies to the loading and storing of hydrocarbons containing H28. 2. Section 110 (Tank Battery or Storage Facility - Within Municipality [Sour 1) The Artesia Re?nery includes storage vessels that store hydrocarbons containing hydrogen sul?de. The vessels comply with the requirements of 202.38.109 by using submerged ?ll. 2) and 3) The vessels comply with the requirements of 20238.1 10 and. 1 13 by using internal or external ?oating roofs with the required seals. NSPS Subpart A for Blowdowns 2016 requirements NSPS I, la, and MACT CC reports Continuous Yes El Yes Reporting: The permittee shall report in are Smeltted semlannually' . . I: Intermittent N0 N0 accordance w1th NSPS or . . MACT Navajo Re?nery is no longer affected by 20.2.37 reqmrements an ectlon B1 10' NMAC. This rule was repealed on September 12, 2016. A113 Facility: 20.2.38 NMAC El Continuous Yes El Yes A. 20.2.38 NMAC Intermittent N0 No ACC Form Part 1 Permit P051-R2 Ver 4.1. 02/25/2015 Page 55 of 144 EPA Inspection Report - Page 451 of 1969 Version 02.25.15 Ver 4.1 02/25/2015 Hydrocarbon Liquids]) applies to certain tanks storing sour hydrocarbon liquids whose vapors contain 324 H2S. 3. Section 1 13 (New Tank Battery and the Pecos?Permian Interstate Air Quality Control Region [Sour Hydrocarbon Liquids]) applies to certain tanks storing sour hydrocarbon liquids Whose vapors contain 324 H28. (NSR 0195M35, Condition Al 13.A) Monitoring: 1_ None Continuous Yes Yes 2. and 3? Demonstrated through NSPS K, 2) and 3) Navajo Inspection Department performs ?oating roof seal seal inspections and maintains those records. emu en 0 0 inspection. Recordkeeping: Continuous Yes Yes I 1: Records Of Tank des1gn showmg Inlet 1) Records of tank designs are maintained in the El No El N0 connectlons. Navajo Engineering Library. Reports required by 2. and 3. No additional requirements other 3110 are submitted as necessary than applicable requirements of NSPS and MACT. Reporting: The permittee shall report in Reports required by B110 are submitted as Continuous El Yes Yes accordance with Section 10. necessary Intermittent No No A118 Facility: MACT Subpart t' For the FCC, Navajo monitors and records the daily on muons es es A. 40 CFR 63, Subpart FCC, average coke bum rate and 0f the continuously Intermittent No No 70-CCR, SRUS 1? Land 3 monitored CO emissions. For the CCR, Navajo monitors and records the weekly average ChlorSorb Requirement: The permittee shall comply catalyst inlet and outlet chloride contentChlorSorb mlet and outlet temperatures, and the W1 a app ica requlrements 9 CCR ?rebox temperature. For the SRUs, Navajo CFR 63: Subpart National monitors and records the $02 cencentration from Standards for Hazardous Air Pollutants for the tail gas incinerators. Petroleum Re?neries: Catalytic Cracking ACC Form Part 1 Permit Page 56 of 144 EPA Inspection Report - Page 452 of 1969 Version 02.25.15 Units, Catalytic Reforming Units, and Sulfur Recovery Units, for all affected sources shown in Tables 103 H&l attached. (63.1560 and 63.1570). Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CF 63, Subpart For the FCC, Navajo monitors and records the daily average coke burn rate and of the continuously monitored CO emissions. For the CCR, Navajo monitors and records the weekly average ChlorSorb catalyst inlet and outlet chloride content, the ChlorSorb inlet and outlet temperatures, and the CCR ?rebox temperature. For the SRUs, Navajo monitors and records the $02 concentration from the tail gas incinerators. IZI Continuous IZI Intermittent Yes No Yes IXI No Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CF 63, Subpart Process records are maintained in Pi. IXI Continuous IXI Intermittent Yes No I: Yes No Reporting: The permittee shall comply with the applicable reporting requirements of40 CFR 63, Subpart Reports required by Subpart were submitted semiannually as follows: 1/ 3 0/ 201 7 7/28/2017 Continuous IZI Intermittent Yes I: No I: Yes IZI No A119 40 CFR 61. Subpart FF. National Emission Standard for Benzene Waste Operations A. 40 CFR 61 Subpart FF, National Emission Standard for Benzene Waste Operations (Units subject in Table 103.C G) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 61, Subpart FF, National Emission Standard for Benzene Waste Operations for the affected sources in Tables 103C, G. The refinery complies with the applicable requirements of NESHAP Subpart FF. Because the refinery?s total annual benzene (TAB) quantity is less than 10 Mg/yr, none of the standards in this regulation apply. Continuous Intermittent Yes No El Yes [3 No Monitoring: The permittee shall comply The refinery complies with the applicable I: Continuous IZI Yes El Yes ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 57 of 144 EPA Inspection Report - Page 453 of 1969 Version 02.25.15 with the applicable monitoring and requirements of NESHAP Subpart FF. Because the El Intermittent El No No testing requirements of 40 CFR 61, re?nery?s total annual benzene (TAB) quantity is Subpart FF. less than 10 Mg/yr, none of the standards in this regulation apply. Recordkeeping: The permittee shall El Continuous Yes El Yes comply With the applicable Records are maintained by Navajo Environmental El Intermittent El No No recordkeeping requirements of 40 CFR Department. 61 .3 56. ACC Fonn Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 58 of 144 EPA Inspection Report - Page 454 of 1969 Version 02.25.15 Reporting: The permittee shall comply with the applicable reporting requirements 0f40 CFR 61.357. Navajo submitted the annual TAB report. 04/06/2017 Continuous Intermittent IZI Yes No DYes IZINO A201 Engines A. Maintenance and Repair Monitoring (Units V-0545, V-0546, 13-8010, E-0600W, 0602E, 3-0603, and Units 0100, V-0543, V-0546, E- 0603, and E-0901) Requirement: These units are subject to Title since they are subject to NSPS and/ or MACT requirements. No emission limits were established since their emissions are small. The permittee shall ensure these units are properly maintained and repaired. Navajo complies with MACT Subpart Unit 0 was installed 1 1/04/2013. The engine was operated a total 0.4 hours during the reporting period. Continuous Intermittent IZI Yes I: No [:lYes No Monitoring: Maintenance and repair shall meet the minimum manufacturer's or permittee's recommended maintenance schedule. Activities that involve maintenance, adjustment, replacement, or repair of functional components with the potential to affect the operation of an emission unit shall be documented as they occur for the following events: (1) Routine maintenance that takes a unit out of service for more than two hours during any twenty-four hour period. (2) Unscheduled repairs that require a unit Navajo complies with MACT Subpart 1) and 2) Unit M-8010 operating hours are monitored. the unit was not taken out of service greater then two hours in any twenty-four hour period. Continuous IZI Intermittent Yes No Yes N0 ACC Form Part 1 Permit P05 l-R2 Ver 4.1 02/25/2015 Page 59 of 144 EPA Inspection Report - Page 455 of 1969 Version 02.25.15 to be taken out of service for more than two hours in any twentyufour hour period. Recordkee ing: The perrnittee shall - maintain rgcords in accordance with Navajo complies with MACT Subpart 2222. El Yes Yes Section B109, including records of . . . . IE Intermittent Un1tM?8010 1s equiped With a non?resetable run~ malntenance and repairs act1v1t1es and a . time meter. Navajo keeps quarterly rolling annual copy of the manufacturer?s or perm1ttee?s . total hours on ?le. recommended maintenance schedule. Reporting: The permittee shall report in Reports required by Bl 10 are submitted as Continuous '3 YES El YES accordance with Section Bl 10. necessary. IE Intermittent El N0 No A201 Engines Continuous IE Yes El Yes B. 40 CFR 63, Subpart 2222 (Units G- Intermittent No No 0100, V-0546, 13?8010, E-0600W, E- 0603, and 13?0901) (Units subject in Table #11 03-] Navajo complies with Subpart Requirement: The units listed as subject in Table 103.] are subject to 40 CFR 63, Subpart 2222 and the permittee shall comply with all applicable requirements of Subpart A and Subpart Monitoring: The permittee shall comply El Continuous IE Yes Yes all monltorlng and Navajo complies with Subpart El Intermittent No No testing requ1rements of 40 CFR 63, Subpart A and Subpart Recordkeeping: The permittee shall El Continuous [3 Yes Yes comply with all applicable recordkeeping requirements of 40 CF 63, Subpart A and Navajo complies with Subpart 2222. Intermittent N0 '3 N0 Subpart 2222, including but not limited to 63.6655 and 63.10. ACC Form Part 1 Permit Page 60 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 456 of 1969 Version 02.25.15 Reporting: The permittee shall comply with all applicable reporting requirements of 40 CFR 63, Subpart A and including but not limited to 63.6645, 63.6650, 63.9, and 63.10. Reports required by Subpart were submitted semiannually as follows: 1/31/2017 7/28/2017 Continuous Intermittent IE Yes No Yes IE N0 A201 Engines C. 40 CFR 60, Subpart 1111 (Diesel Engines subject in Table 103.] Requirement: The units listed as subject in Table 1031 are subject to 40 CFR 60, Subparts A and 1111 and shall comply with the noti?cation requirements in Subpart A and the speci?c requirements of Subpart Navajo complies with Subpart Continuous Intermittent IX Yes No Yes No Monitoring: The permittee shall comply with all applicable monitoring and testing requirements in 40 CF 60, Subpart A and Subpart 1111, including but not limited to 60.4211. Navajo complies with Subpart Continuous IZI Intermittent IXI Yes No I: Yes IX N0 Recordkeeping: The permittee shall comply with all applicable recordkeeping requirements in 40 CF 60, Subpart A and Subpart 1111, including but not limited to 60.4214. Navajo complies with Subpart El Continuous IZI Intermittent Yes No El Yes IE No Reporting: The permittee shall comply with all applicable reporting requirements in 40 CFR 60, Subpart A and Subpart including but not limited to 60.4214. Navajo complies with Subpart Continuous IX Intermittent IZI Yes No Yes IE No A203 Tanks A. NSPS Subpart K, Standards of Performance for Storage Vessels for Petroleum Liquids for Which Navajo continues to comply with the applicable requirements of NSPS Subpart K, as applicable to the affected storage tanks shown in Table 103C of this permit, except for inspections iisted as deviations previously submitted reports. External Continuous IE Intermittent IE Yes No Yes IX N0 ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 61 of 144 EPA Inspection Report - Page 457 of 1969 Version 02.25.15 Construction, Reconstruction, or Modi?cation Commenced After June 11, 1973, and Prior to May 19, 1978 (Tanks subject in Table Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A for the affected sources in Table 103.C. and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR-60, Subpart K. Navajo continues to comply with the applicable requirements of NSPS Subpart K, as applicable to the affected storage tanks shown in Table 103C of this permit, except for inspections listed as deviations previously submitted reports. External and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. El Continuous IZI Intermittent Yes No Yes IZI No Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart K. External and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. El Continuous Intermittent IZI Yes El No I: Yes No Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart K. Navajo submits notifications of seal inspections to the Department. El Continuous El Intermittent IZI Yes El No Yes El No A203 Tanks B. NSPS Subpart Ka, Standards of Performance for Storage Vessels for Petroleum. Liquids for Which Construction, Reconstruction, or Modi?cation Commenced After May 18, 1978, and Prior to July 23, 1984 (Tanks subject in Table Navajo continues to comply with the applicable requirements of NSPS Subpart Ka, as applicable to the affected storage tanks shown in Table 103C of this permit, except for inspections listed as deviations previously submitted reports. External and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as I: Continuous El Intermittent ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 62 of 144 EPA Inspection Report - Page 458 of 1969 Version 02.25.15 Requirement: The pennittee shall comply with all applicable requirements of40 CFR 60, Subparts A Ka for the affected. sources in Table 103C. required. The true vapor pressure is based on the material stored and maximium historical data. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart Ka. Navajo continues to comply with the applicable requirements of NSPS Subpart Ka, as applicable to the affected storage tanks shown in Table 103C of this permit, except for inspections listed as deviations previously submitted reports. External and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. Continuous IZI Intermittent El Yes No Yes No Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart Ka. External and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. Continuous IZI Intermittent IXI Yes No Yes No Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart Ka. Navajo submits noti?cations of seal inspections to the Department. Continuous Intermittent Yes No Yes IXI No A203 Tanks C. NSPS Subpait Kb, ?Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modi?cation Commenced After January 23, 1984" (Tanks subject in Table Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A Kb for the affected Navajo continues to comply with the applicable requirements of MACT Subpart CC as applicable to the processes shown in Table 103 B, C, D, G, except for deviations noted in semi?annual reports. Fugitive components subject to these rules are included in the Leak Detection and Repair (LDAR) program. Navajo uses a third?party contractor for the LDAR monitoring and recordkeeping. Navajo continues to comply with the applicable requirements of MACT Subpart CC as applicable to the affected storage tanks, except for inspections listed as deviations in this report. External and Continuous Intermittent ACC Form Part 1 Permit P05 1 Ver 4.1 02/25/2015 IXI Yes No Yes No Page 63 of 144 EPA Inspection Report - Page 459 of 1969 Version 02.25.15 sources in Table I.O3.C. internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The loading rack subject to portions of MACT Subpart incorporated by reference into MACT CC is equipped with a carbon adsorption system monitored by a CMS. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart Kb. Fugitive components subject to these rules are included in the Leak Detection and Repair (LDAR) program. Navajo uses a third?party contractor for the LDAR monitoring and recordkeeping. The loading rack subject to portions of MACT Subpart incorporated by reference into MACT CC is equipped with a carbon adsorption system monitored by a CMS. Continuous El Intermittent Yes No El Yes No Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart Kb. Navajo maintains records at the Environmental of?ce, with the on?site LDAR contractor, and with Holly Energy Partners (HEP) for the gasoline loading rack. Continuous XI Intermittent Yes No El Yes No Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart Kb. Navajo submited Subpart CC reports semiannually as follows: 2/ 8/2017 8/29/2017 El Continuous El Intermittent Yes No Yes XI No A203 Tanks D. MACT Subpart CC, ?National Emission Standards for Hazardous Air Pollutants from Petroleum Re?neries? (Tanks subject in Table 103C) Navajo maintains records at the Environmental of?ce, with the on-site LDAR contractor, and with Holly Energy Partners (HEP) for the gasoline loading rack. El Continuous El Intermittent Kl Yes No Yes El No Requirement: The permittee shall comply with all applicable requirements of MACT Subpart CC, ?National Emission Standards for Hazardous Air Pollutants from Petroleum Re?neries? for all affected sources shown in Table 103.C attached. Navajo maintains records at the Environmental of?ce, with the on-site LDAR contractor, and with Holly Energy Partners (HEP) for the gasoline loading rack. El Continuous Xi Intermittent Yes No Yes No ACC Form Part 1 Permit POSIHRZ Ver 4.1 02/25/2015 Page 64 of 144 EPA Inspection Report - Page 460 of 1969 Version 02.25.15 (63.640). . . . El Continuous IXI Yes El Yes Monitoring: The pennittee shall comply Navajo maintains records at the Environmental With the applicable monitoring and of?ce, with the on?site LDAR contractor, and with IE Intermittent El No No testing requirements of 40 CFR 63, HOUY Energy Partners (HEP) for the gaSOIine Subpart cc_ loading rack. Recordkeeping: The permittee shall Navajo maintains records at the Environmental El El Yes El Yes comply With the applicable of?ce, with the on-site LDAR contractor, and with El . Intermittent El ?10 No recordkeeping requirements of 40 CFR HOHY Energy (HEP) the gaSOhne 1 IE 63.655. loading rack. Reporting: The permittee shall comply NanaJ-O sut?nitedfh?ACT Sprart CC rcports Continuous Yes Cl Yes with the applicable reporting requirements semiannua as ?40 CFR 63 655 2/18/2017 IXI Intermittent 8/29/2017 A203 Tanks IXI Continuous IX, Yes El Yes IZI Intermittent No IXI No E. Tank Throughput, Temperature, and VOC and H28 Limits (Units shown in Tables 1063 C) Requirement: Compliance with the allowable throughput limits and emission NaVajO 00111131165 through Pi data- limits in Table 106D shall be demonstrated by not exceeding the rolling 1 2-month total throughput to the unit(s) of gallons per year (barrels/year) shown in Table 106D and not exceeding the allowable vapor pres sure listed in. Tables l.06.B C. Monitoring: The permittee shall monitor Continuous El Yes :1 Yes the total throughput, maximum 1? th 1 . . temperature once per month and the vapor avajo comp les I a 8 '3 111th ?11th El N0 le N0 pressure of each tank. Recordkeeping: The permittee shall Navajo complies through Pi data. Continuous IXI Yes El Yes ACC Form Part 1 Permit Page 65 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 461 of 1969 Version 02.25.15 record the total throughput of IZlIntermittent END ENG liquids and the vapor pressure of each tank. Each month, during the ?rst 12 months of monitoring, the permittee shall record the cumulative total liquid throughput and vapor pressure and after the ?rst 12 months of monitoring, the pennittee shall calculate and record a rolling 12-month total liquid throughput and the vapor pressure of each tank. The permittee has calculated the VOCs and H28 annually based on the 12?month total. Tank breathing and working emissions were calculated. using the USEPA Tanks program Version 4.0.9.d or more current. Emission rates computed using the same parameters, but with a different Department approved algorithm that exceed these values will not be deemed non?compliance with this permit. Records shall also be maintained in accordance with Section B109. Reporting: The pennittee shall report in . . . El Continuous Yes Yes . . Navajo complies through P1 data. accordance With Sect1on B1 10. El Intermittent El N0 IE N0 ACC Form Part 1 Permit Page 66 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 462 of 1969 Version 02.25.15 A204 Heaters/Boilers CI Continuous XI Yes Yes A. Operational Inspection (All El Intermittent El N0 N0 heaters/boilers in Tables 103.13 104A) Inspections were performed to ensure proper . operation. Requirement: Compllance With the allowable emission limits in Table 106A shall be demonstrated by performing periodic inSpections to ensure proper Operations. Monitoring: The permittee shall conduct Cl Continuous El Yes El Yes annual operational inspections to determine that the are operating properly. The operational inspections shall include operational checks for indications of insufficient excess air, or too much excess combustion Inspections were performed to ensure proper air. These operational checks shall include Operation. observation of common physical indications of improper combustion, including indications speci?ed by the heater/boiler manufacturer, and indications based on operational experience with the/these unit(s). El Intermittent El N0 XI No Recordkeeping: The permittee shall El Continuous Yes El Yes maintain records. of operational Intermittent CI 0 0 inspectlons, describmg the results of all operational inspections noting chronologically any adjustments needed to bring the into compliance. The pennittee shall maintain records in accordance with Section B109. Inspection results are maintained by Navajo Environmental Department. ACC Fonn Part 1 Permit R2M1 Page 67 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 463 of 1969 Version 02.25.] 5 Reporting: The permittee shall report in continuous IE Yes 1:1 Yes accordance with Section B110. Intermittent 1:1 N0 N0 Within ninety (90) days Ofpermit issuance= Navajo submited MACT Subpart reports the permittee shall submit for Department semiannually as follows: approval a procedure which the permittee 1 /3 0/2017 will use to carry out the operational 7/28/2017 inspections. The pennittee may at any time submit revisions for Department approval. A204 Heaters/Boilers Continuous Yes 1:1 Yes Testing was performed as follows: B. Periodic Emissions Tests (Units Heaters 30019 01/05/2017 Intermittent 1:1 N0 N0 H-0019, H-0020, H-O363, H- H-0020 01/05/2017 0364, and 30362 01/10/2017 01/10/2017 Requirement: Compliance with allowable 3:333? 8211:2138 i; em1ss1on 11m1ts in Table 106A shall be 01/11/2017 demonstrated by performing periodic H-3403 01/11/2017 emissions tests. (NSR 0195M35, All heaters were within allowable emission limits. Condition A204.A, revived) Monitoring: The permittee shall conduct continuous 13 Yes 1:1 Yes Testing was performed as follows NO and CO. 01/05/2017 01/05/2017 Test results that demonstrate compliance 01/10/2017 with the CO emission limits shall also be H-0363 01/10/2017 considered to demonstrate compliance 01/10/2017 with the VOC emission limits. 07/25/2017 Section B108 General Monitoring H8402 01/11/2017 Requirements apply to this condition H3403 01/1 ?2.01.7 . . . . All heaters were Within allowable emiss10n 11m1ts. The permittee shall meet the testing requirements in Section El 1 l. ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 68 of 144 EPA Inspection Report - Page 464 of 1969 Version 02.25.15 Recordkeeping: Records of periodic IZIC?mtinuous Ely? l: Yes emission tests shall include the ?ow rate XI Intermittent NO and the stack gas exhaust temperature. If a combustion analyzer is used to measure NOX, CO, and/or excess air in the ?ue gas, records shall be kept of the make and model of the instrument and instrument calibration data. If an ORSAT apparatus Periodic emission test results are maintained by or other gas absorption analyzer is used, Navajo Environmental Department. the permittee shall. record all calibration results. Records shall be kept of all raw data used to determine ?ue gas ?ow and of all calculations used to determine ?ow rates and emission rates. The permittee shall maintain records in accordance with Section B109, Bl IO, and B111. Reporting: The permittee shall summarize g] Continuous Yes Yes in tabular form the results of the initial or subsequent periodic emissions tests for Intermittent BN0 IENO NOX and CO, specifying the mass emissions rates in pounds per hour. The All testing reports were submitted to the NMED at table shall include the average concentration of all relevant pollutant species. The permittee shall report in accordance with Section B109, El 10, and A204 Heaters/Boilers g] Continuous Yes Yes Intermittent No No C. Summary of Compliance Methods for Heaters and Boilers for Table 106. A, Navajo complies With these requirements, except 20.233 NM AC 20.2.37 NM AC (Boilers for deviations previously reported or identified at and Heaters in Tables and 104A) the end report. Requirement: (NSR 0195M35, ACC Form Part 1 Permit P051-R2 Page 69 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 465 of 1969 Version 02.25.15 Condition A204.B) (1) Demonstrate compliance with Table 106A Allowable Emissions. (2) 20.2.33 NMAC (Gas Burning Equipment Nitrogen Dioxide, 10/31/02) applies to existing and new gas burning equipment having a heat input of greater than 1,000,000 million British Thermal Units per year. It applies to process heaters identi?ed in Tables 103.13 and 104A. These units shall be equipped with burners emitting less than 0.2 lb NOX per MM Btu. Compliance with 20.2.33 NMAC is demonstrated by compliance with the NOX lb per MM Btu limits in Table A106.A. Monitoring: 1) Fuel use measured by Pi. Continuous Yes Yes (1) The permittee shall monitor the fuel usage of the all boilers and heaters. The fuel gas is analyzed at 16351 01106 per IZI Intermittent N0 IZI N0 fuel usage shall be monitored for speci?c week- heaters and boilers subject to 20.2.33 NMAC. (2) For speci?c heaters and boilers subject 4) No combustion sources ?re only purchased gas. to 20.2.33 NMAC, the permittee shall collect and analyze samples of the re?nery fuel gas at least once per week. The . . B-0007 06/21/2017 re?nery fuel gas ana1y31s shall include the . . 06/24/2017 compos1tion of the re?nery fuel gas, the 10/05/2016 07/24/2017 gross heating value, and the net heating H-9851 06/20/2017 Value- 01/09/2017 (3) See Condition A110.A for H28 monitoring requirements. 3) Refer to response for Section A100.A 5) The following combustion sources have CMS that are recerti?ed annually as follows: 6) Test results referenced in Condition A104.B meet this requirement. (4) All process heaters and boilers shall ?re only re?nery gas in accordance with 7) Navajo complies through Pi data. ACC Form Part 1 Permit P051-R2 R2M1 Page 70 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 466 of 1969 Version 02.25.15 Application, Section 2, Table 8) Navajo Re?nery is no longer affected by 20.2.37 NMAC. This rule was repealed on (5) For those com ustlon sources requ1red September 12? 2016. to have a continuous monitoring system (CMS) (listed in below), the permittee shall install, certify, calibrate, maintain, and operate the CMS for each required pollutant in accordance with the applicable requirements of 40 CFR 60 or 63. The hourly average CMS data, the re?nery fuel gas usage data, and the re?nery fuel gas composition data shall be used to estimate the actual emission rates. The following CMS shall be recerti?ed annually: 0 Boiler Bw0007 NOX and 02 CMS - Boiler B-0008 and CMS 9 Boiler B-0009 NOX and H-2501 NOX O2 CMS (6) For those combustion sources required to conduct periodic stack exhaust testing as stated in Condition A204.B, the test reports shall be used to demonstrate compliance with the NOX, CO, and VOC limits in Table 106A. (7) For those units and pollutants that are not required to have a CMS or a periodic stack test, (Units 0018, H-0028, H-0030, H-0040, H-0303, H-0352, H-0354, H- 0355, H-0421, H-0464, H-0473, ACC Form Part 1 Permit R2M1 Page 71 of1.44 Ver 4.1 02/25/2015 EPA Inspection Report - Page 467 of 1969 Version 02.25.15 H~880l, Hu8802, and H?3lOl) the permit application emission factor, the fuel usage, and the re?nery fuel gas analysis shall be used to calculate the emission rates of NOX, CO, VOC, and PM. (8) Compliance with the particulate emission limitation set forth in 20.2.3 7.202.A NMAC shall be determined as speci?ed in NMAC. Combustion of only gaseous fuel has been approved by the Department as the compliance method under NMAC. Recordkeeping: The permittee shall Continuous Yes El Yes maintain the following records: (1) By March 31, the annual fuel usage for all boilers and heaters for the previous calendar year. IXI Intermittent CI No IXI No (2) By March 31, the average fuel 1) Fuel usage records are maintained in Pi. composition and heating value for all boilers and heaters for the previous calendar year. 2) Fuel composition records are maintained in Pi. 3) CMS data is maintained on Pi. (3) For those units required to have a CMS (13?0007, 13-0008, 8-0009, H-9851 4) Test reports are maintained by Navajo and H-2501), the CMS hourly average EnVirO?mental Department- data. 5) The summary spreadsheet is included in the (4) For thOSe units required to conduct Emission Inventory. periodic stack exhaust testing, the periodic test report. (5) For all boilers and heaters, a summary spread sheet shall be maintained comparing the actual annual emissions with the allowable emission limits expressed in ACC Form Part 1 Permit P051-R2 Page 72 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 468 of 1969 Version 02.25.15 tons per year and lb/MMBtu using the appropriate method of compliance demonstration. This spreadsheet shall be updated by March 31 of each year for the previous calendar year. Reporting: The permittee shall report in . . El Continuous Yes Yes Reports required by B110 are submitted as accordance W1th Sectlons B110. necessary. Intermittent No No A204 Heaters/Boilers Continuous El Yes Yes Intermittent IE No El No D. Consent Decree NOX Emission Limits for Boilers 8-0007, and (new as of 201 3) Requirement: (NSR 01 95M35, Condition A204.C) (1) In accordance with the Consent Decree lodged December 20, 2001, emissions from boilers B-0007 (no later than December 31, 2002), B-0008 (no later than December 31, 2003), and B-0009 (new as of 201 3) shall not exceed the limit in Table 106A during any hourly rolling 3?hour period. Demonstration of compliance with the NOX limit for 8?0007, B-0008, and B- 0009 shall be established by averaging the CMS Data over any 3uhour period and comparing the average concentration to the parametric limit of 42.1 corrected to 6.1% 02 as determined by the CMS. (CD1116.D) This also satis?es the requirement in 20.2.3 3.108.A NMAC that emissions I) Data maintained in Pi. 2) No requirement. ACC Form Part 1 Permit Ver 02/25/2015 Page 73 of 144 EPA Inspection Report - Page 469 of 1969 Version 02.25.15 shall not exceed 0.2 (2) Navajo is authorized to operate all three boilers B-0008, and 0009) simultaneously as needed. Monitoring: For the Controlled Boilers as listed in the Consent Decree and (new as of 2013), continuous compliance with their respective permit emissions limits shall be demonstrated by monitoring as follows: (1) For boilers (B-0007, and 0009) with a heat input capacity greater than 150 of HHV, the permittee shall install or continue to operate CMS to measure and 02. Each CMS shall be installed, certi?ed, calibrated, maintained, and operated in accordance with the requirements of 40 CFR 60.11, 60.13, and Part 60 Appendix A and the applicable performance speci?cation test of 40 CFR Part 60 Appendices and F. These CMS shall be used to demonstrate compliance with emission limits. The permittee shall make CMS and process data available to the applicable Federal and State Agencies upon demand as soon as practicable; (CD?lloCi) 1) B-0009 have CMS installed and data maintained in Pi. IZI Continuous IZI Intermittent IZI Yes No Yes IZI No Recordkeeping: The permittee shall keep records of the CMS recerti?cation?s monitored in Condition A2048, Summary of Compliance. CMS recerti?cations are maintained by the Navajo Environemtnal Department. Continuous Intermittent IXI Yes El No Yes N0 ACC Form Part 1 Permit P05 1 -R2 Ver 4.1 02/25/2015 Page 74 of 144 EPA Inspection Report - Page 470 of 1969 Version 02.25.15 Reporting: The permittee Shall report in All testing reports were submitted to the NMED at continuous Yes Yes accordance with Section B110. Intermittent No No A204 Heaters/Boilers Continuous El Yes El Yes E. Monitoring and Testing for Intermittent No El N0 Controlled Heaters Subject to the Consent Decree (Units H-0020, H-0354, H-O600, and H-0601) CMS installed and data maintained. in Pi. Requirement: For the Controlled Heaters as listed in the Consent Decree, continuous compliance with all NOX emissions limits shall be demonstrated by monitoring as follows. (CD1H6.C) (NSR 0195M35, Condition A204.D) Monitoring: XI continuous Yes I: Yes (1) For heaters with a heat input capacity Intermittent No El N0 of equal to or less than 150 (HHV) but greater than 100 (HHV), Navajo shall install or continue to operate CMS to measure and 02 by no later than the date of the installation of the applicable Control Technology on the heater or boiler; or submit for EPA approval, by no later than 60 days after the date of installation of the applicable NOX Control Technology on the heater or boiler, a proposal for monitoring based on operating parameters, including but not limited to, ?rebox 1) is equipped with and O2 CMS that is certi?ed, calibrated, maintained and operated in accordance with the referenced requirements. 2) is equipped with and 02 CMS. Navajo discovered that while the operating parameters of ?rebox temperature and combustion 02 Where monitored for Heaters these parameters have not been used as a means of monitoring performance. 3) Referenced heaters were initially tested and are tested annually. H-0601 is monitored weekly using a handheld portable analyzer. ACC Form Part 1 Permit Ver 4.1. 02/25/2015 Page 75 of 144 EPA Inspection Report - Page 471 of 1969 Version 02.25.15 temperature, air preheat temperature, heat input rate, and combustion 02. Navajo shall evaluate the necessity of using ?rebox or bridgewall temperatures and additional operating parameters and agrees to use such parameters as a means of monitoring performance where Navajo and EPA mutually?agree to their effectiveness. (CD111 6.C.ii). As of January 23, 2014 (notarized date of application), there are no heaters or boilers at the Artesia Re?nery with a capacity of equal to or less than 150 (HHV) but greater than 100 (HHV) subject to Monitoring requirement (2) For heaters with a heat input capacity of equal to or less than 100 of HHV, the permittee shall conduct an initial performance tests for NOX. The results of these tests shall be reported based upon an average of three (3) one?hour testing periods and shall be used to develop representative operating parameters for each unit, which will be used. as indicators of compliance. This condition applies to the following heaters: Heaters H-0353, and 0 Heater H-0020 0 Heaters H-0600 and H-0601 The permittee has completed all of the initial performance tests. ACC Form Part 1 Permit R2M1 Page 76 of 144 Ver 02/25/2015 EPA Inspection Report - Page 472 of 1969 Version 02.25.15 (3) For heater H-0601 compliance shall be demonstrated by continuously monitoring stack oxygen (02) to maintain a 3?hour average below 6.0 vol%. As a further check of compliance, Navajo shall monitor stack NOX at least twice a month using a portable analyzer to assure that the measured NOX value does not exceed the compliance threshold of 38 Continuous IZI Yes Yes Recordkeeping: IE Intermittent No No (1) The permittee shall keep records of the Fuel ?ring rates and Sulfur limits 1) Fuel ?ring rate records are maintained in Pi. monitored for Condition A110.A. 2) and 3) Test records are maintained by the Navajo (2) The permittee shall keep records of the Environmental Department. initial performance tests. (3) The permittee shall keep records of the stack oxygen monitoring and the portable analyzer tests. Reporting: The permittee shall report in Continuous Yes El Yes accordance with Section Bl 10. Condition Reports required by B110 are submitted as does not apply to portable applicable. IE Intermittent El N0 XI No analyzer tests. A204 Heaters/Boilers Continuous Yes El Yes F. Monitoring and Testing for Intermittent El NO No Heaters permitted after the Consent Decree (Units Heaters H-0019, Navajo complies with these requirements. 2501, and Requirement: For the Heaters permitted after the Consent Decree, continuous compliance with their respective ACC Form Part 1 Permit P051-R2 R2M1 Page 77 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 473 of 1969 Version 02.25.15 permit emissions limits in Table 106.A shall be demonstrated by monitoring as follows. (NSR 0195M35, Condition A204.E) Monitoring: Continuous Yes Yes (1) For heaters with a heat input capacity Intermittent N0 12] No greater than 150 MM Btu/hr (LHV Basis), the permittee shall install and operate CMS to measure and 02 by the startup date of each heater. Each CMS shall be installed, certi?ed, calibrated, maintained, and operated in accordance with the requirements of 40 CFR 6011, 60.13, and Part 60 Appendix A and the applicable performance speci?cations of 40 CFR Part 60 Appendices and F. These CMS shall be used to demonstrate compliance 611113310? 11mm The 2) H-2501 hasaCMS installed and permittee shall make CMS and process data maintained in Pi. data available to the applicable Federal and State Agencies upon demand as soon as 3) Initial performance tests were completed as practicable. Condition applies required. to heater H-9851. (2) For heaters with a heat input capacity of equal to or less than 150 MM Btu/hr (LHV) but greater than 100 MM Btu/hr (LHV), Navajo shall: install and operate CMS to measure NOX and Oz by the startup date of each heater; or 1) has a CMS installed and data maintained in Pi. 4) Navajo complies with these requirements. submit to the Permit Program Manager for NMED approval, by no later than 90 days after the startup date of each heater, a proposal for ACC Form Part 1 Permit R2M1 Page 78 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 474 of 1969 Version 02.25.15 monitoring based on operating parameters. Operating parameters to consider include, but are not limited to, ?rebox temperature, air pre?heat temperature, heat input rate, and combustion Oz. Navajo agrees to use such parameters as a means of monitoring performance. Condition applies to heaters H-2501 and. (3) For heaters with a heat input capacity of equal to or less than 100 MM Btu/hr (LHV basis), the permittee shall conduct an initial performance test by no later than 180 days after the startup date. The results of this test shall be reported based upon an average of three (3) one?hour testing periods and shall be used to develop representative operating parameters for each unit, which will be used as indicators of compliance. This condition applies to the following heaters: Heaters H- 0364, and H-2421 0 Heater H-0019 Heaters H-3402 (AMP approved by EPA, see initial performance test completed on July 10, 2013 I Heater H-3403, initial performance test completed on April 30, 2013 (4) US EPA has approved an Alternative ACC Form Part 1 Permit P051-R2 R2M1 Page 79 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 475 of 1969 Version 02.25.15 Monitoring Plan (AMP) for Unit H-3402 for utilizing the oxygen monitor on the H-3402 Unit 34 Hydrocracker Reboiler as a parametric means for demonstrating compliance with NSPS a, monitoring Via a CMS. In accordance with the AMP, the permittee shall. accomplish the following: Install flow indication on the fuel line to provide historical data of the fuel to the Mild Hydrocracker (Unit 34) by January 2015. Monitor the process historical data of the HEP purchased natural gas pressure, and the high pressure fuel balance drum (D-0770). (0) Upgrade the existing the Mild Hydrocracker (Unit 34) Reboiler Heater oxygen monitor to perform daily calibrations as required in 40 (Note that the sample placement does not conform to CMS requirements for process reasons). Conduct biennial performance tests according to the requirements in 40CFR 60.104210). Establish a maximum or curve excess 02 operating limit (MOPV) as required under 40 utilizing the existing monitor. Include Reboiler Heater ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 80 of 144 EPA Inspection Report - Page 476 of 1969 Version 02.25.15 hours of re?nery fuel gas usage and any deviations during such time as required by 40 CFR 60.7 for periodic reporting. Recordkeeping: The permittee shall keep records of the monitoring proposals submitted to the Permit Program Manager for approval and Whether the submittal was approved. (2) The permittee shall keep records of the CMS data, calibration, and recerti?cation?s monitored in Condition A204.A., Summary of Compliance. (3) The permittee shall keep records of the performance tests. (4) The permittee shall keep records of the implementation of the AMP and all required monitoring speci?ed in the AMP. 1) Records are maintained by the Navajo Environmental Department. 2) CMS data maintained in Pi. 3) Performance tests are maintained by the Navajo Environmental Department. 4) the AMP is maintained by the Navajo Environmental Department. El Continuous Intermittent IZI Yes I: No I: Yes IXI N0 Reporting: The permittee shall report in accordance with Section B110. Reports required by B1 10 are submitted as applicable. Continuous Intermittent Yes El No El Yes IZI No A204 Heaters/Boilers G. NSPS Subpart Db, Standards of Performance for Industrial?Commercial? lnstitutional Steam Generating Units (Boilers and heater subject in Table 103E) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A Db SOz-60.42b, for the Heater and Boilers B-0007, and B- 0009 each have a NOX CEMS as required by NSPS Subpart Db. Continuous Intermittent Yes No Yes IZI N0 ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 81 of 144 EPA Inspection Report - Page 477 of 1969 Version 02.25.15 affected sources in Table 103.E. Monitoring: The permittee shall comply . Continuous IE Yes Yes with the applicable monitoring and testing Heater and Bo?ers Bj0008, and requirements of 40 CFR 60. 4 8b, Subpart 0009 each have a CEMS as requlred by NSPS Intermittent El No IE No Subpart Db. Db. Recordkee 'n Th n'ttee shall - . p1 . pen 1 . records are maintained in Pi. Test records are 12' Continuous Yes Yes the recordkeeplng maintained the Nava'o Environmental . requ1rements of 40 CFR 604%, Subpart Interm?ttent N0 N0 epartment. Db. Reporting: The permittee shall comply Navajo submited NSPS Sprart Db reports El Continuous El Yes Yes with the applicable reporting requirements selmannually as El 1/30/2017 Intermittent El No No of 40 CFR 60.49b, Subpart Db. 7/28/2017 Compliance Test: The permittee shall IE Continuous g] Yes El Yes comply w1th the methods and procedures Navajo complies with the requirements of the stipulated in 40 CFR 60, Section 60.45b Compliance Testing. Intermittent No No and 60.46b. A204 Heaters/Boilers Continuous El Yes El Yes H. NSPS Subpart Dc, Standards of Intermittent El N0 '3 N0 Performance for Small Industrial- Commercial - Institutional Steam Generating Units (Boilers and heater subject in Table 103,11) Navajo complies with the requirements of steam generating units. Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A Dc (NOX-60.44C, 802-60420, PM-60.43 c) for the affected sources in Table 103.E. Monitoring: The permittee shall comply El Continuous Kl Yes El Yes Wlth.the monltormg and testmg Navajovcomphes With the requ1rements of steam Intermittent El No No requirements of 40 CFR 60.470, Subpart generating Dc. ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 82 of 144 EPA Inspection Report - Page 478 of 1969 Version 02.25.15 Recordkeeping: The permittee shall Continuous Yes El Yes comply with the applicable recordkeeping Navajo complies with the requirements of steam requirements of 40 CFR 60.480, Subpart generating units. Intermittent N0 Dc. Reporting: The permittee shall comply IE Continuous Yes El Yes applicable Navajo complies with the requirements of steam IE Intermittent No No requirements of 40 CPR 60.480, Subpart generating units. Dc. Compliance Test: The permittee shall Continuous Yes El Yes comply with the methods and procedures Navajo complies with the requirements of steam In . . . No No stlpulated in 40 CF 60, Sect10n 60.44c generating unltS- and 60.45c. Navajo continues to comply with the applicable Continuous Yes El Yes monitoring requirements of NSPS Subpart as applicable to the affected heaters, boilers, Intermittent No No and the FCC shown in Table 103E. The re?nery fuel gas is continuously monitored for A204 Heaters/Boilers H28 content on a 3?hour rolling average basis. NSPS Sfubpart Standafrds ,Of The tail gas incinerator is Per 'ormance or Petro 6?1an Re Inerles continuously monitored for 802 content, corrected (B011ers and heater subject in Table to 0% 02, on a 12?hour 1.01]ng average basis. Requirement: The permittee Shall comply The CCU Catalyst Regenerator Scrubber exhaust With all applicable requirements of 40 is continuously monitored for $02 and CO. PM is CFR 603 Subparts A for the affected monitored annually. Navajo has submitted an sources in Table 1033 alternative monitoring plan (AMP) to comply with the FCC opacity monitoring requirement because the CCU has a wet scrubber which prevents continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CFR 60 Appendix A Method 9. - - - IX, Continuous Yes El Yes Monitoring. The shall comply All of the continuous monitors are operated, ACC Form Part 1 Permit P051-R2 Page 83 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 479 of 1969 Version 02.25.15 with the applicable monitoring and maintained, and certi?ed as required. le Intermittent El No ,1 No testing requirements of 40 CFR 60, Subpart J. Recordkeeping: The permittee shall Continuous El Yes Yes comply w1th the apphcable Records are maintained by Navajo Env1ronmental Kl Intermittent El No El N0 recordkeepmg requirements of 40 CFR Department and 011 P1- 60, Subpart 1. Reporting: The permittee shall comply Navgjo _Subparts reports Continuous Kl Yes Yes with the applicable reporting requirements semiannua as . 7 1/30/2017 El No No of40 CFR 60, Subpart .1. 7/28/2017 ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 84 of 144 EPA Inspection Report - Page 480 of 1969 Version 02.25.15 Navajo continues to comply with the applicable Continuous El Yes El Yes A204 Heaters /Boilers monitoring requirements of NSPS Subpart Ja as applicable to the affected heaters, SRU3, and ?ares Intermittent No No as shown in Table 103E, except for deviations J. NSPS Subpart a, Standards of included in this report, Performance for Petroleum Re?neries for Construction, Reconstruction, or The refinery fuel gas is continuously monitored for Modi?cation Commenced After May 14, H2S content on a 3?hour rolling average basis. 2007 (Boilers and heater subject in Table .ares me minimum 1ea mg va ue, 1p 1&1 velocity, and visible requirements as documented . Tl 'tt 1 11 by the compliance testing detailed. in previous equlremen ie perml 6681a comp responses. with all applicable requirements of 40 CFR 60: Subparts A a for the affected The SRU3 tail gas incinerator is continuously sources in Table l03.E. monitored for 802 content, corrected to 0% 02, on a 12-hour rolling average basis. The permittee Shall comply All of the continuous monitors are operated, Continuous Yes Yes the apphcable monltormg and testing . . ff . requirements of 40 CFR 60, Subpart requm Intermittent No No dk 11 - ecor eepmg permittee .a Records are maintained by Navajo Environmental IE Continuous Yes Yes comply w1th the apphcable recordkeepmg Department and on Pi . requirements of 40 CF 60, Subpart a. Kl Interm?ttent Reporting: The permittee shall comply if Ja raports Continuous Yes Yes w1th the apphcable reporting requirements 1 /3 0 0017 Intermittent El No No A204 Heaters/Boilers El Yes Yes El Intermittent No No K. BACT Ox Limit, Continuous Monitoring System (CMS) (Unit 3-0009) Navajo complies with the BACT requirements for except for deviations previously reported Requirement: The permittee shall comply or Identl?ed at the report. with the allowable emission limits in Table 106A and Condition A106.E that represent NOX BA CT limits for the BACT ACC Form Part 1 Permit P05 l?R2 Ver 4.1 02/25/2015 Page 85 of 144 EPA Inspection Report - Page 481 of 1969 Version 02.25.15 requirements. (N SR 0195M35, Condition A2041 and revised) Monitoring: I: Continuous Yes Yes (1) The Permittee shall comply with the Intermittent No El No CMS monitoring as detailed in Condition 1) Navajo complies with Conditon A20 4.D. A204.D. (2) The permittee shall conduct an EPA 2) 13?0009 went into service on 4/14/2015. The Method test Within six (6) months of initial RATA compliance test was completed on pennit issuance using EPA reference test 1 1/06/2015, except for deviations previously methods and reported or identi?ed at the end of this report. C02. Data from the CMS RATA testing may be used to satisfy this testing requirement. Reeordkeeping: Continuous Yes I: Yes (1) The permittee shall keep records of the l) Navajo complies with A204.B. Intermittent NO No CMS initial calibration and recerti?cation monitored in Condition A2043, Summary 2) The initial compliance test was completed on of Compliance. 11/06/2015- (2) Records of EPA Methods tests shall be maintained for the Boiler. Reporting; Continuous Yes Yes (1) The permittee shall report in IE Intermittent N0 N0 accordance with Section B1 10, to include the CMS initial calibration and 1) Navajo complies with B1 10. recerti?cation. (2) The permittee shall summarize in 2) The initial compliance test was completed on tabular form the results Of the EPA 11/06/2015, except for deviations previously Methods tests for NOX and and (:029 reported or identi?ed at the end of this report. specifying the emissions rates in pounds per hour and lb/MMBtu. The table shall include the average concentration of all relevant pollutant species. ACC Form Part 1 Permit R2M1 Page 86 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 482 of 1969 Version 02.25.15 A204 Heaters/Boilers Continuous Yes Yes Kl Intermittent El No L. MACT Subpart Industrial, Commercial, and Institutional Boilers and Process Heaters (Boilers and heater subject in Table 103.13) Navajo performs the annual tune up required by MACT Subpart Requirement: The units are subject to 40 CFR 63, Subpart and the permittee shall comply with the applicable requirements 01?40 CF 63, Subpart A and Subpart Monitoring: The permittee shall comply Continuous Yes Yes with all applicable monitoring and testing NaVajO Performs the annual tune up retitlil'requirements of 40 CFR 63, Subpart A and MACT Sprart mm en 0 0 Subpart Recordkeeping: The permittee shall El Continuous Yes El Yes comply with the applicable recordkeeping Records are maintained by Navajo Environmental requirements of 40 CFR 63, Subpart A and Department. Intermittent No Xi N0 Subpart Reporting: The permittee shall comply MACT Subpart reports were submitted Continuous Yes Yes with the applicable reporting requirements semi?annually as follows: of 40 CFR 63, Subpart A and Subpart 01/30/2017 Intermittent No No 07/28/2017 A204 Heaters/Boilers El Continuous Yes Yes Intermittent No No M. EPA Methods Test (Unit B-0009) . . 7 Navajo complies with A204.K. The initial Requlrement: Comphance CO compliance test was completed on 11/06/2015. BACT Limit and allowable emission limits in Table 106A shall be demonstrated by emissions tests ensuring the unit is operating correctly and within desired ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 87 of 144 EPA Inspection Report - Page 483 of 1969 Version 02.25.15 parameters. (NSR 0195M35, Condition A204.K and revised) Monitoring: The pennittee shall conduct El continuous Yes Yes an EPA Method test no later than 180 days IE Intermittent 0 IE 0 after permit issuance using EPA reference testm?thOdS 1,11 49 CFR Navajo complies with A204.B. The initial Emissmn testing 15 requtred for CO- TeSt compliance test was completed on 11/06/2015. results that demonstrate compliance with the CO emission limits shall also be considered to demonstrate compliance with the VOC emission limits. Recordkeeping: Records of EPA Methods Navajo Complies with A204.B. The initial El Continuous '2 Yes Yes tests shall be maintained for the Boiler. compliance teSt was 00311316th on 11/06/2015 Intermittent No IE No Reporting: The permittee shall report in El Continuous Yes Yes accordance with the requirements of The initial compliance test was completed on Section 1 1D and summarize in tabular Intermittent N0 repor 6 01EDI-12316 results. Of $8 EPA Methods te.St MACT Subpart reports were submitted or speCifying emiss10ns rates in emi?annu ally as follows: pounds per hour. The table shall include 01/30/2017 the average concentration of all relevant 07/23/2017 pollutant species. A204 Heaters/Boilers Continuous Yes Yes N. Veri?cation of Energy Ef?ciency '2 Intermittent No BACT Control Requirements (Unit 0009) Navajo complies with these conditions. The most . . . recent periodic in3pection and tune-up was Requirement. The permitteetshall comply completed on 01/16/2017. With the allowable emissmn limits and the following BACT requirements. (N SR 0195M35, Condition A204.L and revised) 1. Operation and Maintenance (BACT ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 88 of 144 EPA Inspection Report - Page 484 of 1969 Version 02.25.15 2. a. Periodic Boiler Tuning The boiler shall be tuned annually to maintain optimal thermal ef?ciency. b. Periodic Boiler Inspection and Repair for air leakage The boiler shall be inspected annually to maintain optimal thermal ef?ciency. c. Periodic Boiler Inspection and Cleaning for tube fouling The boiler shall be inspected annually and necessary cleaning performed to prevent tube fouling. Next Generation Ultra?low-NOx high ef?ciency burners (NGULNB) shall be installed in the boiler design. Flue gas economizer (BACT A heat exchanger shall be installed to recover heat from the exhaust gas to preheat incoming boiler feedwater to attain industry standard performance (IMO) for thermal ef?ciency. Boiler insulation (BACT The boiler shall be designed and installed with boiler insulation to an optimum insulation thickness and material to achieve maximum energy ef?ciency. The 0MP shall include the insulation ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 89 of 144 EPA Inspection Report - Page 485 of 1969 Version 02.25.15 design and maintenance schedule. 5. Oxygen Trim Control (BACT An Oxygen Trim Control system shall be designed and installed on the boiler to monitor oxygen concentration in the ?ue gas, and the inlet air ?ow is adjusted to maximize thermal ef?ciency. 6. Boiler blowdown minimization using manual analysis (BACT The Operation and Maintenance Plan (OMP) shall include methods and procedures to minimize blowdowns from the boiler to keep emissions at a minimum. 7. Condensate recovery (BACT Condensate shall be recovered as represented in the application to achieve maximum energy ef?ciency. Condensate recovery shall be maximized through annual steam trap inspections and repairs. Monitoring: The Permittee shall develop Continuous Yes Yes an Operation and Maintenance Plan (OMP) to include at least the requirements Intermittent No N0 listed above Within 12 months of Navajo complies with these conditions. The initial commencement of Operations. The compliance test was completed on 11/06/2015. The Permittee shall review the OMP annually 0MP W85 Smei-tted On 04/12/2016- to ensure it?s effectiveness in meeting the requirements above and recommend changes. Recordkeeping: continuous YES YES Nava?o com lies with these conditions. (1) Records demonstrating compliance Intermittent N0 N0 w1th the energy ef?c1ency requrrement ACC Form Part 1 Permit P051 -R2 R2M1 Page 90 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 486 of 1969 Version 02.25.15 shall be recorded and summarized in the 0MP. (2) The Permittee shall maintain a copy of the OMP onsite and available for inspection. Reporting: Continuous Yes Yes (1) The shall notlfy the . . . . El Intermittent El N0 [3 N0 Department when the 0MP has been Navajo complies With these condltions. No prepared and available for review. changes occurred to the 0MP during this reporting (2) The permittee shall report in the semi- period. Reports required by Bl 10 are submitted as annual report a summary of actions apphcabie' covered in accordance with the 0MP, and in accordance with Section B1 10. A204 Heaters/Boilers Continuous Yes Yes 0. Periodic Emissions Tests (Unit 8?009, Intermittent No CO BACT Limit) Navajo complies with these conditions. Requirement: Compliance with the CO BACT Limit and allowable emission limits in Table 106A shall be demonstrated by performing periodic emissions tests. Monitoring: The permittee shall conduct El Continuous Yes Yes periodic portable analyzer emission tests El Intermittent El N0 No or EPA Reference Method Tests for CO at the intervals in the following schedule: ?r in accordance With the Navajo complies with these conditions. Periodic schedule in Section 1 test completed on: Second Test ?-six (6) months after the 10/05/2016 ?rst test is completed. 07/24/2017 All subsequent testing shall be done annually. Section B108 General Monitoring Requirements apply to this condition. ACC Form Part 1 Permit P05 R2M1 Page 91 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 487 of 1969 Version 02.25.15 The permittee shall meet the testing requirements in Section 11. Recordkeeping: Records of periodic emission tests shall include the boiler fuel ?ow rate and the stack gas exhaust temperature. If a combustion analyzer is used to measure CO, Hand/or excess air in the ?ue gas, records shall be kept of the make and model of the instrument and instrument calibration data. If an ORSAT apparatus or other gas absorption analyzer is used, the permittee shall record all calibration results. Records shall be kept of all raw data used to determine ?ue gas ?ow and of all calculations used to determine ?ow rates and emission rates. The permittee shall maintain records in accordance with Section B109, B110, and B111. Data is maintained in Pi. El Continuous IZI Intermittent Reporting: The permittee shall summarize in tabular form the results of the initial or subsequent periodic emissions tests for CO, specifying the mass emissions rates in pounds per hour. The table shall include the average concentration of all relevant pollutant species. The permittee shall report in accordance with Section B109, 13110, and B111. Reports required by B109, B110, and B111 are submitted as applicable. El Continuous Intermittent Yes El No El Yes IZI No ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 92 of 144 EPA Inspection Report - Page 488 of 1969 Version 02.25.15 A206 Flares A. FL-0400, Requirement: (NSR 0195M35, Condition A206.A) (1) An alarm system in good working order shall be connected to Flare FL-0403 which will signal non-combustion of the gas. (2) The acid gas ?ow meter for ?are L- 0400 or shall be operated and calibrated at a frequency and by the procedure speci?ed by the manufacturer. A chart recorder or data logger (electronic. storage) shall continuously record the amount of gas measured by the ?ow meter. 1) FL-0403 is equipped with a ?are alarm. 2) The fuel gas required to provide supplemental heat to either Flare FL-0400 or is monitored during acid gas ?aring by a ?ow meter. No acid gas ?aring has occurred since September 5, 2006. Continuous Intermittent XI Yes No Yes No Monitoring: The fuel gas required to provide supplemental heat to either Flare or FL-0403 as required under A105.B shall be monitored during ?aring by a ?ow meter. The ?ow meter shall be operated continuously 24 hours per day, 365 days per year except for periods of ?ow meter maintenance or repair. The upper range of the ?ow meter shall be suf?cient to record the highest expected ?ow rate of fuel gas sent to ?are. The reading of this ?ow meter and the ?ow meter to measure acid gas ?ow as required under Condition A105.B shall be The fuel gas required to provide supplemental heat to either Flare or is monitored during acid gas ?aring by a ?ow meter. IZI Continuous Intermittent Yes No Yes No ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/20l 5 Page 93 of 144 EPA Inspection Report - Page 489 of 1969 Version 02.25.15 used to determine compliance with emission limits at A106.C. . Recordkeeping: (1) Records of all periods El contlnuous Yes Yes of operation during which the ?are pilot El Intermittent El N0 El N0 ?ame is absent as included in the MACT SUbPart CC semi?annual reports. 1) Flare pilot outages are included in the MACT CC semiannual reports dated as follows: (2) Records of the quantity of 02/28/2017 supplemental fuel used during each acid 08/29/2017 gas ?aring incident to provide 1) and 2) Records of supplemental fuel use and supplemental heat to ?are or ?are ?are PilOt ?ame are maintained in Pi- (3) The permittee shall maintain records from the ?ow meter of the amount of gas sent to the ?are. Flare ilot outa es are included in the MACT . Reporting: The pennittee shall report in semiannual resorts dated as follows: contmuous Yes Yes accordance with Section B110. 02/28/2017 El Intermittent No I:l No 08/29/2017 A206 Flares El Continuous El Yes El Yes B. MACT Subpart CC, ?National El Intermittent El N0 Emission Standards for Hazardous Air from Petmleum Re?neries? Navajo complies with all the requirements of (Flares listed in Table MACT CC as shown for all affected sources in table 103B. Navajo uses a third party LDAR Requirement: The pennittee Shall comply contractor, except for deviations previously With all applicable requirements reported or identi?ed at the end of this report. Subpart CC, ?National Emission Standards for Hazardous Air Pollutants from Petroleum Re?neries? for all affected sources shown in Tables 1033. (63.640). Monitoring: The permittee shall comply Navajo complies with all the requirements of. El Continuous MACT CC as shown for all affected sources in Wlth,the applicable monitorlng and testing table 103B. Navajo uses a third party LDAR Intermittent No No requirements of 40 CFR 63, Subpart CC. contractor. ACC Form Part 1 Permit Page 94 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 490 of 1969 Version 02.25.15 Recordkeeping: The permittee shall Navajo complies with all the requirements of. El Continuous Yes El Yes corn 1 With the a licable recordkee in MACT CC as shown for all affected sources in I.) pp table 103.B. Navajo uses a third party LDAR Intermittent No No requlrements of 40 CFR 63.655. contractor. Reporting: The permittee Shall comply Navajo complies with all the requirements of . Continuous iZl Yes El Yes With the a licablere ortin re uireme ts MACT CC as shown for all affected sources in f40 (31715123 6 5 table 103.B. Navajo uses a third party LDAR IXI Intermittent N0 N0 0 5 contractor. A207 Sulfur Recovery Plant (SPR), Tail Continuous El Yes El Yes Gas Incinerator (TGI) Intermittent No No A. Consent Decree Requirements for SRP and TGI Requirement: In addition to the applicable requirements of NSPS, 40 CFR 60, Subparts and a, the permittee shall accomplish the following: 1. Navajo shall route all Sulfur Recovery Plant (SRP) sulfur pit emissions from the SRP so that sulfur pit emissions to the atmosphere either are eliminated or are included and monitored as part of the applicable Sulfur Recovery Plant's tail gas emissions that meet the NSPS Subpart or Ja limit for 802. (CD 111.8.C.ii) 2. The SRP and TGI (and any supplemental control devices) shall be operated and maintained, to the extent practicable, in accordance with the obligation to minimize SRP emissions through implementation of good air pollution control practices required by 40 CFR at all times, including periods of start-up, shutdown, and malfunction. (CD ?ll 1) Sulfur Recovery Plant (SRP) sulfur pit emissions are routed to the Tail Gas Incinerators and are continuously monitored as part of the applicable Sulfur Recovery Plant?s tail gas emissions that meet the NSPS Subpart limit for $02. 2) The SRP and TGU are operated and maintained, to the extent practicable, in accordance with the obligation to minimize SRP emissions through implementation of good air pollution control practices required by 40 CFR at all times, including periods of start?up, shutdown, and malfunction. ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 95 of 144 EPA Inspection Report - Page 491 of 1969 Version 02.25.15 (NSR 0195M35, Condition A207.A) Monltorlng: The shall comp 1y All of the continuous monitors are operated, IE continuous Yes Yes the monltorlng maintained and certi?ed as re uired - 7 requirements of NSPS Subpart or a. 7 2 Imerm?ttent N0 N0 Recordkeeping: The permittee shall Continuous Yes Yes maintain records in accordance with the Records are maintained by Navajo Environmental applicable requirements of NSPS Subparts Department and 011 Pi. E1 Intermittent No and a. Reporting: The permittee shall report in Navajo submitted NSPS Subparts and Ja reports El Continuous Yes El Yes accordance with the applicable semlannuauy as fellows: 1/30/2017 IE Intermittent No 12 N0 requirements of NSPS Subparts and Ja. 7/28/2017 A207 Sulfur Recovery Plant (SPR), Tail Continuous Yes El Yes Gas Incinerator (TGI) Intermittent N0 No B. The following BACT 802 work practices and equipment shall apply to the SRP 0195-M25) Maintain at least 98% SRP on- stream operations. This includes curtailing re?nery operations as necessary When SRU capacny IS Navajo has installed BACT, and implemented the limited during planned startup, work practices, as described in this permit shutdown, and maintenance condition, events. Maintain adequate SRP excess capacity to reduce the frequency and quantity of re?nery excess 802 emissions. After the re?nery expansion project proposed units are constructed, the proposed SRU3 will provide at least 25% excess capacity. Continue to maintain and use a ACC Form Part 1 Permit P05 l?R2 Page 96 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 492 of 1969 Version 02.25.15 (C) sulfur shedding plan to prevent or reduce acid gas ?aring events from re?nery upsets. An acid gas ?aring event is de?ned as excess $02 emissions greater than 500 pounds in a 24-hour period. The plan shall state speci?c actions that may be taken to reduce or prevent acid gas ?aring. The actions taken during any event will be based on the re?nery operators? discretion, considering safety and other factors related to prudent operation. This plan is subject to review by NMED or EPA, and shall be amended upon written request by NMED or EPA. The sulfur shedding plan may include, but is not limited to the following options: Store sour water to reduce acid gas generation from the sour water strippers Reduce the operating rate of one or more amine strippers to lower the acid gas generation rate Reduce one or more hydrotreating unit throughput rates to lower acid gas generation rate Use hydrogen, when available, as ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 97 of 144 EPA Inspection Report - Page 493 of 1969 Version 02.25.15 SRU fuel during startup and hot standby to minimize carbon deposits on the SRU During startup and shutdown and to the extent practicable, process vessels shall be depressurized into other process equipment rather than venting to a ?are. The permittee shall document instances when this is not practicable. A207 Sulfur Recovery Plant (SPR), Tail Gas Incinerator (TGI) C. SRU2, and SRU3 Requirement: (NSR 01 95M35, Condition A207.C and revised) The permittee shall demonstrate compliance with the H28, 802, lb/hr, tpy emission limits by completing the following requirements, monitoring, recordkeeping and reporting: A flow meter shall be installed, operated, calibrated, and maintained on the sour water stripper streams that go to the SRUs. (2) An CEMS and ?ow meter shall be installed on the and SRU3 incinerator stacks. In addition, these units shall be equipped with instruments to measure and record sulfur concentration l) A flow meter is in place on the sour water stripper streams into Units SRUZ, and SRU3. 2) The 802 CEMS and flow meter on the and SRU3 incinerator stacks, and the instruments used to measure sulfur concentration and flow rates of the gas streams into SRU2, and SRU3, are calibrated and maintained at a frequency and method speci?ed by the manufacturer, or as dictated by operating conditions. The $02 CEMS follow the quality assurance and quality control procedures in 40 CFR 60 Subpart and Appendix F. 3) The minimum acceptable level of data capture for all instruments measuring ?ow and concentration of sulfur streams into the SRU2, and SRU3 including the CEMS and flow meters on the incinerator stacks shall be at least 90% for each month. The 10% lost data includes periods when the concentration and corresponding flow are not being measured. as a result of calibrations or breakdowns. The data capture is reported in the semi-annual NSPS Subparts and Ja reports. Continuous Intermittent El Yes No Yes IZI N0 ACC Form Part 1 Permit P051-R2 Ver 4.102/25/2015 Page 98 of 144 EPA Inspection Report - Page 494 of 1969 Version 02.25.15 and ?ow rates of the gas streams into SRU2, and SRU3. The CEMS, ?ow meters, and data loggers shall be calibrated and maintained. In addition, the calibration of the $02 CEMS shall follow the quality assurance and quality control procedures in 40 CFR 60 Subpart or a and Appendix F. (3) The minimum acceptable level of data capture for all instruments measuring ?ow of sulfur streams into the SRU2, and SRU3, as well as the GEMS and ?ow meters on the incinerator stacks, shall be at least 90% for each semi-annual period. The 10% lost data will include all periods when the concentration and corresponding ?ow are not being measured as a result of calibrations or breakdowns. Monitoring: The gas stream feeding El Continuous Yes Yes SRUZ, and SRU3 from the amine XI Intermittent El N0 No regeneration units and the sour water stripper Shall be tested at least for H28 concentration. The pennittee shall monitor the following: 1), 2), and 3) Navajo complies with the requirements of this permit condition. (1) Flow rate of sour water stream to SRUs, (2) concentration in SRU incinerator stacks and (3) Flow rate of the SRU incinerator stacks. ACC Form Part 1 Permit P051-R2 Page 99 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 495 of 1969 Version 0225.15 IZI Cont'nuous IX, Yes Yes Recordkeeping: The pennittee shall I maintain records in accordance with the El Intermittent NO No applicable requirements Subparts or a and MACT Subpart The pennittee shall also keep records of the following; I), 2), and 3) Records are maintained by Navajo Environmental Department and on Pi. (1) Flow rate of sour water stream to SRUS, (2) SOZ concentration in SRU incinerator stacks and (3) Flow rate of the SRU incinerator stacks. . Reporting: The permittee Shall report in Navajo submitted NSPS Subparts la and MACT [3 Continuous Yes Yes accordance with the applicable Subpart reports semiannually as follows: requirements of NSPS Subparts or Ja, 1/30/2017 Intermittent No No MACT Subpart and Section B110. 7/28/2017 A207 Sulfur Recovery Plant (SPR), Tail El Continuous Yes El Yes Gas Incinerator (TGI) El Intermittent No 0 3; (14:31:53; 60? Subpart (Unlt(s) SRUI Favajo complies with the requirements of Subpart Requirement: The permittee shall comply with the applicable requirements of 40 CFR 60, Subpart J. Monitoring: The permittee shall install a IE Continuous Yes El Yes continuous monitoring device to monitor 3 and SRUZ TGI has a CMS installed. compliance with the H28 limit. (40 CPR Intermittent No El N0 Recordkeeping: The permittee shall Records are maintained by Navajo Environmental El continuous Yes Yes maintain the continuous emission records. D6partment and on Pi. Intermittent No No ACC Form Part 1 Permit Page 100 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 496 of 1969 Version 02.25.15 Reporting: The permittee shall comply New?? SUb?mttecfl KEEPS. Subpart reports Continuous Yes Yes with the reporting requirements of 40 CFR 86212110123137] as lZi Intermittent El N0 No 60, Subpart J. 7/28/2017 As of May 1, 2016, Navajo has elected to com 1y . A209 with 60.592a(e) of NSPS Subpart for commons Yes Yes process units affected by NSPS Subpart IE Intermittent No No A- NSPS Subpart Standards 0f regardless of whether or not those process units Performance for Equipment Leaks have triggered NSPS Subpart applicability. in Petroleum Re?neries for which Fugitive components subject to this rule are reconstruction, or included in the Leak Detection and Repair (LDAR) modi?cation commenced after January 4) program. Navajo uses a third-party contractor for 19833 and on or before November 7, 2006 the LDAE minttOtingdatjd rigglgesep?nnge?Eare - - - monitore an reporte 1n a 11 part a subject 1n Table 103B) semiannual report As of May 1, 2016, Navajo has elected to comply El Continuous IE Yes El Yes Requirement: The permittee shall comply With 60-5923(e) Sprart for 311 with all applicable requirements process units affected by NSPS Subpart Intermittent No IE No Subpart for all sources in Table regardless of whether or not those process units 103.13 (affected units and voluntarily have? tnggered NSPS apphcat?lhty' . . . Fugltive components subject to this rule are units). table also Includes areas that included in the Leak Detection and Repair (LDAR) are VOtuntar?y $thng the NSPS program. Navajo uses a third?party contractor for Subpart monltorlng requirements. the LDAR monitoring and recordkeeping.These are (See 1 t0 Table 103-3) monitored and reported in a NSPS Subpart semiannual report 221313313266 Shrtiidriittgitipri: Navajo uses a third-party contractor for the LDAR El continuous Yes Yes monitoring and recordkeeping. . requ1rements of 40 CFR 60, Subpart '3 Interm?ttent N0 '3 a requirements of 40 CFR 60, Subpart momtm mg and record caplng' IE Intermittent No El No Reporting: The permittee shall comply Navajo submitted NSPS. Subpart reports El Continuous IE Yes El Yes with the applicable reporting requirements Regen/3311137; as follows. IE Intermittent No IE No of 40 CFR 60, Subpart 8/29/2017 . . Navajo continues to comply with the applicable . A209 requirements of NSPS Subpart as contlnuous IE Yes Yes applicable, except for the deviations noted in ACC Form Part 1. Permit Ver 4.1 02/25/2015 Page 101 of 144 EPA Inspection Report - Page 497 of 1969 Version 02.25.15 B, NSPS Subpart Standards of semiannual reports. Fugitive components subject to El Intermittent El No IE No Perfomance for Equipment Leaks either Of these mleS are inClUded in the Leak in Petroleum Re?neries for which Detection and Repair (LDAR) program. Navajo Construction Reconstruction 01, uses a third?party contractor for the LDAR Modi?cation Commenced After monitoring and recordkeeping. November 7, 2006 (Fugitives subject in Table 1033! 1 Requirement: The permittee shall comply with all applicable requirements of NSPS Subpart for all sources in Table 103B (affected units and voluntarily units). This table also includes areas that are voluntarily following the NSPS Subpart monitoring requirements. Monitoring: The permittee shall comply El Continuous Yes Cl Yes with all applicable monitoring Navajo uses a thirdnparty contractor for the LDAR requirements of 40 CFR 60, Subpart monitoring and recordkeeping. Intermittent N0 El N0 Recordkeeping: The permittee shall El Continuous Yes El Yes comply with all applicable recordkeeping Navajo uses a third-party contractor for the LDAR requirements of 40 CFR 60, Subpart monitoring and recordkeeping. Intermittent No El N0 Reporting: The pennittee shall comply Nav?jo sut?mtte? ESPS Sprart reports El Continuous Yes Yes . . . . semiannua as ows: With the applicable 1eport1ng requlrements 2/28/2017 IE Intermittent N0 IE N0 A209 Fugitives Continuous IXI Yes El Yes C. MACT Subpart CC, ?National Intermittent Cl N0 N0 Emission Standards for Hazardous Air . . . . Pollutants from Petroleum Re?neries? The Gasoline Loading Rack is equipped With a (Fugitives subject in Table 103.B) carbon adsorption SyStem' Requirement: The permittee shall comply with all applicable requirements ACC Form Part 1 Permit P051-1U R2M1 Ver 4.1 02/25/2015 Page 102 of 144 EPA Inspection Report - Page 498 of 1969 Version 02.25.15 Subpart CC, ?National Emission Standards for Hazardous Air Pollutants from Petroleum Re?neries? for all affected sources shown in Tables 103.B. (63.640). For all activities in Table 103.B that are not subject to MACT CC, the permittee voluntarily performs a LDAR program for those units and that program meets the requirements of MACT CC. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. The Gasoline Loading Rack carbon absorption has a VOC CEMS installed in the exhaust air stream. Continuous El Intermittent Yes El No Yes No Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63.655 . Records are kept by Holly Energy Partners (HEP) either at the Gasoline Loading Rack or at the HEP Artesia Of?ce. Continuous Intermittent Yes No Yes IZI No Reporting: The permittee shall comply with the applicable reporting requirements of40 CFR 63.655. Navajo submitted NSPS Subpart reports semiannually as follows: 2/28/20] 7 8/29/2017 El Continuous Intermittent Yes El No Yes No A209 Fugitives D. NSPS Subpart Standards of Performance for VOC Emissions from Petroleum Re?nery Wastewater Systems (Fugitives subject in Table 103B) Requirement The permittee shall comply with all applicable requirements of NSPS, 40 CFR Part 60.690, Subpart Navajo continues to comply with the applicable requirements of NSPS Subparts throughout the re?nery, except for deviations noted in semiannual reports. Oily water sewer drain hubs are inspected at least Junction boxes, and the oil-water separator are inspected at least semi? . annually. El Continuous Intermittent Yes No Yes El No Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart (60.695) Navajo continues to comply with the applicable requirements of NSPS Subparts throughout the re?nery, except for deviations noted in semiannual reports. Oily water sewer drain hubs are inspected at least Junction boxes, and the oil?water separator are inspected at least semi- annually. Continuous Intermittent Yes IZI N0 IZI Yes No ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 103 of 144 EPA Inspection Report - Page 499 of 1969 Version 02.25.15 Recordkeeping: The permittee Records are maintained by Navajo Environmental Continuous Yes g] Yes comply With the applicable recordkeeping Department, except for deviations noted in requirements of 40 CFR 60.696. semiannual reports. Intermittent N0 Cl N0 Reporting: The permittee shall comply New?? submitted NSPS Subpart reports Continuous Yes Yes with the applicable reporting re uirernents semiannually as ?1 1/30/2017 Intermittent N0 N0 of40 CFR 60.697. 7/28/2017 ACC Form Part 1 Permit P051-R2 Ver 4.102/25/2015 Page 104 of 144 EPA Inspection Report - Page 500 of 1969 Version 02.25.15 A209 Fugitives I: Continuous Yes El Yes E. Minor changes within the facility to Intermittent piping and components that affect fugitive Navajo understands that minor changes to the VOC emission source shall be updated and facility piping and components that affect fugitive added during the next available Signi?cant emissions Will be added during the next permit permit revision in accordance with 20.2.72 1T10dt?catt0n- NMAC. The facility wide ?igitive VOC emission limit shown above and in Table 106A of this permit. A210 Loading Racks Continuous Yes El Yes A. Truck and Rail Loading (Unit shown in Intermittent N0 N0 Table 106.G) Requirement: Compliance with the Navajo complies with these requirements. allowable emission limits in Table 1066 shall be demonstrated by not exceeding the rolling 12?month total throughput for each loading rack for each different product in gallons per year (barrels/year). Monitoring: The permittee shall monitor The Truck Rail Loading Racks volumes are Continuous Yes Yes the throughput volumes on a maintained by Navajo?s Accounting and basis. Environmental Departments. Intermittent N0 N0 - Recordkeeping: The permittee shall continuous Yes Yes record the throughput volume for El Intermittent El NO No each loading rack for each different product. Each month during the 12 The Truck Rail Loading Racks volumes are months of monitoring the permittee shall maintained by Navajo's Accounting and record the cumulative condensate loadout Environmental Departments. volume and after the ?rst 12 months of monitoring, the permittee shall calculate and record a rolling 12-month total loadout volume. ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 105 of 144 EPA Inspection Report - Page 501 of 1969 Version 02.25.15 Records shall also be maintained in accordance with Section 3109. Reporting: The permittee shall report in accordance with Section B110. Navajo submitted MACT Subpart CC reports semiannually as follows: 2/28/2017 8/29/2017 Continuous Intermittent Yes No Yes No A210 Loading Racks B. Fuel Truck Loading Rack (Units subject in Table 103D) (40 CFR 63, Subpart CC) Requirement: The permittee shall comply with all applicable requirements of MACT Subpart CC, National Emission Standards for Hazardous Air Pollutants From Petroleum Re?neries. Specially, the truck loading rack shall be equipped with a carbon adsorption system for compliance with the MACT requirements. The Truck Loading Rack has a carbon absorption system installed. Continuous Intermittent Yes El No El Yes No Monitoring: The permittee shall. comply With the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. Speci?cally Where a carbon adsorption system is used, a continuous emission monitoring system (CEMS) capable of measuring organic compound concentration shall be installed in the exhaust air stream. The Truck Loading Rack has a CEMS installed. Continuous I: Intermittent EYesl Yes No Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63, Subpart CC. Records are kept by Holly Energy Partners (HEP) either at the Gasoline Loading Rack or at the HEP Artesia. Of?ce. Continuous El Intermittent Yes No Yes No Reporting: The permittee shall comply with the applicable reporting requirements of40 CFR 63, Subpart CC. Navajo submitted MACT Subpart CC reports semiannually as follows: 2/28/2017 8/29/2017 El Continuous Intermittent Yes El No El Yes No ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 106 of 144 EPA Inspection Report - Page 502 of 1969 Version 02.25.15 A211 Fluid Catalytic Cracking Unit (FCC) A. Continuous Monitor Syste1n(CMS) (Unit FCC REGEN) Requirement: (1) Consent Decree Limits on PM and SO2 emissions from the FCC: By no later than December 31, 2003, the Wet Gas Scrubber (WGS) on the FCC Regenerator shall comply with the following limits: (CD 1112B 1113B) 802 concentration not to exceed 25 on a daily rolling 365? day average basis and 50 on a daily rolling 7?day average basis, each corrected to 0% oxygen. Compliance with this emissions limit shall be demonstrated on an ongoing basis through the use of and a particulate matter (PM) emission limit of 1.0 pound of PM per 1000 pounds of coke burned on a 3-hour average basis (CD 1113B). To demonstrate compliance with this requirement, the Permittee shall conduct an annual EPA Method 5 Test for PM and weekly EPA Method 9, Opacity Test in accordance with their approved 1d) The FCC catalyst regenerator exhaust is continously monitored for $02. 1e) The catalytic cracking regenerator is tested annually for PM and was tested on the following date: 01/04/2017 If) Navajo has submitted an alternative monitoring plan (AMP) to comply with the FCC opacity monitoring requirement because the FCCU has a wet scrubber which prevents continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CFR 60 Appendix A Method 9. 2) The FCC exhaust is continously monitored for and CO. Deviations were reported to the Department as excess emission events and on the NSPS Subpart I report. Continuous Intermittent Yes 1:1 No Yes No ACC Form Part 1 Permit Ver4.102/25/2015 Page 107 ofl44 EPA Inspection Report - Page 503 of 1969 Version 02.25.15 Alternative Monitoring Plan (AMP). As the FCC Regenerator is subject to the provisions of 40 CFR 60.102 (NSPS Subpart J), it shall not discharge to the atmosphere gases exhibiting greater than 30 percent opacity, except for one six?minute average opacity reading in any one?hour period. (2) Consent Decree Limits on and CO emissions from the FCC: The FCC shall comply with and CO emission limits as follows: The concentration?based emission limit based on daily rolling 7~day and daily rolling 365?day averages, corrected to 0% oxygen as established pursuant to the Consent Decree, unless EPA rejects the proposed limit and establishes a different emission limit, in which case the FCC shall comply with established limit. Under no circumstances shall this emission limit be greater than a concentration?based limit that would be equivalent to 34.9 lbs/hr. The 7-day FCC emission limits, shall not apply during periods of Hydrotreater Outage provided that the FCC ACC Form Part 1 Permit P051-R2 Page 108 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 504 of 1969 Version 02.25.15 (including associated air pollution control equipment) is maintained and operated in a manner that minimizes emissions in accordance with an approved good air pollution control practices plan. Navajo shall comply with the plan at all times, including periods of startup, shutdown, and malfunction of the hydrotreater. The daily rolling 365-day average NOX emissions limit shall apply during periods of hydrotreater outages. The NOX limits are: (1) 87.3 NOX, corrected to 0% 02 on a daily rolling 7?day average, and (2) 58.1 NOX, corrected to 0% 02 on a daily rolling 365-day average The Subpart emission limit of 500 CO corrected to 0% 02 on a 1?hour average basis and 100 CO corrected to 0% 02 on a daily rolling 365-day average basis, by no later than December 31, 2003. Mlonitoring' 1) The FCCU Catalyst Regenerator Scrubber Continuous Yes Yes exhaust is continuously monitored for CO, 02, (1) A continuous monitor system (CMS) 802, and PM is monitored annually. Intermittent El N0 No for CO, 02, and NOX shall be installed, calibratedj {maintained? and 2) The FCC regenerator CMS were recerti?ed on ACC Form Part 1 Permit R2M1 Page 109 of144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 505 of 1969 Version 02.25.15 operated on the FCC Catalyst Regenerator vent stack(s) of the scrubber in accordance with 40 CFR Part 60, ?60.13, Appendix A, and the applicable performance specifications of Appendices (Specifications 2 and 3) and F. The CMS shall be used to demonstrate compliance with CO, and NOX emissions limits and to report compliance with the terms and conditions of the Consent Decree. The CMS and process data shall be made available, by permittee, to applicable Federal and State Agencies (NMED) upon demand as soon as practicable. (CD ?ll 1F, 12 D, and 14C) (2) The FCC Regenerator Scrubber NOX, 802, CO and 02 CMS shall be recertified annually. (3) The CMS data shall be monitored to ensure the CO, and emission limits for the FCC are met. (4) The Permittee shall conduct an annual EPA Method 5 Test for PM and weekly EPA Method 9 Opacity test to demonstrate compliance with the pa1ticulate matter (PM) emission limit of 1.0 pound of PM per 1000 pounds of coke burned on a 3?hour average basis and opacity limit of 30%. Permittee shall meet testing requirements of 1 1. the following dates: CO 01/03/2017 01/04/2017 802 01/03/2017 01/04/2017 NOX 01/03/2017 01/04/2017 02 01/03/2017 01/04/2017 3) CMS data is used to ensure emissions limits are met. 4) The catalytic cracking regenerator is tested annually for PM and was tested on the following date: 0 1 04/ 201 7 Navajo has submitted an alternative monitoring plan (AMP) to comply with the FCC opacity monitoring requirement because the FCCU has a wet scrubber which prevents continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CFR 60 Appendix A Method 9. ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1. 02/25/2015 Page 110 of 1.44 EPA Inspection Report - Page 506 of 1969 Version 02.25.15 Recordkeeping: The permittee shall maintain the records of: (1) The certi?cation and re?certiflcation of the CMS. (2) Modi?cations to the good air pollution control practice plan to minimize NOX emissions shall be summarized on an annual basis if any changes were made. CD 1111(3) (3) The permittee shall keep records of CMS data monitoring N02, 802, PM10 and CO emissions from the FCC. (CD ?ll l.F, CD 102D CD 1114C) (4) Records of NOX, CO, 802 lb/hr, tpy; PM lb/hr, tpy and opacity. TPY shall be based on a rolling 12- month total. (5) The permittee shall keep records of annual PM stack tests and weekly Method 9 observations conducted on the FCC. For any opacity observations conducted in accordance with the requirements of EPA Method 9, record the information on the form referenced in EPA Method 9, Sections 2.2 and 2.4. 2), 3), 4), and 5) Records are maintained by Navajo Environmental Department and on Pi. Continuous El Intermittent Reporting: The permittee shall report in accordance with Section B110 and testing requirements of Bl 1 1. Navajo submitted NSPS Subparts and Ja reports semiannually as follows: 1/30/2017 7/28/2017 Continuous Intermittent Yes El No El Yes No ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 111. of144 EPA Inspection Report - Page 507 of 1969 Version 02.25.15 A211 Fluid Catalytic Cracking Unit DContinuous DYes (FCC) IE Intermittent No IE No B. Performance Testing (Unit FCC REGEN) Requirements: (1) The permittee shall demonstrate compliance with the SPS Subpart particulate matter emission limit at Table Navajo complies With the 0f NSPS 1.06.A by conducting an initial Subpart J, Ja, MACT Subpart A, and performance test in accordance with NSPS Subpart A, ?60.8 and NSPS Subpart J, The particulate matter stack test shall be repeated on an annual basis. (2) The permittee shall comply with all applicable performance testing requirements in accordance with MACT Subparts A and Monitoring: Testing shall be conducted in :1 Continuous IZI Yes Yes accordance with NSPS Subparts A and J, Navajo complies with the requirements of NSPS and in accordance with MACT Subparts A Subpart J, Ja, MACT Subpart A, and IXI Intermittent N0 El N0 and Recordkeeping: The permittee shall :1 Continuous Yes Yes maintain performance test records in accordance with NSPS Subparts A and J, MACT Subparts A and and in accordance with Section B109. Navajo complies with the requirements of NSPS X1 Intermittent No IE No Subpart J, Ja, MACT Subpart A, and Reporting: The permittee shall report Continuous Yes Yes performance test results in accordance Navajo complies with the requirements of NSPS with NSPS Subparts A and MACT Subpart J, Ja, MACT Subpart A, and I-Iltel?mlttent 1:1 N0 No Subparts A and and in accordance ACC Form Part 1 Permit R2M1 Page 112 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 508 of 1969 Version 02.25.15 with Section B1 10. A212 Towers El Continuous IE Yes Yes A. MACT Subpart CC, ?National Intermittent N0 N0 Emission Standards for Hazardous Air Pollutants from Petroleum Re?neries? . (Cooling Towers subject in Table 1031:) Navajo complles w1th the applicable requirements for heat exchange systems, except for dev1ations 1 re ortd 'd t'fd fth' Requirement: The permittee shall comply 56:3with all applicable requirements of 40 CFR 63, Subpart CC for heat exchange systems for all affected sources shown in Table 103.F attached. 63 MOHitOI?ngt The permittee shall comply Navajo complies with the applicable requirements Continuous Yes Yes - all monltOI?ing and testing for heat exchange systems, except for deviations requirements of 40 CFR 63, Subpart CC, previously reported or identified at the end of this El Intermittent N0 Kl N0 (63-65403), (01 report Recordkee in The ermittee shall - . . . Records are maintained by the onsite LDAR '1 Continuous El Yes Yes comply all recordkeepmg contractor and the NAva'o Environmental - requirements of 40 CFR 63, Subpart CC. Department El N0 El N0 Reporting: The permittee shall comply Navajo submitted MACT Subpart CC reports I: Continuous El Yes El Yes with all applicable reporting requirements semiannually as follows: of 40 CFR 63, Subpart CC. 2/28/2017 Intermittent N0 NO (00104), 8/29/2017 by l) Navajo operates with less than six (6) El Continuous Yes Yes A212 Coollng Towers recirculating pumps per heat exhange system. 1 . IZI Intermittent No IE No 3- Cooling Tower Operatlons (Coollng 2) The pump capacity is less than 65,500 Towers subject in Table 103.F) 3) The Total Dissolved Solids (TDS) is sampled by Requirement; Compliance with the the Navajo Lab and results maintained in the allowable emission limits in Table 106.H system and maintained by the Navajo shall be demonstrated by meeting the Env1ronmental Department. fouOWlng reqmrementS: 4) Drift eliminators installed are rated by the ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 113 of 144 EPA Inspection Report - Page 509 of 1969 Version 02.25.15 manufacturer for 0.001% or 0.003 drift. I) operate a maximum. of six (6) recirculating pumps at any one 5) Drift eliminators are inspected on an annual time; basis. 2) ensure that each pump capacity shown in Table 104A are not exceeded gallons per minute for each cooling tower (65,500 total maximum rate for 6 pumps); 3) limit the Total Dissolved Solids (TDS) content for the cooling tower recirculating water system to 3500 ppmw, based on a rolling 12-month annual average; 4) ensure that the drift eliminator are rated by the manufacturer at 0.001% or 0.003 drift or less as shown in Table and 5) ensure that the drift eliminator is present and in good working order. The permittee shall measure the Total Dissolved Solids (TDS) content of the recirculating water through direct laboratory analysis, or may use a conductivity meter on the recirculating water system for the cooling tower. The correlation between conductivity of the water and the TDS content shall be taken as 0.9 conductivity (umhos/cm) TDS (ppmw) unless a new correlation is determined through laboratory analysis and submitted to the Permit Program Manager ACC Form Part 1 Permit R2M1 Page 114 of 144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 510 of 1969 Version 02.25.15 for approval. Monitoring: The permittee shall: 1) Monitor the recirculating water TDS content by direct laboratory analysis of the TDS or through use of conductivity meter values and. correlated TDS on a basis; and a. Any correlation other than above shall be developed by the pennittee by independent laboratory measurement of at least 10 water samples with approximately evenly spaced measured TDS values that bracket the minimum and maximum values expected. The highest laboratory TDS sample used for the correlation shall be greater than the maximum allowable TDS of 3500 ppmw. 2) Perform an annual inspection of the drift eliminator and perform any maintenance necessary to ensure the device operates according to the manufacturer?s speci?cations. the 0.9 value described. 1) The Total Dissolved Solids (TDS) is sampled by the Navajo Lab and results maintained in the system and maintained by the Navajo Environmental Department. 2) Drift eliminators are inspected on an annual basis. 3) The Cooling Towers are monitored for VOC breakthrough via the El Paso Method described in Appendix P. El Continuous Intermittent Yes No El Yes No ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 115 of144 EPA Inspection Report - Page 511 of 1969 Version 02.25.15 3) The permittee shall monitor the cooling water inlet and outlet streams for hydrocarbons on an annual basis using either EPA Method 8015 With a large enough sample to achieve accurate quanti?cation of hydrocarbon content, EPA Method 8260, EPA Method 8270 or a similar method as approved by the Department prior to testing. 1) 2) 3) 4) Recordkeeping: The permittee shall maintain the following records: Manufacturer? 8 speci?cations demonstrating maximum capacities of the recirculating water pumps and the manufacturer?s speci?cation for the drift eliminator specified drift rate; TDS and rolling 12-month average; If a conductivity meter is installed, a record of the correlation between conductivity and TDS, any laboratory analyses used to determine the correlation, and all related calculations; Annual drift eliminator inspection and any records of maintenance performed. 1) Records maintained by the Navajo Inspections Department. 2) Records maintained by the Navajo Environmental Department. 3) Records maintained by the Navajo Lab. 4) Records maintained by the Navajo Inspections Department. El Continuous El Intermittent El Yes El No Yes No ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 116 of 144 EPA Inspection Report - Page 512 of 1969 Version 02.25.15 The permittee shall maintain records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section Bl 10. Navajo submitted MACT Subpart CC reports semiannually as follows: 2/28/2017 8/29/2017 El Continuous Intermittent Yes No Yes No A213 Wastewater Systems A. NSPS Subpart Standards of Performance for VOC Emissions from Petroleum Re?nery Wastewater Systems (Unit MAIN API) Requirement: Beginning December 31, 2003, all remaining and newly installed individual drain systems, oil-water separators, and aggregate facilities not previously speci?ed shall be affected facilities, as the term is used in the NSPS, 40 CFR Part 60, Subpart and shall be subject to and comply with the applicable requirements of 40 CFR Part 60, Subpart (CD 1129) The permittee shall comply with all applicable requirements of NSPS Subpart for the affected sources in Tables 103B, C, G. (60.690) Navajo continues to comply with the applicable requirements of NSPS Subparts throughout the refinery, except for deviations noted in semiannual reports. Oily water sewer drain hubs are inspected at least Junction boxes, and the oilwwater separator are inspected at least semi? annually. Continuous IE Intermittent El Yes No Yes No Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CF 60, Subpart (60.695 and 60.696) Navajo continues to comply with the applicable requirements of NSPS Subparts throughout the refinery, except for deviations noted in semiannual reports. Oily water sewer drain hubs are inspected at least Junction boxes, and the oil?water separator are inspected at least semi? annually. Continuous Intermittent .No Yes No Recordkeeping: The permittee shall comply with the applicable recordkeeping Records are maintained by Navajo Environmental Department. Continuous Yes Yes ACC Form Part 1 Permit P05 Ver 4.1 02/25/2015 Page 117 ofl44 EPA Inspection Report - Page 513 of 1969 Version 02.25.15 requirements of 40 CFR 60.697. IZI Intermittent El N0 IE No Reporting: The permittee shall comply New?? submitwd NSPS Sprart reports El Continuous Yes Yes . . . . semlannually as follows: W1th the reportmg requ1rements 1 [30/2017 IZI Intermittent El No No of40 CFR 60.698. 7/28/2017 A213 Wastewater Systems Contt11110118 Yes Yes B. MACT Subpart CC, ?National Intermittent Emission Standards for Hazardous Air Pollutants from Petroleum Refineries? Navajo complies with the requirements of MACT Requirement: The permittee Shall comply CC, except for deviations noted in semiannual with all applicable requirements of MACT reports- Subpart CC, ?National Emission Standards for Hazardous Air Pollutants from Petroleum Re?neries? for all affected sources shown in Tables 103.13, C, attached. (63.640). The shall comply Navajo complies with the requirements of MACT Continuous Yes Yes With the applicable monltoring and testm CC requirements of 40 CFR 63, Subpart CC. '21 Interm?ttent Recordkeeplng: The shall Records are maintained by Navajo Environmental Continuous '2 Yes Yes comply With the applicable recordkeepm De artmen . requirements of 40 CFR 63.655. IZI No Reporting: The permittee shall comply Navajo submitted MACT Subpart CC reports El Continuous Yes El Yes . . . . semiannually as follows: With the applicable reporting requlrements 2/28/2017 Intermittent No N0 of 40 CFR 63.655. 8/29/2017 A213 Wastewater Systems El Continuous Yes Yes C. Wastewater Treatment System (Units Intermittent Shown in Table 106.1) Navajo complies with this requirement, except for deviations noted in semiannual reports. Requirement: Compliance with the emission limits in Table 106.1 shall be demonstrated by properly maintaining and ACC Form Part 1 Permit P051-R2 Ver 02/25/2015 Page 118 of 144 EPA Inspection Report - Page 514 of 1969 Version 02.25.15 repairing the units, and running the Wastewater Model annually to calculate the maximum VOC emissions generated. ACC Form Part 1 Permit P051-R2 R2M1 Page 119 of144 Ver 4.1 02/25/2015 EPA Inspection Report - Page 515 of 1969 Version 02.25.15 Monitoring: (1) Maintenance and repair shall meet the minimum manufacturer?s or permittee?s recommended maintenance schedule. Activities that involve maintenance, adjustment, replacement, or repair of functional components with the potential to affect the operation of an emission unit shall be documented as they occur for the following events: Routine maintenance that takes a unit out of service for more than two hours during any twenty-four hour period. Unscheduled repairs that require a unit to be taken out of service for more than two hours in any twenty? four hour period. (2) The permittee shall annually run the Waste-Water Model to determine the hourly and annual emission rates, based on Toxchem V4 Input Parameters. 1) Navajo complies with this requirement, except for deviations noted in semiannual reports. 2) Navajo uses EPA's Water 9 waste?water model. I: Continuous IE Intermittent Yes IE No IE Yes El No Recordkeeping: (1) The permittee shall maintain records in accordance with Section B109, including records of maintenance and repairs activities and a copy of the manufacturer? or permittee?s recommended maintenance schedule. (2) The permittee shall maintain records of the Toxchem V4 Input Parameters and the emission calculation results compared to permit limits. 1) Navajo complies with this requirement, except for deviations noted in semiannual reports. 2) Navajo uses Water 9 waste-water model. El Continuous IE Intermittent El Yes No Yes I: No ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 120 of 144 EPA Inspection Report - Page 516 of 1969 Version 02.25.15 Reporting: The pennittee shall report in accordance with Section B1 10. Navajo complies with the requirement of section 1 1 O. Continuous Intermittent XI Yes No Yes N0 ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 121 of 144 EPA Inspection Report - Page 517 of 1969 PART 1 General Conditions 1. Have these General Conditions been met during this reporting period? 2. Was this facility in 3. Does compliance with this not apply If the section Heading is marked as no remarks are required. requirement during Check only one box per subiect heading the period? Explain answers in remarks row under subject heading. Yes No B100 Introduction Explain Explain Explain A Below Below Below REMARKS: B101. Legal Yes El No Explain Explain Explain Below Below Below A. Permit Terms and Conditions (20.2.70 sections 7, 201.B, 300, 301B, 302, 405 NMAC) (1) The permittee shall abide by all terms and conditions of this permit, except as allowed under Section 5 02(b)(10) of the Federal Act, and 20.2.70.302.H.l NMAC. Any permit noncompliance is grounds for enforcement action, and signi?cant or repetitious noncompliance may result in termination of this permit. Additionally, noncompliance with federally enforceable conditions of this permit constitutes a violation of the Federal Act. (20.2.70.302.A.2.a NMAC) (2) Emissions trading within a facility (20.2.70.3i02.H.2 NMAC) The Department shall, if an applicant requests it, issue permits that contain terms and conditions allowing for the trading of emissions increases and decreases in the permitted facility solely for the purpose of complying with a federally enforceable emissions cap that is established in the permit in addition to any applicable requirements. Such terms and conditions shall include all terms and conditions required under 202.70.302 NMAC to determine compliance. If applicable requirements apply to the requested emissions trading, permit conditions shall be issued only to the extent that the applicable requirements provide for trading such increases and decreases without a case?by?case approval. The applicant shall include in the application proposed replicable procedures and permit terms that ensure the emissions trades are quanti?able and enforceable. The Department shall not include in the emissions trading provisions any emissions units for which emissions are not quanti?able or for which there are no replicable procedures to enforce the emissions trades. The permit shall require compliance with all applicable requirements. (3) It shall not be a defense for the permittee in an enforcement action to claim that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. (20.2.70.302.A.2.b NMAC) (4) If the Department determines that cause exists to modify, reopen and revise, revoke and reissue, or terminate this ACC Form Part 1 B, Deviation Summary permit Ver 4.0 01/22/2015 Page 122 of 144 EPA Inspection Report - Page 518 of 1969 PART 1 General Conditions permit, this shall be done in accordance with 20.2.70405 NMAC. (20.2.70.302.A.2.c NMAC) (5) The permittee shall furnish any information the Department requests in writing to determine if cause exists for reopening and revising, revoking and reissuing, or terminating the permit, or to determine compliance with the pennit. This information shall be furnished within the time period speci?ed by the Department. Additionally, the permittee shall furnish, upon request by the Department, copies of records required by the permit to be maintained by the permittee. (20.2.70.302.A.2.f NMAC) (6) A request by the permittee that this permit be modi?ed, revoked and reissued, or terminated, or a noti?cation by the permittee of planned changes or anticipated noncompliance, shall not stay any conditions of this permit. (20.2.70.302.A.2.d NMAC) (7) This permit does not convey property rights of any sort, or any exclusive privilege. (20.2.70.302.A.2.e NMAC) (8) In the case where an applicant or permittee has submitted information to the Department under a claim of con?dentiality, the Department may also require the applicant or permittee to submit a copy of such information directly to the Administrator of the EPA. (20.2.70.301.B NMAC) (9) The issuance of this permit, or the ?ling or approval of a compliance plan, does not relieve the permittee from civil or criminal liability for failure to comply with the state or Federal Acts, or any applicable state or federal regulation or law. (20.2.70.302.A.6 NMAC and the New Mexico Air Quality Control Act NMSA 1978, Chapter 74, Article 2) (10) If any part of this permit is challenged or held invalid, the remainder of the permit terms and conditions are not affected and the permittee shall continue to abide by them. (20.2.70.302.A.1.d NMAC) (1 1) A responsible of?cial (as de?ned in 20.2.70.7.AE NMAC) shall certify the accuracy, truth and completeness of every report and compliance certi?cation submitted to the Department as required by this permit. These certi?cations shall be part of each document. (20.2.70.300.E NMAC) (12) Revocation or termination of this permit by the Department terminates the permittee's right to operate this facility. (20.2.70.201.B NMAC) (13) The permittee shall continue to comply with all applicable requirements. For applicable requirements that will become effective during the term of the permit, the permittee shall meet such requirements on a timely basis. (Sections 300.D.10.c and 302.G.3 of 20.2.70 NMAC) B. Permit Shield (20.2.70.302.J NMAC) (1) Compliance with the conditions of this permit shall be deemed to be compliance with any applicable requirements existing as of the date of permit issuance and identi?ed in Table 103.A. The requirements in Table 103.A are applicable to this facility with speci?c requirements identi?ed for individual emission units. (2) The Department has determined that the requirements in Table 103B as identi?ed in the permit application are not ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 5/6/2015 Page 123 of 144 EPA Inspection Report - Page 519 of 1969 PART 1 General Conditions applicable to this source, or they do not impose any conditions in this permit. (3) This permit shield does not extend to administrative amendments (Subsection A of 20.2.70.404 NMAC), to minor permit modi?cations (Subsection of 20270404 NMAC), to changes made under Section 502(b)( 10), changes under Paragraph 1 of subsection of 202.70.302 of the Federal Act, or to permit terms for which notice has been given to reopen or revoke all or part under 20270405 and (4) This permit shall, for purposes of the permit shield, identify any requirement speci?cally identi?ed in the permit application or signi?cant permit modi?cation that the department has determined is not applicable to the source, and state the basis for any such determination. (20.2.70.302.A. .f NMAC) C. The owner or operator of a source having an excess emission shall, to the extent practicable, operate the source, including associated air pollution control equipment, in a manner consistent with good air pollutant control practices for minimizing emissions. (20.2.7.109 NMAC). The establishment of allowable malfunction emission limits does not supersede this requirement. REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. 13102 Authority Yes No Explain Explain Explain Below Below Below A. This permit is issued pursuant to the federal Clean Air Act ("Federal Act"), the New Mexico Air Quality Control Act ("State Act") and regulations adopted pursuant to the State and Federal Acts, including Title 20, New Mexico Administrative Code, Chapter 2, Part 70 (20.2.70 NMAC) Operating Permits. B. This permit authorizes the operation of this facility. This permit is valid only for the named permittee, owner, and Operator. A permit modi?cation is required to change any of those entities. C. The Department speci?es with this permit, terms and conditions upon the operation of this facility to assure compliance with all applicable requirements, as de?ned in 20.2.70 NMAC at the time this permit is issued. (20.2.70.302.A.1 NMAC) D. Pursuant to the New Mexico Air Quality Control Act NMSA 1978, Chapter 74, Article 2, all terms and conditions. in this permit, including any provisions designed to limit this facility's potential to emit, are enforceable by the Department. All terms and conditions are enforceable by the Administrator of the United States Environmental Protection Agency and citizens under the Federal Act, unless the term or condition is speci?cally designated in this permit as not being enforceable under the Federal Act. (20.2.70.302.A.5 NMAC) ACC Form Part 1 Permit P051-R2 Ver 4.1 5/6/2015 Page 124 of 144 EPA Inspection Report - Page 520 of 1969 PART 1 General Conditions E. The Department is the Administrator for 40 CFR Parts 60, 61, and 63 pursuant to the Modi?cation and Exceptions of Section 10 of 20.2.77 NMAC (NSPS), 20.2.78 NMAC (NESHAP), and 202.82 NMAC (MACT). REMARKS: B103 Annual Fee Yes El No The permittee shall pay Title fees to the Department consistent with the fee schedule in 20.2.71 NMAC Operating Permit Explain Explain g/Al . Emission Fees. The fees will be assessed and invoiced separately from this permit. (20.2.70.302.A.1.e NMAC) OW OW am ow REMARKS: 3104 Appeal Procedures Yes No (20.2.70.403.A NMAC) Explain Explain Explain Below Below Below A. Any person who participated in a permitting action before the Department and who is adversely affected by such permitting action, may ?le a petition for a hearing before the Environmental Improvement Board ("board"). The petition shall be made in writing to the board within thirty (30) days from the date notice is given of the Department?s action and shall specify the portions of the permitting action to which the petitioner objects, certify that a copy of the petition has been mailed or hand?delivered, and attach a copy of the permitting action for which review is sought. Unless a timely request for a hearing is made, the decision of the Department shall be final. The petition shall be copied simultaneously to the Department upon receipt of the appeal notice. If the petitioner is not the applicant or permittee, the petitioner shall mail or hand?deliver a copy of the petition to the applicant or permittee. The Department shall certify the administrative record to the board. Petitions for a hearing shall be sent to: Secretary, New Mexico Environmental Improvement Board 1 190 St. Francis Drive, Runnels Bldg. Rm N21 5 3 Santa Fe, New Mexico 87502 REMARKS: ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 5/6/2015 Page 125 of 144 EPA Inspection Report - Page 521 of 1969 PART 1 General Conditions B105 Submittal of Reports and Certi?cations A. Stack Test Protocols and Stack Test Reports shall be submitted electronically to StacktestAQBQi?statenmus or as directed by the Department. B. Excess Emission Reports shall be submitted as directed by the Department. (20.2.7.110 NMAC) C. Compliance Certi?cation Reports, Semi-Annual monitoring reports, compliance schedule progress reports, and any other compliance status information required by this permit shall be certi?ed by the responsible of?cial and submitted to the mailing address below, or as directed by the Department: Manager, Compliance and Enforcement Section New Mexico Environment Department Air Quality Bureau 525 Camino de los Marquez, Suite 1 Santa Fe, NM 87505?1816 D. Compliance Certi?cation Reports shall also be submitted to the Administrator at the address below (20.2.70.302.E.3 NMAC): Chief, Air Enforcement Section US EPA Region-6, 1445 Ross Avenue, Suite 1200 Dallas, TX 75202-2733 IE Yes Explain Below No Explain Below Explain Below REMARKS: Except for deviations reported on the semi?annual reports and/or referenced in this report. ACC Form Part 1 Permit P051-R2 Ver 4.1 5/6/2015 Page 126 of 144 EPA Inspection Report - Page 522 of 1969 PART 1 General Conditions B106 NSPS and/or MACT Startup. Shutdown. and Malfunction Operations A. If a facility is subject to a NSPS standard in 40 CFR 60, each owner or operator that installs and operates a continuous monitoring device required by a NSPS regulation shall comply with the excess emissions reporting requirements in accordance with. 40 CFR lfa facility is subject to a NSPS standard in 40 CFR 60, then in accordance with 40 CFR operations during periods of startup, shutdown, and malfunction shall not constitute representative conditions for the purpose of a performance test nor shall emissions in excess of the level of the applicable emission limit during periods of startup, shutdown, and malfunction be considered a violation of the applicable emission limit unless otherwise specified in. the applicable standard. If a facility is subject to a MACT standard in 40 CFR 63, then the facility is subject to the requirement for a Startup, Shutdown and Malfunction Plan (SSM) under 40 CFR unless speci?cally exempted in the applicable subpart. (20.2.70.302.A.l and A4 NMAC) Yes Explain Below Explain Below El Explain Below REMARKS: Except for deviations reported on the semi?annual reports and/or referenced in this report. B107 Startup, Shutdown, and Maintenance Operations A. The establishment of permitted startup, shutdown, and maintenance (S SM) emission limits does not supersede the requirements of 20.2.7. 1 4.A NMAC. Except for operations or equipment subject to Condition B106, the permittee shall establish and implement a plan to minimize emissions during routine or predictable start up, shut down, and scheduled maintenance (S SM work practice plan) and shall operate in accordance with the procedures set forth in the plan. (20.2.7.14.A NMAC) Yes Explain Below No Explain Below Explain Below REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. ACC Form Part 1 Permit POSI-RZ Ver 4.1 5/6/2015 Page 127 of i 44 EPA Inspection Report - Page 523 of 1969 PART 1 General Conditions B108 General Monitoring Requirements Yes No (20.2.70. 302A and NMAC) Explain Explain Explain Below Below Below A. (1) (2) (3) These requirements do not supersede or relax requirements of federal regulations. The following monitoring and/0r testing requirements shall be used to determine compliance with applicable requirements and emission limits. Any sampling, whether by portable analyzer or EPA reference method, that measures an emission rate over the applicable averaging period greater than an emission limit in this permit constitutes noncompliance with this permit. The Department may require, at its discretion, additional tests pursuant to EPA Reference Methods at any time, including when sampling by portable analyzer measures an emission rate greater than an emission limit in this permit; but such requirement shall not be construed as a determination that the sampling by portable analyzer does not establish noncompliance with this permit and shall not stay enforcement of such noncompliance based on the sampling by portable analyzer. If the emission unit is shutdown at the time when periodic monitoring is due to be accomplished, the permittee is not required to restart the unit for the sole purpose of performing the monitoring. Using electronic or written mail, the perm ittee shall notify the Department?s Enforcement Section of a delay in emission tests prior to the deadline for accomplishing the tests. Upon recommencin operation, the permittee shall submit any pertinent pre~test noti?cation requirements set forth in. the current version of the Department?s Standard Operating Procedures For Use Of Portable Analyzers in Performance Test, and shall accomplish the monitoring. The requirement for monitoring during any monitoring period is based on the percentage of time that the unit has Operated. However, to invoke monitoring period exemptions at hours of operation shall be monitored and recorded. If the emission 'unit has operated for more than 25% of a monitoring period, then the permittee shall conduct monitoring during that period. If the emission unit has operated for 25% or less of a monitoring period then the monitoring is not required. After two successive periods without monitoring, the permittee shall conduct monitoring during the next period regardless of the time operated during that period, except that for any monitoring period in which a unit has operated for less than 10% of the monitoring period, the period will not be considered as one of the two successive periods. If invoking the monitoring period exemption in the actual operating time of a unit shall not exceed the monitoring period required by this permit before the required monitoring is performed. For example, if the ACC Form Part 1 Permit R2M1 Ver 4.1 5/6/2015 Page 128 of. 144 EPA Inspection Report - Page 524 of 1969 PART 1 General Conditions monitoring period is annual, the operating hours of the unit shall not exceed 8760 hours before monitoring is conducted. Regardless of the time that a unit actually operates, a minimum of one of each type of monitoring activity shall be conducted during the five year term of this permit. E. The permittee is not required to report a deviation for any monitoring or testing in a Speci?c Condition if the deviation was authorized in this General Condition 13108. F. For all periodic monitoring events, except when a federal or state regulation is more stringent, three test runs shall be conducted at 90% or greater of the unit?s capacity as stated in this permit, or in the permit application if not in the permit, and at additional loads when requested by the Department. If the 90% capacity cannot be achieved, the monitoring will be conducted at the maximum achievable load under prevailing operating conditions except when a federal or state regulation requires more restrictive test conditions. The load and the parameters used to calculate it shall be recorded to document operating conditions and shall be included with the monitoring report. G. When requested by the Department, the permittee shall provide schedules of testing and monitoring activities. Compliance tests from previous NSR and Title permits may be re-imposed if it is deemed necessary by the Department to determine whether the source is in compliance with applicable regulations or permit conditions. H. If monitoring is new or is in addition to monitoring imposed by an existing applicable requirement, it shall become effective 120 days after the date of permit issuance. .F or emission units that have not commenced operation, the associated new or additional monitoring shall not apply until 120 days after the units commence operation. All pre- existing monitoring requirements incorporated in this permit shall continue to apply from the date of permit issuance. All monitoring periods, unless stated otherwise in the specific permit condition or federal requirement, shall commence at the beginning of the 12'month reporting period as defined at condition A109.B. REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. ACC Form Part 1 Permit P051-R2 Ver 4.1 5/6/2015 Page 129 of144 EPA Inspection Report - Page 525 of 1969 PART 1 General Conditions B109 General Recordkeeping Requirements (20.2.70.302.D.l NMAC) A. The permittee shall maintain records to assure and verify compliance with the terms and conditions of this permit and any applicable requirements that become effective during the term of this permit. The minimum information to be included in these records is (20.2.70.302.D.l NMAC): (1) Records required for testing and sampling: equipment identi?cation (include make, model and serial number for all tested equipment and emission controls); date(s) and time(s) of sampling or measurements; (0) date(s) analyses were performed; the company or entity that performed the analyses; analytical or test methods used; results of analyses or tests; and operating conditions existing at the time of sampling or measurement. (2) Records required for equipment inspections and/or maintenance required by this permit: equipment identi?cation number (including make, model and serial number) date(s) and time(s) of inspection, maintenance; and/or repair date(s) any subsequent analyses were performed (if applicable) name of the person or quali?ed entity conducting the inspection, maintenance, and/or repair copy of the equipment manufacturer?s or the owner or operator?s maintenance or repair recommendations (if required to demonstrate compliance with a permit condition) description of maintenance or repair activities conducted all results of any required parameter readings a description of the physical condition of the equipment as found during any required inspection results of required equipment inspections including a description of any condition which required Yes Explain Below 0 Explain Below Explain Below ACC Form Part 1 Permit Ver 4.1 5/6/2015 Page 130 of144 EPA Inspection Report - Page 526 of 1969 PART 1 General Conditions adjustment to bring the equipment back into compliance and a description of the required adjustments B. The permittee shall keep records of all monitoring data, equipment calibration, maintenance, and inspections, Data Acquisition and Handling System (DAHS) if used, reports, and other supporting information required by this permit for at least five (5) years from the time the data was gathered or the reports written. Each record shall clearly identify the emissions unit and/or monitoring equipment, and the date the data was gathered. (20.2.70.302.D.2 NMAC) C. If the permittee has applied and received approval for an alternative operating scenario, then the permittee shall maintain a log at the facility, which documents, contemporaneously with any change from one operating scenario to another, the scenario under which the facility is operating. (20.2.70.302.A.3 NMAC) D. The permittee shall keep a record describing off permit changes made at this source that result in emissions of a regulated air pollutant subject to an applicable requirement, but not otherwise regulated under this permit, and the emissions resulting from those changes. (202.70.302.12 NMAC) E. Unless otherwise indicated by Speci?c Conditions, the permittee shall keep the following records for malfunction emissions and routine and predictable emissions during startup, shutdown, and scheduled maintenance (SSM): (1 The owner or operator of a source subject to a permit, shall establish and implement a plan to minimize emissions during routine or predictable startup, shutdown, and scheduled maintenance through. work practice standards and good air pollution control practices. This requirement shall not apply to any affected facility defined in and subject to an emissions standard and an equivalent plan under 40 CFR Part 60 (N SPS), 40 CFR Part 63 (MACT), or an equivalent plan under 20.2.72 NMAC - Construction Permits, 20.2.70 NMAC - Operating Permits, 20.2.74 NMAC Permits - Prevention of Significant Deterioration (P SD), or 20.2.79 NMAC Permits Nonattainment Areas. (20.2.7.14.A NMAC) The permittee shall keep records of all sources subject to the plan to minimize emissions during routine or predictable SSM and shall record if the source is subject to an alternative plan and therefore, not subject to the plan requirements under 20.2.7.14.A NMAC. (2) If the facility has allowable SSM emission limits in this permit, the permittee shall record all SSM events, including the date, the start time, the end time, a description of the event, and a description of the cause of the event. This record also shall include a copy of the manufacturer?s, or equivalent, documentation showing that any maintenance qualified as scheduled. Scheduled maintenance is an activity that occurs at an established frequency pursuant to a written protocol published by the manufacturer or other reliable source. The authorization of allowable SSM emissions does not supersede any applicable federal or state standard. The most stringent requirement applies. (3) If the facility has allowable malfunction emission limits in this permit, the permittee shall record all malfunction ACC Form Part 1 Permit Page 131 of 144 Ver 5/6/2015 EPA Inspection Report - Page 527 of 1969 PART 1 General Conditions events to be applied against these limits. The permittee shall also include the date, the start time, the end time, and a description of the event. Malfunction means any sudden and unavoidable failure of air pollution control equipment or process equipment beyond the control of the owner or operator, including malfunction during startup or shutdown. A failure that is caused entirely or in part by poor maintenance, careless operation, or any other preventable equipment breakdown shall not be considered a mal?lnction. (20.2.7.7.E NMAC) The authorization of allowable malfunction emissions does not supersede any applicable federal or state standard. The most stringent requirement applies. This authorization. only allows the permittee to avoid submitting reports under 20.2.7 NMAC for total annual emissions that are below the authorized mal?lnction emission limit. (4) The owner or operator of a source shall meet the operational plan de?ning the measures to be taken to mitigate source emissions during mal?lnction, startup or shutdown. NMAC) REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. B110 General Reporting Requirements (20.2.70.302.E NMAC) A. Reports of required monitoring activities for this facility shall be submitted to the Department on the schedule in section A109. Monitoring and recordkeeping requirements that are not required by a NSPS or MACT shall be maintained on?site or (for unmanned sites) at the nearest company of?ce, and summarized in the semi?annual reports, unless alternative reporting requirements are speci?ed in the equipment speci?c requirements section of this permit. B. Reports shall clearly identify the subject equipment showing the emission unit ID number according to this operating permit. In addition, all instances of deviations from permit requirements, including those that occur during emergencies, shall be clearly identi?ed in the reports required by section A109. (20.2.70.302.E.1 NMAC) C. The permittee shall submit reports of all deviations from permit requirements, including those attributable to upset conditions as de?ned in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. These reports shall be submitted as follows: (1) Deviations resulting in excess emissions as de?ned in 20.2.7.7 NMAC (including those classi?ed as emergencies as de?ned in section B1 14A) shall be reported in accordance with the timelines speci?ed by 20.2.7.1 10 NMAC and in the semi-annual reports required in section A109. (20.2.70.302.E.2 NMAC) (2) All other deviations shall be reported in the semi-annual reports required in section A109. (20.2.70.302.E.2 Yes Explain Below No Explain Below [1 Explain Below ACC Form Part 1 Permit P051-R2 R2M1 Ver 41 5/6/2015 Page 132 of 144 EPA Inspection Report - Page 528 of 1969 PART 1 General Conditions (1) (2) (3) (4) (5) (1) NMAC). The permittee shall submit reports of excess emissions in accordance with 20.2.7.110.A NMAC. Results of emission tests and monitoring for each pollutant (except opacity) shall be reported in pounds per hour (unless otherwise speci?ed) and tons per year. Opacity shall be reported in percent. The number of signi?cant figures corresponding to the full accuracy inherent in the testing instrument or Method test used to obtain the data shall be used to calculate and report test results in accordance with 20.2.1 .1 and NMAC. Upon request by the Department, CEMS and other tabular data shall be submitted in editable, MS Excel format. At such time as new units are installed as authorized by the applicable NSR Permit, the permittee shall ful?ll the notification requirements in the NSR permit. Periodic Emissions Test Reporting: The permittee shall report semi-annually a summary of the test results. The permittee shall submit an emissions inventory for this facility annually. The emissions inventory shall be submitted by the later of April 1 or within 90 days after the Department makes such request. (20.2.73 NMAC and 20.2.70.302.A.l NMAC) The facility emits, or has the potential to emit, 5 tons per year or more of lead or lead compounds, or 100 tons per year or more of PMI 0, PM2.5 sulfur oxides, nitrogen oxides, carbon monoxide, or volatile organic compounds. The facility is de?ned as a major source of hazardous air pollutants under 20.2.70 NMAC (Operating Permits). The facility is located in an ozone nonattainment area and which emits, or has the potential to emit, 25 tons per year or more of nitrogen oxides or volatile organic compounds. Upon request by the department. The permittee shall submit the emissions inventory report by April 1 of each year, unless a different deadline is specified by the current operating permit. Emissions trading within a facility (20.2.70.302.H.2 NMAC) For each such change, the permittee shall provide written notification to the department and the administrator at least seven (7) days in advance of the proposed changes. Such notification shall state when the change will occur and shall describe the changes in emissions that will result and how these increases and decreases in emissions will comply with the terms and conditions of the permit. (2) The permittee and department shall attach each such notice to their copy of the relevant permit. ACC Form Part 1 Permit P051-R2 Ver 4.1 5/6/2015 Page 133 of 144 EPA Inspection Report - Page 529 of 1969 PART 1 General Conditions REMARKS: Except for deviations reported on the semi?annual reports and/or referenced in this report. B111 General Testing Requirements A. Compliance Tests (1) (2) (3) (4) (5) (6) Compliance test requirements from previous permits (if any) are still in effect, unless the tests have been satisfactorily completed. Compliance tests may be re?imposed if it is deemed necessary by the Department to determine whether the source is in compliance with applicable regulations or permit conditions. (20.2.72 NMAC Sections 210C and 213) Compliance tests shall be conducted within sixty (60) days after the unit(s) achieve the maximum normal production rate. If the maximum normal production rate does not occur within one hundred twenty (120) days of source startup, then the tests must be conducted no later than one hundred eighty (l 80) days after initial startup of the source. Unless otherwise indicated by Specific Conditions or regulatory requirements, the default time period for each test run shall be at least 60 minutes and each performance test shall consist of three separate runs using the applicable test method. For the purpose of determining compliance with an applicable emission limit, the arithmetic mean of results of the three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the three runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances, beyond the owner or operator's control, compliance may, upon the Department approval, be determined using the arithmetic mean of the results of the two other runs. Testing of emissions shall be conducted with the emissions unit operating at 90 to 100 percent of the maximum operating rate allowed by the permit. If it is not possible to test at that rate, the source may test at a lower operating rate, subject to the approval of the Department. Testing performed at less than 90 percent of permitted capacity will limit emission unit operation to 10 percent of the tested capacity until a new test is conducted. If conditions change such that unit operation above 10 percent of tested capacity is possible, the source must submit a protocol to the Department within 30 days of such change to conduct a new emissions test. Yes Explain Below No Explain Explain Below Below ACC Form Part 1 Permit Ver 4.1 5/6/2015 Page 134 of 144 EPA Inspection Report - Page 530 of 1969 PART 1 General Conditions B. C. EPA Reference Method Tests 1) All compliance tests required by this permit, unless otherwise speci?ed by Speci?c Conditions of this permit, shall be conducted in accordance with the requirements of 40 CFR 60, Subpart A, General Provisions, and the following EPA Reference Methods as speci?ed by 40 CFR 60, Appendix A: (C) (11) (1) (In) (11) Methods 1 through 4 for stack gas ?owrate Method 5 for TSP Method 6C and 19 for 802 Method 7B for NOX (test results shall be expressed as nitrogen dioxide (N02) using a molecular weight of 46 lb/lb?mol in all calculations (each of is equivalent to 1.194 10-7 Method 9 for opacity Method 10 for CO Method 19 may be used in lieu of Methods 14 for stack gas ?owrate upon approval. of the Department. A justi?cation for this proposal must be provided along with a contemporaneous fuel gas analysis (preferably on the day of the test) and a recent fuel flow meter calibration certi?cate (within the most recent quarter). Method 7B or 20 for Turbines per 60.335 or 60.4400 Method 29 for Metals Method 201A for ?lterable and Method 202 for condensable PM Method 320 for organic Hazardous Air Pollutants (HAPs) Method 25A for VOC reduction ef?ciency Method 30B for Mercury (2) Alternative test method(s) may be used if the Department approves the change. Periodic Monitoring and Portable Analyzer Requirements (1) Periodic emissions tests (periodic monitoring) may be conducted in accordance with EPA Reference Methods or by utilizing a portable analyzer. Periodic monitoring utilizing a portable analyzer shall be conducted in accordance with the requirements of ASTM 6522?00. However, if a facility has met a previously approved ACC Form Part 1 Permit Ver 4.1 5/6/2015 Page 135 of144 EPA Inspection Report - Page 531 of 1969 PART 1 General Conditions (2) (3) (4) (5) Department criterion for portable analyzers, the analyzer may be operated in accordance with that criterion until it is replaced. Unless otherwise indicated by Speci?c Conditions or regulatory requirements, the default time period for each test run shall be at least 20 minutes. Each performance test shall consist of three separate runs. The arithmetic mean of results of the three shall be used to determine compliance with the applicable emission limit. Testing of emissions shall be conducted in accordance with the requirements at Section B108.F. During emissions tests, pollutant and diluent concentration shall be monitored and recorded. Fuel ?ow rate shall be monitored and recorded if stack gas flow rate is determined utilizing Method 19. This information shall be included with the test report furnished to the Department. Stack gas flow rate shall be calculated in accordance with 40 CFR 60, Appendix A, Method 19 utilizing fuel flow rate (scf) determined by a dedicated fuel flow meter and fuel heating value (Btu/sci) determined from a fuel sample obtained preferably during the day of the test, but no earlier than three months prior to the test date. Altematively, stack gas ?ow rate may be determined by using EPA Methods l-4. D. Test Procedures: (1) (2) (3) (4) (5) (6) (7) The permittee shall notify the Department?s Program Manager, Compliance and Enforcement Section at least thirty (3 0) days before the test to afford a representative of the Department an opportunity to be present at the test. (4OCFR Equipment shall be tested in the "as found? condition. Equipment may not be adjusted or tuned prior to any test for the purpose of lowering emissions, and then returned to previous settings or operating conditions after the test is complete. Contents of test noti?cations, protocols and test reports shall conform to the format speci?ed by the Department?s Universal Test Noti?cation, Protocol and Report Form and Instructions. Current forms and instructions are posted to Air Quality web site under Compliance and Enforcement Testing. The permittee shall provide sampling ports adequate for the test methods applicable to the facility, safe sampling platforms, safe access to sampling platforms and utilities for sampling and testing equipment. The stack shall be of suf?cient height and diameter and the sample ports shall be located so that a representative test of the emissions can be performed in accordance with the requirements of EPA Method 1 or ASTM 65 22? 00 as applicable. Where necessary to prevent cyclonic flow in the stack, flow straighteners shall be installed Unless otherwise indicated by Speci?c Conditions or regulatory requirements, test reports shall be submitted to the Department no later than 30 days after completion of the test. ACC Form Part 1 Permit Ver 4.1 5/6/2015 Page 136 of 144 EPA Inspection Report - Page 532 of 1969 PART 1 General Conditions REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in. this report. 13112 Compliance Yes No [1 Explain Explain Explain Below Below Below A. The Department shall be given the right to enter the facility at all reasonable times to verify the terms and conditions of this permit. Required records shall be organized by date and subject matter and shall at all times be readily available for inspection. The permittee, upon verbal or written request from an authorized representative of the Department who appears at the facility, shall immediately produce for inspection or copying any records required to be maintained at the facility. Upon written request at other times, the permittee shall deliver to the Department paper or electronic copies of any and all required records maintained on site or at an off-site location. Requested records shall be copied and delivered at the permittee?s expense within three business days from receipt of request unless the Department allows additional time. Required records may include records required by permit and other information necessary to demonstrate compliance with terms and conditions of this permit. (NMSA 1978, Section 74~2~13) B. A copy of the most recent permit(s) issued by the Department shall be kept at the permitted facility or (for unmanned sites) at the nearest company office and shall be made available to Department personnel for inspection upon request. (20.2.70.302.G.3 NMAC) C. Emissions limits associated with the energy input of a Unit, i.e. leMBtu, shall apply at all times unless stated otherwise in a Specific Condition of this permit. The averaging time for each emissions limit, including those based on energy input of a Unit lb/MMBtu) is one (1) hour unless stated otherwise in a Specific Condition of this permit or in the applicable requirement that establishes the limit. (20.2.70.302.A.l and G3 NMAC) D. The permittee shall submit compliance certi?cation reports certifying the compliance status of this facility with respect to all permit terms and conditions, including applicable requirements. These reports shall be made on the pre?populated Compliance Certi?cation Report Form that is provided to the permittee by the Department, and shall be submitted to the Department and to EPA at least every 12 months. For the most current form, please contact the Compliance Reports Group at For additional reporting guidance see (20.2.70.302.E.3 NMAC) E. The permittee shall allow representatives of the Department, upon presentation of credentials and other documents ACC Form Part 1 Permit Page 137 of 144 Ver 4.1. 5/6/2015 EPA Inspection Report - Page 533 of 1969 PART 1 General Conditions as may be required by law, to do the following (20.2.70.302.G.l NMAC): (1) enter the permittee's premises where a source or emission unit is located, or where records that are required by this permit to be maintained are kept; (2) have access to and copy, at reasonable times, any records that are required by this permit to be maintained; (3) inspect any facilities, equipment (including monitoring and air pollution control equipment), work practices or operations regulated or required under this permit; and (4) sample or monitor any substances or parameters for the purpose of assuring compliance with this permit or applicable requirements or as otherwise authorized by the Federal Act. REMARKS: Except for deviations reported on the semi?annual reports and/or referenced in this report. B113 Permit Reopening and Revocation Yes No I: Explain Explain Below Below Explain A. This permit will be reopened and revised when any one of the following conditions occurs, and may be revoked and Below reissued when or occurs. (20.2.70.405.A.l NMAC) (1) (2) (3) (4) Additional applicable requirements under the Federal Act become applicable to a major source three (3) or more years before the expiration date of this permit. If the effective date of the requirement is later than the expiration date of this permit, then the permit is not required to be reopened unless the original permit or any of its terms and conditions has been extended due to the Department?s failure to take timely action on a request by the permittee to renew this permit. Additional requirements, including excess emissions requirements, become applicable to this source under Title IV of the Federal Act (the acid rain program). Upon approval by the Administrator, excess emissions offset plans will be incorporated into this permit. The Department or the Administrator determines that the permit contains a material mistake or that inaccurate statements were made in establishing the terms and conditiOns of the permit. The Department or the Administrator determines that the permit must be revised or revoked and reissued to assure compliance with an applicable requirement. ACC Form Part Permit P051-R2 Ver 4.1 5/6/2015 Page 138 of144 EPA Inspection Report - Page 534 of 1969 PART 1 General Conditions B. Proceedings to reopen or revoke this permit shall affect only those parts of this permit for which cause to reopen or revoke exists. Emissions units for which permit conditions have been revoked shall not be operated until new permit conditions have been issued for them. (20.2.70.405.A.2 NMAC) REMARKS: Except for deviations reported on the semi?annual reports and/or referenced in this report. 3114 Emergencies (202.70.304 NMAC) A. An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the permittee, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology?based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventive maintenance, or careless or improper operation. B. An emergency constitutes an af?rmative defense to an action brought for noncompliance with technology?based emission limitations contained in this permit if the permittee has demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that: (1) An emergency occurred and that the permittee can identify the cause(s) of the emergency; (2) This facility was at the time being properly operated; (3) During the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or other requirements in this permit; and (4) The permittee submitted notice of the emergency to the Department within 2 working days of the time when emission limitations were exceeded due to the emergency. This notice fulfills the requirement of 20.2.70.302.E.2 NMAC. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. C. In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency has the burden of proof. [Xi Yes Explain Below No Explain Below Explain Below ACC Form Part 1 Permit R2M1 Ver 4.1 5/6/2015 Page 139 of 144 EPA Inspection Report - Page 535 of 1969 PART 1 General Conditions D. This provision is in addition to any emergency or upset provision contained in any applicable requirement. REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. B115 Stratospheric Ozone Yes No (20.2.70.302.A.1 NMAC) Explain Explain Below Below Explain A. If this facility is subject to 40 CFR 82, Subpart F, the permittee shall comply with the following standards for Below recycling and emissions reductions: (1) Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices, except for motor vehicle air conditioners (MVAC) and MVAC?like appliances. (40 CFR 82.156) (2) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment. (40 CFR 82.158) (3) Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certification program. (40 CFR 82.161) REMARKS: Except for deviations reported on the semi?annual reports and/or referenced in this report. 3116 Acid Rain Sources Yes No K4 (20.2.70.302.A.9 NMAC) Explain Explain Below Below Explain Below A. B. If this facility is subject to the federal acid rain program under 40 CFR 72, this section applies. Where an applicable requirement of the Federal Act is more stringent than an applicable requirement of regulations promulgated under Title IV of the Federal Act, both provisions are incorporated into this permit and are federally enforceable. Emissions exceeding any allowances held by the permittee under Title IV of the Federal Act or the regulations promulgated thereunder are prohibited. ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 5/6/2015 Page 140 of 144 EPA Inspection Report - Page 536 of 1969 PART 1 General Conditions D. No modi?cation of this permit is required for increases in emissions that are authorized by allowances acquired pursuant to the acid rain program, provided that such increases do not require a permit modi?cation under any other applicable requirement. E. The permittee may not use allowances as a defense to noncompliance with any other applicable requirement. F. No limit is placed on the number of allowances held by the acid rain source. Any such allowance shall be accounted for according to the procedures established in regulations promulgated under Title IV of the Federal Act. G. The acid rain permit is an enclosure of this operating permit. REMARKS: 3117 Risk Management Plan Yes I: No (20.2.70.302.A.1 NMAC) Explain Explain Below Below Explain Below A. If this facility is subject to the federal risk management program under 40 CFR 68, this section applies. B. The owner or operator shall certify annually that they have developed and implemented a RMP and are in compliance with 40 CFR 68. C. If the owner or operator of the facility has not developed and submitted a risk management plan according to 40 CFR 68150, the owner or operator shall provide a compliance schedule for the development and implementation of the plan. The plan shall describe, in detail, procedures for assessing the accidental release hazard, preventing accidental releases, and developing an emergency response plan to an accidental release. The plan shall be submitted in a method and format to a central point as speci?ed by EPA prior to the date specified in 40 CFR 68.150.b. REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. ACC Form Part 1 Permit RZMI Ver4.15/6/2015 Page 141 of 144 EPA Inspection Report - Page 537 of 1969 Part 2 ACC Deviation Summary Report for Permit P051-R2 R2M1 Deviation Summary Table for deviations not yet reported15111. EN) . .. . Flare monitoring implemented to meet Ja re?nery's most recent NSR permit, M37 increases these iimits.) A106.C, A107.C, A107.F Allowable All Flares Navajo is working on evaluating the data and will SSM and Malfunction Emissions. requirements has resulted in data. that is being address any reporting of excess emissions that may 1 evaluated with respect to potential exceedences of be necessary with the NMED. permit limits. Thus, any excess emissions have not been reported to date. A206.B Fiare gas below 300 btu/scf NHV due to hydrogen Increase H2 consumption and reduce H2 sent to 7 40 CFR 63.1 venting as a result of process upset and hydrogen the ?are. imbalance. A203 .E Tanks The draft results of a recent thirdwparty environmental This is currently under review. compliance audit indicate potential exceedances of the Title permit sour water throughput limit in 2016 (and 3 2015) and the distillate throughput in 2016. (The ACC Part 2, Deviation Summary Title-V Permit Page 142 of 144 EPA Inspection Report - Page 538 of 1969 PART 1 General Conditions and ?ve HC Flaring Incidents. The draft results indicate that a follow-up report was not submitted within 30 days after completion of corrective action for one HC Flaring Incident. A112.A Ammonia emissions from a vent on the knockout pot This is currently under review. associated with may not be less 5 25 4 (The underlying'regulatory provision, 20.2.37 NMAC, has been repealed effective September 12, 2016) 5 A1091) All Flares The draft results of a recent third-party environmental This is currently under review. SRU2 compliance audit indicate that incident reports were not SRU3 submitted within 45 days following the end of one TGI ACC Form Part 1 Permit Ver 4.1 5/6/2015 Page 143 of 144 EPA Inspection Report - Page 539 of 1969 No. Date Time Date Pollutant 3?19?ng :Metnod f..Ainount of . . {Emissions 1 9/1/2016 0000 8/31/2017 23:59 Data Unknown El Yes No Data 2 NJA ?4 (See Note 2 on attached additional Yes No deviation pages) 3 A. - Under P1 Data Review es . Under 4 diam; ?Reg/rm; LJ NH3 Review Yes No 5 AVA 14 A x) $31213; its Data, Document Review El Yes N0 ACC Part 2, Deviation Summary Title?V Permit P05 1 -R2 R2M1 Page 144 of 144 EPA Inspection Report - Page 540 of 1969 Deviation Summary Table for deviations not yet reported. (Cont.) .. Applicable Requirement EmissionCrr?cnv AtonTk 0 (include Ruie Citation) Unit ause 0 evra 10? 0 3 en A106 and A107 All Sources Several excess emission reports required under conditon Navajo tracks emission events on a daiiy basis and has 6 A106 and A107 were not submitted within the time improved training to help ensure emission events are required under 20.2.7 NMAC. reported to Environmental and to agencies in a timeiy manner. EPA Inspection Report - Page 541 of 1969 Deviation Summary Table (cont) Deviation Started Deviation Ended Did you attach an excess emission form? . . . . No. Date Time Date Time Pollutant Method Amoun 6 Various Pi Data, Calculations No Note 1 Consistent with prior reporting and previous discussions with NMED, this table does not include deviations previously reported to NMED, including in reports under the NSPS, MACT, or other programs. Note 2 Refer to attached Table of Events Summary. Deviation Started Date/Time 09/14/2016 16:00 10/11/2016 07:00 02/27/2017 18:00 03/10/2017 14:00 03/10/2017 17:00 08/09/2017 13:00 01/06/2017 11:00 01/07/2017 06:00 02/20/2017 19:00 07/18/2017 12:00 10/04/2016 22:00 10/05/2016 01:00 11/07/2016 16:00 02/21/2017 14:00 02/22/2017 23:00 12/27/2016 06:00 02/10/2017 16:00 02/26/2017 20:00 02/27/2017 03:00 02/28/2017 01:00 03/02/2017 19:00 03/03/2017 22:00 03/04/2017 12:00 03/04/2017 17:00 03/05/2017 09:00 03/08/2017 11:00 03/09/2017 12:00 03/10/2017 07:00 EPA Inspection Report - Page 542 of 1969 Deviation Ended Date/Time 09/15/2017 08:00 10/11/2016 11:00 03/01/2017 21:00 03/10/2017 15:00 03/10/2017 18:00 08/09/2017 15:00 01/06/2017 15:00 01/06/2017 10:00 02/20/2017 21:00 07/19/2017 12:00 10/04/2016 23:00 10/07/2016 00:00 11/07/2016 19:00 02/22/2017 12:00 03/25/2017 02:00 12/27/2016 07:00 02/11/2017 14:00 02/26/2017 23:00 02/27/2017 17:00 02/28/2017 02:00 03/03/2017 00:00 03/04/2017 00:00 03/04/2017 14:00 03/04/2017 21:00 03/07/2017 03:00 03/08/2017 18:00 03/09/2017 21:00 03/10/2017 10:00 Pollutant Monitoring Method Amount of Emissons Excess Emission Form? Table of Events Summary (BTU) Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data lof2 Deviation Started Date/Time 03/12/2017 07:00 03/14/2017 00:00 03/14/2017 04:00 03/14/2017 12:00 08/18/2017 19:00 08/19/2017 15:00 08/23/2017 12:00 10/20/2016 11:00 02/22/2017 04:00 02/22/2017 13:00 02/22/2017 21:00 04/10/2017 16:00 06/01/2017 09:00 07/07/2017 09:00 07/07/2017 12:00 EPA Inspection Report - Page 543 of 1969 Deviation Ended Date/Time 03/12/2017 08:00 03/14/2017 02:00 03/14/2017 06:00 03/14/2017 21:00 08/19/2017 08:00 08/19/2017 22:00 08/23/2017 14:00 10/20/2016 12:00 02/22/2017 05:00 02/22/2017 14:00 03/13/2017 11:00 04/10/2017 17:00 06/01/2017 10:00 07/07/2017 10:00 07/07/2017 13:00 Pollutant Monitoring Method Amount of Emissons Excess Emission Form? Table of Events Summary (BTU) Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data 20f2 EPA Inspection Report - Page 544 of 1969 New Mexico Environment Department Air Quality Bureau Compliance and Enforcement Section 525 Camino de Los Marquez - Suite 1 Santa Fe, NM 87505 Phone (505) 476?4300 Email: Excess Emissions Reporting Form .- AI Number: Activity Number: Facility Name: Company Name: 198 000198-09292016?01 ?Navajo Refining Company LLC Navajo Refining Artesia Refinery Emission Unit No.: Emission Unit Desc: Release Point No.: Release Point Desc.: Unit 55 General Plant, Racks, and Flares - North Ptant Flare Source ls: Stationary Source? Yes Discovery Date/Time; 11/01/2015 00:00 Portable Source? No Start Date/Time: 11/01/2015 00:00 Portable Location: --UTM: End Date/Time ?Lat? Long: 1st Business Day after 11/02/2015 Discovery: . Title Permit No.: P051-R2M1 Submission Status: Initial EER NSR Permit No.: - - Firstname/ Lastname: - Raymond Smalts Office Phone: 575?746?5490 Extn.: E-mail Address: - SECTION. REQ. "57 . Reporting Requirement: . eff 20.2.7 NMAC :1 ?t 20.2.70 NMAC (Title (MACT) I :1 Cell Phone: Malfunction Startup Shutdown Emergency Schedule Maintenance Title Deviation EVENT TYPE . SS or SM Notification: Date: Explain: Affirmative Defense Claim: Yes Page 1 of 2 EPA Inspection Report - Page 545 of 1969 sE_cTioN_Iv NATURE QFEVENT Detailed Description: it was discovered that on approximately 11/01/2015, Navajo had potentially exceeded the permitted TPY limits for 802, CO, and TAKEN OFEXQESS EMISSION - Detailed Description: vi - coke-active MEASURES Detailed Description: SECTION -_Exc_Es__s_EM_issiON - - 131: Duration I Pollutant 5 Event 5 OF Compliance Testing Continuous Emission Monitor. Calcuiation Operating Log(s) Other: LimitsorAveraging . . . Period "Average Emission .. Rate for Averaging Penod_ . .'.Excess. I. II . . Numberof "Exceedences secTioN submission - By clickingon the Certify button, 5 agree to the following: After reasonabie inquiry, I certify this report as true, accurate and complete. Reporting Official: Raymond Smalts Title: Environ mentat Specialist Date: 09/29/2016 Page 2 of 2 EPA Inspection Report - Page 546 of 1969 New Mexico Environment Department Air Quality Bureau Compliance and Enforcement Section 525 Camino de Los Marquez - Su?te 1 - Santa Fe, NM 87505 Phone (505) 476-4300 Email: Excess Emissions Reporting Form AINumber 198 UnItNo .- Unit 55 may N'uimb?fg'ff .aif ?50001gas-0929201002 =52Emi$?i00 '00? D9551 Genera' P'ant? Rae?! and Hares FaICliltyNIarneI; I- . g-.f.Navajo Refining Company LLC ReleaIIsIIeIPoint FL-0401 Company.NamIe:I Navajo Refining - Artesia Refinery South Plant Flare . "IStaIt_ionaIry_ISIource? Yes 11/01/2015 00:00 '3 11/01/2015 00:00 -. 11 111111 Lat .. . I . 'I-1stBus1ness Day IaIfItIerI.? 11/02/2015 Discovery -. Title - . . .?3lnitial EER NSRPermitNo; -- - FIiIrstnIaImIIe 1' :ISmaits ?ofriqe 121111; 1511111.: - IIE?mailAdIdress;. PhoneIzi'I: 111-: Majfgn??ah II II1.IZ.SIS orSM Notification1:1 31.111.1- Dt . ?f I202- I70 NMAIC V) Shutdown I I I ZII?Explain; 4:0 CPR 6'0 (NSPS) :I-i -. Emergency I . . I40 CFR53WACT) I I I I I ScheIcIluIIle Maintenance 4? IITitleI VII Dewation - I I .IAlIfirrTI?aItive Defense Claim; .Yes Page 1 of 2 EPA Inspection Report - Page 547 of 1969 secnomv CAUSE AND NATURE .- Detailed DescriptIon ilt was discovered that on approximately 11/01,/2015 Navajo had potentially exceeded the permitted TPY limits for NOX 802 co and VOC. .. Detailed Description; -- SECTION VI .- CORRECTIVE 1' DetaIled DescrIptIon .5 . SECTION Vili EXCESS EMISSJON DETAIL LINE EmlSSIOl?lileltS oritAveragmgf . Standards . g; ea or veragIng._ - II By ciiokihg oh then-Certify buttohsl' agree to'the folloyIiing: :l ComplIance Testing -- -. . 5 -- .- I I I fAfter reasohableinquiry, I certify this report as'true, accurate and complete, Continuous Emission monitor - - . . :jiCalculatIon . grgeporting Official: Raymond Smalts a Operatmg Log(Specialist 3 Other}. I'Dat'e: 5'09/29/2016 Page 2 of 2 EPA Inspection Report - Page 548 of 1969 New Mexico Environment Department - Air Quality Bureau Compliance and Enforcement Section 525 Camino de Los Marquez - Suite 1 - Santa Fe, NM 87505 Phone (505) 476?4300 - Email: Excess Emissions Reporting Form 3'59"? GENERAL . Al Number: 198 Emission Unit No.: Unit 55 Activity Number; 000198-09292016?03 Emission Unit Desc: General Piant, Racks, and Flares Facility Name:_ .I Navajo Refining Company LLC Release Point No.: I Company Name: Navajo Refining - Artesia Refinery Release Point Desc: Flare Source ls: Stationary Source? Yes Discovery Date/Time: 11/01/2015 00:00 Portable Source? - No Start Date/Time: 11/01/2015 00:00 Portable Locationzl . UTM: I'E-nd Date/Time' I Lat:_ Long: Let Business Day after 11/02/2015 Discovery; -- Title Permit No.: - Submission Status: initial EER NSR Permit . PSD0195-M37 - Firstname/ Lastname: - Raymond Smalts . Office Phone: 575746-5490 Extn.: E?mail Address: Cell Phone: SECTION ll - REQ. EVENT-TYPE Reporting Requ1rement: if Maifunction - SS or SM Noti?cation: 22:? 20.2.7 NMAC 2:2 Startup -- Date: 20.2.70 NMAC (Title V) :3 Shutdown -. - 2.1 40CFR 60 (NSPS) :1 Emergency 40 CFR 03 (MACTI) C. I Schedule Maintenance I I I I {if Title Deviation Affirmative Defense Claim: Yes Page 1 of 2 EPA Inspection Report - Page 549 of 1969 SEcrioN NATURE Detailed Description: it was discovered that on approximately 11/01/2015, Navajo had potentially exceeded the permitted TPY limits for so2, co, and voc. SECTIEQN LIMIT: . Detailed Description: Detailed Description: EMISSION DETAIL LINES . of -- Event Poilutant . I - Standards SECTION IX 4 BAsis _o_F ESTIMATE Compliance Testing LE Continuous Emission Monitor C_a?c_uiation Operating Log(s) Other: . Emis'sion LimitsorAV-eraQiF-IQ for .. - -- Exceedences . - . -- -. -. - _.Permd -. - . Submission I By ciicking on the Certify buttonY i agree to the following: After reasonable inquiry, I certify this report as true, accurate and complete. Reporting Official: Raymond Smalts . Environmental Specialist Date: 09/29/2016 Page 2 of 2 EPA Inspection Report - Page 550 of 1969 New Mexico Environment Department - Air Quality Bureau Compliance and Enforcement Section 525 Camino de Los Marquez - Suite 1 Santa Fe, NM 87505 Phone (505) 476-4300 Email: Excess Emissions Reporting Form SECTION Al Number; I 198 Emission Unit No.: Activity Number: 000198w09292016u04 Emission Unit Desc: Facility Name: Navajo Refining Company LLC Release Point No.: Company Name: - Navajo Refining - Artesia Refinery Release Point Des_c.: . Unit 55 General Plant, Racks, and Flares Alky Flare Source Is: I ?Stationary Source? Yes Discovery Date/Time: - 11/01/2015 00:00 Portable Source? - No Start Date/Time: - 11/01/2015 00:00 Portable Location: UTM: End Date/Time: Lat: Long: 1st Business Day after 11/02/2015 'Discovery:_ . 3. - Title Permit No.: - - . - Submission Status: Initial EER NSR Permit No.: Firstname/ Lastname: Raymond Smalts Office Phone: 575?746-5490 Extn.: E-mail Address: CellPhone: SECTION . Reporting Requirement: . 3i? Malfunction sf? 20.2.7 NMAC {j Startup at? 20.2.70 NMAC (Title V) .. $1 Shutdown 40 CFR 60 (NSPS) .l Emergency 40 CFR 63 (MACT) .. :1 Schedule Maintenance 355? Title Deviation 88 or SM Notification; :Datez. Explain: Af?rmative Defense Claim: Yes Page 1 of 2 EPA Inspection Report - Page 551 of 1969 sEcTioN iv -. cAusE AND NATURE OF EVENT Detailed Description: It was discovered that on approximateiy 11/01/2015, Navajo had potentially exceeded the permitted TPY iimits for 802, CO, and VOC. SECTION STEPS TAKENETQ LIMIT DURATION oi: excess Emissioiv 'f . Detailed Description: SECTIW VI MEASURES TAKEN Detailed Description: SECTIONVIH - . -. l' [Duration of Pollutant . Event . - section ix EBA-SIS ESTIMATE 1? - . Compiiance Testing 23 Continuous Emission Monitor ii Calculation .- Operating Log(s) E?_i Other: Limits or Averaging _:_E:fi::isons for -. .__Pe_rio_d Event . 1 Numberof _--gvgrafgepEmis_sion Exceedences or_ s'gcTioN x_ -'s'ubmissi_bii By clicking on the Certify button, I agree to the following: After reasonable inquiry, certify this report as true, accurateand complete: . Titie: Reporting Official: Raymond Smalts Environmental Specialist Date: 09/29/2016 Page 2 of 2 EPA Inspection Report - Page 552 of 1969 New Mexico Environment Department - Air Quality Bureau Compiiance and Enforcement Section 525 Camino de Los Marquez - Suite 1 - Santa Fe, NM 87505 Phone (505) 476-4300 - Email: Excess Emissions Reporting Form INFORMATION. f' Al Number: 198 Emission Unit 2- Unit 55 Activity Number: '2000198-?09292016?05 Emission Unit Desc: Genera! Plant, Racks, and Flares Facility Name: I Navajo Refining Company LLC Release Point No.: Company Name: Navajo Refining Artesia Refinery Release Point Deso: . - Flare Source is:_ Stationary Source? 1 Yes Discovery Date/Time: - 11/01/2015 00:00 Portable Source? . N0 Start Date/Time: 11/01/2015 00:00 Portable Location: UTM: End Date/Time; I . . . Lat: Long: 1st Business Day after 11/02/2015 Discovery: Titie Permit No.: . .- .. Submission Status: initial EER NSR Permit No.: PSDO195-M37 Firstname/ Lastname: Raymond Smalts . Office Phone: . 575?746-5490 E-maii Address: . . I . Cell Phone: semen TYPE Reporting Requrrement: Malfunction I 2- $8 or SM Notification: s3 20.2.7 NMAC Stamp . .- - .I - Date: 2:3 20.2.70 NMAC (Title V) . . $3 Shutdown is? - Explain: Ll 40 CFR 60 (NSPS) . . - - :3 Emergency - 40 CFR53 (MACT) . I I Maintenance I I Title Deviation - - - FAffirmative Defense Claim: Yes Page 1 of 2 EPA Inspection Report - Page 553 of 1969 _Iy' - CAUSE AND EVENT - Detailed Description: it was discovered that on approximately 11/01/2015, Navajo had potentially exceeded the permitted TPY limits for NOX, 802, CO, and VOC. TAKEN DURATIQN or EXCESS EMISSION, Detailed Description: sleicno'ri Detailed Description: .- of Pollutant - . [Event Emission Limits or. Ayeraging "Standards ..P_eri_od SECTION IX .- -- . 3 Compliance Testing :1 Continuous EmissionMonitor Ll Calculation Ll Operating Log(s) :3 Other: ..I Event 'I'Ex'cess I 7 Emission - . .. - - _EmIsSIonsfor -_Exc_e_edence5_ .. _Rate for _P_erlod_._ By clicking onthe Certify button, 3 agree to the following: . After reasonable inquiry, i certify this report as true, accurate and complete. Reporting Official; Raymond Smalts Titl_e:: - I: Environmental Specialist Date: 09/29/2016 Page 2 of 2 EPA Inspection Report - Page 554 of 1969 New Mexico Environment Department - Air Quality Bureau Compliance and Enforcement Section 525 Camino de Los Marquez - Suite 1 Santa Fe, NM 87505 Phone (505) 476-4300 - Email: Excess Emissions Reporting Form Number: - 198 Emission Unit No.: _Unit 55 Activity Number: . 000198?09292016-06 - Emission Unit Desc: . General Plant, Racks, and Flares Facility Name: Navajo Refining Company LLC ReleasePoint No: Flare Malf Cap Company Name: Navajo Refining Artesia Refinery Release Point Deso: .. . Upset and Malfunction Emissions Source is: 3 Stationary Source? Yes DiscoveryDate/Time; 11/01/2015 00:00 Portable Source? NO Start Date/Time: 11/01/2015 00:00 Portable Location: . IE-nd Date/Time' I Lat; . Long: st Business Day after 11/02/2015 -- Discovery: TitleVPermitNo.: - P051-R2M1 - Submission Status: _lnitial EER NSR Permit No.: . PSD0195-M37 - - Firstname/ Lastname: Raymond Smalts Office Phone: _575?746n5490 .Extn.:_ E-maiiAddress: Cell Phone: Reporting Requtrement:__ Malfunction - .I I SS or SM Notification: 0.2.7NMAC - . - - 2 - . i?J Stamp - - . Date: e3 20.2.70 V) Shutdown . . . Ex lain: 3:3 40 CFR-63 (MAST) . :3 Schedule Maintenance I g? Title Deviation I I Affirmative Defense Claim: Yes Page 1 of 2 EPA Inspection Report - Page 555 of 1969 sectioN Iv - ZCAuse AND NATUREQF EVEN-T. I Detailed Description: I I i I it was discovered that on approximately 11/01/2015, Navajo had potentially exceeded the permitted TPY limits for NOX, 802, CO, and VOC. section To EMISSION. Detailed Description: -. SECTION _vi-chREcTIvE I Detailed Description: SECTION _VlEi excess EMISSION DETAIL LINES . Pollutant - - Event L'mits . ?EmiS'Sions for 5 - - - Standards Period - - - - - -- Event I Average-Emission - Rate for Averaging :Pe?od . Number of. Exceedences By clicking on the Certify button, 1 agree to the following: are-w Compliance Testing After reasonable inquiry, certify this report as true, accurate and complete. Em} Continuous Emission Monitor - . - - -. . L3 Calculation . . . Reporting Offi_c1a1: Raymond Smalts :3 Operating Title: - Environmental Specialist Other: - Date: 09/29/2016 Page 2 of 2 EPA Inspection Report - Page 556 of 1969 Version 05.02.13 Lg?. .7 . n? 11" I, if? Llii II II- 9-0271 NMED USE ONLY it? New Mexico Environment Department 3 -- Air Quality Bureau Compliance and Enforcement Section 525 Camino de [es Marquez, Suite 1 Santa Fe, NM 87505 Phone (5:35) 476-43111] Fm.- (5115} 4745-4375 NMED USE ONLY Scott Benton Environmental Manager Scott Denton TEMPO REPORTING SUBMITTAL FORM Staff 0022' Admin Aw:? PLEASE NGTE: IE - Indicates required iield A 1 3 SECTION I - GENERAL COMPANY AND FACILITY INFORMATION A. @Company Name: D. 61 Facility Name: HoIIyFrontier Navajo Re?ning LLC Navajo Re?ning LLC 3.1 Company Address: [5.1 (E) Facility Address: PO Box159 501 E.Main St. 3.2 1E City: 3.3 State: 3.4 131 Zip: Ed! City: E3 15} State: E.4 Zip: Artesia NM 83211-01591 Artesia val 3821!] {3.1 to Company Environmental Contact: 0.2 to Title: F.1 a Facility Contact: F.2 a Title: Environmental Manager (2.3 Phone Number: (3.4 0'3) Fax Number: STE-7466451 F.3 it} Phone Number: 5?5-746?5487 FA 13 Fax Number: 575-?45-5451 (3.5 ?t Email Address: Scott. F.5 (E) Email Address: G. Resoonsible Official: 11 tile It only}: Robert K. O?Brien H. Title: ?v?ice President <1 Re?nery Manager, Holinrontier Navajo Re?ning LLC Phone Number: 575-745?331 1 J. Fax Number: 57'5-7'46-5451 K. Number: L. Title Permit Number: M. Title Permit Issue Date: N. NSR Permit Number: 0. NSR Permit Issue Date: 198 P051-R2M1 6 UBI12I2016 P. Reporting Period: From: [1910112017 To: D8!31t2018 SECTION II TYPE OF SUBMITTAL (check one that applies) A Title?v? Annual Compliance Permit Conditiontsi: Description: Certification A109 Annual Compliance Certi?cation Title Semi-annual Permit Conditionlsi: Description: Monitoring Report Reoulation: Sectiontsl: Descr?ot'on: NSPS Requirement I I It': MACT Requirement can a :on ac ten 5 escrlo Ion (cecmee) NMAC Requirement Reoulation: Sectionisl: Description: E. (20.2.:ch or NESHAP Requirement Permit or NDI Conditionts): Description: Permlt or Notice of Intent Requirement NEW No. or No. El: Sectionts): Description: Re uirement of an . . Action EL or Other D- SECTION IV - CERTIFICATION After reasonable inquiry, Robert K. lO'Brien [name at reporting cilitiul] certin that the information in this submittai is true, accurate and complete. IE Signal Reporting Official: Ux/scb?Kiizvz?ff CC g4? 13 Title: Date Vice President 3. Re?nery Manager, HoIIyFrontier Navajo Refining LLC Rasponsihle DfIitiuI for Title Yes No Reviewed By: Date Reviewed: EPA Ins ection Report - Page 557 of 1969 . New Mex1co EnVIronment Department Air Quality Bureau Compliance and Enforcement Section 525 Camino de los Marquez, Suite 1 Santa Fe, NM 87505 Phone (505) 476?4300 Fax (505) 476-4375 Version 05.02.13 NMED USE ONLY TEMPO PLEASE NOTE: - Indicates required field REPORTING SUBMITTAL FORM NMED Staff Admin SECTION FACILITY . .. .. . . . . .. A. Company Name: Navajo Re?ning LLC D. Facility Name: Navajo Refining LLC BA Company Address: E.1 Facility Address: PO Box 159 501 E.Main St. B.2 City: 8.3 State: 3.4 Zip: 5.2 City: E.3 State: E.4 Zip: Artesia NM 8821 Artesia NM 88210 0.1 (E) Company Environmental Contact: {3.2 GB Title: F.1 Facility Contact: F.2 Title: Scott Denton Environmental Manager Scott Denton Environmental Manager C.3 Phone Number: C.4 Fax Number: 575-746-5451 F.3 Phone Number: 575-746-5487 F.4 Fax Number: 576-746-5451 C.5 Email Address: F.5 Email Address: G. Resoonsible Official: (Title onlvl: Robert K. O?Brien H. Title: Vice President 8. Refinery Manager. HoilyFrontier Navajo l. Phone Number: 575-748-331 1 J. Fax Number: 575-746-5451 Refining LLC K. Al Number: L. Title Permit Number: M. Title Permit issue Date: N. NSR Permit Number: 0. NSR Permit Issue Date: 198 P051-R2M1 01i22i2016 PSD-NM-O195-M37 08i12i2016 P. Reporting Period: From: 09i01z?201? To: 08l31l2018 (check one thataPPlies) A Title Annual Compliance Permit Conditionls): Description: A Certification A109 Annual Compliance Certification l:l Titje Semi-annual Permit Conditionlsl: Description: Monitoring Report Reuulation: Sectionlsl: Descriptiori: l:l NSPS Requtrement (4DCFR60) Regulation: Sectionlsl: Description; l:l MACT Reqwrement (4DCFR63) NMAC Requirement Regulation: Sectionlsl: Description: E. (20.2.xx) or NESHAP Requirement (4DCFR61) Permit or Condition(s): Description: l:l Permit or Notice of Intent (NOI) Requirement NOV N013: or SFO No. Section(s): Description: Requirement of an . . '1 Enforcement Action or CD No. or Other EL After reasonable inquiry, Robert K. O'Brien [name of reporting official} certify that the information in this submittal is true, accurate and complete. Navajo Refining LLC of Reporting Official: Title: Date Responsible Official for Title Vice President Refinery zf: Manager, 09l2712018 Yes No Reviewed By: Date Reviewed: EPA Inspection Report - Page 558 of 1969 September 27, 2018 Enforcement Manager Air Quality Bureau Enforcement Certi?ed Mail/Return Receipt NM Environment Department 7015 0640 0006 6577 6.992 525 Camino de los Marquez, Suite 1 Santa Fe, New Mexico 87505?1816 Re: Navajo Re?ning LLC Artesia, NM Re?nery Title Operating Permits Annual Compliance Certi?cation Agency Interest No. 198 Reporting Period September 1, 2016 through August 31, 2017 On behalf of Navajo Re?ning LLC (Navajo), I am submitting Navajo?s annual compliance certi?cation (ACC) for the Artesia, NM Re?nery. Title Operating Permit l?051?R2Mi Reporting Period: September I, 2017 through August 3 l, 2018 Consistent with the initial compliance certi?cation, items identi?ed during work practices, such as fugitive component monitoring inspections, that are corrected or repaired within the regulatory timeframe and that are properly documented, do not comprise exceptions or deviations. Please feel free to contact me at (575) 7466487 or Ray Smalts at (575) 746-5490 if you have any questions or should require any further information. Sincerely, Scott M. Denton Environmental Manager Navajo Re?ning LLC PO. Box 1.59 Artesia, New Mexico 8821 10159 Phone: (575) 746-5487 E?mail: Enclosure cc: US EPA (wfenc): Chief, Air Permits, US. EPA Region 6 1445 Ross avenue, Suite 2200, Dallas, TX 75202?2233 Navajo: R. O?Brien, W. Rominc, G. Combs, R. Smalts, S. Hammond Environmental File: 2.10 Annual Compliance Certi?cations (Title V)\Artesia Certi?catiom2018 Artesia 2? Artesia Title Annual Compliance Ccrti?cationpdf Navajo Re?ning LLC 501 East Main Artesia, NM 88210 (575) 7483311 - EPA Inspection Report - Page 559 of 1969 Title Report Certi?cation Form 3 . 332?; w" ?shy. ?si" I Annual Compliance Certi?cation 1: Semi?Annual Monitoring Report 0 I Other ecif Artesia Re?nery lity Name LL, 09.! ear?1 :9 1: tag 5 ?9 tr?: D?r 0:53 0.0 ..D Hm A 50"? .: >3 mm on.) 2 ,9 72?s: oo .ceoo a) HVFcos-4 09>? ca ?50] 07?? at undo DO '52 (1)935 .. a 0 Eco-.9 ?agog? 5 bgof?w 1:439 -I?l CG -r$90053 5 8*82 ts of 20.2.70.7.AD iremen certify that 1 meet the requ 161] ble Of?cial indicated above. 1, Robert K. NMAC. I certify that, based on information and belief formed after reasonable inquiry, the statements and information spons1 I am the Re he attached Title report are true, accurate, and complete. dint containe .3 09/27/2018 Date a PW /fgzw/? 1gnature EPA Inspection Report - Page 560 of 1969 Title Annual Compliance Certi?cation for Permit east-?a2 RZME Title (TV) Permit Administration Amendment On January 22.. 201.6 NMED AQB issued an Administrative Amendment to Operating Permit The Administrative Amendment Pii?inZM 1 corrected the following: a The Department acknowiedges the name change from Navajo Refining Company5 LLC. to Holiyiirentier Navajo Refining LLC. For this is an Administrative Amendment the facility can use one Annual Compliance Certi?cation (ACC) Form which will cover both TV Permits. Although the facility is only required to submit one ACC Form, the facility shall submit two (2) separate TV Report Certi?cation Forms. Each form shall list the corresponding TV Permit number, TV Permit Issue Date and Reporting Period. Please note that this is a one-time authorization. Submittal forms for future Administrative Revisions will be evaluated on a case by case basis. This form can also be used for future submittal that cover only the permit. EPA Inspection Report - Page 561 of 1969 Part 1 - Permit Requirements Certi?cation Table ..: Methods) Dir-othermfohiiatlon or other facts used to . 3. What IS the 4. Was facility In 5- Were there any - - -.'determine the compliance status: {fret'mency of data - compliance with this deviations associated -. collection used to _-requirement during the with this requirement determine .. '_reporting period? during the reporting FACILITY SPECIFIC El Continuous Yes Yes REQUIREMENTS IE Intermittent No No A101 Permit Duration (expiration) A. The term 0 this permit is ?ve (5) Navajo submitted the application for renewal on - September 11, 2013. years. It expire ?ve years from the date of issuance. Application for renewal of this permit is due twelve (12) months prior to the date of expiration. (202.70.300.32 and 302B NMAC) A101 Permit Duration (expiration) El Continuous Yes Yes B. If a renewal permit is not issued prior Intermittent to the ex iration date, the ermittee Navajo submitted the for renewal on continue to operate beyond the expiration September ll, 2013. date, prov1ded that a timely and complete renewal application is submitted no later than twelve (12) months prior to the expiration date. (20.2.70.400.D NMAC) A102 FaCility: Description Continuous Yes Yes . .. . . . . . Thisitlel t? fN ?ne. - B. facxlity IS located in the City limits 1 ma mu 0 avajo re ry Interm?ttent of Artesia, NM. This-permit condition provides a list of theapplicable El Continuous El Yes Yes A103 Facility: Applicable Regulations requrrements that are addressed in detail in other permit conditions but does not impose any speci?c Intermittent No El No A. The permittee shall comply with all applicable sections of the requirements listed in Table l03.A standards, monitoring, recordkeeping, or reporting requirements. Therefore, no further response is required. As instructed by the AQB, Navajo is completing the check box responses in columns 3, 4, EPA Inspection Report - Page 562 of 1969 Version 02.25.15 1. Permit Condition and Permit Condition: 3 Method(s) or other information or other facts used to.- "determine the compliance status: the -Was this facility' in there any compliance with this requirement during the With this requirement reporting period? during the reporting . -. iiperiod? . and 5 of this form. Navajo continues to comply with ali applicable requirements except for speci?c deviations as noted elsewhere in this document. (See the speci?c responses to the permit conditions that contain standards, monitoring, recordkeeping, or reporting requirements for more information). ACC Form Part i Permit P051-R2 RZMI Ver 4.1 02/25/2015 Page 3 of 143 EPA Inspection Report - Page 563 of 1969 Version 02.25.15 Table 103.A: Applicable Requirements . . ederall . Applicable Requirements Enforcegble Unit No. NSR Permit No: PSD (Per 20.2.72 NMAC) Entire Facility 20.2.1 NMAC General Provisions Entire Facility 20.2.7 NMAC Excess Emissions Entire Facility . . . . . Affected sources 20.2.33 NMAC Gas Burning Equ1pment?? Nitrogen Diox1de in Table l03.E 20.2.36 NMAC Petroleum Re?nery - Sul?ir Entire Facility 20.2.37 NMAC Petroleum Processing Facilities Entire Facility 20.2.38 NMAC Hydrocarbon Storage Facilities Entire Facility 20.2.70 NMAC Operating Permits Entire Facility 20.2.71 NMAC Operating Permit Emission Fees Entire Facility 20.2.72 NMAC Construction Permit Entire Facility 20.2.73 NMAC Notice of Intent and Emissions Inventory Entire Facility Requirements 20.2.74 NMAC Prevention of Signi?cant Deterioration Entire Facility Units sub'ect to 20.2.77 NMAC New Source Performance 40 CFR 6J0 20.2.78 NMAC Emission Standards for Hazardous Air Pollutants Units subject to (HAPs) 40 CFR 61 202.82 NMAC MACT Standards for Source Categories of HAPS to 40 CFR 50 National Ambient Air Quality Standards Entire Facility 40 CFR 60, Subpart A, General Provisions 3:11:33: 03.K 40 CFR 60, Subpart Db ?Standards of Performance for lndustrial- See Tables Commercialulnstitutional Steam Generating Units? 1033 to 103.] 40 CFR 60, Subpart Dc ?Standards of Performance for Small Steam Generating Units, Which H3101 Construction, Reconstruction, or Modi?cation Commenced After June 9, 40 CFR 60, Subpart J, ?Standards of Performance for Petroleum See Tables Refineries? 103.8 to 1.03.] 40 CFR 60, Subpart Ja, ?Standards of Performance for Petroleum See Tables Re?neries for which Construction, Reconstruction, or Modification 103,]3 to 103,] Commenced After May 14, 2007? ACC Form Part 1 Permit Ver 4.1 02/25/20l5 Page 4 of 143 EPA Inspection Report - Page 564 of 1969 Version 02.25.15 40 CFR 60, Subpart K, ?Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modi?cation Commenced After June 11, 1973, and Prior to May 19, See Tables to 103 .J 40 CFR 60, Subpart Ka, ?Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modi?cation Commenced After May 18, 1978, and Prior to July 23, 1984? See Tables to 103k 40 CFR 60, Subpart Kb, ?Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modi?cation Commenced After January 23, 1984? See Tables to 03K 40 CFR 60, Subpart Standards of Performance for Equipment Leaks of VOC in Petroleum Re?neries for which construction, reconstruction, or modi?cation commenced after January 4, 1983, and on or before November 7, 2006. See Tables to 103K 40 CFR 60, Subpart Standards of Performance for Equipment Leaks of VOC in Petroleum Re?neries for which construction, reconstruction, or modi?cation commenced after November 7, 2006. See Tables 103B to 103K 40 CFR 60, Subpart Standards of Performance for VOC See Tables Emissions From Petroleum Refinery Wastewater Systems 1033 to 103K 40 CFR 60, Subpart HII, Standards of Performance for_Stati0nary See Tables Compression Ignition Internal Combustion Engines 103.B to 103.K 40 CF 61, Subpart A, General Provisions Entire Facility 40 CFR 61, Subpart FF, National Emission Standards for Benzene Benzene Waste Waste Operations Operations 40 CFR 63, Subpart A, General Provisions Entire Facility 40 CFR 63, Subpart Q, National Emission Standards for Hazardous See Table Air Pollutants for Industrial Process Cooling Towers 103.F See Tables 40 CFR. 63, Subpart CC 103.13 to 103K See Tables 40 CFR 63 Subpart 103.9: to 103K . . . See Tables 40 CFR 63 Subpart Petroleum Re?neries: Catalytic Crackrn 1 03 Units, Catalytic Reforming Units, and Sulfur Recovery Units m] 0 ACC Form Part 1 Permit 8: Ver 4.1 0295/2015 Page 5 of 143 EPA Inspection Report - Page 565 of 1969 Version 02.25. 5 40 CFR 63, Subpart National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines See Tables 103 .B to 103.KJ 40 CFR 68, (RMP), Section 1 120?) Accidental Release Entire Facility 3/5/2002 Consent Decree 1422LH Lodged 12/20/2001, Entered Entire Facility Tabie 103.B Summary Applicability-Fugitives Titie Permit Description 20.2.3? MACT NSPS NSPS NSPS NESHAP NESI-IAP Unit CC CC FUG-O2-SP CRUDE South Division Crude Unit YES YES NO YES YES NO NO NO FUG-OS-KERO Kerosene HDS Unit JPS Hydrodesultin'ization AMINE Amine UnitJI?reatingRegenYES PUG-07-SWS2 Sour Water Stripper YES Loading Racks ALKY North Alkyiation Unit (New-Inside batteiy limitsFCC waVS YES YES YES NO YES NO NO NO Naphtha HDS Unit YES YES YES NO YES NO N0 N0 MEROX Merofo erichern Treating Units FUG-20-ISOM Powerformer??enex Unit waVS VACUUM FlasherNacnum Unit EUG-ZS-ROSEQ ROSE Unit YES YES NO YES YES NO NO NO FARM Light Oi] Tankage PUG-3 SRU3 Unit YES YES NO YES YES NO NO NO Reiocatod Diesel HDS Unit waVS YES YES YES NO YES NO NO NO FUG-34-HYDROCRACKER WX I-Iydroeracker YES YES NO YES YES NO NO NO FUG-35-SAT GAS Saturates Gas Plant PUG-4 i -PBC PBC Unit PUG-43S ALKY South Aiky Unit (W36Gas Oil Hydrotreater (incl. CVSACC Form Part 1 Permit POSI-R2 R2M1 Ver 4.1 02/25/20} 5 Page 6 of 143 EPA Inspection Report - Page 566 of 1969 Version 02.25.15 between iaileais and trucks. FUG-45-DIST-HDU Gas Oil Hydrotreater (inclPUG-63412 Hydrogen Plant ?1964412 PLANT-3 Hydrogen Plant UG-70-CCR CCR. Reformer (WK in battery limitsFUG-73-SP UTIL Utilities PUG-80W CVS Oil/Water Separator YES YES YES NO YES NO NO YES STG Asphail?fl-Ieavy 011 Storage GAS Fuel Gas Distribution System LPG Storage System ALT Asphaitf'l?itch Loading Rack YES Crude oil unloading system, closed loop system ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 7 of 143 EPA Inspection Report - Page 567 of 1969 Version 02.25.15 Table 103.C, Summary Applicability 1m MACT NSPS NSPS NSPS CC MACT CC NESHAP NSPS 20.231205 20.2.38.]09 20.2.38.110 20.2.38.112 20.2.38.113 CA Tank No. Ka Kb Storage Wastewater FF NMAC NMAC NMAC NMAC NMAC RWRWT-0002 ?130003 T-0012 T-0013 T-0028 T-0040 "110041 T-0042 T-0045 ~{-0046 T-0055 T-0056 13-0059 T006 T-0063 T-0064 ?if?0065 ?130072 ?110073 T-0074 T-OO78 T-0079 T-0081 ACC Form Part 1 Permit R2M1 Page 8 of I43 Ver 02/25/2015 ?171 J0 6 939d SIOZISZIZO ['17 19A 78? II i 133d DOV 17170[.171709171701 68701 8E1?0E1701 179701 ?97011$1701 ZZVOZL 170?]; 1701 ?11701 $1170112311701111170114 011701 601701 901701 1701701 301701 00?90172 {O9110'}; SHOZL SOIOZL 90i038001 696140 899 989d 1J0d98 Vd3 EPA Inspection Report - Page 569 of 1969 Version 02.25.15 T-0449 T-0450 T0453 T-0460 T-0465 T-0467 T-0468 T-0600 T-0737 13-0802 T-0804 T-0807 T-0809 T-0810 T-0816 T-0830 T-0834 T0839 T-0840 T-0891 T-1223 T-1224 T-1225 BioDiesel Ethanol ACC Form Part I Permit R2M1 Ver 4.1 02/25/2015 Page 10 0f143 EPA Inspection Report - Page 570 of 1969 Version 02.25.15 Table 103.1), Summary Applicability Unit Description MACT CC 20.2.37.205.C MACT MACT CAM Fuels Truck Loading Rack YES NO NO NO NO Truck Loading Rack NO NO NO NO NO RLO-8 Railcar Loading Off-Loading Rack NO NO NO NO NO Table 103.E, Summary Applicability Heaters and Boilers . . . NSPS NSPS NSPS MACT 20.233.103 20.2.36 20.2.37 Umt ID DeSCI?lpthIl - Db Dc NSPS NSPS CAM 0-0007 Boiler B-0008 Boiler 130009 Boiler H-0009 Um? 13 NaPhFha 39?1Reborler 21;; :31H-0018 Unit 06 HDS Reboiler south Elga?fmrge somh H-0028 Unit 21 Heater H-0030 Unit 06 Charge Heater H-0040 Unit 13 Charge Heater H0303 Unit 05 Charge Heater {ti-0312 Unit 10 FCC Feed Heater H-0352 Unit 70 ?gielfefomeEf?eljefomer 11-0354 70 Elg?gefomer Stablhzer Rebo?er Heater H-0362 Unit 70 CCR Heater H-0363 Unit 70 CCR Heater ACC Form Part 1 Permit P051-R2 R2MI Ver 4.1 0295/2015 Page 11 of 143 EPA Inspection Report - Page 571 of 1969 Version 02.25.15 H0364 Unit 70 CCR Heater Unit 44 Charge Heater H-0464 SRU Hot or: Heater H-0473 and .SRU2 Tall Gas Incmerator H-0600 09 DeprOPamzer Reborler Heater H0601 Unit 33 Charge Heater Unit 45 Charge Heater H?ggm/ 63 Hydrogen mam H-8802 Reformer 13-3402 34 Hydrocmker Reborler 1 H3403 HydrocraCker ReamCharge Heater H9 851 64 Hydrogen Plant Reformer Unit 25 Unit N02 Hot Oil Heater H-3101 (formerly SRU3- SRU3 Hot Oil Heater HOH) Tall Gas Incmerator ACC Form Part 1. Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 12 of 143 EPA Inspection Report - Page 572 of 1969 Version 02.25.15 Table 103.F, Summary Applicability - Cooling Towers Cooling Tower Description MACT MACT CC CAM TCC Cooling Tower YES YES NO Y-0002 S. Alky Cooling Tower (Marley Cooling YES YES NO Tower) Y-0008 North Alky Cooling Tower YES YES NO Y-0011 FCC NP Cooling Tower NO YES NO Hydrogen Plants Cooling Tower NO YES NO CT Unit 07 Amine Wm0745 Cooling Tower NO NO NO Table 103.G, Summary Applicability Wastewater Emission Point MACT CC Equipment ID ID Wastewater NESHAP FF NSPS CAM MAIN API YES YES YES NO BAP-0896 YES YES NO NO BAP-0806 BAP-0806 YES YES NO NO T0801 YES YES NO NO T0805 YES YES NO NO T0829 YES YES NO NO T-0836 YES YES NO NO T-0897 YES YES NO NO Table 103.}1, Summary Applicability FCC-CCR MACT 20.2.37 Unit ID NSPS NSPS Ja NMAC CAM FCCREGEN YES NO YES YES YES - Satis?ed by MACT CCR YES NO ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 13 of 143 EPA Inspection Report - Page 573 of 1969 Version 02.25.15 Table 103.1, Summary Applicability SRU Source Emission NSPS NSPS MACT ID Point ID Description Ja 20.2.37.200B 20.2.37.202.A 20.2.39 CAM H-0473 and SRU2 Tail YES NO YES YES YES YES NO YES-Satisfied Gas Incinerator by MACT SRU2 and SRU2 Tail YES NO YES YES YES YES NO YES~Satis?ed Gas Incinerator by MACT SRU3 SRU3-TGI SRU3 Tail Gas YES~Satis?ed Incinerator by MACT Table 103.J, Summary Applicability - Engines 20.2.61.109 20.2.61.114 Source ID Description NSPS MACT NMAC NMAC CAM E-0600W Fire Water Pump Engine YES YES YES YES NO Fire Water Pump Engine YES YES YES YES NO Fire Water Pump Engine YES YES YES YES NO E-0603 Fire Water Pump Engine YES YES YES YES NO E-0901 Fire Water Pump Engine YES YES YES YES NO G-0100 UPS backup generator NO YES YES YES NO 01 UPS backup generator NO YES YES YES NO V-05 43 Portable Air Compressor YES YES YES YES NO Portable Air Compressor YES YES YES YES NO V-05 46 Portable Air Compressor YES YES YES YES NO E-8010 WWTP Emergency Engine YES YES YES YES NO ACC Form Part 1 Permit P05 1 R2M1 Ver 4.1 02/25/2015 Page 14 of 143 EPA Inspection Report - Page 574 of 1969 Version 02.25.15 Table Summary Ap licability FLARES NESHAP 20.2.36.112 20.2.36.113b 20.2.37.2OIB Unit ID Description NSPS A NSPS NSPS a A MACT A NMAC NMAC NMAC North Plant Flare YES NO YES NO YES YES YES YES South Plant Flare YES NO YES NO YES YES YES YES FCCU Flare YES NO YES NO YES YES YES YES FL-403 Alky Flare YES NO YES NO YES YES YES YES FL-404 GOHT Flare YES NO YES NO YES YES YES YES All ?ares are steam assisted. State of New Mexico requires that an exit gas velocity of 65 ft/sec for modeling. The heating value of the gas for all ?ares is 1000 BTU/scf. This. permit condition provides a list of the l:l Continuous El Yes Yes applicable requ1rements that are addressed in detail A103 Applicable Regulations in other permit conditions but does not impose any IXI Intermittent No No speci?c standards, monitoring, recordkeeping, or Compliance With. the terms and reporting requirements. Therefore, no further ofthis permit regarding source response is required. As instructed by the AQB, emissions and Operation demonstrate Navajo is completing the check box responses in compliance with national ambient air columns 3, 4, and 5 of this form. Navajo continues quality standards speci?ed at 40 CFR 50, to comply with all applicable requirements except which were applicable at the time air for speci?c deviations as noted elsewhere in this dispersion modeling was performed for the document. (See the speci?c responses?to the permit facility? NSR Permit conditions that contam standards, monitoring, recordkeeping, or reporting requrrements for more information). This permit condition provides a list but does not l:l Continuous El Yes Yes A104 Facility: Regulated Sources impose any standards, monitoring, recordkeeping, or reporting requirements. Therefore, no further El Intermittent No No A. Table 104.A lists the emission units response is required. As instructed by the AQB, authorized for this facility. Emission units Navajo is completing thecheck box responses'in identi?ed as insigni?cant 0r trivial columns 3, 4, and 5 of this form. l?lavajo contmues activities (as de?ne in 20.2-70.7 NM A C) :00 comply With all'applicable requirements except or spec1fic dev1at10ns as noted elsewhere in this and/or equ?pmeT?t not regulated pursuant to document. (See the speci?c responses to the permit the Ad are not included. conditions that contain standards, monitoring, recordkeeping, or reporting requirements for more ACC Form Part Permit P051-R2 R2MI Ver 02/25/2015 Page 15 of I43 EPA Inspection Report - Page 575 of 1969 Version 02.25.15 information). ACC Form Part 1 Permit R2M1 Page 16 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 576 of 1969 Version 02.25.15 Table 104.A: Regulated Sources List Unit No. Unit Type Manufacturer Model o. Mangzigture Capacity 3?0007 Boiler 7 Todleohn Zink burners Unknown 10i'8l2001 215 (LHV Basis) 8-0008 Boiler 8 Todleohn Zink burners Unknown 2003 215 MMBtulhr (LHV Basis) 3?0009 Boiler 9 Babcock Wilcox TBD "3'80 220 MMBtulhr (LHV Basis) 5-8010 WWTP Diesel Pump Engine John Deere RGBOQOL101484 232011 400 hp E-OESUOW Fire Water Pump Engine Clarke Diesel (John Deere) 71201 2 376 hp 5060?? Fire Water Pump Engine Clarke Diesel (John Deere) 7/2012 hp E- 0 6 02 Fire Water Pump Engine Clarke Diesel (.lohn Deere) ?22323; 111:2); W2012 376 hp E-0603 Fire Water Pump Engine (lilarke Diesel (John Deere) $226552):ng 2012 305 hp Fire Water Pump Engine Clarke Diesel (John Deere) JR??gzgg? 61 18 3022007 430 hp @0100 UPS backup generator Dents hngme ?rmly 1998 52 hp (5-0101 UPS backup generator Deutz ION Fr 5191-68CA00-000-0053 1999 54 hp Pmtable Air Compressor Cummings, Inc. QSC, 7310461 1 8f30i?201 0 260 hp V-0545 Po?able Air Compressor Cummings, Inc. QSC, 73142120 4i'8l'2011 260 hp V-0546 Portable Air Compressor Cummings, Inc. QSC, 46917364- 1 1/19l'2008 240 hp H-0009 Unit 13 Naphtha Splitter Reboiler Zeeco burners GSFW-12 burners Unknown 44 MMBtulhr(Ll-1V Basis) Unit 21 Vacuum Flasher Heater Unknown Unknown Unknown 38 MMBtu?nr (LHV Basis) H-0018 Naphtha HDS Reboiler Zeeco burners GSFW-B burners Unknown 32 MMBtulhr (LHV Basis) Callidus Technologies, LLC South Crude Charge Heater burners CUBL-BW burners New burners in 2005 54 MMBturhr (LHV Basis) Callidus Technologies, LLC H-0020 South Crude Charge Heater burners CUBL-12W burners New burners in 2005 78 MMBtulhr (LHV Basis) 14?0028 Unit 21 Heater H-28 (previously H-10) John Zink burners 2 burners Unknown 12.3 MMBtul?hr (LHV Basis) Unit 06 Charge Heater John Zink burners PSFG-16R burners 2000* 42 (LHV Basis) H-0040 Unit 13 Charge Heater John Zink burners PSFG-16 burners 1990* 42 MMBtufhr (LHV Basis) H-0303 Unit 05 Charge Heater John Zink burners burners 1982* 11 MMBtulhr (LHV Basis) H-0312 Unit 10 FCC Feed Heater John Zink burners WD-18 burners 1990* 35 MMBtulhr (LHV Basis) Callidus Technologies, LLC H-0352 Unit 7'0 CCR Heater (previously 70-1-11) burners CUBL-10W burners New burners in 2006 63 MMBtufhr (LHV Basis) Callidus Technologies, LLC H-0353 Unit 70 CCR Heater (previously 704-12) burners CUBL-10W burners New burners in 2006 81 MMBtua'hr (LHV Basis) Callidus Technologies, LLC H-0354 Unit 70 CCR Heater (previously burners CUBL-10W burners New burners in 2006 56 (LHV Basis) Unit 70 Stabilizer Reboiler Heater H-355 H-0355 (previously 70H-4) John Zink burners Unknown 1991* 24 MMBtulhr (LHV Basis) Callidus Technologies, LLC H-0362 Unit 70 CCR Heater burners burners New burners in 2006 40 MMBtulhr (LHV Basis) Callidus Technologies, LLC H-0363 Unit 70 CCR Heater burners burners New burners in 2006 50 MMBtulhr (LHV Basis) ACC Form Part 1 Permit P05 l?R2 Ver 4.1 02/25/2015 Page 17 of 143 EPA Inspection Report - Page 577 of 1969 Version 02.25.15 Calttdus Technologies, LLC Unit 70 CCR Heater burners CUBL-6W burners New burners in 2006 35 MMBtuihr (LHV Basis) H-0421 Unit 44 Charge Heater (previously H-21) John Zink burners burners 1981* 27 MMBtufhr (LHV Basis) Callidus Technologies, LLC SRU Hot Oil Heater burners burners 2003* 9.6 MMBtulhr (LHV Basis) Depropanizer Reboiler Heater {previously Callidus Technologies, LLC 1991*, New burners in H-0600 3F-1) burners burners 2009 84 MMBtufhr (LHV Basis) Catiidus Technologies, LLC H-0601 Unit 33 Charge Heater burners CUB-BP-CW burners New burners in 2003 78 MMBtufhr Basis) GLSF-14 Round Flame Unit 45 Charge Heater Zeeco, Inc. burners "Free Jet" burners 2006* 27 MMBtufhr (LHV Basis) Callidus Technologies, LLC LE-CSG-12W-PSA H-8801 Unit 63 Hydrogen Plant Reformer Furnace burners burners 2006* 60 MMBtulhr (LHV Basis) Catiidus Technologies, LLC LE-CSG-12W-PSA Unit 63 Hydrogen Plant Reformer Furnace burners burners 2006* 60 MMBtul?hr (LHV Basis) H-2501 ROSEZ Hot Oil Heater John Zink Company, LLC burners COOLstar-18 burners 2009* 120 MMBtulhr(Ll-1V Basis) Callidus Technologies, LLC H-3403 Hydrocracker Reactor Charge Heater burners 0W burners TBD 32.0 MMBtufhr (LHV Basis) Callidus Technotogies, LLC H-3402 Hydrocracker Fractionatoz' Reboiler 1 burners LE-CSG-12W burners 2009* 52 MMBtulhr (LHV Basis) Callidus Technologies, LLC H-9851 Unit 64 Hydrogen Plant Reformer burners CUBL-3WDF burners 2009* 337 MMBtufhr (LHV Basis) Cattidus Technologies, LLC Ha3101 SRU3 Hot Oil Heater burner Unknown 05l?t1l2009 9.6 MMBtufnr (LHV Basis) H-0473 (SRUHSRUZ TGI) and SRUZ Tail Gas Incinerator Unknown Unknown Unknown NA Callidus Technologies, LLC SRU3 Tail Gas Incinerator burners Unknown 05f11r?2009 NA FCC Regenerator FCC Regenerator Scrubber Unknown Unknown Unknown NA CCR Reformer Unknown Unknown Unknown NA North Plant Flare North Plant Flare Unknown Unknown Unknown NA FL-0401, South Plant Flare South Plant Flare Unknown Unknown Unknown NA FL-0402, FCC Flare FCC Flare Unknown Unknown Unknown NA FL-0403, Atky Flare Alky Flare Unknown Unknown Unknown NA FL-0404, GOHT Flare GOHT Flare Unknown Unknown Unknown NA TCC Cooling Tower Unknown Unknown Unknown 5,000 gpm, 0.003% drift 8. Alky Cooting Tower (Marley Cooling Tower) Unknown Unknown Unknown 5,000 gpm, 0.003% drift North Alky Cooling Tower Unknown Unknown Unknown 12.500 gpm, 0.003% drift FCC 8. NP Cooling Tower Unknown Unknown Unknown 30,000 gpm, 0.001% drift Y-0012 Hydrogen Plants Cooltng Tower Unknown Unknown Unknown 10,000 gpm, 0.001% drift CT TT-0006 Unit 07 Amine Cooling Tower Unknown Unknown Unknown 3,000 gpm, 0.003% drift MAIN API Above Ground API Oil?Water Separator Unknown Unknown Unknown 1,200 T-0896 DAF Untt T-0896 Unknown Unknown Unknown 1,200 T-0801 Enhanced Biodegradation Tank 7-0801 Unknown Unknown Unknown 1,200 T-0836 Enhanced Biodegradation Tank T-0836 Unknown Unknown Unknown 1,200 T-0829 Equalization Tank T-0829 Not yet installed Not yet installed Not yet installed 1,200 T-0806 DAF Unit T-0806 Not yet installed Not yet installed Not yet instatled Not yet installed Equipment cornponent leaks (pump seals. Fugitives (see Table 103B) valves, flanges, etc.) NA NA Varies NA Loading (see Table 1030) Bulk LoadinglUnloading Racks NA NA Varies Varies Fixed Roof, External Fioating Roof Tanks {see Table 103C) internal Floating Roof Tanks NA NA Varies Varies Installation date ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 18 of 143 EPA Inspection Report - Page 578 of 1969 Version 02.25.15 Note: Serial numbers are not used since most equipment consists of ?eld erected parts that are assembled on site and may have several ?serial numbers? for various components. Heaters are the best example because each of the burners has a serial number but the heater as a whole does not have a single serial number. The heater as a whole is typically identi?ed by our equipment number. There may also be a ?project number? or ?j ob number? from the manufacturer, but that can change if a heater is revamped at a later date Such as when they modify the convection section to improve energy ef?ciency. A105 Facility: Control Methods A. Table 105 .A lists all the pollution control equipment required for this facility. Each emission point is identi?ed by the same number that was assigned to it in the permit application. This permit condition provides a iist but does not impose any standards, monitoring, recordkeeping, or reporting requirements. Therefore, no further response is required. As instructed by the AQB, Navajo is completing the check box responses in columns 3, 4, and 5 of this form. Navajo continues to comply with all applicable requirements except for speci?c deviations as noted elsewhere in this document. (See the speci?c responses to the permit conditions that contain standards, monitoring, recordkeeping, or reporting requirements for more information). El Continuous Intermittent Yes No El Yes No Table 105.A: Control Methods: C?mlml . . . BACT Pollutant being Colt?)! for Equipment Unit Control Description Unit Yes or No controlled 1 No. Number(s) Fluid Catalytic FCC Regenerator Cracking Unit FCC Scrubber Regenerator Cyclones NO PM 802 Regenerator Wet Gas Scrubber CCR CHLOR CCR Regenerator vent NO Chloride Regenerator Control Vent . . Re?nery FL-0400 North Plant Flare NO VOC H25 . process units ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 19 ofl43 EPA Inspection Report - Page 579 of 1969 Version 02.25.15 South Plant Flare NO voc st RE?nery . process units FL-0402 FCC Flare NO voc Re?nery . process un1ts FL-0403 Alky Flare NO voc Re?nery . process units GOH Flare NO voc Re?nery . process units Portable Flare for Holly Pipeline FL-HEP-PORT Ef?gy Palm?? (HEP) NO voc Pigging . . Operations peratlons Sulfur Recovery Units . No. 2 Tail Gas NO Sulfur SRUI and . SRU2 Inc1nerat0r Selective Catalytic SCR Reduction ultra?10W YES H-9851 burners Sulfur Recovery Unit SRU3 -TGI N0. 3 Tail Gas YES Sulfur SRU3 Incinerator Best Work Practices, A207.B (B ACT) YES SRU3 Mali] API carbon NO voc MAIN API Camsters Drift Eliminators on 1, Y-0012 Cooling Towers YES PM 00?? 1? Y- (BACT) ACC Form Part 1. Permit P051-R2 Ver 4.1 02/25/2015 Page 20 of 143 EPA Inspection Report - Page 580 of 1969 Version 02.25.15 External Floating Roofs (BACT) YES VOC T-0737, T-1225 . External and Internal See Tables Wm Floating Roofs (None- NO voc 106.B(l) and - BACT) (2) Energy Ef?ciency, A204.N (B A CT) Yes Greenhouse Gases H-3402, H- ultra-10w burners Yes Ox 01, 3101 (BACT) 3402, H- H-2501, Combust gaseous fuels Yes VOC, PM 25019 H-3402. 11-3402, only 3101 1 Control for unit number refers to a unit number from the Regulated Equipment List B. In accordance with the requirement that Navajo Re?ning prevent exceedances of the 24-hour and 3-hour National Ambient Air Quality Standards (NAAQS) for 80;; during major re?nery malfunctions, Navajo Re?ning shall only ?are acid gas from existing Flare FL-O403 according to Navajo Re?ning's ?Phase Two? plan dated January 5, 1996 and received by the Department on January 8, 1996, or from Flare FL- 0400. Navajo shall undertake the following measures for acid gas ?aring from FL-O4OO and A RT 0. 1 supp FUEL FOR 502 NAAQS COMPLIANCE, FL-400 90.0 000 2:00 a E00.0 3 50.0 0 a? 40.0 ?0 :3 30.0 20.0 10Supp Fuel Gas Flow (1) Existing Flare FL-O400 shall be equipped with a ?are tip or burners to supply supplemental. fuel gas to provide enough heat to supplement the ACC Form Part 1 Permit P051-R2 R2M1 Page 2} of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 581 of 1969 Version 02.25.15 heat released by combustion of the acid gas itself and the heat provided by smoke-suppressing steam. The minimum ?ow rate of supplemental fuel gas to be supplied during acid gas ?aring such that compliance with the NAAQS for is assured shall be determined using Chart No. l. The fuel gas used for this purpose shall be natural gas (see de?nition at C101.F). (2) Existing Flare shall be equipped with a ?are tip or burners to supply supplemental fuel gas to provide enough supplemental heat. The volume of supplemental ?iel gas to be provided to generate enough supplemental heat to ensure compliance with NAAQS for 302 shall be determined using Chart No. 2. The supplemental heat to be provided when ?aring the maximum quantity of acid gas has been determined to be 52.9 million BTU per hour which is generated by burning 96,200 SCFH of supplemental fuel gas. This assumption has been made to ensure compliance with the NAAQS for $02. The ?Jel gas used for this purpose shall be natural gas (see definition at C101 .F). CHART NO. 2 SUPP. FUEL FOR 802 NAAQS COMPLIANCE, FL-403 4D Supp. Fuel Gas Meow 01001 01 Anti Gas Flow (Thousand SCFH100 Supp. Fuel Gas (Thousand SCFH) Beginning December 20, 2001 no fuel oil. shall be burned in combustion units except as follows: (CD 1l17.C) Torch Oil may be burned in the FCC Regenerator during FCC start-ups; and. (2) Fuel Oil may be burned in combustion units after the establishment of FCC emissions limits pursuant to permit condition A110.A, provided that emissions from any such combustion units are routed. through the FCC Wet Gas Scrubber and Navajo demonstrates, with the approval of EPA, that the emissions limits contained therein and the 802 emissions limits stated in A106.A and A107.A will continue to be met. The Artesia Re?nery FCC was initially limited to less than 20,000 BPD capacity. Following the December 2003 expansion of the Artesia refinery?s FCC as authorized by permit l95?Ml5, the catalyst regenerator for the FCC is subject to the minimum requirements for continuous emission monitoring and recording set forth in Appendix to 40 CFR Part 51. Consent Decree Paragraph 15 required the FCC to be subject to NSPS Subpart for opacity as of December 31, 2003. A wet gas scrubber was installed in 2003. An Alternative Monitoring Plan (AMP) request was submitted to EPA on December 31 2003 because a continuous opacity monitoring system (COMS) will not work on a wet gas scrubber exhaust because of the interference from the water vapor. The AMP satis?es the requirements for both NSPS Subpart and 40 CFR Part 51 Appendix ACC Form Part 1 Permit Page 22 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 582 of 1969 Version 02.25.15 A106 Facility: Allowable Emissions 1:1 Continuous 1:1 Yes Yes A. The following Section lists the emission Nan/511.0 001113111163 to comply WiFh a1] appl?lcable Intermittent No No units, and their a1lowable emission limits. em1ss1on 11m1ts except for specx?c dev1at10ns as (See Table 1 03. A for all applicable noted elsewhere in this document and events regulations) reported per 20.2.7 NMAC. Table 106.A: Allowable Emissions so2 CO 4PM VOC Buuhr Saba-m Btu Source ID 5 ([bfhr) {tonfyn Sablhr) (tom?yr) 5(113mm Btu) 5(11111119 (tom?yr) LHV) (1mm) (tonfyr) 5(lb1?llr) (ton/yr) 13-0007 215 7.8 12.7 12.9 56.5 0.06 19.6 85.7 1.8 7.8 1.3 5.6 13-0008 215 7.8 12.7 12.9 56.5 0.06 19.6 85.7 1.8 7.8 1.3 5.6 13-0009 220 2.6 11.4 4.4 19.3 0.02 BACT 8.1 35.7 1.6 7.2 0.9 3.9 11-0009 44 1.6 2.6 4.0 17.3 0.09 4.0 17.5 0.4 1.6 0.3 1.2 11-0011 38 1.4 2.3 9.5 31.6 - 3.5 15.2 0.3 1.4 0.2 1.0 11?0018 32 1.2 1.9 3.5 15.2 - 2.9 12.8 0.3 1.2 0.2 0.8 110019 54 2.0 3.2 2.9 12.5 0.0527 4.9 21.5 0.4 2.0 0.3 1.4 11?0020 78 2.8 4.6 4.2 18.3 0.0535 7.1 31.1 0.6 2.8 0.5 2.0 311-0028 12.3 0.4 0.7 2.2 9.5 - 1.1 4.9 0.1 0.4 0.1 0.3 11-0030 42 1.5 2.5 3.2 14.0 3.8 16.8 0.4 1.5 0.3 1.1 1.1-0040 42 1.5 2.5 3.8 16.6 3.8 16.8 0.4 1.5 0.3 1.1 31552/0353/0354 63/81/56 7.3 11.8 9.0 39.4 0.045 18.2 79.7 1.7 7.2 1.2 5.2 11-0355 24 0.9 1.4 2.2 9.5 - 2.2 9.6 0.2 0.9 0.1 0.6 110303 11 0.4 0.7 1.2 5.2 - 1.0 4.4 0.1 0.4 0.1 0.3 110312 35 1.3 2.1 4.6 20.2 - 3.2 14.0 0.3 1.3 0.2 0.9 5362/03 63/0364 4050/35 4.6 7.4 6.9 30.1 0.055 11.4 49.8 1.0 4.5 0.7 3.3 11-0421 27 1.0 1.6 2.4 10.6 0.09 2.5 10.8 0.2 1.0 0.2 0.7 11-0464 93.1 5.0 4.7 20.3 0.05 7.6 33.5 0.7 3.03 0.5 2.2 1.1-0601 78 2.8 4.6 3.5 15.4 0.045 7.1 31.1 0.6 2.8 0.5 2.0 11-242] 27 1.0 1.6 1.2 5.3 0.045 2.5 10.8 0.2 1.0 0.2 0.7 11-880178802 60/60 0.2 0.8 4.2 18.4 0.035 10.9 47.8 1.0 4.3 0.7 3.1 11-2501 120 4.4 7.1 3.6 15.8 0.03 7.2 31.5 0.09 BACT 1.0 4.3 0.7 3.1 11-3402 52 1.9 3.1 1.6 6.8 0.03 4.7 20.7 0.09 BACT 0.4 1.9 0.3 1.4 ACC Form Part 1 Permit R2M1 Ver 4.1. 02/25/2015 Page 23 of 143 EPA Inspection Report - Page 583 of 1969 Version 02.25.15 Ver 4.1 02.125/2015 11-3403 32.0 1.2 1.9 1.0 4.2 0.03 2.9 1.2.8 0.3 1.2 0.2 0.8 00125 H-9851 337 0.5 2.2 4.2 18.5 BACT 20.2 88.6 0.06 BACT 2.8 1.2.2 2.0 8.8 11?3101 9.6 0.4 0.6 0.3 1.3 0.03 09 3.8 0.09 BACT 0.1 0.4 0.1 0.3 11?0473 NA 30.0 81.8 6.5 28.5 27.7 121.2 05 2.2 01 0.6 SRU3-TGI NA 30.0 81.8 6.5 28.5 15.0 65.7 0.5 2.2 0.1. 0.6 FCC Regenerator NA 27.9 61.0 35.0 101.9 121.9 106.8 25.0 109.5 - - North NA 0.2 0.5 0.2 0.8 1.0 4.3 0.0 0.0 0.2 0.7 Plant Flare ?70401? South Plant Flare FCC glare NA 0.1 0.Flare 3? ky NA <01. <01 <01 <01 <01 0.2 0.0 0.0 <01 <01 GOHT Flare A 2.4 10.5 4.1 18.1 13.6 59.6 00 0_0 23 10.2 Subtotal 345.4 668.8 1156.2 196.0 70.2 Tanks, Table 106.E 322.4 Fugitives, Table 106.F 9946 Misc Sources, Table 106.6 Cooling Towers, Table 106.11 2.5 9.0 56.2 Oil/Water Separators, Table 5.3 9.5 106.1 Table 107 27.4 31.6 97.6 0.4 46.2 TOTAL- NA 372.8 700.4 1256.3 205.3 1515.7 1 Totals are for information and are not enforceable conditions. 2 Nitrogen dioxide emissions include all oxides of nitrogen expressed as N02 3' lbs?NOx/MMBtu of heat input, calculated as a 3-hour average, when ?ring natural gas at 3% stack oxygen at full design load without air preheat. 4 Ail Particuiate Matter emitted is assumed to be of aerodynamic diameter 10 microns or less. 5 Hourly emission limits and lb/MM Btu limits are based on a hourly rolling 3-hour average. 6 Maximum allowable emissions during maintenance, startup, or shutdown (SSM) and malfunction activities. indicates that in accordance with the application, emissions of this pollutant are not expected. indicates that the emissions are less than 1.0 or 1.0 tpy and emission limits are not required for this permit, unless it?s for a control device. Unit 9851, the SCR exhaust has Ammonia Slip limit of 7 on a wet basis and 6.1 tpy (BACT). ACC Form Part 1 Permit R2M .1 Page 24 of 143 EPA Inspection Report - Page 584 of 1969 Version 02.25.15 ACC Form Part 1 Permit P051-R2 Page 25 of I43 Ver 4.1 02/25/2015 EPA Inspection Report - Page 585 of 1969 Version 02.25.15 A106 Facility: Allowable Emissions B. The permitted emission. sources at the re?nery shall consist only of the sources listed in Table 106.A and Tables 1063 through 106.1 of this permit. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous Intermittent Yes El No El Yes No INTERNAL FLOATING ROOF STORAGE TANKS TABLE 106.130) VAPOR PRESSURE LIMITATIONS FOR REFIN ERY NON- COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOC) Typical Liquid Most Volatile Category NIfaIl?I/IVatp?grlP?SSEre (1381123 ank No. Stored of Allollagigrl?ilquids to 0 osMaoxaTle I: pull? a T-0056 Naphthas High Vapor Pressure2 1 .0 Distillates High Vapor Pressure2 1. l. .0 110107 Gasolines High Vapor Pressure2 1.0 110108 Gasolines High Vapor Pressure2 1.0 T-0109 Gasolines High Vapor Prr-3ssure2 "l .0 T-01 1 1 Naphthas High Vapor Pressure2 1 1.0 12 Naphthas High Vapor Pressure2 1 1.0 12001 1 Gasolines High Vapor Pressure2 1 1.0 T-0124 Gasolines High Vapor Pressure2 1 1.0 T-0012 Gasolines High Vapor Pressure? 1 1.0 T-0413 Distillates High Vapor Pressure2 1 1.0 T-0415 Gasolincs High Vapor Pressure2 1.0 T-04l 7 Gasolines High Vapor Pressure2 1.0 T-0439 Crude Oil High Vapor Pressure2 1.0 Liquids in lower volatility categories may also be stored tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allowed to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub-grade, reguiar, premium, and other blends), Alkylate, Reformate, FCC Gasoline, Ethanol, Isomerate, Straight Run Gasoline, and other refinery feedstocks, intermediates. products. byproducts, and wastes having a max vapor pressure of 1 psia or less under actual storage conditions. ACC Form Part 1 Permit Page 26 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 586 of 1969 Version 02.25.15 EXTERNAL FLOATING ROOF STORAGE TANKS TABLE 1063(2) VAPOR PRESSURE LIMITATIONS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (V OC) Tank No. Typical Liquid Most Volatile Category of Max Vapor Pressure Stored Allowable Liquids to be StoredI (psia) of Most Volatile Liquid at Max Temp. 'r?0057 Naphthas High Vapor Pressure2 11.0 Isomerates High Vapor Pressure2 11.0 Isomerates High Vapor Pressure2 1 1.0 17 Gasolines High Vapor Pressure2 11.0 T-0401 Gasolines High Vapor Pressure2 11.0 T0402 Gasolines High Vapor Pressure2 1 1.0 Gasolines High Vapor Pressure2 1 l0 Gasolines High Vapor Pressure2 1 1.0 10435 Crude on High Vapor Pressure2 11.0 Crude Oil High Vapor Pressure2 1 1.0 T0450 Naphthas High Vapor Pressure2 11.0 T-0802 Sour Water High Vapor Pressure2 11.0 Slop High Vapor Pressure2 11.0 Distillates Moderate Vapor Pressures 1.5 T0835 Distillates High Vapor Pressure2 1 1.0 r1225 Naphthas High Vapor Pressure2 11.0 Sour Water High Vapor Pressure2 1 1.0 TK-NEWETHANOL Ethanol High Vapor Pressure: 2.32 Liquids in lower volatility categories may also be stored tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allowed to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). 2 High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub-grade, regular, premium, and other blends), Alkylate, Reformate, FCC Gasoline, Ethanol, Isomerate, Straight Run Gasoline, and other re?nery feedstocks, intermediates. products. byproducts, and wastes having a max vapor pressure of 1 psia or less under actual storage conditions. 3 Moderate Vapor Pressure Liquids include: Desul?lrized Naphtha (Splitter Bottoms), Light Slop, and other re?nery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 1.5 psia or less under actual storage conditions. ACC Form Part 1 Permit R2M1 Page 27 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 587 of 1969 Version 02.25.15 FIXED ROOF STORAGE TANKS TABLE 106.C VAPOR PRESSURE LIMITATIONS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOCs) Tank N0. Typical Liquid Most Volatile Category of Max Vapor Pressure (psia) of Stored Aliowable Liquids to be Most Volatile Liquid at Max StoredI Temp. T-0013 Slop Moderate Vapor Pressure:5 1.5 Distillates Low Vapor Pressure4 0.5 Distillates Low Vapor Pressure4 0.5 T-OI 10 Asphalt/Pitch Low Vapor Pressure4 0.5 T-0400 Gas Oils Low Vapor Pressure?; 0.5 T-0404 Carbon Black Oil Low Vapor Pressure4 0.5 (CBO) T-0405 CBO Low Vapor Pregame? 0.5 T0409 Gas Oils Low Vapor Pressure4 0.5 T-0410 Asphalt/Pitch Low Vapor Pressure4 0.5 T-0418 Distillates Low Vapor Pressure4 0.5 T-0419 Distillates Low Vapor Pressure4 0.5 CBO Low Vapor Pressure4 0.5 Distillates Low Vapor Pressure? 0.5 Disti?ates Low Vapor Pressure4 0.5 ?17-0431 Distiliates Low Vapor Pressure; 0.5 T-0432 Distillates Low Vapor Pressure4 05 Slop Moderate Vapor~ Pressure3 1.5 T-0055 Distillates Low Vapor Pressure? 0.5 Distillates Low Vapor Pressure4 0.5 CBO Low Vapor Pressure4 0.5 T-0061 Distillates Low Vapor Pressure4 0.5 CBO Low Vapor Pressure4 05 ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 28 of 143 EPA Inspection Report - Page 588 of 1969 Version 02.25.15 CBO Low Vapor Pressure4 0.5 T-0075 CBO Low Vapor Pressure4 0.5 Gas Oils Low Vapor Pressure4 0.5 r0434 Distillates Low Vapor Pressure? 0.5 Gas Oils Low Vapor Pressure4 0.5 Slop Moderate Vapor Pressure3 1.5 1 4 Asphalt/Pitch Low Vapor Pressure4 0.5 15 Distillates Low Vapor Pressure4 0.5 T-O 838 Distillates Low Vapor Pressure4 0.5 T?l 227 Asphalt/Pitch Low Vapor Pressure4 0.5 Asphalt/Pitch Low Vapor Pressure4 0.5 Asphalt/Pitch Low Vapor Pressure4 0.5 RW-4 Recovery Well High Vapor Pressure2 1 1.0 Hydrocarbons RW-S Recovery Well High Vapor Pressure2 1 1.0 Hydrocarbons RW-6 Recovery Well High Vapor Pressure2 11.0 Hydrocarbons Biodiesel Low Vapor Pressure4 0.022 NEWBZODIES EL TABLE 106.!) STORAGE TANK THRO UGHPUT AND TEMPERATURE LIMITS Material Throughput (phi/yr) Maximum Storage Temperature Asphalt/Pitch 30,872,000 510 Carbon Black Oil (CBO) 1,291,610 250 Crude Oil 76,212,000 Ambient Liquids in lower volatility categories may also be stored tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allowed to store moderate vapor pressure category liquids can also store iow vapor pressure category liquids). High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub?grade, regular, premium, and other blends), Alkylate, Reformate, FCC Gasoline, Ethanol, Isomerate, Straight Run Gasoline, and other re?nery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 1 psia or less under actual storage conditions. Moderate Vapor Pressure Liquids include: Desulfurized Naphtha (Splitter Bottoms), Light Slop, and other re?nery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 1.5 psia or less under actual storage conditions. Low Vapor Pressure Liquids include: Diesel (raw or ?nished), Kerosene (raw or ?nished), P-8, CBO, LCO, Slurry, Heavy Slop, Cutback Asphalt, Cutter, VGO, AGO, and other re?nery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure less than 0.5 psia under actual storage conditions. ACC Form Part 1 Permit R2M1 Ver 02/25/2015 Page 29 of 143 EPA Inspection Report - Page 589 of 1969 Version 02.25.15 Distillate 55,076,590 310 Gas Oil 25,059,500 310 Gasoline (includes isomerates) 57,9l0,908 Ambient Naphtha 39,028,084 Ambient Slop 1,330,000 Ambient Sour Water 45,051 Ambient BioDiesel 949,000 Ambient Methanol 142,3 50 Ambient TABLE STORAGE TANK VOC AND HZS EMISSION LIMIT Sl (return to A203) Tank Type VOC Emission Rate Emission Rate (tpy) Fixed-Roof 238.6 0.0 Floating-Roof 83.8 1 .47 Total Tanks 322.4 1.47 i Table 106.F, 1EMISSIONS LIMITS FOR REFINERY SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOC) FUGITIVE EMISSIONS FROM EQUIPMENT LEAKS Maximum Hourly Average Annual Process Unit ID Number Description VOC Emission Rate VOC Emission Rate (tons/yr) CRUDE South Division Crude Unit 10.2 44.6 FCC 10.8 47.2 PowerfonneriPenex Unit 5.9 25.7 FUG-21-SP VACUUM Flashert?Vacuuln Unit 3.2 l3.9 FUG-US-KERO Kerosene HDS Unit 5.2 22.7 DU .1P8 l-lydrodesulfurization 7.l 30.9 MEROX Meroxr'Merichem ?l"reating Units 3.5 15.3 FUG-35-SAT GAS Saturates Gas Plant 18.3 80.0 FARM Light Oil Tankage 6.8 29.6 STG Asphalt/Heavy Oi? Storage 3.5 15.3 GAS Fuel Gas Distribution System 4.2 18.2 The permittee shall demonstrate compliance with the above throughputs and emission limits through the annual emissions inventory process. Speci?c tank data g. temperature 82; throughputs) shall be monitored and recorded weekly by the permittee. ACC Form Part 1 Permit P051-R2 82; Ver 4.1 02/25/2015 Page 30 of 143 EPA Inspection Report - Page 590 of 1969 Version 02.25.15 LPG Storage System 21.6 94.4 FUG-41-PBC PBC Unit 3.4 14.7 CC Refonne1?(wfin battery limits) 23.4 102.3 3-NHDU Naphtha HDS Unit 102 44.6 FUG-43-S ALKY South Alky Unit L7 7.5 ALKY North Alkylation Unit (New-Inside battely limits) 12.0 52.5 Gas Oi} Hydi?otreater (incl. CVS) 9.3 40.6 Gas Oil Hydrotreater (incl. CVS) 2.6 11.2 AMINE Amine 6.3 27.5 waV8 2.4 10.4 Sour Water Stripper 1.6 7.0 FUG-SO-WWTP CVS ()iUWater Separator 1.3 5.5 HDU Relocated Diesel l-lDS Unit waVS 12.9 56.4 RK loading Racks 2.8 12.1 ALT AsphaltfPitch loading Rack 0.7 2.9 UTIL Utilities 16.7 73.3 PUG-63412 PLANT-1 Hydrogen Plant 2.6 1 1.2 SRU3 Unit 07 3.1 WX Hydrocracker 6.2 27.2 ROSE Unit 8.0 35.] FUG-64-H2 PLANT-2 Hydrogen Plant 2.6 11.2 FUG-RRTOTRUCK Crude oil unloading system, closed 100p system 0.1 0.5 between raiicars and trucks Subtotal Facility VOC CAP 227.8 994.6 Minor changes within the facility to piping and components that affect fugitive VOC emission source shail be updated and added during the next available Signi?cant permit revision in accordance with 20.2.72 NMAC. The facility wide fugitive VOC emission Iimit shown above and in Table 106A of this permit. MISCELLANEOUS SOURCES Table 106.G EMISSION LIMITS FOR REFINERY NON-COMBUSTION SOURCES Of VOLATILE ORGANIC COMPOUNDS (V OCs) Loadin Loadin Rack . Hourl Annuai . . Rackg Descrigption Material Loaded Througlfput Throughput VOC EmlsSions bbl/hr bbl/yr lb/hr ton/yr Gasoline 1214 1,600,696 4.25 2.80 Fueis Truck Loading Diesel 107100 3,650,000 1.72 1.72 Rack Jet Fuel 35700 1 021,718 0.75 0.34 TOTAL VOC 6.73 4.86 TL-7 Truck Carbon Black Oil 6.30 1.57 ACC Form Part 1 Permit P051-R2 Page 31 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 591 of 1969 Version 02.25.15 Loading Rack Light Cycle Oil 38100 20,119 3.55 0.06 TOTAL VOC 6.30 1.63 Carbon Black 011 30000 365,000 6.30 1.15 Diesel 20000 1,144,000 0.32 0.54 RLO-8 gi?agal?d?i?jgl?ic?f: .161; Fuel 20000 1,144,000 0.42 0.38 Asphalt 30000 2,628,000 0.01 0.03 TOTAL VOC 6.30 2.09 FUG- Odor Controllin ODOR Atomizer 0'46 2?0 Note:1 . Caiculation method and factors per Section 5.2, dated June 2008. a Controlled emission rate. The previous controlled rate was set by the terms of the consent agreement between Navajo Re?ning Co. and the Department executed January 28, 1994. The agreement required that the incinerator have a minimum 90% destruction efficiency for gasoline loading and a minimum 80% destruction ef?ciency for diesel fuel loading or let A fuel loading. This was achieved by a vapor combustor. This device has since been replaced with a carbon adsorption system compliant with MACT Subpart R, as subject per MACT Subpart CC. Emission limits changed in 195-M-i7 to correspond to Title permit values. COOLING TOWERS Table 106.H EMISSION LIMITS FOR REFINERY NON-COMBUSTION SOURCES OF ORGANIC COMPOUMDS and PM Source ID VOC VOC PM PM CO (lb/hr) CO lb/hr tons/yr (lb/hr) (tons/yr) (tons/yr) 1.8 7.9 0.3 1.2 Y-0002 1.8 7.9 0.3 1.2 Y-0008a 6.5 28.3 0.7 2.9 0.58 2.54 1.3 5.5 0.5 2.3 Y-0012 0.4 1.8 0.2 0.8 CT TT-0006 1.1 4.7 0.2 0.7 Subtotal (for informational 12,8 56_ 1 2_1 9.1 purposes only) API SEPARATORS Table 106.1 EMISSION LIMITS FOR REF INERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOCs) Maximum Average Hourly VOC Annuai VOC Equipment Emission Point Emission Emission 1D 1D Description Rate (lb/hr) Rate (tons/yr) MAEN Above Ground Oil?Water Separators <0.1 <0.1 a cooling tower provides 100% control of any NH3 emissions from V-H2 and Unit 64, Hydrogen Plant has de-aerator line that has dissolved CO that is connected to the cooling tower. ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 32 of 143 EPA Inspection Report - Page 592 of 1969 Version 02.25.15 and enciosed drain system. T-0896 DAF Unit T-0801 T-0801 Enhanced Biodegradation Tank T-0801 Enhanced Biodegradation Tank 0.1 0.5 T-0829 Equalization Tank T-0829 5.1 8.9 T-0806 DAF-0806 DAF Unit T-OBOS <03 Subtotal (for informational purposes only) 5.3 9.4 A106 Facility: Allowable Emissions Continuous Yes Yes C. Compliance with Allowable Emission Intermittent N0 El N0 Limits Requirement: The allowable minBtu/hr, lb/mthu, lb/hr, and tpy emission limits for equipment listed in Table 106A construction of which predates the Navajo continues to comply with all applicable effective date of 202.72 NM AC (August emission limits except for speci?c deviations as 31? 1972), and have not been modi?ed noted elsewhere in this document and events since August 31, 1972, shall be the reported Per 20'2? "potential emission rate? of that unit as de?ned in 202.72.107 NMAC and the potential to emit of that unit de?ned under 20.2.74 NMAC. The mthu/hr, lb/hl? and lb/mthu limits are based on an hourly rolling 3?hour average. (NSR 0195M35, Condition A106.C and revised) to a a Permittee shall monitor the ?3/1111an to em1ss1on encept for spe01?c dev1ations as El Intermittent N0 El No noted elsewhere in this document and events demonstrate compliance With the reported per 2027 NMAC. mthu/hr, lb/hr, and tpy emission limits. Nava'o continues to com 1 with all a licable - Recordkeeping: To demonstrate emissjion limits except foIr) speci?c deinEtions as El Continuous Yes El Yes compliance, records Shall be kept showing noted elsewhere in this document and events Intermittent El No No the correlation between lb/mthu and the reported per 20.2.7 NMAC. ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 33 of 143 EPA Inspection Report - Page 593 of 1969 Version 02.25.15 mthu/hr and lb/hr, and the rolling 12?m0nth tpy totals. The records shall also document any non? compliance with emission limits. For each unit, a summary of the method used to determine compliance shall be recorded. The permittee shall maintain records in accordance with Section B109. Reporting: The pennittee shall report in accordance with Section Bl 10. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous Intermittent Yes No Yes El No A106 Facility: Allowable Emissions D. BACT $02 Limit Fuel sulfur limit Re?nery?Wide for all units burning re?nery fuel gas (excluding units H-8801, and which burn only natural gas) shall not exceed 60 H23 on a daily rolling 365-day average. The ton/yr emission rates for $02 in Table 106A 0fthis permit are based on this daily rolling 365?day average 60 H28 limit. Compliance with this limit shall be demonstrated per the methods described in Condition A110.A. Navajo continues to comply with all applicable emission limits except for Speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous Intermittent Yes IXI No IXI Yes No A106 Facility: Allowable Emissions E. BACT Limit - In addition to the emission limits shown in Table 106A, Boiler Unit B-0009 has a BACT limit 0f0.02 lb/MM Btu, and C02 limit ofl 12.1 lb/MM Btu. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. IXI Continuous IXI Intermittent Yes IXI No Yes El No ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 34 of E43 EPA Inspection Report - Page 594 of 1969 Version 02.25.15 A106 Facility: Allowable Emissions F. BACT SOZ Limit The Sulfur Recovery Unit No. 3 Tail Gas Incinerator is limited to 192 $02 at zero percent oxygen on a hourly rolling 12-hour average basis. In addition, TG1 is limited. to 192 $02 at zero percent oxygen on a daily rolling 365-day average basis. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. El Continuous IXI Intermittent A106 Facility: Allowable Emissions G. BACT VOC Limit The naphtha storage tank T-1225 and sour water storage tank T-0737 shall be equipped with an external ?oating roof using double seals to reduce VOC emissions to the atmosphere. The maximum true vapor pressure of any volatile organic liquid stored in either tank shall not exceed 11.0 psia. Demonstration of compliance is through the NSPS Kb and MACT emission limits. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. IXI Continuous IXI Intermittent Yes No El Yes IXI No A106 Facility: Allowable Emissions .H. VOC - All fugitive piping components in VOC service associated with the process units proposed in Permit (Units PUG-31- and Hydorcracker) shall be monitored under the MACT subpart CC leak detection and repair program, or an approved equivalent program, to reduce VOC emissions. Navajo continues to comply with all applicable emission limits except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous Intermittent IZI Yes El No El Yes No ACC Form Part 1 Permit P05 1 -R2 Ver 4.l 02/25/2015 Page 35 of 143 EPA Inspection Report - Page 595 of 1969 Version 02.25.15 A106 Facility: Allowable Emissions Continuous Yes Yes Navajo continues to comply with all applicable I. VOC Consistent with MACT Subpal?t emission limits except for speci?c deviations as Intermittent El N0 El No the gasoline truck loading rack (T LO- noted elsewhere in this document and events 4) shall. be limited to 10 mg of VOC 13er 20-2-7 NMAC emissions per liter of gasoline loaded. A106 Facility: Allowable Emissions Continuous Yes Yes Intermittent El No IXI No J- Cooling Units 1 Navajo continues to comply with all applicable and Shall be equipped with high emission limits except for speci?c deviations as ef?ciency dri? eliminators to reduce PM 1 0 noted elsewhere in this document and events emissions. Demonstration of compliance is reported per 20-2-7 NMAC- through annual inspection in accordance with in Condition A2123. A107 Facility: Allowable Startup, Continuous Dyes Shutdown, Maintenance (SSM) and Malfunction Emissions Intermittent N0 A. Th maximum allowable SSM and Navajo continues to comply With all applicable . . . . . . emissmn 11m1ts except for specr?c dev1at10ns as Malfunction e1mss10ns limits for this . . l' bl 10 noted elsewhere in this document and events 301 ?y are 1sted 1n Ta 7.A an were reported per 20.2.7 NMAC. relied upon by the Department to determine compliance with applicable regulations. Table 107.A: Allowable SSM and Malfunction Units, Activities, and Emission Limitsl NOX CO VOC 5 302 H25 Unit Description of Emissions tpy tpy tpy tpy tpy tpy SSM Emissions during SCR downtime1 l0.l 1.2 20SSM Emissions from roof landing -- -- -- 33.0 0.5 -- -- -- -- 88M Misc 1 Emissions from catalyst handling -- -- 1.5 <0.1 -- ACC Form Part 1 Permit P051-R2 Page 36 of 143 Ver 02/25/2015 EPA Inspection Report - Page 596 of 1969 Version 02.25.15 from SRU3 stamp and 5.5 <01 15.0 0.1 0.1 <01 159.0 04 5.5 <01 SSM shutdown Emissions from roof landing and SSM tank re?iling -- 177.0 -- -- - Emissions from root landing and SSM tank re?lling -- -- -- 306.0 4.6 -- -- ?m SSM Emissions from roof landing 187.0 2.8 SSM Temporary, portable ?are for natural PORT gas pipeline maintenance 173.4 0.1 943.5 0.5 160.7 0.1 -- 1.7 <0.1 0.02 <01 SSM Emissions from SRU2 startup and (ii-0473) shutdown 6.5 0.1 27.7 0.2 0.2 0.1 159.0 0.4 6.6 0.1 Emissions from venting SSM activity gases to 1133. SSM Flare Cap FL-403, or i-?L-404. 162.9 18.3 1243.0 77.0 211.6 13.2 4 14.9 0.4 0.1 Flares Malt Cap Upset and Malfunction Emissions 10.0 -- 10.0 -- 10.0 -- -- 10.0 Low?Emitting Maintenance Activities such as de-inventorying small equipment, clearing piping associated with emission units, and routine maintenance activities such as heat SSM Misc 2 exchanger repair. 17.0 1.9 127.1 7.8 21.2 1.4 -- -- 129.3 1.6 0.7 0.1-- SSM Tanks Misc Storage Tanks -- -- 112.0 10.6 -- -- -- 0.1 0.1 Subtotal 31.6 98.0 46.2 0.4 27.4 0.4 During startup, shutdown, schedule maintenance or malfunction of the SCR control system, BACT for H-985 1 shall be ultra?low burners emitting no more than 03 lb per (LHV) on a hourly rolling 3?hour average basis at 3% excess oxygen. Pound per hour and tons per year limits are based on the lb/MMBtu limits and were used. to demonstrate compliance with the lb/MMBtu limits and the Ambient Air Quality Standards (AAQS). A107 Facility: Allowable Startup, Continuous I: Yes Yes Shutdown, Maintenance (SSM) and Intermittent No No Malfunction Emissions Navajo complies with the conditions of B101 .C and 8107A. Except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. B. The authorization of emission limits for startup, shutdown, maintenance, and malfunction does not supersede the requirements to minimize emissions according to Conditions and 8107A. ACC Form Part 1 Permit P051-R2 R2M1 Page 37 of 143 Ver 02/25/2015 EPA Inspection Report - Page 597 of 1969 Version 02.25.15 A107 Facility: Allowable Startup, Continuous Dyes .Yes Shutdown, Maintenance (SSM) and Malfunction Emissions Intermittent C. SSM Flaring and combustion Emissions Requirement: The permittee shall comply with the ?aring and combustion SSM CO, VOC, SOZ, TSP, and H28 emission limits at Table 107A for the following SSM events: 1) SSM Emissions during SCR downtime . 2), 3), 4), 5), and 6) Navajo obtains fuel gas 2) SSM from analysis from New Mexico Gas Company. SRU3 startup and shutdown Navajo continues to comply with these 3) SSM FL-HERPORT requirements except for speci?c deviations as noted elsewhere in this document and events reported per Temporary, portable ?are for 20-27 NM A C. natural gas pipeline maintenance 4) SSM SRU2-TGI (PI-0473), Emissions from SRU2 startup and shutdown 5) SSM Flare Cap, Emissions from venting SSM activity gases to FL- 400, FL-401, FL-402, FL-403, or FL-404 6) SSM. Misc 2, Low?Emitting Maintenance Activities such as de-inventorying small equipment, clearing piping associated with emission units, and routine maintenance activities such as ACC Form Part 1 Permit it P051-R2 Page 38 of 143 Ver 4.1 02f25/2015 EPA Inspection Report - Page 598 of 1969 Version 02.25.15 heat exchanger repair. (NSR 0195M35, Condition A107.C and duration of every SSM ?aring or combustion event. The CO, VOC, volume of gas sent to the ?are and the total sulfur content of the ?ared gas. Compliance with the hourly emission rates shall be demonstrated by calculating the hourly emission rates for each event and. comparing the results to the hourly emission rate at Table 107A. The annual. emission rate shall be calculated as follows: and 2) After the ?rst 803, TSP, and H38 emissions shall be calculated for each event based on the I) To demonstrate compliance during the ?rst 12 months of monitoring, the permittee shall. calculate and sum the cumulative total of CO, VOC, $02, TSP, PM35, and H28 emissions; 12 months of monitoring, the permittee shall Navajo keeps records of SSM events. Maintenance scheduling is based on engineering judgment and Operating experience. revised) Monitoring: The permittee shall monitor Continuous El Yes Yes all ?aring and combust10n due to routine and predictable startups, shutdowns, and Navajo Environmental Department keeps an up?to? Inter mittent No No scheduled maintenance events. This Shall date events summary with emission units and be accomplished by collecting all the SSM ?aring and combustion information speci?ed in A107C. Recordkeeping. Recordkeeping: The permittee shall Continuous El Yes Yes record the date, start and end times, and K4 Intermittent K4 N0 N0 ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 39 of 143 EPA Inspection Report - Page 599 of 1969 Version 02.25.15 calculate and sum the total of CO, voc, s02, TSP, PMIO, and HZS emissions on a rolling 12 month basis. 3) The permittee shall maintain all records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. Reports required by Section B110 are submitted as necessary, except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. El Continuous Intermittent A107 Facility: Allowable Startup, Shutdown, Maintenance (SSM) and Malfunction Emissions D. SSM VOC Emissions (Facility-Wide, Non?Combustion Sources) Requirement: The permittee shall comply with the SSM VOC emission limit at Table 107A. Navajo compiies with the requirements listed in table 107.A. El Continuous IXI Intermittent Monitoring: The permittee shall monitor all VOC emission activities due to routine and predictable startups, shutdowns, and scheduled maintenance events. This shall be accomplished by collecting VOC emission. calculation information for the following SSM VOC emission activities: 1) SSM T-0737, Emissions from rooflanding 2) SSM T-0078, Emissions from roof landing and tank re?lling 3) SSM Emissions from Navajo complies with these requirements, except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. I:l Continuous Intermittent ACC Form Part 1 Permit P051-R2 Ver 4.1 02/252?2015 Page 40 of 143 EPA Inspection Report - Page 600 of 1969 Version 02.25.15 4) 5) roof landing and tank re?lling SSM T-l 225, Emissions from roof landing SSM Tanks Miscellaneous 2) 3) Recordkeeping: The annual SSM VOC emission rate shall be calculated as follows: To demonstrate compliance during the ?rst 12 months of monitoring the perrnittee shall calculate and sum the cumulative total of VOC emissions; and After the ?rst 12 months of monitoring the permittee shall calculate and sum the total of VOC emissions on a rolling 12 month basis, including the methodology and/or assumptions used in the calculation(s). The perrnittee shall keep records to demonstrate compliance in accordance with Condition 1. 09C, except the requirement in to record the start and end times of SSM events shall not apply to known quantities emissions. The perrnittee shall maintain all records in accordance with Section B109. Navajo complies with these requirements, except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous IE Intermittent Yes No IZI Yes No Reporting: The perrnittee shall report in accordance with Section B1 10. Navajo complies with these requirements, except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. Continuous IZI Intermittent Yes No Yes No ACC Form Part 1 Permit it R2M1 Ver 4.1 02/25/2015 Page 41 of I43 EPA Inspection Report - Page 601 of 1969 Version 02.25.15 A107 Facility: Allowable Startup, Continuous Dyes Shutdown, 8.: Maintenance (SSM) and Malfunction Emissions Intermittent N0 El N0 Navajo complies with these requirements, except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. E. SSM Particulate Emissions (Unit SSM Misc 1) Requirement: The permittee shall minimize particulate emissions due to SSM events. Monitoring: The permittee shall monitor El Continuous Yes Yes all particulate emissions due to routine and predictable startups, shutdowns, and Intermittent El N0 N0 scheduled maintenance events. For the Navajo complies With these requrrements, except . for speci?c deviations as noted elsewhere in this event type Catalyst Loading, the document and events reported per 20.2.7 NMAC. maximum material usage shall not exceed '1 hr-duration, 1 loading event/yr; and 237,048 lb/event/yr. Recordkeeping: For each event, the El Continuous Yes El Yes permittee shall maintain records of the duration in hours, events per year, and Intermittent DNO No material usage for the particulate matter Catalyst loading data collected on a daily basis and emitting SSM event - FCCU Catalyst maintained by the Navajo Process Engineering Loading. The annual material usage shall Department. be based on rolling 12?month total. The permittee shall maintain all records in accordance with Section Bl 09. Navajo complies with these requirements, except '1 Continuous Yes Yes ?th t' BI 10 for speci?c deviations as noted elsewhere in this accor ance W1 ec 1011 document and events reported per 20.2.7 NMAC. El Intermittent El N0 El N0 Reporting: The permittee shall report in ACC Form Part 1 Permit at Page 42 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 602 of 1969 Version 02.25.15 A107 Facility: Allowable Startup, Shutdown, Maintenance (SSM) and Malfunction Emissions F. SSM and Malfunction Flaring Emissions (SSM Flare Cap and Flares MalfCap) Requirement: The permittee shall not exceed the pound per hour (pph) and ton per year (tpy) emission limits in Table A107.A and shall demonstrate compliance with these limits by calculating and summarizing these emission rates as required in recordkeeping. Navajo complies with these requirements, except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. [3 Continuous Intermittent El Yes No Yes I: No Monitoring: A gas ?owmeter and ?ow totalizer, equipped with a chart recorder or electronic data logger, shall be installed in the ?are line to measure and record the total standard cubic feet (sci) of all gas (process gas, purge gas, pilot gas, and supplemental fuel gas) sent to the ?are during each hour and each month. The permittee shall measure the H28 content, the total sulfur content, the VOC content, and the heating value (Btu/sci) of the gas sent to the ?are for combustion. HZS shall be measured at least once every 24?hours on each of the inlet gas types/streams using a stain tube of the appropriate size range or an inline HZS monitor. The total sulfur content, VOC content, and heating value (Btu/sci) of the Navajo complies with these requirements, except for speci?c deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. [3 Continuous Intermittent Yes No El Yes No ACC Form Part .1 Permit 8: Ver 4.1 02/25/2015 Page 43 of 143 EPA Inspection Report - Page 603 of 1969 Version 02.25.15 natural gas sent to the ?are shall be measured at least once annually with an extended gas analysis. The ?ow meter and ?ow totalizer shall be operated, calibrated, and maintained as speci?ed by the manufacturer and as necessary to ensure correct and accurate readings. If used, the inline monitor shall be operated, calibrated, and maintained as speci?ed by the manufacturer and as necessary to ensure correct and accurate readings. Recordkeeping: The following records El contin'm? Yes Yes Shall be k?pt: Intermittent No No a stain tube and/or inline H28 measurements 9 annual extended gas analysis a both the hourly and volume (scf) of gas sent to the ?are Each month, the permittee shall record and summarize in a table format the following. Navajo complies with these requirements, except 9 H23 and the tOtEll SUl?-lf content for speci?c deviations as noted elsewhere in this 0 percent VOC content document and events reported per 20.2.7 NMAC. - gas heating value (Btu/30f) the maximum hourly gas ?ow rate (scf/hr) that occurred during the month a each hourly gas ?ow rate (scf/hr) for any hour(s) that exceeded any emission limit during the month a the total. month?s of gas sent to the ?are ACC Form Part 1 Permit P051-R2 Page 44 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 604 of 1969 Version 02.25.15 the rolling 12-month total of gas sent to each ?are (scf/yr) Each month, the permittee shall record all routine and predictable startups, shutdowns, and scheduled maintenance events and shall also meet the recordkeeping requirements in General Condition B109 of this permit, except the requirement to record the start and end times of SSM events shall not apply. Records of ?owmeter, totalizer, and inline monitor certi?cations, calibrations, documentation of the manufacturer?s recommended calibration maintenance schedule, breakdowns, reasons for the breakdown, and corrective actions taken shall be maintained. Each month, to demonstrate compliance with both the SSM and malfunction emission limits, the perrnittee shall calculate and summarize the maximum emission rate, any emission rate exceeding the permitted limits, and the rolling 12?month total. ton per year emission rates of CO, VOC, $02, and H28 for both SSM and malfunction events, using the following information: a the H28 content, total sulfur content, VOC content, and the gas heating value (MMBtu/scf.) from the most recent H28 measurements and gas analyses 0 the emission factors used to ACC Form Part 1 Permit Page 45 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 605 of 1969 Version 02.25.15 calculate and CO the maximum hourly gas flow rate (scf/hr) a each hourly gas ?ow rate (scf/hr) for any hour(s) that exceeded any emission limit during the month, including the dates and times of these occurrences the rolling 12-month total of gas sent to the ?are (scf/yr) For each event, the permittee shall record whether the emissions are due to SSM and/0r malfunction. 1f the emissions are due to malfunction, the permittee shall indicate whether the emissions resulting from the event are included in the amount allowed by this permit?s malfunction limit or whether the event is reported under 20.2.7 NMAC. Navajo complies with these requirements, Navajo El Continuous El Yes Yes Reporting: The permittee Shall report complies with these requirements, except for according to Condition B1 10, speci?c deviations as noted elsewhere in this El Intermittent El No No document and events reported per 20.2.7 NMAC. A108 Facility: Hours of Operation Continuous Yes Yes IXI Intermittent El No No A. This facility is authorized for continuous operation. Monitoring, recordkeeping, and reportng are not required to demonstrate compliance with continuous hours of. operation. No requirement. A109 Facility: Reporting Schedules El Continuous El Yes El Yes Navajo submitted the requested monitoring reports A. A Semi?Annual Report of. monitoring as follows: Intermittent El N0 N0 activities is due within 45 days following 10/12/2017 the end of every (5-month reporting period. 04/ 13/201 8 The six month reporting periods start on ACC Form Part 1 Permit P05 1 Page 46 of 143 Ver 4.1 02/25f2015 EPA Inspection Report - Page 606 of 1969 Version 02.25.15 September 1St and March 1St of each year. A109 Facility: Reporting Schedules B. The Annual Compliance Certi?cation Report is due within 30 days of the end of every 12?month reporting period. The 12- month reporting period starts on September 1St of each year. Navajo submitted the requested compliance certi?cation report as follows: 09/28/2017 El Continuous IE Intermittent IE Yes No I: Yes No A109 Facility: Reporting Schedules C. In addition to the reports required by the applicable NSPS, NESHAP and MACT Subparts (including any voluntary programs referencing NESHAP, 0r Subparts) and by the applicable parts of 20.2 NMAC.) the reporting required by the Consent Decree shall be submitted to the Department. The reports shall be submitted to the Air Quality Bureau within forty five (45) days of the end of each calendar quarter. If any reports indicate potential non-compliance with the terms of this permit, the Bureau may impose a more frequent reporting time-frame. The Department shall handle any confid enti a1 information in accordance with the provisions of20.2.1.l 1.5 NMAC. The Department has not requested more frequent reporting time-frames. El Continuous Intermittent Yes [Xi No Yes No A109 Facility: Reporting Schedules D. Reporting required by the Consent Decree (not an exhaustive listing) (1) The permittee shall notify the Department? 5 Enforcement Section, Air Navajo submitted the Annual NOX Control Technology report as follows: 12/28/2017 Continuous [Xi Intermittent [Xi Yes No El Yes No ACC Form Part 1 Permit Ver 4.1 0235/2015 Page 47 of 143 EPA Inspection Report - Page 607 of 1969 Version 02.25.15 Quality Bureau in writing of the annual progress of installation of Control Technology required by Paragraph 16 of the Consent Decree. The report shall be submitted. to the EPA and. the NMED on or before December 3 1 st of each calendar year commencing with the year 2002. (CD 106.13) (2) No later than forty?five (45) days following the end of an AG Flaring or TG Incident, the permittee shall submit to EPA and. the NMED a report that sets forth the items detailed. in the Consent Decree. (CD In20, A110 Facility: Fuel and Fuel Sulfur Continuous Yes Yes Requirements (as Required) Intermittent No No A. Fuel, Fuel Sulfur, and NSPS J, Ja Sulfur Requirements (See Tables 103.13, H, I, K, Summary of Applicable Requirements) Re?nery fuel gas IS contlnously monltored for H2S content on a 3-hour rolling average. Exceedances are reported on Navajo's Subpart and Subpart Ja Requirement: (NSR 0195M35, semiannual reporm Condition A1 10A and. revised) (1.) To comply with NSPS Subpart J, NSPS Subpart Ja, and. the PSD BACT requirements in Section 106, the permittee ACC Form Part 1 Permit P051-R2 Page 48 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 608 of 1969 Version 02.25.15 shall install, calibrate and maintain a continuous monitoring system (CMS) to continuously measure and record either the hydrogen sul?de (H28) in the re?nery fuel gas streams being burned in the Heaters and Boilers or the concentration of sulfur dioxide emissions to the atmosphere. (2) All stationary combustion equipment shall be ?red with NSPS quality fuel gas with a maximum H28 content of 0.1 grains/dscf (approx. 162 ppmv), based on a hourly rolling 3-hour average. (3) All stationary combustion equipment shall not combust gas with an annual average sulfur content exceeding 60 (approx. 0.037 grains) as a daily rolling 365uday average. (4) All stationary combustion equipment shall be affected facilities, as de?ned in NSPS 40 CFR Part 60, Subparts A and or a, if re?nery-produced fuel gas is combusted. in the heaters and boilers, and shall comply with all. applicable requirements of NSPS Subparts A and or .la. (See Table 103.E, Summary of Applicable Requirements) . . Continuous Yes Yes Monitoring: (1) The permittee shall install, certify, . . . Intermittent N0 N0 . . . 1) CMS has been installed and is certified, calibrate, maintain and operate a fuel gas . . . calibrated and maintained. continuous monitoring system (CMS) at ACC Form Part 1 Permit R2M1 Page 49 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 609 of 1969 Version 02.25.15 the fuel gas mix drum outlet in accordance with the requirements of40 CFR 60.1 1, 60.13, and Part 60 Appendix A, and the applicable performance speci?cation of 40 CFR Part 60 Appendices and F. (2) The following CMS shall be certi?ed initially and recerti?ed annually: 0 D-0019 Low Pressure Fuel Gas HZS CMS 9 High Pressure Fuel Gas H28 CMS (3) As required by the EPA-approvable alternative monitoring procedure (AMP), CCR off-gas streams that enter the re?nery fuel gas system of the H28 CMS shall be monitored quarterly for H28 using gas detector tubes or an equivalent method as follows: CCR stabilizer off gas stream, H2 recycle gas stream, and c) CCR feed stream. 2) CMS annual RATAs were completed as follows: Low Pressure Fuel Gas H28 2/ 15/201 8 D-0770 High Pressure Fuel Gas H2S 2/15/2018 3) The CCR stabilizer off gas, the H2 recycle gas and the CCR feed streams are analyzed a minimium of quarterly. Recordkeeping: The perrnittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subparts A, J, and Ja. (1) Records of the quantity of the re?nery fuel gas and the average heating value of the re?nery fuel gas. This is used to demonstrate compliance with lb/mmBTU and lb/hr limits shown in Table 106A. (permit limit) (2) Records of repairs, maintenance, and calibrations performed for the instruments that measure ?ow or 1) Fuel records are maintained in Pi. 2) Repair, maintenance, and calibration records are maintained by Navajo Instrument and Electrical Department. 3) CCR off?gas stream analysis records are maintained in the Navajo Environmental Department Files (REF.ART.3.J.05.A). Continuous Intermittent Yes No Yes No ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 50 of 143 EPA Inspection Report - Page 610 of 1969 Version 02.25.15 concentration for an applicable permit limit shall be kept. Examples include, but are not limited to, CMS, acid gas ?ow meters, and fuel gas flow meters. (40 CFR 60, Appendix F) (3) Records shall be kept of Alternative Monitoring Plan (AMP) H28 analyses of the OCR off-gas streams that enter the re?nery fuel gas system of the fuel gas H28 CMS. (NSPS or Ja) Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subparts A, J, and Ja, and Reports required by Subpart A are submitted El Continuous IE Yes Yes semiannuaily. Reports required by Subparts J, Ja, El Intermittent El N0 0 and Section B1 10 are submitted as necessary. Section B110. A111 Facility: 20.2.36 NMAC Continuous Yes Yes A. Facility: 20.2.36 NMAC Imermimt Requirement: 20.2.36 NMAC (Petroleum Re?nery Sulfur, 1/ 30/95) applies to the re?nery as a Whole. Quarterly re?nery? Navajo Refinery is no longer affected by 20.2.36 wide sulfur balance reports shall be ?led in NMAC. This rule was repealed on February 15, accordance with 202.36.] 13 NMAC. All 2016. ?ares and. stacks shall meet the applicable height requirements of 20236.1 14 NMAC as demonstrated through air dispersion modeling done at the time of unit installation. (NSR 0195M35, Condition Al 1 1.A) Monitoring: Quarterly monitoring 0 Navajo Re?nery 15 no longer affected by 20.2.36 Continuous Yes Yes . NMAC. rule was repealed on February 15, re?nery-Wide sulfur balance. 2016. Intermittent N0 N0 Recordkeeping: The permittee shall keep Navajo Re?nery is no longer affected by 20.2.36 Continuous Yes Yes record of a copy of the Facility-Wide NMAC. This rule was repealed on FebruarylS, Sulfur Balance Report and the actual 2016- Intermittent No No ACC Form Part I Permit R2M1 Page 51 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 611 of 1969 Version 02.25.15 Ver 4.102/25/2015 height of ?ares and stacks. . . . Navajo Re?nery is no longer affected by 20.2.36 Continuons Yes Yes Reportmg. The shall report NMAC. This rule was repealed on February 15 accordance With 202.36.] 13A NMAC. 2016. Intermittent [3 N0 N0 A112 Facility: 20.2.37 NMAC I3 Continuous Yes Yes 1) All ?ares have alarms 1nd1catm loss of ?ame A. 20.2.37 NMAC that are in good working order. Intermittent I: No IE No Requirement: (NSR 0195M352 2) The FCC catalyst regenerator exhaust is A1 12A) continou sly monitored for CO. (1) Section 200A (Mercaptans) and 3) The catalytic cracking regenerator is tested section 200B (Hydrogen Sulfide) apply to annually for PM. Navajo has submitted an mercaptan and H28 emissions from the alternative monitoring plan (AMP) to comply with re?nery. Section 200C applies to FL. the FCC opacity monitoring requirement because 04003 FL-040 15 13110402, and the FCCU has a wet scrubber which prevents FL-0404 and requires an alarm in good continuous opacity monitoring. Under the AMP, workin order to si a1 non-combustion 0f opacity is monitored weekly using 40 CFR 60 the gasg g1] Appendix A Method 9. . 4) There are no process vents to the atmosphere, so (2) 86010011 201 applies to the the re?nery is not expected to emit ammonia. Any re?nery 5 FCC regenerator Stad? The trace ammonia emissions are expected to comply owner or operator of an ex15ting petroleum with the 2 5-13pm limit. processing facility shall not permit, cause, suffer or allow carbon monoxide emissions 5) Navajo continues to comply with the applicable to the atmosphere from a catalyst cracking requirements S111313Elrt at re?nery recirculation or regeneration unit in excess Oil/water seperators. The o1l/water separator is 0f20 000 by volume in the undiluted inspected at least semi?annually, and the carbon ef?uent gas stream or streams. vapor control is tested at least (.3) Section 202? (1) (PM), The owner or 6) Blowdowns are accomplished by ventmg to . ?ares that are deSIgned to be operated smokelessly. operator of a new petroleum processmg fac?ity Sh?? ?0t permlt, calls? suffer 01? Navajo Re?nery is no longer affected by 20.2.37 allow pamculate matter 611118510115 t0 the NMAC. This rule was repealed on September 12, atmosphere from the catalytic cracking 2016. regenerator vessel in. excess of 1.0 .Kg/1000 Kg (1.0 lb/1000 lb) of coke ACC Form Part 1 Permit 82; Page 52 of 143 EPA Inspection Report - Page 612 of 1969 Version 02.25.15 burnoff or visible emissions of thirty percent opacity or greater except for one six-minute average opacity reading in any one-hour period. (4) Section 203 (Ammonia, undiluted emissions 3 25 ppmv) applies to all. emission points of the re?nery. The owner or operator of a. petroleum processing facility shall not permit, cause, suffer or allow ammonia emissions to the atmosphere in excess of 25 by volume in the undiluted ef?uent gas stream or streams. (5) Section 204 (Hydrocarbon Separation Facility) applies to all oil/water separators at the refinery. Compliance with this condition is met by complying with the applicable NSPS Subpart requirements. (6) Section 205 (Facilities Storage - Handling - Pumping Blowdown System) applies to certain of the following: storage tanks for organic compounds, loading and unloading of organic compounds, seals on pumps and compressors, and disposal (?aring) of hydrocarbon gases. The permittee shall not permit, cause, suffer or allow the operation of a blowdown system without disposing of the gases in a manner which will minimize hydrocarbon emission to the atmosphere. If combustion is the means of disposal, it shall be by: smokeless ?are; or any other method that is equally effective to achieve complete ACC Form Part 1 Permit P051-R2 Page 53 of ?43 Ver 4.1 02/25/2015 EPA Inspection Report - Page 613 of 1969 Version 02.25.15 combustion. (20.2.37.205.E NMAC) Monitoring: (1) For Units FL-0400, 0402, FL-0403, and The permittee shall install and maintain a ?are pilot ?ame monitoring system. (20.2.37.200.A.2 NMAC) (2) A CO CMS has been installed to monitoring the emissions from the FCC. (3) The annual EPA Method 9 Opacity Test and annual Stack test on Unit FCC (lb/hr PM emissions) and the calculated Coke burn rate will be "used for the annual. determination of pounds of PM per 1000 pounds of Coke burned. (4) None (5) No additional monitoring since compliance is met by complying with the applicable NSPS Subpart requirements. See other conditions of this permit for applicable NSPS or MACT requirements. (6) Compliance is demonstrated through NSPS K, NSPS Ka, NSPS Kb, or MACT CC for Tanks; through MACT CC for Loading Racks; through NSPS NSPS or MACT CC for Pumps and Compressors; and through NSPS Subpart A for Blowdowns. I) All ?ares have alarms indicating loss of flame that are in good working order. 2) The FCC catalyst regenerator exhaust is continously monitored for CO. 3) The catalytic cracking regenerator is tested annually for PM. Navajo has submitted an alternative monitoring plan (AMP) to comply with the FCC opacity monitoring requirement because the FCCU has a wet scrubber which prevents continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CFR 60 Appendix A Method 9. 4) Not monitoring requirement. 5) Navajo continues to comply with all requirements except for speci?c deviations as noted elsewhere in this document. 6) Navajo continues to comply with all applicable requirements except for deviations previously reported or identi?ed at the end of this report. Navajo Re?nery is no longer affected by 20.2.37 NMAC. This rule was repealed on September 12, 2016. Continuous Intermittent IE Yes El No Yes No Recordkeeping: (1) Pilot ?ame monitoring records (2) CO CMS measurements 1) Records are maintaned in Pi. 2) Records are maintained in Pi. 3) Stack test reports are maintained by the Navajo Continuous IE Intermittent ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 0325/2015 Page 54 of 143 EPA Inspection Report - Page 614 of 1969 Version 02.25.15 (3) Copy of annual coke burn rate determination, stack test report, and opacity test report (4) None (5) Applicable NSPS Subpart requirements (6) Applicable NSPS K, NSPS Ka, NSPS Kb, or MACT CC for Tanks; through MACT CC for Loading Racks; through NSPS NSPS or MACT CC for Pumps and Compressors; and through Environmental Department. 4) No recordkeeping requirement. 5) NSPS reports are maintained by the Navajo Environmental Department. 6) NSPS K, NSPS Ka, NSPS Kb, NSPS NSPS J, NSPS Ja, and MACT CC reports are maintained by the Navajo Environmental Department. Navajo Re?nery is no longer affected by 20.2.37 NMAC. This rule was repealed on September 12, Requirement: 20.2.3 8 NMAC (Hydrocarbon Storage Facilities, 1 1/3 0/95) applies to the re?nery as follows: 1. Section 109 (Tank Storage Associated with Petroleum Production or Processing Facility [Sour Hydrocarbon Liquids]) applies to the loading and storing of hydrocarbons containing H28. 2. Section 110 (Tank Battery or Storage Facility - Within Municipality [Sour l) The Artesia Re?nery includes storage vessels that store hydrocarbons containing hydrogen sul?de. The vessels comply with the requirements of 20.238.109 by using submerged ?ll. 2) and 3) The vessels comply with the requirements of 202.38.110 and 113 by using internal or external ?oating roofs with the required seals. NSPS Subpart A for Blowdowns 2016. requirements NSPS J, .la, and MACT CC reports Continuous El Yes :1 Yes Reporting: The permittee shall report in are Smeltted semlannuauy' accordance with applicable NSPS or . . Intermittent N0 N0 MACT requirements and Section Bl 10- avajo Re?nery 13 no longer affected by 20.2.37 NMAC. Th1s rule was repealed on September l2, 2016. A113 Facility: 20.2.38 NMAC Continuous El Yes Yes A. 20.2.38 NMAC El Intermittent 1:1 No El No ACC Form Part 1 Permit R2M1. Ver 4.1 Page 55 of 143 EPA Inspection Report - Page 615 of 1969 Version 02.25.15 Ver 4.1 02/25/2015 Hydrocarbon LiquidsD applies to certain tanks storing sour hydrocarbon liquids whose vapors contain 224 H28. 3. Section. 113 (New Tank Battery and the Pecos-Permian Interstate Air Quality Control. Region [Sour Hydrocarbon LiquidsD applies to certain tanks storing sour hydrocarbon liquids whose vapors contain 324 ppm. H28. (NSR 0195M35, Condition Al l3.A) Monitoring: 1. None El Continuous YES El YES 2. and 3. Demonstrated through NSPS K, 2) and 3) Navajo 111519306011 Department Performs . Ka, Kb and ACT CC ?oating roof seal seal inspections and maintains those records. Intermittent No El N0 inspection. Recordkeeping: Continuous Yes Records 0f Tank d681gn Showmg Inlet 1) Records of tank designs are maintained in the Intermittent No El N0 piping connectlons. Navajo Engineering Library. Reports required by 2. and 3. No additional requirements other 3110 are Smeitted 35 116065530?- than applicable requirements of NSPS and MACT. Reporting: The pennittee shall report in Reports required by BI 10 are submitted as continmm Yes Yes accordance section B1 10. necessaly? Intermittent N0 N0 A118 Facility: MACT Subpart t' For the FCC, Navajo monitors and records the daily on muons es Yes A. 40 CFR 63, Subpart CC, FUG- average coke burn rate and 0f the continuously IXI Intermittent No No SRUs 1. 2,and 3 monitored CO emissions. For the CCR, Navajo monitors and records the weekly average ChlorSorb Requirement: The pennittee shall comply catalyst inlet and outlet chloride contentChlorSorb inlet and outlet temperatures, and the Wit 3 app ica requrrements CCR ?rebox temperature. For the SRUs, Navajo CFR 639 Subpart Natlonal monitors and records the SO2 concentration from Standards for Hazardous Pollutants for the tail gas incinerators. Petroleum Re?neries: Catalytic Cracking ACC Form Part 1 Permit P051-R2 R2M1 Page 56 of 143 EPA Inspection Report - Page 616 of 1969 Version 02.25.15 Units, Catalytic Reforming Units, and Sulfur Recovery Units, for all affected sources shown in Tables attached. (63.1560 and 631570). Monitoring: The pennittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63 Subpart For the FCC, Navajo monitors and records the daily average coke burn rate and of the continuously monitored CO emissions. For the CCR, Navajo monitors and records the weekly average ChlorSorb catalyst inlet and outlet chloride content, the ChlorSorb inlet and outlet temperatures, and the CCR firebox temperature. For the SRUS, Navajo monitors and records the $02 concentration from the tail gas incinerators. Continuous Intermittent Yes No El Yes No Recordkeeping: The pennittee shall comply with the applicable recordkeepin requirements of 40 CFR 63, Subpart Process records are maintained in Pi. Continuous El Intermittent Yes El No Yes No Reporting: The pennittee shall comply with the applicable reporting requirements of40 CFR 63, Subpart Reports required by Subpart were submitted semiannually as follows: 1/30/2018 7/30/2018 El Continuous El Intermittent Yes No Yes No A119 40 CFR 61 Subpart FF. National Emission Standard for Benzene Waste Operations A. 40 CFR 61 Subpart FF, National Emission Standard for Benzene Waste Operations (Units subject in Table 103C G) Requirement: The pennittee shall comply with all applicable requirements of 40 CFR 61 Subpart FF, National Emission Standard for Benzene Waste Operations for the affected sources in Tables 103C, G. The refinery complies with the applicable requirements of NESHAP Subpart FF. Because the re?nery?s total annual benzene (TAB) quantity is less than 10 Mg/yr, none of the standards in this regulation apply. Continuous In termittent Yes No Yes No Monitoring: The pennittee shall comply The re?nery complies with the applicable Continuous Yes El Yes ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 57 of 143 EPA Inspection Report - Page 617 of 1969 Version 02.25.15 with the applicable monitoring and requirements of NESHAP Subpart FF. Because the El Intermittent El N0 No testing requirements of 40 CFR 61 3 re?nery?s total annual benzene (TAB) quantity is Subpart FF. less than 10 Mg/yr, none of the standards in this regulation apply. Recordkeeping: The permittee shall El Continuous Yes Yes comply with the applicable Records are maintained by Navajo Environmental ., . . . I tt recordkeeplng requlrements of 40 CFR Department56. ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 58 of 143 EPA Inspection Report - Page 618 of 1969 Version 02.25.15 Reporting: The pennittee shall comply with the applicable reporting requirements of 40 CFR 61.357. Navajo submitted the annual TAB report. 04/06/2018 Continuous Intermittent Yes No Yes IE No A201 Engines A. Maintenance and Repair Monitoring (Units V-0543, V-0545, E-8010, E-0600W, E- 060213, 13-0603, and Units G- 0100, V-0543, V-0545, 13-8010, E-0600W, E-0602E, 0603, and E-0901) Requirement: These units are subject to Title since they are subject to NSPS and/or MACT requirements. No emission limits were established since their emissions are small. The permittee shall ensure these units are properly maintained and repaired. Navajo complies with MACT Subpart 2222. Unit M-8010 was installed 11/04/2013. The engine was Operated a total 0.0 hours during the reporting period. El Continuous IE Intermittent ?Monitoring: Maintenance and repair shall meet the minimum manufacturer's or permittee?s recommended maintenance schedule. Activities that involve maintenance, adjustment, replacement, or repair of functional components with the potential to affect the operation of an emission unit shall be documented as they occur for the following events: (1) Routine maintenance that takes a unit out of service for more than two hours during any twenty~four hour period. (2) Unscheduled repairs that require a unit Navajo complies with MACT Subpart 222.2. 1) and 2) Unit operating hours are monitored. the unit was not taken out of service greater then two hours in any twenty?four hour period. Continuous Intermittent Yes No Yes No ACC Form Part 1 Permit P05 I-R2 Ver 4.1 02/25/2015 Page 59 of 143 EPA Inspection Report - Page 619 of 1969 Version 02.25.15 to be taken out of service for more than two hours in any twenty-four hour period. Recordkee in The permittee shall - maintain rle'cogds in accordance with Navajo complies With MACT Subpart DContmuous lZlYes I: Yes t. incl . . . Intermittent No IZI No Sec 1011 ing . reoords 0f Unit M43010 1s equ1ped With a non-resemble run? mamtenance and repairs and a . time meter. Navajo keeps quarterly rolling annual copy of the manufacturers or permittee?s . total hours on ?le. recommended maintenance schedule. Reporting: The permittee shall report in Reports required by B110 are submitted as Continuous Yes Yes accordance with Section Bl 10. necessary El Intermittent N0 El No A201 Engines Continuous Yes El Yes B. 40 CFR 63, Subpart 2222 (Units G- Intermittent No No 0100, G-0101, V-0545, E-8010, E-0600W, E-0601M, E- 0603, and E-0901) (Units subject in Table 103"] Navajo complies with Subpart Requirement: The units listed as subject in Table 103.] are subject to 40 CFR 63, Subpart 2222 and the pennittee shall comply with all applicable requirements of Subpart A and Subpart Monitoring: The perrnittee shall comply El Continuous Yes Yes all applicable monltonng and Navajo complies with Subpart 2222. XI Intermittent N0 N0 requirements of 40 CFR 63, Subpart A and Subpart Recordkeeping: The permittee shall El Continuous El Yes El Yes comply with all applicable recordkeeping requirements of 40 CFR 63, Subpart A and Navajo complies with Subpart Intermittent No El N0 Subpart 2222, including but not limited to 63.6655 and 63.10. ACC Form Part 1 Permit it P051-R2 RZME Page 60 of 143 Ver 0325/2015 EPA Inspection Report - Page 620 of 1969 Version 02.25.15 Reporting: The permittee shall comply with all applicable reporting requirements of 40 CFR 63, Subpart A and 2222, including but not limited to 63.6645, 63.6650, 63.9, and 63.10. Reports required by Subpart were submitted semiannuaily as follows: 1/30/2018 7/3 0/201 8 El Continuous IX, Intermittent Yes El No El Yes No A201 Engines C. 40 CFR 60, Subpart 1111 (Diesel Engines subject in Table 103.] Requirement: The units listed as subject in Table 103.] are subject to 40 CFR 60, Subparts A and and shall comply with the noti?cation requirements in Subpart A and the speci?c requirements of Subpart Navajo complies with Subpart 1111. El Continuous IX, Intermittent Yes No El Yes IXI No Monitoring: The permittee shall comply with all applicable monitoring and testing requirements in 40 CFR 60, Subpart A and Subpart 1111, including but not limited to 60.421 l. Navajo complies with Subpart 1111. [3 Continuous Intermittent Recordkeeping: The permittee shall comply with all applicable recordkeeping requirements in 40 CFR 60, Subpart A and Subpart 1111, including but not limited to 60.4214. Navajo complies with Subpart 1111. El Continuous IXI Intermittent IXI Yes N0 El Yes IXI No Reporting: The permittee shall comply with all applicable reporting requirements in 40 CFR 60, Subpart A and Subpart 1111, including but not limited to 60.4214. Navajo complies with Subpart 1111. El Continuous Intermittent Yes El No El Yes IE No A203 Tanks A. NSPS Subpart K, Standards of Performance for Storage Vessels for Petroleum Liquids for Which Navajo continues to comply with the applicable requirements of NSPS Subpart K, as applicable to the affected storage tanks shown in Table 103C of this permit, except for inspections listed as deviations in previously submitted reports. El Continuous Intermittent Yes El No El Yes IX, No ACC Form Part 1 Permit ti P051-R2 Ver 4.1 02/259015 Page 61 of 143 EPA Inspection Report - Page 621 of 1969 Version 02.25.15 Construction, Reconstruction, or Modi?cation Commenced After June 11, 1973, and Prior to May 19, 1978 (Tanks subject in Table Requirement: The pennittee shall comply with all applicable requirements of 40 CF 60, Subparts A for the affected sources in Table 103C. External and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements 0f40 CFR 60, Subpart K. Navajo continues to comply with the applicable requirements of NSPS Subpart K, as applicable to the affected storage tanks shown in Table 103C of this permit, except for inspections listed as deviations in previously submitted reports. External and internal floating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required, The true vapor pressure is based on the material stored and maximium historical data. El Continuous Intermittent Yes No El Yes No Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart K. External and internal floating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. El Continuous Intermittent Yes No El Yes IXI No Reporting: The permittee shall comply with the applicable reporting requirements of 40 CF 60, Subpart K. Navajo submits noti?cations of seal inspections to the Department. El Continuous Intermittent Yes No El Yes IXI No A203 Tanks B. NSPS Subpart Ka, Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modi?cation Commenced After May 18, 1978, and Prior to July 23, 1984 (Tanks Navajo continues to comply with the applicable requirements of NSPS Subpart Ka, as applicable to the affected storage tanks shown in Table 103C of this permit, except for inspections listed as deviations in previously submitted reports. External and internal ?oating roof tank seals are periodically inspected as required. Records are El Continuous Intermittent Yes El No El Yes IXI No ACC Form Part 1 Permit P05 l-R2 Ver 4.1 02/25/2015 Page 62 of 143 EPA Inspection Report - Page 622 of 1969 Version 02.25.15 subject in Table Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A Ka for the affected sources in Table 103C. maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart Ka. Navajo continues to comply with the applicable requirements of NSPS Subpart Ka., as applicable to the affected storage tanks shown in Table 103C of this permit, except for inspections listed as deviations in previously submitted reports. External and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. El Continuous Intermittent Yes El No El Yes No Reeordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart Ka. External and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The true vapor pressure is based on the material stored and maximium historical data. El Continuous Intermittent Yes El No El Yes No Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart Ka. Navajo submits noti?cations of seal inspections to the Department. El Continuous IXI Intermittent Yes I: No El Yes No A203 Tanks C. NSPS Subpart Kb, "Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modi?cation Commenced After January 23, 1984" (Tanks subject in Table Requirement: The permittee shall comply Navajo continues to comply with the applicable requirements of MACT Subpart CC as applicable to the processes shown in Table 103 B, C, D, G, except for deviations previously reported or identi?ed at the end of this report. Fugitive components subject to these rules are included in the Leak Detection and Repair (LDAR) program. Navajo uses a third?party contractor for the LDAR monitoring and recordkeeping. Navajo continues to comply with the applicable El Continuous IXI Intermittent ACC Form Part. 1 Permit Ver 4.l 02/25/2015 IXI Yes El No El Yes IXI No Page 63 of I43 EPA Inspection Report - Page 623 of 1969 Version 02.25.15 With all applicable requirements of 40 requirements of MACT Subpart CC as applicable to CFR 60, Subparts A Kb for the affected the affected storage tanks, except for inspections sources in Table 103C. listed as deviations in previously submitted reports. External and internal ?oating roof tank seals are periodically inspected as required. Records are maintained of the materials stored and the storage temperature as required. The loading rack subject to portions of MACT Subpart incorporated by reference into MACT CC is equipped with a carbon adsorption system monitored by a CMS. Pugitive components subject to these rules are El Continuous Yes El Yes 1ncluded. 1n the Leak Detection and Repalr (LDAR) program. Navajo uses a third?party contractor for Intermittent No No Monitoring: The pet?mittee Shall comply the LDAR monitoring and recordkeeping. with the applicable monitoring and testing requirements of 40 CFR 60, Subpart Kb. The loading rack subject to portions of MACT Subpart incorporated by reference into MACT CC is equipped with a carbon adsorption system monitored by a CMS. Recordkeeping: The permittee shall Navajo mamtams records at the Env1ronmental . El Continuous Yes El Yes comply with the applicable recordkeeping Of?ce, W1th the on?s1te LDAR contractor, and With Holly Energy Partners (HEP) for the gasolme l2] Intermittent El No No requtrements of 40 CFR 60, Subpart Kb. loading rack. Reporting: The permittee shall comply :lsagj??gmlte?l Sprart CC reports semiannually El Continuous Yes El Yes With the applicable reporting requirements 2/28/2018 Intermittent El N0 N0 0f40 CFR 60, Subpart Kb. 8/30/2018 A203 Tanks Continuous Yes El Yes Navajo maintains records at the Environmental D. MACT Subpart CC, ?National of?ce, with the on?site LDAR contractor, and with Intermittent El No Emission Standards for Hazardous Air Holly Energy Partners (HEP) for the gasoline Pollutants from Petroleum Re?neries? loading rack- (Tanks subject in Table 103C) Requirement: The permittee shall comply Navajo maintains records at the Environmental . El Continuous Yes El Yes with all applicable requirements 0 fM A CT office, W1th the on?SIte LDAR contractor, and With . . Holly Energy Partners (HEP) for the gasoline Intermittent No No Subpart CC, ?Natlonal Emisswn Standards loading rack. ACC Form Part 1 Permit R2M1 Page 64 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 624 of 1969 Version 02.25.15 for Hazardous Air Pollutants from Petroleum Re?neries? for all affected. sources shown in Table 103C attached. (63.640). . Co t'n 0 Monitoring: The peI?mlttee Shall comply Navajo maintains records at the Environmental us El es I: es with the applicable monitoring and Of?ce, with the onnsite LDAR contractor, and with El Intermittent No No testing requirements of 40 CFR 63, Holly Energy Partners (HEP) for the gasoline Subpar?t CC. loading rack. Recordkeeping: The pet?mittee Shall Navajo maintains records at the Environmental El Continuous El Yes El Yes comply with the applicable of?ce, with the on-site LDAR contractor, and with recordkeeping requirements of 40 CFR Energy Partners (HEP) for the gasoline NO NO 63 .655. loading rack. Reporting: The permittee shall comply NanlJ'O suginitedfh?ACT Subpart CC reports Continuous Yes Yes with the applicable reporting requirements smmannua as ?40 CFR 63 655 2/28/2018 El Internuttent No No 0 - - 8/30/2018 A203 Tanks IXI Continuous Yes Yes Intermittent El No No E. Tank Throughput, Temperature, and VOC and H28 Limits (Units shown in Tables 106.13 C) Requirement: Compliance with. the allowable throughput limits and emission NEIVEIJO 00111131163 through Pi data. limits in Table 106D shall be demonstrated by not exceeding the rolling 12-month total throughput t0 the unit(s) of gallons per year (barrels/year) shown in Table 106D and not exceeding the allowable vapor pressure listed in Tables 106.13 C. Monitoring: The permittee shall monitor Navajo complies through Pi data. Continuous Yes El Yes the total throughput, max1mum ACC Form Part 1 Permit Page 65 of I43 Ver 4.1 02/25/2015 EPA Inspection Report - Page 625 of 1969 Version 02.25.15 temperature once per month and the vapor pressure of each tank. ?3 Intermittent KING Recordkeeping: The permittee shall record the total throughput of liquids and the vapor pressure of each tank. Each month, during the ?rst 12 months of monitoring, the permittee shall record. the cumulative total liquid throughput and vapor pressure and after the ?rst 12 months of monitoring, the permittee shall calculate and record a rolling 12-month total liquid throughput and the vapor pressure of each tank. The permittee has calculated the VOCs and H28 annually based on the 12?month total. Tank breathing and working emissions were calculated using the USEPA Tanks program Version 4.0.9.d or more current. Emission. rates computed using the same parameters, but with a different Department approved algorithm that exceed these values will not be deemed non?compliance with this permit. Records shall also be maintained in accordance with Section B109. Navajo complies through Pi data. Continuous Intermittent Yes No Yes IXI No Reporting: The permittee shall report in accordance with Section B1 10. Navajo complies through Pi data. El Continuous Intermittent DNO. Yes IXI No ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 66 of 143 EPA Inspection Report - Page 626 of 1969 Version 02.25.15 A204 Heaters/Boilers A. Operational Inspection (All heaters/boilers in Tables 103.E 104A) Requirement: Compliance with the allowable emission limits in Table 106A shall be demonstrated by performing periodic inspections to ensure proper operations. IHSpections were performed to ensure proper operation, I: Continuous IZI Intermittent Yes No Yes No Monitoring: The permittee shall conduct annual operational inspections to determine that the are operating properly. The operational inspections shall include operational checks for indications of insuf?cient excess air, or too much excess combustion air. These operational checks shall include observation of common physical indications of improper combustion, including indications speci?ed by the heater/boiler manufacturer, and indications based on operational experience with the/these unit(s). Inspections were performed to ensure proper operation. El Continuous Intermittent Yes I: No Yes No Recordkeeping: The permittee shall maintain records of operational inspections, describing the results of all operational inspections noting chronologically any adjustments needed to bring the into compliance. The permittee shall maintain records in accordance with Section 3109. Inspection results are maintained by Navajo Environmental Department. El Continuous IZI Intermittent ACC Form Part 1 Permit P05 1 Ver 4.1 02/25/2015 Page 67 of 143 EPA Inspection Report - Page 627 of 1969 Version 02.25.15 Reporting: The permittee shall report in Continuous Yes El Yes accordance with Section B110. Intermittent El 0 0 Within ninety (90) days Ofpermit $31121an Navajo submited MACT Subpart reports the permittee shall submit for Department semiannually as fouows: approval a procedure which the permittee 1/30/2013 will use to carry out the operational 7/30/2018 inspections. The permittee may at any time submit revisions for Department approval. A204 Heaters/Boilers . Continuous El Yes El Yes Testing was performed as follows: B. Periodic Emissions Tests (Units Heaters 01/11/2018 Intermittent El N0 El N0 H-0019, H-0020, 140020 01/11/2018 0364, 14-2421, and H-3403) 30362 01/31/2013 01/31/2018 Requirement: Compliance with allowable 3:333: 353533 6111188101] 11] Table l06.A shall be H-3402 01/3 1/2018 demonstrated by performing periodic 02/01/2013 emissions tests. (NSR 0195M35, All heaters were within allowable emission limits. Condition A204.A, revived) Monitoring: The permittee shall conduct El Continuous Yes Yes Teslflin?0f?solijf5?3fg as follows and 01/11/2018 Test results that demonstrate compliance H-0362 01/31/2018 with the CO emission limits shall also be H-03 63 01/31/2018 considered to demonstrate compliance 01/31/2018 with the VOC emission limits. 03/20/2018 Section B108 General Monitoring H3402 01/31/2018 Requirements apply to this condition. 116403 02/01/201-8 . . . . All heaters were Within allowable emissmn lumts. The permittee shall meet the testing requirements in Section .B1 1 l. ACC Form Part 1 Permit R2M 1 Ver 4.1 02/25/2015 Page 68 of I43 EPA Inspection Report - Page 628 of 1969 Version 02.25.15 Recordkeeping: Records of periodic .C?mtimm? gYes I: Yes emission tests shall include the ?ow rate El Intermittent No and the stack gas exhaust temperature. If a combustion analyzer is used to measure NOX, CO, and/or excess air in the ?ue gas, records shall be kept of the make and model of the instrument and instrument calibration data. If an ORSAT apparatus Periodic emission test results are maintained by or other gas absorption analyzer is used, Navajo Environmental Department. the permittee shall record all calibration results. Records shall be kept of all raw data. used to determine ?ue gas ?ow and of all calculations used to determine ?ow rates and emission rates. The permittee shall maintain records in accordance with Section B109, B110, and Bl l. Reporting: The permittee shall summarize Continuous Yes Yes in tabular form the results of the initial or subsequent periodic emissions tests for Elmermittent NO): and CO, specifying the mass emissions rates in pounds per hour. The All testing reports were submitted to the NMED at table shall include the average concentration of all relevant pollutant species. The permittee shall report in accordance with Section B109, B1 10, and Bl l. A204 Heaters/Boilers Continuous Yes Yes IXI Intermittent IXI No No C. Summary of Compliance Methods for Heaters and Boilers for Table 106. A, Navajo complies with these requirements, except 20.2.33 NMAC, 20.2.37 NMAC (Boilers for deviatfiogs previously reported or identi?ed at and Heaters in Tables 103.E and 104A) the end 0 ?3 r3130?. Requirement: (NSR 0195M35, ACC Form Part 1 Permit P05 RZMI Page 69 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 629 of 1969 Version 02.25.15 Condition A2043) (1) Demonstrate compliance with Table 106A Allowable Emissions. (2) 20.2.33 NMAC (Gas Burning Equipment Nitrogen Dioxide, 10/31/02) applies to existing and new gas burning equipment having a heat input of greater than 1,000,000 million British Thermal Units per year. lt applies to process heaters identi?ed in Tables 103E and 104A. These units shall be equipped with burners emitting less than 0.2 lb per MM Btu. Compliance with 20.2.33 NMAC is demonstrated by compliance with the NO): lb per MM Btu limits in Table A106.A. Monitoring: (1) The permittee shall monitor the fuel usage of the all boilers and heaters. The fuel usage shall be monitored for speci?c heaters and boilers subject to 20.2.33 NMAC. (2) For specific heaters and boilers subject to 20.2.33 NMAC, the perrnittee shall collect and analyze samples of the re?nery fuel gas at least once per week. The re?nery fuel gas analysis shall include the composition of the rciinery fuel gas, the gross heating value, and the net heating value. (3) See Condition for HZS monitoring requirements. (4) All process heaters and boilers shall ?re only refinery gas in accordance with 1) Fuel use measured by Pi. 2) Refinery fuel gas is analyzed at least once per week. 3) Refer to response for Section A100.A 4) No combustion sources ?re only purchased gas. 5) The following combustion sources have CMS that are recerti?ed annually as follows: B-0007 03/06/2018 13-0008 03/07/2018 03/07/2018 03/20/2018 01/10/2018 6) Test results referenced in Condition A104.B meet this requirement. 7) Navajo complies through .Pi data. Continuous El Intermittent Yes :1 No 1:1 Yes No ACC Form Part 1 Permit P05 1 -R2 Ver 4.1 02/25/2015 Page 70 of143 EPA Inspection Report - Page 630 of 1969 Version 02.25.15 Application, Section 2, Table 8) Navajo Re?nery is no longer affected by 20.2.37 NMAC. This rule was repealed on (5) For those combustion sources requ1red September 12, 2016. to have a continuous monitoring system (CMS) (listed in (21) below), the permittee shall install, certify, calibrate, maintain, and operate the CMS for each required pollutant in accordance with the applicable requirements of 40 CFR 60 or 63. The hourly average CMS data, the re?nery fuel gas usage data, and the re?nery fuel gas composition data shall be used to estimate the actual emission rates. The following CMS shall be recerti?ed annually: 0 Boiler NOX and 02 CMS *9 Boiler B-0008 NOX and 02 CMS - Boiler B-0009 NOX and 02 and CO2 CMS 0 H-9851 NOX 02 CMS H-2501 NOX 02 CMS (6) For those combustion sources required to conduct periodic stack exhaust testing as stated in Condition A204.B, the test reports shall be used to demonstrate compliance with the CO, and VOC limits in Table 106A. (7) For those units and pollutants that are not required to have a CMS or a periodic stack test, (Units 1, H- 0018, H-0030, H-0040, 11?0312, H-0352, H-0353, 11-0354, 0355, H-0464, H-0473, H-0600, ACC Form Part 1 Permit it Page 71 of I43 Ver 4.1 02/252?2015 EPA Inspection Report - Page 631 of 1969 Version 02.25.15 H-0601, H-8802, and 101) the permit application emission factor, the fuel usage, and the re?nery fuel gas analysis shall be used to calculate the emission rates CO, VOC, and PM. (8) Compliance with the particulate emission limitation set forth in 20.2.37.202.A NMAC shall be determined as specified in NMAC. Combustion of only gaseous fuel has been approved by the Department as the compliance method under NMAC. Recordkeeping: The permittee shall Continuous Yes Yes maintain the following records: IXI Intermittent No IXI N0 (1) By March 31, the annual fuel usage for all boilers and heaters for the previous calendar year. (2) By March 31, the average fuel 1) Fuel usage records are maintained in Pi. composition and heating value for all boilers and heaters for the previous calendar year. 2) Fuel composition records are maintained in Pi. 3) CMS data is maintained on Pi. (3) For those units required to have a CMS (B-0007, 13-0009, H-9851 4) Test reports are maintained by Navajo and the CMS hourly average B?ViTOHme?tal Depa?ment data. 5) The summary Spreadsheet is included in the (4) For those units required to conduct Emission Inventory. periodic stack exhaust testing, the periodic test report. (5) For all boilers and heaters, a summary spreadsheet shall be maintained comparing the actual annual emissions with the allowable emission limits expressed in ACC Form Part 1 Permit P051-R2 R2M1 Page '72 of 143 Ver 4.1 EPA Inspection Report - Page 632 of 1969 Version 02.25.15 tons per year and lb/MMBtu using the appropriate method of compliance demonstration. This spreadsheet shall be updated by March 31 of each year for the previous calendar year. . . . - El Continuous Yes El Yes Reporting. The permittee shall report in Reports required by El 10 are submitted as accordance With Sections Bl 10. necessary Intermittent No El No A204 Heaters/Boilers El Continuous El Yes Yes Intermittent N0 El No D. Consent Decree Emission Limits for Boilers B-0007, B-0008, and B-0009 (new as of2013) Requirement: (NSR 01 95M3 5, Condition A204.C) (1) In accordance with the Consent Decree lodged December 20, 2001, emissions from boilers B-0007 (no later than December 31, 2002), B-0008 (no later than December 31, 2003), and B-0009 (new as of 201 3) shall not exceed the limit in Table 106.A during any hourly rolling 3-hour period. Demonstration of compliance with the NOX limit for B-0007, and B- 0009 shall be established by averaging the CMS Data over any 3~hour period and comparing the average concentration to the parametric limit of 42.1 corrected to 6.1% 02 as determined by the CMS. (comao) This also satis?es the requirement in 20.2.33 . 08.A NMAC that emissions 1) Data maintained in Pi. 2) No requirement. ACC Form Part 1 Permit R2MI Ver 4.1 02/25/2015 Page 73 of 143 EPA Inspection Report - Page 633 of 1969 Version 02.25.15 shall not exceed 0.2 (2) Navajo is authorized to operate all three boilers (B-0007, B-0008, and B- 0009) simultaneously as needed. Monitoring: For the Controlled Boilers (B-0007, B-0008) as listed in the Consent Decree and (new as of 2013), continuous compliance with their respective permit emissions limits shall be demonstrated by monitoring as follows: (1) For boilers (Bw0007, B-0008, and 0009) with a heat input capacity greater than 150 0f HHV, the permittee shall install or continue to operate CMS to measure and 02. Each CMS shall be installed, certi?ed, calibrated, maintained, and operated in accordance with the requirements of 40 CPR 60.11, 60.13, and Part 60 Appendix A and the applicable performance speci?cation test of 40 CFR Part 60 Appendices and F. These CMS shall be used to demonstrate compliance with emission. limits. The permittee shall make CMS and process data available to the applicable Federal and State Agencies upon demand as soon as practicable; (coarser) 1) have CMS installed and data maintained in Pi. El Continuous Intermittent El Yes No El Yes No Reco rdkeeping: The permittee shall keep records of the CMS recerti?cation?s monitored in Condition A204.B, Summary of Compliance. CMS recerti?cations are maintained by the Navajo Environmental Department. El Continuous El Intermittent Yes No Yes No ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 74 of 143 EPA Inspection Report - Page 634 of 1969 Version 02.25.15 Reporting: The permittee shall 1?6port in All testing reports were submitted to the NMED at 12' Continuous Yes Yes accordance with Section Bl 10. Intermittent No 0 A204 Heaters/Boilers Continuous Yes Yes E. NOX Monitoring and Testing for Intermittent Controlled. Heaters Subject to the Consent Decree (Units H-0352, H-0353, H-0600, and H-0601) CMS installed and data maintained in Pi. Requirement: For the Controlled Heaters as listed in the Consent Decree, continuous compliance with all NOX emissions limits shall be demonstrated by monitoring as follows. (CD111 6.C) (NSR 0195M35, Condition A204.D) Monitoring: Continuous Yes Yes (1) For heaters with a heat input capacity [3 Intermittent El No No of equal to or less than 150 (HHV) but greater than 100 (HHV), Navajo shall install or continue to operate CMS to measure and 02 by no later than the date of the installation of the applicable NOX Control Technology on the heater or boiler; or submit for EPA approval, by no later than 60 days after the date of installation of the applicable NOX Control Technology on the heater or boiler, a pr0posal for monitoring based on operating parameters, including but not limited to, firebox l) is equipped with NOX and 02 CMS that is certi?ed, calibrated, maintained and operated in accordance with the referenced requirements. 2) Referenced heaters meet these requirements. All initial performance tests have been reported. 3) Referenced heaters were initially tested and are tested annually. is monitored weekly using a handheld portable analyzer. ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 75 of I43 EPA Inspection Report - Page 635 of 1969 Version 02.25.15 temperature, air preheat temperature, heat input rate, and combustion 02. Navajo shall evaluate the necessity of using ?rebox or bridgewall temperatures and additional operating parameters and agrees to use such parameters as a means of monitoring performance where Navajo and EPA mutually-agree to their effectiveness. (CD1l16.C.ii). As of January 23, 2014 (notarized date of application), there are no heaters or boilers at the Artesia Re?nery with a capacity of equal to or less than 150 (HHV) but greater than 100 (HHV) subject to Monitoring requirement (2) For heaters with a heat input capacity of equal to or less than 100 of HHV, the permittee shall conduct an initial performance tests for The results of these tests shall be reported based upon an average of three (3) one?hour testing periods and shall be used to develop representative operating parameters for each unit, which will be used as indicators of compliance. This condition applies to the following heaters: a Heaters H-0352, and H-0354 9 Heater Heaters H-0600 and H-0601 The permittee has completed all of the initial performance tests. ACC Form Part 1 Permit P051-R2 R2M1 Page 76 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 636 of 1969 Version 02.25.15 (3) For heater H-060l compliance shall be demonstrated by continuously monitoring stack oxygen (02) to maintain a 3~hour average below 6.0 vol%. As a further check of compliance, Navajo shall monitor stack NOX at least twice a month using a portable analyzer to assure that the measured NOX value does not exceed the compliance threshold of 38 NOX. Continuous El Yes El Yes Recordkeeping: Intermittent El No El No l) The permittee shall keep records of the Fuel ?ring rates and Sulfur limits 1) Fuel ?ring rate records are maintained in Pi. monitored for Condition A1 10A. 2) and 3) Test records are maintained by the Navajo (2) The permittee shall keep records of the Environmental Department. initial performance tests. (3) The permittee shall keep records of the stack oxygen monitoring and the portable analyzer tests. Reporting: The permittee shall report in Continuous Yes Yes accordance with Section Bl 10. Condition Reports required by Bl 10 are submitted as . 8.1 does not apply to portable applicable. Interm?ttent analyzer tests. A204 Heaters/Boilers Continuous Yes Yes F. Monitoring and Testing for Intermittent El 0 No Heaters permitted after the Consent Decree (Units Heaters H-0362, H-0363, H9421: H6402: Navajo complies with these requirements. 250], and H-9851) Requirement: For the Heaters permitted after the Consent Decree, continuous compliance with their respective ACC Form Part 1 Permit ii P05 1 -R2 Page 77 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 637 of 1969 Version 02.25.15 permit emissions limits in Table 106.A shall be demonstrated by monitoring as follows. (NSR 0195M35, Condition A204.E) Monitoring: IXI Continuous IXI Yes El Yes (1) For heaters with a heat input capacity IE Intermittent El No No greater than 150 MM Btu/hr (LHV Basis), the permittee shall install and operate CMS to measure and 02 by the startup date of each heater. Each CMS shall be installed, certi?ed, calibrated, maintained, and. Operated in accordance with the requirements of 40 CFR 60.11, 60.13, and Part 60 Appendix A and the applicable performance speci?cations of 40 CFR Part 60 Appendices and F. These CMS shall be used to demonstrate compliance With 611115510? limitse The 2) H-2501 anssoussoz has a CMS installed and permittee shall make CMS and process data maintained in Pi. data available to the applicable Federal and State Agencies upon demand as soon as 3) Initial performance tests were completed as practicable. Condition applies required. to heater (2) For heaters with a heat input capacity of equal to or less than 150 MM Btu/hr (LHV) but greater than 100 MM Btu/hr (LHV), Navajo shall: 1) 11-9851 has a CMS installed and data maintained in Pi. 4) Navajo complies with these requirements. install and operate CMS to measure NOX and by the startup date of each heater; or submit to the Permit Program Manager for NMED approval, by no later than 90 days a?er the startup date of each heater, a proposal for ACC Form Part 1 Permit P051-R2 Page 78 of M3 Ver 4.1 02/25/2015 EPA Inspection Report - Page 638 of 1969 Version 02.25.15 monitoring based on operating parameters. Operating parameters to consider include, but are not limited to, ?rebox temperature, air pre-heat temperature, heat input rate, and combustion 02. Navajo agrees to use such parameters as a means of monitoring performance. Condition applies to heaters and (3) For heaters with a heat input capacity of equal to or less than 100 MM Btu/hr (LHV basis), the permittee shall conduct an initial performance test by no later than 180 days after the startup date. The results of this test shall be reported based upon an average of three (3) one?hour testing periods and shall be used to develop representative operating parameters for each unit, which will be used as indicators of compliance. This condition applies to the following heaters: . Heaters H-0363, H- 0364, and H-2421 9 Heater 9 a Heaters H-3402 (AMP approved by EPA, see initial performance test completed on July 10, 2013 9 Heater H-3403, initial performance test completed on April 30, 2013 (4) US EPA has approved an Alternative ACC Form Part 1 Permit Page 79 of 143 Ver4.1 02/25/2015 EPA Inspection Report - Page 639 of 1969 Version 02.25.15 Monitoring Plan (AMP) for Unit H-3402 for utilizing the oxygen monitor on the H-3402 Unit 34 Hydrocracker Reboiler 1 as a parametric means for demonstrating compliance with NSPS a, NOX monitoring via a CMS. In accordance with the AMP, the permittee shall accomplish the following: lnstall ?ow indication on the fuel line to provide historical data of the fuel to the Mild Hydrocracker (Unit 34) by January 15?, 2015. Monitor the process historical data of the HEP purchased natural gas pressure, and the high pressure fuel. balance drum Upgrade the existing the Mild Hydrocracker (Unit 34) Reboiler Heater oxygen monitor to perform daily calibrations as required in 40 (Note that the sample placement does not conform to CMS requirements for process reasons). Conduct biennial performance tests according to the requirements in 40CFR Establish a maximum or curve excess 02 operating limit (MOPV) as required under 40 utilizing the existing monitor. Include Reboiler Heater (PI-3402) ACC Form Part 1 Permit R2M1 Page 80 of143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 640 of 1969 Version 02.25.15 hours of re?nery fuel gas usage and any deviations during such time as required by 40 CFR 60.7 for periodic reporting. IE Continuous IE Yes El Yes Recordkeeping: K1 Intermittent No No The permittee shall keep records of the monitoring proposals submitted to the Permit Program Manager for approval and whether the submittal was approved. 1) Records are maintained by the Navajo Environmental Department. 2) CMS data maintained in Pi. (2) The permittee shall keep records of the CMS data, calibration, and recertification?s 3) Performance tests are maintained by the Navajo monitored in Condition A204.A, Summary Environmental Department. of Compliance. 4) the AMP is maintained by the Navajo (3) The permittee shall keep records of the Environmental Department. performance tests. (4) The permittee shall keep records of the implementation of the AMP and all required monitoring Specified in the AMP. Reporting: The permittee shall report in Reports required by B110 are submitted as Continuous El Yes Yes accordance with Section Bl 10. applicable. Intermittent No No A204 Heaters/Boilers El Continuous Yes I:l Yes IE Intermittent I:l No IE No G. NSPS Subpart Db, Standards of Performance for Industrial-Commercial? Institutional Steam Generating Units Heater and Boilers and (Boilers and heater subject in Table 103.13) 0009 each have a NOX CEMS as required by NSPS Subpart Db. Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A Db (NOx?60.44b, SOz-60.42b, for the ACC Form Part 1 Permit it P051-R2 RZME. Page 81 of 143 Ver 4.1 5 EPA Inspection Report - Page 641 of 1969 Version 02.25.15 affected sources in Table M. Monitoring: The permittee shall comply . Continuous Yes Yes with the applicable monitoring and testing Heater He2501 and Bo1lers and requirements of 40 CFR. 60.48b, Subpart gagiaiacgbhave a NOX GEMS as reqmred by NSPS Intermittent No No Db. Reeordkee in The ermittee shall . . . . NOX records are maintained in Pi. Test records are Continuous Yes Yes comply WIth the applicable recordkeep 111g maintained the Nava'o Environmental requirements of 40 CFR 60.49b, Subpart Intermittent epartment. Db. Reporting: The permittee shall comply New?? Smeited NSPS subpm Db reports Continuous Yes Yes with the applicable reporting requirements semlannually as fellows; l/30/20l 8 Intermittent No IXI No of 40 CFR 60.49b, Subpart Db. 7/30/2018 Compliance Test: The permittee shall Continuous Yes El Yes comply with the methods and procedures Navajo complies with the requirements of the stipulated in 40 CFR. 60, Section 60.45b Compliance Testing. Intermittent Ne No and 60.46b. A204 Heaters/Boilers El Continuous Yes Yes H. NSPS Subpart Dc, Standards of Intermittent No No Performance for Small Industrial? Commercial - Institutional Steam Generating Units (Boilers and heater subject in Table 103,131 Navajo complies with the requirements of steam generating units. Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A Dc (NOx-60.44c, 802?60420, c) for the affected sources in Table 103.13. Monitoring: The permittee shall comply Continuous Yes Yes with the applicable monitoring and testing Navajo complies with the requirements of steam . . I tt requirements of 40 CFR 60.4%, Subpart generating units. em" 9" 0 0 Dc. ACC Form Part 1 Permit P05 -R2 Ver 4.1 02/25/2015 Page 82 of 143 EPA Inspection Report - Page 642 of 1969 Version 02.25.15 Recordkeeping: The permittee shall Continuous Yes El Yes comply with the applicable recordkeeping Navajo complies with the requirements of steam requirements of 40 CFR 60.48c, Subpart generating units. Intermittent El N0 N0 Dc. Reporting: The permittee shall comply El Continuous Yes El Yes Wlth,the applicable reporting Navajo complies with the requirements of steam El Intermittent No El No requirements of 40 CPR 60.48c, Subpart generating units. Dc. Compliance Test: The permittee shall Continuous Yes Yes comply with the methods and procedures Navajo complies with the requirements of steam . . . - . Intermittent N0 N0 stipulated in 40 CFR 60, Section 60.44c generating units- and 60.45c. Navajo continues to comply with the applicable El Continuous El Yes El Yes monitoring requirements of NSPS Subpart as applicable to the affected heaters, boilers, El Intermittent El No El No and the FCC shown in Table l03E. The re?nery fuel gas is continuously monitored for A204 Heaters/Boilers H2S content on a 3?hour rolling average basis. i; NSPS 81,.pr :11 Standai'ids .Of The tail gas incinerator is or ormance OI .etIo cum Re nenes continuously monitored for 802 content, corrected (Boilers and heater in Table 10313 to 0% 02, on a 12?hour rolling average basis. Requirement: The pennittee Shall comply The FCCU Catalyst Regenerator Scrubber exhaust with all applicable requirements of 40 is continuously monitored for 802 and CO. PM is CFR 60, Subparts A for the affected monitored annually. Navajo has submitted an sources in Table 103.13. alternative monitoring plan (AMP) to comply with the FCC opacity monitoring requirement because the FCCU has a wet scrubber which prevents continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CF 60 Appendix A Method 9. IXI Continuous IXI Yes El Yes Monitoring: The permittee Shall comply All of the continuous monitors are operated, ACC Form Part 1 Permit#P051-R2 Page 83 of 143 Ver 4.1 02050015 EPA Inspection Report - Page 643 of 1969 Version 02.25.15 With the applicable monitoring and maintained, and certi?ed as required. Intermittent El 0 N0 testing requirements of 40 CFR 60, Subpart J. Recordkeeping: The permittee shall Continuous Yes El Yes comply with the applicable Records are maintained by Navajo Environmental V4 . . . I tt recordkeeplng requirements of 40 CFR Department and 011 P1- emu en 0 N0 60,, Subpart J. Reporting: The permittee shall. comply Newly-0 sut?nitedejISPS 'SUhpartS repms Continuous Yes Yes with the applicable reporting requirements 8611111303331; as 0 Inte .0f40 CFR 60, Subpart J. 7/30/2018 ACC Form Part 1 Permit Page 84 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 644 of 1969 Version 02.25.15 Navajo continues to comply with the applicable El Continuous El Yes El Yes A204 Heaters/Boders monttoring requirements of NSPS Subpart a as applicable to the affected heaters, SRU3, and ?ares Intermittent No No J. NSPS Subpart Ja, Standards of as Shown Table 103E for Petroleum Refineries for The re?nery ?iel gas is continuously monitored for 10-1 Construction, 0r H28 content on a 3?hour rolling average basis. Modificatlon Commenced After May 14, 2007 (Boilers and heater subject in Table The ?ares met the minimum heating value, tip 103.13! velocity, and visible requirements as documented by the compliance testing detailed in previous Requirement: The permittee shall comply ?3513011333- With all applicable requirements of 40 . . . . CFR 60; Subparts A Ja for the affected The SRU3 tail gas incmerator IS contlnuously . monitored for $02 content, corrected to 0% 02, on sources 1n Table 103.E. . . a 12-hour rolling average basrs. 't ?tt ll 1 1' .Om orlng . he perrm 6? a comp All of the continuous monitors are operated, Continuous Yes Yes With the apphcablc momtormg and testing maintained and certi?ed as required requirements of 40 CFR 60, Subpart Ja. El Intermittent N0 131 No dk ll - ecor eeplng The .a Records are maintained by Navajo Environmental El Contlnuous Yes Yes comply With the applicable recordkeepmg Department and on Pi requirements of 40 CFR 60, Subpart a. Interm?ttent El No Reporting: The permittee shall comply New?? Smelted NSPS Spra?S J3 reports Continuous Yes Yes 'th t1 1. bl rt' . ent sennannually as follows: ?6 app ?03 mg req?mem 5 1/30/2018 El Intermittent No No A204 Heaters/Boilers El Continuous Yes Yes Intermittent No No K. BACT NOX Limit, Continuous Monitoring System (CMS) (Unit B0009) Navajo complies with the BACT requirements for B-0009, except for deviations previously reported Requirement: The permittee shall comply or identi?ed at the end of this report. with the allowable emission limits in Table 106A and Condition A106.E that represent BACT limits for the BACT requirements. (NSR 0195M35, Condition ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 85 of 143 EPA Inspection Report - Page 645 of 1969 Version 02.25.15 and revised) Monitoring: El Continuous Yes Yes (1) The Permittee shall comply with the El Intermittent El N0 El N0 CMS momtormg as detailed Condition 1) Navajo complies with Conditon A204.D. A204.D. (2) The permittee Shall an EPA 2) B-0009 went into service on 4/14/2015. The Method test Within Six (6) months of initial RATA compliance test was completed on permit issuance using EPA reference test 11/06/2015, except for deviations previously methods in 40 CFR 60 for and and reported or identi?ed at the end of this report. C02. Data from the CMS RATA testing may be used to satisfy this testing requirement. Recordkeeping: El Continuous Yes El Yes (1) The permittee shall keep records 0fthe l) Navajo complies with A204.B. El Intermittent No El N0 CMS initial calibration and recerti?cation monitored in Condition Summary 2) The initial compliance test was completed on of Compliance. 11/06/2015 (2) Records of EPA Methods tests shall be maintained for the Boiler. Reporting: El Continuous Yes Yes 1) The permittee shall report in El Intermittent No IXI No accordance with Section B1 10, to include the CMS initial calibration and 1) Navajo complies with B110. recerti?cation. (2) The permittee shall summarize in 2) The initial compliance test was completed on tabular form the results of the EPA 11/06/2015, except for deviations previously Methods tests for and 02 and C02, reported or identi?ed at the end of this report. specifying the emissions rates in pounds per hour and lb/MMBtu. The table shall include the average concentration of all relevant pollutant species. ACC Form Part 1 Permit P051-R2 R2M1 Page 86 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 646 of 1969 Version 02.25.15 A204 Heaters/Boilers L. MACT Subpart Industrial, Commercial, and Institutional Boilers and Process Heaters (Boilers and heater subject in Table Requirement: The units are subject to 40 FR 63, Subpart and the permittee shall comply with the applicable requirements of 40 CF 63, Subpart A and Subpart Navajo performs the annual tune up required by MACT Subpart IE Continuous IE Intermittent IE Yes El No Yes No Monitoring: The permittee shall comply with all applicable monitoring and testing requirements of 40 CFR 63, Subpart A and Subpart Navajo performs the annual tune up required. by MACT Subpart IE Continuous IE Intermittent Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63, Subpart A and Subpart Records are maintained by Navajo Environmental Department. El Continuous Intermittent Reporting: The pennittee shall comply with the applicable reporting requirements of 40 CFR 63, Subpart A and Subpart MACT Subpart reports were submitted semi?annually as follows: 01/30/2018 07/3 0/201 8 El Continuous Intermittent Yes No Yes No A204 Heaters/Boilers M. EPA Methods Test (Unit 13-0009) Requirement: Compliance with CO BA CT Limit and allowable emission limits in Table shall be demonstrated by emissions tests ensuring the unit is operating correctly and within desired Navajo complies with A204.K. The initial compliance test was completed on 11/06/2015. El Continuous Intermittent Yes El No Yes No ACC Form Part 1 Permit 8r. Ver 4.1 02/25/2015 Page 87 of 143 EPA Inspection Report - Page 647 of 1969 Version 02.25.15 parameters. (NSR 0195M35, Condition A204.K and revised) Monitoring: The permittee shall conduct El Continuous Yes Yes an EPA Method test no later than 180 days Intermittent El N0 0 after pennit issuance usmg EPA reference {1?1 49 CFR 90- Navajo complies with A2043. The initial 15 I?eqmred for CO- TeSt compliance test was completed on 11/069015. results that demonstrate compliance with the CO emission limits shall also be considered to demonstrate compliance with the VOC emission limits. Recordkeeping: Records of EPA Methods Navajo complies with A2043. The initial continno?? Yes Yes tests shall be maintained for the Boiler. compliance test was completed on llX06/2015. Intermittent El 0 g} 0 Reporting: The permittee shall report in . El Continuous Yes El Yes accordance with the requirements of The inittal compliance test was completed on Section B1 1 LB and summarize in tabular 11/06/2015, except for deviations previously Intermittent N0 N0 form the results of the EPA Methods test reported or identi?ed at the end of this report. . . . . . MACT Subpart reports were submitted or spec; ying em1ss1ons rates in mi-annually as follows: pounds per hour. The table shall include 01/30/2013 the average concentration of all relevant 07/30/20?; pollutant species. A204 Heaters/Boilers El Continuous El Yes Yes N. Veri?cation of Energy Ef?ciency Intermittent No No BACT Control Requirements (Unit 0009) Navajo complies with these conditions. The most . recent periodic inspection and tune-up was Requirement. The pennittee'shall comply completed on 02/06/2018. With the allowable emiss10n 11m1ts and the following BACT requirements. (NSR 0195M35, Condition A204.L and revised) 1. Operation and Maintenance (BACT ACC Form Part 1 Permit R2M1 Page 88 of I43 Ver 4.1 02/25/2015 EPA Inspection Report - Page 648 of 1969 Version 02.25.15 a. Periodic Boiler Tuning The boiler shall be tuned annually to maintain optimal thermal ef?ciency. b. Periodic Boiler Inspection. and Repair for air leakage The boiler shall be inspected annually to maintain optimal thermal efficiency. c. Periodic Boiler Inspection and Cleaning for tube fouling The boiler shall be inspected annually and necessary cleaning performed to prevent tube fouling. Next Generation Ultra-low-NOx high ef?ciency burners (NGULNB) shall be installed in the boiler design. Flue gas economizer (BACT A heat exchanger shall be installed to recover heat from the exhaust gas to preheat incoming boiler feedwater to attain industry standard performance (IMO) for thermal ef?ciency. Boiler insulation (BACT The boiler shall be designed and installed. with boiler insulation to an optimum insulation thickness and material to achieve maximum energy ef?ciency. The 0MP shall include the insulation ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 89' of 143 EPA Inspection Report - Page 649 of 1969 Version 02.25.15 design and maintenance schedule. 5. Oxygen Trim Control (BACT An Oxygen Trim Control system shall be designed and installed on the boiler to monitor oxygen concentration in the ?ue gas, and the inlet air ?ow is adjusted to maximize thermal ef?ciency. 6. Boiler blowdown minimization using manual analysis (BACT The Operation and Maintenance Plan (OMP) shall include methods and procedures to minimize blowdowns from the boiler to keep emissions at a minimum. 7. Condensate recovery (BACT Condensate shall be recovered as represented in the application to achieve maximum energy ef?ciency. Condensate recovery shall be maximized through annual steam trap inspections and repairs. Monitoring: The Permittee shall develop an Operation and Maintenance Plan (0MP) to include at least the requirements listed above within 12 months of commencement of operations. The Permittee shall review the OMP annually to ensure it?s effectiveness in meeting the requirements above and recommend changes. Navajo complies with these conditions. The initial compliance test was completed on 1 1/06/2015. The OMP was submitted on 04/12/20} 6. El Continuous Intermittent Yes No Yes No Recordkeeping: (1) Records demonstrating compliance with the energy ef?ciency requirement Navajo complies with these conditions. [1 Continuous Intermittent Yes No Yes No ACC Form Part 1 Permit ii POSI-RZ RZMI Ver 4.1 021?25/2015 Page 90 of 143 EPA Inspection Report - Page 650 of 1969 Version 02.25.15 shall be recorded and summarized in the 0MP. (2) The Permittee shall maintain a COpy of the 0MP onsite and available for inspection. Reporting: Continuous IXI Yes El Yes The permittee shall notify the Intermittent El N0 No Department What} the 0MP has been Navajo complies with these conditions. The 0MP prepared and available for rewew? was updated during this reporting period. Reports (2) The permittee shall report in the semi? required by B110 are submitted as applicable. annual report a summary of actions covered in accordance with the 0MP, and in accordance with Section B1 10. A204 Heaters/Boilers Continuous Yes Yes 0. Periodic Emissions Tests (Unit B-009, Intermittent CO BACT Limit) Navajo complies with these conditions. Requirement: Compliance with the CO BACT Limit and allowable emission limits in Table 106A shall be demonstrated by performing periodic emissions tests. Monitoring: The permittee shall conduct El Continuous Yes Yes periodic portable analyzer emission tests Intermittent El 0 No or EPA Reference Method Tests for CO at the intervals in the following schedule: First Test in accordance with the . . . Navajo complies w1th these Per10d1c schedule in Section B1 1 Test ?six (6) months after the teSt completed on' 3c?? 03/07/201 8 ?rst test is completed. All subsequent testing shall be done annually. Section B108 General Monitoring Requirements apply to this condition. Form Part 1 Permit R2MI Page 91 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 651 of 1969 Version 02.25.15 The permittee shall meet the testing requirements in Section B11 1. Recordkeeping: Records of periodic emission tests shall include the boiler fuel ?ow rate and the stack gas exhaust temperature. If a combustion analyzer is used to measure CO, and/or excess air in the ?ue gas, records shall be kept of the make and model of the instrument and instrument calibration data. If an ORSAT apparatus or other gas absorption analyzer is used, the permittee shall record all calibration results. Records shall be kept of all raw data used to determine ?ue gas ?ow and of all calculations used to determine ?ow rates and emission rates. The permittee shall maintain records in accordance with Section B109, B110, and B1 1 1. Data is maintained in Pi. El Continuous Intermittent Yes El No Yes No Reporting: The permittee shall summarize in tabular form the results of the initial or subsequent periodic emissions tests for CO, specifying the mass emissions rates in pounds per hour. The table shall include the average concentration of all relevant pollutant species. The permittee shall report in accordance with Section B109, B110, and. Bl 1.1. Reports required by B109, B110, and Bill are submitted as applicable. El Continuous Xi Intermittent Yes No Yes No ACC Form Part 1 Permit it P051-R2 Ver 4.1 02/25/2015 Page 92 of ?43 EPA Inspection Report - Page 652 of 1969 Version 02.25.15 A206 Flares Continuous Yes Yes Intermittent No No A. Requirement: (N SR 0195M35, Condition A206.A) 1) Fla-0403 is equipped with a ?are alarm. (1) An alarm system in good order shall be connected to Flare FL-0403 2) The fuel gas required to provide supplemental which will Signal non-combustion 0f the heat to either Flare FL-0400 or is gas. monitored during acid gas ?aring by a ?ow meter. (2) The acid gas ?ow meter for ?are No acid gas ?aring has occurred since September 5, 0400 or shall be operated and 2006- calibrated at a ??equency and by the procedure speci?ed by the manufacturer. A chart recorder or data logger (electronic storage) shall continuously record the amount of gas measured by the ?ow meter. Monitoring: The fuel gas required to Continuous Yes Yes provrde supplemental heat to e1ther Flare Intermittent 0 N0 FL-0400 or FL-0403 as required under A105.B shall be monitored during ?aring by a ?ow meter. The ?ow meter shall be operated continuously 24 hours 'per day, 365 days The fuel gas required to provide supplemental heat peryear except for p'enOdS 0f ?ow meter to either Flare or is monitored malntenance or repair. during acid gas ?aring by a ?ow meter. The upper range of the ?ow meter shall be suf?cient to record the highest expected ?ow rate of fuel gas sent to ?are. The reading of this ?ow meter and the ?ow meter to measure acid gas ?ow as required under Condition A105.B shall be ACC Form Part 1 Permit P05 l-R2 Page 93 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 653 of 1969 Version 02.25.15 used to determine compliance with emission limits at A106.C. . Continuous Yes Yes Recordkeeping: (1) Records of all periods of operation during which the ?are pilot Intermittent No No ?ame is absent as included in the MACT 5111313311 CC semi-annual ?3130113 1) Fiare pilot outages are included in the MACT CC semiannual reports dated as follows: (2) Records of the quantity of 02/23/2013 supplemental fuel used during each acid 08/30/2018 gas ?aring incident to provide 1) and 2) Records of supplemental fuel use and supplemental heat to ?are FL-0400 or ?are ?are pilot ?ame are maintained in Pi. (3) The permittee shall maintain records from the ?ow meter of the amount of gas sent to the ?are. l) Flare pilot outages are included in the MACT t? Reporting: The permittee Shall report in CC semiannual reports dated as follows: on inuous El es es accordance with Section Bi 10. 02/28/2018 Intermittent No No 08/30/2018 A206 Flares Continuous Yes Yes B. MACT Subpart CC, ?National El Intermittent No No Emission Standards for Hazardous Air Pollutants from Petroleum Refineries? Navajo complies with all the requirements of (Flares listed in Table 1033:! MACT CC as shown for ail affected sources in table 103.13. Navajo uses a third party LDAR Requirement: The permittee Shall comply contractor, except for deviations previously with all applicable requirements ACT reported or identi?ed at the end of this report. Subpart CC, ?National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries? for all affected sources shown in Tables 103.8. (63.640). Monitoring: The permittee shall comply Navajo complies with all the requirements of El Continuous Yes Yes 'MACT CC as shown for all affected sources In 6 pp 10a mon 0111 an es 111g table 103.B. Navajo uses a third party LDAR Intermittent No No requirements of 40 CFR 63, Subpart CC. contractor. ACC Form Part 1 Permit Page 94 of 143 Ver 4. 1 02/25/2015 EPA Inspection Report - Page 654 of 1969 Version 02.25.15 Recordkeeping: The permittee shall Navajo complies with all the requirements of. El Continuous Yes El Yes com 1 with the a licable recordkee in MACT CC as shown for all affected sources In I.) pp table 103B. Navajo uses a third party LDAR Intermittent No No requrrements of40 CFR 63.655. contractor. . . Nava'o com lies with all the re uirements of . Re Th errnittee shall 0 El Continuous Yes El Yes witlfliheneig ?Gail: If uirc 1:11:13! MACT CC as shown for all affected sources in pp 130 mg req table 103B. Navajo uses a third party LDAR Intermittent El N0 N0 Of40 CFR 63.655. ontractor. A207 Sulfur Recovery Plant (SPR), Tail Continuous Yes El Yes Gas Incinerator (TGI) Intermittent N0 No A. Consent Decree Requirements for SRP and TGI Requirement: In addition to the applicable requirements of SPS, 40 CFR 60, Subparts and a, the permittee shall accomplish the following: 1. Navajo shall route all Sulfur Recovery Plant (SRP) sulfur pit emissions from the SRP so that sulfur pit emissions to the atmosphere either are eliminated or are included and monitored as part of the applicable Sulfur Recovery Plant's tail gas emissions that meet the NSPS Subpart or Ja limit for 802. (CD 1l18.C.ii) 2. The SRP and TGI (and any supplemental control devices) shall be operated and maintained, to the extent practicable, in accordance with the obligation to minimize SRP emissions through implementation of good air pollution control practices required by 40 CFR at all times, including periods of start-up, shutdown, and malfunction. (CD 10 1) Sulfur Recovery Plant (SRP) sul?ir pit emissions are routed to the Tail Gas Incinerators and are continuously monitored as part of the applicable Sulfur Recovery Plant?s tail gas emissions that meet the NSPS Subpart limit for SOZ. 2) The SRP and TGU are operated and maintained, to the extent practicable, in accordance with the obligation to minimize SRP emissions through implementation of good air pollution control practices required by 40 CFR 60.1 at all times, including periods of start-up, shutdown, and malfunction. ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page 95 of 143 EPA Inspection Report - Page 655 of 1969 Version 02.25.15 (NSR 0 95 M3 5 Condition A207.A) Monitoring: The permittee shall comply with the applicable monitoring requirements of NSPS Subpart or a. All of the continuous monitors are operated, Continuous Yes Yes maintained, and certi?ed as required. Intermittent El No No Recordkeeping: The permittee shall IXIContinuous maintain records in accordance with the Records are maintained by Navajo Environmental applicable requirements of NSPS Subparts Department and on Pi. Intermittent and a. Reporting: The permittee shall report in New?? Sul?n?te? Subparts and a reports Continuous Yes El Yes accordance with the applicable 8611;130:331? as IE Intermittent l:l IE requirements of NSPS Subparts and a. 7/30/2018 0 0 A207 Sulfur Recovery Plant (S PR), Tail Continuous Yes Yes Gas Incinerator (TGI) IXI Intermittent No IXI No B. The following BACT work practices and equipment shall apply to the SRP (PSD-NM- 0195-M25) Maintain at least 98% SRP on- stream operations. This includes curtailing re?nery operations as necessary when SRU capacity is Navajo has installed BACT, and implemented the limited during planned startup, work practices, as described in this permit shutdown, and maintenance condition. events. Maintain adequate SRP excess capacity to reduce the frequency and quantity of re?nery excess emissions. After the re?nery expansion project proposed units are constructed, the proposed SRU3 will provide at least 25% excess capacity. Continue to maintain and use a ACC Form Part 1 Permit Page 96 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 656 of 1969 Version 02.25.15 (C) sulfur shedding plan to prevent or reduce acid gas ?aring events from re?nery upsets. An acid gas ?aring event is de?ned as excess emissions greater than 500 pounds in a 24?hour period. The plan shall state speci?c actions that may be taken to reduce or prevent acid gas ?aring. The actions taken during any event will be based on the re?nery operators? discretion, considering safety and other factors related to prudent operation. This plan is subject to review by NMED or EPA, and shall be amended upon written request by NMED or EPA. The sulfur shedding plan may include, but is not limited to the following options: Store sour water to reduce acid gas generation from the sour water strippers Reduce the operating rate of one or more amine strippers to lower the acid gas generation rate Reduce one or more hydrotreating unit throughput rates to lower acid gas generation rate Use hydrogen, when available, as ACC Form Part I Permit POST-R2 Ver 4.1 02/25/2015 Page 97 of 143 EPA Inspection Report - Page 657 of 1969 Version 02.25.15 SRU fuel during startup and hot standby to minimize carbon deposits on the SRU During startup and shutdown and to the extent practicable, process vessels shall be depressurized into other process equipment rather than venting to a ?are. The permittee shall document instances when this is not practicable. A207 Sulfur Recovery Plant (SPR), Tail Gas Incinerator (TGI) C. SRUZ, and SRU3 Requirement: (N SR 0195M3 5, Condition A207.C and revised) The permittee shall demonstrate compliance with the H28, 802, lb/hr, tpy emission limits by completing the following requirements, monitoring, recordkeeping and reporting: (1) A ?ow meter shall be installed, operated, calibrated, and maintained on the sour water stripper streams that go to the SRUs. (2) An $02 CEMS and ?ow meter shall be installed on the and SRU3 incinerator stacks. In addition, these units Shall be equipped with instruments to measure and record sulfur concentration l) A flow meter is in place on the sour water stripper streams into Units SRUZ, and SRU3. 2) The $02 CEMS and flow meter on the and SRU3 incinerator stacks, and the instruments used to measure sulfur concentration and flow rates of the gas streams into SRU2, and SRU3, are calibrated and maintained at a frequency and method speci?ed by the manufacturer, or as dictated by operating conditions. The 802 CEMS follow the quality assurance and quaiity control procedures in 40 CFR 60 Subpart and Appendix F. 3) The minimum acceptable ievei of data capture for all instruments measuring flow and concentration of sulfur streams into the SRUZ, and SRU3 including the CEMS and ?ow meters on the incinerator stacks shail be at ieast 90% for each month. The 10% lost data includes periods when the concentration and corresponding flow are not being measured as a result of calibrations or breakdowns. The data capture is reported in the semi?annual NSPS Subparts and Ja reports. Continuous Intermittent Yes No Yes No ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/20 1 5 Page 98 of 143 EPA Inspection Report - Page 658 of 1969 Version 02.25.15 and ?ow rates of the gas streams into SRU2, and SRU3. The CEMS, ?ow meters, and data loggers shall be calibrated and maintained. In addition, the calibration of the $02 CEMS shall follow the quality assurance and quality control procedures in 40 CFR 60 Subpart or a and Appendix F. (3) The minimum acceptable level of data capture for all instruments measuring ?ow of sulfur streams into the SRU2, and SRU3, as well as the GEMS and ?ow meters on the incinerator stacks, shall be at least 90% for each semi-annual period. The 10% lost data will include all periods when the concentration and corresponding ?ow are not being measured as a result of calibrations or breakdowns. Monitoring: The gas stream feeding El Continuous Yes El Yes .. SPUZ, and SRU3 from the amine Intermittent El N0 No regeneratlon units and the sour water stripper shall be tested at least for H28 concentration. The permittee shall monitor the following: I), 2), and 3) Navajo complies with the requirements of this permit condition. (1) low rate of sour water stream to SRUS, (2) 802 concentration in SRU incinerator stacks and (3) Flow rate of the SRU incinerator stacks. ACC Form Part 1 Permit P05 i-R2 Page 99 of 143 Ver 4.1 EPA Inspection Report - Page 659 of 1969 Version 02.25.15 Recordkeeping: The permittee shall maintain records in accordance with the applicable requirements of NSPS Subparts or a and MACT Subpart The permittee shall also keep records of the following: (1) Flow rate of sour water stream to SRUs, (2) 802 concentration in SRU incinerator stacks and (3) Flow rate of the SRU incinerator stacks. 2), and 3) Records are maintained by Navajo Environmental Department and on Pi. IXI Continuous Intermittent IXI Yes No El Yes IXI No Reporting: The permittee shall report in accordance with the applicable requirements of NSPS Subparts or Ja, MACT Subpart and Section B1 10. Navajo submitted NSPS Subparts J, Ja and MACT Subpart reports semiannuaily as follows: 7/30/2018 Continuous IXI Intermittent Yes No Yes El No A207 Sulfur Recovery Plant (SPR), Tail Gas Incinerator (TGI) D. 40 CFR 60, Subpart (Unit(s) and SRU2) Requirement: The permittee shall comply with the applicable requirements of 40 CFR 60, Subpart J. Navajo complies with the requirements of Subpart J. Continuous Intermittent Yes No El Yes IE No Monitoring: The permittee shall install a continuous monitoring device to monitor compliance with the H28 limit. ('40 CPR and SRU2 TGI has a CMS installed. Continuous IXI Intermittent Yes No Yes IXI No Recordkeeping: The permittee shall maintain the continuous emission records. Records are maintained by Navajo Environmental Department and on Pi. IXI Continuous Intermittent Yes No Yes No ACC Form Part 1 Permit P05 l.-R2 Ver 4.1. 02/25/2015 Page 100 of 143 EPA Inspection Report - Page 660 of 1969 Version 02.25.15 Reporting: The pennittee shall comply Navajo SUblimttecfl $18135. Spra? reports Continuous Yes Yes with the reporting requirements of 40 CFR 56111121107331? as 0 Intermittent El No No 609 SL119}?art - 7/3 0/2018 . As of May 1, 2016, Navajo has elected to comply . A209 F?g"??es with 60.592303) Subpart for all continuous Yes Yes process units affected by NSPS Subpart El Intermittent No IE No A- NSPS Subpart Standards 0f regardless of whether or not those process units Performance for Equipment Leaks of VOC have triggered NSPS Subpart applicability. in Petroleum Re?neries for which Fugitive components subject to this rule are construction, reconstruction, or included in the Leak Detection. and Repair (LDAR) modi?cation commenced after January 4, progTam- USES a third-p811?! for 1983, and on 01. before November 7? 2006 the LDAR monitoring and recordkeeping.These are - - - . monitored and reported in a NSPS Subpart (Fugitives subject in Table l_03_.B) semiannual report As of May I, 2016, Navajo has elected to comply El Continuous Kl Yes El Yes Requirement: The pennittee shall Comply with 60.592a(e) Subpart Elli with all applicable requirements process units affected by NSPS Subpart Intermittent No El No Subpait for all sources in Table regardless of whether or not those process units 103.13 (affected units and voluntarily ha?? irigge?ed NSPS applicability . . . Fug1t1ve components subject to this rule are units). This table also 1ncludes areas that included in the Leak Detection and Repair (LDAR) are voluntarlly $110ng the NSPS program. Navajo uses a third-party contractor for Subpart monitorlng requirements. the LDAR monitoring and recordkeeping.These are (See footnote 1 to Table 103-8) monitored and reported in a NSPS Subpart semiannual report 8113;133:2311: Navajo uses a third?party contractor for the LDAR El Continuous El Yes Yes monitoring and recordkeeping. - requirements of 40 CFR 60, Subpart Intermittent . . 151g appli fail?:cdi?ii?k6ee:ii:1gl Navajo uses a third-party contractor for the LDAR El Continuous Kl Yes Yes requirements of 40 CFR 60, Subpart momtormg and recordkeepmg' Intermittent No Reporting: The ermitt 6 shall comply Navajo submitted NSPS Subpart reports El Continuous El Yes El Yes with the applicable reporting requirements 8632118733111? as followsCFR 60, Subpart 8/30/2018 ?1 em? 8" . . Nava'o continues to comply with the a plicable . A209 Fugitives requiiements of NSPS Subpart 1is El Continuous Yes Yes applicable, except for the deviations previously ACC Form Part I Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 10} of 143 EPA Inspection Report - Page 661 of 1969 Version 02.25.15 B, NSPS Subpart Standards of reported or identi?ed at the end of this report. Intermittent El No 0 Performance for Equipment Leaks Fugitive components subject to either of these rules in Petroleum Re?neries for which are included in the Leak Detection and Repair Construction Reconstruction or (LDAR) program. Navajo uses a third-party Modi?cation} Commenced After contractor for the LDAR monitoring and . . . . dk . November 7, 2006 (Fugitives subject in recor eepmg Table 103B) Requirement: The permittee shall comply with all applicable requirements of NSPS Subpart for all sources in Table 103B (affected units and voluntarily units). This table also includes areas that are voluntarily following the NSPS Subpart monitoring requirements. Monitoring: The permittee shall comply Continuous Yes Yes with all applicable monitoring Navajo uses a third?party contractor for the LDAR requirements of 40 CFR 60, Subpart monitoring and recordkeeping. Intermittent El N0 El N0 Recordkeeping: The permittee shall Continuous Yes Yes comply with all applicable recordkecping Navajo uses a third-party contractor for the LDAR requirements of 40 CFR 60, Subpart monitoring and recordkeeping. Interm?ttem Re ortin The ermittee shall 0 1 Navajo submitted NSPS Subpart reports El Continuous 'semiannually as follows: the applicable reporting requzrements 2/28/2018 [3 Intermittent No No A209 Fugitives Continuous Yes Yes C. MACT Subpart cc, ?National El Intermittent N0 N0 Emission Standards for Hazardous Air . . . Pollutants from Petroleum Re?neries? The Gasohne Loading Rack rs equ1pped With a (Fugitives subject in Table 103.13) Garbo? adsomtm System- Requirement: The permittee shall comply with all applicable requirements of MACT ACC Form Part 1 Permit P05 1 Ver 4.1 02/25/2015 Page 102 of I43 EPA Inspection Report - Page 662 of 1969 Version 02.25.15 Subpart CC, ?National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries? for all affected sources shown in Tables 103B. (63640). For all activities in Table 103B that are not subject to MACT CC, the permittee voluntarily performs a LDAR. program for those units and that program meets the requirements of MACT CC. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. The Gasoline Loading Rack carbon absorption has a VOC CEMS installed in the exhaust air stream. Continuous Intermittent Yes El No Yes No Recordkeeping: The permittee shall comply with the applicable recordkeepin requirements of 40 CFR 63.655. Records are kept by Holly Energy Partners (HEP) either at the Gasoline Loading Rack or at the HEP Artesia Of?ce. Continuous Intermittent Yes No Yes No Reporting: The permittee shall comply with the applicable reporting requirements 0f40 CFR 63.655. Navajo submitted NSPS Subpart reports semiannually as follows: 2/28/2018 8/30/2018 Continuous Intermittent Yes El No El Yes No A209 Fugitives D. NSPS Subpart Standards of Performance for VOC Emissions from Petroleum Re?nery Wastewater Systems (Fugitives subj ect in Table 103B) Requirement The permittee shall comply with all applicable requirements 40 CFR Part 60.690, Subpart Navajo continues to comply with the applicable requirements Subparts throughout the re?nery, except for deviations previously reported or identi?ed at the end of this report. Oily water sewer drain hubs are inspected. at least Junction boxes, and the oil-water separator are inspected at least semi?annually. Continuous Intermittent Yes No Yes No Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CF 60, Subpart (60.695) Navajo continues to comply with the applicable requirements of NSPS Subparts throughout the re?nery, except for deviations previously reported or identi?ed at the end of this report. Oily water sewer drain hubs are inspected at least Junction boxes, and the oil?water separator are inspected at least semi~annually. El Continuous Intermittent El Yes No Yes No ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 103 of 143 EPA Inspection Report - Page 663 of 1969 Version 02.25.15 Recordkeeping: The permittee comply with the applicable recordkeeping requirements of 40 CFR 60.696. Records are maintained by Navajo Environmental Department, except for deviations previously reported or identi?ed at the end of this report. Continuous El Intermittent Yes No Yes No Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60.697. Navajo submitted NSPS Subpart reports semiannually as follows: 1/30/2018 7/30/2018 Continuous Intermittent Yes I: No Yes No ACC Form Part 1 Permit Ver 02/25/2015 Page 104 of143 EPA Inspection Report - Page 664 of 1969 Version 02.25.15 A209 Fugitives E. Minor changes within the facility to piping and components that affect fugitive VOC emission source shall be updated and added during the next available Signi?cant permit revision in accordance with 20.2.72 NMAC. The facility wide ?lgitive VOC emission limit shown above and in Table 106A ofthis permit. Navajo understands that minor changes to the facility piping and components that affect fugitive emissions will be added during the next permit modi?caiton. El Continuous Intermittent Yes El No Yes No A210 Loading Racks A. Truck and. Rail Loading (Unit shown in Table 106G) Requirement: Compliance with the allowable emission limits in Table 106.G shall be demonstrated by not exceeding the rolling 12?month total throughput for each loading rack for each different product in gallons per year (barrels/year). Navajo complies with these requirements. IE Continuous Intermittent Yes El N0 El Yes IE N0 Monitoring: The permittee shall monitor the throughput volumes on a basis. The Truck Rail Loading Racks volumes are maintained by Navajo?s Accounting and Environmental Departments. Continuous IE Intermittent Yes El N0 El Yes IE N0 Recordkeeping: The permittee shall record the throughput volume for each loading rack for each different product. Each month during the ?rst 12 months of monitoring the permittee shall record the cumulative condensate loadout volume and after the first 12 months of monitoring, the pennittee shall calculate and record a rolling 12-month total loadout volume. The Truck Rail Loading Racks volumes are maintained by Navajo's Accounting and Environmental Departments. IE Continuous Iutermittent ACC Form Part I Permit Ver 4.1 02/250015 Page 105 of I43 EPA Inspection Report - Page 665 of 1969 Version 02.25.l5 Records shall also be maintained in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. Navajo submitted MACT Subpart CC reports semiannually as follows: 2/28/2018 8/30/2018 El Continuous Intermittent Yes No Yes No A210 Loading Racks B. Fuel Truck Loading Rack (Units subject in Table 103D) (40 CFR 63, Subpart CC) Requirement: The permittee shall comply with all applicable requirements of MACT Subpart CC, National Emission Standards for Hazardous Air Pollutants From Petroleum Re?neries. Specially, the truck loading rack shall be equipped with. a carbon adsorption system for compliance with the MACT requirements. The Truck Loading Rack has a carbon absorption system installed. IXI Continuous IE Intermittent Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. Speci?cally where a carbon adsorption system is used, a continuous emission monitoring system (CEMS) capable of measuring organic compound concentration shall be installed in the exhaust air stream. The Truck Loading Rack has a CEMS installed. IE Continuous El Intermittent IXI Yes No Yes IE No Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63, Subpart CC. Records are kept by Holly Energy Partners (HEP) either at the Gasoline Loading Rack or at the HEP Artesia Of?ce. El Continuous El Intermittent EYes Yes IXI No Reporting: The perrnittee shall comply with the applicable reporting requirements of 40 CFR 63, Subpart CC. Navajo submitted MACT Subpart CC reports semiannually as follows: 2/28/2018 8/30/2018 El Continuous El Intermittent Yes No El Yes El No ACC Form Part 1 Permit P051-R2 Ver 4.1 Page l06 of I43 EPA Inspection Report - Page 666 of 1969 Version 02.25.15 A211 Fluid Catalytic Cracking Unit (FCC) A. Continuous Monitor System(CMS) (Unit FCC REGEN) Requirement: 1) Consent Decree Limits on PM and SO2 emissions ?'om the FCC: By no later than December 31 2003, the Wet Gas Scrubber (WGS) on the FCC Regenerator shall comply with the following limits: (CD 1112.13 1113.13) 802 concentration not to exceed 25 on a daily rolling 365- day average basis and 50 on a daily rolling 7?day average basis, each corrected to 0% oxygen. Compliance with this emissions limit shall be demonstrated on an ongoing basis through the use of and a particulate matter (PM) emission limit of 1.0 pound of PM per 1000 pounds of coke burned. on a 3?hour average basis (CD To demonstrate compliance with this requirement, the Permittee shall conduct an annual EPA Method 5 Test for PM and weekly EPA Method 9, Opacity Test in accordance with their approved 1d) The FCC catalyst regenerator exhaust is continously monitored for 802. le) The catalytic cracking regenerator is tested annually for PM and was tested on the following date: 01/09/2018 If) Navajo has submitted an alternative monitoring plan (AMP) to comply with the FCC opacity monitoring requirement because the FCCU has a wet scrubber which prevents continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CFR 60 Appendix A Method 9. 2) The FCC exhaust is continously monitored for and CO. Deviations were reported to the Department as excess emission events and on the NSPS SubpartJ report. Continuous El Intermittent Yes No Yes N0 ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 107 of 143 EPA Inspection Report - Page 667 of 1969 Version 02.25.15 Alternative Monitoring Plan (AMP). As the FCC Regenerator is subject to the provisions of 40 CFR 60.102 (NSPS Subpart J), it shall not discharge to the atmosphere gases exhibiting greater than 30 percent opacity, except for one six-minute average opacity reading in any one-hour period. (2) Consent Decree Limits on NO: and CO emissions from the FCC: The FCC shall comply with and CO emission limits as follows: The concentration~based emission limit based on daily rolling 7-day and daily rolling 365-day averages, corrected to 0% oxygen as established pursuant to the Consent Decree, unless EPA rejects the proposed limit and establishes a different NOX emission limit, in which case the FCC shall comply with established limit. Under no circumstances shall this emission limit be greater than a concentration-based limit that would be equivalent to 34.9 lbs/hr. The 7-day FCC NOX emission limits, shall not apply during periods of Hydrotreater Outage provided that the FCC ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 108 of 143 EPA Inspection Report - Page 668 of 1969 Version 02.25.15 (including associated air pollution control equipment) is maintained and operated in a manner that minimizes emissions in accordance with an EPA- approved good air pollution control practices plan. Navajo shall comply with the plan at all times, including periods of startup, shutdown, and malfunction of the hydrotreater. The daily rolling 365-day average emissions limit shall apply during periods of hydrotreater outages. The NOX limits are: (1) 87.3 NOX, corrected to 0% 02 on a daily rolling 7?day average, and (2) 58.1 NOX, corrected. to 0% 02 on a daily rolling 365~day average The NSPS Subpart emission limit of 500 CO corrected to 0% 02 on a 1?hour average basis and. 100 CO corrected to 0% 02 on a daily rolling 365-day average basis, by no later than December 31, 2003. Monitoring: 1) The FCCU Catalyst Regenerator Scrubber Continuous Yes Yes exhaust is continuously monitored for CO, 02, A continuous monitor system (CMS) $02, and PM is monitored annually. Intermittent El N0 N0 for CO, 02, and NOX shall be installed, calibrated, maintained, and 2) The FCC regenerator CMS were recerti?ed on ACC Form Part 1 Permit P05I-R2 Page 109 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 669 of 1969 Version 02.25. I 5 operated on the FCC Catalyst Regenerator vent stack(s) of the scrubber in accordance with 40 CFR Part 60, ?60.13, Appendix A, and the applicable performance speci?cations of Appendices (Speci?cations 2 and 3) and F. The CMS shall be used to demonstrate compliance with CO, S02 and emissions limits and to report compliance with the terms and conditions of the Consent Decree. The CMS and process data shall be made available, by permittee, to applicable Federal and State Agencies (NMED) upon demand as soon as practicable. (CD 1l11.F, 12 D, and MC) (2) The FCC Regenerator Scrubber 802, CO and 02 CMS shall be recertifled annually. (3) The CMS data shall be monitored to ensure the CO, S02 and NO): emission limits for the FCC are met. (4) The Pennittee shall conduct an annual EPA Method 5 Test for PM and weekly EPA Method 9 Opacity test to demonstrate compliance with the particulate matter (PM) emission limit of 1.0 pound ofPM per 1000 pounds of coke burned on a 3~hour average basis and opacity limit of 30%. Permittee shall meet testing requirements of Bl 1 1. the following dates: CO 01/09/2018 802 01/09/2018 01/09/2018 02 01/09/2018 3) CMS data is used to ensure emissions limits are met. 4) The catalytic cracking regenerator is tested annually for PM and was tested on the following date: 01/09/2018 Navajo has submitted an alternative monitoring pian (AMP) to comply with the FCC Opacity monitoring requirement because the FCCU has a wet scrubber which prevents continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CFR 60 Appendix A Method 9. ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 110 of 143 EPA Inspection Report - Page 670 of 1969 Version 02.25.15 Recordkeeping: The permittee shall maintain the records of: (1) The certi?cation and re-certi?cation of the CMS. (2) Modi?cations to the good air pollution control practice plan to minimize NOX emissions shall be summarized on an annual basis if any changes were made. CD t1 LG) (3) The permittee shall keep records of CMS data monitoring N02, 802, and CO emissions from the FCC. (CD 1111.13, CD 1112.D CD 1114C) (4) Records of CO, 802 lb/hr, tpy; PM lb/hr, tpy and opacity. TPY shall be based on a rolling 12? month total. (5) The permittee shall. keep records of annual PM stack tests and weekly Method 9 observations conducted on the FCC. For any opacity observations conducted in accordance with the requirements of EPA Method 9, record the information on the form referenced in EPA Method 9, Sections 2.2 and 2.4. 2), 3), 4), and 5) Records are maintained by Navajo Environmental Department and on Pi. Continuous Intermittent Yes No Yes No Reporting: The permittee shall report in accordance with Section B1 10 and testing requirements of B1 1 1. Navajo submitted NSPS Subparts and Ja reports semiannually as follows: 1/30/2018 7/30/2018 El Continuous Intermittent Yes No Yes No ACC Form Part 1 Permit P051-R2 Ver 4.1 02/25/2015 Page ll} of 143 EPA Inspection Report - Page 671 of 1969 Version 02.25.15 A211 Fluid Catalytic Cracking Unit DContinuous [EYes DYes (FCC) Intermittent No No B. Performance Testing (Unit FCC REGEN) Requirements: (1) The permittee shall demonstrate compliance with the NSPS Subpart particulate matter emission limit at Table Navajo complies with the requirements of NSPS by conducting an initial Subpart J, Ja, MACT Subpart A, and performance test in accordance with NSPS Subpart A, ?60.8 and NSPS Subpart J, The particulate matter stack test shall be repeated on an annual basis. (2) The permittee shall comply with all applicable performance testing requirements in accordance with MACT Subparts A and Monitoring: Testing shall be conducted in El Continuous Yes El Yes accordance with NSPS Subpal?ts A and J, Navajo complies with the requirements of NSPS and in accordance with MACT Subparts A Subpart Ja, MACT Subpart A, and Intermittent No and Recordkeeping: The permittee shall Continuous Yes Yes maintain performance test records in accordance with NSPS Subparts A and J, MACT Subparts A and and in accordance with Section 8109. Navajo complies with the requirements of NSPS Intermittent El No El No Subpart J, Ja, MACT Subpart A, and Reporting: The permittee shall report Continuous Yes . Yes performance test results in accordance Navajo complies with the requirements of NSPS with NSPS Subparts A and 9 ACT Subpart J, Ja, MACT Subpart A, and Inter mitte?t El N0 N0 Subparts A and and in accordance ACC Form Part 1 Permit RZMI Page 112 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 672 of 1969 Version 02.25.15 with Section B1 10. A212 (3001ng Towers Continuous IXI Yes El Yes A. MACT Subpart CC, ?National Intermittent No No Emission Standards for Hazardous Air Pollutants from Petroleum Refineries? . . . (Cooling Towers subject in Table 103-13) Navajo comphes With the applicable requirements for heat exchange systems, except for devzations 'd t'f'd fth? Requirement: The permittee shall comply Egg: us yrepo 6 01with all applicable requirements of 40 CFR 63, Subpart CC for heat exchange systems for all affected sources shown in Table 103.F attached. 63 Monitoring The permittee shall comply Navajo complies with the applicable requirements Continuous Yes Yes With all applicable monitoring and testing for heat exchange systems, except for deviations requirements of 40 CFR 63, Subpart CC, previously reported or identi?ed at the end of this Intermittent El N0 Xi N0 (63-65403), (0) report- Recordkee in The ermittee shall . . . . Records are maintained by the onsite LDAR El Continuous Yes Yes comply With all recordkeepmg contractor and the Nava'o Environmental requirements of 40 CFR 63,. Subpart CC. Depamem 1 Intermittent No No Reporting: The permittee shall comply Navajo submitted MACT Subpart CC reports Continuous Yes Yes with all applicable reporting requirements semiannually as follows: of 40 CFR 63, Subpart CC. (63.6556), 2/28/2018 Intermittent N0 N0 (DUXVU, 8/30/2013 l) Navajo operates with less than six (6) Cl ontin 0 El Yes A212 Cooling Towers recirculating pumps per heat exhange system. es . . . IE Intermittent No No 3- (30011113 Tower Operations ?30011119; 2) The pump capacity is less than 65,500 Towers subject in Table 103.F) 3) The Total Dissolved Solids (TDS) is sampled by Requirement; Compliance with the the Navajo Lab and results maintained in the allowable emission limits in Table 106.H system and maintained by the Navajo shall be demonstrated by meeting the Environmental Dep?mmem? follow1ng requ1rements: 4) Drift eliminators installed are rated by the ACC Form Part 1 Permit Ver 4.1 02/25/2015 Page 113 of143 EPA Inspection Report - Page 673 of 1969 Version 02.25.15 manufacturer for 0.001% or 0.003 drift. 1) operate a maximum of six (6) recirculating pumps at any one 5) Drift eliminators are inspected onanannual time; basis. 2) ensure that each pump capacity shown in Table 104A are not exceeded gallons per minute for each cooling tower (65,500 total maximum rate for 6 pumps); 3) limit the Total Dissolved Solids (TDS) content for the cooling tower recirculating water system to 3500 ppmw, based on a rolling 12-month annual average; 4) ensure that the drift eliminator are rated by the manufacturer at 0.001% or 0.003 drift or less as shown in Table and 5) ensure that the drift eliminator is present and in good working order. The permittee shall measure the Total Dissolved Solids (TDS) content of the recirculating water through direct laboratory analysis, or may use a conductivity meter on the recirculating water system for the cooling tower. The correlation between conductivity of the water and the TDS content shall be taken as 0.9 conductivity (umhos/cm) r: TDS (ppmw) unless a new correlation is determined through laboratory analysis and submitted to the Permit Program Manager ACC Form Part 1 Permit P051-R2 Page 114 of 143 Ver 4.1 02/25/2015 EPA Inspection Report - Page 674 of 1969 Version 02.25.15 for approval. Monitoring: The permittee shall: 1) Monitor the recirculating water TDS content by direct laboratory analysis of the TDS or through use of conductivity meter values and correlated TDS on a basis; and a. Any correlation other than the 0.9 value described above shall be developed by the permittee by independent laboratory measurement of at least 10 water samples with approximately evenly spaced measured TDS values that bracket the minimum and maximum values expected. The highest laboratory TDS sample used for the correlation shall be greater than the maximum allowable TDS of 3500 ppmw. 2) Perform an annual inspection of the drift eliminator and perform any maintenance necessary to ensure the device operates according to the manufacturer?s speci?cations. 1) The Total Dissolved Solids (TDS) is sampled by the Navajo Lab and results maintained in the system and maintained by the Navajo Environmental Department 2) Drift eliminators are inSpected on an annual basis. 3) The Cooling Towers are monitored for VOC breakthrough via the El Paso Method described in Appendix P. Continuous Intermittent Yes No Yes No ACC Form Part 1 Permit R2M1 Ver 4.1 02/25/2015 Page 115 of 143 EPA Inspection Report - Page 675 of 1969 Version 02.25.15 3) The permittee shall monitor the cooling water inlet and outlet streams for hydrocarbons on an annual basis using either EPA Method 8015 with a large enough sample to achieve accurate quanti?cation of hydrocarbon content, EPA Method 8260, EPA Method 8270 or a similar method as approved by the Department prior to testing. Recordkeeping: The permittee shall maintain the following records: 1) Manufacturer?s speci?cations demonstrating maximum capacities of the recirculating water pumps and the manufacturer?s speci?cation for the drift eliminator speci?ed drift rate; 2) TDS and rolling 12-month average; 3) If a conductivity meter is installed, a record of the correlation between conductivity and TDS, any laboratory analyses used to determine the correlation, and all related calculations; 4) Annual drift eliminator inspection and any records of maintenance performed. 1) Records maintained by the Navajo Inspections Department. 2) Records maintained by the Navajo Environmental Department. 3) Records maintained by the Navajo Lab. 4) Records maintained by the Navajo Inspections Department. Continuous IXI Intermittent Yes [:lNo Yes No ACC Form Part 1 Permit P051-R2 Ver 4.1 02/232015 Page 116 of 143 EPA Inspection Report - Page 676 of 1969 Version. 02.25.15 The permittee shall maintain records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. Navajo submitted MACT Subpart CC reports semiannually as follows: 2/2 8/20 1 8 8/30/2018 El Continuous Intermittent IXI Yes El No El Yes IXI No A213 Was tewater Systems A. NSPS Subpart Standards of Performance for VOC Emissions from Petroleum Re?nery Wastewater Systems (Unit MAIN API) Requirement: Beginning December 31, 2003, all remaining and newly installed individual drain systems, oil?water separators, and aggregate facilities not previously speci?ed shall be affected facilities, as the term is used in the NSPS, 40 CFR Part 60, Subpart and shall be subject to and comply with the applicable requirements of 40 CFR Part 60, Subpart (CD 1129) The permittee shall comply with all applicable requirements of NSPS Subpart for the affected sources in Tables 103.8, C, G. (60.690) Navajo continues to comply with the applicable requirements of NSPS Subparts throughout the re?nery, except for deviations previously reported or identifed at the end of this report. Oily water sewer drain hubs are inspected at least Junction boxes, and the oil?water separator are inspected at least semi~annually El Continuous Intermittent El Yes No El Yes No Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart (60.695 and 60.696) Navajo continues to comply with the applicable requirements of NSPS Subparts throughout the re?nery, except for deviations previously reported or identifed at the end of this report. Oily water sewer drain hubs are inspected at least Junction boxes, and the oil-water separator are inspected at least semi-annually. El Continuous IXI Intermittent Recordkeeping: The permittee shall comply with the applicable recordkeeping Records are maintained by Navajo Environmental. Department. El Continuous El Yes El Yes ACC Form Part 1 Permit it P051-R2 Ver 4.1 02/25/2015 Page 117 of 143 EPA Inspection Report - Page 677 of 1969 Version 02.25.15 requirements of 40 CFR 60.697. El Intermittent El N0 El No Reporting: The permittee shall comply Naviljo Smeitted NSPS reports Continuous semiannually as follows: With the applicable reporting requirements 1/30/2018 Intermittent No No of 40 CFR 60.698. 7/30/2018 A213 Wastewater Systems El Continuous El Yes Yes B. MACT Subpart CC, ?National Intermittent No No Emission Standards for Hazardous Air Pollutants from Petroleum Refineries? Navajo complies with the requirements of MACT Requirement: The permittee shall comply CC, except for deviations noted in semiannual with all applicable requirements of MACT reports. Subpart CC, ?National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries? for all affected sources shown in Tables 103B, C, attached. (63.640). The ermittee Shall comply Navajo complies with the requirements of MACT El Continuous Yes Yes w1th the applicable monitoring and testing CC requirements of 40 CFR 63, Subpart CC. El Recordkeeplng: The Shall Reeords are maintained by Navajo Environmental Continuous Yes Yes comply w1th the applicable recordkeeplng De artment . requirements of 40 CFR 63.655. Interm?ttent Reporting: The permittee shall comply Navfljo Smeitted MACT Spra? CC reports El Continuous El Yes Yes with the applicable reporting requirements semlannuauy as 2/28/2018 IXI Intermittent I: No IXI No of40 CFR 63.655. 8/30/2018 A213 Wastewater Systems Continuous Yes Yes C. Wastewater Treatment System (Units Intermittent El N0 shown in Table 106.1) Navajo complies with this requirement, except for deviations noted in semiannual reports. Requirement: Compliance with the emission limits in Table 106.1 shall be demonstrated by properly maintaining and ACC Form Part 1 Permit at P051-R2 Ver 4.1 02/25/2015 Page 118 of I43 EPA Inspection Report - Page 678 of 1969 Version 02.25.15 repairing the units, and running the Wastewater Model annually to calculate the maximum VOC emissions generated. ACC Form Part 1 Permit R2M1 Page 119 0f143 Ver 4.1. 02/25/2015 EPA Inspection Report - Page 679 of 1969 Version 02.25.15 Monitoring: 1) Maintenance and repair shall meet the minimum manufacturer's or pennittee's recommended maintenance schedule. Activities that involve maintenance, adjustment, replacement, or repair of functional components with the potential to affect the operation of an emission unit shall be documented. as they occur for the following events: Routine maintenance that takes a unit out of service for more than two hours during any twenty-four hour period. Unscheduled repairs that require a unit to be taken out of service for more than two hours in any twenty? four hour period. (2) The permittee shall annually run the Waste-Water Model to determine the hourly and annual emission rates, based on Toxchem V4 Input Parameters. l) Navajo complies with this requirement, except for deviations noted in semiannual reports. 2) Navajo uses EPA's Water 9 waste-water model. Continuous Intermittent Yes No El Yes No Recordkeeping: The permittee shall maintain records in accordance with Section 8109, including records of maintenance and repairs activities and a copy of the manufacturer? or permittee?s recommended maintenance schedule. (2) The permittee shall maintain records of the Toxchem V4 Input Parameters and the emission calculation results compared to permit limits. l) Navajo complies with this requirement, except for deviations noted in semiannual reports. 2) Navajo uses Water 9 waste?water model. El Continuous Intermittent Yes No Yes No ACC Form Part 1 Permit P051-R2 Ver 4.1. 02/25/2015 Page 120 of 143 EPA Inspection Report - Page 680 of 1969 Version 02.25.15 Reporting: The permittee shall report in accordance with Section B110. Navajo complies with the requirement of section 1 10. El Continuous El Intermittent ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 02/25/2015 Page 121 of143 EPA Inspection Report - Page 681 of 1969 PART 1 General Conditions 1. Have these General Conditions been met during this reporting period? 2. Was this facility in 3. Does compliance with this not apply I the section Heading is marked as no remarks are required. requirement during Check only one box per subiect heading. the reporting parted? Explain answers in remarks row under sabiect heading. Yes No B100 Introduction Explain Explain Explain A. A Below Below Below REMARKS: B101 Legal Yes No Explain Explain Explain Below Below Below A. Permit Terms and Conditions (20.2.70 sections 7, 201 .B, 300, 301B, 302, 405 NMAC) The permittee shall abide by all terms and conditions of this permit, except as allowed under Section 502(b)(10) of the Federal Act, and 20.2.70.302.H.l NMAC. Any permit noncompliance is grounds for enforcement action, and signi?cant or repetitious noncompliance may result in termination of this permit. Additionally, noncompliance with federally enforceable conditions of this permit constitutes a violation of the Federal Act. (20.2.70.302.A.2.a NMAC) (2) Emissions trading within a facility (20.2.70.302.H.2 NMAC) The Department shall, if an applicant requests it, issue permits that contain terms and conditions allowing for the trading of emissions increases and decreases in the permitted facility solely for the purpose of complying with a federally enforceable emissions cap that is established in the permit in addition to any applicable requirements. Such terms and conditions shall include all terms and conditions required under 20.2.70302 NMAC to determine compliance. If applicable requirements apply to the requested emissions trading, permit conditions shall be issued only to the extent that the applicable requirements provide for trading such increases and decreases without a case?by?case approval. (13) The applicant shall include in the application proposed replicable procedures and permit terms that ensure the emissions trades are quanti?able and enforceable. The Department shall not include in the emissions trading provisions any emissions units for which emissions are not quanti?able or for which there are no replicable procedures to enforce the emissions trades. The permit shall require compliance with all applicable requirements. (3) It shall not be a defense for the permittee in an enforcement action to claim that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. (20.2.70.302.A.2.b NMAC) (4) If the Department determines that cause exists to modify, reopen and revise, revoke and reissue, or terminate this ACC Form Part I B, Deviation Summary permit P051-R2 Ver 4.0 01/22/2015 Page 122 of 143 EPA Inspection Report - Page 682 of 1969 PART 1 General Conditions permit, this shall be done in accordance with 20.270.405 NMAC. (20.2.70.302.A.2.c NMAC) (5) The permittee shall furnish any information the Department requests in writing to determine if cause exists for reopening and revising, revoking and reissuin g, or terminating the permit, or to determine compliance with the permit. This information shall be furnished within the time period speci?ed by the Department. Additionally, the permittee shall furnish, upon request by the Department, copies of records required by the permit to be maintained by the permittee. (20.2.70.302.A.2.f NMAC) (6) A request by the permittee that this permit be modi?ed, revoked and reissued, or terminated, or a noti?cation by the permittee of planned changes or anticipated noncompliance, shall not stay any conditions of this permit. (20.2.70.302.A.2.d NMAC) (7) This permit does not convey property rights of any sort, or any exclusive privilege. (20.2.70.302.A.2.e NMAC) (8) In the case where an applicant or permittee has submitted information to the Department under a claim of confidentiality, the Department may also require the applicant or permittee to submit a copy of such information directly to the Administrator of the EPA. (20.2.70.301.B NMAC) (9) The issuance of this permit, or the ?ling or approval of a compliance plan, does not relieve the permittee from civil or criminal liability for failure to comply with the state or Federal Acts, or any applicable state or federal regulation or law. (20.2.70.302.A.6 NMAC and the New Mexico Air Quality Control Act NMSA 1978, Chapter 74, Article 2) (10) If any part of this permit is challenged or held invalid, the remainder of the permit terms and conditions are not affected and the permittee shall continue to abide by them. .d NMAC) 1) A responsible of?cial (as defined in 20.2.70.7.AE NMAC) shall certify the accuracy, truth and completeness of every report and compliance certi?cation submitted to the Department as required by this permit. These certi?cations shall be part of each document. (20.2.70.300.E NMAC) (12) Revocation or termination of this permit by the Department terminates the permittee's right to operate this facility. (20.2.70.201.B NMAC) (l 3) The permittee shall continue to comply with all applicable requirements. For applicable requirements that will become effective during the term of the permit, the permittee shall meet such requirements on a timely basis. (Sections 300.D.10.c and 302.G.3 of20.2.70 NMAC) B. Permit Shield (20.2.70.302.J NMAC) (1) Compliance with the conditions of this permit shall be deemed to be compliance with any applicable requirements existing as of the date of permit issuance and identi?ed in Table 103A. The requirements in Table 103.A are applicable to this facility with speci?c requirements identi?ed for individual emission units. (2) The Department has determined that the requirements in Table 103.B as identi?ed in the permit application are not ACC Form Part 1 Permit it Ver 4.1 5/6/2015 Page 123 of143 EPA Inspection Report - Page 683 of 1969 PART 1 General Conditions applicable to this source, or they do not impose any conditions in this permit. (3) This permit shield does not extend to administrative amendments (Subsection A of 20270404 NMAC), to minor permit modi?cations (Subsection of 202.70.404 NMAC), to changes made under Section 502(b)( 10), changes under Paragraph 1 of subsection of 20270302 of the Federal Act, or to permit terms for which notice has been given to reopen or revoke all or part under 20.2.70405 and (4) This permit shall, for purposes of the permit shield, identify any requirement speci?cally identi?ed in the permit application or signi?cant permit modi?cation that the department has determined is not applicable to the source, and state the basis for any such determination. C. The owner or operator of a source having an excess emission shall, to the extent practicable, operate the source, including associated air pollution control equipment, in a manner consistent with good air pollutant control practices for minimizing emissions. (20.2.7.109 NMAC). The establishment of allowable malfunction emission limits does not supersede this requirement. REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. B102 Authority Yes No I: Explain Explain Explain Below Below Below A. This permit is issued pursuant to the federal Clean Air Act ("Federal Act?), the New Mexico Air Quality Control Act (?State Act") and regulations adopted pursuant to the State and Federal Acts, including Title 20, New Mexico Administrative Code, Chapter 2, Part 70 (20.2.70 NMAC) - Operating Permits. This permit authorizes the operation of this facility. This permit is valid only for the named permittee, owner, and operator. A permit modi?cation is required to change any of those entities. The Department speci?es with this permit, terms and conditions upon the operation of this facility to assure compliance with all applicable requirements, as de?ned in 20.2.70 NMAC at the time this permit is issued. (20.2.70.302.A.1 NMAC) Pursuant to the New Mexico Air Quality Control Act NM SA 978, Chapter 74, Article 2, all terms and conditions in this permit, including any provisions designed to limit this facility's potential to emit, are enforceable by the Department. All terms and conditions are enforceable by the Administrator of the United States Environmental Protection Agency and citizens under the Federal Act, unless the term or condition is speci?cally designated in this permit as not being enforceable under the Federal Act. (20.2.70.302.A.5 NMAC) ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 5/6/2015 Page 124 of 143 EPA Inspection Report - Page 684 of 1969 PART 1 General Conditions E. The Department is the Administrator for 40 CF Parts 60, 61, and 63 pursuant to the Modi?cation and Exceptions of Section 10 of 20.2.77 NMAC (NSPS), 20.2.78 NMAC (NESHAP), and 202.82 NMZAC (MACT). REMARKS: B103 Annual Fee The permittee shall pay Title fees to the Department consistent with the fee schedule in 20.2.71 NMAC - Operating Permit Emission Fees. The fees will be assessed and invoiced separately ?om this permit. (20.2.70.302.A.l.e NMAC) Yes Explain Below No Explain Below Explain Below REMARKS B104 Appeal Procedures (20.2.70.403.A NMAC) A. Any person who participated in a permitting action before the Department and who is adversely affected by such permitting action, may ?le a petition for a hearing before the Environmental Improvement Board ("board"). The petition shall be made in writing to the board within thirty (30) days from the date notice is given of the Department?s action and shall specify the portions of the permitting action to which the petitioner objects, certify that a copy of the petition has been mailed or hand?delivered, and attach a COpy of the permitting action for which review is sought. Unless a timely request for a hearing is made, the decision of the Department shall be ?nal. The petition shall be copied simultaneously to the Department upon receipt of the appeal notice. If the petitioner is not the applicant or permittee, the petitioner shall mail or hand?deliver a copy of the petition to the applicant or permittee. The Department shall certify the administrative record to the board. Petitions for a hearing shall be sent to: Secretary, New Mexico Environmental Improvement Board 1190 St. Francis Drive, Runnels Bldg. Rm N2153 Santa Fe, New Mexico 87502 XI Yes Explain Below No Explain Below Explain Below REMARKS ACC Form Part Permit Ver 4.1 5/6/2015 Page 125 of 143 EPA Inspection Report - Page 685 of 1969 PART 1 General Conditions BIOS Submittal of Reports and Certi?cations A. Stack Test Protocols and Stack Test Reports shall be submitted electronically to Stacktest.AQBtCOstatemmus or as directed by the Department. Excess Emission Reports shall be submitted as directed by the Department. (20.2.7.l 10 NMAC) Compliance Certi?cation Reports, Semi?Annual monitoring reports, compliance schedule progress reports, and any other compliance status information required by this permit shall be certi?ed by the reSponsible of?cial and submitted to the mailing address below, or as directed by the Department: Manager, Compliance and Enforcement Section New Mexico Environment Department Air Quality Bureau 525 Camino de los Marquez, Suite 1 Santa Fe, NM 87505?1816 Compliance Certi?cation Reports shall also be submitted to the Administrator at the address below (20.2.70.302.E.3 NMAC): Chief, Air Enforcement Section US EPA Region-6, (SEN-AA 1445 Ross Avenue, Suite 1200 Dallas, TX 75202?2733 Yes Explain Below No Explain Below Explain Below REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. ACC Form Part I. Permit Ver 5/6/2015 Page 126 of 143 EPA Inspection Report - Page 686 of 1969 PART 1 General Conditions B106 NSPS and/or MACT Startup, Shutdown, and Malfunction Operations A. If a facility is subject to a NSPS standard in 40 CFR 60, each owner or operator that installs and operates a continuous monitoring device required by a NSPS regulation shall comply with the excess emissions reporting requirements in accordance with 40 CFR If a facility is subject to a NSPS standard in 40 CFR 60, then in accordance with 40 CFR operations during periods of startup, shutdown, and malfunction shail not constitute representative conditions for the purpose of a. performance test nor shall emissions in excess of the level of the applicable emission limit during periods of startup, shutdown, and malfunction be considered a. violation of the applicable emission limit unless otherwise speci?ed in the applicable standard. If a facility is subject to a MACT standard in 40 CFR 63, then the facility is subject to the requirement for a Startup, Shutdown and Malfunction Plan (SSM) under 40 CFR unless speci?cally exempted in the applicable subpart. (20.2.70.302.A.1 and A.4 NMAC) El Yes Explain Below No Explain Below Explain Below REMARKS: Except for deviations reported on the semi?annual reports and/or referenced in this report. B107 Startup, Shutdown, and Maintenance Operations The establishment of permitted startup, shutdown, and maintenance (S SM) emission limits does not supersede the requirements of 20.2.7. 1 4A NMAC. Except for operations or equipment subject to Condition 106, the permittee shall establish and implement a plan to minimize emissions during routine or predictable start up, shut down, and scheduled maintenance (SSM work practice plan) and shall operate in accordance with the procedures set forth in the plan. (20.2.7.14.A NMAC) IE Yes Explain Below El No Explain Below El Explain Below REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. ACC Form Part 1 Permit it Ver 5/6/2015 Page 127 of 143 EPA Inspection Report - Page 687 of 1969 PART 1 General Conditions B108 General Monitoring Requirements Yes No (20.2.70. 302.A and NMAC) Explain Explain Explain Below Below Below A. (1) (2) (3) These requirements do not supersede or relax requirements of federal regulations. The following monitoring and/or testing requirements shall be used to determine compliance with applicable requirements and emission limits. Any sampling, whether by portable analyzer or EPA reference method, that measures an emission rate over the applicable averaging period greater than an emission limit in this permit constitutes noncompliance with this permit. The Department may require, at its discretion, additional tests pursuant to EPA Reference Methods at any time, including when sampling by portable analyzer measures an emission rate greater than an emission limit in this permit; but such requirement shall not be construed as a determination that the sampling by portable analyzer does not establish noncompliance with this permit and shall not stay enforcement of such noncompliance based on the sampling by portable analyzer. If the emission unit is shutdown at the time when periodic monitoring is due to be accomplished, the permittee is not required to restart the unit for the sole purpose of performing the monitoring. Using electronic or written mail, the permittee shall notify the Department?s Enforcement Section of a delay in emission tests prior to the deadline for accomplishing the tests. Upon recommencing operation, the permittee shall submit any pertinent pre?test notification requirements set forth in the current version of the Department?s Standard Operating Procedures For Use Of Portable Analyzers in Performance Test, and shall accomplish the monitoring. The requirement for monitoring during any monitoring period is based on the percentage of time that the unit has operated. However, to invoke monitoring period exemptions at hours of operation shall be monitored and recorded. If the emission unit has operated for more than 25% of a monitoring period, then the permittee shall conduct monitoring during that period. If the emission unit has operated for 25% or less of a monitoring period then the monitoring is not required. After two successive periods without monitoring, the permittee shall conduct monitoring during the next period regardless of the time operated during that period, except that for any monitoring period in which a unit has operated for less than 10% of the monitoring period, the period will not be considered as one of the two successive periods. If invoking the monitoring period exemption in the actual operating time of a unit shall not exceed the monitoring period required by this permit before the required monitoring is performed. For example, if the ACC Form Part 1 Permit POSI-RZ RZMI Ver 4.1 5/6/20l5 Page 128 of 143 EPA Inspection Report - Page 688 of 1969 PART 1 General Conditions H. monitoring period is annual, the operating hours of the unit shall not exceed 8760 hours before monitoring is conducted. Regardless of the time that a unit actually Operates, a minimum of one of each type of monitoring activity shall be conducted during the five year term of this permit. The permittee is not required to report a deviation for any monitoring or testing in a Speci?c Condition if the deviation was authorized in this General Condition 28108. For all periodic monitoring events, except when a federal or state regulation is more stringent, three test runs shall be conducted. at 90% or greater of the unit?s capacity as stated in this permit, or in the permit application if not in the permit, and at additional loads when requested by the Department. If the 90% capacity cannot be achieved, the monitoring will be conducted at the maximum achievable load under prevailing operating conditions except when a federal or state regulation requires more restrictive test conditions. The load and the parameters used to calculate it shall be recorded to document operating conditions and shall be included with the monitoring report. When requested by the Department, the permittee shall provide schedules of testing and monitoring activities. Compliance tests from previous NSR and Title permits may be re?imposed if it is deemed necessary by the Department to determine whether the source is in compliance with applicable regulations or permit conditions. If monitoring is new or is in addition to monitoring imposed by an existing applicable requirement, it shall become effective 120 days after the date of permit issuance. For emission units that have not commenced operation, the associated new or additional monitoring shall not apply until 120 days after the units commence Operation. All pre- existing monitoring requirements incorporated in this permit shall continue to apply from the date of permit issuance. All monitoring periods, unless stated otherwise in the speci?c permit condition or federal. requirement, shall commence at the beginning of the 12 month reporting period as defined at condition A109.B. REMARKS Except for deviations reported on the semi?annual reports and/or referenced in this report. ACC Form Part 1 Permit Ver 4.1 5/6/2015 Page 129 of 143 EPA Inspection Report - Page 689 of 1969 PART 1 General Conditions B109 General Recordkeeping Requirements Yes El No El (20.2.70.302.D.l NMAC) Explain Explain Below Below Explain A. The permittee shall maintain records to assure and verify compliance with the terms and conditions of this permit and any applicable requirements that become effective during the term of this permit. The minimum information to be included in these records is (20.2.70.302.D.l NMAC): (1) Records required for testing and sampling: equipment identification (include make, model and serial number for all tested equipment and emission controls); date(s) and time(s) of sampling or measurements; (0) date(s) analyses were performed; the company or entity that performed the analyses; analytical or test methods used; results of analyses or tests; and Operating conditions existing at the time of sampling or measurement. (2) Records required for equipment inspections and/or maintenance required by this permit: equipment identi?cation number (including make, model and serial number) date(s) and time(s) of inspection, maintenance, and/or repair (0) date(s) any subsequent analyses were performed (if applicable) name of the person or quali?ed entity conducting the inspection, maintenance; and/or repair copy of the equipment manufacturer?s or the owner or operator?s maintenance or repair recommendations (if required to demonstrate compliance with a permit condition) description of maintenance or repair activities conducted all results of any required parameter readings a description of the physical condition of the equipment as found during any required inspection results of required equipment inspections including a description of any condition which required Below ACC Form Part I. Permit P051-R2 Ver 4.1 5/6/2015 Page 130 of 143 EPA Inspection Report - Page 690 of 1969 PART 1 General Conditions adjustment to bring the equipment back into compliance and a description of the required adjustments B. The permittee shall keep records of all monitoring data, equipment calibration, maintenance, and inspections, Data Acquisition and Handling System (DAHS) if used, reports, and other supporting information required by this permit for at least five (5) years from the time the data was gathered or the reports written. Each record shall clearly identify the emissions unit and/or monitoring equipment, and the date the data was gathered. (202.70.302.D.2 NMAC) C. if the permittee has applied and received approval for an alternative operating scenario, then the permittee shall maintain a log at the facility, which documents, contemporaneously with any change from one operating scenario to another, the scenario under which the facility is operating. (202.70.302.A.3 NMAC) D. The permittee shall keep a record describing off permit changes made at this source that result in emissions of a regulated air pollutant subject to an applicable requirement, but not otherwise regulated under this permit, and the emissions resulting from those changes. (202.70.302.12 NMAC) E. Unless otherwise indicated by Specific Conditions, the permittee shall keep the following records for malfunction emissions and routine and predictable emissions during startup, shutdown, and scheduled maintenance (SSM): The owner or operator of a source subject to a permit, shall establish and implement a plan to minimize emissions during routine or predictable startup, shutdown, and scheduled maintenance through work practice standards and good air pollution control practices. This requirement shall not apply to any affected facility de?ned in and subject to an emissions standard and an equivalent plan under 40 CF Part 60 (NSPS), 40 CFR Part 63 (MACT), or an equivalent plan under 202.72 NMAC Construction Permits, 20.2.70 NMAC Operating Permits, 20.2.74 NMAC - Permits Prevention of Signi?cant Deterioration (PSD), or 202.79 NMAC Permits Nonattainment Areas. (20.2.7.14.A NMAC) The permittee shall keep records of all sources subject to the plan to minimize emissions during routine or predictable SSM and shall record if the source is subject to an alternative plan and therefore, not subject to the plan requirements under 20.2.7.14.A NMAC. (2) If the facility has allowable SSM emission limits in this permit, the permittee shall record all SSM events, including the date, the start time, the end time, a description of the event, and a description of the cause of the event. This record also shall include a copy of the manufacturer?s, or equivalent, documentation showing that any maintenance quali?ed. as scheduled. Scheduled maintenance is an activity that occurs at an established frequency pursuant to a written protocol published by the manufacturer or other reliable source. The authorization of allowable SSM emissions does not supersede any applicable federal or state standard. The most stringent requirement applies. (3) If the facility has allowable malfunction emission limits in this permit, the permittee shall record all malfunction ACC Form Part 1 Permit P051-R2 Page 131 of 143 Ver 4.1 5/6/2015 EPA Inspection Report - Page 691 of 1969 PART 1 General Conditions events to be applied against these limits. The permittee shall also include the date, the start time, the end time, and a description of the event. Malfunction means any sudden and unavoidable failure of air pollution control equipment or process equipment beyond the control of the owner or operator, including malfunction during startup or shutdown. A failure that is caused entirely or in part by poor maintenance, careless operation, or any other preventable equipment breakdown shall not be considered a malfunction. (20.2.7.7.E NMAC) The authorization of allowable mal?inction emissions does not supersede any applicable federal or state standard. The most stringent requirement applies. This authorization only allows the permittee to avoid submitting reports under 20.2.7 NMAC for total annual emissions that are below the authorized malfunction emission limit. (4) The owner or operator of a source shall meet the operational plan de?ning the measures to be taken to mitigate source emissions during malfunction, startup or shutdown. NMAC) REMARKS: Except for deviations reported on the semi?annual reports and/or referenced in this report. BIIO General Reporting Requirements IE Yes No [3 (202.70.302.13 NMAC) Explain Explain Explain Below Below Below A. Reports of required monitoring activities for this facility shall be submitted to the Department on the schedule in section A109. Monitoring and recordkeeping requirements that are not required by a NSPS or MACT shall be maintained on?site or (for unmanned sites) at the nearest company of?ce, and summarized in the semi?annual reports, unless alternative reporting requirements are speci?ed in the equipment speci?c requirements section of this permit. B. Reports shall clearly identify the subject equipment showing the emission unit ID number according to this operating permit. In addition, all instances of deviations from permit requirements, including those that occur during emergencies, shall be clearly identi?ed in the reports required by section A109. (20.2.70.302.E.1 NMAC) C. The permittee shall submit reports of all deviations from permit requirements, including those attributable to upset conditions as de?ned in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. These reports shall be submitted as follows: (1) Deviations resulting in excess emissions as de?ned in 20.2.7.7 NMAC (including those classi?ed as emergencies as de?ned in section Bl l4.A) shall be reported in accordance with the timelines speci?ed by 20.2.7.1 10 NMAC and in the semi-annual reports required in section A109. (20.270.302.132 NMAC) (2) All other deviations shall be reported in the semi?annual reports required in section A109. (20.2.70.302.E.2 ACC Form Part 1 Permit P05 l-R2 Page 132 of M3 Ver 4.1 5/6/2015 EPA Inspection Report - Page 692 of 1969 PART 1 General Conditions NMAC). The permittee shall submit reports of excess emissions in accordance with 20.2.7.1 10.A NMAC. Results of emission tests and monitoring for each pollutant (except opacity) shall be reported in pounds per hour (unless otherwise Speci?ed) and tons per year. Opacity shall be reported in percent. The number of signi?cant ?gures corresponding to the full accuracy inherent in the testing instrument or Method test used to obtain the data shall be used to calculate and report test results in accordance with 20.2. l. .1 16B and NMAC. Upon request by the Department, CEMS and other tabular data shall be submitted in editable, MS Excel format. At such time as new units are installed as authorized by the applicable NSR Permit, the permittee shall ful?ll the noti?cation requirements in the NSR permit. Periodic Emissions Test Reporting: The permittee shall report semi?annually a summary of the test results. The permittee shall submit an emissions inventory for this facility annually. The emissions inventory shall be submitted by the later of April 1 or within 90 days after the Department makes such request. (20.2.73 NMAC and 20.2.70.302.A.1 NMAC) The facility emits, or has the potential to emit, 5 tons per year or more of lead or lead compounds, or 100 tons per year or more of 0, PM2.5, sulfur oxides, nitrogen oxides, carbon monoxide, or volatile organic compounds. (2) The facility is de?ned as a major source of hazardous air pollutants under 20.2.70 NMAC (Operating Permits). (3) The facility is located in an ozone nonattainment area. and which emits, or has the potential to emit, 25 tons per year or more of nitrogen oxides or volatile organic compounds. (4) Upon request by the department. (5) The permittee shall submit the emissions inventory report by April 1 of each year, unless a different deadline is (1) (2) speci?ed by the current operating permit. Emissions trading within a facility (20.2.70.302.H.2 NMAC) For each such change, the permittee shall provide written noti?cation to the department and the administrator at least seven (7) days in advance of the prOposed changes. Such noti?cation shall state when the change will occur and shall describe the changes in emissions that will result and how these increases and decreases in emissions will comply with the terms and conditions of the permit. The permittee and department shall attach each such notice to their copy of the relevant permit. ACC Form Part 1 Permit ii Ver 4.1 5/6/2015 Page 133 ofl43 EPA Inspection Report - Page 693 of 1969 PART 1 General Conditions REMARKS Except for deviations reported on the semi?annual reports and/or referenced in this report. BI 11 General Testing Requirements A. Compliance Tests (1) (2) (3) (4) (5) (6) Compliance test requirements from previous permits (if any) are still in effect, unless the tests have been satisfactorily completed. Compliance tests may be re?imposed if it is deemed necessary by the Department to determine whether the source is in compliance with applicable regulations or permit conditions. (20.2.72 NMAC Sections 210.C and 213) Compliance tests shall. be conducted within sixty (60) days after the unit(s) achieve the maximum normal production rate. If the maximum normal production rate does not occur within one hundred twenty (120) days of source startup, then the tests must be conducted no later than one hundred eighty (1 80) days after initial startup of the source. Unless otherwise indicated by Speci?c Conditions or regulatory requirements, the default time period for each test run shall be at least 60 minutes and each performance test shall consist of three separate runs using the applicable test method. For the purpose of determining compliance with an applicable emission limit, the arithmetic mean of results of the three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the three runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances, beyond the owner or operator's control, compliance may, upon the Department approval, be determined using the arithmetic mean of the results of the two other runs. Testing of emissions shall be conducted with the emissions unit operating at 90 to 100 percent of the maximum operating rate allowed by the permit. If it is not possible to test at that rate, the source may test at a lower operating rate, subject to the approval of the Department. Testing performed at less than 90 percent of permitted capacity will limit emission unit operation to 10 percent of the tested capacity until a new test is conducted. If conditions change such that unit operation above 110 percent of tested capacity is possible, the source must submit a protocol to the Department within 30 days of such change to conduct a new emissions test. El Yes Explain Below No 1] Explain Explain Below Below ACC Form Part 1 Permit Ver 4.1 5/6/2015 Page 134 of 143 EPA Inspection Report - Page 694 of 1969 PART 1 General Conditions B. C. EPA Reference Method Tests (1) All compliance tests required by this permit, unless otherwise speci?ed by Speci?c Conditions of this permit, shall be conducted in accordance with the requirements of 40 CFR 60, Subpart A, General Provisions, and the following EPA Reference Methods as speci?ed by 40 CFR 60, Appendix A: (C) U) (1) (In) (H) Methods 1 through 4 for stack gas ?owrate Method 5 for TSP Method 6C and 19 for Method 713 for NOX (test results shall be expressed as nitrogen dioxide (N 03) using a molecular weight of 46 lb/lb-mol in all calculations (each of is equivalent to 1.194 10-7 Method 9 for opacity Method 10 for CO Method 19 may be used in lieu of Methods 1-4 for stack gas ?owrate upon approval of the Department. A justi?cation for this proposal must be provided along with a contemporaneous fuel gas analysis (preferably on the day of the test) and a recent fuel ?ow meter calibration certi?cate (within the most recent quarter). Method 7E or 20 for Turbines per 60.335 or 60.4400 Method 29 for Metals Method 201A for ?lterable and Method 202 for condensable PM Method 320 for organic Hazardous Air Pollutants (HAPs) Method 25A for VOC reduction ef?ciency Method 30B for Mercury (2) Alternative test method(s) may be used if the Department approves the change. Periodic Monitoring and Portable Analyzer Requirements (1) Periodic emissions tests (periodic monitoring) may be conducted in accordance with EPA Reference Methods or by utilizing a portable analyzer. Periodic monitoring utilizing a portable analyzer shall be conducted in accordance with the requirements of ASTM 6522-00. However, if a facility has meta previously approved ACC Form Part 1 Permit P051-R2 R2M1 Ver 5/6/2015 Page 135 of 143 EPA Inspection Report - Page 695 of 1969 PART 1 General Conditions (2) (3) (4) (5) Department criterion for portable analyzers, the analyzer maybe operated in accordance with that criterion until it is replaced. Unless otherwise indicated by Speci?c Conditions or regulatory requirements, the default time period for each test run shall be at least 20 minutes. Each performance test shall consist of three separate runs. The arithmetic mean. of results of the three runs shall be used to determine compliance with the applicable emission limit. Testing of emissions shall be conducted in accordance with the requirements at Section B108.F. During emissions tests, pollutant and diluent concentration shall be monitored and recorded. Fuel flow rate shall be monitored and recorded if stack gas flow rate is determined utilizing Method 19. This information shall be included with the test report furnished to the Department. Stack gas flow rate shall be calculated in accordance with 40 CFR 60, Appendix A, Method l9 utilizing fuel ?ow rate (sci) determined by a dedicated fuel ?ow meter and fuel heating value (Btu/sci) determined from a fuel sample obtained preferably during the day of the test, but no earlier than three months prior to the test date. Alternatively, stack gas flow rate may be determined by using EPA Methods l?4. D. Test Procedures: (1) (2) (3) (4) (5) (6) (7) The permittee shall notify the Department?s Program Manager, Compliance and Enforcement Section at least thirty (30) days before the test to afford a representative of the Department an opportunity to be present at the test. (40CFR Equipment shall be tested in the "as found" condition. Equipment may not be adjusted or tuned prior to any test for the purpose of lowering emissions, and then returned to previous settings or operating conditions after the test is complete. Contents of test noti?cations, protocols and test reports shall conform to the format speci?ed by the Department?s Universal Test Noti?cation, Protocol and Report Form and Instructions. Current forms and instructions are posted to Air Quality web site under Compliance and Enforcement Testing. The permittee shall provide sampling ports adequate for the test methods applicable to the facility, safe sampling platforms, safe access to sampling platforms and utilities for sampling and testing equipment. The stack shall be of suf?cient height and diameter and the sample ports shall be located so that a representative test of the emissions can be performed in accordance with the requirements of EPA Method 1 or ASTM 6522? 00 as applicable. Where necessary to prevent cyclonic flow in the stack, flow straighteners shall be installed Unless otherwise indicated by Speci?c Conditions or regulatory requirements, test reports shall be submitted to the Department no later than 30 days after completion of the test. ACC Form Part 1 Permit P051-R2 R2M1 Ver 4.1 5/6/2015 Page 136 of I43 EPA Inspection Report - Page 696 of 1969 PART 1 General Conditions REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. BI 12 Compliance A. The Department shall be given the right to enter the facility at all reasonable times to verify the terms and conditions of this permit. Required records shall be organized by date and subject matter and shall at all times be readily available for inSpection. The permittee, upon verbal or written request from an authorized representative of the Department who appears at the facility, shall immediately produce for inspection or copying any records required to be maintained at the facility. Upon written request at other times, the permittee shall deliver to the Department paper or electronic copies of any and all required records maintained on site or at an. off?site location. Requested records shall be copied and delivered at the permittee?s expense within three business days from receipt of request unless the Department allows additional time. Required records may include records required by permit and other information necessary to demonstrate compliance with terms and conditions of this permit. (NM SA 1978, Section 74-2-13) B. A copy of the most recent permit(s) issued by the Department shall be kept at the permitted facility or (for unmanned sites) at the nearest company office and shall be made available to Department personnel for inspection upon request. (20.2.70.302.G.3 NMAC) C. Emissions limits associated with the energy input ofa Unit, i.e. lb/MMBtu, shall apply at all times unless stated otherwise in a Specific Condition of this permit. The averaging time for each emissions limit, including those based on energy input of a Unit lb/MMBtu) is one (1) hour unless stated otherwise in a Speci?c Condition of this permit or in the applicable requirement that establishes the limit. (20.2.70.302.A.l and G.3 NMAC) D. The permittee shall submit compliance certification reports certifying the compliance status of this facility with respect to all permit terms and conditions, including applicable requirements. These reports shall be made on the pre?populated Compliance Certi?cation Report Form that is provided to the permittee by the Department, and shall be submitted to the Department and to EPA at least every 12 months. For the most current form, please contact the Compliance Reports Group at For additional reporting guidance see (20.270.302.133 NMAC) E. The permittee shall allow representatives of the Department, upon presentation of credentials and other documents Yes Explain Below No Explain Explain Below Below ACC Form Part Permit Ver 4.1 5/6/2015 Page 137 of143 EPA Inspection Report - Page 697 of 1969 PART 1 General Conditions as may be required by law, to do the following (20.2.70.302.G.l NMAC): i) enter the permittee?s premises where a source or emission unit is located, or where records that are required by this permit to be maintained are kept; (2) have access to and copy, at reasonable times, any records that are required by this permit to be maintained; (3) inspect any facilities, equipment (including monitoring and air pollution control equipment), work practices or operations regulated or required under this permit; and (4) sample or monitor any substances or parameters for the purpose of assuring compliance with this permit or applicable requirements or as otherwise authorized by the Federal Act. REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. B113 Permit Reopening and Revocation A. This permit will be reopened and revised when any one of the following conditions occurs, and may be revoked and reissued when or occurs. (20.2.70.405.A.i NMAC) (1) (2) (3) (4) Additional applicable requirements under the Federal Act become applicable to a major source three (3) or more years before the expiration date of this permit. If the effective date of the requirement is later than the expiration date of this permit, then the permit is not required to be reopened unless the original permit or any of its terms and conditions has been extended due to the Department?s failure to take timely action on a request by the permittee to renew this permit. Additional requirements, including excess emissions requirements, become applicable to this source under Title IV of the Federal Act (the acid rain program). Upon approval by the Administrator, excess emissions offset plans will be incorporated into this permit. The Department or the Administrator determines that the permit contains a material mistake or that inaccurate statements were made in establishing the terms and conditions of the permit. The Department or the Administrator determines that the permit must be revised or revoked and reissued to assure compliance with an applicable requirement. XI Yes Explain Below El No Explain Below Explain Below ACC Form Part 1 Permit POSI-R2 RZMI Ver4.15/6/2015 Page 138 ofl43 EPA Inspection Report - Page 698 of 1969 PART 1 General Conditions B. Proceedings to reopen or revoke this permit shall affect only those parts of this permit for which cause to reopen or revoke exists. Emissions units for which permit conditions have been revoked shall not be operated until new permit conditions have been issued for them. (20.2.70.405.A.2 NMAC) REMARKS: Except for de viations reported on the semi?annual reports and/or referenced in this report. B1 14 Emergencies (20 (1) (2) (3) (4) C. 2.70.304 NMAC) An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the permittee, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology?based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventive maintenance, or careless or improper operation. An emergency constitutes an af?rmative defense to an action brought for noncompliance with technology-based emission limitations contained in this permit if the permittee has demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that: An emergency occurred and that the permittee can identify the cause(s) of the emergency; This facility was at the time being properly operated; During the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or other requirements in this permit; and The permittee submitted notice of the emergency to the Department within 2 working days of the time when emission limitations were exceeded due to the emergency. This notice ful?lls the requirement of 20.2.70.302.E.2 NMAC. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency has the burden of proof. 8 Yes Explain Below El No Explain Below Explain Below ACC Form Part 1 Permit P051-R2 RZMI Ver 4.1 5/6/2015 Page l39 ofl43 EPA Inspection Report - Page 699 of 1969 PART 1 General Conditions D. This provision is in addition to any emergency or upset provision contained in any applicable requirement. REMARKS: Except for deviations reported on the semi?annual reports and/or referenced in this report. B115 Stratospheric Ozone Yes A. If this facility is subject to the federal acid rain program under 40 CFR 72, this section applies. B. Where an applicable requirement of the Federal Act is more stringent than an applicable requirement of regulations promulgated under Title IV of the Federal Act, both provisions are incorporated into this permit and are federally enforceable. C. Emissions exceeding any allowances held by the permittee under Title IV of the Federal Act or the regulations promulgated thereunder are prohibited. (20.2.70.302.A.1 NMAC) Explain Explain Below Below Explain A. If this facility is subject to 40 CFR 82, Subpart F, the permittee shall comply with the following standards for Below recycling and emissions reductions: (1) Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices, except for motor vehicle air conditioners (MVAC) and MVACwlike appliances. (40 CFR 82.156) (2) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment. (40 CFR 82.158) (3) Persons performing maintenance, service, repair, or disposal of appliances must be certi?ed by an approved technician certi?cation program. (40 CFR 82.161) REMARKS: Except for deviations reported on the semi?annual reports and/or referenced in this report. 8116 Acid Rain Sources Yes No (20.2.70.302.A.9 NMAC) Explain Explain Below Below Explain Below ACC Form Part 1 Permit it P051-R2 4.l 5/6/2015 Page 140 of 143 EPA Inspection Report - Page 700 of 1969 PART 1 General Conditions D. No modi?cation of this permit is required for increases in emissions that are authorized by allowances acquired pursuant to the acid rain program, provided that such increases do not require a permit modi?cation under any other applicable requirement. E. The permittee may not use allowances as a defense to noncompliance with any other applicable requirement. F. No limit is placed on the number of allowances held by the acid rain source. Any such allowance shall be accounted for according to the procedures established in regulations promulgated under Title IV of the Federal Act. G. The acid rain permit is an enclosure of this operating permit. REMARKS: 3117 Risk Management Plan Yes No El (20.2.70.302.A.l NMAC) Explain Explain Below Below Explain Below A. If this facility is subject to the federal risk management program under 40 CFR 68, this section applies. B. The owner or operator shall certify annually that they have deve10ped and implemented a RMP and are in compliance with 40 CFR 68. C. If the owner or operator of the facility has not developed and submitted a risk management plan according to 40 CFR 68.150, the owner or Operator shall provide a compliance schedule for the development and implementation of the plan. The plan shall describe, in detail, procedures for assessing the accidental release hazard, preventing accidental releases, and developing an emergency response plan to an accidental release. The plan shall be submitted in a method and format to a central point as specified by EPA prior to the date speci?ed in 40 CFR 68.150.b. REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. ACC Form Part 1 Permit it R2M1 Ver 4.1 5/6/2015 Page 141 of M3 ACC Deviation EPA Inspection Report - Page 701 of 1969 Part 2 Summary Report for Permit P051-R2 RZMI Deviation Summary Table for deviations not yet reported. IXlYes ElNo DYes EYes throughput in 2016. (The re?nery's most recent NSR permit, increases these limits.) No. Applicable Requirement Cause of Deviation Corrective Action Taken (Include Rule Citation) Umt A107.C, Ail Flares Flare monitoring implemented to meet NSPS a Navajo has been working to quantify emissions from. Allowable SSM and Malfunction requirements has resulted in data that has been under its ?ares, and draft permit appiications to re?ect new Emissions evaluation for potential exceedences of permit limits. permit limits were provided to and discussed with the 1 Thus, any excess emissions have not been reported NMED. Navajo will address any reporting of excess to date. emissions that may be necessary with the NMED. A206.B Flare gas below 300 btu/scf NHV due to hydrogen Increase H2 consumption and reduce H2 sent to the 2 40 CFR 63.1 1(b) venting as a result of process upset and hydrogen ?are. imbalance. FL-0404 Tanks The draft results of a recent third-party Navajo currently intenbds to seek a conforming environmental compliance audit indicate potential amendment to the Title permit to re?ect the exceedances of the Title permit sour water underiying applicable requirements in the most 3 throughput limit in 2016 (and 205) and the distillate recent NSR permit. ACC Part 2, Deviation Summary Table Title-V Permit Page 142 of 144 EPA Inspection Report - Page 702 of 1969 PART 1 General Conditions Deviation Summary Table for deviations not yet reported. (cont) No. Applicable Requnement ETD-1831011 Cause of Deviation Corrective Action Taken (include Rule Citation) Unit A109.D HC Flaring Incident Corrective Active Follow-up Navajo tracks RCA events on a weekly basis to 4 Letter was not submitted within 30 days of determine if corrective actions have been implementation. implemented, and if a followup letter is therefore due within 30 days of implementation. A106 and A107 All Sources Several excess emission reports required under Navajo tracks emission events on a daily basis and is 5 condition A106 and A107 were not reported within in the process of installing a Data Acquisition System the time required under 20.2.7 NMACV (DAS) to capture events immediately. A103.A, 20.2.74 NMAC GOHT, The draft results ofa voluntary, third-party, focused A draft application to revise NSR Permit No. 0195-M37 to including environmental compiiance audit received on April 9, re?ect increased ?are emission limits has been prepared FL-0404 and 2018, as updated by the auditor on May 29, 2018, indicate and was recently discussed with the NMED. Preperation H-0601 that PSD for carbon monoxide (CO) and may have ofa PSD permit application in connection with the GOHT been triggered in connection with the 200] GOHT Project Project is underway and approaches have been discussed ?5 it updated FL-0404 emissions data. from recent with the MED. Based on current review, BACT for CO monitoring under NSPS la were to be applied and NOX is expected to require neither any reductions retroactiveiy. This is under further review. below current emission levels nor the installation of any controi equipment. Temporary Notice to NMED or other permitting steps may have This is currently under review. Engines triggered for the brief app. 4 hrs) installation of a temporary engine used as an alternative power source for a. server in the IT Department in order to establish wiring 7 connections for the forthcoming installation of a permanent standby emergency generator. This area is currently under review. An administrative permit revision was recentiy submitted for the permanent standby generator. ACC Fonn Part. 1 Permit it P051-R2 RZMI Ver 4.1 5/6/2015 Page 143 of 144 EPA Inspection Report - Page 703 of 1969 Deviation Summary Table (cont.) Deviation Started Deviation Ended Did you attach an excess emissmn form? . 1. . . Amount of No. Date T1n1e Date 11116 Pollutant Monitoring Method . . 1 09/01/2017 0000 08/31/2018 2369 Data Data DYes (See Note 2) . Under 3 P1 Data . DYes REVIEW 4 06/24/2018 00:00 07/30/2018 00:00 302 Pi .Data Yes EN0 5 Various Pi Data, Calculations Data EYES END 7 06/20/2018 08:30 06/20/2018 12:30 Various Calculations DYes Note 1 Consistent with prior reporting and previous discussions with NMED, this table does not include deviations previously reported to NMED, including in reports under the NSPS, MACT, or other programs. Note 2 Refer to attached Table of Events Summary. ACC Part 2, Deviuation Summary Title-V Permit P051 -R2 Page 144 of 144 EPA Inspection Report - Page 704 of 1969 No. 2 2 (FL-0401) 2 Deviation Started Date/Time 12/04/2017 13:00 08/06/2018 14:00 02/05/2018 01:00 02/13/2018 13:00 02/16/2018 00:00 02/16/2018 02:00 02/16/2018 04:00 10/14/2017 16:00 10/15/2017 12:00 10/02/2017 14:00 10/09/2017 17:00 12/28/2017 05:00 06/19/2018 13:00 Deviation Ended Date/Time 12/04/2017 14:00 08/06/2018 20:00 02/05/2018 02:00 02/13/2018 19:00 02/16/2018 01:00 02/16/2018 03:00 02/16/2018 06:00 10/14/2017 17:00 10/15/2017 01:00 10/02/2017 16:00 10/09/2017 18:00 12/28/2017 07:00 06/20/2018 06:00 Poiiutant Monitoring Method Amount of Emissons Excess Emission Form? Table of Events Summary (<300 BTU) Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data Pi Data lofl EPA Inspection Report - Page 705 of 1969 New Mexico Environment Department - Air Quaiity Bureau Compliance and Enforcement Section 525 Camino de Los Marquez Suite 1 - Santa Fe, NM 87505 Phone (505) 476-4300 - Email: Excess Emissions Reporting Form .miS?ion 000198?09292016?01 Facility Name Navajo Refining Company LLC FL-0400 Qomp'an'y'NameL5 North Plant Flare Title. sporting .Re?l Ltirement :(Title V) beef-snisip's' Page 1 of 2 EPA Inspection Report - Page 706 of 1969 it wee discovered that on approximateiy 11/01/2015, Navajo had potentialiy exceeded the permitted TPY limits for 1' Page 2 of 2 EPA Inspection Report - Page 707 of 1969 New Mexico Environment Department - Air Quaiity Bureau Compliance and Enforcement Section 525 Camino de Los Marquez - Suite 1 Santa Fe, NM 87505 Phone (505) 47?8-4300 - Emaii: Excess Emissions Reporting Form 000198-09292016~02 ?'acility Name Navajo Refining Company LLC Navaio Refining - Artesia Refinery Souroe .i'sff Portable. Opation Title! Permit AftmatweDefense?l?i Page 1 of 2 EPA Inspection Report - Page 708 of 1969 {fit was discovered that on approximateiy 11/01/2015, Navajo had potentialiy exceeded the permitted TPY limits for andVOC .. .. .. .. .. .. i??taii?? .. 53% $9191? on 75.1-sz Clicking on the Certify button, '1 aagree. to ..ihefosiowmg .II .eedify this repair-t asztrue aAfter reasonable inq ditty}. aecdfate and combiete. Cl Contmuous ITReper'tiing' Of?cial-1 Raymond Smalts Speciaiist 5 Page 2 of 2 EPA Inspection Report - Page 709 of 1969 New Mexico Environment Department - Air Quality Bureau Compiiance and Enforcement Section 525 Camino de Los Marquez Suite 1 - Santa Fe, NM 87505 Phone (505) 47'6-4300 Email: Excess Emissions Reporting Form 00198-09292016-03 avajo Refining Company LLC 1/01/2015 00:00 1/01/2015 00:00 1/02/2015 Affirmative". Defense" ?Claim Page 1 of 2 EPA Inspection Report - Page 710 of 1969 Edit-was discovered that on approximately had potentiaily exceeded the permitted NOX, I 02 CO VOC Page 2 of 2 EPA Inspection Report - Page 711 of 1969 New Mexico Environment Department - Air Quality Bureau Compliance and Enforcement Section 525 Camino de Los Marquez - Suite 1 - Santa Fe. NM 87505 Phone (505) 476-4300 - Email: Excess Emissions Reporting Form 000198-09292016-04 Navajo Refining Company LLC cpmpa_ny_N_a_ Navajo Refining Artesia Refinery Source._ ?Stationary Scum? 1/01/2015 00:00 1/01/2015 00:00 Page 1 of 2 EPA Inspection Report - Page 712 of 1969 :lt was discovered that on approximately 11/01/2015, Navajo had potentially exceeded the permitted TPY limits for CO and VOC. . .fo clicking .Ohfthe .Cedify button, agree; latheronowmg (S) Page 2 012 EPA Inspection Report - Page 713 of 1969 New Mexico Environment Department Air Quality Bureau Compiiance and Enforcement Section 525 Camino de Los Marquez - Suite 1 - Santa Fe. NM 87505 Phone (505) 476-4300 - Email: Excess Emissions Reporting Form Sourcels StationarySource'? 1?01/20150000 I I ?01/20150000 . Page 1 of 2 EPA Inspection Report - Page 714 of 1969 was discovered that on approximateiy 11/01/2015, Navajo had potentialiy exceeded the permitted TPY limits for CO and VOC Page 2 of 2 EPA Inspection Report - Page 715 of 1969 New Mexico Environment Department - Air Quazity Bureau Compliance and Enforcement Section 525 Camino de Los Marquez - Suite 1 - Santa Fe. NM 87505 Phone (505) 476-4300 - Email: Excess Emissions Reporting Form 000198?09292016-06 ;.Fa.cili_tyf_Na_rn_e Navajo Refining Company LLC iCompany?Na'me Navajo Refining Artesia Refinery {Source is; .f Page 1 of 2 EPA Inspection Report - Page 716 of 1969 etailed Description- It was discovered that oh approximateiy 11/01/2015, Navajo had poteh?'aililyn exceeded the fof 80200 OW Page 2 of 2 EPA Inspection Report - Page 717 of 1969 H:OLLYFRONTIER" September 30, 2019 Enforcement Manager Air Quality Bureau - Enforcement NM Environment Department 525 Camino de los Marquez, Suite l Santa Fe, New Mexico 87505-1816 Re: Certified. Mail/Return. ReceipJ 7018 0360 0001 7923 5958 HollyFrontier Navajo Refining LLC Artesia, NM Refinery Title V Operating Permits P051-R2Ml Annua] Compliance Certification Agency Interest No. 198 Reporting Period September 1, 2018 through August 31, 2019 On behalf of HollyFrontier Navajo Refining LLC (Navajo), I am submitting Navajo's annual compliance certification (ACC) for the Artesia, NM Refinery. Title V Operating Permit P051-R2Ml Reporting Period: September 1, 2018 through August 31, 2019 Consistent with the initial compliance certification, items identified during work practices, such as fugitive component monitoring inspections, that are corrected or repaired within the regulatory timeframe and that are properly documented, do not comprise exceptions or deviations. Please feel free to contact me at (575) 746-5487 or Ray Smalts at (575) 746-5490 if you have any questions or should require any further information. Sincerely, Scott M. Denton Environmental Manager Enclosure cc: US EPA (w/enc): Chief, Air Permits, U.S. EPA Region 6 (6PD-R), 1201 Elm Street, Suite 500, Dallas, TX 75270-2102 Navajo: P. Miller, W. Romine, R Smalts, S. Hammond Environmental File: 2.10 Annual Compliance Certifications (Title V)\Artesia Certification\2019 Artesia Certification\2019-0930 Artesia. Title .v..Annual ..Compliance. Certification ..ndf .HollyFmntier Navajo Refining LLC 501 East Ma.in• Artesia, NM 88210 (575) 748-331 l • ht1r.iiwww.Jwlt;fr:2ntfa~I&9m HFNA-000005178 EPA Inspection Report - Page 718 of 1969 New l\1exico Environment Department Air Quality Bureau Compliance and Enforcement Section 525 Camino de los Marquez, Suite 1 Santa Fe, NJV[ 87505 Phone (505) 476-4300 Fax (505) 476-4375 Version 05.02.13 NMED USE ONLY i REPORTING SUBMITTAL FORM t TEMPO ,.-....................N.MED.USE.ONLY............ ] Staff · I •••••••••••••••••••••••••••••••••••••••••••ccccc-} ________!\f!mir:i. ,.......................................................... l'llilSE !\IOU:® - Indicates required field SECTION I - GENERAL COMPANY ANO FACILITY INFORMATION A.® Company Name: HollyFrontier Navajo Refining LLC B. 1 ® Company Address: PO Box 159 ···············-------------------! D. ® Facility Name: HollyFrontier Navajo Refining LLC E. 1 ® Facility Address: 501 E.Main St. •••••••••ssss•"""""""""""' .....................................- - - - - - 1 ~:~··@·sfute:1~~~~-z1i,: .. B.2® City: !~e:~ity: • B.3 ® State: i B.4 ® Zip: .............. : NM - 8 8 2 1 '1 - 0 '1 5 9 Artesia F .1 ® Facility Cont-ac_t_:-----+.·=Fcc.2~@"'""R-="Titie:· ........................._............_. C.1 ® Company Environmental Contact: C.2 ® Title: Scott Denton Environmental Manager Scott Denton Environmental Manager 1 ~C---.3""®~P""h_o_n_e-"ON"'""u_m_b~e-r_:_ _ _ _ _-,--.,c"".~4® Fax Number:"······················· F.3 ® Phone Number: F.4 ® Fax Number: .........................._ 575-746-5487 575-746-5451 575-746-5487 575-746-5451 -------·····························---··------··------····c·.5 ® Email Address: F.5 ® Email Address: Scott.Denton@hollyfrontier.com Scott.Denton@hollyfrontier.com G. Resoonsible Official: /Title V onlvl: H. Title: L Phone Number: , J. Fax Number: Vice President & Refinery I Parrish R. Miller Manager, HollyFrontier Navajo 575-748-3311 1 575-746-5451 Refininq LLC 1 K. ® Al Number: [ L Title VP M. Title V Permit Issue Date: IN. NSR Permit Number: 0. NSR Permit Issue Date: 198 P051-R2M1 • 01/22/2016 PSD-NM-0195-M37 08/12/2016 : ; ~~po~~~~1~;~;~d:-~To: ....0..8 ..../.3···1···/··2····0···1···9···················'················,1···················1,..............................................,........................................... ,[_................ 0 I ._!~-"""'-------.. . . . . . . . . . . . . . . . . . . . . . .. 0 NII -TYPE OF SUBMITIAl (check one that applies) ························--······----·r--·---- A. [g1 IPermit Conditionls}: s. D Title V Semi-annual Monitoring Report C. D NSPS Requirement (40CFR60) D. D MACT Requirement (40CFR63) D NMAC Requirement {20.2.xx} or NESHAP Requirement (40CFR61} E. F.0 - ..- .................................-............. Title V Annual Compliance Permit Condition{s}: Certification A109 i Descriotion: j Reaulation: Sectionisl: •Descriotion: Sectionlsl: •Descriotion: !Section!sl: •Descriotion: I I I Reaulation: i IReau!ation: I I Permit No.O: or NOi No.D: Condition{s): Permit or Notice of Intent Requirement I •Description: (NO!) NOV No. D: ~r SFO Ni,,~~:]_ Section(s): G.0 -----------------------------------························~~~~~~~~~~~~~~ Description: Annual Compliance Certification Requirement of an Enforcement Action jDescription: orCONo.O.orOtherD. i SECTION IV- CERTIFICATION ---------------------------·-················----------- ---------------..·····························-·----··················-- After reasoµabfuinquiry, I /,,_/ ··········---- er-~""-"" / ................ Parrish R. Miller ............................ certify that the information in this submittal is true, accurate and complete. (name of reporting official) » n= =nnnn~ • ..,.. ............. .. ® Date 1® Responsible Official for Title V? ® Title: Vice President & Refinery Manager, HollyFrontier 09/30/2019 Yes _ _ _ _..,.__ _ _ _ _ _ ___._ _ __,,,_ __....__ _ _ _ _ _ _ _ _ _ _,...,__[g1 _ _ _ _ _0No _ _.......l! Nava·o Refinin LLC ® ~Jwiature of~p9-rtj,ig ~c\~;>_t' ,, /._,,"''' / / ,.. ;-- / ----·,,, ··;>· /.,, _ _,./ '· ., ~ > / ~--r ,.· ,. Reviewed By: . ,.. ' ·,,, ······························=··------------ Date Reviewed: HFNA-000005179 EPA Inspection Report - Page 719 of 1969 Title V Report Certification Form 1111 Annual Compliance Certification o Semi-Annual l\1onitoring Report Facility Name: Artesia Refinery ----------------------------------------~ Facility Address: PO Box 159, Artesia State: NM Responsible Official (RO): Parrish R. Miller Phone; 575-748-331 l RO Title: Vice President & Refinery Manager, HollyFrontier Navajo Refining LLC Zip: 88211-0159 Fax: 575-746-5421 ------------------------------- RO e-mail: ----------~------········--------------------- -------------------------! _________ ________________ Permit No.: P051-R2M1 ,,___ ,__ ,, Date Permit Issued: 01/22/2016 Report Due Date (as required by the Permit Al number: 0198 permit):09/30/201_8_ _ _ _ _ _ _ _ _,____ _ _~ -------------·-------------------' Time period covered by this Report: From: I am the Responsible Official indicated above. I, :Parrish R. Miller, certify that I meet the requirements of 20.2. 70. 7 .AD NMAC. I certify that, based on information and belief formed after reasonable inquiry, the statements and information contained in the attached Title V report are true, accurate, and complete. Signature_L~"~ ~-- '-------------------·····························---- ----------------------------------------- HFNA-000005180 EPA Inspection Report - Page 720 of 1969 Title V Annual Compliance Certification for Permit P051-R2 & R2J\11 Title (TV) Permit Administration Amendment On January 22, 2016 NMED AQB issued an Administrative Amendment to Operating Permit PG52-R2. The Administrative Amendment PG51-R2Ml corrected the following: ® 'lhe Department ackrnrnvledges the 0'%TWr/PennHke rrnme change from Navajo Refh:dng Compan;\ LLC to EfoUyFnmtfor Navajo Rdmmg LLC For this is an Administrative Amendment (P0Sl-R2I\U}, the facility can use one Annual Compliance Certification (ACC) Form which will cover both TV Permits. Although the facility is only required to submit one ACC Form, the facility sha1I submit two (2) separate TV Report Certification Forms. Each form shall list the corresponding TV Permit number, TV Permit Issue Date and Reporting Period. Please note that this is a one-time authorization. Submittal forms for future Administrative Revisions win be evaluated on a case by case basis. This form can also be used for future submittal that cover only the PG51-R2l\U permit HFNA-000005181 EPA Inspection Report - Page 721 of 1969 Part 1 - Permit Requirements Certification Table 2. Method(s) or other int:i'mnation or other facts used to dctcnninc the compliance status: FACILITY REQUIREMENTS :frequency of data coHectk,n used to dc-tc-nninc crnnpfomce? SPECIFIC 4. Was this fadity in compliance with this requirement during the reporting period? 5. Were there any deviations associated with this requirement during the rnporting rwriod? D Continuous [Sl Yes []Yes 0 0No [Sl No Intermittent AHH Permit Duration (expiration) Navajo submitted the application for renewal on May 06, 2019. A. The term of this pen11it is five (5) years. It -.,,vill expire five years from the date of issuance. Application for renewal of this permit is due twelve (l 2) months prior to the date of expiration, 202, 70300.R2 and 302.B NMAC A101 Permit Duration (expiration) D Continuous [Sl Yes 0Yes B. If a renewal pen11it is not issued prior tZI Intermittent 0No [ZI No D Couthmom, [gjycs 0Yes \Xl Intermittent 0No rgj No D Continuom, 0Yes rgj Yes [Sl Intermittent [gj No 0No to the expiration date, the pen11ittee may continue to operate beyond the expiration date, provided that a timely and complete rene\val application is submitted no later than twelve (12) months prior to the , exniration date, (202. 70AOO.D NMAC) Navajo submitted the application frir renewal on May 06, 2019. Al 02 .Facility: Description E. This facility is located in the dtv limits I This is the location of Navajo refinery. of Artesia, NM, I • A103 .Facility: Applicable Regulations I "Tl z :r0 0 0 0 0 01 ...... OJ N A. The permittee shall comply with all applicable sections of the requirements listed in Table 103 .A This permit condition pro-v:ides a 1ist of the applicable requirements that arc addressed in detail in other permit conditions but does not impose any specific standa.rds, monitoring, recordkceping, or reporting requirements. Therefore, no further response is required. As :instructed by the AQB, Navajo is completing the check box :responses in columns 3, 4, and 5 of this form. Navajo continues I I EPA Inspection Report - Page 722 of 1969 Version 02.25.15 ! i. Pennit Condition # and Pem1it Condition: I' 2. Method(s} or other infonnatio11 or other facts used to determine the compliMce status: to comply with all applicable requirements except for specific deviations as :noted elsewhere in this document. (See the specific responses to the permit conditions that contain standards, monitoring, recordkeeping, or reporting requirements for more information). 4. Was this facility in complianc.e with this requirement during the reporting period? 3. W11at is the frequency of data collection used to determine comnlianee? u-•··-·.·.·.·.·.·.·.·.·.·.·.·.·.·.·.·.·.·.·.·.·.·.·.·.· I 5. Werethereany deviations associated with this requirement during the reporting •.. Q~od? ____ ,,,,, U£u.-.-.-.-.-.-.-.- .-.-.-.-.-.- I "Tl z :r0 0 0 0 0 01 ..... OJ (,) ACC Form Part l Permit# P051-R2 & R2Ml Ver4.1 02/25/2015 Page 3 of 144 EPA Inspection Report - Page 723 of 1969 Version 02.25.15 Table 103.A: Applicable Requirements A i: 1,.i O Federally • i··········p·····p·····n·······c·····a····u········.1.···e·········=·.··········e········q·········u·········1··--r······e········n········1·····e·······n··········t······s··········------··-··-··------····----··················--···----------·-------------------,---~nforceat:>.~e . U ·tN I m o. NSR Permit No: PSD 0195-M35 20.2. 1 NMAC General Provisions X ___________ .......... '. .. EntireFacility_ X • Entire Facility 20.2.7 BM1!gEx~(;:S8EtEis~ions__ X X • 20.2.33 NMAC Gas Burning Equipment -- Nitrogen Dioxide ..JJii:i.Jjr~I~£ntr • Affected sources in Table 103.E - · • - • • CCC • 20.2.36 NMAC Petroleum Refinerv - Sulfur • ~:~:!!=~=- [w.2:1:fNMAc:--construction:--rermiT······--···--------···············---············ · · · · · · · · · · · · · · · · · · · · · · · · · •:· · xX ) 20.2.73 NMAC Notice oflntent and Emissions Inventory : . I Re.qmrements X • : , . ~9-?:11~~J::fE~Y.~!!!}ggg{§J~Q~~!Q~~~rt~~~~~?~ .............................................].... • 20.2.77 NMAC New Source Perfonnance •--- cuuuucu··· c· -,u. ----------------------------------------------- ----------- c·------------------------------ • :r0 0 0 0 0 01 ..... OJ .i:,,. ,E . F .. ntrre ac111ty : i X ........ . X cc-------------------------------------------------- JI Units ~~!t!·~subject ..!:~~-~~!Y-... to 1 I 40 CFR 60 X Units subject to 40 CFR 61 20.2.82 NMAC MACT Standards for Source Categories of HAPS J){ HnitR ,J(J YES NO NO ------.---- ~-------YES NO NO NO FUG-21-SF VACUUM Flasher/Vacuum Unit NO NO NO '(ES YES NO NO FUG 25-ROSE-2 ROSE Unit YES YES YES YES ........... ________ NO NO NO NO NO NO 0 FARM FUG-31-SRU3/TGTU3/TGI3 Light Oil Tanbge NO YES ................ ...... NO --------=- NO ,._ SRV3 Unit YES YES NO ---------~ - YES YES YES .......... _______ YES --···· -------n.•.•.•.•.•.w}ssss-'••••• fUG-33-DIST HDU Relocated Die!iel HOS Unit w/CVS YES YES YES NO YES NO YES NO cccc=u•-•-• I "Tl z :r0 0 0 0 0 01 ...... OJ 0) FlJG-34-HYDROCRACKER WX Hydmcrn.cb::-r \TS YES NO FUG-35-SAT GAS Saturates Gas Plant NO YES NO Fl!G-41-PBC l'BC t!nit NO FUG-43-S ALKY South Alky Unit (W-76; ILn~-l·~-----I HJG-44-D!ST-HDU Gm, Oil Hydrotri;ater (incL CVS) ACC Form Part 1 Permit# P051-R2 & R2Jv11 Ver 4.1 02125/2015 YES NO YES NO NO NO NO NO NO NO NO NO NO Page 6 of 144 EPA Inspection Report - Page 726 of 1969 Version 02.25.15 ,,..-,~uu,--· FUG,45-DIST HDU 0 Gas Oil Hydminwter (ind CVS) NO YES YES NO YES 1-.JO NO NO NNNuu.-.-.~-.-.-.- Hydrogen Plant NO FUG-64-H2 PL"'1"JT-2 Hydmgen Plant NO FUG-70-CCR CCR Reformer (wiin battery lin:lits) FUG-73°SP UTIL Utilities FUG-80-WWTP CVS OiliWater Separntor PUG-ASPHALT STG FUG-63-H2 PLANT-! NO NO NO NO YES NO NO NO NO NO YES NO NO NO YES : \TS YES NO YES NO NO NO NO : NO NO NO YES NO NO NO \'ES YES YES NO YES NO NO YES Asphalt/Heavy Oil Storage NO NO NO NO YES NO NO NO FUG-FUEL GAS Fuel Gas Distribution Sysiem NO YES NO NO YES NO NO NO FUG-LPG LPG Stornge System NO NO NO NO YES NO NO YES FUG-RLO-ASPHALT AsphaltiPitch Loading Rack NO NO NO NO YES NO NO NO SRU!/SRU2iSWS w/CVS YES NO YES NO YES NO NO YES NO NO NO NO YES NO NO NO FUG-SRUliSRU2!TGTU FUG-RRTOTRUCK Crude oil "-•~-~«'-;:: system, dosed loop system '·'"""""" ! I I "Tl z :r0 0 0 0 0 01 ...... OJ -..,J ACC Form Part 1 Permit# P051-R2 & R2M1 Ver 4. 1 02/25/2015 Page 7 of144 EPA Inspection Report - Page 727 of 1969 Version 02.25,15 Table 103.C, Summary Applicability-Tmks . ' NSPS .. - ...... ,,. K RWA RW-5 RW-6 NO NO NO T-0001 T-000? T-0003 T-0004 T-0057 T-0059 T-0061 NO NO NO NO NO NO NO NO NO N0 NO ------:-NO NO NO . NO NO i --: NO NO NO NO NO T-0064 T-0065 T-0071 T-0072 T-0073 T-0074 T-0075 T-0076 T-0078 T-0079 T-0081 NO NO NO NO NO NO NO NO NO NO NO T-0106 NO ' . ,.~,------·-----···· MACT CC MACT CC fJt.,,all.<: Warmcrnm:, NO NO NO NIA N/A NS.PS Ka NO NO NO NSPS Kb NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO \'ES NO YES NO YES NO NO NO NO NO NO NO YES · - · " " " _..............._,, NO YES NO · · NO NO I NO NO NO NO YES YES NO NO YES NO YES NO YES NO YES NO YES NO NO YES YES NO NO NO NO NO NO NO NO YES ·vEs NO NO YES \13S YES YES YES rTS YES YES NO YES NIA NESHAP FF NIA N/A NIA NSPS QQQ NIA NIA NIA 2(t2,37,205 YES YES YES NO NIA NI A YES N/A NIA Nii\ N/A NIA N N/A NIA NI A NIA NIA YES N/A NI A NIA N/A NIA NIA NIA NIA NIA NIA NIA NIA NIA N/A NIA NIA NI A NIA NIA NO NO NO NO NIA NI A YES NI A NIA N/A NIA NIA NI A N/A NIA YES NIA NI A NIA NIA NIA N/A NIA NIA NIA NiA N/A NiA NIA NIA NIA NIA NIA NIA. NIA NO NO NO NO YES rLS NO NO NO NO NO NO YES YES YES NO YES YES YES NO NO NO NO YES YES YES YES YES YES \'ES YES r13S YES YES YES NMAC" NO NO NO ·--···--·--········· • • W.23lt1G9 20-:U&JW 20238-112 20,23U13 • • NMAC .NMA.C fiTh"f~C N~Ji\~ JG/\fyfj NO YES NO ···········1 ·····················.,·················7····-·····-< YES NO . ,., ....... ,,.... ..............................,..... I NO YES NO NO NO ---····· ., - NO )'ES NO NO NO NO -· No ..........L No~ NO . NO . NO NO i NO i . NO . NO NO NO NO YES YES NO NO NO YES YES NO NO NO • NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES YES YES YES NO NO NO YES NO NO NO NO YES NO NO NO NO NO NO NO NO NO YES NO NO YES YES NO NO NO \'ES YES YES YES NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO NO NO NO YES NO NO NO NO YES NO NO NO NO YES NO NO NO NO YES NO NO I NO NO YES NO NO NO NO YES NO NO YES YES YES YES NO YES YES YES YES NO NO NO YES NO NO NO NO YES NO NO YES YES NO NO NO ·········1···---- -------~-: T-OOU T-0012 !········-··-· T-0013 T-0026 }····· T-0023 T-0046 I "Tl z :r0 0 0 0 0 01 ..... OJ OJ i i ACC Form Part 1 Permit# P051-R2 & R2.\iil Ver4.l 02125/2015 i YES \'ES YES YES N/A NIA NIA NIA N/A NIA N/A. ···························· NIA N/ A N/A NIA I NIA NIA NIA NI A NIA N/ A NIA NIA NIA NIA NiA , NIA NIA NIA NIA NIA NIA ••••••••••••• . . nun~• NII, NI A NI A NIA Page 8 of 144 EPA Inspection Report - Page 728 of 1969 ·-rs?. . . . Version 02.25J5 11 T-0107 NO [ NO i I NO NIA YES ~;t. · · · · ~~ . . 1. . . . . . . . I t.....IJJit·=J ~g :g ~§··l , L. .~f.:tHi~ I ~g ~g ~§ l ! 1········~;t : r~~ NIA YES ··················+ NIA ........................ NIA NIA NOc.........f.•••...••••• c...... +··· ....... NO .J T-0420 T-0423 T-0431 T-0432 T-0433 T-0434 ------------..----T-0435 T-0437 I i I 0 0 8 ~ ...... OJ (!) I . NO NO NO NO I NO NO NO NO NO NO NO NO NO NO NO NQ NO NO NO NO NO NO . NO , NO NO NO NO NO l NO NO l NO l NO NO NO NO ' NO NO YES NO NO T-0438 NO T-0439 NO NO T-0446 I T-0447 .....i... ... No .. , T-0448 I NO 11 NO ................,...,. +-- NIA NIA N/A YES YES YES YES YES YES YES YES \'ES YES YES YES N/A NiA NIA N/A N/A N/A NiA NiA J l YES 1~;x·······i · · · {~§ L :~~~ ····+···· ;;_~ J~Q········+····· ~~ YES YES L,,,,, _ X.1:l_§__ ···+············t]~··················••..i L NO -----·····~g--- i ·••••·······~~.. I ~g . ~§- r···········~~~ ! NO 1" ~.~. . l :g : N NIA NIA NI l NIA NIA NI I NIA ~~ ! ~~ NIA 'A T-0405 . N; NIA NIA T-0409 T-0410 T-0411 T-0412 T-0413 T-0415 'f.. 0417 T-0418.... T-0419 . NiA NIA NiA NIA N/A NIA I l NIA NIA NIA NiA NI A I YES YES YES i! NQ....... NO NO YES YES NO N/A l ~~ NO .t'./Q .L. . . . . ~E2 YES YES 1'ES NIA NIA N/A N/A l YES NO NO NO NIA ! ·-····~~·o··········r······· 1 N, N/A NiA N/A • NO ! \'ES NO t~. j NQ NO NO . YES NO NO I [j~.Q:::J ·.:·:···.·.•.••.•.t.~+i~ _ijg 1 1.·.·.~ . .<.~.:.I.~.:. , ..... YES )7??. . J l1 ~9 ..........._?Jo ......... NO NO . YES NO YES NO ......................... ······································ YES NO .......................... YES NO YES I NO NO I NO NO NO NO NO NO NO NO NO NO NO NO NO NO ::t::::~B.] . NO l i NO NO n~·•••••"•"•"-'""'"·· NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO NO NO YES i NO • NO j NO YES YES YES N/A LNO J. .,,No i NO j '' NIA N/A NIA NIA NIA NIA NIA NO NO NO NO N/A N/A YES NIA NIA NQ t51~6 +~b I :g l ~ ACC Fonn Part 1 Permit# P051-R2 & R.2M l Ver 4.1 02/25/2015 NO YES NIA NIA NO NO NO NO NO NO NO NO NO NO NO NO NO YES YES YES YES NO NO Page 9 of 144 EPA Inspection Report - Page 729 of 1969 Version 0225.15 r=::::r~_iE~2·····1··N'.9J=J~oJ:·No1·· ~§ . ~;~ ·············t·•···· ~~~ i T-0465 i NO NO I NO NO !i N/A i NO NO I NO NO YES NO NO YES . N/A 8:fflil~ ~~ , filg=~~ i T-0468 l I~Q(SQQ I T-0737 j t!Q i NO ;tiQ NO LI j 1 NIA i . NO 1 '{ES NIA L.. :LQ.ill..J~C:illi:+.-2'.]]l;._l_:J'li.A . T-0839 ! NO i NO i NO · ~gJ I NO i N/A -t-- NO I NO i NO NO NO i NO NO YES NIA ' NO NIA -----,--~ NQ NIA . YES NIA 1 L.! NO NO NO___ YES + NO _NO YES : No a •- NQ_ i NO NO NO i NO NO NO \ NO NO YES I NO---;NO NO . .. YES YES NO NO YES NO NO ---- NO N/A . NO . NI A NI A NIA • ., NO NO. NO NO NO ·····t~············· ············t~·······-----=:::i11}--==-te······: YES YES NO - ; - - N o NO NO N/A NO -~ i ~ YES • NIA ! NO Yll.~ t • NO YE~ ____ ::::::••l I NLA . . . . . . NIA l. . . ~~:: : :1-l ------~g---------...: -: .~: : : :~~~-~g--------l. . . . . . . ~g. . . . . . . I ::'.! L ~g C11~; . ~§·············· ··· LNiA I J ~§-------·· NIA til~r:::F::~§··. -~g--]::::Wlr ·:::::::::¥Fi:::~::=_:;___ --fit-----------4~1--- ----~t------- i T-0835 • NO r NO NO ::'.! t!!A-.........,.~---- N(~--- .• NIA ~~ •-BlA_ _ _. J. . . . NIA L ! NO N() NO , NO NO i ~i1;gJ ;gt.-E~=r~~it+_j_ ~=1f-~i[i~f1 NO i -----------------------------•--· N/A NO 1 ' • N O = ~ INO -----~e:::··::::r::::-------~r---- -----tg·. N/A NIA NIA NIA YES YES YES _____________ .::::f.{.o. NO NO NO NO .. - I :· NO . NO T>10 : N<) ... ! NO r· ~g · · · · · · · · · · · n§····-~··±-·~@ ::j NO • NO • ! r NOi . I z :r0 01 ..... (!) 0 ACC Form Part l Penn.it# P051-R2 & R2Ml Ver4.1 02/25/2015 i NQj "Tl 0 0 0 0 • !'i RL0-8 [ CBO/Lc6·i\11ckL~~dhiiRack • Railcar Loading &cQff-1,oadin_g Rack .......................................................... J I -" I MACT YES L ················-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·--------............... · · · · · · · · - - · · · · · -........................... . cc~ 20.2.37,~~?~t:; NO NO """ NO NO NO MACT BBBBBB f NO NO NO L i crg::i~ctc"" NO NO - "" NQ·-··- :::: . NO )~'.<:?. . . NO Table 103.E, Summary Applicability - li~_aters and Boilers Unitm Description B-0007 B-0008 B-0009 Boiler 7 Boiler 8 Boiler 9 Unit 13 Naphtha Splitter Reboiler Unit 21 Vacuum Unit Heater Unit 06 HDS Reboiler H-0009 H-0011 z 0 0 0 0 01 ...... (!) ...... NSPS YES YES I YES NO NSPS J De MACT DDDDD 20.2.33.108 NMAC 20.2.36 NMAC 'Y 1.x, YES YES I I NO NO YES Yes YES YES YES I NO YES I NSPS Ja NO NO NO YES YES NO NO NO NO NO NO YES NO NO NO YES NO 20.2.37 CAM NMAC YES YES YES YES YES NO NO NO NO YES YES NO YES NO YES YES NO YES NO NO NO YES NO YES NO YES H-0019 NO NO NO YES NO YES NO YES YES NO H-0020 South Crude Charge Heater NO NO NO 'f"ES NO YES NO YES YH:S NO Unit 21 Heater H-28 NO NO NO I NO YES NO YES I NO YES YES I NO NO NO I ···No NO ····No +···-· YES ·········;········ NO NO YES YES NO I NO NO NO I NO YES NO YES NO YES YES I NO I NO YES NO YES NO YES YES I NO YES NO YES YES NO NO I H-0030 Unit 06 Charge Heater H-0040 Unit 13 Charge He ,-·······················-············~···· ···········-··-··········-··-·· H-0303 Unit 05 Charge Heater H-0312 I Unit 10 FCC Feed Heater Unit 70 CCR Refonner H-0352 Heater :r0 NSPS Db NO H-0028 "Tl D South Crude Charge Heater H-0018 I NSPS I • 1 ~6 +~6 ,_X!l~t:g+~~ . . . . . j. . . . . . . :6 · · . ,. . . . I:. . . . . . .~ . . . . . . . . _J_ -~~ ····-·········-······ :6 : • YES ............ YES 1I YES YES I H-0353 Unit 70 CCR Reformer Heater NO NO H-0354 Unit 70 CCR Reformer Heater NO NO NO YES NO H-0355 Unit 70 Stabilizer Reboiler Heater NO NO NO YES NO YES NO YES YES H-0362 Unit 70 CCR Heater NO NO NO YES NO YES NO YES YES ·····················································........................f..... H-0363 ;·-······················l-················ ............,... .. Unit 70 CCR Heater ACC Forni Part 1 Perm.it# P051-R2 & R2Ml Ver 4J 02/25/2015 NO NO NO I YES I ! ......... .,....-t,... NO ...................+.. NO NO ·····························.-,,,,,.. . ., YES YES Page 11 of 144 NO EPA Inspection Report - Page 731 of 1969 Version 02.25.15 I H-0364 Unit 70 CCR Heater NO NO NO YES NO YES NO YES YES NO H-0421 Unit 44 Charge Heater NO NO NO YES NO YES NO YES YES NO H-0464 SRU Hot Oil Heater NO NO YES YES NO NO NO YES YES NO H-0473 SRUl and SRU2 Tail Gas Incinerator NO NO NO "i:'ES NO NO NO YES YES NO .H-0600 Unii 09 Deprnpanizer Reboikr Heater NO NO YES NO YES YES NO H~060! Unit 33 Charge Heater NO NO NO YES NO YES YES NO H-2421 Unit 45 Charge Heater NO NO NO "'[ES NO YES NO YES YES NO H-8801/ H-8802 Unit 63 Hydrogen Plant NO NO NO YES NO YES YES YES YES NO YES NO YES YES NO NO YES YES NO YES NO Reformer H-3402 Unit 34 Hydrocrn.cker Reboiler 1 NO NO NO NO YES H-3403 Hydrocracker Reactor Charge Heater NO NO NO NO YES H-9851 Unit 64 Hydrogen Plant Reformer NO NO NO NO YES YES YES YES H-2501 Unii 25 ROSE@ Unit No.2 Hot Oil Heater NO YES NO NO YES YES YES YES H-3101 (formerly SRU3HOH) SRU3 Hot Oil Heater NO NO NO NO YES NO NO YES YES NO SRU3-TGI SRU3 Tail Gas Incinerator NO NO NO NO YES NO NO YES YES NO ' I "Tl z :r0 0 0 0 0 01 ...... (!) N ACC Fonn Part 1 Permit# P05 l-R2 & R2Ml Ver4.l 02/25/2015 Page 12 of 144 '1 I EPA Inspection Report - Page 732 of 1969 Version 02.25,15 ..........~................ ··················· ,·-------------------- ................................. ,..---------------------------------····························· ·············· Table~~3.F, Su:ry • l (,.__._._._.._ •••••••••••••••·""····· TCC Cooling Tower S. Alky Cooling Tower (Marley j Y-0002 i i •••••••••••••••••••••••••··f i Y-0008 Appli•:::•lin~T•:~rs Cooline Tower) North Alky Cooling Tower ••••••••••••••··-· ·---~·-············-···--•~ Y-0012 l H;~!:an~:~~;:wer ~--········· •••••••••••••••••••••••••••••••••• • CT TT-0006 M~CTQ ~A_q~L_~CA~L.. : YES 1 YES • • YES YES -+=~ I T-0836 T-0897 ............................................ • \ YES YES YES YES YES YES YES YES YES . NO • ·····················i- ···························································-~ ccccccccc.-.-.-.-.-.-.-.-.-.-.-.- L NO i ···············.·.··---------------------------------------------! ·.-----------• ............, ...... + YES YES YES YES YES NO NO l:---1 -~~ l Table 103.G, Smnm~t..Y...~.£!!~.?~ill!I=~~~!~~?ter i Emission Point MACT CC 1..... Efr;~e~~---···•·········o~(i"g~;ci"g30·................. W.~~ri§~t.~~ N,~§~ F'F DAJ,'-0896 DAF-0806 • • NO '"""""''~"""'-"'"·····- NO····················· .. . ·· cccccccc.-.-.j.-.-,.-.-.-.-.-.-.- YES ..................... ------· DAF-0896 . DAF-0806 T-0801 T-0805 T-0829 • """ · · ·······- ·····ygf·····················t ••••••••••••••f ...... ••••••••••••••••••••••· Unit 07 Amine W-0745 Cooling Tower ! 1 NSP~E~~------· ..... l C~i NO NO NO NO NO NO NO NO NO NO NO NO NO NO ············································-,-- -----------------------------,- l~~T • Table 103.H, Summarv A ary Applicability - FCC-CCR '. ! Unit ID FCCREGEN • NSPSJ •• NS~Ja YES ........... I ' CAM ' .YES·-···-, Satisfied by MACTUUU I ccR NIA \-NIA 1 YEs NIA NO I "Tl z :r0 0 0 0 0 01 ..... (!) (,) ACC Fom1 Part l Permit # P051-R2 & R2M l Ver4.1 02/25/2015 Page 13 ofl 44 EPA Inspection Report - Page 733 of 1969 Version 02,25, 15 -SRU Table Sou:rcc N§P§ Enlission Point ID H~0473 ID SR!Jl NSPS MACT 20.2.36.113.A(l){d) & CA.'vl YES~Satisfied byMACTUUU Gas lndncrator SRU2 H-0473 SRUl and SRU2 Tail Gas Incinerator YES NO YES YES SRU3 SRU3-TGI SRU3 Tail Gas Incinerator NO YES YES YES YES YES NO YES NO YES-Satisfied byMACTUUU byMACTUUU ccccccccccccccc Tabfo 103.J, Summary A UcaMlity - Engines. 20.2JH.114 NMAC CATV[ YES YES NO ..-,...·········--·················----·····••c.c.c. ...c.;, ......._ _- - - - i 20.2.61.109 ~~11rce ID _J E-0600W NJMAC DesctIPJi.~I.!-....................... ....! ......~.§?.~UH L Fire Wat~t?:i:11:1:?P?!::gine ·····•·················.•.•.•.•.•.•.•.•.•.•.•.•.•.-.........................- Fire Water Pump Engine E-0601TVI Y~ TIS YES YES YES YES ! ····+·· I E-0602E Fire \Vater Pump Engine E~0603 Fire \Vater Pump Engine YES YES YES YES E~0901 Fire \Vater Pump Engine YES YES YES YES G-0100 UPS backup generator NO YES YES '{ES NO G-0101 UPS back-up generator NO YES YES YES NO YES YES YES YES NO NO E-8010 I ' NO Portable Air -r :-;;nr YES Portable Air ·r- -1,r YES YES YES Portable Air Compressor YES YES YES YES NO YES YES YES YES NO \%/WT? Emergency Engine ( I "Tl z :r0 0 0 0 0 01 ...... (!) .i:,,. ACC form Part 1 Permit# P051-R2 & R2M1 Ver4,1 02/25/2015 Page 14 of 144 EPA Inspection Report - Page 734 of 1969 Version 02.25.15 -------------------------------------------- .• Tabl2 !9~~~ ~0111rnary Applicahility. -FLARES, ·--································---···········--······--········---···-············---························ . • , ! l ······I FIA02 FIA03 • FL-404 FCCU flare A1ky Flare GOHT Flare NO NO NO NO YES YES YES YES YES YES \'ES . : NO NO NO ~ - - ~ - - - - - - - ~ - - - ~ - - - - - - < - - - - - - - - - · • " - " ' " " "_ _ ......................,,................- -................________ --------~ . 20,236,113b Ni:~~11rfa;e ···~iti 6 l·I!~I1·J,,,,+---~~fl11····""'' ' ' ' ' ' 'N1r·········-~---~!v~I i 1 N.ESHAP A YES YES YES "l'FS i YES YES YES YES j i j I ; I I 1{L2,J7,201B . N~~~c ··········-!···· N~~~c 7 i : · T · \ES I -YES ....................... ................................................ YES I YES . YES YES j YES YES : ~ i I ,C _ _ _ _~ - - - - - ' - - - - c c ~ c c c c c c c c c c c c c . · · · ~ - - - - - All fiares are steam assisted. . State ofNew Mexico requires that an exit gas velocity of65 ft/sec for modeling._ • The heatinz value of the gas for all flares is< 1000 BTU!scf --=----------···· ....................... . ........... : ....._._................._._._...... '7.•: .. ___ ........................................................................................................................................................................................................................................................................................................·.·························································~---------------~-------···· ------------------------------ -----------"·""""""""""""'~"""-""""'"" .... 1 . i A103 I 1 , , , , --------------------; ---------- .--------- ----------' . -----------------' .- •----------------------7: _-----~ --~- -- •-,. ---------_, ---------------------------------, Facility: Applicable Regulatmm , _. M. Complrnnce w1th the tenns and conditions of this permit regarding source emissions and operation demonstrate compliance with national ambient air quality standards specified at 40 CFR 50, which were applicable at the time air dispersion modeling was perfonned for the fadlitv's NSR Permit 0195-M35. · A104 Facility: Regulated Sources I "Tl A. Table 104,A lists the emission units authorized for this facility, Emission units identified as insignificant or trivial activities (as defined in 202, 70, 7 NMAC) and/or equipment not regulated pursuant to the Act are not included, z :r0 0 0 0 0 01 ..... (!) 01 ACC Fonn Part l Permit# P05 J-R2 & R2M! Ver4.1 02/25i2015 1 This perrmt cond1t10n prov Ide:-; a 11::,t ot the I applicable requirements that are addressed in detail I in other permit conditions but does not impose any specific standards, monitoring, record.keeping, or I reporting requirements, Therefore, no further I response is required_ As instructed by the AQB, Navajo is completing the check box responses in columns 3, 4, an:r.i§S.....·.·.····················································· 1 Varies Varies · · - - ; _.................. . i . r seriaf~~1mbern are not used since most equipment consists of field e;;;t; ·•······ ........~............... "Tl J?:QMMI:l.!u,ibLtbl:N Qs:1;;.is) ! i ! GOHT Flare ···································T···FccK·Nfcooiin~··to;;;;;;;··· i Q\)!3-l,dl(vD[Jiumers CCc1! Unknown burners Unknown .LJBD · 2009' . l 1 -·-········································ ················"!"··································· F,L:Qqg3, A_lliy__EI@[§ FL-0404, GOHT Flare . CUBL-iO'N burners ... : LE-CSG-12W burners • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • n n , ~ - - - - - - - - - - - , .• SRU3 Tall Gas Incinerator I FCC Re,;enerator Scrubber 120 MMBtul!}LLhdYBs:1;;.i;;;L j Page 18 of 144 EPA Inspection Report - Page 738 of 1969 Version 02.25.15 ~------------------------------------ -----------------------------------·« «•••• a whole is typically identified by our equipment number. There may also be a "project number" or ''job number" from the manufacturer, but that can change if a heater is revamped at a later date such as when they modify the convection section to improve energy efficiency. A105 Facility: Control Methods A. Table 105.A lists all the pollution control equipment required for this i facility. Each emission point is identified by the same number that was assigned to it in the permit application. I This pe1mit condition provides a list but does not impose any standards, monitoring, record.keeping, or reporting requirements. Therefore, no further response is required. As instructed by the AQB, Navajo is completing the check box responses in columns 3, 4, and 5 of this form. Navajo continues to comply with all applicable requirements except for specific deviations as noted elsewhere in this document. (See the specific responses to the permit conditions that contain standards, monitoring, record.keeping, or reporting requirements for more information}. D Continuous f2J Yes 0Yes r2J Intermittent 0.No [2J No I Table 105.A: Control Methods: I Control Equipment Unit No. Control Description FCC Regenerator Scrubber Fluid Catalytic Cracking Unit Regenerator Cyclones + Wet Gas Scrubber CHLORSORB@ CCR Regenerator Vent Control FL-0400 FL-0401 Pollutant being controlled Control for Unit Number(s) 1 PM&S02 FCC Regenerator NO Chloride CCR Regenerator Vent North Plant Flare NO VOC&H2S Refinery process units South Plant Flare NO VOC&IhS Refinery process units BACT Yes or No NO I "Tl z :r0 0 0 0 0 01 ...... (!) (!) l ACC Form Part 1 Permit# P051-R2 & R2Ml Ver 4.1 02/25/2015 '' ""'""~- Page 19 of 144 """"""""""-~~~UN EPA Inspection Report - Page 739 of 1969 Version 0225,15 FL-0402 FCC Flare NO VOC&H2S Refinery process units FL-0403 Alky Flare NO voe Refinery process units FL-0404 GOH Flare NO VOC&H2S Refinery process units ,,,,,,,~--------------------- Portable Flare for Holly Energy Partners (HEP) Pipeline Pigging Operations I NO voe Pipeline Pig0ring Operations Sulfur Recovery Units No. 1 & 2 TaH Gas Incinerator NO Sulfur SRUl and SRU2 SCR Selective Catalytic Reduction + ultra-low NOx burners YES NOx H-9851 SRU3-TG1 Sulfur Recovery Unit No. 3 Tail Gas Incinerator YES Sulfur SRU3 SRU3/TGTU3/TG13 Best \Vork Practices, A207 .B (BAGI') YES S02 SRU3 D-0829/0830 Main API Carbon Canisters NO voe MAINAPI YES PM Y-0011, Y0012 YES voe T-0737, T-1225 FL-HEP-PORT i i -------~..--................---........................................ ·············· H-0473 Y-0011, Y-0012 Drift Eliminators on Cooling Towers I 'i I "Tl z :r0 0 0 0 0 01 N 0 0 T-0737, T-1225 External Floating Roofs (BACT) l I --~~~-.-... ACC form Part l Pcrmit#P051-R2 & R2M1 Ver4,l 02/25/2015 Page 20 of 144 EPA Inspection Report - Page 740 of 1969 Version 0225. 15 See Tab1es 106,B(i) and (2) External and Internal floating Roofs (NoneBACT) NO voe See Tables 106,BO) and (2) B-0009 Energy Efficiency, A204.N (BACT) Yes Greenhouse Gases B-0009 H-2501, H-3402, H3101 ultra-low NOx bumcrs (BACT) Yes NOx H-2501, H3402, H-3101 SRU-TGI, H-2501, H-3402, H-3101 Comhust gaseous fuels only Yes VOC,PM SRU-TGI, H2501, H-3402, H-3101 1 R to a unit number the Regulated Eqoipment List In accordance with the requirement that Navajo Refining prevent exceedances of the 24-hour and 3-hour National Ambient Air Quality Standards (NAAQS) for S02 during major refinery malfunctions, Navajo Refining shall only flare acid gas from existing Flare FL-0403 according to Navajo Re:fini11g1s !!Phase Two" plan dated January 5, 1996 and received by the Department 011 January 8, 1996, or from flare FL-0400, Navajo shall undertake the following measures for acid gas flaring from FL-0400 and FL-0403. CHART NO. 1 SUPP FUEL FOR 302 NAAQS COMPUANCE, fl.-400 6M ··················'·······································'···········,..-'"·'··· ~-10.0 ~ 60.0 ~ 50.0 ;;:'. 40.0 ,.................... ,.................. ,.,,.· .............•...................;. ..................,....................;. ............... . ;" 30.0 •··········· ,,,.,_ .......•................. , ................, ............, ................ ,.......... .• 1'; 20.0 <( 10.0 f IO 30 20 S;.:pp I "Tl z :r0 0 0 0 0 01 N 0 ..... 40 60 60 10 ~ul'3: Gasf!ow {Msdh} (1) Existing Flare FL-0400 shall be equipped with a flare tip or burners to supply supplemental fuel gas to provide enough heal to supp1eme11t the heat released by combustion of the acid gas itself and the heat provided by smoke-suppressing steam. The minimum flow rate ot supplemental fuet gas to he supplied during acid gas flaring such that compliance with the NAAQS fiJr S02 is assured shall be determined using Chart No. 1. The fuel gas used for this purpose shall be natural gas (sec definition at Cl 01,1::2:«««<«<<<<< /\CC Form Part 1 Pennit # P051-R2 & R2M1 Ver 4J 02/25/2015 Page 21 of 144 EPA Inspection Report - Page 741 of 1969 Version 02.25.15 (2) Existing Flare FL-0403 shall be equipped with a flare tip or burners to supply supplemental fuel gas to provide enough supplementa1 heat The volume of supplemental fuel gas to be provided to generate enough supplemental heat to ensure compliance with NAAQS for S02 shall be determined using Chart No. 2. The supplemental heat to be provided when flaring the maximum quantity of acid gas has been determined to be 52.9 million BTU per hour which is generated by buming 96,200 SCFH of supplemental fuel gas. This assumption has been made to ensure compliance with the NAAQS for S02. The fue] gas used for this purpose shall be natural gas (see definition at ClOLF). CHART NO. 2 SUPP. FUEL FOR S02 NAAQS COMPLIANCE, FL-403 4(J ·•.················ f35 Mso ;25 , . . . . . . . . , . . . . . . . . . i! [20 !1s II ~10 Is 0 C. :20 40 50 Supp. Fuel Gas (Thousand SCfH) 80 100 Beginning December 20, 2001 no fuel oil shall be burned in combustion units except as frlllows: (CD ,17.C) (1) Torch Oil may be burned in the FCC Regenerator during FCC start-ups; and. (2) Fue1 Oil may be burned in combustion units after the establishment of FCC NOx emissions limits pursuant to permit condition Al 10.A, provided that emissions from any such combustion units are routed through the FCC Wet Gas Scmbber and Navajo demonstrates, with the approval of EPA, that the NOx emissions limits contained therein and the S0:2 emissions limits stated in A106.A and A107,A will continue to be met. D. The Artesia Refinery FCC was initially limited to less than 20,000 BPD capacity. FoHowing the December 2003 expansion of the Artesia refinery's FCC as authorized by permit 195-M:15, the catalyst regenerator for the FCC is subject to the minimum requirements for continuous emission monitoring and recording set forth in Appendix P to 40 CFR Part 51, Consent Decree Paragraph 15 required the FCC to be subject to N SPS Subpart J for opacity as of December 31, 2003. A wet gas scrubber was installed in 2003. An Alternative Monitoring Plan (AMP) request was submitted to EPA 011 December 31, 2003 because a continuous opacity monitoring system (COMS) will not v,mrk on a wet gas scrubber exhaust because of the interference from the water vapor. The AMP satisfies the requirements for both NSPS Subpart J and 40 CFR Part 51 Appendix P I "Tl z :r0 0 0 0 0 01 N 0 N i A.106 Facility: Allowable Emissions ACC Form I'art 1 I'ennit # P051-R2 & R2Ml Ver 4J 02/25/20 t 5 Navajo continues to comply with all applicable D Couu:num:rn 0Yes rgj Yes Page 22 of 144 EPA Inspection Report - Page 742 of 1969 Version 02.25,15 r A, The following Sec tion · Wits me emrnsmn units, and their allov,rable emission limits. emission limits except for specific deviations as noted elsewhere in this document and events reported per 20.2.7 NMAC. k8:J !ntennithmt ~ No D No __ for all applicable (See Table 1030A regulz ' J:;a~;~·:·;: ~owa~1.~!;,;i~~i•~~ · · · · · · · · · · · · --Ir , , , , , - - - - - -, - - - - - - - - ~ ~- - - - - - - -· ·, · . . . !~..: ,":'"' _c_~ ~. _(T'fPL·~r;i '. '';~';1 :~'o~~;" co 'N-'O_x_.-----~-------····· +~~t' ":~, I '';Td '"l'!r 1t·r,r1voe !'i!~l!,Ll~ 1 ~ ~, 11 ,~-~~ -f~:~ie~:~~!l~.t~~f!! . ~!J-tlb.~+ i1 T!J~1-·=S!- ;i~-1;J11W 9 H- · 6 .) 18 1! 56 i 7"' ' HR t!BITl?)~?.~?~:::r:.: ?~:::::::J~:--o~~,,:~,,,T:; ;:; :9i··············[ -·.- " H-0303 ·: \ 11 l 0.4 h·..-.·.············-"""""'"··---.-.-.-.-.-.-.-.-'f,~---.-.-.- \ 0.7 L2 5.2 t~::;363LO~j~;~m j !! IH-0421 :rf-0464 -=--:::::-:J iM~6~6T · · · · · · · · · · · · · 27 --------§:·§::: 1·············;§ I "Tl z :r0 0 0 0 0 01 N 0 (,) i :~··:.... /lI:: i 004" 182 r~ 1\ "97 i ,9,~ __ L j ~~-,~ . :~~ ,--~~;; 140 ;~:;--1 i 2.5 -.-.-.-.-.-.-.-.--1----.-.. LO 394 01) r: 1 . .·.········}},~,,j 2A o:?..... ·---· o.5 .... L6 . »-~:-~, , , ~ -~{~---- 10.6 J 2,3 i ~~:!-------······ LO I ... - 4.4 ::,:::_:~:~----e---- ---~-:?.. ff{j1j i ~:~ 72 1? -,-, .. , ·· ·- '.L 0,6 lU 0.1 -·-·-·-·-·-·-·-·-·-·-·-·-·-·-·--··----------·--········-,---······ 0J)9 ]'1 03 03 LO 02 4-5 0.7 LO . 3,03 2.8 I=~~=~!~-! II; 1T~i~-;)~L,~$iitt . ~~~·1·8} l :~~ i ~:: ACC Form Part 1 Permit# P051-R2 & R2M1 Ver4J 02/25/2015 i ''''''"~~: 1 I ::~ . L 1~; ~to1 1 !-~:~§~-------~ . . ;\6.. . 33 0.4 ·······t···· ~~-~ 0.9 · !-·~·:~: ~~~ I ~:~ 1-------~: 0.7 0.7 0.3 3.1 2.0 8,8 1.4 ~L+~ 02 0.8 0.1 03 Page 23 of 144 EPA Inspection Report - Page 743 of 1969 Version 02.25,15 H-0473 (SRUl/SRU2 TGl) isri.uj>fdi !FCC Reucneratm >----······--"' iFL-0400, North :Plant Flare NA 30J) 81,8 6.5 28.5 NIA 27.7 121-2 0.5 2.2 0.1 0.6 NA 3CUJ 6.5 35.0 28.5 101.9 65.7 106.8 0.5 25.0 2.2 109.5 (),6 NIA 15.0 121.9 0.1 27.9 8L8 6LO NIA NA 0.2 0.5 0.2 0.8 Nii\ LO 4.3 OJl 0.0 0.2 0.7 NA NA l~i~~~l;~.~o~::h········ 'FL-0402, FCC Flare FL-0403, Alley Flare FL-0404, GOHT ! . 1 Flare 1Suhtotai Tanks, .'able 106.E Fugitives, Table 106,F Misc Somces, Table 106.G Cooling Towers, Table 106.H Oi1W s"':~'"°''tr,rn 'able 106.I 0 SSM, Table 107 TOTAL 1 NA NA NA ............... (U 0.1 'P'""''"p.k High Vapor !-lrP•S:,S:,'1irP" 1LOJ 11.01 High Vaporµ,."'."""'""'" 11.0 , High Vapor l LO High Vapor 1 LO Liquids in lower volatility categories may also be stored (i.e., tanks allo,vcd to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allmved to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). High Vapor Pressure Liquids indude: Crude, Naphtha (raw or treated), Unleaded Gasolines (sob-grade, regular, premium, and other blends), Alkylate, Refonnate, FCC Gasoline, Ethanol, Isomerate, Straight Run Gasoline, and other refinery foedstocks, intermediates products byproducts, and wastes having a max vapor pressure of 11 psia or less under actual storage conditions. I I l 1 1 i ~----------------------------------------••« «•«««<<• ACC Form Part 1 Permit# P051-R2 & R2M1 Ver 4.1 02/25/2015 -----------------------~· J Page 25 of 144 EPA Inspection Report - Page 745 of 1969 Version 0225J5 EXTERT'1AL FLOATING ROOF STORAGE TA.t""iKS TABLE 106.3{2} VAPOR PRESSURE LIMITATIONS FOR REFINERYNON-COJ\,IBUSTION SOURCES or VOLATILE ORGA.t'\JIC COMPOUNDS (VOC) . . . . . . . . • • • • • • • • n n . • • • • • s s , ~ - . - . - . _______ _ Tank No, , Typical Liquid Most Vohl.tile Category of Allowable Liquids to be Sto.red 1 : Stored Max Vapor .Presim.re (psia) of lVfost Vo!atik Liquid at Max Tempo :i i.,.,p11t1,,,,. l'"...J .;.;.;.;.;.;.;.;.;....••................................. ! ........ Note:i. Calculation method and factors per AP-42, Section 5-2, dated June 2008a Controlled emission rate. The previous controlled rale ,vas set by the terms of the consent agreement between Navajo Refining Co. and the DepartJ.nent executed January 28, 1994. The agreement required that the incinerator have a minimum 90% destruction efficiency for gasoline loading and a minimum 80% destruction efficiency for diesel fuel loading or fo! A fuel loading. This was achieved by a vapor combustor. This device has since: been replaced with a carbon adsorption system compliant with MACT Subpart R, as subject per .\1IACT Subpart CC Emission limits changed i.n 195-l\11-17 to correspond to Titk V pcm1it values. .... COOLL.'\/G TOWERS Table 106,H EMISSION LIM]TS FOR REFINERY NON-COMBliSTION SOT.TR.CE§ OF VOLATILE PM Source lD VOC lb/hr Y-0001 Y-0002 --------------------------- ----Y-0008a L8 1.8 i Subtotal (for informational !_ ..PX1T'?J~~.. 9?b:.l, _ _ _ VOC PM PM CO CO 7.9 0.3 L2 7.9 0.3 12 1------------------------------------------------i-------------------------------,-----------------------------------------------s------------+·-....................... ___ .. ____,__, 6.5 1,3 OA 28.3 5,5 1.8 Ll 123 4.7 56J 0.7 0.5 2.9 23 0.8 fl7 02 02 2J 0.58 2.54 9J Y-0008 cooling tmver provides 100%1 control of any NH3 emissions from V-H2 and V-H2-2. Unit 64, Hydrogen Plant has de-aerator Ene that has dissolved CO that is connected to the cooling tower, a ,------------------------- ----------------------- ............................~u1ori1,vAT"i:1i"s-irARAT0Rs IGT~"s'y~~·L 1 i Table 106.l EMISSION LIMITS FOR .RE!'INERY NON-COMBUSTION SOURCES OF VOLATILE ; Equipment : Em1ss1on Pomt ! IJQ • !D "'Tl i : :r0 •- MA!N AP! • D-0829/0830 I z 0 0 0 0 01 N ...... ...... De~gciE!i2EL Above Ground AP! Oil-Water Separators and enclosed drain system. ACC Fom1 Part t Permit# P051-R2 & R2Ml Ver 4. l 02/2512015 I H~~~~~~::~s~~ Emission , ! . Em1ss1on 3§!~f1~£brt....,.._R.§]QJt?_Q_§(Y..r.L ;, J. PM10 ---- Cooling towers, Units Y-0011 11 Navajo continues to comply with aH applicable and Y-0012, sha11 be equipped with high- emission limits except for specific deviations as efficiency drif1 eliminators to reduce l noted elsewh~Te in thls document and events PM10 emissions. Demonstration of I reported per 202. 7 NlVIAC, compliance is through annual inspection in accordance with in Condition A212,R AJ 07 Facility: Allowable Startup, Shutdmvn, & l\!lai:nte:nance (SSM) and M_aifunctio:n Emissions A. The maximum allowable SSM and Malfunction emissions limits for this facility are listed in Table 107.A and were relied upon by the Department to determine compfo:mce with applicable 0Yes l ~ Intermittent D No !6J No D Continuous D Yes rsJ Yes [8'.] Intermittent [8'.] No 0No Navajo continues to comply with all applicable emission limits except for specific deviations as noted elsewhere i.n this document and events reported per 20.2.7 NMAC regulations. -----~ ------------ --------------------········-'- Table 107,A: Allowable SSM and l\!falfundion Units, Activities, and Emission Limits 1 i ~···--··················- ! r···~nit ... ---------------------------: $$jlllJ::?851 ! SSM T-0737 I "Tl z :r0 0 0 0 0 01 N ...... 01 ---------------.,------------·------·-·---------~l---t~;°P/PM10/PM2. co NQx _r::R;i0.~iP.t.l0.J?fEmissions pp-h-- I Emissions durinq SCR .99Y!U!iDJf!: _; Emissions from roof landing --- : :: • SSM Misc 1 • Emissions from cata! st handEn · i -------------------------------------------,- c::::iiii :1 ppry 1.2 20.2 JQ:L j 'I pp~ 2.~ ~......2.:.9 J - r !e"x. ....ie.h···---r----iii:::::: - pph voe 1 5 0.2_ _____________ ?:13.~I [ : -- • -- -- SSM~RU3-l}!j J~~=,;~sRu!~;,;;;;;~;~d - r 55=r~;;:;-=;;~~ ~ - ~ <0.1 I- SSM T-OO?B · ;e~i,f~:ons from roof landing and tank __J ACC Form Part 1 Permit# P051-R2 & R2Ml Ver 4.1 02i25/2fH 5 __ 0.3 l~.:9.... __Q&...... ________________ ---L.... 1.5 I J Jl heaters ,vere within aHowable emission limits. Testing was performed as follows: H-0019 02/20/2019 Yes ~.No H-0020 02/20/2019 H-0362 02/14/2019 H-0363 02/14/2019 H-0364 02/14/2019 H-2421 04/18/2019 H-3402 ?2115!2019 H-3403 02/14/2019 AU heaters were within allowable emission limits. I Periodic emission test results are maintai • ACC Form Part 1 Permit# P051-R2 & R2Ml Ver 4J 02/25/2015 rs:] Intermittent 7/30/2019 Monitoring: The pennHtee shall conduct annual periodic portable analyzer emission tests or EPA Reference Method Tests for NOx and CO. 0Yes II Navajo submited MACT Subpart DDDDD reports semiannually as fr)Uows: 1/30/2019 A204 Heaters/Boilers B. Periodic Emissions Tests (Units Heaters H-0019, H-0020, H-0362, H0363, H-0364, H~2421, H-3402, and H3403) ~ Yes D Continuous Reporting: The permittee shall report in accordance with Section B110, uu••••••uccc,--------, ··------------------------------------------~.. •••uu~n D Continuous ! 2s] Yes 0Yes .uu>"NNN~ Page 67 of 144 EPA Inspection Report - Page 787 of 1969 Version 02.25. 15 ~--------------------------.....--------·""" --""""""" emission tests shall include the How rate Navajo Emimnrnental Department. I and the stack gas exhaust temperature_ If a combustion analyzer is used to measure NOx, CO, andior e~cess air in the fiue gas, ' records shall be kept of the make and model of the instrument and instrument calibration data. If an ORSAT apparatus or other gas absorption analyzer is used, the pen11ittee shall record all calibration results. Records shall be kept of all raw data used to detennine :flue gas :flow and of all calculations used to determine :flow rates and emission rates. The permittee shall maintain records in accordance with [8'.] Intermittent f D No [8'.] No ' • Section Bl09, BUO, and B11 L "-""""""""-i·""""""""· · · · · · · · · · · · · · · · · · · · · · · · · · · · -·-·-·-·-·-·-·- - - ~- - - - Reporting: The permittee shall summarize in tabular fom1 the results of the initial or subsequent periodic I emrns1ons tests for NOx and CO. I specifying the mass emissions rates i~ All testing reports wt.Ye submitted to the NMED at I pounds per hour- The table shaH include . I the average concentration of aU relevant [ poUutant species. The pe1111ittee shall i report in accordance with Section Bl09, B110, and Bll L I 1 . . . . . . ···········1 D Continuous ~ Yes 0Yes rsl Intermittent D No rgj No l D Yes rgJ Yes ~No 0No I I l A204 Heaters/Boilers C. Summary of Compliance Methods for Heaters and Boilers for Table 106,A, 20233 NMAC, 202,37 NMAC (Boilers and Heaters in Tables 103,E and 104.A) I [g] Continuous I kSJ Intermittent Navajo complies with these requirements, except for deviations previously reported or identified at the end of this report. Requirement: (NSR 0195M35, I "Tl z Condition A204,B) :r0 0 0 0 0 01 N .i:,,. OJ ACC Form Part 1 Permit# P05 l ~R2 & R2M l Vcr4J 02i25/201.5 Page 68 of 144 EPA Inspection Report - Page 788 of 1969 Vernion 02.25-15 (1) Demonstrate compliance v.rith Table 106,A Allowable Emissions. (2) 202.33 NMAC (Gas Burning Equipment~ Nitrogen Dioxide, 10/31/02) , applies to existing and new gas burning equipment having a heat input of greater than 1,OOOJJOO million British Thermal Units per year. It applies to process heaters identified in Tables 103,E and 104,A These unJts sha11 be equipped with burners emitting less than 0.2 lb NOx per MM Btu, Compliance with 202.33 NMAC is demonstrated by compliance with the NOx lb per MM Btu hrnits in Table Al 06.A. lvfonitoring: (1) The permittee shall monitor the fuel usage of the all boilers and heaters, The fuel usage shall be monitored for specific heaters and boilers subject to 202.33 Nl\1AC, · I 1) Fud use measured by PL j I z :r0 0 0 0 0 01 N .i:,,. (!) 2sJ Continuous ! [gJ Ye1. ! 2;J Intermittent ! D No 0Yes ;gj No ! 3) Refor to response for Section A 100.A (2) For specific heaters and boilers subject to 202.33 NMAC, the permittee shall col1ec1 and analyze samples of ihe refinery fuel gas at least once per week The refinery fuel gas ana1ysis shall include the composition of the refinery fheI gas, the 5>ross heating value, and the net heating value. "Tl ' 2) Refinery fuel gas is analyzed at least once per week 4) No combustion sources fire only purchased gm;, 5) The following combustion sources have CMS that axe recertified annually as follows: B-0007 03/19i2019 B-0008 03/19/2019 B-0009 03/20/2019 H-9851 03/2! /2019 H-2501 02/19/2019 (3) Sec Condition A110,A for H2S monitoring requirements, 6) Test results referenced in Condition Al 04J3 _ _ ll h _1 1 '] meet this requirement. 1 11 (4J A process eaters anu om em si1au fire ~nly_ refinery_ gas in accordance with j 7) Navajo complies through Pi data. Apphcat1011, Sect1on 2, Table 2~J. 8) Navajo Refinery is no longer affected by {5} For those combustion sources re,iuired f 202.37 NMAC. This rule was repealed on I . . -----------------------------------------------------------------· ---------------------'------------»»-.-.---.-.-.-.-.-.--.--- ----------------'--------'--------"''··-······ ACC Form Part 1 Permit# P05 t-R2 & R2M1 Ver4,l 02/25/2015 Page 69 of 144 EPA Inspection Report - Page 789 of 1969 Version 0225.15 ! to have a continuous monitoring system I September 12, 2016, (CMS) (Hsted in (a) below), the pem1ittee shall install, certify, calibrate, maintain, and operate the CMS for each required poUutant in accordance with the applicable requirements of 40 CFR 60 or 63. The hourly average CMS data, the refinery fuel gas usage data, and the refinery foe1 gas cornposWon data shall he used to estimate the actual emission mtes, (a) The fi:)llowing CMS shaU be recertified annually: • Boiler B-0007 NOx and 02 CMS * Boi1er B-0008 NOx and 02 CMS • Boiler B-0009 NOx and 02 and CO2 CMS H-9851 NOx 02 CMS I • H-2501 NOx 02 CMS I • I (6) For those combustion sources required to conduct periodic stack exhaust testing as stated in Condition A204.B, the test reports shall be used to demonstrate compliance with the NOx, CO, and VOC limits in Tah1e 106.A I "Tl z :r0 0 0 0 0 01 N 01 0 (7) For those units and pollutants that are not required to have a CMS or a periodic stack test, (Units H-009, H-0011, H0018, H-0028, H-0030, H-0040, H-0303, H-0312, H-0352, H-0353, H-0354, H0355, H-0421, H-0464, H-0473, H-0600, H-0601, H-8801, H-8802, and H-3101) the permit application emission factor, the_~\:te}11sa,g_e,and_the_refinery-fu-e-l__,,,g'--a-s_L,__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .__L_ _ _ _ _ _L , __ _ _ __ ACC Form Part 1 Permit# P051~R2 & R2M1 Ver 4.1 02/25/2015 Page 70 ofl 44 EPA Inspection Report - Page 790 of 1969 Version 02.25.15 shall be used to calculate the emission rates of NOx, CO~ VOC, and Plvl (8) Compliance \Vith the particulate em1ss1011 limitation set forth in 202,37.202.A NMAC shall be . determined as specified in 20237.202D(3) NMAC. Combustion of j' only gaseous foe1 has been approved by the Department as the compliance method 1 under 20237202,D(3} NMAC. Record.keeping: The permittee shall maintain the foUowfog records: I ---------------------------------------------------------,,,,,,,,_______________.,,, ___,,,,,,,,-.,,,,,,___.,,,_____. , , , , , , , , , , , , , , , - , _ , , , , , - - - - - . , . , . + - ( 1) By March 31, the amrnal fuel usage for aU boi1ers and heaters for the previous calendar year, (2) By March 31, the average fuel composition and heating value for a11 boilers and heaters for the previous calendar year, (3) For those units required to have a CMS (B-0007, B-0008, B-0009, H-9851 and H-2501 ), the CMS hourly average data. I "Tl z :r0 0 0 0 0 01 N 01 ..... ~ Continuous ~ Yes 0Yes ~ Intermittent D No ~No 1) Fuel usage records are maintained in PL 2) Fud composition records are maintained in Pi. 3) CMS data is maintained on PL I 4) Test reports arc maintained by Navajo I Envirnmnental Department (4) For those units req u.fred to conduct periodic stack exhaust testing, the 5) The summary spreadsheet is included in the periodic test report, Emission Inventory. (5) For all boilers and heaters, a sun11nruy spreadsheet shall be maintained comparing the actual ammal emissions with the aUowab1e emission limits expressed in tons per year and lb/MMBtu. us111g the appropriate method of compliance demonstration. This ,,,~preadsheet shall be updated by March 31 ACC Form Part l Pcm1it # P051-R2 & R2M ! Ver 4.1 02i25i20l5 Page 71 ofl44 EPA Inspection Report - Page 791 of 1969 Version 0225-15 of each year for the previous calendar veaL ] -, Reportin;Thep~itt:~h: ireport~,::::accordance w1th Sect10ns B 110. necessruy. A.204 Heaters/Boiiers : ~~:::~::, : ~ : · : ~::' [gl Contbrnous D Yes [gl Yes [gl !ntennitient [gl No 0No D. Consent Decree NOx Emission Limits for Boilers B-0007, B-0008, and B-0009 (new as of 201.3) Requirement: (NSR Condition A204.C) 0195M35, (1) In accordance with the Consent Decree lodged December 20, 2001, NOx emissions from boilers B-0007 (no later than December 31, 2002), B-0008 (no later than December 31, 2003), and B. 0009 (nev,: as of 2013) shaH not exceed i the limit in Table 106.A during any hou:r1y romng 3-hour period, Demonstration of compliance with the NOx limit for B-0007, B-0008, and B0009 shall be estabHshe. D Continuous !X:l Yes 13:l Intermittent 0No Dves l3J No ,.-.-.--.-.-.-.----- A204 Heaters/Bollen ~ Continuous r8:l Yes 0Yes E. NOx Monitoring and Testing for ControHed Heaters Subject to the Consent Decree (Units H-0020, H-0352~ H-0353, H-0354, H-0600, and H-0601) rzJ Intermittent 0No ~No lV[onito.ring: 13:l Continuous ;:g:J Yes 0Yes (] ) For heaters wlth a heat input capacity I of equal to or less than 150 MMBTUihr 1 (HHV) but greater than 100 MMBTU/hr (HHV), Navajo sha11 ~ Intermittent 0No l3J No I Requirement: For the Controlled Heaters I as CMS installed and data maintained in Pi. listed in the Consent Decree, compliance with all NOx ' emfasions limits shall be demonstrated by monitoring as foHov,/s. (CD~f16.C) (NSR 0195M35, Condition A204,D) I continuous 1) H-9851 is equipped with NOx and 02 CMS that (a) install or continue to operate CMS ls certified, calibrated, maintained and operated in to measure NOx and 02 by no later accordance \vith the referenced requirements. than the date of the instal1ation of the applicable NOx Control Technology 2) Referenced heaters meet these requirements. All initial performance tests have been reported. on the heater or boiler; or I "Tl z :r0 0 0 0 0 01 N 01 .i:,,. (b) submit for EPA approval, by no 3) Referenced heaters were initially tested and are later than 60 days after the date of tested annually, H-0601 is monitored weekty usiJ1g installation of the applicable NOx a handheld portable analyzer, Control Technology on the heater or boiler, a proposal for monitoring based on operating parameters, including but not limited to, firebox temperature, air preheat temperature, I heat input rate, and combustion 02, ! -.-.-uuuuu~.-.-u~.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-. ACC Fonn Part 1 Permit# P05 l-R2 & R2Ml Ver 4-1 02125/2015 .J- •••••••••••••••••••••••••··········-.-.-.-.-.-.-~.-.-.-.-.-.- Page 74 of 144 EPA Inspection Report - Page 794 of 1969 Version 02.25.15 Navajo shall evaluate the necessity of using firebox or bridgewaH temperatures and additional operating parameters and agrees to use such parameters as a means of monitoring perfommnce where Navajo and EPA mutually-agree to their effectiveness. (CD~l 6.C.ii). As of January 23, 2014 (notarized date of application), there are no heaters or boilers at the Artesia Refinery with a capacity of equal to or less than 150 MMBTU/hr (HHV) but greater than l 00 MMBTU/hr (HHV) subject to Monitoring requirement (1 ). (2) For heaters with a heat input capacity of equal to or less than 100 MMBTU/hr of HHV, the pe1mittee shall conduct an initial performance tests for NOx. The results of these tests shall be reported based upon an average of three (3) onehour testing periods and shall be used to 1 develop representative operating I ! parameters for each unit, which will be ! ' used as indicators of compliance. (CD~l 6.C.iii). This condition applies to the following heaters: I "Tl z :r0 0 0 0 0 01 N 01 01 • Heaters H-0352, H-0353, and H-0354 • Heater H-0020 • Heaters H-0600 and H-0601 The permittee has completed all of the initial performance tests. (3) For heater H-0601 compliance shall be demonstrated by conthmously ACC Form Part 1 Permit# P051-R2 & R2Ml Ver 4.1 02/25/2015 Page 75 ofl44 EPA Inspection Report - Page 795 of 1969 Version 02-25-15 I ,_ monitoring stack oxygen {02) to maintain a 3~hour average below 6.0 voFViio As a further check of compliance, Navajo shaJ] monitor stack NOx at least twice a month using a portable analyzer to assure that the rneasured NOx value does not exceed the compliance threshold of 38 ppmv NOx. ~J2_:Ciil} liSI Continuous Recordkeepiug: (1) The permittee shall keep records of the Fuel firing rates and Sulfur limits monitored for Condition A 11 Cl.A. j F. NOx Monitoring and Testing for Heaters permitted after the Consent Decree (Units Heaters H-0019, H~0362, HAH63, H-0364, H-2421, H-3402, H3403, H-2501, H~8801/8802, and H9851) I "Tl z :r0 0 0 0 0 01 N 01 0) 0Yes liSI Intermittent I D No liSI No D Continuous l'8J Yes 0Yes liSI Intermittent 0No r8J No ; liSI Continuous l'8J Yes 0Yes I l8J Intermittent 0No [SJ No I 1) Fuel firing rate records are maintained in Pi. ' 2) and 3) Test records arc maintained by the (2) The pem1ittee shaU keep records of the I Navajo Environmental Department. initial perforn1m1ce tests. (3) TI1e permittee shall keep records of the stack oxygen monitoring and the portable analyzer tests" I Reporting: The pern1ittee shaH report in accordance with Section B 110. Condition Reports required by B 110 are submitted as R 111 .D(7) does not apply to portable applicable. I m1alyzer tests. I A204 Heaters/Boilers r8J Yes ' i I I I I Navajo complies with these requirements. Requirement: For the HeatcTs pcnnitted after the Consent Decree, continuous compliance with their respective NOx permit emissions limits in Table 106,A _shall be demonstrated by monitoring as ACC Form Part 1 Permit# .P051-R2 & R2Ml Ver4J 02/25/2015 Page 76 of 144 EPA Inspection Report - Page 796 of 1969 Version 02,25, !.5 1 fo1lows. (NSR 0195M35, Condition ·················· ··· «-· ·············-~ A204.E) !:8J Continuous .lVfonito:ring: (1) For heaters vvith a heat input capacity greater than 150 MM Btu/hr (LHV Basis), the permittee shall install and operate CMS to measure NOx and 02 by the startup date of each heater. Each CMS shall be installed, certified, calibrated, maintained, and operated in accordance \.Vith the requirements of 40 CFR 60.1 L 60.13, and Part 60 Appendix A and the applicable perfonnance specifications of 40 CFR Part 60 Appendices B and F. 1) H-9851 has a CMS installed and data ' These CMS shall be used to demonstrate , . . . , maintained in PL comphance with en11ss10n lnmts. The , permitte: shall make CM~ and process , data available to the applicable Federal and State Agencies upon demand as soon as practicabk Condition A204.F(1) applies to heater H-9851, (2) For heaters with a heat input capacity of equal to or less than 150 MM Btu/hr (LHV) but greater than 100 MM Btu/hr (LHV), Navajo sha.11: , !Z:l Intermittent i I cgi Yes ! D No OYes ~No 12) H-2.501 ~ H~.8801:/88?2 has a CMS installed and data mamtamed m Pl. i · 3) Initial perfrnmance tests were completed as required, 4) Navajo complies with these requirements, (a) install and operate CMS to measure NOx and 02 by the startup date of each heater; or I "Tl z :r0 0 0 0 0 01 N 01 -..,J (b) submit to the Permit Program Manager for NMED approval, by no later than 90 days after the startup date of each heater, a proposal for monitoring based on operating -p_ar_a_m_e_t_er_s_·,_O._,ip,__e_r_a_ti_ng'"'--'p.._ar_a~~!,~=~,,L """"··········----···············----- ,, ACC Form Part l Pennit # P051-R2 & R2M l Ver4J 02/25/2015 «««««<«·' ···········------------------'--------' Page 77 of 144 EPA Inspection Report - Page 797 of 1969 Version 02.25.15 r to consider include, but are not limited to, firebox temperature, air ; pre-heat temperature, heat input rate, and combustion 02. Navajo agrees to use such parameters as a means of monitoring performance. Condition A204.F(2) applies to heaters H-2501 and H-8801/8802 (3) For heaters with a heat input capacity of equal to or less than l 00 MM Btu/hr (LHV basis), the pennittee shall conduct an initial performance test by no later than 180 days after the startup date. The results of this test shall be reported based upon an average of three (3) one-hour testing periods and shall be used to develop representative operating parameters for each unit, which will be used as indicators of compliance. This condition applies to the following heaters: I "Tl z :r0 0 0 0 0 01 N 01 OJ • Heaters H-0362, H-0363, H0364, and H-2421 • Heater H-0019 • Heaters H-3402 (AMP approved by EPA, see (4)) , initial performance test completed on July 10, 2013 • Heater H-3403, initial perlommnce test completed on April 30, 2013 (4) US EPA has approved an Alten1ative 1 ! Monitoring Plan (AMP) for Unit H-3402 for utilizing the oxygen monitor on the · H-3402 Unit 34 Hvdrocracker Reboiler 1 I ACC Form Part 1 Pennjt# P051-R2 & R2M1 Ver4.1 02/25/2015 Page 78 of 144 EPA Inspection Report - Page 798 of 1969 Version 02.25.15 as a parametric means for demonstrating compliance with NSPS Ja, NOx monitoring via a CMS, In accordance with the AMP, the permittee shall accomplish the fo11owing: (a) lnstaH flow indication on the fuel Ene to provide historical data of the fuel to the Mild Hydrocrackcr (Unit 34) by January P, 2015. (b) Monitor the process historical data of the HEP purchased natural gas pressure, and the high pressure fuel balance drum (D-0770). 1 (c) Upgrade the existing the Mild Hydrncracker (Unit 34) Reboiler Heater (H-3402) oxygen monitor to perfo1111 daily calibrations as required in 40 CFR60,13(d)(1). (Note that the sample placement docs not confonn to CMS requirements for process reasons), (d) Conduct biennial performance tests according to the requirements in 40CFR 60.104a(i). (e) Establish a maximum or curve excess 02 operating limit (TvIOPV) as required under 40 CFR60J07a(c)(6) utilizing the existing monitor, (t) ]ndnde Reboiler Heater (H-3402) I "Tl z :r0 0 0 0 0 01 N 01 (!) hours of refinery fuel gas usage and any deviations during such time as required hv 40 CFR 60.7 for ACC Form Part l Pem1it # P051-R2 & R2M l. Ver 4.1 02i25i20l5 Page 79 of 144 EPA Inspection Report - Page 799 of 1969 Version 0225.15 periodic reporting. ! I Record.keeping: (1) Thepern1ittee shal1 keep records of the monitoring proposals submitted to the Pennit Program Manager for approval and whether the submittal ;vas approved. t8'.I Continuous t8'.I Yes 0Yes t8'.I Intermittent 0No [8'.I No D Coath!uous rg) Yes 0Yes [8'.I Intermittent 0No [8'.I No t8'.I Continuous I [8'.I Yes 0Yes [8'.I Intm·mhtent I 0No [8'.I No 1) Records are maintained by the Navajo Environmental Department 2) CMS data maintained in PL (2) The fK,'ITTiittee shaU keep records of the CMS data, calibrntion, and recertification's monitored in Condition A204,A, Summary of Compliance. 3) Performance tests are maintained by the Navajo Environmental Department. 4) the Al"\1P is maintained by the Navajo Environmental Department (3) The pennittee shall keep records ofthe performance tests. (4) The permittee shall keep records of the implementafam of the AMP and all required monitoring specified in the M1P. Reporting: 111e permittee shall report in accordance \Vith Section B 110, Reports required by B 110 are submitted as applicable, •.,........................,,,,,,, A204 Heaters/Boilers G. NSPS Subpart Db, Standards of Performance for Industria1-Commercial1 I Institutional Steam Generating Units . ' (Boilers and heater subject in Table H.eater H-2501 and Bo!krs B-0007, B-0?08, and ! - - - - - - - --.-.-uu~.-.-.-.-. J' l 03,E) B-0009 each have a NOx CEMS as required by I NSPS Subpart Db. Requirement: The permittee shall comply with al] applicable requirements of 40 CFR 60, Subparts A & Db (N0xI "Tl z :r0 0 0 0 0 01 N 0) 0 60A4b, S02-60A2b, & PM-60A3b) for ___!__~e affected sources in Tab1e 103,R ACC Form Part 1 Penn.it# P051-R2 & R2Ml Ver 4.1 02/25/2015 Page 80 of 144 I EPA Inspection Report - Page 800 of 1969 Version 0225.15 [Xl Continuous l\fo:nitori:ng: The pcrmittec shall comply Heater H-2501 and Boilers B-0007, B-0008, and !8J Yes with the applicable monitoring and testmg B-0009 each have a NOx CEMS as required by !Ll Intermittent [JNo i requirements of 40 CFR 60A8b, Subpart NSPS Subpart Db. 1 Db. ..4............................................- - - - - - - - - - - - - j - - - - - - r - : rR~~~rdkceping:· The pennittee s~aH ! NOx records are maintained in PL Test records arc lSJ Continuous !8J Yes ! comply with the applicable recordkeepmg maintained by the Navajo Environmental ~ fotennhtent 0No \ requirements of 40 CFR 60.49b, Subpart Department. I 1 Db. Reporting: The permittee shall comply Navajo submited NS.PS Subpart Db reports D Continuous k?SJ Yes with the applicable reporting semiannually as follows: ~ Intermittent 0No 1/30/2019 requirements of 40 CFR 60.49b, Subpart 7/30/2019 Db, Compliance Test: The pennittee shall I R$J Continuous ['8'.l Yes comply with the methods and procedures Navajo complies with the requirements of the I !8J Intermittent 0No stipulated in 40 CFR 60, Section 60.45b Compliance Testing, and 60A6b. I 1 0Yes rgj No 0Ycs ~No 0Yes ~No uuu~=~•-• 0Yes !8J No A204 Heaters/Boilers !8J Continuous [Xl Yes 0Yes H. NSPS Subpart De, Standards of Performance for Sman IndustrialCommerciaL - lnstitutioual Steam Generating Units (Boilers and heater Navajo complies wfrh the requirements of steam subject in Table 103 .R} generating units. Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A & De (N0x60.44c, S02-60A2c, & PM-60A3c) for the affected sources in Table 103.E JV[onitoring: The pennittee shall comply !8J Intermittent 01'-fo !8J No __.............+1 rgj Continuous !8J Yes............_....,,,, D Yes with.the appllca. bk monitoring and testing reqmrcmcnts of 40 CFR 60A7c, Subpart De. I N.avajo .compl,ies with the requirements of steam generatmg umts. rx Intermittent 1 D No [Xl No I "Tl z :r0 0 0 0 0 01 N 0) ..... ACC Fonn Part l Permit# P051-R2 & R2M l Ver4J 02/25i2015 Page 81 ofl44 I I EPA Inspection Report - Page 801 of 1969 Version 02,25. l.5 rccccccc------------------ .............. .Recordkeeping: The pennittee shaH comply '>Nith the apphcab1e record.keeping requirements of 40 CFR 60A8c, Subpart Navajo complies with the requirements of steam generating units. ~ Contl.uu.ous ~Yes 0Yes [8:l Inte:rmatent 0l'1 , mt k'.)J Intcrnutt, 0Yes r::7! N·. un k:-J .!. ; I cccc,cccc,cccc cccc,cccccccccc ,cccccccccc,,cc , c c c c c c c c c c , c c c c , - - - cccccccccccccccccccc,~cccccccc, Recordkeeping: The permittec shaH comr1y with the apphcab]e recordkeeping reqmrements of 40 CFR 60 , Subpart · ,Ja, Records are maintain~d by Navajo Environmental Department and on PL Reporting: The pcrmittec shall comply Nav~jo submiled NSPS Subparts Ja reports with the applicable reporting requirements of 40 CFR 60 Subpart]" · ' ·· · a. semiannually as foUows: 113 2019 0! 7/30/2019 A204 Heaters/Boilers K, BACT NOx Limit, Continuous Monitoring Systern (CMS) (Unit B-0009) Requirement: I "Tl z :r0 0 0 0 0 01 N 0) .i:,,. The permittee shall comply with the aUowab1e emission limits in Table 106,A and Condition AJ 06.E that represent NOx BACT Emits for the BACT requirements. (NSR . ()] 95M35, Condition A204J and revised), ACC Form Part 1 Permit# P051-R2 & R2M1 Ver 4. 1 02/25/2015 25] Yes 0No !8:]Yes :zJ Continum IS I uNJ lntermHt, mt ! D , . ii!i I :zJ 0No uuuuu Contmum !Ut Intermitt, :g:J y. es 0No ~ Continuous 0Yes ~Ye1i D Intermittent :g:j lN0 0No Navajo complies with the BACT requirements frir B-0009, except for deviations previously reported or identified at the end of this repmt. """L , ....................... .l~.........· - - - - - - - ' Page 84 of 144 EPA Inspection Report - Page 804 of 1969 Version 0225.15 11\/[o:nito:ring: C Continuous [2'.] Yes CYes ! (1) Tue Pcnnittec sha11 comp1y with the rs: Intermittent D No K?l "!'<'<> v.::,J l~v D Continuum, 0Yes 0Yes CMS monitoring as detailed in Condition I 1) Navajo complies with Conditon A.204.D, A204D, (2) The pennittee shall conduct an EPA 2) B~0009 went into service on 4/14/2015. The Method test vvithin six (6) months of initial RATA compliance test was completed on permit issuance using EPA reference test 11/06/2015, except for deviations previously methods in 40 CFR 60 for NOx and 0 2 and reported or identified at the end of this report CO2. Data from the CJv1S Rl\.TA testing may be used to satisfy this testing requirement Reconikeeping: (1) The pcrmittee shall keep records of the CvIS initial calibration and recertification monitored in Condition A204.B, Summary of Compliance. (2) Records of EPA Methods tests shall be maintained for the Boiler. I D No [2'.] No 2) The initial compliance test was completed on 11/06/2015. ««««««<« «««««<«----1----------------,,---+-------+------- ---l D Continuous rs:! Ye§ 0Yes Reporting: (J) TI1e permittee shall report in accordance with Section B 110~ to include the CMS initial calibration and recertification. (2) The pennittee shall summarize m tabular fom1 the results of the EPA Methods tests fr,r NOx and 02 and CO2, specifying the emissions rates in pounds per hour and lb/Mlv1Btu. The table shall include the average concentration of al1 ~ relevant_pollutantspecies, [2'.] lnte:r.mJttent l) Navajo complies with A204.R rs:! Intermittent D No !,'g! No 1) Navajo complies with Bl 10. 2) The initial compliance test was compteted on 1!/06/2015, except for deviations previously reported or identified at the end of this report I "Tl z :r0 0 0 0 0 01 N 0) 01 ACC Form Fart 1 Permit # P051-R2 & R2rv1 l Ver 4.1 02/25/2015 Page 85 of 144 EPA Inspection Report - Page 805 of 1969 Version 02.25.15 A204 Hcate.rs/BoHers ~ Continuous ~Yes ~ Intermittent 0No L. MACT Subpart DDDDD, Industrial, Commercial, and Institutional Boilers and Process Heaters (Boilers and heatc'f Navajo perrorms the annual tune up required by subject in Table 103 .E} 0Yes I ~No I I t MACT Subpart DDDDD. Requirement: The units are subject to 40 CFR 63, Subpart DDDDD and the permittee sha11 comply with the applicable requirements of 40 CFR 63, Subpart A and Subpart DDDDD. Monitoring: The pem1ittee shal1 comp1y with.an applicable mon!toring ~:1d testing ~av, performs the annual tune up required by rcqmrcmcnts of 40 CFR 63, Subpart A MAC 1 Subpart DDDDD. I and Subpart ?DDDD, . I Recortlkeepmg: The perm1ttee shall com~ly with the applicable recordkeeping Records are maintained by Navajo Environmental reqwrements of 40 CFR 63, Subpart A Department and Subpart DDDDD. Reporting: The permittee shall comply MACT Subpart DDDDD reports were submitted with the applicable reporting semi-an:nuaHy as foUows: requirements of 40 CFR 63, Subpart A 01/30/2019 and DDDDD. 07/30/2019 I 1_~ I I A204 Heaters/Boilers :!VI. EPA Methods Test (Unit B-0009) ~ Continumrn 2;J Yes 0Yes ~ Intermittent D No R:71 v:::J "'-"o n I I I D Continuous I !ZJ Yes ~ Intermittent I D No ««-« 0Yes ~No D Continuous !Z] Yes 0Yes !ZJ Intermittent CNo !2:] No D Continuous 2;J Yes CYes 2$] Intermittent D No 2;J No Requirement: Compliance with CO ! Navajo comp hes with A204X. The initial Limit and aHowable emission i compliance test was completed on 11/06/2015. I1 Emits in Table 106.A shall be ! dcmonstratcd by emissions tests ensuring the unit is operating correctly and within desired parameters. (NSR 0195M35, Condition A204J( and revised.) ! BACT I "Tl z :r0 0 0 0 0 01 N 0) 0) I I J 1 « « - C C C ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , C ' ' ' ' ' " " ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' " " " " ' ' ' ' ' ' ' ' ' " " ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' ' " ' ' ' l______'c'c'c'c"" ACC FonnPart l Permit# P051--R2 & R2Ml Ver 4, ! 02/25/2015 c'c',-'c'c'c'c'"""' Page 86 of 144 EPA Inspection Report - Page 806 of 1969 Version 0225-15 ««········· ..... Monitoring: The permittee shall conduct an EPA Method test no later than 180 days after permit issuance using EPA reference test methods in 40 CFR 60. Emission testing is required for CO. Test results that demonstrate compliance with the CO emission limits shaU a1so be considered to demonstrate compliance ! ;~~o~:k~~~n=~iss~~~:!t~o .of · _ . . "EP,\ . Methods tests shaU be mamtamed for the Boiler. Reporting: The pennittee sha11 report in accordance with the requirements of Section B 111,D and summarize in tabular form the results of the EPA Methods test for CO, specifying the emissions rates in pounds per hour. The tab1e shaH include the average concentration of all relevant I :r-1~~~::~'::~ilcrs D Continuous ! l:8] Yes [Z] Intermittent 1 D Yes ! D No t8J No I ~ Yes I O Yes ! D No I ~ No I Navajo compUes vdth A204.R The initial compliance test was compk~ted on 11/06/2015. N ~ , l' 'ti.. ')04 B Th•· m'1"t1'al ····················------··ro~:~;~nuous awl) o comp ies \Vl 11 /)J., . . " compliance test was completed on 11/06/2015. I [g] Intermittent The initial compliance test was completed on 11/06/2015, except for deviations previously reported or identified at the end of this report MACT Subpart DDDDD reports were submitted semi-annually as foHows: 01/30/2019 07/30/2019 D Continuous t8J Inte:rml.ttent -----j-~Dcontlnnou, N. Verification of Energy Efficiency BACT Control Requirements (Unit B~ [Z] Intermittent l2?J Yes 0Yes 0No !2?J No I0Yes I~Yes ! ~ No 0No 0009) Requirement: The pe1111ittee shall Navajo complies with these conditions. The most comply with the al1owab1e emission recent periodic inspection and tunc~u.p was limits and the foUowing BA CT completed on 04/09/2019, requirements. (NSR 0195]\/135, Condition i\.204.L and revised) I "Tl z :r0 0 0 0 0 01 N 0) -..,J l, Operation and Maintenance (BACT #6): a. Periodic Boiler Tuning The boiler shall be tuned ACC Form Part 1 Penni!# P05 l-R2 & R2Ml Ver4.1 02/25/2015 Page 87 of 144 I I EPA Inspection Report - Page 807 of 1969 Version 0225.15 annually to optimal efficiency, maintain thermal bo Periodic Boiler Inspection and Repair for air leakage - The boiler shall be inspected annually to maintain optimal therma1 efficiency, c. Periodic Boiler Inspection and C1eaning for tube fouling - The boiler shaH be inspected arnmall y and necessary deaning perfi:.im1ed to prevent tube fouling. 2, Next Generation Ultra-low-NOx high efficiency burners (NGCLNB) (#5) shaU be installed in the boiler design. 3. Flue gas economizer (BACT #2) ····· A heat exchanger shaU be fastaUed to recover heat from the exhaust gas to preheat incoming boiler feedwater to attain industry standard perfon11ance (IMO) for thermal efficiency. 4. Boiler insulation (BACT #4) - The boiler shal1 be designed and installed v,dth boiler insulation lo an optimum insulation thickness and material to achieve maximum energy efficiency, The OMP shall include the insulation design and maintenance schedule. I "Tl z :r0 0 0 0 0 01 N 0) OJ 5. Oxygen Trim Control {BACT #7) An Oxygen Trim Control svstem shall :s: •• ~----·-----------------------··································-~ ACC Fonn Part I Permit# P051-R2 & R2M1 Ver4-102/25/2015 Page 88 of 144 EPA Inspection Report - Page 808 of 1969 Version 0225.15 be designed and installed 011 the boiler to monitor oxygen concentration in the flue gas, and the inlet air flow is adjusted to maximize thermal efficiency, 6. Boiler blowdown minimization using manual analysis (BACT #3) ~ The Operation and Maintenance Plan (OMP) shafl include methods and procedures to minimize blmvdowns from the boiler to keep emissions at a mmmmm, 7. Condensate recovery (BACT #8): Condensate shall be recovered as represented. in the application to achieve maximum energy efficiency. Condensate recovery shall be maximized through annua1 steam trap iin§?ections and r~airs, -1-M.onitoring: The Permittee shall develop an Operation and Maintenance Plan (OMP) to indude at 1east the requirements listed above within 12 Navajo complies with these conditions. The initial months of commencement of operations, compliance test was compkted on 11!06i2015, The Permittee shall review the OMP The OMF was submitted on 04/12i2016. annually to ensure ifs effectiveness in meeting the requirements above and recommend changes, I "Tl z :r0 0 0 0 0 01 N 0) (!) ! ...............................................;....... _ _ _ _ ___, 1 D Continuous ~Yes 0Ycs ;g] Intermittent 0No L]No Recordk.eeping: D Contim1.ous 0 (1) Records demonstrating compliance with the energy efficiency requirement shail be recorded and summarized in the I Navajo complies with these conditions, OMP. (2) The Pen11ittee shaU maintain a copy of the OMP onsite and available for ~ :Intermittent D .No ACC form Part 1 Permit# P05 l-R2 & R2M1 Ver4.1 02/25i2015 Yes [ 0Yes ii !.:::.'.:::J.l~v r,;;;;::'l "''" ! : Page 89 of 144 EPA Inspection Report - Page 809 of 1969 Version 02-25, 15 inspection. f.---_,.,,---------------1-------------------+------+-----,cc cccccccc t--·"' ••••••• """- .- - - - 1 Reporting: LJ ~Yes .- , t:o:ntinuous 0Ycs (1) The pennittee shall notify the Department when the OMP has been prepared and available for reviev,-. (2) The permittee shall report in the semiannual report a summary of actions covered 111 accordance with the OMP, and in accordance with Section Bl 10, A204 Heaters/Boilers O. Periodic Emissions Tests (Unit B-009, CO BACT Limit) Requirement; Compliance with the CO , BACT Limit and a11owab1e emission ' hmits in Table 106.A shall be demonstrated by perfonning periodic emissions tests. [X] lnte:r.mJ.ttent 0No [X] No D Continuous ~Y!c§ 0Ycs ~ Intermittent 0No [ZJ No LJ ~ Continuous ~ Yes ' 0Yes L:8J Intermittent D No L:8J No D Continuous [ZJ Yes 0Yes Navajo complies with these conditions. The OMP was updated during this reporting pe1iod. Reports required by B 110 are submitted as applicable. Navajo complies with these conditions, ,cc,cccccc t ········· .......... f·······--·················-···············-····································----·····················--····················--------------·i-- Monitoring: The pem1iHee shall conduct periodic portable analyzer emission tests or EPA Reference Method Tests for CO at the intervals in the fo11owing schedule: First Test --- in accordance with the schedule in Section B 111.A(2). Navajo complies with these conditions. Periodic Second Test --six (6) months after the test completed on: first test is completed. 03i20!2019 All subsequent testing shall be done annually, ~-------· Section B 108 General Monitoring Requirements apply to this condition, The permittee sha11 meet the testing requirements in Section B] 11, I "Tl z :r0 0 0 0 0 01 N -..,J 0 Record.keeping: Records of periodic I Data is maintained in PL emission tests shall include the boiler fuel ACC Fonn Part 1 Permit# P051-R2 & R2M1 Ver 4-1 02125/2015 Page 90 ofl 44 -----1 EPA Inspection Report - Page 810 of 1969 Version 02.25.15 flow rate and the stack gas exhaust temperature. If a combustion analyzer is used to measure CO, and/or excess air in the flue gas, records shall be kept of the make and mode] of the instrnment and instrnment calibration data. If an ORS AT apparatus or other gas absorption analyzer is used, the perrnittee shall record all calibration results. Records shall be kept of an raw data used to determine flue gas flow and of an calculations used to determine flow rates and emission rates. The pennittee shall maintain records in accordance with Section B109, Bl 10, and Bl 11. Reporting: The permittee shall summarize in tabular form the results of the initial or subsequent periodic emissions tests for CO, specifying the mass emissions rates in pounds per hour. Reports required by Bl09, Bl 10, and Bl 11 are The table shall include the average submitted as applicable. concentration of alI relevant pollutant species. TI1e perrnittee shall rep01t in accordance with Section B 109, B 110, and BllL ~ Intermittent 0No ~No D Continuous ~Yes ~ Intermittent II 0Yes 0No ~No I "Tl z :r0 0 0 0 0 01 N -..,J ...... ACC Form Part 1 Permit# P051-R2 & R2Ml Ver 4J 02/25/2015 Page 91 ofl44 EPA Inspection Report - Page 811 of 1969 Version 02.25.15 A206 Ffares t8'.I Continuous t8'.I Yes 0Yes A, FL-0400, FL-0403 D Intermittent 0No t8'.i No l';8l Continuous t8'.I Yes 0Yes D Intermittent 0No t8'.i No Rcqui.rcment: (NSR Condition A206.A) 0195M35, (1) An alarm system in good working order shall be connected to Flare FL-0403 which wm si&snal non-combustion of the gas. (2) The acid gas flow meter for flare FL0400 or FL-0403 shall be operated and calibrated at a frequency and by the procedure specified by the manufacturer, A chart recorder or data logger (electronic storage) shall continuously record the amount of gas measured by the flow meter. 1) FL-0403 (ALK Y /CCR) is equipped with a flare almm. 2) The fuel gas required lo provide supplemental heat to either Flare FL-0400 or FL-0403 is monitored during add gas flaring by a flow meter. No acid gas Haring has occurred since September 5, 2006, lVfonitoring: The fue1 gas required to provide supp1ementa1 heat to either Flare FL-0400 or FL-0403 as required under A 105 ,B shaU be monitored during flaring by a now meter. The flow meter shall be operated continuous1y 24 hours per day, 365 days per year except for periods of flow meter maintenance or repair. I "Tl z :r0 0 0 0 0 01 N -..,J N I 1 The fuel gas required to provide supplemental heat to either Flare FL-0400 or FL-0403 is monitored during acid gas fiming by a fiow meter, The upper range of the flow meter shall be sufficient to record the highest expected flow rate of fuel gas sent to flare, The reading of this flow meter and the flow meter to measure acid gas flow as required under Condition Al 05,B shall be used to dete1111ine compliance with ACC fonn Part 1 Pennit # P051-R2 & R2Ml Ver4,1 02/25/2015 Page 92 of 144 EPA Inspection Report - Page 812 of 1969 Version 0225.15 emission limits at A J 06.C ·------------------------------------------------------------------------+----Record.keeping: (l) Records of all periods of operation during which the flare pilot flame is absent as included in the MACT subpart CC semi-annual reports. --------------------------------------------------------------------------------~. l A206 Flares _ z :r0 0 0 0 0 01 N -..,J (,) [8J Inte1·mittent 0No [8J No : I I : I; ' 1 ! D Continuous I I 0Yes IZJ Intennittent 25] No -1 ~y~ 0No I~y~ 0No Navajo complies with all the requirements of MAC'I CC as shown for aU affected sources in table 103.R Navajo uses a third party LDAR contractor, except for deviations previously reported or identified at the end of this report Requirement: The pem1ittee shall comply with all applicable requirements of MA.Cr Subpart CC, "National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries" for all affected sources shown in Tables I 0Yes ~ Inte:rnlittent IZJ No --+-----08/22/2019 -----------1------L D Continuous 0Yes B. MACT Subpart CC, "National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries" (Flares listed in Table t 03,K) "Tl [8J Yes 1) Flare pilot outages are included in the MACT CC semimmual reports dated as follows: ')l')Q/"J0" 19 O"<"'w,";, (2) Records of the quantity of ' I d d unng . 1. • 1 08;22tL019 supplementa1 ±ue use , d. f _ 1 1 fu i d 1) and 2 -) R ecor ..--1 . . 'd t eacu acu . ...i s o supp ementa e, use an gas uarmg me1 ent o prov1ue fl .1 t] - · - d - p· · l h fl are p1 ot ame are mamtame m . i. supp1ementa eat to are FL- 040 · 0 or I flare FL-0403. · (3) The pcnnittcc shall maintain records from the fimv meter of the amount of gas sent to the flare. 1) Flare pilot outages arc included in the MACT Reporting: The pcnnittcc shall report in CC semiannual reports dated as follows: 02/28/20! 9 accordance with Section Bl 10. !-·----.. --------------------------------------------------------------------------------------------- [8J Continuous I ----~-----·--· - - - - - - - - - - - - - - ------------------------·--·------..-------+.---------i D Continuom, I t2:! Ye§ D Ye§ •. :s , . • , ·- I MACT CC as shown for all affected sources m l with the a_l)phcable momtormg and te_ stmg- II ta blc 103 ,B , Nawuo . uses a th·rrd party LD" n 1\71 •• t , 1I D 1'-10 "'" l"7l "'' 'i k:::J -'-"-tenmt en, V::::J ;~o 103,B. (63.640). JVfonitorino-: The pcrmittce shall complv • .1: , . I Navajo complies with all the r~quirements of_ ?:, ~~h?~lt ~~· J contractor·------------------- __ reqmrements of 40_CFI::.. ACC Form Part 1 Permit# P051-R2 & R2_Ml Ver 4.1 0212512015 f"li"- ____ 1 · Page 93 of I 44 EPA Inspection Report - Page 813 of 1969 Version 0225.15 Navajo complies with all the requirements of Ocont:inumg, MACT CC as shown for aH affected sources in table 103.B. Navajo uses a third party LDAR ~ Intermittent contractor. ;,,,,,,,-----------------+---------- ---------...+--««c.c.cccccccc. D Continuous Reporting: The permittee shall comply Navajo complies with all the requirements of MA.CT CC as shown for all affected sources in with the applicable reporting IBJ lnten:nittent table l 03J3. Navajo uses a third party LDAR requirements of 40 CFR 63.655. rnn!Tactor. [SJ Yes 0Ycs 0No [2J No 1S'J YetiJ 0Yes 0No IB] No !Z] Conthmou§ IBJ Yer; 0Ycs rz:l Intermittent 0No [SJ No Rcco.rdkccping: The permHtee shaU comply with the applicable recordkeeping requirements of 40 CFR 63.655. 1-----------------+------- ----------•ccccc.jc A207 Sulfur Recovery Plant (SPR), Tail Gas Incinerator ffGl) A. Consent Decree Requirements for SRP and TGI Requirement; In addition to the applicable requirements ofNSPS, 40 CFR 60, Subparts J and Ja, the permittee shall accomplish the following: 1} Sulfur Recovery Plant (SRP) sulfur pit emissions are routed to the Tail Gas Incinerators and are continuously monitored as part of the applicable Sulfur Recovery Plant's tail gas enlissions that meet the NSPS Subpart J limit for 1. Navajo shall route all Sulfur Recovery Plant (SRP) sulfur pH emissions from the SRP so that sulfur pit emissions to the atmosphere either are eliminated or are S02. included and monitored as part of the app1foable Su]fu'.r Recovery Plant's tail gas 2) The SRP and TGU are operated and maintained, emissions that meet the NSPS Subpart J to the extent practicable, in accordance with the obligation to minimize SR2 emissions through or Ja Emit for S02. (CD ip 8.C.ii) I "Tl z :r0 0 0 0 0 01 N -..,J .i:,,. 2, The SRP and TGI (and any supplemental contro1 devices) shall be operated and maintained, to the extent practicable, in accordance with the obligation to minimize SRP emissions through implementation of good air poHution contro1 practices required by 40 CFR § 60. 11 (d), at all times, including periods of start-up, shutdown, and malfunction. (CD 9f18.C3ii) ___ (NSR__ 01?5~1~5, gg~~4~:,m A207 .A) ACC Form Part 1 Pcnnit # P05 l-R2 & R2Ml Ver4.l 02i25/2015 implementation of good air pollution control practices required hy 40 CFR 60. 1 l(d), at all times, including periods of start-up, shutdown, and malfu:nctinn. Page 94 of 144 EPA Inspection Report - Page 814 of 1969 Version 02.25J5 - - - - - - - - - - - - - - - - - - , - ,--------"""""'"________ ·····------------------------ -------------~~"------~-----~-~---- -~ l\Jonltoring; The pern1ittee shaU comply ! AJJ t' b ~ , , . .. , ., ... , 1 j ~Ye;; ~ Continuom, 0Ycs 'th ti bJ 't . , ,,-,, o t e contmuous momtorn arc op,;rateo, Wl . ie fapp lea ~mom onng i maintained, and certified as required. ~ Intermittent II 0No ~No reqrurements o N SPS Suopmi J or JfL r ·~~~ 1 ~~--·-····.~~~-.-.~~~=····.~~~~~=~~~n{,-n.~~~..·-------------------+---------l--- Recordkeeping: The pennittee shall i maintain records in accordance with the I Records are maintained by Navajo Environmental applicable requirements of NSPS I Department and on Pi. !. . . . . . . . . . . . . . . ,. . . . . . . . . . . . . , , , , , , _ _ _ u.-u.-.-.-. lZJ Continuom; [gj Yes 0Yes lZJ Intermittent 0No lZJ No f,,c~l.liJQArts.J ..an4.Ja...............................,................................................. -CCCC-CCC,"CCCCCC-------i---------1Navajo submitted NSPS Subparts J and fa reports .Reporting: The pe1111ittee shall report in lZJ Yes D Conti:mwm semiannually as follows: I accordance with the applicable 1/30i2019 ~ Intermittent 0No requirements ofNSPS Subparts J and Ja. 7!30i20l9 A207 Sulfur Recovery Plant (SPR), D Continuous ~y. es Tail Gas Incinerator (TGl) I [gJ Intc:rm.ittent 0No l 0Yes ~No 0Yn, [gJ No B. The following BACT S02 -s,vork practices and eq u1pment shall apply to the SRP (SRU3/TGTU3/TGB): (PSD-NM0195-M25) Maintain at least 98% SRP onstream operations, This includes curtailing refinery operations as necessary when SRU capacity is limited during planned stmtup, shutdown, and maintenance events, Navajo has instaHed BACT, and impkmented the work practices, as described in this permit condition, Maintain adequate SRP excess capacity to reduce the frequency and quantity of refinery excess 802 emissions. After the refinery expansion project proposed units are constructed, the proposed SRU3 wm provide at least 25% excess capacity. I "Tl z :r0 0 0 0 0 01 N -..,J 01 Continue to maintain and use a sulfur shedding plan to prevent or reduce acid .....gas flaring events ACC Form Part ! Pennit # P051-R2 & R2Ml Ver 4,1 02/25/2015 Page 95 ofl44 EPA Inspection Report - Page 815 of 1969 Version 02.25,15 ~ ,...-...-~...-~ .u...-...- ·-~- - ___ .... ~ from refinery upsets, An acid gas flaring event is defined as excess S02 emissions greater than 500 pounds in a 24-hour period. The plan shall state specific actions that may be taken to reduce or prevent acid gas flaring. The actions taken during any event will he based on the refinery operators' discretion, considering safety and other factors related to prudent operation, This plan is subject to review by NhdED or EPA, and shall be amended upon written request by NMED or EPA. i ! The sulfur shedding p1an may ' include~ but is not limited to the following options: I "Tl z :r0 0 0 0 0 01 N -..,J 0) L___ (a) Store sour water to reduce acid gas generation from the sour water strippers (b) Reduce the operating rate of one or more amine strippers to lower the acid gas generation rate (c) Reduce one or more hydrotreahng unit throughput rates to 1ower acid gas generation rate Use hydrogen, when available, as , _______SRU fuel during startup and hot I ACC Fom1 Part 1 Permit# P05!-R2 & R2M1 Ver4.1 02/25/2015 Page 96 of 144 EPA Inspection Report - Page 816 of 1969 ·-,,,,-,,,,,,,,,,~,,-·-""" Version 02.25 J 5 ,,,,,,.,,,,.-1 . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., , , standby to minimize carbon deposits on the SRU catalysts. , ·······-"' I I i During startup and shutdown and to the extent practicable, process I vessels shall be depressurized into other process equipment rather than venting to a fiarc. i The permittee shaH document I instances when this is not i practicable, I A:207 Sulfur Recovery Plant (SPR), Tail Gas Incinerator (TGI) 1) A flm.v meter is in place on the sour water stripper streams into Units SRU1, SRU2, and SRU3. C. SRUl, SRU2, and SRU3 Requirement: (NSR 0195M35, Condition A207.C and revised) The permittee shall demonstrate compliance with the H2S, S02, lb/hr, tpy emissfon limits by completing the following requirements, monitoring, recordkeeping and reporting: [2;'.l Continuous lxl Yes OYes [2;'.l Inkrmittent 0No [2J No 2) The S02 CEMS and flow meter on foe SRU1/SRU2 and S.RU3 incinerator stacks, and the instruments used to measure sulfur concentration and How rates of the gas streams into SRUl, SRU2, and SRU3, are calibrated and maintained at a frequency and method specified by the manufacturer, or as dictated by operating conditions. The S02 CEMS follow tbe quality assurance and quaUty contro1 procedures in 40 CFR 60 Subpart J and Appendix F, (1) A flow meter shall be installed, operated, calibrated, and maintained on the sour water stripper strearns that go to the SRUs. 3) The minimum acceptable level of data capture for aH instruments measuring flow and concentration of sulfur streams into the SRU1, SRU2, and SRU3 including the CEMS and fiow meters on the incinerator stacks shall be at least .r. 1·11clude,, ' l?) \. = · ,An S02- CEMS and flow meter shaH 10 1or eac1J. month . , ,.l'he 100' Yo lost data • 90 0, I be installed on the SRU1/SRU2 _ ,and periods when the concentration and corresponding SRU3 incirn:.,'fator stacks, In add1t10n, flow are not being measured as a result of these units shall be equipped with , calibrations or breakdowns. The data capture is instruments to measure. and record sulfur reported in the semi-annual NS.PS Subparts J and concentration and flow rates of the gas Ja reports, streams into SRUl, SRU2, and SRU3. 0 I "Tl z :r0 0 0 0 0 01 N --.J --.J I ACC Form Part 1 Permit ti ?05 I-R2 & R2MJ Ver4,1 02/25/2015 Page 97 of J44 EPA Inspection Report - Page 817 of 1969 Version 0225.15 TI1e GEMS, flow meters, and data loggers shall he calibrated and maintained, In addition, the calibration of the S02 CEMS shall follow the quality assurance and quality control procedures in 40 CFR 60 Subpart J or Ja and Appendix E (3) The minirnum acceptable level of data capture for aH instruments measuring flow of sulfur streams into the SRU1, SRU2, and SRU3, as well as the CEMS and flow meters on the incinerator stacks, shaU be at least 90%) fr.r each semi-annual period. The 10% lost data \Vill include all periods when the concentration and corresponding flow are not being measured as a result of calibrations or breakdowns. I Monitoring: The gas stream foeding SRUl SRU2, and SRU3 from the amine regeneration units and the sour water stripper shaJ] be tested at least monthly for H2S concentration. The permittee shall monitor the fo 11mvfrlg: D Continuous ~Yes 0Yes ~ .Intermittent 0No ~No 1), 2), and 3) Navajo complies with the requirements of this pem1it condition. (1) Flow rate of sour water stream to SRUs, (2) S02 concentration in SRU incinerator stacks and (3) Flow rate of the SRU incinerator stacks, I "Tl z :r0 0 0 0 0 01 N -..,J OJ ACC Form Part 1 Pcm1it # J'05 l-R2 & R2Ml Ver4.l 02i25i20l5 Page 98 of144 EPA Inspection Report - Page 818 of 1969 Version 02.25.15 NN•---------- ---- ••••••·--·~•••• ---- ••••••••• --------•••••••••••••••••••••---- ••••••••••••••••••••••••••••••••••••••-------""-"t' Recordkeeping: The permittee shall maintain records in accordance with the applicable requirements of NSPS Subparts J or Ja and MACT Subpart I I n·-------,---------.---------~ ~ Continuous [gl Yes OYes ~ Intermittent [gl No [gl No D Continuous 0Yes ~Yes [gl Intermittent [gi No 0No D Continuous ~Yes 0Yes [gl Intermittent 0No [gi No r uuu. The permittee shall also keep records of the following: I), 2), and 3) Records are maintained by Navajo Environmental Department and on Pi. (1) Flow rate of sour water stream to SRUs, (2) S02 concentration in SRU incinerator stacks and (3) Flow rate of the SRU incinerator stacks. Reporting: The permittee shall report in accordance with the applicable requirements of NSPS Subparts J or Ja, MACT Subpru.t UUU, and Section Bl 10. I I Navajo submitted NSPS Subparts J, Ja and MACT Subpart UUU reports semiannually as follows: 1/30/2019 7/30/2019 A207 Sulfur Recovery Plant (SPR), Tail Gas Incinerator (TGI) D. 40 CFR 60, Subpart J (Unit(s) SRUl Navajo complies with the requirements of Subpart and SRU2) J. Requirement: The permittee shall I , comply with the applicable requirements i I of 40 CFR 60, Su~:,~!:LL_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ' Monitoring: The permittee shall install a i J I'I ··············----------------------------------------·····--------··---···--------------------·----------"'!-"-'----------,;------ I l8J Continuous continuous monitoring device to monitor I H-0473 SRUl and SRU2 TGI has a CMS installed. I compliance with the lhS limit. (40 CFR I I I l8J Yes l8J Intermittent I 0No I 0Yes [ [gi No I 6o:!os(a)(3-4))____________________________________ ----------··--·----------L-- · · · · ·---------·· -----·· ----------------_,,_______ - - - - - - - - - - t - - - - - - - - - - - - i - - = - - Recordkeeping: The permittee shall I "Tl z :r0 0 0 0 0 01 N -..,J (!) maintain the continuous emission records. I Records are maintained by Navajo Environmental Department and on Pi. [gl Continuous ~Yes [gl Intermittent 0No i 0Ycs I [gl +-- No D Continuous I ~Yes [ 0Ycs _ __ _ ___1_ _ _ __1_ _ _ _L: i .. ~.~~.~.~~·:·····~~~....~.~~~.~:~--··~~~l~··------~~~~--~~----J----~~;1l~:::i~~i~:~o~~~~: Subpart J reports ACC Form Part l Pennit # P051-R2 & R2M1 Page 99 of 144 Ver4.l 02/25/2015 EPA Inspection Report - Page 819 of 1969 Version 02.25J5 1 li30/2019 rgj No r2:l Intermittent r D No 7/30/2019 1 As of May], 2016, Navajo has elected to compiy 0 Continuous [8'.] Yes 0Yes A209 ~Fugitives with 60,592a(e) ofNSPS Subpart GGGa for all i process units affected by NSPS Subpart GGG r2:l Intermittent 0No [2;J No A. NSPS Subpart GGG, Standards of regardless of \vhether or not those process units Performance for Equipment Leaks of have triggered NSPS Subpart GGGa applicability. i VOC in Petroleum Refineries for which Fugitive components subject to this rule are construction. reconstruction, or included in the Leak Detection and Repair (LD.A.R) ' modificatio~ commenced after January 4, program. Nava~o ~ses a third-party co:1tr~~tor for 1983, and on or before N(wember 7, 2006 the LDAR momtonng and recordkeepmg.lhese are (Fuglfrves subject in Table l 03 .B) · mon_itored and reported in a NSPS Subpart GGGa semiannual re 1ort ,------------------~--------------------1-'"-------+--------+.--««««««««. · A~ of May 1, 201~, ~avajo has ele~ted to .comply O Contimwut;; rgJ Yetii 0Yes Requirement: The pcrmittce shall w1th 60.592a(e} o1 NSPS Subpart GGGa 1or all comply with aU applicable requirements process units affected by NSPS Subpart GGG r2:l Intennittent D No [2J No of NSPS Subpart GGG for sources in regardless of whether or not those process units Table 103.B (affected units and have triggered NSPS Subpart GGGa applicability. voluntarily units), This table also Fugitive components subject to this rnle are includes areas that are vo1untarily included in the Leak Detection and Repair (LDAR) 1 following the NSPS Subpart GGG program. Navajo uses a third-party contractor for monitoring requirements. (See footnote 1 the LDAR monitoring and recordkeeping.These are · ; monitored and reported in a NSPS Subpart GGGa to Table 103.B) ! semiannual lVfonito:ring: The permittce shall comply D co:ntimmm; [8'.] Yes 0Yes with. all applicable monitoring Nav~jo :ises a third-party c~mtractor for the LDAR [8'.] No 0No reqmremm1ts of 40 CFR 60, Subpart momtonng and rccordkccpmg. I [8'.] Intermittent wi:h the reporting requirements of 40 _CI:r:mHtent 0No [8J No 0 [8'.] Yes 0Yes 0No !SJ No Continuous [8J Intermittent «cc D Continuom, [8'.] Yes ·································j, •• D Yes app1ica'ble,.. ex:ct:p;..f2!.th?.4?Y!?:~l?!!?.PT~Yi?Y?1Y ACC Fonn Part 1 Penni!# P051 -R2 & R2M l Ver 4.1 02/25/2015 Page 100 of 144 EPA Inspection Report - Page 820 of 1969 Vernion 02.25.15 B, NSPS Subpart GGGa, Standards of • . Performance for Eqmpment Leaks of VOC in Petroleum Refineries for \vhich Con~t:uct~on, Reconstruction, or , h1oving limits: (CD 1[12.B & 1[13.B) (d) S02 concentration not to ex.ceed 25 pprnvd on a daily rolling 365day average basis and 50 ppmvd on a daily rolling 7-day average basis, each corrected to 0% oxygen. Compliance with this emissions limit shall be demonstrated on an ongoing basis through the use of CMS; l d) The FCC cataiyst regenerator exhaust is continously monitored for SOL 1e) The catalytic cracking regenerator is tested annually for PM and was tested on the following date: 02/13/2019 li) Navajo has submitted an a1ternative monitoring plan (A\:IP) to comply with the FCC opacity monitoring requirement because the FCCU has a wet scrubber which prevents continuous opacity monitoring. Under the AMP, opacity is monitored weekly using 40 CFR 60 Appendix A Method 9. and (e) I "Tl z :r0 0 0 0 0 01 N OJ -..,J 2) The FCC exhaust is continously monitored for a particulate matter (PM) NOx and CO. Deviations were reported to the emission limit of 1.0 pound of Department as excess emfasion events and on the PM per 1000 pounds of coke NSPS Subpart J report. burned cm a 3-hour average basis (CD 1P3.B). To demonstrate compliance with this requirement, the Pem1ittce shaU conduct an annual EPA Method 5 Test for PM and weekly EPA Method 9, OJ:1acity Test in accordance vvith their approved Alternative Monitoring Plan (AMPJ ACC Form Part 1 Permit# P051-R2 & R2Ml Ver4.1 02/25/2015 Page 107 of 144 EPA Inspection Report - Page 827 of 1969 Version 02.25, 15 ««««« (f) ....... -------------,--------~ As the FCC Regenerator is subject to the provisions of 40 CFR 60. l 02 (NSPS Subpart J), it shall not discharge to the atmosphere gases exhibiting greater than 30 percent opacity, except for one six-minute average opacity reading in any one-hour period, I (2) Consent Decu;.Q___ Li1:p.its __Q_n____N.Q~_ .J.+:ng I CO emissionsfrom the FCC: The FCC shall comply with NOx and CO emission limits as follows: (a) The concentrntfon-hased (ppmvd) NOx emission Emit , I "Tl z :r0 0 0 0 0 01 N OJ OJ based on daily rolling 7-day and daily rolling 365-day averages, corrected to 0% oxygen as estabHshed pursuant to the Consent Decree, unless EPA rejects the proposed limit and estah1ishes a different NOx emission limit, in which case the FCC shall comply with EPA's established limit Under no circumstances shall this emission limit be greater than a concentration-based limit that would be equivalent to 34.9 lbs/hr. The 7-day FCC NOx emission limits, shall not apply during periods of Hydrotreater f Outage provided that the FCC I (including associated air i pollution control equipment) is I maintained . -.-.-and ~------u~u .-.-...-.-.-.-.-.-........oreratcd ~-~- ••••••••••••••••••••••••• in a ,i ~ ACC fonn Part 1 Permit# P051-R2 & R2Ml Ver4,l 02/25/2015 ~~~~~ n n n n n . - - - - - - - - - - - - - - - - - - •••••••••••••••••••• ,1,w~-----~ Page 108 of144 EPA Inspection Report - Page 828 of 1969 Version 02.25,15 manner that mm1m1zes emissions in accordance with m1 EPA-approved good air po11ution control practices phm. Navajo shall comply with the plan at all times, including periods of start1ip, shutdown, and ma hydrotreate 365-day av limit shall of hydrotr NOx Hmits ! ! I !I (1) 87,3 corre daily avera 1 ' (2) 58, 1 corm daily avera (b) The NSPS Sub of 500 ppmvd CO a 1-hour average l CO corrected to 00, 365-day average b December_ 31_, __200 ---------------------------- ·---~~------~~~--·-·uunn 1\fonitoring: I "Tl z :r0 0 0 0 0 01 N OJ (!) , (]) A continuous mo nitor system (Cl'v1S) for CO, 02, S02 ant NOx shall be instaHed, cahhrated, maintained, and operated on the FCC Catalyst Regenerator vent sta ck(s) downstream of the scrubber in acco dance with 40 CFR Part60, 160) 3, _Ap1 endix A, and the ACC Form Part 1 Permit# P051-R2 & R2M1 Ver 4. l 02/25/2015 •nun~ 1) The FCCU Catalyst Regenerator Scrubber exhaust is continuously monitored for CO, 02, , S02, and NOx. PM is monitored annually. ""~ ~ Contirmous [;gj Yet;; 0Yes ~ Intermittent 0No ~No 2) The FCC regenerator CMS were recertified on the following dates: co 02/13/2019 S02 02/13/2019 NOx 02/13/2019 uuuuuu~. ---------------- -------- -~~~··~~~ Page l 09 of 144 EPA Inspection Report - Page 829 of 1969 Version 0225, 15 ~uu. .-.-.-.-.-.-.-.-.-.-.-.-.-.-.-••.~. ..• ········~~~~~·n 02 02/l 3/2019 applicable pe1formance specifications of Appendices B (Specifications 2 and 3) andF. The CMS shall be used to demonstrate compliance with CO, S02 and NOx emissions limits and to report compliance with the terms and conditions of the Consent Decree. 3) CMS data is used to ensure emissions Emits are met I 4) The catalytic cracking regenerator is tested annually for PM and was tested on the following date: ! I 02/13/2019 The CMS and process data shaU be made available, by permittee, to applicable Federal and State Agencies (NMED) upon demand as soon as practicable. (CD ~1 LF, 12 D, and 14.C) I Nawtjo has submitted an alternative monitoring plan (A.MP) to comply with the FCC opacity monitoring requirement because the FCCU has a wet scrubber which prevents continuous opacity monitoring. Under the Al\1P, opacity is monitored weekly using 40 CFR 60 Appendix A Method 9, (2) 111e FCC Regenerator Scrubber NOx, S02, CO and 02 CMS shall be recertified ammally, (3) The CMS data shall be monitored to ensure the CO, S02 and NOx emission limits for the FCC are met , (4) The Permittee shall conduct an annual EPA Method 5 Test for Ptvr and weekly EPA Method 9 Opacity test to demonstrate compliance with the particulate matter (PM) emission limit of l 1,0 pound of P\'1 per ] 000 pounds of ! coke burned on a 3-hou:r average basis and opacity limit of 3m·L Pe1111ittee shall meet testing requirements ofB11L ......... ------------------- ---------- I -~~---~~~--~~~=~~ Recordkeeping: The permittee shall maintain the records of: I "Tl z :r0 0 0 0 0 01 N (!) 0 ~ 1), 2), 3), 4), and 5) Records are maintained by Navajo Environmental Department and on PL ""'""··----.-.- [2'.l Con tin u m.rn rgj Yet. 0Yes r8J Intermittent 0No rgj No (1) The certification and re-certification of the CMS, ............................................... ~"""""·------.-.-.-.-.-.---.-.-.-.-.-.-.-.- """' ACC Form Part 1 Pennit # P051-R2 & R2Ml Ver4.1 02i25/2015 Page 110 ofl 44 EPA Inspection Report - Page 830 of 1969 Version 02.25.15 I (2) Modifications to the FCC' s good air pollution control practice p1an to mm1m1ze NOx em1ss1ons shall be surnmarized on an annual basis if any changes were madeo ( CD ~11.G) (3) The pe1111ittee shall keep records of C!v1S data monitoring N02, S02, PM10 and CO emissions from the FCC (CD ~1 LF, CD T12D & CD 9114.C) (4) Records of NOx, CO, S02 ppmvd, lb/1u, tpy; PM lb/1u, tpy and opacity. TPY shall be based on a monthly roHing 12month totaL (5) The permittee shall keep records of annual PM stack tests and weekly Method 9 observations conducted on the FCC For any opacity obsc1Vations conducted in accordance with the requirements of EPA Jvfothod 9, record the infommtion on the fonn referenced in EPA Method 9, Sections 22 and 2A ~ - - - - - - - - - - - - - - - - t - - - - - - - - - - - - - - - - - - - + - - - - - - - + - - - « · « « - « « « « . ······t ·········· .. Reportino: The pennittee shall report 111 Nav~jo su.bmittc~ NS.PS Subparts J and Ja reports D Continuom, ! !8J Yer,; 0Yes "' . . . . senuannually as foUows: acco~ dance w1t~ Section B 110 and testmg 1/JO/lO 19 K7l "''o [2l Intermittent l D No k:'.\Jr< reqmrements of B 111. 7/30/2019 ·······················~----..............i 0 I "Tl z :r0 0 0 0 0 01 N (!) ...... ACC Fom1 Part 1 Permit# P051-R2 & R2M1 Ver 4J 02/2512015 Page 111 ofl 44 EPA Inspection Report - Page 831 of 1969 Version 0225.15 A2H Fluid Catalytic Cracking Unit (FCC) D Continuous 0 0 D No Intermittent Yes 0Yes 0No B. Perfonnance Testing (Unit FCC REGEN) Requirements: (1) The permittee sbalI demonstrate compliance with the NSPS Subpart J particulate matter emission limit at Table 106.A by conducting an initial performance test in accordance with NSPS Subpart A, §60.8 and NSPS Subpart J, §60.106(b). The particulate matter stack test shall be repeated on an annual basis, I Navajo comp.lies with the requirements of NSPS Subpart J, Ja, MACT Subpart A, and ll1J1J, (2) The permittee shall comply with all applicable performance testing requirements in accordance with MACT ! Subp:1rts _A and U~JU, I "Tl z :r0 0 0 0 0 01 N (!) N Momtormg: Testmg shall be conducted in acc?rdance with N~PS Subparts A and J, and maccordancev,nthMACT Subparts A and UUlL Record.keeping: The pennittee shall maintain performance test records in accordance with NSPS Subparts A and J, MACT Subparts A and UUU, and in accordance \Vith Section B109. Reporting: The permittec shall rc1)ort perfonrnmce test results in accordance with NSPS Subparts A and J, JVL'\CT Subparts A and UUU, and in accordance with Section B 110, ACC Fom1 Part I Permit# P051-R2 & R2Ml Ver 4.1 02/25/2015 I I """""!"·""""· w1,t~ 0No D Continuoni;i 0Yes OYes , !ZJ Intermittent 0No rz:iNo ! D Continuous !ZJ ·Yes OYes I ~ .Inte.rmlttent 0No [gJ No '.J~ ~avajo complies :he rcquircmentvs NSPS Subpart J, Ja, MACl Subpart A, and {_;UL. Navajo complies with the requirements of NSPS Subpart J, Ja, MAf'.T Subpart A, and UUU ···············+~------·-----l-----· 0Yes D Continum:rn I ~ Yes !ZJ Intermittent I D No ! Navajo complies with the requirements of NSPS Subpart J, Ja, MACT Subpart A, and UUU. ' I Page 112 of 144 I EPA Inspection Report - Page 832 of 1969 Version 02.25.15 A212 Cooling Towers D Continuous rgj Yes 0Yes A, TvfACT Subpart CC, '"Nationai Emission Standards for Hazardous Air Pollutants from Petrolemn Refineries'" (Cooling Towers subject in Tab1e 103.F) rZJ Intermittent D No r2:J No rgj Yes 0Yes rgj Intermittent 0No [;8J No D Continuous rgJyes 0Yes rgj intermittent 0No rgj No D Continuous k$J Yes 0Yes rZJ Intermittent 0No [:gj No D Continuous r8J Intennittent rgj Yes 0Yes 0.No r8J No Requirement: Navajo complies with the applicable requirements for heat exchange systems, except for deviations previously reported or identified at the end of this report The pennittee shall comply with all app1icab1c requirements of 40 CFR 63, Subpart CC for heat exchange systems for an affected sources shown 111 Table 103.F attached. (63.654(a), 63.640(h)(6)) Monitoring: The pe1n1ittee shall comply I Navajo complies with the applicable requirements with all applicable monitoring and testing for heat exchange systems, except frn deviations requirements of 40 CFR 63, Subpart CC, previously reported or identified at the end of this (63.654(c), (d), (e), (f)} report Recordkeeping: The permittec shaH comr1y with aJ] applicable recordkeeping Records arc maintained by the onsite LDAR reqmrements of 40 CFR 63, Subpart CC contractor and by the Navajo Environmental (63.654(g), 63,655(i){4J,(i}(S)) Department l semrn:nnually as follows: R~porting: . Tue permi~cc shall_ comply Nav~1jo submitte~ MAC'f Subpart CC reports w1th aU apphcab1e reportmg reqmrements of 40 CFR 63, Subpart CC (63.655(±), (t)(] )(vi), (g)(9), (h)(1 }, (7)) AZ U Cooling Towers Towers subject in Table 103,F) , . Requirement: Comphance with !he aHowable emission limits in Table 106.H shall be demonstrated by meeting the following requirements: I "Tl z :r0 0 0 0 0 01 N (!) (,) 1) operate a maximum of six (6) 1 I uuuu 1) Navajo operates with less than six (6) recirculating pumps per heat exhange system. B. Cooling Tower Operations (Cooling _ 2/28/2019 8/22/2019 I D Continuous recirculating pumps at any one A.CC Form Part 1 Pcnnit # P05 t-R2 & R2M l Ver4.l 02/25/2015 .-.-.-.-.--.-.----- 2) The pump capacity is less than 65,500 gpm 3) The Total Dissolved Solids (TDS) is sampled by the Nav.tjo Lab and results maintained in the VortalBUSS system and maintained by the Navajo Environmental Department ; I I I 4) Drift eliminators installed are rated by the manufacturer for 0.001 % or CL003 drift, -------------------------········--···---------------------------------------------- ___ I ,,,,,,. ,, , Page 113 of 144 EPA Inspection Report - Page 833 of 1969 Version 02.25,15 5) Drift eliminators are inspected on an amuial basis. time; 2) ensure that each pump capadty shown in Tab1e 104,A are not exceeded gallons per minute for each cooling tower (65,500 gpm total maximum rate for 6 pumps); 3) limit the Total Dissolved Solids (TDS) content for the cooling tower recirculating ,vater system to 3500 ppmw, based on a monthly roning 12-month annual average; 4} ensure that the drift eliminator are rated by the manufacturer at OJ)Ol % or 0,003 drift or less as shown in Table 104,.A; and 5) ensure that the drift eHminator is present and in good working order, I "Tl z :r0 0 0 0 0 01 N (!) .i:,,. The permittee shall measure the Total Dissolved Solids (TDS) content of the recirculating water through direct laboratory analysis, or may use a conductivity meter on the recirculating water system for the cooling toweL The correlation between conductivity of the water and the TDS content shall be taken as f>-9 * conductivity frunhos/cm) = TDS (pprnw) unless a new correlation is deterrnined through laboratory analysis and submitted to the Pennit Program , Manager for approvaL ACC Form Part 1 Penn.it # P05 l-R2 & R2M 1 Vcr4J 02/25/2015 1 C cccc cccccccccc Page 114 of 144 EPA Inspection Report - Page 834 of 1969 Version 02.25.15 •-~uu. lVfo.nito.riog: The permittee shaH: 1) Monitor the recirculating water TDS content hv direct lahoratorv . analysis of the TDS or through use of conductivity meter values and correlated TDS on a monthly basis; and ··········------- --·----------~~~~~~~ D Continuous [gl Yes 0Yes [gl Intermittent 0No [gl No ~ a. Any correlation other than the (l9 value described above shaU be deve1oped by the permittee by laboratory 1) The Total Dissolved Solids (TDS) is sampled by independent measurement of at least 10 the Navajo Lab and results maintained in the with Vorta:lBLISS system and maintained by the Navajo water samples evenly Environmental Department. approximately spaced measured TDS 2) Drift eliminators are inspected on an annual values that bracket the basis. minimum and maximum values expected. The 3) The Cooling Towers are monitored for VOC highest laboratory TDS breakthrough via the El Paso Method described in sample used for the Appendix?. correlation shall be greater max1mum than the aHowable TDS of 3500 ppm\V, l I 2) Perform an annual inspection of the drift eliminator and perform any maintenance necessary to ensure the device operates according to the manufodurer's specifications. I "Tl z :r0 0 0 0 0 01 N (!) 01 3) The pcm1ittee shall monitor the cooHng water inlet and outlet u •••••••••-.-. ACC Form Part l Pennit # P05 l-R2 & R2M1 Ver 4. 1 02i25/2015 ••••••••••••••••••••·~~~~~~~~·N>"~~N Page 115 of 144 EPA Inspection Report - Page 835 of 1969 Version 02,25,15 streams for hydrocarbons on an '"·-"""""'" --· annual basis using either EPA Method 8015 \\dth a large enough samp1e to achieve accurate quantification of hydrocarbon content, EPA Method 8260, EPA .l'v1ethod 8270 or a similar method as approved by the Department prior to testing, Recordkeeping: The permittee shall maintain the foHowing records: speci.fi cations dmmnstrating maximum capacities of the recirculating water pumps and the manufacturer's specification fbr the drift ehminator specified drift rate; D Continuous ! [Xi Yes [8J Intermittent ! D No [8J No I r8J Yes 0Yes 0Yes 1) Manufacturer's I "Tl z :r0 0 0 0 0 01 N (!) 0) l) Records maintained by the Navajo Inspections Department 2) Monthly TDS and monthly rolEng 12~month average; 2) Records maintained by the Navajo Environmental Department 3) If a. conductivity meteris fosta11ed, a record of the correlation between conductiv.itv " and TDS... any laboratory analyses used to determine the correlation, am.I all related calculations; 3) Records maintained by the Navajo Lab. 4) Records maintained by the Navajo Inspections Department 4) Annual drift eliminator inspection and any records of maintenance ' performed, The perrnittee sha11 rnaintafa records m accordance with Section B109. ! Reporting: The pennittee shall report in ACC Form Part 1 Pcnnit # P05 l-R2 & R2Ml Ver4,1 02/25/2015 I ~av~jo submitted MACT Subpart CC reports ::;emrnnnually as follows: D Continuous Page 116 of 144 EPA Inspection Report - Page 836 of 1969 Version 0225.15 2/28/2019 8/22/2019 accordance with Section B 110. r:8'.l Intermittent ! D No r:8'.]No A213 \Vastewater Syste:rns D Continuous D Yes r:8'.J Yes A. NSPS Subpart QQQ, Standards of Performance for VOC Emissions from Petroleum Refinerv . Waste;vater Svstems (Unit MAIN API) r:8'.l Intermittent r:8'.J No 0No ~ Requirement: Beginning December 31, Navajo continues to comply with the applicable 2003, a11 remaining and newly installed requirements ofNSPS Subparts QQQ throughout individual drain systems, oil-vniter the refinery, except for deviations previously separators, and aggregate facilities not reported or identifed at the end of this report Oily previously specified sha11 be affocted ,vater sewer drain hubs are inspected at least monthly, Junction boxes, and the oil-water facilities, as the term is used in the NSPS, separator arc inspected at least semi-annually. 40 CFR Part 60, Subpart QQQ, and shall be subject to and comply with the applicable requirements of 40 CFR Part 60, Subpart QQQ. (CD 129) The perrnittee shall comply with all app1kab1e requirements of NSPS Subpart QQQ for the affected sources in Tables 60 69 ' 0) I I Navajo continues to comply with the applicable 1 l03.B, C, Go ( Monitoring: The pen:nHtee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart QQQ. (60.695 and 60.696) i D Contin~~:;«······ ----[]-~~~ requirernents ofNSPS Subparts QQQ throughout the refmery, except for deviations previously reported or identifed at the end of this report Oily ;: :·~~:- :;~- ~~:~t=~::~- ~~--~=~=~·: ~ ::::;! ·t1. w111 "Tl z :r0 0 0 0 0 01 N (!) --.J t·h. e app1·1ca_bl e comply repo.rt'mg f. CFR 60 .1)., "·og • 1 reqmrements o 40 , 1 , . , ' ACC Form Part l Permit # POS 1..R2 & R2M 1 Vcr4.1 02i25/2015 D No r:8'.l No water sewer drain hubs are inspected at least Recordl~~~pi;g·;........ P.~~;~~'itt·~~. . . .;1~·~ff" . . comrly with th: apphcablc rccordkecpmg De artment I 1 i r:8'.l Intermittent monthly. Junction boxes, and the oU~water senarntor are insnected at least semi-annually. T~~;. . . . r:8'.J Yes ----------- , E:vironmental • . Na:ajo submi~ NSPS Subpart QQQ reports sern1annua1lv · a::; foUmvs. rirono 1/30/2019 9 t,5-,~- 1- ............. I D Continuous I ~ Yes ... , ID , Yes , ci ::::::::• ~ :: f . r:8'.l Intenmttent I r:8'.J No ..~....,....~--------------------------------------------------------····"··----· I D No I ci::, ·~ . I Page 117 of144 EPA Inspection Report - Page 837 of 1969 Version 02,25J5 I A213 \Vastewater Systems D Coufomom, I D Yes ~ Intermittent ?vf ACT Subpart CC, "National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries" ' B, M~~~~~-.-.-. Record.keeping: Tue permittec shall comr1y with the apphcab]e recordkeeping reqmrements of 40 CFR 63 .5,;;;,:;; - ., , Reporting: The pem1ittee shall comply with the applicable reportino 0 , renmremcnts of 40 CFR 63 655 ' , _ _ ~a,vaJo complies with the requirements of MACT D Continum CC ~ 1".71 Records are maintained by Navajo Environmental O ConHnum m IZl Yes Department. r:sJ lnte.rmati mt 0No Nav~jo submitted MACT Subpart CC reports semiannually as follows; D , . lS] Yes 2/29../"0 l 9 u 8/22/2019 k - • fX1 · v::,, IS 1nternutt, , mt IS Co:ntmuo1 ~nt lnte:nnitti rgj Yes 0No 0.No A213 Vt'astewater Systems D Continuous ! tzl Yes C. Wastewater Treatment System (Units shown in Table 106J) ~ Intermittent Requirement: Compliance with the emission Emits in Tab1e 106J shall be demonstrated by properly maintaining and repairing the units, and running the Wastewater Model annually to calculate the maximum VOC emissions generated. 0No Navajo complies with the requirements of MACT CC, except for deviations noted in semiannual reports, Requirement: The permittee shaH comply with all applicable requirements of MACT Subpart CC, "National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries" for all affected sources shown in Tables 103 .B, C, Qattached. (63.§49} 1\~o:nito.ring: The permittee shall comply w1th_the applicable monitoring and testing reqwrements of 40 CFR 63,. Subpart CC . "1 I (S'.! No rgj Yes I D No 0Yes IZJ No Navajo complies with this requirement, except for deviations noted in semiannual reports. 1 uuuuuuuucc:-------------------------······· •••••••••••••. :i:~.•-••nnn~-----'-------'--- · - - - - - - - ' I "Tl z :r0 0 0 0 0 01 N (!) OJ ACC Fonn Part l Permit# P051-R2 & R2M1 Ver 4, 1 02125/2015 Page 118 of 144 EPA Inspection Report - Page 838 of 1969 Vernion 02.25.J 5 ,------·""~""'"~"--"""""""""·-u--.-.-.-uu.-. -.- -.-.-.-.-.-.-.-.-.-.-r-· .-.-.-.-.-.-.-•••••••••••-.-----------···--------- -----------~~~~~----"-"""""" _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _, __ __ lVfonitoring: (1) Maintenance and repair shaH meet the minimum manufacturer's or permittee's recommended maintenance schedule. Activities that involve maintenance, adjustment, replacement, or repair of functional components with the potential to affect the operation of an emission unit shall. be documented as they occur for the following events: D Continuous [8J Intermittent I I "Tl z :r0 0 0 0 0 01 N (!) (!) ..,, ACC Form Part 1 Fennit # P051-R2 & R2M1 Ver 4.1 02/25/2015 rgJ .No I 1) Navajo complies with this requirement, except ····-·· , D Continuous fv'!"'"'es ~. 0Yes rxl Intermittent 0No [Xl No D Continuous-: ~e~ 1) Navajo complies with this requirement, except for deviations noted in semiannual reports, 2) Navajo uses EPA's Water 9 waste-water modeL I :1=~~~~~ permlttee ,ilicll,;;p~~complies with the cequirelllent of section i,......accordance with Section B 110, Yes I Dtfo (a) Routine maintenance that takes a ' for deviations noted in semiannual reports. unit out of service for more than two 2) Navajo uses EPA's '>ilatcr 9 waste-water model, hours during any twenty-four hour period, (b) Unscheduled repairs that require a unit to be taken out of service for more than two hours in any twentyfour hour period. (2) The permittee shall annually nm the Wastc~ W atcr Model to determine the hour1y and annual emission rates, based on Toxchem V 4 Input Parameters, I ------·· · · · · ·-------- ...... -----+--· Recordkeeping: (1) The pennittee shall maintain records in accordance with Section Bl09, including records of maintenance and repairs activities and a copy of the manufacturer's or pennittee's recommended maintenance schedule. (2) The pennittee shall maintain records of the Toxchem V4 Input Parameters and . the emission calculation results compared . . . . . . .,.D. . . ~-- [sl Yes I B 110. -·································· - I D Yes I ! . _ ·····--·--------------'----------'------,,.., Page 119 of 144 EPA Inspection Report - Page 839 of 1969 Version 02.LU5 ~-~...-~...-................................................................ ~ 1:8'.1 Intermittent 0No i:8'.INo I "Tl z :r0 0 0 0 0 01 (,) 0 0 ACC Form Part 1 Pennit # P051-R2 & R2Ml Ver4.1 02/25/2015 Page 120 of 144 EPA Inspection Report - Page 840 of 1969 PART l B General Conditions i 1. ················ ······ -------- ---------! 2. Was this facility Have these General Conditions been met during this reporting period? I I! I{the section Heading is marked as NIA ,w remarks are required. Check milr one box per subiect heading. II Explain answers in remarks row under subject heading,......... --·····--------······· , , , , , .,,.1, .:~y~~~es ~ . . . . . . . . . . . . . . . . . . . . . . . . . . , , . . . . . . . . . . . . . . . . . . _____ ---------------------------·· · Legal A Permit Terms and Conditions (20.2.70 sections 7, 201.B, 300, 301.B, 302,405 NMAC) I Below r8J Yes Explain Below ! Below 0No Explain Below (1) The permittee shall abide by all terms and conditions of this permit, except as allowed under Section 502(b)(l0) of the Federal Act, and 20.2.70.302.H.l NMAC. Any permit noncompliance is grounds for enforcement action, and significant or repetitious noncompliance may result in termination of this permit. Additionally, noncompliance with federally enforceable conditions of this pennit constitutes a violation of the Federal Act (20.2.70.302.A.2.a NMAC) (2) Emissions trading within a facility (20.2.70.302.H.2 NMAC) (a) The Department shall, if an applicant requests it, issue pennits that contain tem1s and conditions allowing for the trading of emissions increases and decreases in the permitted facility solely for the purpose of complying with a federally enforceable emissions cap that is established in the permit in addition to any applicable requirements. Such terms and conditions shalt include all tenns and conditions required under 20.2.70.302 NMAC to determine compliance. If applicable requirements apply to the requested emissions trading, permit conditions shall be issued only to the extent that the applicable requirements provide for trading such increases and decreases without a case-by-case approval. (b) The applicant shall include in the application proposed replicable procedures and permit terms that ensure the emissions trades are quantifiable and enforceable. The Department shall not include in the emissions trading provisions any emissions units for which emissions are not quantifiable or for which there a:re no replicable procedures to enforce the emissions trades. The permit shall require compliance with all applicable requirements. I "Tl z :r0 0 0 0 0 01 (,) 0 ..... (3) It shall not be a defense for the permittee in an enforcement action to claim that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. ------------·····-----··········· (20.2.70.302.A.2.b NMAC) ·-----------=·········----.. ············· ACC Form Part 1 B, Deviation Summary permit# P051-R2 Ver 4.0 01/22/2015 l:1Does I1 not apply ro·-----···N········ ··········f··.,,,,,,;-...:..:....-~; , o NIA I Explain I Explain I B100 Introduction II RE~iARKS:··· A N/A B101 ---,_,,,,,,,......____ j in.compl~ance with . this_reqmrement. I d~ng the reporting Page 121 of 144 Explain Below ON/A Explain Below EPA Inspection Report - Page 841 of 1969 PART 1 B General Conditions {4) If the Department determines that cause exists to modify, reopen and revise, revoke and reissue, or terminate this permit, this shall be done in accordance with 20.2.70.405 NMAC. (20.2.70.302.A.2.c NMAC) (5) The permittee shall furnish any information the Department requests in writi11g to determine if cause exists for reopening and revising, revoking and reissuing, or terminating the permit, or to detennine compliance with the permit. This information shall be furnished within the time period specified by the Department. Additionally, the permittee shall furnish, upon request by the Department, copies of records required by the permit to be maintained by the permittee. (20.2.70.302.A.2.fNMAC) (6) A request by the permittee that this permit be modified, revoked and reissued, or terminated, or a notification by the permittee of planned changes or anticipated noncompliance, shall not stay any conditions of this pennit. (20.2.70.302.A.2.d NMAC) (7) This permit does not convey property rights of any sort, or any exclusive privilege. (20.2.70.302.A.2.e NMAC) (8) In the case where an applicant or permittee has submitted information to the Department under a claim of confidentiality, the Department may also require the applicant or pennittee to submit a copy of such information directly to the Administrator of the EPA (20.2.70.301.B NMAC) (9) The issuance of this permit, or the filing or approval of a compliance plan, does not relieve the permittee from civil or criminal liability for failure to comply with the state or Federal Acts, or any applicable state or federal regulation or law. (20.2.70.302.A.6 NMAC and the New Mexico Air Quality Control Act NMSA 1978, Chapter 74, Article 2) (10) If any part ofthis pennit is challenged or held invalid, the remainder of the permit terms and conditions are not affected and the permittee shall continue to abide by them. (20.2.70.302.A.1.d NMAC) (11) A responsible official (as defined in20.2.70.7.AE NMAC) shall certify the accuracy, truth and completeness of every report and compliance certification submitted to the Department as required by this permit. These certifications shall be part of each document. (20.2.70.300.E NMAC) (12) Revocation or tennination of this permit by the Department terminates the pennittee's right to operate this facility. (20.2.70.201.B NMAC) (13) The pennittee shall continue to comply with all applicable requirements. For applicable requirements that will become effective during the term of the permit, the pennittee shall meet such requirements on a timely basis. (Sections 300.D.10.c and 302.G.3 of 20.2.70 NMAC) B. Pennit Shield (20.2.70.302.J NMAC) I "Tl z :r0 0 0 0 0 01 (,) 0 N ACC Form Part 1 B Permit# P051-R2 & R2Ml Ver4.1 5/6/2015 Page 122 of 144 EPA Inspection Report - Page 842 of 1969 PART 1 B General Conditions (1) Compliance with the conditions of this permit shall be deemed to be compliance with any applicable requirements existing as of the date of permit issuance and identified in Table 103,A, The requirements in Table 103,A are applicable to this facility with sped fie requirements :identified for individual emission units_ (2) The Department has detennined that the requirements in Table 103,B as identified in the permit application are not applicable to this source, or they do not impose any conditions in this pennit (3) This pennit shield does not extend to administrative amendments (Subsection A of 20-2,70.404 NMAC), to minor permit modifications (Subscctkm B of 20,2,70.404 N1v1AC), to changes made under Section 502(b)(10), changes under Paragraph 1 of subsection H of20.L70.302 of the Federal Act, or to permit terms for which notice has been given to reopen or revoke all or part under 202,70.405 and 202,7(U02J(6). (4) This pernrit shall, for purposes of the permit shield, identify any requirement specifically identified in the permit application or significant pennit modification that the department has determined is not applicable to the source, and state the basis for any such determination, (20.2.70302,AJSNiviAC) C. The owner or operator of a source having an excess emission shall, to the extent practicable, operate the source, including associated air pollution control equipment, in a manner consistent with good air pollutant control practices for minimizing emissions. (202.7. 109 N1v1AC). The establishment of allowable malfunction emission limits does not supersede this requirement. i REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report B102 I Authoritv A. This permit is issued pursuant to the federal Clean Air Act ("Federal Act''), the New }Aexico Air Quality Control I Act ("State Act") and regulations adopted pursuant to the State and Federal Acts, including Title 20, New Mexico Administrative Code, Chapter 2, Part 70 (202.70 Nf,,,L\C) - Operating Permits. i. . ! ~ IZ! Yes i D No Explain i Explain Below I Below ON/A Explain Below i I . 1 I "Tl z :r0 0 0 0 0 01 (,) 0 (,) fl This permit authorizes the operation of this facility. This pennit is valid only for the named pem1ittee, owner, i and operator, A permit modification is required to change any of those entities. i C, The Department sped.fies \vith this permit, terms and conditions upon the operation of this facility to assure 1 compliance with all applicable requirements, as defined in 202,70 NlVIAC at the time this pennit is issued. I . _ _ _ _ _ {.:Z.0.:.?..:.7.9.:?.9?.:f\-1 NM AC) ACC Fonn Part 1 B Penn.it# P051-R2 & R2Ml Ver 4.1 5!6i2015 ········""·········································································· ------···· ........................... !. !• i ff~. I -uuu.----------- ••••••••• : Page 123 of l44 EPA Inspection Report - Page 843 of 1969 PART l B General Conditions D, Pursuant to the New Mexico /Jr Quality ControL Act NMSA 1978, Chapter 74, Article 2, all tenns and conditions in this permit, including any provisions designed to limit this facilitis potential to emit, are enforceable by the Department AU terms and conditions arc enforceable by the Administrator of the United States Environmental Protection Agency ("EPA") and citizens under the Federal Act unless the tenn or condition is specifically desissnatcd in this permit as not being enforceable under the Federal Act (20.2-70302-AS NlvfAC) E The Department is foe .Adminisfrator for 40 CFR Parts 60, 61, and 63 pursuant to the Modification and Exceptions of Section 10 of202.77 NMAC (NSPS), 20.2.78 NivIAC (NESRA.:P), and 202,82 NMAC (MACT), REMARKS: R103 Annual Fee The permittee shall pay Title V fees to the Department consistent with the fee schedule in 20.2-71 J\1vIAC - Operadng Permit Emission fees. The foes wiU be assessed and invoiced st1;arately from this permit (202.70.302.ALe N1V[AC) ~Yes D D Explain Below Explain Below N/A Q:::J Yes 0No Explain Belmv Explain Below REMARKS: BHM Appeal Procedures (202,70-403.A NTVIAC) A, Explain Below DN/A Explain Below Any person who participated in a permitting action before the Department and who is adversely affected by such pcn:nitting action, may file a petition for a hearing before the Environmental Improvement Board ("board'} The petition shall be made in writing to the board within thirty (30) days from the date notice is given ofthe Department's action and shall specify the portions of the permitting action to which the petitioner oL'.iects, certify that a copy of the petition has been mailed or hand-delivered, and attach a copy of the pennitting action for which review is sought Unless a timely request for a hearing is made, the decision of the Department shaU be finaL The petition shall be copied simultaneously to the Department upon receipt of the appeal notice. If the petitioner is not the applicant or permittee, the petitioner shall maU or hand-deliver a copy of the petition to the appli.cant or pennittee. The Department shaH certify the administrative record to the board. Petitions for a hearing shall be sent to: I "Tl z :r0 0 0 0 0 01 (,) 0 ,i:,,. Secretary, New Mexico Environmental Improvement Board 1190 St Francis Drive, Runnels Bldg. Rm N2153 ACC Form Part 1 B Pennit # P05 l -R2 & R2Ml Ver 4. 1 5/6/2015 Page 124 of 144 EPA Inspection Report - Page 844 of 1969 PART 1 B General Conditions Santa Fe, New Mexico 87502 REMARKS: ·---------------------------cccccccccc--1 ••••••••••••••••••••••••••••••••••••••••••••······························-·~ssssss-~»~-----~•,.•••••••••••••• B105 Submittal of Reports and Certifications [8l Yes Explain Below A. Stack Test Protocols and Stack Test Reports shall be submitted electronically to as directed by the Department. B. Excess Emission Reports shall be submitted as directed by the Department. (20.2.7.110 NMAC) C. Compliance Certification Reports, Semi-Ammal monitoring reports, compliance schedule progress reports, and any other compliance status infonnation required by this permit shall be certified by the responsible official and submitted to the mailing address below, or as directed by the Department: or D No Explain Below D NIA Explain Below Manager, Compliance and Enforcement Section New Mexico Enviromnent Department Air Quality Bureau 525 Camino de los Marquez, Suite 1 Santa Fe, NM 87505-1816 D. Compliance Certification Reports shall also be submitted to the Administrator at the address below (20.2.70.302.E.3 NMAC): Chief, Air Enforcement Section US EPARegion-6, 6EN-AA 1445 Ross Avenue, Suite 1200 Dallas, TX 75202-2733 I "Tl z REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. :r0 0 0 0 0 01 (,) 0 01 ACC Fonn Part 1 B Permit# P05 l-R2 & R2Ml Ver 4.1 5/6/2015 Page 125 of 144 EPA Inspection Report - Page 845 of 1969 PART 1 B General Conditions I "Tl z :r0 0 0 0 0 01 (,) 0 0) ACC Fonn Part !. B Pennit # I'051-R2 & R2Ml Ver4.15/6/2015 Page 126 of 144 EPA Inspection Report - Page 846 of 1969 PART 1 B General Conditions B106 NSPS and/or MAC'f Startup, Shutdown. and Ma]ft:rnction Operations ~Yes A If a facility is subject to a NSPS standard in 40 CFR 60, each owner or operator that instaUs and operates a continuous monitoring device required by a NSPS regulation shall comply with the excess emissions reporting requirements in accordance with 40 CFR 60.7(c} B, If a facility is subject to a NSPS standard in 40 CFR 60, then in accordance with 40 CFR 60.8(c), operations during periods of startup, shutdown, and malfunction shall not constitute representative conditions for the purpose of a performance test nor shall emissions in excess of the level of the applicable emission limit during periods of startup, shutdown, and matfunction be considered a violation of the applicable emission limit unless othenvise specified in the applicable standard" C. 1f a facility is subject to a MACT standard in 40 CFR 63, then the facflity is subject to the requirement for a Explain Below No Explain Below NIA Explain Below D No ON/A Explain Below Startup, Shutdmvn and Malfonction Plan (SSM) under 40 CFR 63Ji(e)(3), unless specifically exempted in the applicable subpart (20,2070.302.A.1 and AA NMAC) REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report :8107 Startup, Shutdown, and Maintenance Ope.rations Explain Below A, Explain Below The establishment of pem1itted startup, shutdown, and maintenance (SSM) emission limits does not supersede the requirements of 20.2,7J4,A NrvIAC Except :fiJr operations or equipment subject to Condition 8106, the permittee shall establish and implement a plan to minimize emissions during routine or predictable start up, shut down, and scheduled maintenance (SSM work practice plan) and shall operate in accordance with the procedmes set forth in the plan. (202.7.14.A NMAC) . . . . . ., w • • • • ••• • • n . • ••••• ...........................................--............. . ....................... . RElU.ARKS: Except for deviations reported on the semi-annual reports and/or reforenced in this report - - - - - - -...., ........................ . I "Tl z :r0 0 0 0 0 01 (,) 0 --.J ACC Form Part l B Permit# P05 l-R2 & R2Ml Ver4.1 5/6/2015 Page 127 of 144 EPA Inspection Report - Page 847 of 1969 PART 1 B General Conditions B108 General Monitoring Requirements (20.2.70. 302.A and C NMAC) A These requirements do not supersede or relax requirements of federal regulations. B. The following monitoring and/or testing requirements shall be used to determine compliance with applicable requirements and emission limits. Any sampling, whether by portable analyzer or EPA reference method, that measures an emission rate over the applicable averaging period greater than an emission limit i.i1 this permit constitutes noncompliance with this pennit. The Department may require, at its discretion, additional tests pursuant to EPA Reference Methods at any time, including when sampling by portable analyzer measures ru:1 emission rate greater than an emission limit in this permit; but such requirement shall not be constmed as a determination that the sampling by portable analyzer does not establish noncompliance with this permit and shall not stay enforcement of such noncompliance based on the sampling by pmtable analyzer. C. If the emission unit is shutdown at the time when periodic monitoring is due to be accomplished, the pennittee is not required to restart the unit for the sole purpose of perfonning the monitoring. Using electronic or written mail, the pennittee shall notify the Department's Enforcement Section of a delay in emission tests prior to the deadline for accomplishing the tests. Upon recommencing operation, the permittee shall submit any pertinent pre-test notification requirements set forth in the current version of the Department's Standard Operating Procedures For Use Of Portable Analyzers in Performance Test, and shall accomplish the monitoring. D. The requirement for monitoring during any monitoring period is based on the percentage of time that the unit has operated. However, to invoke monitoring period exemptions at Bl08.D(2), hours of operation shall be monitored and recorded. ( 1) If the emission unit has operated for more than 25% of a monitoring period, then the permittee shall conduct monitoring during that period. (2) If the emission unit has operated for 25% or less of a monitoring period then the monitoring is not required. After two successive periods without monitoring, the permittee shall conduct monitoring during the next period regardless of the time operated during that period, except that for ru:1y monitoring period in which a unit has operated for less than 10% of the monitoring period, the period will not be considered as one of the two successive periods. (3) [:8] Yes D No I Explain I Below Explain Below ----,---------------------------- ------------------------------------ If invoking the monitoring period exemption in Bl 08 .D(2), the actual operating time of a unit shall not exceed ON/Ai Explain Below I ! I I "Tl z :r0 0 0 0 0 01 (,) 0 OJ -~~;__ ;~::i::_::::::~;~::~~~;~h~t~:~r::\~~;~;;i:~::~~;~r:~~~~~~;:J;r:~~~::r:db~.:.;~~.:;;ir.~;;.~~--l--.. ACC Form Part 1 B Permit# P051-R.2 & R.2Ml Ver 4J 5/6/2015 -··' Page 128 of144 EPA Inspection Report - Page 848 of 1969 PART 1 B General Conditions ••• n u ~ ·······:"""'' ----- is conducted. Regardless of the time that a unit actually operates, a minimum of one of each type of monitoring activity shall be conducted during the five year term of this pennit. E. The permittee is not required to report a deviation for any monitoring or testing in a Specific Condition if the deviation was authorized in this General Condition B 1 F. For all periodic monitoring events, except when a federal or state regulation is more stringent, three test runs shaH be conducted at 90% or greater of the unit's capacity as stated in this permit, or in the permit application if not in the pennit, and at additional loads when requested by the Department. If the 90% capacity cannot be achieved, the monitoring wiU be conducted at the maximum achievable load under prevailing operating conditions except when a federal or state regulation requires more restrictive test conditions. The load and the parameters used to calculate it shall be recorded to document operating conditions and shall be included with the monitoring report. G. When requested by the Department, the pem1ittee shall provide schedules of testing and monitoring activities. Compliance tests from previous NSR and Title V permits may be re-imposed if it is deemed necessary by the Department to determine whether the source is in compliance with applicable regulations or pem1it conditions. H. If monitoring is new or is in addition to monitoring imposed by an existing applicable requirement, it shall become effective 120 days after the date of permit issuance. For emission units that have not commenced operation, the associated new or additional monitoring shall not apply until 120 days after the units commence operation. All pre-existing monitoring requirements incorporated in this pem1it shall continue to apply from the date of permit issuance. All monitoring periods, unless stated otherwise in the specific pennit condition or federal requirement, shall commence at the beginning of the 12 month reporting period as defined at condition A109.B. REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. I "Tl z :r0 0 0 0 0 01 (,) 0 (!) ACC Form Part l B Permit# P05 l-R2 & R2Ml Ver 4.1 5/6/2015 Page 129 of 144 < EPA Inspection Report - Page 849 of 1969 PART 1 B General Conditions :8109 General Recordkeeging Requirements (20.2.70.302.D.1 NMAC) A. ['8JYes • 0No Explain • Explain Below • Below •D I NIA • Explain Below The permittee shall maintain records to assure and verify compliance with the terms and conditions of this permit and any applicable requirements that become effective during the term of this permit. The minimum information to be included in these records is (20.2.70.302.D. l NMAC): (1) Records required for testing and sampling: (a) equipment identification (include make, model and serial number for all tested equipment and , emission controls); (b) date(s) and time(s) of sampling or measurements; (c) date(s) analyses were performed; (d) the company or entity that performed the analyses; (e) analytical or test methods used; (f) results of analyses or tests; and (g) operating conditions existing at the time of sampling or measurement. (2) Records required for equipment inspections and/or maintenance required by this permit: I "Tl z :r0 0 0 0 0 01 (,) ..... 0 (a) equipment identification number (including make, model and serial number) (b) date(s) and time(s) of inspection, maintenance, and/or repair (c) date(s) any subsequent analyses were performed (if applicable) (d) name of the person or qualified entity conducting the inspection, maintenance, and/or repair (e) copy of the equipment manufacturer's or the owner or operator's maintenance or repair recommendations (if required to demonstrate compliance with a permit condition) (f) description of :maintenance or repair activities conducted i i i (g) all results of any required parameter readings i ! (h) a description of the physical condition of the equipment as found during any required inspection \ I i (i) results of required equipment inspections including a description of any condition which required I ::i4j~1~!~~!1!_ ~'?,J?~iP:8_!1,:l~-~9,,u,!£!!1:~nt back into compliance and a description ~I!·h~E~I1:1iE~4 ::iqj~1~~~~~~!~J • L ACC Form Part 1 B Permit# P05 l-R2 & R2Ml Ver4.l 5/6/2015 I ~ I _____- _ L____ Page 130 of 144 EPA Inspection Report - Page 850 of 1969 PART 1 B General Conditions B. The permittee shall keep records of aH monitoring data, equipment calibration, maintenance, and inspections, Data Acquisition and Handling System (DAHS) if used, reports, and other supporting information required by this permit for at least five (5) years from the time the data was gathered or the reports written. Each record shall clearly identify the emissions unit and/or monitoring equipment, and the date the data was gathered. (20.2.70.302.D.2 NMAC) C. If the pem1ittee has applied and received approval for an alternative operating scenario, then the pennittee shall maintain a log at the facility, which documents, contemporaneously with any change from one operating scenario to another, the scenario under which the facility is operating. (20.2.70.302.A.3 NMAC) D. The pennittee shall keep a record describing off pennit changes made at this source that result in emissions of a regulated air pollutant subject to an applicable requirement, but not otherwise regulated under this permit, and the emissions resulting from those changes. (20.2.70.302.I.2 NMAC) E. Unless othenvise indicated by Specific Conditions, the pe1mittee shall keep the following records for malfunction emissions and routine and predictable emissions during startup, shutdown, and scheduled maintenance (SSM): (]) The owner or operator of a source subject to a permit, shall establish and implement a plan to minimize emissions during routine or predictable startup, shutdown, and scheduled maintenance through work practice standards and good air pollution control practices. This requirement shaU not apply to any affected facility defined in and subject to an emissions standard and an equivalent plan under 40 CFR Part 60 (NSPS), 40 CFR Part 63 (MACT), or an equivalent plan under 20.2.72 NMAC - Construction Permits, 20.2.70 NMAC Operating Permits, 20.2.74 NMAC - Pennits - Prevention of Significant Deterioration (PSD), or 20.2.79 NMAC - Permits - Nonattainment Areas. (20.2. 7 .14.A NMAC) The pem1ittee shall keep records of all sources subject to the plan to minimize emissions during routine or predictable SSM and shall record if the source is subject to an alternative plan and therefore, not subject to the plan requirements under 20.2.7.14.A NMAC. I "Tl z :r0 0 0 0 0 01 (,) ...... ...... (2) If the facility has allowable SSM emission limits in this permit, the pennittee shall record all SSM events, including the date, the start time, the end time, a description of the event, and a description of the cause of the event. This record also shall include a copy of the manufacturer's, or equivalent, documentation showing that any maintenance qualified as scheduled. Scheduled maintenance is an activity that occurs at an established frequency pursuant to a written protocol published by the manufacturer or other reliable source. The authorization of allowable SSM emissions does not supersede any applicable federal or state standard. The most stringent requirement annli"'" ACC Form Part 1 B Permit# P05 l-R2 & R2Ml Ver4.1 5/6/2015 Page 131 of 144 EPA Inspection Report - Page 851 of 1969 PART 1 B General Conditions (3) If the facility has allowable malfunction emission limits in this permit, the pennittee shall record all malfunction events to be applied against these limits. The pennittee shall also include the date, the start time, the end time, and a description of the event. Malfunction means any sudden and unavoidable failure of air pollution control equipment or process equipment beyond the control of the owner or operator, including malfunction during startup or shutdown. A failure that is caused entirely or in part by poor maintenance, careless operation, or any other preventable equipment breakdown shall not be considered a malfunction. (20.2.7.7.E NMAC) The authorization of allowable malfunction emissions does not supersede any applicable federal or state standard. The most stringent requirement applies. This authorization only allows the pennittee to avoid submitting reports under 20.2.7 NMAC for total annual emissions that are below the authorized malfunction emission limit. (4) The owner or operator of a source shall meet the operational plan defining the measures to be taken to mitigate source emissions during malfunction, startup or shutdown. (20.2.72.203.A(S) NMAC) REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report 8110 I "Tl z :r0 0 0 0 0 01 (,) ...... N General Reporting Requirements (20.2.70.302.E NNIAC) A Reports of required monitoring activities for this facility shall be submitted to the Department 011 the schedule in section A] 09. Monitoring and recordkeeping requirements that are not required by a NSPS or MACT shall be maintained on-site or (for umnanned sites) at the nearest company office, and summarized in the semi-an:nual reports, unless alternative reporting requirements are specified in the equipment specific requirements section of this permit. B. Reports shall clearly identify the subject equipment showing the emission unit ID number according to this operating pennit. In addition, all instances of deviations from pem1it requirements, including those that occur during emergencies, shall be clearly identified in the reports required by section Al 09. (20.2. 70.302.E.1 NMAC) C. The permittee shall submit reports of all deviations from permit requirements, including those attributable to upset conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. These reports shall be submitted as follows: (1) 0Yes i 0No !"ON/A Explain i Explain ! Explain Below ! Below Below Deviations resulting in excess em1ss10ns as defined in 20.2.7.7 NMAC (including those classified as emergencies as defined in section Bl 14.A) shall be reported in accordance with the timelines specified by 20.2.7.110 NMAC ai;id_i~Jh~~~:ip.i-ammal reports required in~~g!;2n A109.J20.2.70.302.R?;NM_A_C~,)--~-~· ACC Form Part l B Permit# P05 i-R2 & R2M1 Ver4.l 5/6/2015 Page 132 of 144 EPA Inspection Report - Page 852 of 1969 PART 1 B General Conditions (2) All other deviations shall be reported in the semi-annual reports required in section A109. (20.2.70.302.E.2 NMAC). D. The permittee shaH submit reports of excess emissions in accordance with 20.2.7.110.A NMAC. E. Results of emission tests and monitoring for each pollutant (except opacity) shall be reported in pounds per hour (unless otherwise specified) and tons per year. Opacity shaH be reported in percent. The number of significant figures corresponding to the full accuracy inherent in the testing instnunent or Method test used to obtain the data shall be used to calculate and report test results in accordance with 20.2.1.116.B and C NMAC. Upon request by the Department, CEMS and other tabular data shall be submitted in editable, MS Excel format F. At such time as new units are installed as authorized by the applicable NSR Permit, the pem1ittee shall fulfill the notification requirements in the NSR permit. G. Periodic Emissions Test Reporting: The pennittee shall report semi-annually a summary of the test results. H. The pennittee shall submit an emissions inventory for this facility annually. The emissions inventory shall be submitted by the later of April l or within 90 days after the Department makes such request. (20.2.73 NMAC and 20.2.70.302.A.1 NMAC) I. (1) The facility emits, or has the potential to emit, 5 tons per year or more of lead or lead compounds, or 100 tons per year or more of PMlO, PM2.5, sulfur oxides, nitrogen oxides, carbon monoxide, or volatile organic compounds. (2) The facility is defined as a major source of hazardous air pollutants under 20.2.70 NMAC (Operating Permits). (3) The facility is located in an ozone nonattaimnent area and which emits, or has the potential to emit, 25 tons per year or more of nitrogen oxides or volatile organic compounds. (4) Upon request by the department. (5) The pennittee shall submit the emissions inventory report by April 1 of each year, unless a different deadline is specified by the current operating pem1it. Emissions trading within a facility (20.2.70.302.H.2 NMAC) (l) For each such change, the permittee shall provide written notification to the department and the administrator at I "Tl z :r0 0 0 0 0 01 (,) ..... (,) least seven (7) days in advance of the proposed changes. Such notification shall state when the change will occur and shall describe the changes in emissions that will result and how these increases and decreases in emissions conditions of the ACC .Form Part l B Perntit #P051-R2 & R2Ml Ver4.l 5/6/2015 Page 133 of 144 EPA Inspection Report - Page 853 of 1969 PART 1 B General Conditions (2) The per:mittee and department shall attach each such notice to their copy of the relevant I "Tl z :r0 0 0 0 0 01 (,) ...... .i:,,. ACC Fonn Part 1 B Pennit # P051-R.2 & R.2Ml Ver 4.1 5/6/20] 5 Page 134 of 144 EPA Inspection Report - Page 854 of 1969 PART 1 B General Conditions ..................... REMARKS: Except for deviations reported on the semi-annual reports and/or referenced in this report. B111 GeneralTesting Reg11irements A. Compliance Tests (1) Compliance test requirements from previous permits (if any) are still in effect, unless the tests have been satisfactorily completed. Compliance tests may be re-imposed if it is deemed necessary by the Department to determine whether the source is in compliance with applicable regulations or permit conditions. (20.2.72 NMAC Sections 210.C and 213) (2) Compliance tests shall be conducted within sixty (60) days after the unit(s) achieve the ma:x.imum nom1al production rate. If the maximum normal production rate does not occur within one hundred twenty (120) days of source startup, then the tests must be conducted no later than one hundred eighty (180) days after initial startup of the source. (3) Unless otherwise indicated by Specific Conditions or regulatory requirements, the default time period for each test run shall be at least 60 minutes and each performance test shall consist of three separate runs using the applicable test method. For the purpose of determining compliance with an applicable emission limit, the arithmetic mean of results of the three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the three runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances, beyond the owner or operator's control, compliance may, upon the Department approval, be determined using the arithmetic mean of the results of the two other runs. (4) Testing of emissions shall be conducted with the emissions unit operating at 90 to 100 percent of the maximum operating rate allowed by the permit. If it is not possible to test at that rate, the source may test at a lower operating rate, subject to the approval ofthe Department. (5) Testing performed at less than 90 percent of permitted capacity will limit emission unit operation to 110 percent of the tested capacity until a new test is conducted. (6) If conditions change such that unit operation above 110 percent of tested capacity is possible, the source must submit a protocol to the Department within 30 days of such change to conduct a new emissions test. t:?sl Yes Explain Below D No Explain Below roN1A i Explain IBelow I "Tl z :r0 0 0 0 0 01 (,) ...... 01 B. EPA Reference Method Tests ACC Form Part 1 B Permit # P05 l -R2 & R2M l Ver4.l 5/6/2015 Page 135 ofl44 EPA Inspection Report - Page 855 of 1969 PART 1 B General Conditions (1) (2) C. I z :r0 0 0 0 0 01 (,) ...... 0) (a) Methods 1 through 4 for stack gas flowrate (b) Method 5 for TSP (c) Method 6C and 19 for S02 (d) Method 7E for NOx (test results shall be expressed as nitrogen dioxide (N02) using a molecular weight of 46 lb/lb-mo1 in all calculations (each ppm of NO/N02 is equivalent to 1.194 x 10-7 lb/SCF) (e) Method 9 for opacity (t) Method 10 for CO (g) Method 19 may be used in lieu of Methods 1-4 for stack gas flowrate upon approval of the Department. A justification for this proposal must be provided along with a contemporaneous fuel gas analysis (preferably on the day of the test) and a recent fuel flow meter calibration certificate (within the most recent quarter). (h) Method 7E or 20 for Turbines per 60.335 or 60.4400 (i) Method 29 for Metals (j) Method 201A for filterable PM10 and PM2.s (k) Method 202 for condensable PM (l) Method 320 for organic Hazardous Air Pollutants (HAPs) (m) Method 25A for VOC reduction efficiency (11) Method 30B for Mercury Alternative test method(s) may be used if the Department approves the change. Peliodic Monitming and Portable Analyzer Requirements (1) "Tl All compliance tests required by this permit, unless otherwise specified by Specific Conditions of this permit, shall be conducted in accordance with the requirements of 40 CFR 60, Subpart A, General Provisions, and the following EPA Reference Methods as specified by 40 CFR 60, Appendix A: Periodic emissions tests (periodic monitoring) may be conducted in accordance with EPA Reference Methods or by utilizing a portable analyzer. Peliodic monitoling utilizing a portable analyzer shall be conducted in accordance with the requirements of ASTM D 6522-00. However, if a facility has met a previously approved Department criterion for portable analyzers, the analyzer may be operated in accordance with that criterion until it is repb~""c1 ACC Fonn Prut 1 B Permit# P051-R2 & R2Ml Ver4.l 5/6/2015 Page 136 of 144 EPA Inspection Report - Page 856 of 1969 PART 1 B General Conditions ·····-·-·-·-·-·--------------~-------------------""""""""""""""""""" (2) Unless otherwise indicated by Specific Conditions or regulatory requirements, the default time period for each test run shall be at least 20 minutes. Each performance test shaH consist of three separate nms. The arithmetic mean of results of the three runs shall be used to detennine compliance with the applicable emission limit. D. I "Tl z :r0 0 0 0 0 01 (,) ..... -..,J (3) Testing of emissions shall be conducted in accordance with the requirements at Section B108.F. (4) During emissions tests, pollutant and diluent concentration shall be monitored and recorded. Fuel flow rate shall be monitored and recorded if stack gas flow rate is determined utilizing Method 19. This information shall be included with the test report furnished to the Department. (5) Stack gas flow rate shall be calculated in accordance with 40 CFR 60, Appendix A, Method 19 utilizing fuel flow rate (sd) determined by a dedicated fuel flow meter and fuel heating value (Btu/scf) detem1ined from a fuel sample obtained preferably during the day of the test, but no earlier than three months p1ior to the test date. Alternatively, stack gas flow rate may be determined by using EPA Methods 1-4. Test Procedures: (1) The permittee shall notify the Department's Program Manager, Compliance and Enforcement Section at least thirty (30) days before the test to afford a representative of the Department an opportunity to be present at the test. (40CFR 60.8(d)) (2) Equipment shall be tested in the "as fom1d" condition. Equipment may not be adjusted or tuned prior to any test for the purpose oflowering emissions, and then returned to previous settings or operating conditions after the test is complete. (3) Contents of test notifications, protocols and test reports shall conform to the format specified by the Department's Universal Test Notification, Protocol and Report Form and Instructions. Current forms and instructions are posted to NMED's Air Quality web site under Compliance and Enforcement Testing. (4) The pennittee shall provide (a) sampling ports adequate for the test methods applicable to the facility, (b) safe sampling platfomrn, (c) safe access to sampling platforms and (d) utilities for sampling and testing equipment. (5) The stack shall be of sufficient height and diameter and the sample ports shall be located so that a j representative test of the en1issions can be perfonned in accordance with the requirements of EPA Method l · or ASTM D 6522-00 as applicable. (6) Where necessary to prevent cyclonic flow in the stack, flow straighteners shall be installed (7) Unless othenv-ise indicated by Specific Conditions or regulatory requirements, test rep011s shall be submitted to the Department no later than 30 days after completion of the test. ;.... L::,~:~_vi3:!~9.~_S._ cc--uu.-.-.-.-.- !.~P.9.1.!_t?4. 100,000 Note: Total Potential Pollutant Emissions in Table 102.A,may include fugitive emissions; routine or predictable, startup, shutdown, and maintenance emissions (SSM); and permitted malfunction allowances if these are a sources of regulated air pollutants from this facility. Table 102.B: Total Potential Hazardous Air Pollutants (HAPs)* and State Toxic Air Pollutants (TAPs) Pollutant Emissions (tons per year) Ammonia Benzene 6.1 36.26 Ethylbenzene 16.39 Toluene; (Methyl benzene) 27.63 Xylenes (total); (Xylol) 14.03 EPA Inspection Report - Page 885 of 1969 Table 102.B: Total Potential Hazardous Air Pollutants (HAPs)* and State Toxic Air Pollutants (TAPs) Pollutant Hexane Emissions (tons per year) 144.71 Total HAPs** 239.04 * HAP emissions are included in the Table 102.A VOC emissions total. ** Total HAP emissions may not agree with the sum of individual HAPs because only individual HAPs emitted at a rate greater than 1.0 ton per year are listed in Table 102.B. A103 Facility: Applicable Regulations A. The permittee shall comply with all applicable sections of the requirements listed in Table 103.A. Table 103.A: Applicable Requirements Applicable Requirements 20.2.1 NMAC General Provisions 20.2.3 NMAC Ambient Air Quality Standards 20.2.7 NMAC Excess Emissions 20.2.33 NMAC Gas Burning Equipment -- Nitrogen Dioxide 20.2.37 NMAC Petroleum Processing Facilities Federally Enforceable X X X Unit No. 20.2.38 NMAC Hydrocarbon Storage Facilities 20.2.61 NMAC Opacity X 20.2.70 NMAC Operating Permits 20.2.71 NMAC Operating Permit Emission Fees 20.2.72 NMAC Construction Permit 20.2.73 NMAC Notice of Intent and Emissions Inventory Requirements 20.2.74 NMAC Prevention of Significant Deterioration 20.2.75 NMAC Construction Permit Fees X X X Entire Facility Entire Facility Entire Facility Affected sources in Table 103.E Entire Facility unless repealed Entire Facility Combustion sources if 20.2.37 NMAC is repealed. Entire Facility Entire Facility Entire Facility X Entire Facility X X 20.2.77 NMAC New Source Performance X Entire Facility Entire Facility Units subject to 40 CFR 60 Units subject to 40 CFR 61 Units subject to 40 CFR 63 Entire Facility 20.2.78 NMAC Emission Standards for Hazardous Air Pollutants (HAPs) 20.2.82 NMAC MACT Standards for Source Categories of HAPS 40 CFR 50 National Ambient Air Quality Standards X X X X X X EPA Inspection Report - Page 886 of 1969 Table 103.A: Applicable Requirements Applicable Requirements 40 CFR 60, Subpart A, General Provisions 40 CFR 60, Subpart Db “Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units” 40 CFR 60, Subpart Dc “Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, Which Construction, Reconstruction, or Modification Commenced After June 9, 1989” 40 CFR 60, Subpart J, “Standards of Performance for Petroleum Refineries” 40 CFR 60, Subpart Ja, “Standards of Performance for Petroleum Refineries for which Construction, Reconstruction, or Modification Commenced After May 14, 2007” 40 CFR 60, Subpart K, “Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978” 40 CFR 60, Subpart Ka, “Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984” 40 CFR 60, Subpart Kb, “Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After January 23, 1984” 40 CFR 60, Subpart GGG, Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries for which construction, reconstruction, or modification commenced after January 4, 1983, and on or before November 7, 2006. 40 CFR 60, Subpart GGGa, Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries for which construction, reconstruction, or modification commenced after November 7, 2006. Federally Enforceable Unit No. X See Tables 103.B to 103.K See Tables 103.B to 103.J X H-0464; H-3101 X X X X X X X X See Tables 103.B to 103.J See Tables 103.B to 103.J See Tables 103.B to 103.J See Tables 103.B to 103.J See Tables 103.B to 103.K See Tables 103.B to 103.K See Tables 103.B to 103.K EPA Inspection Report - Page 887 of 1969 Table 103.A: Applicable Requirements Applicable Requirements 40 CFR 60, Subpart QQQ, Standards of Performance for VOC Emissions From Petroleum Refinery Wastewater Systems 40 CFR 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines 40 CFR 61, Subpart A, General Provisions 40 CFR 61, Subpart FF, National Emission Standards for Benzene Waste Operations 40 CFR 63, Subpart A, General Provisions Federally Enforceable X X X X See Tables 103.B to 103.K X Entire Facility X Entire Facility X 40 CFR 63 Subpart DDDDD X Table 103.C, Summary Applicability – Tanks Table 103.D, Summary Applicability – Loading Table 103.E, Summary Applicability – Heaters and Boilers Table 103.F, Summary Applicability – Cooling Towers Table 103.G, Summary Applicability – Wastewater Table 103.H, Summary Applicability – FCC-CCR Table 103.I, Summary Applicability – SRU See Tables 103.B to 103.K X X X Table 103.B, Summary Applicability – Fugitives See Tables 103.B to 103.K Entire Facility Benzene Waste Operations Entire Facility See Tables 103.B to 103.K See Tables 103.B to 103.K See Tables 103.B to 103.K 40 CFR 63, Subpart CC 40 CFR 63 Subpart UUU, Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units 40 CFR 63, Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines 40 CFR 68, (RMP), Section 112(r) Accidental Release Consent Decree CIV-01 1422LH Lodged 12/20/2001, Entered 3/5/2002 Note: Tables 103.B through 103.K are located in Attachment D. Unit No. EPA Inspection Report - Page 888 of 1969 Table 103.J, Summary Applicability – Engines Table 103.K, Summary Applicability – Flares A104 Facility: Regulated Sources A. Table 104.A (attached) lists the emission units authorized for this facility. Emission units that were identified as NSR exempt or Title V Insignificant activities and/or equipment not regulated pursuant to the Act are not included. A105 Facility: Control Methods A. Table 105.A lists all the pollution control equipment required for this facility. Each emission point is identified by the same number that was assigned to it in the permit application. Table 105.A: Control Methods: Control BACT Pollutant being Equipment Unit Control Description Yes or No controlled No. Fluid Catalytic FCC Regenerator Cracking Unit NO PM & SO2 Scrubber Regenerator Cyclones + Wet Gas Scrubber CCR Regenerator Vent Control NO Chloride FL-0400 North Plant Flare NO VOC & H2S FL-0401 South Plant Flare NO VOC & H2S FL-0402 FCC Flare NO VOC & H2S FL-0403 Alky Flare NO VOC FL-0404 GOH Flare NO VOC & H2S CHLOR SORB ® FL-HEP-PORT H-0473 Portable Flare for Holly Energy Partners (HEP) Pipeline Pigging Operations Sulfur Recovery Units No. 1 & 2 Tail Gas Incinerator Control for Unit Number(s)1 FCC Regenerator CCR Regenerator Vent Refinery process units Refinery process units Refinery process units Refinery process units Refinery process units NO VOC Pipeline Pigging Operations NO Sulfur SRU1 and SRU2 EPA Inspection Report - Page 889 of 1969 Table 105.A: Control Methods: Control BACT Equipment Unit Control Description Yes or No No. Selective Catalytic SCR Reduction + ultra-low YES NOx burners Sulfur Recovery Unit SRU3-TGI No. 3 Tail Gas YES Incinerator Best Work Practices, SRU3/TGTU3/TGI3 YES A207.B (BACT) Main API Carbon D-0829/0830 NO Canisters Drift Eliminators on Y-0011, Y-0012 Cooling Towers YES (BACT) External Floating T-0737, T-1225 YES Roofs (BACT) External and Internal See Tables 106.B(1) Floating Roofs NO and (2) (None-BACT) Energy Efficiency, B-0009 Yes A204.N (BACT) H-2501, H-3402, H- ultra-low NOx Yes 3101 burners (BACT) Pollutant being controlled Control for Unit Number(s)1 NOx H-9851 Sulfur SRU3 SO2 SRU3 VOC MAIN API PM Y-0011, Y0012 VOC VOC Greenhouse Gases T-0737, T1225 See Tables 106.B(1) and (2) B-0009 H-2501, H3402, H-3101 SRU-TGI, HSRU-TGI, H-2501, Combust gaseous Yes VOC, PM 2501, H-3402, H-3402, H-3101 fuels only H-3101 1 Control for unit number refers to a unit number from the Regulated Source List B. NOx In accordance with the requirement that Navajo Refining prevent exceedances of the 24hour and 3-hour National Ambient Air Quality Standards (NAAQS) for SO2 during major refinery malfunctions, Navajo Refining shall only flare acid gas from existing Flare FL-0403 according to Navajo Refining's "Phase Two" plan dated January 5, 1996 and received by the Department on January 8, 1996, or from Flare FL-0400. Navajo shall undertake the following measures for acid gas flaring from FL-0400 and FL-0403. EPA Inspection Report - Page 890 of 1969 (2) C. Existing Flare FL-0400 shall be equipped with a flare tip or burners to supply supplemental fuel gas to provide enough heat to supplement the heat released by combustion of the acid gas itself and the heat provided by smoke-suppressing steam. The minimum flow rate of supplemental fuel gas to be supplied during acid gas flaring such that compliance with the NAAQS for SO2 is assured shall be determined using Chart No. 1. The fuel gas used for this purpose shall be sweetened fuel gas or sweet natural gas (see definition at C101.E). C H A RT N O . 1 SUPP FUEL FOR SO2 NAAQS COMPLIANCE, FL-400 90.0 80.0 Acid Gas FLow (Mscfh) (1) 70.0 60.0 50.0 40.0 30.0 20.0 10.0 0.0 0 10 20 30 40 50 60 Supp Fuel Gas Flow (Mscfh) Existing Flare FL-0403 shall be equipped with a flare tip or burners to CHART NO. 2 supply supplemental fuel gas to SUPP. FUEL FOR SO2 NAAQS COMPLIANCE, FL-403 40 provide enough supplemental heat. Supp. Fuel Gas 35 The volume of supplemental fuel gas 30 to be provided to generate enough 25 supplemental heat to ensure 20 compliance with NAAQS for SO2 15 shall be determined using Chart No. 2. 10 5 The supplemental heat to be provided 0 when flaring the maximum quantity of 100 80 60 40 20 0 Supp. Fuel Gas (Thousand SCFH) acid gas has been determined to be 52.9 million BTU per hour which is generated by burning 96,200 SCFH of supplemental fuel gas. This assumption has been made to ensure compliance with the NAAQS for SO2. The fuel gas used for this purpose shall be sweetened fuel gas or sweet natural gas. Beginning December 20, 2001 no fuel oil shall be burned in combustion units except as follows: (CD ¶17.C) (1) Torch Oil may be burned in the FCC Regenerator during FCC start-ups; and. (2) Fuel Oil may be burned in combustion units after the establishment of FCC NOx emissions limits pursuant to permit condition A110.A, provided that emissions from any such combustion units are routed through the FCC Wet Gas Scrubber and Navajo demonstrates, with the approval of EPA, that the NOx emissions limits contained therein and the SO2 emissions limits stated in A106.A will continue to be met. 70 EPA Inspection Report - Page 891 of 1969 D. The Artesia Refinery FCC was initially limited to less than 20,000 BPD capacity. Following the December 2003 expansion of the Artesia refinery’s FCC as authorized by permit 195M15, the catalyst regenerator for the FCC is subject to the minimum requirements for continuous emission monitoring and recording set forth in Appendix P to 40 CFR Part 51. Consent Decree Paragraph 15 required the FCC to be subject to NSPS Subpart J for opacity as of December 31, 2003. A wet gas scrubber was installed in 2003. An Alternative Monitoring Plan (AMP) request was submitted to EPA on December 31, 2003 because a continuous opacity monitoring system (COMS) will not work on a wet gas scrubber exhaust because of the interference from the water vapor. The AMP satisfies the requirements for both NSPS Subpart J and 40 CFR Part 51 Appendix P. A106 Facility: Allowable Emissions A. The following Section list the emission units and their allowable emission limits. (See Table 103.A for all applicable regulations) Table 106.A: Allowable Emissions (attached) B. The permitted emission sources at the refinery shall consist only of the sources listed in Table 106.A and Tables 106.B through 106.I and 107.A of this permit. C. Compliance with Allowable Emission Limits Requirement: The allowable mmBtu/hr, lb/mmBtu, lb/hr, and tpy emission limits for equipment listed in Table 106.A construction are based on an hourly rolling 3-hour average. Monitoring: For units with lb/mmBtu emission limits in Table 106.A, the Permittee shall monitor the lb/mmBtu to demonstrate compliance with the mmBtu/hr, lb/hr, and tpy emission limits. Recordkeeping: To demonstrate compliance, records shall be kept on a monthly basis showing the correlation between lb/mmBtu and hourly and 12-month rolling yearly totals. The records shall also document any non-compliance with emission limits. For each unit, a summary of the method used to determine compliance shall be recorded. The permittee shall maintain records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. D. BACT SO2 Limit – Fuel sulfur limit Refinery-Wide for all units burning refinery fuel gas (excluding units H-8801, H-8802 and H-9851 which burn only natural gas) shall not exceed 60 ppmv H2S on a daily rolling 365-day average. The ton/yr emission rates for SO2 in Table 106.A of this permit are based on this daily rolling 365-day average 60 ppmv H2S limit. Compliance with this limit shall be demonstrated per the methods described in Condition A110.A. EPA Inspection Report - Page 892 of 1969 E. BACT NOx Limit - In addition to the emission limits shown in Table 106.A, Boiler Unit B0009 has a BACT NOx limit of 0.02 lb/MM Btu, and CO2 limit of 112.1 lb/MM Btu. F. BACT SO2 Limit – The Sulfur Recovery Unit No. 3 Tail Gas Incinerator (SRU3-TGI) is limited to 192 ppmvd SO2 at zero percent oxygen on a hourly rolling 12-hour average basis. In addition, SRU3-TGI is limited to 192 ppmvd SO2 at zero percent oxygen on a daily rolling 365-day average basis. G. BACT VOC Limit – The naphtha storage tank T-1225 and sour water storage tank T-0737 shall be equipped with an external floating roof using double seals to reduce VOC emissions to the atmosphere. The maximum true vapor pressure of any volatile organic liquid stored in either tank shall not exceed 11.0 psia. Demonstration of compliance is through the NSPS Kb and MACT emission limits. H. VOC – All fugitive piping components in VOC service associated with the process units proposed in Permit 195-M25 (Units FUG-25-ROSE-2, FUG-31-SRU3/TGI3/TGI3, and FUG-34-Hydorcracker) shall be monitored under the MACT subpart CC leak detection and repair program, or an approved equivalent program, to reduce VOC emissions. I. VOC – Consistent with MACT Subpart CC, the gasoline truck loading rack (TLO-4) shall be limited to 10 mg of VOC emissions per liter of gasoline loaded. J. PM10 – Cooling towers, Units Y-0011 and Y-0012, shall be equipped with high-efficiency drift eliminators to reduce PM10 emissions. Demonstration of compliance is through annual inspection in accordance with in Condition A212.B. A107 Facility: Allowable Startup, Shutdown, & Maintenance (SSM) and Malfunction Emissions A. The maximum allowable SSM emission limits for specific units are listed in Table 107.A and were relied upon by the Department to determine compliance with applicable regulations. Table 107.A: Allowable SSM and Malfunction Emissions Units, Activities, and Emission Limits (attached) B. The authorization of emission limits for startup, shutdown, maintenance, (SSM) and malfunction does not supersede the requirements to minimize emissions according to Conditions B101.C and B107.A. C. SSM Flaring and combustion Emissions Requirement: The permittee shall comply with the flaring and combustion SSM NOx, CO, VOC, SO2, TSP, PM10, PM2.5, and H2S emission limits at Table 107.A for the following SSM events: 1) SSM H-9851, Emissions during SCR downtime EPA Inspection Report - Page 893 of 1969 2) 3) 4) 5) SSM SRU-TGI, Emissions from SRU3 startup and shutdown SSM FL-HEP-PORT, Temporary, portable flare for natural gas pipeline maintenance SSM SRU2-TGI (H-0473), Emissions from SRU2 startup and shutdown SSM Flare Cap, Emissions from venting SSM activity gases to FL-400, FL-401, FL-402, FL-403, or FL-404 6) SSM Misc 2, Low-Emitting Maintenance Activities such as de-inventorying small equipment, clearing piping associated with emission units, and routine maintenance activities such as heat exchanger repair. Monitoring: The permittee shall monitor all flaring and combustion due to routine and predictable startups, shutdowns, and scheduled maintenance events. This shall be accomplished by collecting all the SSM flaring and combustion information specified in A107C. Recordkeeping. Recordkeeping: The permittee shall record the date, start and end times, and duration of every SSM flaring or combustion event. The NOx, CO, VOC, SO2, TSP, PM10, and H2S emissions shall be calculated for each event based on the volume of gas sent to the flare and the total sulfur content of the flared gas. Compliance with the hourly emission rates shall be demonstrated by calculating the hourly emission rates for each event and comparing the results to the hourly emission rate at Table 107.A. The annual emission rate shall be calculated as follows: 1) To demonstrate compliance during the first 12-months of monitoring, the permittee shall calculate and sum the monthly cumulative total of NOx, CO, VOC, SO2, TSP, PM10, PM2.5, and H2S emissions; and 2) After the first 12-months of monitoring, the permittee shall calculate and sum the total of NOx, CO, VOC, SO2, TSP, PM10, PM2.5, and H2S emissions on a monthly rolling 12-month basis. 3) The permittee shall maintain all records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. D. SSM VOC Emissions (Facility-Wide, Non-Combustion Sources) Requirement: The permittee shall comply with the SSM VOC emission limit at Table 107.A. Monitoring: The permittee shall monitor all VOC emission activities due to routine and predictable startups, shutdowns, and scheduled maintenance events. This shall be accomplished by collecting VOC emission calculation information for the following SSM VOC emission activities: 1) SSM T-0737, Emissions from roof landing 2) SSM Tanks Miscellaneous Recordkeeping: The annual SSM VOC emission rate shall be calculated as follows: 1) To demonstrate compliance during the first 12-months of monitoring the permittee shall calculate and sum the monthly cumulative total of VOC emissions; and 2) After the first 12-months of monitoring the permittee shall calculate and sum the total of VOC emissions on a monthly rolling 12-month basis, including the methodology and/or assumptions used in the calculation(s). The permittee shall keep records to demonstrate compliance in accordance with Condition B109C, except the requirement in B109.C(2) to EPA Inspection Report - Page 894 of 1969 record the start and end times of SSM events shall not apply to known quantities of VOC emissions. 3) The permittee shall maintain all records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. E. SSM and Malfunction Flaring Emissions (SSM Flare Cap and Flares Malfunction Cap) Requirement: The permittee shall not exceed the pound per hour (pph) and ton per year (tpy) emission limits in Table A107.A and shall demonstrate compliance with these limits by calculating and summarizing these emission rates as required in recordkeeping. Monitoring: A gas flowmeter and flow totalizer, equipped with a chart recorder or electronic data logger, shall be installed in the flare line to measure and record the total standard cubic feet (scf) of all gas (process gas, purge gas, pilot gas, and supplemental fuel gas) sent to the flare during each hour and each month. The permittee shall measure the H2S content, the total sulfur content, the VOC content, and the heating value (Btu/scf) of the gas sent to the flare for combustion during SSM and malfunction events. H2S shall be measured on each of the inlet gas types/streams using a stain tube of the appropriate size range or an inline H2S monitor. The flow meter and flow totalizer shall be operated, calibrated, and maintained as specified by the manufacturer and as necessary to ensure correct and accurate readings. If used, the inline monitor shall be operated, calibrated, and maintained as specified by the manufacturer and as necessary to ensure correct and accurate readings. Recordkeeping: The following records shall be kept: • stain tube and/or inline H2S measurements • annual gas analysis • both the hourly and monthly volume (scf) of gas sent to the flare for SSM or malfunction events. Each event, the permittee shall record and summarize in a table format the following. • H2S and the total sulfur content • percent VOC content • gas heating value (Btu/scf) • the maximum hourly gas flow rate (scf/hr) that occurred • each hourly gas flow rate (scf/hr) for any hour(s) that exceeded any pph emission limit • the total scf of gas sent to the flare • the monthly rolling 12-month total of gas sent to each flare (scf/yr) Each month, the permittee shall record all routine and predictable startups, shutdowns, and scheduled maintenance events and shall also meet the recordkeeping requirements in General Condition B109 of this permit, except the requirement to record the start and end times of SSM events shall not apply. Records of flowmeter, totalizer, and inline monitor certifications, calibrations, documentation of the manufacturer’s recommended calibration / maintenance schedule, breakdowns, reasons for the EPA Inspection Report - Page 895 of 1969 breakdown, and corrective actions taken shall be maintained. Each month, to demonstrate compliance with both the SSM and malfunction emission limits, the permittee shall calculate and summarize the maximum pph emission rate, any pph emission rate exceeding the permitted limits, and the monthly rolling 12-month total ton per year emission rates of NOx, CO, VOC, SO2, and H2S for both SSM and malfunction events, using the following information: • the H2S content, total sulfur content, VOC content, and the gas heating value (MMBtu/scf) from the most recent H2S measurements and gas analyses • the emission factors used to calculate NOx and CO • the maximum hourly gas flow rate (scf/hr) • each hourly gas flow rate (scf/hr) for any hour(s) that exceeded any pph emission limit during the month, including the dates and times of these occurrences • the monthly rolling 12-month total of gas sent to the flare (scf/yr) For each event, the permittee shall record whether the emissions are due to SSM and/or malfunction. If the emissions are due to malfunction, the permittee shall indicate whether the emissions resulting from the event are included in the amount allowed by this permit’s malfunction limit or whether the event is reported under 20.2.7 NMAC. Reporting: The permittee shall report according to Condition B110. A108 Facility: Allowable Operations A. This facility is authorized for continuous operation. Monitoring, recordkeeping, and reporting are not required to demonstrate compliance with continuous hours of operation. A109 Facility: Reporting Schedules A. The permittee shall report according to the Specific Conditions and General Conditions of this permit. B. In addition to the reports required by the applicable NSPS, NESHAP and MACT Subparts (including any voluntary programs referencing NSPS, NESHAP, or MACT Subparts) and by the applicable parts of 20.2 NMAC, the following information shall be submitted to the Department. The reports shall be submitted to the Air Quality Bureau within forty five (45) days of the end of each calendar quarter. If any reports indicate potential non-compliance with the terms of this permit, the Bureau may impose a more frequent reporting time-frame. The Department shall handle any confidential information in accordance with the provisions of 20.2.1.115 NMAC. C. Reporting required by the Consent Decree (not an exhaustive listing) (1) The permittee shall notify the Department’s Enforcement Section, Air Quality Bureau in writing of the annual progress of installation of NOx Control Technology required by Paragraph 16 of the Consent Decree. The report shall be submitted to the EPA and EPA Inspection Report - Page 896 of 1969 the NMED on or before December 31st of each calendar year commencing with the year 2002. (CD ¶16.E) (2) No later than forty-five (45) days following the end of an AG Flaring or TG Incident, the permittee shall submit to EPA and the NMED a report that sets forth the items detailed in the Consent Decree. (CD ¶20, CD¶21) A110 Facility: Fuel and Fuel Requirements A. Fuel, Fuel Sulfur, and NSPS J, Ja Sulfur Requirements (See Tables 103.E, H, I, & K, Summary of Applicable Requirements) Requirement: (1) To comply with NSPS Subpart J, NSPS Subpart Ja, and the PSD BACT requirements in A100.B(7), the permittee shall install, calibrate and maintain a continuous monitoring system (CMS) to continuously measure and record either the hydrogen sulfide (H2S) in the refinery fuel gas streams being burned in the Heaters and Boilers or the concentration of sulfur dioxide emissions to the atmosphere. (2) All stationary combustion equipment shall be fired with NSPS quality fuel gas with a maximum H2S content of 0.1 grains/dscf (approx. 162 ppmv), based on an hourly rolling 3-hour average. (3) All stationary combustion equipment shall not combust gas with an annual average sulfur content exceeding 0.037 grains/dscf (approx. 60 ppmv) as a daily rolling 365-day average. (4) All stationary combustion equipment shall be affected facilities, as defined in NSPS 40 CFR Part 60, Subparts A and J or Ja, if refinery-produced fuel gas is combusted in the heaters and boilers, and shall comply with all applicable requirements of NSPS Subparts A and J or Ja. (See Table 103.E, Summary of Applicable Requirements) Monitoring: (1) The permittee shall install, certify, calibrate, maintain and operate a fuel gas continuous monitoring system (CMS) at the fuel gas mix drum outlet in accordance with the requirements of 40 CFR §§ 60.11, 60.13, and Part 60 Appendix A, and the applicable performance specification of 40 CFR Part 60 Appendices B and F. (2) The following CMS shall be certified initially and recertified annually: • D-0019 Low Pressure Fuel Gas H2S CMS • D-0770 High Pressure Fuel Gas H2S CMS (3) As required by the EPA-approvable alternative monitoring procedure (AMP), CCR off-gas streams that enter the refinery fuel gas system downstream of the H2S CMS shall be monitored quarterly for H2S using gas detector tubes or an equivalent method as follows: (a) CCR stabilizer off gas stream, (b) H2 recycle gas stream, and c) CCR feed stream. EPA Inspection Report - Page 897 of 1969 Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subparts A, J, and Ja. (1) Records of the quantity of the refinery fuel gas and the monthly average heating value of the refinery fuel gas. This is used to demonstrate compliance with lb/mmBTU limits and lb/hr limits shown in Table 106.A. (permit limit) (2) Records of repairs, maintenance, and calibrations performed for the instruments that measure flow or concentration for an applicable permit limit shall be kept. Examples include, but are not limited to, CMS, acid gas flow meters, and fuel gas flow meters. (40 CFR 60, Appendix F) (3) Records shall be kept of Alternative Monitoring Plan (AMP) H2S analyses of the CCR offgas streams that enter the refinery fuel gas system downstream of the fuel gas H2S CMS. (NSPS J or Ja) Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subparts A, J, and Ja, and Section B110. A111 Facility: 20.2.36 NMAC – repealed 1/29/2016 A. Facility: 20.2.36 NMAC was repealed by EIB in Fall of 2015 and the effective date is 1/29/2016. A112 Facility: 20.2.37 NMAC A. 20.2.37 NMAC Requirement: If this regulation is repealed, then this regulation shall no longer apply as of the effective date of the repeal. (1) Section 200.A (Mercaptans) and section 200.B (Hydrogen Sulfide) apply to mercaptan and H2S emissions from the refinery. Section 200.C applies to FL-0400, FL-0401, FL-0402, FL-0403, and FL-0404, and requires an alarm in good working order to signal non-combustion of the gas. (2) Section 201.A (CO), applies to the refinery's FCC regenerator stack. The owner or operator of an existing petroleum processing facility shall not permit, cause, suffer or allow carbon monoxide emissions to the atmosphere from a catalyst cracking recirculation or regeneration unit in excess of 20,000 ppm by volume in the undiluted effluent gas stream or streams. (3) Section 202.C(1) (PM), The owner or operator of a new petroleum processing facility shall not permit, cause, suffer or allow particulate matter emissions to the atmosphere from the catalytic cracking regenerator vessel in excess of 1.0 Kg/1000 Kg (1.0 lb/1000 lb) of coke burnoff or visible emissions of thirty percent (30%) opacity or greater except for one six-minute average opacity reading in any one-hour period. (4) Section 203 (Ammonia, undiluted emissions ≤ 25 ppmv) applies to all emission points of the refinery. The owner or operator of a petroleum processing facility shall not permit, cause, suffer or allow ammonia emissions to the atmosphere in excess of 25 ppm by volume in the undiluted EPA Inspection Report - Page 898 of 1969 effluent gas stream or streams. (5) Section 204 (Hydrocarbon Separation Facility) applies to all oil/water separators at the refinery. Compliance with this condition is met by complying with the applicable NSPS Subpart QQQ requirements. (6) Section 205 (Facilities - Storage - Handling - Pumping - Blowdown System) applies to certain of the following: storage tanks for organic compounds, loading and unloading of organic compounds, seals on pumps and compressors, and disposal (flaring) of hydrocarbon gases. The permittee shall not permit, cause, suffer or allow the operation of a blowdown system without disposing of the gases in a manner which will minimize hydrocarbon emission to the atmosphere. If combustion is the means of disposal, it shall be by: smokeless flare; or any other method that is equally effective to achieve complete combustion. (20.2.37.205.E NMAC) Monitoring: (1) For Units FL-0400, FL-0401, FL-0402, FL-0403, and FL-0404: The permittee shall install and maintain a flare pilot flame monitoring system. (20.2.37.200.A.2 NMAC) (2) A CO CMS has been installed to monitor the emissions from the FCC. (3) The annual Stack test on Unit FCC (lb/hr PM emissions) and the calculated Coke burn rate will be used for the annual determination of pounds of PM per 1000 pounds of Coke burned. (4) None (5) No additional monitoring since compliance is met by complying with the applicable NSPS Subpart QQQ requirements. See other conditions of this permit for applicable NSPS or MACT requirements. (6) Compliance is demonstrated through NSPS K, NSPS Ka, NSPS Kb, or MACT CC for Tanks; through MACT CC for Loading Racks; through NSPS GGG, NSPS GGGa or MACT CC for Pumps and Compressors; and through NSPS Subpart A for Blowdowns. Recordkeeping: (1) Pilot flame monitoring records (2) CO CMS measurements (3) Copy of annual coke burn rate determination and stack test report (4) None (5) Applicable NSPS Subpart QQQ requirements (6) Applicable NSPS K, NSPS Ka, NSPS Kb, or MACT CC for Tanks; through MACT CC for Loading Racks; through NSPS GGG, NSPS GGGa or MACT CC for Pumps and Compressors; and through NSPS Subpart A for Blowdowns requirements Reporting: The permittee shall report in accordance with applicable NSPS or MACT requirements and Section B110. B. 20.2.61 NMAC Opacity Limit (Combustion Units) EPA Inspection Report - Page 899 of 1969 Requirement: Visible emissions from all stationary combustion emission stacks shall not equal or exceed an opacity of 20 percent in accordance with the requirements at 20.2.61.109 NMAC. This regulation does not apply as long as 20.3.37 NMAC is still in effect per 20.2.61.109 NMAC. If 20.2.37 NMAC is repealed, 20.2.61 NMAC will apply to these units within 120 days of the effective date of the 20.2.37 NMAC repeal. Monitoring: Use of natural gas fuel constitutes compliance with 20.2.61 NMAC unless opacity equals or exceeds 20% averaged over a 10-minute period. When any visible emissions are observed during operation other than during startup mode, opacity shall be measured over a 10minute period, in accordance with the procedures at 40 CFR 60, Appendix A, Reference Method 9 (EPA Method 9) as required by 20.2.61.114 NMAC, or the operator will be allowed to shut down the equipment to perform maintenance/repair to eliminate the visible emissions. Following completion of equipment maintenance/repair, the operator shall conduct visible emission observations following startup in accordance with the following procedures: • Visible emissions observations shall be conducted over a 10-minute period during operation after completion of startup mode in accordance with the procedures at 40 CFR 60, Appendix A, Reference Method 22 (EPA Method 22). If no visible emissions are observed, no further action is required. If any visible emissions are observed during completion of the EPA Method 22 observation, subsequent opacity observations shall be conducted over a 10-minute period, in accordance with the procedures at EPA Method 9 as required by 20.2.61.114 NMAC. For the purposes of this condition, Startup mode is defined as the startup period that is described in the facility’s startup plan. Recordkeeping: If no visible emissions were observed, none. If any visible emissions observations were conducted, the permittee shall keep records in accordance with the requirements of Section B109 and as follows: • For any visible emissions observations conducted in accordance with EPA Method 22, record the information on the form referenced in EPA Method 22, Section 11.2. For any opacity observations conducted in accordance with the requirements of EPA Method 9, record the information on the form referenced in EPA Method 9, Sections 2.2 and 2.4. Reporting: The permittee shall report in accordance with Section B110. • A113 Facility: 20.2.38 NMAC A. 20.2.38 NMAC Requirement: 20.2.38 NMAC (Hydrocarbon Storage Facilities, 11/30/95) applies to the refinery as follows: 1. Section 109 (Tank Storage Associated with Petroleum Production or Processing Facility [Sour Hydrocarbon Liquids]) applies to the loading of hydrocarbons containing H2S. 2. Section 110 (Tank Battery or Storage Facility - Within Municipality [Sour Hydrocarbon Liquids]) applies to certain tanks storing sour hydrocarbon liquids whose vapors contain >24 ppm EPA Inspection Report - Page 900 of 1969 H2S. 3. Section 113 (New Tank Battery and the Pecos-Permian Interstate Air Quality Control Region [Sour Hydrocarbon Liquids]) applies to certain tanks storing sour hydrocarbon liquids whose vapors contain >24 ppm H2S. Monitoring: 1. None 2. and 3. Demonstrated through NSPS K, Ka, Kb, and MACT CC floating roof seal inspection. Recordkeeping: 1. Records of Tank design showing inlet piping connections. 2. and 3. No additional requirements other than applicable requirements of NSPS and MACT. Reporting: The permittee shall report in accordance with Section B110. A114 Facility: Relocation Requirements – Not Required A115 Alternative Operating Scenario – Not Required A116 Compliance Plan – Not Required A117 Reducing Facility Emissions A. Upon the issuance of this permit, the following Units removed from this permit shall not be authorized to operate whether installed or never constructed: T-0013, T-0058, T-0404, T0405, T-0409, T-0810, and T-0078. A118 Facility: MACT Subpart UUU A. 40 CFR 63, Subpart UUU FCC, FUG-70-CCR, SRUs 1, 2, and 3 Requirement: The permittee shall comply with all applicable requirements of 40 CFR 63, Subpart UUU, National Emission Standards for Hazardous Air Pollutants for Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units, for all affected sources shown in Tables 103H&I attached. (63.1560 and 63.1570). Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart UUU. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63, Subpart UUU. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 63, Subpart UUU. EPA Inspection Report - Page 901 of 1969 A119 40 CFR 61 Subpart FF, National Emission Standard for Benzene Waste Operations A. 40 CFR 61 Subpart FF, National Emission Standard for Benzene Waste Operations (Units subject in Table 103.C & G) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 61, Subpart FF, National Emission Standard for Benzene Waste Operations for the affected sources in Tables 103.C, G. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 61, Subpart FF. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 61.356. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 61.357. EQUIPMENT SPECIFIC REQUIREMENTS OIL AND GAS INDUSTRY A200 Oil and Gas Industry A. This section has common equipment related to most Oil and Gas Operations. A201 Engines A. Maintenance and Repair Monitoring (Units G-0100, G-0101, V-0543, V-0545, V-0546, E8010, E-0600W, E-0601M, E-0602E, E-0603, and E-0901; Units G-0100, G-0101, V-0543, V-0545, V-0546, E-8010, E-0600W, E-0601M, E-0602E, E-0603, and E-0901) Requirement: These units are subject to Title V since they are subject to NSPS and/or MACT requirements. No emission limits were established since their emissions are small. The permittee shall ensure these units are properly maintained and repaired. Monitoring: Maintenance and repair shall meet the minimum manufacturer's or permittee's recommended maintenance schedule. Activities that involve maintenance, adjustment, replacement, or repair of functional components with the potential to affect the operation of an emission unit shall be documented as they occur for the following events: (1) Routine maintenance that takes a unit out of service for more than two hours during any twenty-four hour period. (2) Unscheduled repairs that require a unit to be taken out of service for more than two hours in any twenty-four hour period. EPA Inspection Report - Page 902 of 1969 Recordkeeping: The permittee shall maintain records in accordance with Section B109, including records of maintenance and repairs activities and a copy of the manufacturer’s or permittee’s recommended maintenance schedule. Reporting: The permittee shall report in accordance with Section B110. B. 40 CFR 63, Subpart ZZZZ (Units G-0100, G-0101, V-0543, V-0545, V-0546, E-8010, E0600W, E-0601M, E-0602E, E-0603, and E-0901) (Units subject in Table 103.J) Requirement: The units listed as subject in Table 103.J are subject to 40 CFR 63, Subpart ZZZZ and the permittee shall comply with all applicable requirements of Subpart A and Subpart ZZZZ. Monitoring: The permittee shall comply with all applicable monitoring requirements of 40 CFR 63, Subpart A and Subpart ZZZZ. Recordkeeping: The permittee shall comply with all applicable recordkeeping requirements of 40 CFR 63, Subpart A and Subpart ZZZZ, including but not limited to 63.6655 and 63.10. Reporting: The permittee shall comply with all applicable reporting requirements of 40 CFR 63, Subpart A and ZZZZ, including but not limited to 63.6645, 63.6650, 63.9, and 63.10. C. 40 CFR 60, Subpart IIII (Diesel Engines subject in Table 103.J) Requirement: The units listed as subject in Table 103.J are subject to 40 CFR 60, Subparts A and IIII and shall comply with the notification requirements in Subpart A and the specific requirements of Subpart IIII. Monitoring: The permittee shall comply with all applicable monitoring requirements in 40 CFR 60, Subpart A and Subpart IIII, including but not limited to 60.4211. Recordkeeping: The permittee shall comply with all applicable recordkeeping requirements in 40 CFR 60, Subpart A and Subpart IIII, including but not limited to 60.4214. Reporting: The permittee shall comply with all applicable reporting requirements in 40 CFR 60, Subpart A and Subpart IIII, including but not limited to 60.4214. A202 Glycol Dehydrators – Not Required A203 Tanks A. NSPS Subpart K, Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978 (Tanks subject in Table 103.C) Requirement: The permittee shall comply with all applicable requirements of NSPS Subparts A & K for the affected sources in Table 103.C. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart K. EPA Inspection Report - Page 903 of 1969 Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart K. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart K. B. NSPS Subpart Ka, Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984 (Tanks subject in Table 103.C) Requirement: The permittee shall comply with all applicable requirements of NSPS Subpart Ka for the affected sources in Table 103.C. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart Ka. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart Ka. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart Ka. C. NSPS Subpart Kb, "Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After January 23, 1984" (Tanks subject in Table 103.C) Requirement: The permittee shall comply with all applicable requirements of NSPS Subpart Kb for the affected sources in Table 103.C. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart Kb. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart Kb. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart Kb. D. MACT Subpart CC, “National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries” (Tanks subject in Table 103.C) Requirement: The permittee shall comply with all applicable requirements of MACT Subpart CC, “National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries” for all affected sources shown in Tables 103B, C, D, G attached. (63.640). Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63.655. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 63.655. EPA Inspection Report - Page 904 of 1969 E. Tank Throughput, Temperature, and VOC and H2S Limits (Units shown in Tables 106.B & C) Requirement: Compliance with the allowable throughput limits and emission limits in Table 106.D & E shall be demonstrated by not exceeding the monthly rolling 12-month total throughput to the unit(s) of gallons per year (barrels/year) shown in Table 106.D and not exceeding the allowable vapor pressure listed in Tables 106.B & C. Monitoring: The permittee shall monitor the monthly total throughput, maximum temperature once per month and the vapor pressure of each tank. Recordkeeping: The permittee shall record the monthly total throughput of liquids and the vapor pressure of each tank. Each month, during the first 12-months of monitoring, the permittee shall record the cumulative total liquid throughput and vapor pressure and after the first 12months of monitoring, the permittee shall calculate and record a monthly rolling 12-month total liquid throughput and the vapor pressure of each tank. The permittee has calculated the VOCs and H2S annually based on the 12-month total. Tank breathing and working emissions were calculated using the USEPA AP-42 Section 7.1 calculation methods. Emission rates computed using the same parameters, but with a different Department approved algorithm that exceed these values will not be deemed non-compliance with this permit. Records shall also be maintained in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. A204 Heaters/Boilers A. Operational Inspection (All heaters/boilers in Tables 103.E & 104.A) Requirement: Compliance with the allowable emission limits in Table 106.A shall be demonstrated by performing periodic inspections to ensure proper operations. Monitoring: The permittee shall conduct annual operational inspections to determine that the heater(s)/boiler(s) are operating properly. The operational inspections shall include operational checks for indications of insufficient excess air, or too much excess combustion air. These operational checks shall include observation of common physical indications of improper combustion, including indications specified by the heater/boiler manufacturer, and indications based on operational experience with the/these unit(s). Recordkeeping: The permittee shall maintain records of operational inspections, describing the results of all operational inspections noting chronologically any adjustments needed to bring the heater(s)/boiler(s) into compliance. The permittee shall maintain records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. Within ninety (90) days of permit issuance, the permittee shall submit for Department approval EPA Inspection Report - Page 905 of 1969 a procedure which the permittee will use to carry out the operational inspections. The permittee may at any time submit revisions for Department approval. B. Periodic Emissions Tests (Units Heaters H-0019, H-0020, H-0362, H-0363, H-0364, H2421, H-3402, H-3403, and H-5401) Requirement: Compliance with allowable emission limits in Table 106.A shall be demonstrated by performing periodic emissions tests. Monitoring: The permittee shall conduct annual periodic portable analyzer emission tests or EPA Reference Method Tests for NOx and CO. Test results that demonstrate compliance with the CO emission limits shall also be considered to demonstrate compliance with the VOC emission limits. Section B108 General Monitoring Requirements apply to this condition. The permittee shall meet the testing requirements in Section B111. Recordkeeping: Records of periodic emission tests shall include the flow rate and the stack gas exhaust temperature. If a combustion analyzer is used to measure NOx, CO, and/or excess air in the flue gas, records shall be kept of the make and model of the instrument and instrument calibration data. If an ORSAT apparatus or other gas absorption analyzer is used, the permittee shall record all calibration results. Records shall be kept of all raw data used to determine flue gas flow and of all calculations used to determine flow rates and emission rates. The permittee shall maintain records in accordance with Section B109, B110, and B111. Reporting: The permittee shall summarize in tabular form the results of the initial or subsequent periodic emissions tests for NOx and CO, specifying the mass emissions rates in pounds per hour. The table shall include the average concentration of all relevant pollutant species. The permittee shall report in accordance with Section B109, B110, and B111. C. Summary of Compliance Methods for Heaters and Boilers for Table 106.A, 20.2.33 NMAC, 20.2.37 NMAC (Boilers and Heaters in Tables 103.E and 104.A) Requirement: (1) Demonstrate compliance with Table 106.A Allowable Emissions. (2) 20.2.33 NMAC (Gas Burning Equipment – Nitrogen Dioxide, 10/31/02) applies to existing and new gas burning equipment having a heat input of greater than 1,000,000 million British Thermal Units per year. It applies to process heaters identified in Tables 103.E and 104.A. These units shall be equipped with burners emitting less than 0.2 lb NOx per MM Btu. Compliance with 20.2.33 NMAC is demonstrated by compliance with the NOx lb per MM Btu limits in Table A106.A. (3) Compliance with the particulate emission limitation set forth in 20.2.37.202.A NMAC. If 20.2.37 NMAC is repealed by the NM Environmental Improvement Board, then this requirement is not effective after the repeal dated. EPA Inspection Report - Page 906 of 1969 Monitoring: (1) The permittee shall monitor the fuel usage of the all boilers and heaters. The fuel usage shall be monitored for specific heaters and boilers subject to 20.2.33 NMAC. (2) For specific heaters and boilers subject to 20.2.33 NMAC, the permittee shall collect and analyze samples of the refinery fuel gas at least once per week. The refinery fuel gas analysis shall include the composition of the refinery fuel gas, the gross heating value, and the net heating value. (3) See Condition A110.A for H2S monitoring requirements. (4) All process heaters and boilers shall fire only refinery gas in accordance with Application, Section 2, Table 2-J. (5) For those combustion sources required to have a continuous monitoring system (CMS) (listed in (a) below), the permittee shall install, certify, calibrate, maintain, and operate the CMS for each required pollutant in accordance with the applicable requirements of 40 CFR 60 or 63. The hourly average CMS data, the refinery fuel gas usage data, and the refinery fuel gas composition data shall be used to estimate the actual emission rates. The following CMS shall be recertified annually: • Boiler B-0007 NOx and O2 CMS • Boiler B-0008 NOx and O2 CMS • Boiler B-0009 NOx and O2 and CO2 CMS • H-9851 NOx O2 CMS • H-2501 NOx O2 CMS (6) For those combustion sources required to conduct periodic stack exhaust testing as stated in Condition A204.B, the test reports shall be used to demonstrate compliance with the NOx, CO, and VOC limits in Table 106.A. (7) For those units and pollutants that are not required to have a CMS or a periodic stack test, (Units H-009, H-0011, H-0018, H-0028, H-0030, H-0040, H-0303, H-0312, H-0352, H-0353, H-0354, H-0355, H-0421, H-0464, H-0473, H-0600, H-0601, H-8801, H-8802, and H-3101) the permit application emission factor, the fuel usage, and the refinery fuel gas analysis shall be used to calculate the emission rates of NOx, CO, VOC, and PM. (8) If 20.2.37 NMAC is repealed by the NM Environmental Improvement Board, then this requirement is not effective after the repeal dated. Compliance with the particulate emission limitation set forth in 20.2.37.202.A NMAC shall be determined as specified in 20.2.37.202.D(3) NMAC. Combustion of only gaseous fuel has been approved by the Department as the compliance method under 20.2.37.202.D(3) NMAC. Recordkeeping: The permittee shall maintain the following records: (1) By March 31, the annual fuel usage for all boilers and heaters for the previous calendar year. (2) By March 31, the average fuel composition and heating value for all boilers and heaters for the previous calendar year. EPA Inspection Report - Page 907 of 1969 (3) For those units required to have a CMS (B-0007, B-0008, B-0009, H-9851 and H-2501), the CMS hourly average data. (4) For those units required to conduct periodic stack exhaust testing, the periodic test report. (5) For all boilers and heaters, a summary spreadsheet shall be maintained comparing the actual annual emissions with the allowable emission limits expressed in tons per year and lb/MMBtu using the appropriate method of compliance demonstration. This spreadsheet shall be updated by March 31 of each year for the previous calendar year. Reporting: The permittee shall report in accordance with Sections B110. D. Consent Decree NOx Emission Limits for Boilers B-0007 and B-0008 Requirement: (1) In accordance with the Consent Decree lodged December 20, 2001, NOx emissions from boilers B-0007 (no later than December 31, 2002) and B-0008 (no later than December 31, 2003) shall be less than 0.06 lb/MMBtu during any hourly rolling 3-hour period. Demonstration of compliance with the NOx limit for B-0007 and B-0008 shall be established by averaging the CMS Data over any 3-hour period and comparing the average concentration to the parametric limit of ≤ 42.1 ppm NOx, corrected to 6.1% O2 as determined by the CMS. (CD¶16.D) This also satisfies the requirement in 20.2.33.108.A NMAC that NOx emissions shall not exceed 0.2 lb/MMBTU. (2) Navajo is authorized to operate all three boilers (B-0007 and B-0008) simultaneously as needed. Monitoring: For the Controlled Boilers (B-0007, B-0008) as listed in the Consent Decree , continuous compliance with their respective NOx permit emissions limits shall be demonstrated by monitoring as follows: (CD¶16.C) (1) For boilers (B-0007 and B-0008) with a heat input capacity greater than 150 MMBTU/hr of HHV, the permittee shall install or continue to operate CMS to measure NOx and O2. Each CMS shall be installed, certified, calibrated, maintained, and operated in accordance with the requirements of 40 CFR 60.11, 60.13, and Part 60 Appendix A and the applicable performance specification test of 40 CFR Part 60 Appendices B and F. These CMS shall be used to demonstrate compliance with emission limits. The permittee shall make CMS and process data available to the applicable Federal and State Agencies upon demand as soon as practicable; (CD¶16.C.i) Recordkeeping: The permittee shall keep records of the CMS recertification’s monitored in Condition A204.B, Summary of Compliance. Reporting: The permittee shall report in accordance with Section B110. E. NOx Monitoring and Testing for Controlled Heaters Subject to the Consent Decree (Units H-0020, H-0352, H-0353, H-0354, H-0600, and H-0601) EPA Inspection Report - Page 908 of 1969 Requirement: For the Controlled Heaters as listed in the Consent Decree, continuous compliance with all NOx emissions limits shall be demonstrated by monitoring as follows. (CD¶16.C) Monitoring: (1) For heaters with a heat input capacity of equal to or less than 150 MMBTU/hr (HHV) but greater than 100 MMBTU/hr (HHV), Navajo shall (a) install or continue to operate CMS to measure NOx and O2 by no later than the date of the installation of the applicable NOx Control Technology on the heater or boiler; or (b) submit for EPA approval, by no later than 60 days after the date of installation of the applicable NOx Control Technology on the heater or boiler, a proposal for monitoring based on operating parameters, including but not limited to, firebox temperature, air preheat temperature, heat input rate, and combustion O2. Navajo shall evaluate the necessity of using firebox or bridgewall temperatures and additional operating parameters and agrees to use such parameters as a means of monitoring performance where Navajo and EPA mutually-agree to their effectiveness. (CD¶16.C.ii). As of January 23, 2014 (notarized date of application), there are no heaters or boilers at the Artesia Refinery with a capacity of equal to or less than 150 MMBTU/hr (HHV) but greater than 100 MMBTU/hr (HHV) subject to Monitoring requirement (1). (2) For heaters with a heat input capacity of equal to or less than 100 MMBTU/hr of HHV, the permittee shall conduct an initial performance tests for NOx. The results of these tests shall be reported based upon an average of three (3) one-hour testing periods and shall be used to develop representative operating parameters for each unit, which will be used as indicators of compliance. (CD¶16.C.iii). This condition applies to the following heaters: • Heaters H-0352, H-0353, and H-0354 • Heater H-0020 • Heaters H-0600 and H-0601 The permittee has completed all of the initial performance tests. (3) For heater H-0601 compliance shall be demonstrated by continuously monitoring stack oxygen (O2) to maintain a 3-hour average below 6.0 vol%. As a further check of compliance, Navajo shall monitor stack NOx at least twice a month using a portable analyzer to assure that the measured NOx value does not exceed the compliance threshold of 38 ppmv NOx. (CD¶16.C.iii) Recordkeeping: (1) The permittee shall keep records of the Fuel firing rates and Sulfur limits monitored for Condition A110.A. (2) The permittee shall keep records of the initial performance tests. (3) The permittee shall keep records of the stack oxygen monitoring and the portable analyzer tests. EPA Inspection Report - Page 909 of 1969 Reporting: The permittee shall report in accordance with Section B110. Condition B.111.D(7) does not apply to portable analyzer tests. F. NOx Monitoring and Testing for Heaters and Boilers permitted after the Consent Decree (Units Heaters H-0019, H-0362, H-0363, H-0364, H-2421, H-3402, H-2501, H-8801/8802, H-9851, and B-0009) Requirement: For the Heaters permitted after the Consent Decree, continuous compliance with their respective NOx permit emissions limits in Table 106.A shall be demonstrated by monitoring as follows. Monitoring: (1) For heaters with a heat input capacity greater than 150 MM Btu/hr (LHV Basis), the permittee shall install and operate CMS to measure NOx and O2 by the startup date of each heater or boiler. Each CMS shall be installed, certified, calibrated, maintained, and operated in accordance with the requirements of 40 CFR 60.11, 60.13, and Part 60 Appendix A and the applicable performance specifications of 40 CFR Part 60 Appendices B and F. These CMS shall be used to demonstrate compliance with emission limits. The permittee shall make CMS and process data available to the applicable Federal and State Agencies upon demand as soon as practicable. Condition A204.E(1) currently includes heater H-9851 and boiler B-0009. (2) For heaters with a heat input capacity of equal to or less than 150 MM Btu/hr (LHV) but greater than 100 MM Btu/hr (LHV), Navajo shall: (a) install and operate CMS to measure NOx and O2 by the startup date of each heater; or (b) submit to the Permit Program Manager for NMED approval, by no later than 90 days after the startup date of each heater, a proposal for monitoring based on operating parameters. Operating parameters to consider include, but are not limited to, firebox temperature, air pre-heat temperature, heat input rate, and combustion O2. Navajo agrees to use such parameters as a means of monitoring performance. Condition A204.F(2) applies to heaters H-2501 and H-8801/8802 (3) For heaters with a heat input capacity of equal to or less than 100 MM Btu/hr (LHV basis), the permittee shall conduct an initial performance test by no later than 180 days after the startup date. The results of this test shall be reported based upon an average of three (3) one-hour testing periods and shall be used to develop representative operating parameters for each unit, which will be used as indicators of compliance. This condition applies to the following heaters: • • • • Heaters H-0362, H-0363, H-0364, and H-2421 Heater H-0019 Heaters H-3402 (AMP approved by EPA, see (4)) , initial performance test completed on July 10, 2013 Heater H-3403, initial performance test completed on April 30, 2013 (4) US EPA has approved an Alternative Monitoring Plan (AMP) for Unit H-3402 for utilizing the oxygen monitor on the H-3402 Unit 34 Hydrocracker Reboiler 1 as a parametric means for EPA Inspection Report - Page 910 of 1969 demonstrating compliance with NSPS Ja, NOx monitoring via a CMS. In accordance with the AMP, the permittee shall accomplish the following: (a) Install flow indication on the fuel line to provide historical data of the fuel to the Mild Hydrocracker (Unit 34) by January 1st, 2015. (b) Monitor the process historical data of the HEP purchased natural gas pressure, and the high pressure fuel balance drum (D-0770). (c) Upgrade the existing the Mild Hydrocracker (Unit 34) Reboiler Heater (H-3402) oxygen monitor to perform daily calibrations as required in 40 CFR60.13(d)(1). (Note that the sample placement does not conform to CMS requirements for process reasons). (d) Conduct biennial performance tests according to the requirements in 40CFR 60.104a(i). (e) Establish a maximum or curve excess O2 operating limit – (MOPV) as required under 40 CFR60.107a(c)(6) utilizing the existing monitor. (f) Include Reboiler Heater (H-3402) hours of refinery fuel gas usage and any deviations during such time as required by 40 CFR 60.7 for periodic reporting. Recordkeeping: (1) The permittee shall keep records of the fuel firing rates and sulfur limits monitored for Condition A110.A. (2) The permittee shall keep records of the CMS recertification’s monitored in Condition A204.B, Summary of Compliance. (3) The permittee shall keep records of the performance tests. (4) The permittee shall keep records of the implementation of the AMP and all required monitoring specified in the AMP. Reporting: The permittee shall report in accordance with Section B110. G. NSPS Subpart Db, Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units (Boilers and heater subject in Table 103.E) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A & Db (NOx-60.44b, SO2-60.42b, & PM-60.43b) for the affected sources in Table 103.E. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60.48b, Subpart Db. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60.49b, Subpart Db. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60.49b, Subpart Db. Compliance Test: The permittee shall comply with the methods and procedures stipulated in 40 CFR 60, Section 60.45b and 60.46b. EPA Inspection Report - Page 911 of 1969 H. NSPS Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units (Boilers and heater subject in Table 103.E) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A & Dc (NOx-60.44c, SO2-60.42c, & PM-60.43c) for the affected sources in Table 103.E. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60.47c, Subpart Dc. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60.48c, Subpart Dc. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60.48c, Subpart Dc. Compliance Test: The permittee shall comply with the methods and procedures stipulated in 40 CFR 60, Section 60.44c and 60.45c. I. NSPS Subpart J, Standards of Performance for Petroleum Refineries (Boilers and heater subject in Table 103.E) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A & J for the affected sources in Table 103.E. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart J. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart J. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart J. J. NSPS Subpart Ja, Standards of Performance for Petroleum Refineries for which Construction, Reconstruction, or Modification Commenced After May 14, 2007 (Boilers and heater subject in Table 103.E) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 60, Subparts A & Ja for the affected sources in Table 103.E. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart Ja. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart Ja. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart Ja. K. BACT NOx Limit, Continuous Monitoring System (CMS) (Unit B-0009) Requirement: The permittee shall comply with the allowable emission limits in Table 106.A and Condition A106.E that represent NOx BACT limits for the BACT requirements. EPA Inspection Report - Page 912 of 1969 Monitoring: (1) The Permittee shall comply with the CMS monitoring as detailed in Condition A204.D. (2) The permittee shall conduct an EPA Method test within six (6) months of startup using EPA reference test methods in 40 CFR 60 for NOx and O2 and CO2. Data from the CMS RATA testing may be used to satisfy this testing requirement. Recordkeeping: (1) The permittee shall keep records of the CMS initial calibration and recertification monitored in Condition A204.B, Summary of Compliance. (2) Records of EPA Methods tests shall be maintained for the Boiler. Reporting: (1) The permittee shall report in accordance with Section B110, to include the CMS initial calibration and recertification. (2) The permittee shall summarize in tabular form the results of the EPA Methods tests for NOx and O2 and CO2, specifying the emissions rates in pounds per hour and lb/MMBtu. The table shall include the average concentration of all relevant pollutant species. L. MACT Subpart DDDDD, Industrial, Commercial, and Institutional Boilers and Process Heaters (Boilers and heater subject in Table 103.E) Requirement: The units are subject to 40 CFR 63, Subpart DDDDD and the permittee shall comply with the applicable requirements of 40 CFR 63, Subpart A and Subpart DDDDD. Monitoring: The permittee shall comply with all applicable monitoring and testing requirements of 40 CFR 63, Subpart A and Subpart DDDDD. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63, Subpart A and Subpart DDDDD. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 63, Subpart A and Subpart DDDDD. M. EPA Methods Test (Unit B-0009) Requirement: Compliance with CO BACT Limit and allowable emission limits in Table 106.A shall be demonstrated by emissions tests ensuring the unit is operating correctly and within desired parameters. Monitoring: The permittee shall conduct an EPA Method test no later than 180 days after startup using EPA reference test methods in 40 CFR 60. Emission testing is required for CO. Test results that demonstrate compliance with the CO emission limits shall also be considered to demonstrate compliance with the VOC emission limits. Recordkeeping: Records of EPA Methods tests shall be maintained for the Boiler. EPA Inspection Report - Page 913 of 1969 Reporting: The permittee shall report in accordance with the requirements of Section B111.D and summarize in tabular form the results of the EPA Methods test for CO, specifying the emissions rates in pounds per hour. The table shall include the average concentration of all relevant pollutant species. N. Verification of Energy Efficiency BACT Control Requirements (Unit B-0009) Requirement: The permittee shall comply with the allowable emission limits and the following BACT requirements. 1. Operation and Maintenance (BACT #6): a. Periodic Boiler Tuning – The boiler shall be tuned annually to maintain optimal thermal efficiency. b. Periodic Boiler Inspection and Repair for air leakage – The boiler shall be inspected annually to maintain optimal thermal efficiency. c. Periodic Boiler Inspection and Cleaning for tube fouling – The boiler shall be inspected annually and necessary cleaning performed to prevent tube fouling. 2. Next Generation Ultra-low-NOx high efficiency burners (NGULNB) (#5) shall be installed in the boiler design. 3. Flue gas economizer (BACT #2) – A heat exchanger shall be installed to recover heat from the exhaust gas to preheat incoming boiler feedwater to attain industry standard performance (IMO) for thermal efficiency. 4. Boiler insulation (BACT #4) – The boiler shall be designed and installed with boiler insulation to an optimum insulation thickness and material to achieve maximum energy efficiency. The OMP shall include the insulation design and maintenance schedule. 5. Oxygen Trim Control (BACT #7) – An Oxygen Trim Control system shall be designed and installed on the boiler to monitor oxygen concentration in the flue gas, and the inlet air flow is adjusted to maximize thermal efficiency. 6. Boiler blowdown minimization using manual analysis (BACT #3) – The Operation and Maintenance Plan (OMP) shall include methods and procedures to minimize blowdowns from the boiler to keep emissions at a minimum. 7. Condensate recovery (BACT #8): Condensate shall be recovered as represented in the application to achieve maximum energy efficiency. Condensate recovery shall be maximized through annual steam trap inspections and repairs. Monitoring: The Permittee shall develop an Operation and Maintenance Plan (OMP) to include at least the requirements listed above within 12-months of commencement of operations. The Permittee shall review the OMP annually to ensure it’s effectiveness in meeting the requirements above and recommend changes. Recordkeeping: (1) Records demonstrating compliance with the energy efficiency requirement shall be recorded EPA Inspection Report - Page 914 of 1969 and summarized in the OMP. (2) The Permittee shall maintain a copy of the OMP onsite and available for inspection. Reporting: (1) The permittee shall notify the Department when the OMP has been prepared and available for review. (2) The permittee shall report in the semi-annual report a summary of actions covered in accordance with the OMP, and in accordance with Section B110. O. Periodic Emissions Tests (Unit B-009, CO BACT Limit) Requirement: Compliance with the CO BACT Limit and allowable emission limits in Table 106.A shall be demonstrated by performing periodic emissions tests. Monitoring: The permittee shall conduct periodic portable analyzer emission tests or EPA Reference Method Tests for CO at the intervals in the following schedule: First Test --- in accordance with the schedule in Section B111.A(2). Second Test --six (6) months after the first test is completed. All subsequent testing shall be done annually. Section B108 General Monitoring Requirements apply to this condition. The permittee shall meet the testing requirements in Section B111. Recordkeeping: Records of periodic emission tests shall include the boiler fuel flow rate and the stack gas exhaust temperature. If a combustion analyzer is used to measure CO, and/or excess air in the flue gas, records shall be kept of the make and model of the instrument and instrument calibration data. If an ORSAT apparatus or other gas absorption analyzer is used, the permittee shall record all calibration results. Records shall be kept of all raw data used to determine flue gas flow and of all calculations used to determine flow rates and emission rates. The permittee shall maintain records in accordance with Section B109, B110, and B111. Reporting: The permittee shall summarize in tabular form the results of the initial or subsequent periodic emissions tests for CO, specifying the mass emissions rates in pounds per hour. The table shall include the average concentration of all relevant pollutant species. The permittee shall report in accordance with Section B109, B110, and B111. A205 Turbines not required A206 Flares A. FL-0400, FL-0403 Requirement: (1) An alarm system in good working order shall be connected to Flare FL-0403 which will signal non-combustion of the gas. EPA Inspection Report - Page 915 of 1969 (2) The acid gas flow meter for flare FL-0400 or FL-0403 shall be operated and calibrated at a frequency and by the procedure specified by the manufacturer. A chart recorder or data logger (electronic storage) shall continuously record the amount of gas measured by the flow meter. Monitoring: (1) The fuel gas required to provide supplemental heat to either Flare FL-0400 or FL-0403 as required under A105.B shall be monitored during flaring by a flow meter. (2) The flow meter shall be operated continuously 24 hours per day, 365 days per year except for periods of flow meter maintenance or repair. (3) The flow meter and flow totalizer shall be operated, calibrated, and maintained as specified by the manufacturer and as necessary to ensure correct and accurate readings. If used, the inline monitor shall be operated, calibrated, and maintained as specified by the manufacturer and as necessary to ensure correct and accurate readings. The upper range of the flow meter shall be sufficient to record the highest expected flow rate of fuel gas sent to flare. (4) The reading of this flow meter and the flow meter to measure acid gas flow as required under Condition A105.B shall be used to determine compliance with emission limits at A106.C. Recordkeeping: (1) Records of all periods of operation during which the flare pilot flame is absent as included in the MACT subpart CC semi-annual reports. (2) Records of the quantity of supplemental fuel used during each acid gas flaring incident to provide supplemental heat to flare FL-0400 or flare FL-0403. (3) The permittee shall maintain records from the flow meter of the amount of gas sent to the flare. Reporting: The permittee shall report in accordance with Section B110. B. NSPS Subpart Ja (Flares listed in Table 103.K) Requirement: The permittee shall comply with all applicable requirements of NSPS Subpart Ja. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart Ja. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60, Subpart Ja. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart Ja. A207 Sulfur Recovery Plant (SRP), Tail Gas Incinerator (TGI) A. Consent Decree Requirements for SRP and TGI Requirement: In addition to the applicable requirements of NSPS, 40 CFR 60, Subparts J and Ja, the permittee shall accomplish the following: EPA Inspection Report - Page 916 of 1969 1. Navajo shall route all Sulfur Recovery Plant (SRP) sulfur pit emissions from the SRP so that sulfur pit emissions to the atmosphere either are eliminated or are included and monitored as part of the applicable Sulfur Recovery Plant's tail gas emissions that meet the NSPS Subpart J or Ja limit for SO2. (CD ¶18.C.ii) 2. The SRP and TGI (and any supplemental control devices) shall be operated and maintained, to the extent practicable, in accordance with the obligation to minimize SRP emissions through implementation of good air pollution control practices required by 40 CFR § 60.11(d), at all times, including periods of start-up, shutdown, and malfunction. (CD ¶18.C.iii) Monitoring: The permittee shall comply with the applicable monitoring requirements of NSPS Subpart J or Ja. Recordkeeping: The permittee shall maintain records in accordance with the applicable requirements of NSPS Subparts J and Ja. Reporting: The permittee shall report in accordance with the applicable requirements of NSPS Subparts J and Ja. B. The following BACT SO2 work practices and equipment shall apply to the SRP (SRU3/TGTU3/TGI3): (1) Maintain at least 98% SRP on-stream operations. This includes curtailing refinery operations as necessary when SRU capacity is limited during planned startup, shutdown, and maintenance events. (2) Maintain adequate SRP excess capacity to reduce the frequency and quantity of refinery excess SO2 emissions. After the refinery expansion project proposed units are constructed, the proposed SRU3 will provide at least 25% excess capacity. (3) Continue to maintain and use a sulfur shedding plan to prevent or reduce acid gas flaring events from refinery upsets. An acid gas flaring event is defined as excess SO2 emissions greater than 500 pounds in a 24-hour period. The plan shall state specific actions that may be taken to reduce or prevent acid gas flaring. The actions taken during any event will be based on the refinery operators’ discretion, considering safety and other factors related to prudent operation. This plan is subject to review by NMED or EPA, and shall be amended upon written request by NMED or EPA. The sulfur shedding plan may include, but is not limited to the following options: (a) Store sour water to reduce acid gas generation from the sour water strippers (b) Reduce the operating rate of one or more amine strippers to lower the acid gas generation rate (c) Reduce one or more hydrotreating unit throughput rates to lower acid gas generation rate (4) Use hydrogen, when available, as SRU fuel during startup and hot standby to minimize carbon deposits on the SRU catalysts. EPA Inspection Report - Page 917 of 1969 (5) During startup and shutdown and to the extent practicable, process vessels shall be depressurized into other process equipment rather than venting to a flare. The permittee shall document instances when this is not practicable. C. SRU1, SRU2, and SRU3 Requirement: The permittee shall demonstrate compliance with the H2S, SO2, lb/hr, tpy emission limits by completing the following requirements, monitoring, recordkeeping and reporting: (1) A flow meter shall be installed, operated, calibrated, and maintained on the sour water stripper streams that go to the SRUs. (2) An SO2 CEMS and flow meter shall be installed on the SRU1/SRU2 and SRU3 incinerator stacks. In addition, these units shall be equipped with instruments to measure and record sulfur concentration and flow rates of the gas streams into SRU1, SRU2, and SRU3. The CEMS, flow meters, and data loggers shall be calibrated and maintained. In addition, the calibration of the SO2 CEMS shall follow the quality assurance and quality control procedures in 40 CFR 60 Subpart J or Ja and Appendix F. (3) The minimum acceptable level of data capture for all instruments measuring flow of sulfur streams into the SRU1, SRU2, and SRU3, as well as the CEMS and flow meters on the incinerator stacks, shall be at least 90% for each semi-annual period. The 10% lost data will include all periods when the concentration and corresponding flow are not being measured as a result of calibrations or breakdowns. Monitoring: The gas stream feeding SRU1, SRU2, and SRU3 from the amine regeneration units and the sour water stripper shall be tested at least monthly for H2S concentration. The permittee shall monitor the following: (1) Flow rate of sour water stream to SRUs, (2) SO2 concentration in SRU incinerator stacks and (3) Flow rate of the SRU incinerator stacks. Recordkeeping: The permittee shall maintain records in accordance with the applicable requirements of NSPS Subparts J or Ja and MACT Subpart UUU. The permittee shall also keep records of the following: (1) Flow rate of sour water stream to SRUs, (2) SO2 concentration in SRU incinerator stacks and (3) Flow rate of the SRU incinerator stacks. Reporting: The permittee shall report in accordance with the applicable requirements of NSPS Subparts J or Ja, MACT Subpart UUU, and Section B110. D. 40 CFR 60, Subpart J (Unit(s) SRU1 and SRU2) Requirement: The permittee shall comply with the applicable requirements of 40 CFR 60, Subpart J. Monitoring: The permittee shall install a continuous monitoring device to monitor compliance with the H2S limit. (40 CFR 60.105(a)(3-4)) EPA Inspection Report - Page 918 of 1969 Recordkeeping: The permittee shall maintain the continuous emission records. Reporting: The permittee shall comply with the reporting requirements of 40 CFR 60, Subpart J. E. 40 CFR 60, Subpart Ja (Unit SRU3) Requirement: The permittee shall comply with the applicable requirements of 40 CFR 60, Subpart Ja. Monitoring: The permittee shall install a continuous monitoring device to monitor compliance with the H2S limit. (40 CFR 60.105a(a)(3-4)) Recordkeeping: The permittee shall maintain the continuous emission records. Reporting: The permittee shall comply with the reporting requirements of 40 CFR 60, Subpart Ja. A208 Amine Unit – Not Required A209 Fugitives A. NSPS Subpart GGGa, Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries for which Construction, Reconstruction, or Modification Commenced After November 7, 2006 (Fugitives subject in Table 103.B) Requirement: The permittee shall comply with all applicable requirements of NSPS Subpart GGGa for all sources in Table 103.B (affected units and voluntarily units). This table also includes areas that are voluntarily following the NSPS Subpart GGGa monitoring requirements. Monitoring: The permittee shall comply with all applicable monitoring requirements of 40 CFR 60, Subpart GGGa. Recordkeeping: The permittee shall comply with all applicable recordkeeping requirements of 40 CFR 60, Subpart GGGa. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60, Subpart GGGa. B. NSPS Subpart QQQ, Standards of Performance for VOC Emissions from Petroleum Refinery Wastewater Systems (Fugitives subject in Table 103.B) Requirement The permittee shall comply with all applicable requirements of NSPS, 40 CFR Part 60.690, Subpart QQQ. Per the Consent Decree CIV-01 1422LH Lodged 12/20/2001, Entered 3/5/2002, the permittee agreed that this regulation would apply to the entire facility not just those source applicable due to construction dates. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart QQQ. (60.695) Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60.696. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR EPA Inspection Report - Page 919 of 1969 60.697. C. Minor changes within the facility to piping and components that affect fugitive VOC emission source shall be updated and added during the next available Significant permit revision in accordance with 20.2.72 NMAC. The facility wide fugitive VOC emission limit shown above and in Table 106.A of this permit. A210 Loading Racks A. Truck and Rail Loading (Unit shown in Table 106.G) Requirement: Compliance with the allowable emission limits in Table 106.G shall be demonstrated by not exceeding the monthly rolling 12-month total throughput for each loading rack for each different product in barrels/year. Monitoring: The permittee shall monitor the throughput volumes on a monthly basis. Recordkeeping: The permittee shall record the monthly throughput volume for each loading rack for each different product. Each month during the first 12-months of monitoring the permittee shall record the cumulative condensate loadout volume and after the first 12-months of monitoring, the permittee shall calculate and record a monthly rolling 12-month total loadout volume. Records shall also be maintained in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. B. Fuel Truck Loading Rack (Units subject in Table 103.D) (40 CFR 63, Subpart CC) Requirement: The permittee shall comply with all applicable requirements of MACT Subpart CC, National Emission Standards for Hazardous Air Pollutants From Petroleum Refineries. Specially, the truck loading rack shall be equipped with a carbon adsorption system for compliance with the MACT requirements. Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. Specifically 63.427(a)(2), where a carbon adsorption system is used, a continuous emission monitoring system (CEMS) capable of measuring organic compound concentration shall be installed in the exhaust air stream. Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63, Subpart CC. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 63, Subpart CC. A211 Fluid Catalytic Cracking Unit (FCC) A. Continuous Monitor System (CMS) (Unit FCC REGEN) Requirement: (1) Consent Decree Limits on PM and SO2 emissions from the FCC: By no later than December EPA Inspection Report - Page 920 of 1969 31, 2003, the Wet Gas Scrubber (WGS) on the FCC Regenerator shall comply with the following limits: (CD ¶12.B & ¶13.B) (a) SO2 concentration not to exceed 25 ppmvd on a daily rolling 365-day average basis and 50 ppmvd on a daily rolling 7-day average basis, each corrected to 0% oxygen. Compliance with this emissions limit shall be demonstrated on an ongoing basis through the use of CMS; and (b) A particulate matter (PM) emission limit of 1.0 pound of PM per 1000 pounds of coke burned on a 3-hour average basis (CD ¶13.B). To demonstrate compliance with this requirement, the Permittee shall conduct an annual EPA Method 5 Test for PM and weekly EPA Method 9, Opacity Test in accordance with their approved Alternative Monitoring Plan (AMP). (c) As the FCC Regenerator is subject to the provisions of 40 CFR 60.102 (NSPS Subpart J), it shall not discharge to the atmosphere gases exhibiting greater than 30 percent opacity, except for one six-minute average opacity reading in any one-hour period. (2) Consent Decree Limits on NOx and CO emissions from the FCC: The FCC shall comply with NOx and CO emission limits as follows: (a) The concentration-based (ppmvd) NOx emission limit based on daily rolling 7-day and daily rolling 365-day averages, corrected to 0% oxygen as established pursuant to the Consent Decree, unless EPA rejects the proposed limit and establishes a different NOx emission limit, in which case the FCC shall comply with EPA’s established limit. Under no circumstances shall this emission limit be greater than a concentration-based limit that would be equivalent to 34.9 lbs/hr. The 7-day FCC NOx emission limits, shall not apply during periods of Hydrotreater Outage provided that the FCC (including associated air pollution control equipment) is maintained and operated in a manner that minimizes emissions in accordance with an EPA-approved good air pollution control practices plan. Navajo shall comply with the plan at all times, including periods of startup, shutdown, and malfunction of the hydrotreater. The daily rolling 365-day average NOx emissions limit shall apply during periods of hydrotreater outages. The NOx limits are: (1) 87.3 ppmvd NOx, corrected to 0% O2 on a daily rolling 7-day average, and (2) 58.1 ppmvd NOx, corrected to 0% O2 on a daily rolling 365-day average (b) The NSPS Subpart J emission limit of 500 ppmvd CO corrected to 0% O2 on a 1-hour average basis and 100 ppmvd CO corrected to 0% O2 on a daily rolling 365-day average basis, by no later than December 31, 2003. Monitoring: (1) A continuous monitor system (CMS) for CO, O2, SO2 and NOx shall be installed, calibrated, maintained, and operated on the FCC Catalyst Regenerator vent stack(s) downstream of the scrubber in accordance with 40 CFR Part 60, §60.13, Appendix A, and the applicable performance specifications of Appendices B (Specifications 2 and 3) and F. The CMS shall be used to demonstrate compliance with CO, SO2 and NOx emissions limits and to report compliance with the terms and conditions of the Consent Decree. The CMS and process data shall be made available, by permittee, to applicable Federal and State EPA Inspection Report - Page 921 of 1969 Agencies (NMED) upon demand as soon as practicable. (CD ¶11.F, 12 D, and 14.C) (2) The FCC Regenerator Scrubber NOx, SO2, CO and O2 CMS shall be recertified annually. (3) The CMS data shall be monitored to ensure the CO, SO2 and NOx emission limits for the FCC are met. (4) The Permittee shall conduct an annual EPA Method 5 Test for PM and weekly EPA Method 9 Opacity test to demonstrate compliance with the particulate matter (PM) emission limit of 1.0 pound of PM per 1000 pounds of coke burned on a 3-hour average basis and opacity limit of 30%. Permittee shall meet testing requirements of B111. Recordkeeping: The permittee shall maintain the records of: (1) The certification and re-certification of the CMS. (2) Modifications to the FCC’s good air pollution control practice plan to minimize NOx emissions shall be summarized on an annual basis if any changes were made. ( CD ¶11.G) (3) The permittee shall keep records of CMS data monitoring NO2, SO2, PM10 and CO emissions from the FCC. (CD ¶11.F, CD ¶12.D & CD ¶14.C) (4) Records of NOx, CO, SO2 ppmvd, lb/hr, tpy; PM lb/hr, tpy and opacity. TPY shall be based on a monthly rolling 12-month total. (5) The permittee shall keep records of annual PM stack tests and weekly Method 9 observations conducted on the FCC. For any opacity observations conducted in accordance with the requirements of EPA Method 9, record the information on the form referenced in EPA Method 9, Sections 2.2 and 2.4. Reporting: The permittee shall report in accordance with Section B110 and testing requirements of B111. B. Performance Testing (Unit FCC REGEN) Requirements: (1) The permittee shall demonstrate compliance with the NSPS Subpart J particulate matter emission limit at Table 106.A by conducting an initial performance test in accordance with NSPS Subpart A, §60.8 and NSPS Subpart J, §60.106(b). The particulate matter stack test shall be repeated on an annual basis. (2) The permittee shall comply with all applicable performance testing requirements in accordance with MACT Subparts A and UUU. Monitoring: Testing shall be conducted in accordance with NSPS Subparts A and J, and in accordance with MACT Subparts A and UUU. Recordkeeping: The permittee shall maintain performance test records in accordance with NSPS Subparts A and J, MACT Subparts A and UUU, and in accordance with Section B109. Reporting: The permittee shall report performance test results in accordance with NSPS Subparts A and J, MACT Subparts A and UUU, and in accordance with Section B110. EPA Inspection Report - Page 922 of 1969 A212 Cooling Towers A. MACT Subpart CC, “National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries” (Cooling Towers subject in Table 103.F) Requirement: The permittee shall comply with all applicable requirements of 40 CFR 63, Subpart CC for heat exchange systems for all affected sources shown in Table 103.F attached. (63.654(a), 63.640(h)(6)) Monitoring: The permittee shall comply with all applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. (63.654(c), (d), (e), (f)) Recordkeeping: The permittee shall comply with all applicable recordkeeping requirements of 40 CFR 63, Subpart CC. (63.654(g), 63.655(i)(4), (i)(5)) Reporting: The permittee shall comply with all applicable reporting requirements of 40 CFR 63, Subpart CC. (63.655(f), (f)(1)(vi), (g)(9), (h)(1), (7)) B. Cooling Tower Operations (Cooling Towers subject in Table 103.F) Requirement: Compliance with the allowable emission limits in Table 106.H shall be demonstrated by meeting the following requirements: 1) operate a maximum of six (6) recirculating pumps at any one time; 2) ensure that each pump capacity shown in Table 104.A are not exceeded gallons per minute for each cooling tower (65,500 gpm total maximum rate for 6 pumps); 3) limit the Total Dissolved Solids (TDS) content for the cooling tower recirculating water system to 3500 ppmw, based on a monthly rolling 12-month annual average; 4) ensure that the drift eliminator are rated by the manufacturer at 0.001% or 0.003 drift or less as shown in Table 104.A; and 5) ensure that the drift eliminator is present and in good working order. The permittee shall measure the Total Dissolved Solids (TDS) content of the recirculating water through direct laboratory analysis, or may use a conductivity meter on the recirculating water system for the cooling tower. The correlation between conductivity of the water and the TDS content shall be taken as 0.9 * conductivity (μmhos/cm) = TDS (ppmw) unless a new correlation is determined through laboratory analysis and submitted to the Permit Program Manager for approval. Monitoring: The permittee shall: 1) Monitor the recirculating water TDS content by direct laboratory analysis of the TDS or through use of conductivity meter values and correlated TDS on a monthly basis; and a. Any correlation other than the 0.9 value described above shall be developed by the permittee by independent laboratory measurement of at least 10 water samples with approximately evenly spaced measured TDS values that bracket the minimum and maximum values expected. The highest laboratory TDS sample used for the correlation shall be greater than the maximum allowable TDS of 3500 ppmw. 2) Perform an annual inspection of the drift eliminator and perform any maintenance EPA Inspection Report - Page 923 of 1969 necessary to ensure the device operates according to the manufacturer’s specifications. 3) The permittee shall monitor the cooling water inlet and outlet streams for hydrocarbons on an annual basis using either EPA Method 8015 with a large enough sample to achieve accurate quantification of hydrocarbon content, EPA Method 8260, EPA Method 8270 or a similar method as approved by the Department prior to testing. Recordkeeping: The permittee shall maintain the following records: 1) Manufacturer’s specifications demonstrating maximum capacities of the recirculating water pumps and the manufacturer’s specification for the drift eliminator specified drift rate; 2) Monthly TDS and monthly rolling 12-month average; 3) If a conductivity meter is installed, a record of the correlation between conductivity and TDS, any laboratory analyses used to determine the correlation, and all related calculations; 4) Annual drift eliminator inspection and any records of maintenance performed. The permittee shall maintain records in accordance with Section B109. Reporting: The permittee shall report in accordance with Section B110. A213 Wastewater Systems A. NSPS Subpart QQQ, Standards of Performance for VOC Emissions from Petroleum Refinery Wastewater Systems Requirement: Beginning December 31, 2003, all remaining and newly installed individual drain systems, oil-water separators, and aggregate facilities not previously specified shall be affected facilities, as the term is used in the NSPS, 40 CFR Part 60, Subpart QQQ, and shall be subject to and comply with the applicable requirements of 40 CFR Part 60, Subpart QQQ. (CD ¶29) The permittee shall comply with all applicable requirements of NSPS Subpart QQQ for the affected sources in Tables 103.B, C, G. (60.690) Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 60, Subpart QQQ. (60.695 and 60.696) Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 60.697. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 60.698. B. MACT Subpart CC, “National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries” Requirement: The permittee shall comply with all applicable requirements of MACT Subpart CC, “National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries” for all affected sources shown in Tables 103.B, C, G attached. (63.640). Monitoring: The permittee shall comply with the applicable monitoring and testing requirements of 40 CFR 63, Subpart CC. EPA Inspection Report - Page 924 of 1969 Recordkeeping: The permittee shall comply with the applicable recordkeeping requirements of 40 CFR 63.655. Reporting: The permittee shall comply with the applicable reporting requirements of 40 CFR 63.655. C. Wastewater Treatment System (Units shown in Table 106.I) Requirement: Compliance with the emission limits in Table 106.I shall be demonstrated by properly maintaining and repairing the units, and running the Wastewater Model annually to calculate the maximum VOC emissions generated. Monitoring: (1) Maintenance and repair shall meet the minimum manufacturer's or permittee's recommended maintenance schedule. Activities that involve maintenance, adjustment, replacement, or repair of functional components with the potential to affect the operation of an emission unit shall be documented as they occur for the following events: (a) Routine maintenance that takes a unit out of service for more than two hours during any twenty-four hour period. (b) Unscheduled repairs that require a unit to be taken out of service for more than two hours in any twenty-four hour period. (2) The permittee shall annually run the Waste-Water Model to determine the hourly and annual emission rates, based on EPA’s WATER9, the wastewater treatment model. Recordkeeping: (1) The permittee shall maintain records in accordance with Section B109, including records of maintenance and repairs activities and a copy of the manufacturer’s or permittee’s recommended maintenance schedule. (2) The permittee shall maintain records of the EPA’s WATER9, the wastewater treatment model Input Parameters and the emission calculation results compared to permit limits. Reporting: The permittee shall report in accordance with Section B110. PART B GENERAL CONDITIONS (Attached) PART C MISCELLANEOUS: Supporting On-Line Documents; Definitions; Acronyms (Attached) PART D ATTACHMENTS EPA Inspection Report - Page 925 of 1969 Table 103.B, Summary Applicability – Fugitives [return] 20.2.37 MACT CC NSPS GGG NSPS GGGa NSPS QQQa NESHAP Jb NESHAP Vc South Division Crude Unit YES NO NO YES YES NO NO FUG-05-KERO Kerosene HDS Unit NO NO NO YES YES NO NO FUG-06-NHDU Naphtha HDS Unit 06 NO NO YES YES NO NO FUG-07-N AMINE Amine Unit-Treating/Regen. YES NO NO NO YES YES NO NO YES YES NO NO Title V Permit Unit ID Description FUG-02-SP CRUDE FUG-07-SWS1 Sour Water Stripper YES NO NO FUG-08-TRUCK RK Loading Racks North Alkylation Unit (New-Inside battery limits) FCC w/CVS NO NO NO NO NO YES YES NO NO YES YES NO NO YES NO NO YES YES NO NO Naphtha HDS Unit 13 YES NO NO YES YES NO NO Merox/Merichem Treating Units NO NO NO YES YES NO NO BenFree Unit NO NO NO YES YES NO NO NO NO NO YES YES NO NO YES NO NO YES YES NO NO NO NO YES YES NO NO FUG-09-N ALKY FUG-10-FCC FUG-13-NHDU FUG-18-LSR MEROX TRT FUG-20-ISOM FUG-21-SP VACUUM FUG-25-ROSE-2 FUG-29-BLENDER/TK FARM FUG-31SRU3/TGTU3/TGI3 FUG-33-DIST HDU FUG-34HYDROCRACKER FUG-35-SAT GAS Flasher/Vacuum Unit ROSE Unit YES Light Oil Tankage NO SRU3 Unit YES NO NO YES YES NO NO Relocated Diesel HDS Unit w/CVS YES NO NO YES YES NO NO WX Hydrocracker YES NO YES YES NO NO Saturates Gas Plant NO NO NO YES YES NO NO FUG-41-PBC PBC Unit NO NO YES YES NO NO FUG-43-S ALKY South Alky Unit (W-76) YES NO NO NO YES YES NO NO NO NO NO YES YES NO NO NO YES YES NO NO NO YES YES NO NO FUG-44-DIST-HDU Gas Oil Hydrotreater (incl. CVS) NO FUG-45-DIST-HDU Gas Oil Hydrotreater (incl. CVS) NO NO FUG-54-PRIMEG Prime G Unit YES NO EPA Inspection Report - Page 926 of 1969 20.2.37 MACT CC NSPS GGG NSPS GGGa NSPS QQQa NESHAP Jb NESHAP Vc Hydrogen Plant NO NO NO NO YES NO NO FUG-64-H2 PLANT-2 Hydrogen Plant NO YES NO NO CCR Reformer (w/in battery limits) YES NO NO NO FUG-70-CCR NO NO YES YES NO NO FUG-73-SP UTIL Utilities NO YES NO NO Oil/Water Separator YES NO NO NO FUG-80-WWTP CVS NO NO YES YES NO NO FUG-ASPHALT STG Asphalt/Heavy Oil Storage NO NO NO YES NO NO FUG-FUEL GAS Fuel Gas Distribution System NO YES NO NO YES YES NO NO FUG-LPG LPG Storage System NO NO NO YES YES NO NO FUG-RLO-ASPHALT FUGSRU1/SRU2/TGTU Asphalt/Pitch Loading Rack NO NO NO NO YES NO NO SRU1/SRU2/SWS w/CVS YES NO NO YES YES NO NO NO NO NO NO YES NO NO Title V Permit Unit ID Description FUG-63-H2 PLANT-1 Crude oil unloading system, closed loop system between railcars and trucks. a. All wastewater sources subject to NSPS QQQ per consent decree Section 29B. b. No refinery streams contain benzene at concentrations of 10 wt% or greater. c. NESHAP V is only applicable if subject to NESHAP J. FUG-RRTOTRUCK EPA Inspection Report - Page 927 of 1969 Table 103.C, Summary Applicability - Tanks Tank No. RW-4 RW-5 RW-6 T-0001 T-0002 T-0003 T-0004 T-0011 T-0012 T-0026 T-0028 T-0031 T-0040 T-0041 T-0042 T-0045 T-0046 T-0049 T-0055 T-0056 T-0057 T-0059 T-0061 T-0063 T-0064 T-0065 T-0071 T-0072 T-0073 T-0074 T-0075 T-0076 T-0079 T-0081 T-0082 T-0106 T-0107 T-0108 T-0109 NSPS K NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NSPS Ka NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NSPS Kb NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO NO NO NO YES NO YES YES YES NO NO NO NO MACT CC Storage NO NO NO NO NO NO NO YES YES NO NO NO YES YES NO NO NO YES YES YES YES YES YES YES NO YES NO NO NO NO YES NO YES YES YES YES YES YES YES MACT CC Wastewater N/A N/A N/A YES YES YES YES N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NESHAP FF N/A N/A N/A YES YES YES NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NSPS QQQ N/A N/A N/A NO NO NO NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 20.2.37.205 NMAC NO NO NO NO NO NO NO YES YES NO NO NO NO NO YES YES YES NO YES YES YES NO NO NO NO YES YES YES YES YES YES YES YES YES YES YES YES YES YES 20.2.38.109 NMAC NO NO NO NO NO NO NO YES YES NO NO NO NO NO YES NO NO NO NO YES YES NO NO NO NO NO NO NO NO NO NO NO YES NO NO YES YES YES YES 20.2.38.110 NMAC YES YES YES NO NO NO NO YES YES NO NO NO NO NO YES NO NO NO NO YES YES NO NO NO NO NO NO NO NO NO NO NO YES NO NO YES YES YES YES 20.2.38.112 NMAC NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES YES YES NO YES NO YES NO NO NO NO YES YES YES YES YES YES YES YES YES YES NO NO NO NO 20.2.38.113 NMAC YES NO YES NO NO NO NO NO NO NO NO NO NO NO YES NO NO NO NO NO YES NO NO NO NO NO NO NO NO NO NO NO YES NO NO NO NO NO NO CAM NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO EPA Inspection Report - Page 928 of 1969 Tank No. T-0110 T-0111 T-0112 T-0114 T-0115 T-0116 T-0117 T-0119 T-0124 T-0400 T-0401 T-0402 T-0410 T-0411 T-0412 T-0413 T-0415 T-0417 T-0418 T-0419 T-0420 T-0422 T-0423 T-0431 T-0432 T-0433 T-0434 T-0435 T-0437 T-0438 T-0439 T-0446 T-0447 T-0448 T-0449 T-0450 T-0451 T-0452 T-0453 T-0460 NSPS K NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO NO NO NO NO NO NO NSPS Ka NO NO NO NO NO NO NO NO YES NO YES YES NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO NO NO NO NO NSPS Kb NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO NO NO NO NO NO NO YES MACT CC Storage YES YES YES NO NO NO YES NO YES YES YES YES YES YES YES YES YES YES YES YES YES YES YES YES YES YES YES YES YES YES YES NO NO NO NO YES MACT CC Wastewater N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NESHAP FF N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NSPS QQQ N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 20.2.37.205 NMAC NO YES YES YES YES YES YES YES YES YES YES YES NO YES YES YES YES YES NO NO NO NO NO NO NO NO YES YES YES YES YES NO NO NO NO YES 20.2.38.109 NMAC NO YES YES NO NO NO YES NO YES NO YES YES NO YES YES YES YES YES NO NO NO NO NO NO NO NO NO YES YES NO YES NO NO NO NO YES 20.2.38.110 NMAC NO YES YES NO NO NO YES NO YES NO YES YES NO YES YES YES YES YES NO NO NO NO NO NO NO NO NO YES YES NO YES NO NO NO NO YES 20.2.38.112 NMAC NO NO NO YES YES YES NO YES YES YES YES YES NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES YES YES YES YES NO NO NO NO YES 20.2.38.113 NMAC NO NO NO NO NO NO NO NO YES NO YES YES NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES YES NO YES NO NO NO NO YES CAM NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO N/A N/A N/A N/A N/A N/A NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES YES NO N/A N/A N/A N/A N/A N/A YES YES NO NO NO NO NO NO NO NO NO NO EPA Inspection Report - Page 929 of 1969 Tank No. T-0465 T-0466 T-0467 T-0468 T-0600 T-0737 T-0802 T-0803 T-0804 T-0807 T-0809 T-0814 T-0815 T-0816 T-0830 T-0834 T-0835 T-0838 T-0839 T-0840 T-0841 T-0891 T-0892 T-1221 T-1222 T-1223 T-1224 T-1225 T-1227 T-5401 T-0829 NSPS K NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NSPS Ka NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NSPS Kb NO NO NO NO NO YES YES NO NO NO NO YES YES NO YES NO NO NO NO NO NO NO NO NO NO NO NO YES YES YES NO MACT CC Storage NO NO NO NO NO YES YES NO NO NO NO YES YES NO NO YES YES YES NO NO NO NO NO NO NO NO NO YES YES YES NO MACT CC Wastewater N/A N/A N/A N/A N/A N/A N/A YES YES N/A YES N/A N/A N/A YES N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES N/A N/A N/A YES NESHAP FF N/A N/A N/A N/A N/A N/A N/A YES YES N/A YES N/A N/A N/A YES N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A YES N/A N/A N/A YES NSPS QQQ N/A N/A N/A N/A N/A N/A N/A NO NO N/A NO N/A N/A N/A YES N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A NO N/A N/A N/A NO 20.2.37.205 NMAC NO NO NO NO NO YES YES NO NO NO NO YES YES YES YES NO YES YES NO NO NO NO NO NO NO NO NO YES YES YES NO 20.2.38.109 NMAC NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO NO NO NO NO NO NO NO NO NO YES NO YES NO 20.2.38.110 NMAC NO NO NO NO NO YES YES NO NO NO NO NO NO NO NO NO YES NO NO NO NO NO NO NO NO NO NO YES NO YES NO 20.2.38.112 NMAC NO NO NO NO NO YES YES NO NO NO NO YES YES NO YES NO NO NO NO NO NO NO NO NO NO NO NO YES YES YES NO 20.2.38.113 NMAC NO NO NO NO NO YES YES NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES NO YES NO CAM NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO EPA Inspection Report - Page 930 of 1969 Table 103.D, Summary Applicability – Loading Unit ID TLO-1 TL-2 TL-4 TL-7 RLO-8 RLO-19 TLO-20 Description Asphalt Truck Loading and OffLoading Rack #1 Asphalt Truck Loading Rack #2 Fuels Truck Loading Rack CBO/LCO Truck Loading Rack Railcar Loading & Off-Loading Rack Railcar Loading & Off-Loading Rack Asphalt/Pitch Truck Loading Rack MACT CC NO NO YES NO NO NO NO 20.2.37.205.C NO MACT BBBBBB NO MACT CCCCCC NO CAM NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO EPA Inspection Report - Page 931 of 1969 Table 103.E, Summary Applicability – Heaters and Boilers Unit ID Description B-0007 B-0008 B-0009 Boiler 7 Boiler 8 Boiler 9 Unit 13 Naphtha Splitter Reboiler Unit 21 Vacuum Unit Heater Unit 06 HDS Reboiler South Crude Charge Heater South Crude Charge Heater H-0009 H-0011 H-0018 H-0019 H-0020 NSPS D NO NO NO NSPS Db YES YES YES NSPS Dc NO NO NO NSPS J YES YES NO NSPS Ja NO NO Yes MACT DDDDD YES YES YES 20.2.33.108 NMAC YES YES YES 20.2.37 NMAC YES YES YES NO NO NO YES NO YES NO YES NO NO NO NO YES NO YES NO YES NO NO NO NO YES NO YES NO YES NO NO NO NO YES NO YES NO YES NO NO NO NO YES NO YES NO YES NO CAM NO NO NO H-0028 Unit 21 Heater H-28 NO NO NO YES NO YES NO YES NO H-0030 H-0040 H-0303 Unit 06 Charge Heater Unit 13 Charge Heater Unit 05 Charge Heater Unit 10 FCC Feed Heater Unit 70 CCR Reformer Heater Unit 70 CCR Reformer Heater Unit 70 CCR Reformer Heater Unit 70 Stabilizer Reboiler Heater NO NO NO NO NO NO NO NO NO YES YES YES NO NO NO YES YES YES NO NO NO YES YES YES NO NO NO NO NO NO YES NO YES NO YES NO NO NO NO YES NO YES NO YES NO NO NO NO YES NO YES NO YES NO NO NO NO YES NO YES NO YES NO NO NO NO YES NO YES NO YES NO H-0362 Unit 70 CCR Heater NO NO NO YES NO YES NO YES NO H-0363 Unit 70 CCR Heater NO NO NO YES NO YES NO YES NO H-0312 H-0352 H-0353 H-0354 H-0355 EPA Inspection Report - Page 932 of 1969 Unit ID Description NSPS D NSPS Db NSPS Dc NSPS J NSPS Ja MACT DDDDD 20.2.33.108 NMAC 20.2.37 NMAC CAM H-0364 Unit 70 CCR Heater NO NO NO YES NO YES NO YES NO H-0421 Unit 44 Charge Heater NO NO NO YES NO YES NO YES NO H-0464 SRU Hot Oil Heater NO NO YES YES NO NO NO YES NO NO NO NO YES NO NO NO YES NO NO NO NO YES NO YES NO YES NO H-0473 H-0600 SRU1 and SRU2 Tail Gas Incinerator Unit 09 Depropanizer Reboiler Heater H-0601 Unit 33 Charge Heater NO NO NO YES NO YES NO YES NO H-2421 Unit 45 Charge Heater NO NO NO YES NO YES NO YES NO H-8801/ H-8802 Unit 63 Hydrogen Plant Reformer Unit 34 Hydrocracker Reboiler 1 Hydrocracker Reactor Charge Heater Unit 54 HDS Reactor Heater Unit 64 Hydrogen Plant Reformer Unit 25 ROSE® Unit No.2 Hot Oil Heater NO NO NO YES NO YES YES YES NO NO NO NO NO YES YES NO YES NO NO NO NO NO YES YES NO YES NO NO NO NO NO YES YES NO YES NO NO NO NO NO YES YES YES YES NO NO YES NO NO YES YES YES YES NO SRU3 Hot Oil Heater NO NO NO NO YES NO NO YES NO SRU3 Tail Gas Incinerator NO NO NO NO YES NO NO YES NO H-3402 H-3403 H-5401 H-9851 H-2501 H-3101 (formerly SRU3-HOH) SRU3-TGI EPA Inspection Report - Page 933 of 1969 Table 103.F, Summary Applicability – Cooling Towers Cooling Tower Y-0001 Y-0002 Y-0008 Y-0011 Y-0012 CT TT-0006 Description TCC Cooling Tower S. Alky Cooling Tower (Marley Cooling Tower) North Alky Cooling Tower FCC & NP Cooling Tower Hydrogen Plants Cooling Tower Unit 07 Amine W-0745 Cooling Tower MACT Q NO NO MACT CC YES YES CAM NO NO NO NO NO NO YES YES YES NO NO NO NO NO Table 103.G, Summary Applicability – Wastewater [return] Equipment ID MAIN API DAF-0896 DAF-0806 T-0801 T-0805 T-0829 T-0836 T-0897 Emission Point ID D-0829/0830 DAF-0896 DAF-0806 MACT CC Wastewater YES YES YES YES YES YES YES YES NESHAP FF YES YES YES YES YES YES YES YES NSPS QQQ YES NO NO NO NO NO NO NO CAM NO NO NO NO NO NO NO NO EPA Inspection Report - Page 934 of 1969 Table 103.H, Summary Applicability – FCC-CCR Unit ID FCCREGEN NSPS J YES NSPS Ja NO CCR N/A N/A MACT UUU YES 20.2.37 NMAC YES YES N/A CAM YES Satisfied by MACT UUU NO Table 103.I, Summary Applicability – SRU Source Emission ID Point ID SRU1 H-0473 SRU2 H-0473 SRU3 SRU3TGI Description SRU1 and SRU2 Tail Gas Incinerator SRU1 and SRU2 Tail Gas Incinerator SRU3 Tail Gas Incinerator NSPS J YES NSPS Ja NO MACT UUU YES YES NO YES YES YES NO NO YES YES YES YES NO 20.2.37.200B 20.2.37.202.A YES YES 20.2.39 NO CAM YESSatisfied by MACT UUU YESSatisfied by MACT UUU YESSatisfied by MACT UUU EPA Inspection Report - Page 935 of 1969 Table 103.J, Summary Applicability – Engines [return] Source ID E-0600W E-0601M E-0602E E-0603 E-0901 G-0100 G-0101 V-0543 V-0545 V-0546 E-8010 Description Fire Water Pump Engine Fire Water Pump Engine Fire Water Pump Engine Fire Water Pump Engine Fire Water Pump Engine UPS backup generator UPS backup generator Portable Air Compressor Portable Air Compressor Portable Air Compressor WWTP Emergency Engine NSPS IIII YES YES YES YES YES NO NO YES YES YES YES MACT ZZZZ YES YES YES YES YES YES YES YES YES YES YES 20.2.61.109 NMAC YES YES YES YES YES YES YES YES YES YES YES CAM NO NO NO NO NO NO NO NO NO NO NO Table 103.K, Summary Applicability – FLARES [return] Unit ID Description NSPS A NSPS J NSPS Ja NESHAP A FL-400 North Plant Flare YES NO YES NO FL-401 South Plant Flare YES NO YES NO FL-402 FCCU Flare YES NO YES NO FL-403 Alky Flare YES NO YES NO FL-404 GOHT Flare YES NO YES NO All flares are steam assisted. State of New Mexico requires that an exit gas velocity of 65 ft/sec for modeling. The heating value of the gas for all flares is < 1000 BTU/scf. MACT A YES YES YES YES YES 20.2.37.201B NMAC YES YES YES YES YES EPA Inspection Report - Page 936 of 1969 Table 104.A: Regulated Sources List [return to A104] Unit No. Unit Type Manufacturer Model No. Manufacture Date B-0007 Boiler 7 Todd/John Zink burners Unknown 10/8/2001 * B-0008 Boiler 8 Todd/John Zink burners Unknown 2003 * B-0009 Boiler 9 Babcock & Wilcox TBD Capacity 215 MMBtu/hr (LHV Basis) 215 MMBtu/hr (LHV Basis) 220 MMBtu/hr (LHV Basis) E-8010 WWTP Diesel Pump Engine John Deere Clarke Diesel Deere) Clarke Diesel Deere) Clarke Diesel Deere) Clarke Diesel Deere) Clarke Diesel Deere) 2/2011 400 hp 7/2012 7/2012 376 hp 376 hp 7/2012 376 hp 2012 305 hp 10/2007 430 hp 1998 52 hp 1999 8/30/2010 4/8/2011 11/19/2008 54 hp 260 hp 260 hp 240 hp 44 MMBtu/hr (LHV Basis) 38 MMBtu/hr (LHV Basis) 32 MMBtu/hr (LHV Basis) UPS backup generator Deutz UPS backup generator Deutz Portable Air Compressor Portable Air Compressor Portable Air Compressor Cummings, Inc. Cummings, Inc. Cummings, Inc. TBD 6090HF485/ RG6090L101484 JW6H-UFAD70/ RG6090L113548 JW6H-UFAD70/ RG6090L113561 JW6H-UFAD70/ RG6090L113574 JU6H-UFADX8/ PE6068L228486 JX6H-UF30’ RG6125A016118 F4L912GEN/ Engine Family WDZXL05.7010 F4L 1011 F/ EI9768CA00-000-0053 QSC, 73104611 QSC, 73142120 QSC, 46917364 H-0009 Unit 13 Naphtha Splitter Reboiler Zeeco burners GSFW-12 burners Unknown H-0011 Unit 21 Vacuum Flasher Heater John Zink burners HEVD-14 9/26/2014 H-0018 Naphtha HDS Reboiler Zeeco burners GSFW-8 burners Unknown E-0600W E-0601M E-0602E E-0603 E-0901 G-0100 G-0101 V-0543 V-0545 V-0546 Fire Water Pump Engine Fire Water Pump Engine Fire Water Pump Engine Fire Water Pump Engine Fire Water Pump Engine (John (John (John (John (John EPA Inspection Report - Page 937 of 1969 Unit No. Unit Type Manufacturer Model No. Callidus Technologies, LLC burners CUBL-8W burners Callidus Technologies, LLC burners CUBL-12W burners Manufacture Date New burners in 2005 New burners in 2005 H-0019 South Crude Charge Heater H-0020 H-0028 South Crude Charge Heater Unit 21 Heater H-28 (previously H-10) John Zink burners PSFG-12 burners Unknown H-0030 Unit 06 Charge Heater John Zink burners PSFG-16R burners 2000* H-0040 Unit 13 Charge Heater John Zink burners 1990* H-0303 Unit 05 Charge Heater John Zink burners PSFG-16 burners HEVD-Q-18 burners H-0312 John Zink burners Callidus Technologies, LLC burners Callidus Technologies, LLC burners Callidus Technologies, LLC burners VYD-18 burners 1990* New burners 2006 New burners 2006 New burners 2006 H-0355 Unit 10 FCC Feed Heater Unit 70 CCR Heater (previously 70-H1) Unit 70 CCR Heater (previously 70-H2) Unit 70 CCR Heater (previously 70-H3) Unit 70 Stabilizer Reboiler Heater H-355 (previously 70H-4) Unknown H-0362 Unit 70 CCR Heater H-0363 Unit 70 CCR Heater H-0364 John Zink burners Callidus Technologies, LLC burners Callidus Technologies, LLC burners Callidus Technologies, LLC burners Unit 70 CCR Heater Unit 44 Charge Heater (previously H-21) John Zink burners Callidus Technologies, SRU Hot Oil Heater LLC burners Depropanizer Reboiler Heater Callidus Technologies, (previously 3F-1) LLC burners H-0352 H-0353 H-0354 H-0421 H-0464 H-0600 CUBL-10W burners CUBL-10W burners CUBL-10W burners CUBL-8W burners CUBL-8W burners CUBL-6W burners LNC-PC-18 burners LE-CSG-4W burners CUBL-12W burners 1982* 1991* New burners 2006 New burners 2006 New burners 2006 in in in in in in 1981* 2003* 1991*, New burners in 2009 Capacity 54 MMBtu/hr Basis) 78 MMBtu/hr Basis) 12.3 MMBtu/hr Basis) 42 MMBtu/hr Basis) 42 MMBtu/hr Basis) 11 MMBtu/hr Basis) 35 MMBtu/hr Basis) 63 MMBtu/hr Basis) 81 MMBtu/hr Basis) 56 MMBtu/hr Basis) 24 MMBtu/hr Basis) 40 MMBtu/hr Basis) 50 MMBtu/hr Basis) 35 MMBtu/hr Basis) 27 MMBtu/hr Basis) 9.6 MMBtu/hr Basis) 84 MMBtu/hr Basis) (LHV (LHV (LHV (LHV (LHV (LHV (LHV (LHV (LHV (LHV (LHV (LHV (LHV (LHV (LHV (LHV (LHV EPA Inspection Report - Page 938 of 1969 Unit No. Unit Type Manufacturer Model No. Callidus Technologies, CUB-8P-CW LLC burners burners GLSF-14 Round Flame "Free Jet" Zeeco, Inc. burners burners Callidus Technologies, LE-CSG-12W-PSA LLC burners burners Callidus Technologies, LE-CSG-12W-PSA LLC burners burners John Zink Company, LLC COOLstar-18 burners burners Callidus Technologies, LLC burners CUBL-10W burners Callidus Technologies, LE-CSG-12W LLC burners burners Tulsa Heaters Inc. TBD Callidus Technologies, CUBL-3WDF LLC burners burners Callidus Technologies, LLC burner Unknown Manufacture Date Capacity New burners in 78 MMBtu/hr (LHV 2003 Basis) 05/11/2009 * 27 MMBtu/hr (LHV Basis) 60 MMBtu/hr (LHV Basis) 60 MMBtu/hr (LHV Basis) 120 MMBtu/hr (LHV Basis) 32.0 MMBtu/hr (LHV Basis) 52 MMBtu/hr (LHV Basis) 21.3 MMBtu/hr HHV 337 MMBtu/hr (LHV Basis) 9.6 MMBtu/hr (LHV Basis) Unknown NA SRU3 Tail Gas Incinerator FCC Regenerator Scrubber Unknown Unknown Callidus Technologies, LLC burners Unknown Unknown Unknown 05/11/2009 * Unknown NA NA North Plant Flare Unknown Unknown Unknown NA South Plant Flare FCC Flare Alky Flare Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown NA NA NA GOHT Flare TCC Cooling Tower Unknown Unknown Unknown Unknown Unknown Unknown NA 5,000 gpm H-0601 Unit 33 Charge Heater H-2421 Unit 45 Charge Heater Unit 63 Hydrogen Plant Reformer Furnace Unit 63 Hydrogen Plant Reformer Furnace H-8801 H-8802 H-2501 H-3402 H-5401 ROSE2 Hot Oil Heater Hydrocracker Reactor Charge Heater Hydrocracker Fractionator Reboiler 1 Unit 54 HDS Reactor Heater H-9851 Unit 64 Hydrogen Plant Reformer H-3403 H-3101 SRU3 Hot Oil Heater H-0473 (SRU1/SRU2 SRU1 and SRU2 Tail TGI) Incinerator SRU3-TGI FCC Regenerator FL-0400, North Plant Flare FL-0401, South Plant Flare FL-0402, FCC Flare FL-0403, Alky Flare FL-0404, GOHT Flare Y-0001 Gas 2006* 2006* 2006* 2009* 2011 2009* 2016 2009* EPA Inspection Report - Page 939 of 1969 Unit No. Unit Type S. Alky Cooling Tower (Marley Y-0002 Cooling Tower) Y-0008 North Alky Cooling Tower Y-0011 FCC & NP Cooling Tower Y-0012 Hydrogen Plants Cooling Tower Unit 07 Amine W-0745 Cooling CT TT-0006 Tower Above Ground API Oil-Water MAIN API Separator T-0896 DAF Unit T-0896 Enhanced Biodegradation Tank T-0801 T-0801 Enhanced Biodegradation Tank T-0836 T-0836 T-0829 Equalization Tank T-0829 T-0806 DAF Unit T-0806 Fugitives (see Table Equipment component leaks 103.B) (pump seals, valves, flanges, etc.) Loading (see Table 103.D) Bulk Loading/Unloading Racks Fixed Roof, External Floating Tanks (see Table Roof & Internal Floating Roof 103.C) Tanks * Installation date Manufacturer Model No. Manufacture Date Capacity Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown Unknown 5,000 gpm 12,500 gpm 30,000 gpm 10,000 gpm Unknown Unknown Unknown 3,000 gpm Unknown Unknown Unknown Unknown Unknown Unknown 1,200 gpm 1,200 gpm Unknown Unknown Unknown 1,200 gpm Unknown Not yet installed Not yet installed Unknown Not yet installed Not yet installed Unknown Not yet installed Not yet installed 1,200 gpm 1,200 gpm Not yet installed NA NA Varies NA NA NA Varies Varies NA NA Varies Varies Note: Serial numbers are not used since most equipment consists of field erected parts that are assembled on site and may have several “serial numbers” for various components. Heaters are the best example because each of the burners has a serial number but the heater as a whole does not have a single serial number. The heater as a whole is typically identified by our equipment number. There may also be a “project number” or “job number” from the manufacturer, but that can change if a heater is revamped at a later date such as when they modify the convection section to improve energy efficiency. EPA Inspection Report - Page 940 of 1969 3,5MM Source ID B-0007 B-0008 B-0009 H-0009 H-0011 H-0018 H-0019 H-0020 H-0028 H-0030 H-0040 H-0303 H-0312 H-0352 /0353/0354 H-0355 H-0362/ 0363/0364 H-0421 H-0464 H-0600 H-0601 H-2421 H-2501 H-3101 H-3402 H-3403 H-8801 Btu/hr 215 215 220 44 38 32 54 78 12.3 42 42 11 35 63/81/56 Table 106.A Allowable Emission Limits 2NOx 4PM VOC H2S SO2 CO 5(lb/MM 5 (lb/hr) (ton/yr) 5(lb/hr) (ton/yr) 5(lb/hr) (ton/yr) (lb/hr) (ton/yr) 5(lb/hr) (ton/yr) (lb/hr) (ton/yr) Btu) 7.8 12.7 12.9 56.5 0.06 19.6 85.7 1.8 7.8 1.3 5.6 7.8 12.7 12.9 56.5 0.06 19.6 85.7 1.8 7.8 1.3 5.6 2.6 11.4 4.4 19.3 0.02 8.1 35.7 1.6 7.2 0.9 3.9 1.6 2.6 4.0 17.3 0.09 4.0 17.5 0.4 1.6 0.3 1.2 1.4 2.3 9.5 31.6 3.5 15.2 0.3 1.4 0.2 1.0 1.2 1.9 3.5 15.2 2.9 12.8 0.3 1.2 0.2 0.8 2.0 3.2 2.9 12.5 0.0527 4.9 21.5 0.4 2.0 0.3 1.4 2.8 4.6 4.2 18.3 0.0535 7.1 31.1 0.6 2.8 0.5 2.0 0.4 0.7 2.2 9.5 1.1 4.9 0.1 0.4 0.1 0.3 1.5 2.5 3.2 14.0 3.8 16.8 0.4 1.5 0.3 1.1 1.5 2.5 3.8 16.6 3.8 16.8 0.4 1.5 0.3 1.1 0.4 0.7 1.2 5.2 1.0 4.4 0.1 0.4 0.1 0.3 1.3 2.1 4.6 20.2 3.2 14.0 0.3 1.3 0.2 0.9 7.3 11.8 9.0 39.4 0.045 18.2 79.7 1.7 7.2 1.2 5.2 24 40/50/35 0.9 1.4 2.2 9.5 - 2.2 9.6 0.2 0.9 0.1 0.6 4.6 7.4 6.9 30.1 0.055 11.4 49.8 1.0 4.5 0.7 3.3 27 9.6 84 78 27 120 9.6 52 32.0 60/60 1.0 0.4 3.1 2.8 1.0 4.4 0.4 1.9 1.2 0.2 1.6 0.6 5.0 4.6 1.6 7.1 0.6 3.1 1.9 0.8 2.4 0.5 4.7 3.5 1.2 3.6 0.3 1.6 1.0 4.2 10.6 2.3 20.3 15.4 5.3 15.8 1.3 6.8 4.2 18.4 0.09 0.05 0.045 0.045 0.03 0.03 0.03 0.03 0.035 2.5 0.9 7.6 7.1 2.5 7.2 0.9 4.7 2.9 10.9 10.8 3.8 33.5 31.1 10.8 31.5 3.8 20.7 12.8 47.8 0.2 0.1 0.7 0.6 0.2 1.0 0.1 0.4 0.3 1.0 1.0 0.4 3.03 2.8 1.0 4.3 0.4 1.9 1.2 4.3 0.2 0.1 0.5 0.5 0.2 0.7 0.1 0.3 0.2 0.7 0.7 0.3 2.2 2.0 0.7 3.1 0.3 1.4 0.8 3.1 EPA Inspection Report - Page 941 of 1969 2NOx SO2 3,5MM Source ID Btu/hr /8802 H-9851 337 H-5401 6.44 H-0473 NA (SRU1/SRU 2 TGI) SRU3-TGI NA FCC NA Regenerator FL-0400, NA North Plant Flare FL-0401, NA South Plant Flare FL-0402, NA FCC Flare FL-0403, NA Alky Flare FL-0404, NA GOHT Flare Subtotal Tanks, Table 106.E Fugitives, Table 106.F Misc Sources, Table 106.G 4PM CO VOC H2S 5(lb/MM 5 (lb/hr) (ton/yr) 5(lb/hr) (ton/yr) Btu) 5(lb/hr) (ton/yr) (lb/hr) (ton/yr) 5(lb/hr) (ton/yr) (lb/hr) (ton/yr) 0.5 0.71 2.2 1.1 4.2 0.64 18.5 2.8 0.0125 0.03 20.2 0.64 88.6 2.8 2.8 0.16 12.2 0.7 2.0 0.12 8.8 0.5 30.0 81.8 6.5 28.5 N/A 27.7 121.2 0.5 2.2 0.1 0.6 0.3 1.31 30.0 81.8 6.5 28.5 N/A 15.0 65.7 0.5 2.2 0.1 0.6 0.3 1.31 27.9 61.0 35.0 101.9 N/A 121.9 106.8 25.0 109.5 - - 0.2 0.5 0.2 0.8 N/A 1.0 4.3 0.0 0.0 0.2 0.7 0.1 0.1 <0.1 0.2 N/A 0.2 1.1 0.0 0.0 <0.1 0.2 0.1 0.1 <0.1 0.2 N/A 0.2 1.1 0.0 0.0 <0.1 0.2 <0.1 <0.1 <0.1 <0.1 N/A <0.1 0.2 0.0 0.0 <0.1 <0.1 2.4 10.5 4.1 18.1 N/A 13.6 59.6 0.0 0.0 2.3 10.2 346.6 697.9 1181.4 197.8 96.2 297.3 1022.6 16.6 1.1 0.83 EPA Inspection Report - Page 942 of 1969 2NOx SO2 3,5MM Source ID Btu/hr Cooling Towers, Table 106.H Oil/Water Separators, Table 106.I 6 SSM, Table 107 Site TOTAL NA 1 1 4PM CO VOC H2S 5(lb/MM 5 (lb/hr) (ton/yr) 5(lb/hr) (ton/yr) Btu) 5(lb/hr) (ton/yr) (lb/hr) (ton/yr) 5(lb/hr) (ton/yr) (lb/hr) (ton/yr) 2.5 8.9 56.2 1.3 27.5 31.7 374.1 729.6 N/A 98.0 0.4 1281.9 207.1 5.9 36.2 1531.0 14.32 1.7 Totals are for information and are not enforceable conditions. Nitrogen dioxide emissions include all oxides of nitrogen expressed as NO2 3 lbs-NOX/MMBtu of heat input, calculated as a 3-hour average, when firing natural gas at 3% stack oxygen at full design load without air preheat. 4 All Particulate Matter emitted is assumed to be of aerodynamic diameter 10 microns or less. 5 Hourly emission limits and lb/MM Btu limits are based on an hourly rolling 3-hour average. 6 Maximum allowable emissions during maintenance, startup, or shutdown (SSM) and malfunction activities. “-” or leaving a cell blank indicates that in accordance with the application, emissions of this pollutant are not expected. “- -” indicates that the emissions are less than 1.0 pph or 1.0 tpy and emission limits are not required for this permit, unless it’s for a control device. Unit 9851 has Ammonia Slip limit of 7 ppmv on a wet basis and 6.1 tpy 2 0.60 4.05 EPA Inspection Report - Page 943 of 1969 TABLE 106.B(1) VAPOR PRESSURE LIMITATIONS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOC) INTERNAL FLOATING ROOF STORAGE TANKS T-0056 T-0106 T-0107 Naphthas Sour Water Gasolines Most Volatile Category of Allowable Liquids to be Stored1 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 T-0108 Gasolines High Vapor Pressure2 11.0 T-0109 Gasolines High Vapor Pressure2 11.0 T-0111 Gasolines High Vapor Pressure2 11.0 T-0112 T-0011 Gasolines Gasolines 2 High Vapor Pressure High Vapor Pressure2 11.0 11.0 T-0124 Gasolines High Vapor Pressure2 11.0 T-0012 Gasolines High Vapor Pressure2 11.0 T-0413 Distillates High Vapor Pressure2 11.0 T-0415 Gasolines 2 High Vapor Pressure 11.0 T-0417 Gasolines High Vapor Pressure2 11.0 2 Tank No. 1 2 Typical Liquid Stored Max Vapor Pressure (psia) of Most Volatile Liquid at Max Temp. 11.0 11.0 11.0 T-0439 Naphtha High Vapor Pressure 11.0 T-0451 Biodiesel High Vapor Pressure2 11.0 T-0452 Ethanol High Vapor Pressure2 11.0 Liquids in lower volatility categories may also be stored (i.e., tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allowed to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub-grade, regular, premium, and other blends), Alkylate, Reformate, FCC Gasoline, Ethanol, Isomerate, Straight Run Gasoline, and other refinery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 11 psia or less under actual storage conditions. EPA Inspection Report - Page 944 of 1969 TABLE 106.B(2) VAPOR PRESSURE LIMITATIONS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOC) Tank No. T-0057 T-0079 T-0117 T-0401 T-0402 T-0411 T-0412 T-0435 T-0437 T-0450 T-0802 T-0830 T-0834 T-0835 T-1225 EXTERNAL FLOATING ROOF STORAGE TANKS Typical Liquid Most Volatile Category of Max Vapor Pressure Stored Allowable Liquids to be (psia) of Most 1 Stored Volatile Liquid at Max Temp. Naphthas Gasolines Gasolines Gasolines Gasolines Gasolines Gasolines Sour Water Crude Oil Naphthas Sour Water Slop Distillates Distillates Crude Oil High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 Moderate Vapor Pressure3 High Vapor Pressure2 High Vapor Pressure2 11.0 11.0 11.0 11.0 11.0 11.0 11.0 11.0 11.0 11.0 11.0 11.0 1.5 11.0 11.0 T-0737 Sour Water High Vapor Pressure2 11.0 2 T-5401 Gasolines High Vapor Pressure 11.0 1 Liquids in lower volatility categories may also be stored (i.e., tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allowed to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). 2 High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub-grade, regular, premium, and other blends), Alkylate, Reformate, FCC Gasoline, Ethanol, Isomerate, Straight Run Gasoline, and other refinery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 11 psia or less under actual storage conditions. 3 Moderate Vapor Pressure Liquids include: Desulfurized Naphtha (Splitter Bottoms), Light Slop, and other refinery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 1.5 psia or less under actual storage conditions. EPA Inspection Report - Page 945 of 1969 TABLE 106.C VAPOR PRESSURE LIMITATIONS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOCs) FIXED ROOF STORAGE TANKS Tank No. Typical Liquid Stored Most Volatile Category of Allowable Liquids to be Stored1 Max Vapor Pressure (psia) of Most Volatile Liquid at Max Temp. T-0040 Spent Caustic Low Vapor Pressure4 0.5 T-0041 Spent Caustic Low Vapor Pressure4 0.5 T-0110 Asphalt/Pitch Low Vapor Pressure4 0.5 T-0400 Gas Oils Low Vapor Pressure4 0.5 T-0410 Asphalt/Pitch Low Vapor Pressure4 0.5 T-0418 Distillates Low Vapor Pressure4 0.5 T-0419 Distillates Low Vapor Pressure4 0.5 T-0420 Fuel Oil Low Vapor Pressure4 0.5 T-0422 Black Oil Low Vapor Pressure4 0.5 T-0423 Black Oil Low Vapor Pressure4 0.5 T-0431 Fuel Oil Low Vapor Pressure4 0.5 T-0432 Fuel Oil Low Vapor Pressure4 0.5 EPA Inspection Report - Page 946 of 1969 TABLE 106.C –cont’d EMISSION LIMITATIONS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOCs) Tank No. T-0049 T-0055 T-0059 T-0061 T-0063 T-0065 T-0075 T-0433 T-0434 T-0438 T-0814 T-0815 T-0838 T-1227 T-0081 T-0082 RW-4 RW-5 RW-6 1 FIXED ROOF STORAGE TANKS Typical Liquid Stored Most Volatile Category of Max Vapor Pressure Allowable Liquids to be (psia) of Most Volatile Stored1 Liquid at Max Temp. Slop Distillates Distillates Distillates Black Oil Black Oil Black Oil Gas Oils Distillates Gas Oils Asphalt/Pitch Distillates Distillates Asphalt/Pitch Asphalt/Pitch Asphalt/Pitch Recovery Well Hydrocarbons Recovery Well Hydrocarbons Recovery Well Hydrocarbons Moderate Vapor Pressure3 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 Low Vapor Pressure4 High Vapor Pressure2 High Vapor Pressure2 High Vapor Pressure2 Liquids in lower volatility categories may also be stored (i.e., tanks allowed to store high vapor pressure category liquids can also store moderate and low vapor pressure category liquids; tanks allowed to store moderate vapor pressure category liquids can also store low vapor pressure category liquids). 2 High Vapor Pressure Liquids include: Crude, Naphtha (raw or treated), Unleaded Gasolines (sub-grade, regular, premium, and other blends), Alkylate, Reformate, FCC Gasoline, Ethanol, Isomerate, Straight Run Gasoline, and other refinery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 11 psia or less under actual storage conditions. 3 Moderate Vapor Pressure Liquids include: Desulfurized Naphtha (Splitter Bottoms), Light Slop, and other refinery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure of 1.5 psia or less under actual storage conditions. 4 Low Vapor Pressure Liquids include: Diesel (raw or finished), Kerosene (raw or finished), JP-8, CBO, LCO, Slurry, Heavy Slop, Cutback Asphalt, Cutter, VGO, AGO, and other refinery feedstocks, intermediates, products, byproducts, and wastes having a max vapor pressure less than 0.5 psia under actual storage conditions. 1.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 11.0 11.0 11.0 EPA Inspection Report - Page 947 of 1969 TABLE 106.D – STORAGE TANK THROUGHPUT AND TEMPERATURE LIMITS Material Throughput (bbl/yr) Maximum Storage Temperature (ºF) Asphalt/Pitch 30,872,000 510 Black Oil 3,305,356 250 Crude Oil 76,212,000 Ambient Distillate 158,185,540 Ambient Gas Oil 25,059,500 310 Gasoline (includes isomerates) 63,438,600 Ambient Naphtha 47,632,500 Ambient Slop 1,049,590 Ambient Sour Water 15,030,000 Ambient BioDiesel 949,000 Ambient Ethanol 142,350 Ambient Fuel Oil 10,609,022 Ambient Spent Caustic 56,000 Ambient Ground Water 7,200 Ambient TABLE 106.E– STORAGE TANK VOC AND H2S EMISSION LIMITS1 1 Tank Type VOC Emission Rate (tpy) H2S Emission Rate (tpy) Fixed-Roof 195.53 0.0 Floating-Roof 101.77 0.83 Total Tanks 297.30 0.83 See Specific Condition A203.E for monitoring, recordkeeping and reporting requirements. EPA Inspection Report - Page 948 of 1969 Table 106.F 1EMISSIONS LIMITS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOC) FUGITIVE EMISSIONS FROM EQUIPMENT LEAKS Process Unit ID Number FUG-02-SP CRUDE FUG-10-FCC FUG-20-ISOM FUG-21-SP VACUUM FUG-05-KERO FUG-06-NHDU FUG-18-LSR MEROX TRT FUG-35-SAT GAS FUG-29BLENDER/TK FARM FUG-ASPHALT STG FUG-FUEL GAS FUG-LPG FUG-41-PBC FUG-70-CCR FUG-13-NHDU FUG-43-S ALKY FUG-09-N ALKY FUG-44-DIST-HDU FUG-45-DIST-HDU FUG-07-N AMINE FUGSRU1/SRU2/TGTU FUG-07-SWS1 FUG-80-WWTP CVS FUG-33-DIST HDU FUG-08-TRUCK RK FUG-RLO-ASPHALT FUG-73-SP UTIL FUG-63-H2 PLANT-1 FUG-31SRU3/TGTU3/TGI3 FUG-34- Maximum Hourly VOC Emission Rate (lb/hr) 10.2 10.8 5.94 3.2 5.2 7.11 3.5 Average Annual VOC Emission Rate (tons/yr) 44.6 47.2 26.03 13.9 22.7 31.15 15.3 Saturates Gas Plant Light Oil Tankage 18.3 6.8 80.0 29.6 Asphalt/Heavy Oil Storage Fuel Gas Distribution System LPG Storage System PBC Unit CCR Reformer (w/in battery limits) Naphtha HDS Unit 13 South Alky Unit (W-76) North Alkylation Unit (NewInside battery limits) Gas Oil Hydrotreater (incl. CVS) Gas Oil Hydrotreater (incl. CVS) Amine Unit-Treating/Regen. SRU1/SRU2/SWS w/CVS 3.5 4.2 21.6 3.4 23.4 15.3 18.2 94.4 14.7 102.3 10.17 1.7 12.0 44.55 7.5 52.5 9.39 2.6 6.3 2.4 41.14 11.2 27.5 10.4 1.6 1.3 13.47 7.0 5.9 59.01 2.8 0.7 16.7 2.6 0.7 12.1 2.9 73.3 11.2 3.1 6.2 27.2 Description South Division Crude Unit FCC w/CVS BenFree Unit Flasher/Vacuum Unit Kerosene HDS Unit Naphtha HDS Unit 06 Merox/Merichem Treating Units Sour Water Stripper Oil/Water Separator Relocated Diesel HDS Unit w/CVS Loading Racks Asphalt/Pitch Loading Rack Utilities Hydrogen Plant SRU3 Unit WX Hydrocracker EPA Inspection Report - Page 949 of 1969 Process Unit ID Number Maximum Hourly VOC Emission Rate (lb/hr) Description HYDROCRACKER FUG-25-ROSE-2 FUG-64-H2 PLANT-2 FUG-RRTOTRUCK 1 Average Annual VOC Emission Rate (tons/yr) ROSE Unit 8.0 35.1 Hydrogen Plant 2.6 11.2 Crude oil unloading system, 0.1 0.5 closed loop system between railcars and trucks FUG-54-PRIMEG Prime G Unit 5.6 24.7 Subtotal (for informational purposes only, may differ due to 234.084 1,023.38 rounding) Minor changes within the facility to piping and components that affect fugitive VOC emission source shall be updated and added during the next available significant modification to the NSR permit. The VOC total emissions have a safety level due to rounding to accommodate these minor variations in emissions. Table 106.G EMISSION LIMITS FOR REFINERY NON-COMBUSTION SOURCES Of VOLATILE ORGANIC COMPOUNDS (VOCs) -MISCELLANEOUS SOURCESMaximum Average Hourly VOC Annual VOC Emission Emission Source ID Description Rate (lb/hr) Rate (tons/yr) Asphalt Truck Loading and Off-Loading TLO-1 Rack #1 <0.1 <0.1 TL-2 Asphalt Truck Loading Rack #2 <0.1 <0.1 a TL-4 Fuels Truck Loading Rack 6.7 4.9 TL-7 CBO/LCO Truck Loading Rack 6.3 1.6 RLO-8 Railcar Loading & Off-Loading Rack 6.3 2.1 RLO-19 Railcar Loading & Off-Loading Rack 8.4 5.6 TLO-20 Asphalt/Pitch Truck Loading Rack <0.1 <0.1 FUG-ODOR Odor Controlling Atomizer 0.46 2.0 Subtotal (for informational purposes only) 28.6 16.6 a Controlled emission rate. The previous controlled rate was set by the terms of the consent agreement between Navajo Refining Co. and the Department executed January 28, 1994. The agreement required that the incinerator have a minimum 90% destruction efficiency for gasoline loading and a minimum 80% destruction efficiency for diesel fuel loading or Jet A fuel loading. This was achieved by a vapor combustor. This device has since been replaced with a carbon adsorption system compliant with MACT Subpart R, as subject per MACT Subpart CC. Emission limits changed in 195-M-17 to correspond to Title V permit values. EPA Inspection Report - Page 950 of 1969 Table 106.H EMISSION LIMITS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUMDS and PM -COOLING TOWERSSource ID VOC VOC PM PM lb/hr tons/yr (lb/hr) (tons/yr) Y-0001 1.8 7.9 0.3 1.2 Y-0002 1.8 7.9 0.3 1.2 a Y-0008 6.5 28.3 0.7 2.9 Y-0011 1.3 5.5 0.5 2.3 Y-0012 0.4 1.8 0.2 0.8 CT TT-0006 1.1 4.7 0.2 0.7 Subtotal (for 12.8 56.2 2.1 9.0 informational purposes only) a Y-0008 includes 0.58 lbs/hour CO and 2.54 tpy CO. This cooling tower provides 100% control of any NH3 emissions from V-H2 and V-H2-2. Unit 64, Hydrogen Plant has de-aerator line that has dissolved CO that is connected to the cooling tower. Table 106.I EMISSION LIMITS FOR REFINERY NON-COMBUSTION SOURCES OF VOLATILE ORGANIC COMPOUNDS (VOCs) API OIL/WATER SEPARATORS Maximum Average Hourly Annual VOC VOC Emission Emission Rate Rate Equipment ID Emission Point ID Description (lb/hr) (tons/yr) Above Ground API OilWater Separators and MAIN API D-0829/0830 enclosed drain system. <0.1 <0.1 T-0896 DAF-0896 DAF Unit T-0896 0.2 0.7 Enhanced Biodegradation Tank TT-0801 T-0801 0801 0.2 1.0 Enhanced Biodegradation Tank TT-0836 T-0836 0836 0.8 3.5 Equalization Tank TT-0829 T-0829 0829 <0.1 <0.1 T-0806 DAF-0806 DAF Unit T-0806 0.2 0.7 Subtotal (for informational purposes only) 1.3 5.9 EPA Inspection Report - Page 951 of 1969 Table 107.A [return] MAINTENANCE STARTUP AND SHUTDOWN EMISSION LIMITS PM/PM10/PM Unit SSM H-9851 SSM T-0737 SSM SRU3TGI SSM FL-HEPPORT SSM SRU2TGI (H-0473) SSM Flare Cap Flares Malf Cap SSM Misc 2 SSM Tanks Misc Subtotal SSM/M1 Description of Emissions Emissions during SCR downtime Emissions from roof landing Emissions from SRU3 startup and shutdown Temporary, portable flare for natural gas pipeline maintenance Emissions from SRU2 startup and shutdown Emissions from venting MSS activity gases to FL-400, FL401,FL-402, FL-403, or FL-404. Upset and Malfunction Emissions Low-Emitting Maintenance Activities such as de-inventorying small equipment, clearing piping associated with emission units, and routine maintenance activities such as heat exchanger repair. Storage Tanks NOx pph tpy 10.1 1.2 --- pph 20.2 -- tpy 2.4 -- VOC pph tpy 2.0 0.2 33.0 0.5 pph 2.8 -- tpy 0.3 -- pph 0.5 -- tpy 0.1 -- H2S pph tpy ----- 6.5 0.1 15.0 0.1 0.1 0.1 -- -- 159.0 0.4 6.5 0.1 173.4 0.1 943.5 0.5 160.7 0.1 -- -- 1.7 0.1 0.02 0.1 6.5 0.1 27.7 0.2 0.2 0.1 -- -- 159.0 0.4 6.6 0.1 162.9 -- 18.3 10.0 1243.0 -- 77.0 10.0 211.6 -- 13.2 10.0 --- --- 1133. 4 -- 14.9 10.0 0.4 -- 0.1 -- 17.0 1.9 127.1 7.8 21.2 1.4 -- -- 129.3 1.6 0.7 0.1 -- -- -- -- 173.1 10.6 -- -- -- -- 0.1 0.1 27.5 14.32 0.6 31.7 CO 98.0 36.2 SO2 2.5 0.3 EPA Inspection Report - Page 952 of 1969 AIR QUALITY BUREAU NEW SOURCE REVIEW PERMIT Issued under 20.2.72 NMAC GENERAL CONDITIONS AND MISCELLANEOUS Part B B100 B101 B102 B103 B104 B105 B106 B107 B108 B109 B110 B111 B112 B113 B114 B115 B116 Part C C100 C101 C102 TABLE OF CONTENTS GENERAL CONDITIONS .......................................................................................... B2 Introduction ............................................................................................................... B2 Legal ......................................................................................................................... B2 Authority ................................................................................................................... B3 Annual Fee ................................................................................................................ B3 Appeal Procedures .................................................................................................... B3 Submittal of Reports and Certifications .................................................................... B4 NSPS and/or MACT Startup, Shutdown, and Malfunction Operations ................... B4 Startup, Shutdown, and Maintenance Operations ..................................................... B5 General Monitoring Requirements ........................................................................... B5 General Recordkeeping Requirements ..................................................................... B6 General Reporting Requirements .............................................................................. B9 General Testing Requirements ................................................................................ B10 Compliance ............................................................................................................. B12 Permit Cancellation and Revocation....................................................................... B13 Notification to Subsequent Owners ........................................................................ B13 Asbestos Demolition ............................................................................................... B14 Short Term Engine Replacement ............................................................................ B14 MISCELLANEOUS ..................................................................................................... C1 Supporting On-Line Documents ............................................................................... C1 Definitions................................................................................................................. C1 Acronyms .................................................................................................................. C3 EPA Inspection Report - Page 953 of 1969 PART B GENERAL CONDITIONS B100 Introduction A. The Department has reviewed the permit application for the proposed construction/modification/revision and has determined that the provisions of the Act and ambient air quality standards will be met. Conditions have been imposed in this permit to assure continued compliance. 20.2.72.210.D NMAC, states that any term or condition imposed by the Department on a permit is enforceable to the same extent as a regulation of the Environmental Improvement Board. B101 Legal A. The contents of a permit application specifically identified by the Department shall become the terms and conditions of the permit or permit revision. Unless modified by conditions of this permit, the permittee shall construct or modify and operate the Facility in accordance with all representations of the application and supplemental submittals that the Department relied upon to determine compliance with applicable regulations and ambient air quality standards. If the Department relied on air quality modeling to issue this permit, any change in the parameters used for this modeling shall be submitted to the Department for review. Upon the Department’s request, the permittee shall submit additional modeling for review by the Department. Results of that review may require a permit modification. (20.2.72.210.A NMAC) B. Any future physical changes, changes in the method of operation or changes in restricted area may constitute a modification as defined by 20.2.72 NMAC, Construction Permits. Unless the source or activity is exempt under 20.2.72.202 NMAC, no modification shall begin prior to issuance of a permit. (20.2.72 NMAC Sections 200.A.2 and E, and 210.B.4) C. Changes in plans, specifications, and other representations stated in the application documents shall not be made if they cause a change in the method of control of emissions or in the character of emissions, will increase the discharge of emissions or affect modeling results. Any such proposed changes shall be submitted as a revision or modification. (20.2.72 NMAC Sections 200.A.2 and E, and 210.B.4) D. The permittee shall establish and maintain the property’s Restricted Area as identified in plot plan submitted with the application. (20.2.72 NMAC Sections 200.A.2 and E, and 210.B.4) E. Applications for permit revisions and modifications shall be submitted to: Program Manager, Permits Section New Mexico Environment Department EPA Inspection Report - Page 954 of 1969 Air Quality Bureau 525 Camino de los Marquez, Suite 1 Santa Fe, NM 87505 F. The owner or operator of a source having an excess emission shall, to the extent practicable, operate the source, including associated air pollution control equipment, in a manner consistent with good air pollutant control practices for minimizing emissions. (20.2.7.109 NMAC). The establishment of allowable malfunction emission limits does not supersede this requirement. B102 Authority A. This permit is issued pursuant to the Air Quality Control Act (Act) and regulations adopted pursuant to the Act including Title 20, Chapter 2, Part 72 of the New Mexico Administrative Code (NMAC), (20.2.72 NMAC), Construction Permits and is enforceable pursuant to the Act and the air quality control regulations applicable to this source. B. The Department is the Administrator for 40 CFR Parts 60, 61, and 63 pursuant to the delegation and exceptions of Section 10 of 20.2.77 NMAC (NSPS), 20.2.78 NMAC (NESHAP), and 20.2.82 NMAC (MACT). B103 Annual Fee A. The Department will assess an annual fee for this Facility. The regulation 20.2.75 NMAC set the fee amount at $1,500 through 2004 and requires it to be adjusted annually for the Consumer Price Index on January 1. The current fee amount is available by contacting the Department or can be found on the Department’s website. The AQB will invoice the permittee for the annual fee amount at the beginning of each calendar year. This fee does not apply to sources which are assessed an annual fee in accordance with 20.2.71 NMAC. For sources that satisfy the definition of “small business” in 20.2.75.7.F NMAC, this annual fee will be divided by two. (20.2.75.11 NMAC) B. All fees shall be remitted in the form of a corporate check, certified check, or money order made payable to the “NM Environment Department, AQB” mailed to the address shown on the invoice and shall be accompanied by the remittance slip attached to the invoice. B104 Appeal Procedures A. Any person who participated in a permitting action before the Department and who is adversely affected by such permitting action, may file a petition for hearing before the Environmental Improvement Board. The petition shall be made in writing to the EPA Inspection Report - Page 955 of 1969 Environmental Improvement Board within thirty (30) days from the date notice is given of the Department's action and shall specify the portions of the permitting action to which the petitioner objects, certify that a copy of the petition has been mailed or hand-delivered and attach a copy of the permitting action for which review is sought. Unless a timely request for hearing is made, the decision of the Department shall be final. The petition shall be copied simultaneously to the Department upon receipt of the appeal notice. If the petitioner is not the applicant or permittee, the petitioner shall mail or hand-deliver a copy of the petition to the applicant or permittee. The Department shall certify the administrative record to the board. Petitions for a hearing shall be sent to: (20.2.72.207.F NMAC) Secretary, New Mexico Environmental Improvement Board 1190 St. Francis Drive, Runnels Bldg. Rm. N2153 Santa Fe, New Mexico 87502 B105 Submittal of Reports and Certifications A. Stack Test Protocols and Stack Test Reports shall be submitted electronically to Stacktest.AQB@state.nm.us or as directed by the Department. B. Excess Emission Reports shall be submitted as directed by the Department. (20.2.7.110 NMAC) C. Routine reports shall be submitted to the mailing address below, or as directed by the Department: Manager, Compliance and Enforcement Section New Mexico Environment Department Air Quality Bureau 525 Camino de los Marquez, Suite 1 Santa Fe, NM 87505 B106 NSPS and/or MACT Startup, Shutdown, and Malfunction Operations A. If a facility is subject to a NSPS standard in 40 CFR 60, each owner or operator that installs and operates a continuous monitoring device required by a NSPS regulation shall comply with the excess emissions reporting requirements in accordance with 40 CFR 60.7(c), unless specifically exempted in the applicable subpart. B. If a facility is subject to a NSPS standard in 40 CFR 60, then in accordance with 40 CFR 60.8(c), emissions in excess of the level of the applicable emission limit during periods of startup, shutdown, and malfunction shall not be considered a violation of the applicable emission limit unless otherwise specified in the applicable standard. EPA Inspection Report - Page 956 of 1969 C. If a facility is subject to a MACT standard in 40 CFR 63, then the facility is subject to the requirement for a Startup, Shutdown and Malfunction Plan (SSM) under 40 CFR 63.6(e)(3), unless specifically exempted in the applicable subpart. B107 Startup, Shutdown, and Maintenance Operations A. The establishment of permitted startup, shutdown, and maintenance (SSM) emission limits does not supersede the requirements of 20.2.7.14.A NMAC. Except for operations or equipment subject to Condition B106, the permittee shall establish and implement a plan to minimize emissions during routine or predictable start up, shut down, and scheduled maintenance (SSM work practice plan) and shall operate in accordance with the procedures set forth in the plan. (SSM work practice plan) (20.2.7.14.A NMAC) B108 General Monitoring Requirements A. These requirements do not supersede or relax requirements of federal regulations. B. The following monitoring requirements shall be used to determine compliance with applicable requirements and emission limits. Any sampling, whether by portable analyzer or EPA reference method, that measures an emission rate over the applicable averaging period greater than an emission limit in this permit constitutes noncompliance with this permit. The Department may require, at its discretion, additional tests pursuant to EPA Reference Methods at any time, including when sampling by portable analyzer measures an emission rate greater than an emission limit in this permit; but such requirement shall not be construed as a determination that the sampling by portable analyzer does not establish noncompliance with this permit and shall not stay enforcement of such noncompliance based on the sampling by portable analyzer. C. If the emission unit is shutdown at the time when periodic monitoring is due to be completed, the permittee is not required to restart the unit for the sole purpose of conducting the monitoring. Using electronic or written mail, the permittee shall notify the Department’s Compliance and Enforcement Section of a delay in emission tests prior to the deadline for completing the tests. Upon recommencing operation, the permittee shall submit pre-test notification(s) to the Department’s Compliance and Enforcement Section and shall complete the monitoring. D. The requirement for monitoring during any monitoring period is based on the percentage of time that the unit has operated. However, to invoke the monitoring period exemption at B108.D(2), hours of operation shall be monitored and recorded. (1) If the emission unit has operated for more than 25% of a monitoring period, then the permittee shall conduct monitoring during that period. EPA Inspection Report - Page 957 of 1969 (2) If the emission unit has operated for 25% or less of a monitoring period then the monitoring is not required. After two successive periods without monitoring, the permittee shall conduct monitoring during the next period regardless of the time operated during that period, except that for any monitoring period in which a unit has operated for less than 10% of the monitoring period, the period will not be considered as one of the two successive periods. (3) If invoking the monitoring period exemption in B108.D(2), the actual operating time of a unit shall not exceed the monitoring period required by this permit before the required monitoring is performed. For example, if the monitoring period is annual, the operating hours of the unit shall not exceed 8760 hours before monitoring is conducted. Regardless of the time that a unit actually operates, a minimum of one of each type of monitoring activity shall be conducted during any five-year period. E. For all periodic monitoring events, except when a federal or state regulation is more stringent, three test runs shall be conducted at 90% or greater of the unit’s capacity as stated in this permit, or in the permit application if not in the permit, and at additional loads when requested by the Department. If the 90% capacity cannot be achieved, the monitoring will be conducted at the maximum achievable load under prevailing operating conditions except when a federal or state regulation requires more restrictive test conditions. The load and the parameters used to calculate it shall be recorded to document operating conditions and shall be included with the monitoring report. F. When requested by the Department, the permittee shall provide schedules of testing and monitoring activities. Compliance tests from previous NSR and Title V permits may be re-imposed if it is deemed necessary by the Department to determine whether the source is in compliance with applicable regulations or permit conditions. G. If monitoring is new or is in addition to monitoring imposed by an existing applicable requirement, it shall become effective 120 days after the date of permit issuance. For emission units that have not commenced operation, the associated new or additional monitoring shall not apply until 120 days after the units commence operation. All preexisting monitoring requirements incorporated in this permit shall continue to apply from the date of permit issuance. B109 General Recordkeeping Requirements A. The permittee shall maintain records to assure and verify compliance with the terms and conditions of this permit and any other applicable requirements that become effective after permit issuance. The minimum information to be included in these records is as follows: (1) Records required for testing and sampling: EPA Inspection Report - Page 958 of 1969 (2) (a) equipment identification (include make, model and serial number for all tested equipment and emission controls) (b) date(s) and time(s) of sampling or measurements (c) date(s) analyses were performed (d) the qualified entity that performed the analyses (e) analytical or test methods used (f) results of analyses or tests (g) operating conditions existing at the time of sampling or measurement Records required for equipment inspections and/or maintenance required by this permit: (a) equipment identification number (including make, model and serial number) (b) date(s) and time(s) of inspection, maintenance, and/or repair (c) date(s) any subsequent analyses were performed (if applicable) (d) name of the person or qualified entity conducting the inspection, maintenance, and/or repair (e) (f) (g) (h) (i) B. copy of the equipment manufacturer’s or the owner or operator’s maintenance or repair recommendations (if required to demonstrate compliance with a permit condition) description of maintenance or repair activities conducted all results of any required parameter readings a description of the physical condition of the equipment as found during any required inspection results of required equipment inspections including a description of any condition which required adjustment to bring the equipment back into compliance and a description of the required adjustments Except as provided in the Specific Conditions, records shall be maintained on-site or at the permittee’s local business office for a minimum of two (2) years from the time of recording and shall be made available to Department personnel upon request. Sources subject to 20.2.70 NMAC “Operating Permits” shall maintain records on-site for a minimum of five (5) years from the time of recording. EPA Inspection Report - Page 959 of 1969 C. Unless otherwise indicated by Specific Conditions, the permittee shall keep the following records for malfunction emissions and routine or predictable emissions during startup, shutdown, and scheduled maintenance (SSM): (1) The owner or operator of a source subject to a permit shall establish and implement a plan to minimize emissions during routine or predictable startup, shutdown, and scheduled maintenance through work practice standards and good air pollution control practices. This requirement shall not apply to any affected facility defined in and subject to an emissions standard and an equivalent plan under 40 CFR Part 60 (NSPS), 40 CFR Part 63 (MACT), or an equivalent plan under 20.2.72 NMAC - Construction Permits, 20.2.70 NMAC - Operating Permits, 20.2.74 NMAC Permits - Prevention of Significant Deterioration (PSD), or 20.2.79 NMAC Permits - Nonattainment Areas. The permittee shall keep records of all sources subject to the plan to minimize emissions during routine or predictable SSM and shall record if the source is subject to an alternative plan and therefore, not subject to the plan requirements under 20.2.7.14.A NMAC. (2) If the facility has allowable SSM emission limits in this permit, the permittee shall record all SSM events, including the date, the start time, the end time, a description of the event, and a description of the cause of the event. This record also shall include a copy of the manufacturer’s, or equivalent, documentation showing that any maintenance qualified as scheduled. Scheduled maintenance is an activity that occurs at an established frequency pursuant to a written protocol published by the manufacturer or other reliable source. The authorization of allowable SSM emissions does not supersede any applicable federal or state standard. The most stringent requirement applies. (3) If the facility has allowable malfunction emission limits in this permit, the permittee shall record all malfunction events to be applied against these limits. The permittee shall also include the date, the start time, the end time, and a description of the event. Malfunction means any sudden and unavoidable failure of air pollution control equipment or process equipment beyond the control of the owner or operator, including malfunction during startup or shutdown. A failure that is caused entirely or in part by poor maintenance, careless operation, or any other preventable equipment breakdown shall not be considered a malfunction. (20.2.7.7.E NMAC) The authorization of allowable malfunction emissions does not supersede any applicable federal or state standard. The most stringent requirement applies. This authorization only allows the permittee to avoid submitting reports under 20.2.7 NMAC for total annual emissions that are below the authorized malfunction emission limit. (4) The owner or operator of a source shall meet the operational plan defining the measures to be taken to mitigate source emissions during malfunction, startup or shutdown. (20.2.72.203.A(5) NMAC) EPA Inspection Report - Page 960 of 1969 B110 General Reporting Requirements (20.2.72 NMAC Sections 210 and 212) A. Records and reports shall be maintained on-site or at the permittee’s local business office unless specifically required to be submitted to the Department or EPA by another condition of this permit or by a state or federal regulation. Records for unmanned sites may be kept at the nearest business office. B. The permittee shall notify the Department’s Compliance Reporting Section using the current Submittal Form posted to NMED’s Air Quality web site under Compliance and Enforcement/Submittal Forms in writing of, or provide the Department with (20.2.72.212.A and B): (1) the anticipated date of initial startup of each new or modified source not less than thirty (30) days prior to the date. Notification may occur prior to issuance of the permit, but actual startup shall not occur earlier than the permit issuance date; (2) after receiving authority to construct, the equipment serial number as provided by the manufacturer or permanently affixed if shop-built and the actual date of initial startup of each new or modified source within fifteen (15) days after the startup date; and (3) the date when each new or modified emission source reaches the maximum production rate at which it will operate within fifteen (15) days after that date. C. The permittee shall notify the Department’s Permitting Program Manager, in writing of, or provide the Department with (20.2.72.212.C and D): (1) any change of operators or any equipment substitutions within fifteen (15) days of such change; (2) any necessary update or correction no more than sixty (60) days after the operator knows or should have known of the condition necessitating the update or correction of the permit. D. Results of emission tests and monitoring for each pollutant (except opacity) shall be reported in pounds per hour (unless otherwise specified) and tons per year. Opacity shall be reported in percent. The number of significant figures corresponding to the full accuracy inherent in the testing instrument or Method test used to obtain the data shall be used to calculate and report test results in accordance with 20.2.1.116.B and C NMAC. Upon request by the Department, CEMS and other tabular data shall be submitted in editable, MS Excel format. E. The permittee shall submit reports of excess emissions in accordance with 20.2.7.110.A NMAC. EPA Inspection Report - Page 961 of 1969 B111 General Testing Requirements A. Compliance Tests (1) Compliance test requirements from previous permits (if any) are still in effect, unless the tests have been satisfactorily completed. Compliance tests may be reimposed if it is deemed necessary by the Department to determine whether the source is in compliance with applicable regulations or permit conditions. (20.2.72 NMAC Sections 210.C and 213) (2) Compliance tests shall be conducted within sixty (60) days after the unit(s) achieve the maximum normal production rate. If the maximum normal production rate does not occur within one hundred twenty (120) days of source startup, then the tests must be conducted no later than one hundred eighty (180) days after initial startup of the source. (3) Unless otherwise indicated by Specific Conditions or regulatory requirements, the default time period for each test run shall be at least 60 minutes and each performance test shall consist of three separate runs using the applicable test method. For the purpose of determining compliance with an applicable emission limit, the arithmetic mean of results of the three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the three runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances, beyond the owner or operator's control, compliance may, upon the Department approval, be determined using the arithmetic mean of the results of the two other runs. (4) Testing of emissions shall be conducted with the emissions unit operating at 90 to 100 percent of the maximum operating rate allowed by the permit. If it is not possible to test at that rate, the source may test at a lower operating rate, subject to the approval of the Department. (5) Testing performed at less than 90 percent of permitted capacity will limit emission unit operation to 110 percent of the tested capacity until a new test is conducted. (6) If conditions change such that unit operation above 110 percent of tested capacity is possible, the source must submit a protocol to the Department within 30 days of such change to conduct a new emissions test. B. EPA Reference Method Tests (1) All compliance tests required by this permit, unless otherwise specified by Specific Conditions of this permit, shall be conducted in accordance with the requirements of CFR Title 40, Part 60, Subpart A, General Provisions, and the following EPA Reference Methods as specified by CFR Title 40, Part 60, Appendix A: (a) Methods 1 through 4 for stack gas flowrate EPA Inspection Report - Page 962 of 1969 (2) C. (b) Method 5 for TSP (c) Method 6C and 19 for SO2 (d) Method 7E for NOX (test results shall be expressed as nitrogen dioxide (NO2) using a molecular weight of 46 lb/lb-mol in all calculations (each ppm of NO/NO2 is equivalent to 1.194 x 10-7 lb/SCF) (e) Method 9 for opacity (f) Method 10 for CO (g) Method 19 may be used in lieu of Methods 1-4 for stack gas flowrate upon approval of the Department. A justification for this proposal must be provided along with a contemporaneous fuel gas analysis (preferably on the day of the test) and a recent fuel flow meter calibration certificate (within the most recent quarter). (h) Method 7E or 20 for Turbines per 60.335 or 60.4400 (i) Method 29 for Metals (j) Method 201A for filterable PM10 and PM2.5 (k) Method 202 for condensable PM (l) Method 320 for organic Hazardous Air Pollutants (HAPs) (m) Method 25A for VOC reduction efficiency (n) Method 30B for Mercury Alternative test method(s) may be used if the Department approves the change Periodic Monitoring and Portable Analyzer Requirements (1) Periodic emissions tests (periodic monitoring) may be conducted in accordance with EPA Reference Methods or by utilizing a portable analyzer. Periodic monitoring utilizing a portable analyzer shall be conducted in accordance with the requirements of the current version of ASTM D 6522. However, if a facility has met a previously approved Department criterion for portable analyzers, the analyzer may be operated in accordance with that criterion until it is replaced. (2) Unless otherwise indicated by Specific Conditions or regulatory requirements, the default time period for each test run shall be at least 20 minutes. Each performance test shall consist of three separate runs. The arithmetic mean of results of the three runs shall be used to determine compliance with the applicable emission limit. (3) Testing of emissions shall be conducted in accordance with the requirements at Section B108.E. EPA Inspection Report - Page 963 of 1969 (4) During emissions tests, pollutant and diluent concentration shall be monitored and recorded. Fuel flow rate shall be monitored and recorded if stack gas flow rate is determined utilizing Method 19. This information shall be included with the test report furnished to the Department. (5) Stack gas flow rate shall be calculated in accordance with 40 CFR 60, Appendix A, Method 19 utilizing fuel flow rate (scf) determined by a dedicated fuel flow meter and fuel heating value (Btu/scf) determined from a fuel sample obtained preferably during the day of the test, but no earlier than three months prior to the test date. Alternatively, stack gas flow rate may be determined by using EPA Methods 1-4. D. Test Procedures: (1) The permittee shall notify the Department’s Program Manager, Compliance and Enforcement Section at least thirty (30) days before the test date and allow a representative of the Department to be present at the test. (2) Equipment shall be tested in the "as found" condition. Equipment may not be adjusted or tuned prior to any test for the purpose of lowering emissions, and then returned to previous settings or operating conditions after the test is complete. (3) Contents of test notifications, protocols and test reports shall conform to the format specified by the Department’s Universal Test Notification, Protocol and Report Form and Instructions. Current forms and instructions are posted to NMED’s Air Quality web site under Compliance and Enforcement Testing. (4) The permittee shall provide (a) sampling ports adequate for the test methods applicable to the facility, (b) safe sampling platforms, (c) safe access to sampling platforms and (d) utilities for sampling and testing equipment. (5) The stack shall be of sufficient height and diameter and the sample ports shall be located so that a representative test of the emissions can be performed in accordance with the requirements of EPA Method 1 or ASTM D 6522-00 as applicable. (6) Where necessary to prevent cyclonic flow in the stack, flow straighteners shall be installed (7) Unless otherwise indicated by Specific Conditions or regulatory requirements, test reports shall be submitted to the Department no later than 30 days after completion of the test. B112 Compliance A. The Department shall be given the right to enter the facility at all reasonable times to verify the terms and conditions of this permit. Required records shall be organized by date and subject matter and shall at all times be readily available for inspection. The permittee, upon verbal or written request from an authorized representative of the Department who appears at the facility, shall immediately produce for inspection or EPA Inspection Report - Page 964 of 1969 copying any records required to be maintained at the facility. Upon written request at other times, the permittee shall deliver to the Department paper or electronic copies of any and all required records maintained on site or at an off-site location. Requested records shall be copied and delivered at the permittee’s expense within three business days from receipt of request unless the Department allows additional time. Required records may include records required by permit and other information necessary to demonstrate compliance with terms and conditions of this permit. (NMSA 1978, Section 74-2-13) B. A copy of the most recent permit(s) issued by the Department shall be kept at the permitted facility or (for unmanned sites) at the nearest company office and shall be made available to Department personnel for inspection upon request. (20.2.72.210.B.4 NMAC) C. Emissions limits associated with the energy input of a Unit, i.e. lb/MMBtu, shall apply at all times unless stated otherwise in a Specific Condition of this permit. The averaging time for each emissions limit, including those based on energy input of a Unit (i.e. lb/MMBtu) is one (1) hour unless stated otherwise in a Specific Condition of this permit or in the applicable requirement that establishes the limit. B113 Permit Cancellation and Revocation A. The Department may revoke this permit if the applicant or permittee has knowingly and willfully misrepresented a material fact in the application for the permit. Revocation will be made in writing, and an administrative appeal may be taken to the Secretary of the Department within thirty (30) days. Appeals will be handled in accordance with the Department's Rules Governing Appeals From Compliance Orders. B. The Department shall automatically cancel any permit for any source which ceases operation for five (5) years or more, or permanently. Reactivation of any source after the five (5) year period shall require a new permit. (20.2.72 NMAC) C. The Department may cancel a permit if the construction or modification is not commenced within two (2) years from the date of issuance or if, during the construction or modification, work is suspended for a total of one (1) year. (20.2.72 NMAC) B114 Notification to Subsequent Owners A. The permit and conditions apply in the event of any change in control or ownership of the Facility. No permit modification is required in such case. However, in the event of any such change in control or ownership, the permittee shall notify the succeeding owner of the permit and conditions and shall notify the Department’s Program Manager, Permits Section of the change in ownership within fifteen (15) days of that change. (20.2.72.212.C NMAC) EPA Inspection Report - Page 965 of 1969 B. Any new owner or operator shall notify the Department’s Program Manager, Permits Section, within thirty (30) days of assuming ownership, of the new owner’s or operator’s name and address. (20.2.73.200.E.3 NMAC) B115 Asbestos Demolition A. Before any asbestos demolition or renovation work, the permittee shall determine whether 40 CFR 61 Subpart M, National Emissions Standards for Asbestos applies. If required, the permittee shall notify the Department’s Program Manager, Compliance and Enforcement Section using forms furnished by the Department. B116 Short Term Engine Replacement A. The following Alternative Operating Scenario (AOS) addresses engine breakdown or periodic maintenance and repair, which requires the use of a short term replacement engine. The following requirements do not apply to engines that are exempt per 20.2.72.202.B(3) NMAC. Changes to exempt engines must be reported in accordance with 20.2.72.202.B NMAC. A short term replacement engine may be substituted for any engine allowed by this permit for no more than 120 days in any rolling twelve month period per permitted engine. The compliance demonstrations required as part of this AOS are in addition to any other compliance demonstrations required by this permit. (1) The permittee may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with another engine regardless of manufacturer, model, and horsepower without modifying this permit. The permittee shall submit written notification to the Department within 15 days of the date of engine substitution according to condition B110.C(1). (a) The potential emission rates of the replacement engine shall be determined using the replacement engine’s manufacturer specifications and shall comply with the existing engine’s permitted emission limits. (b) The direction of the exhaust stack for the replacement engine shall be either vertical or the same direction as for the existing engine. The replacement engine’s stack height and flow parameters shall be at least as effective in the dispersion of air pollutants as the modeled stack height and flow parameters for the existing permitted engine. The following equation may be used to show that the replacement engine disperses pollutants as well as the existing engine. The value calculated for the replacement engine on the right side of the equation shall be equal to or greater than the value for the existing engine on the left side of the equation. The permitting page of the Air Quality Bureau website contains a spreadsheet that performs this calculation. EPA Inspection Report - Page 966 of 1969 EXISTING ENGINE REPLACMENT ENGINE [(g) x (h1)] + [(v1)2/2] + [(c) x (T1)] <= [(g) x (h2)] + [(v2)2/2] + [(c) x (T2)] q1 q2 Where g = gravitational constant = 32.2 ft/sec2 h1 = existing stack height, feet v1 = exhaust velocity, existing engine, feet per second c = specific heat of exhaust, 0.28 BTU/lb-degree F T1 = absolute temperature of exhaust, existing engine = degree F + 460 q1 = permitted allowable emission rate, existing engine, lbs/hour h2 = replacement stack height, feet v2 = exhaust velocity, replacement engine, feet per second T2 = absolute temperature of exhaust, replacement engine = degree F + 460 q2 = manufacturer’s potential emission rate, replacement engine, lbs/hour The permittee shall keep records showing that the replacement engine is at least as effective in the dispersion of air pollutants as the existing engine. (c) Test measurement of NOx and CO emissions from the temporary replacement engine shall be performed in accordance with Section B111 with the exception of Condition B111A(2) and B111B for EPA Reference Methods Tests or Section B111C for portable analyzer test measurements. Compliance test(s) shall be conducted within fifteen (15) days after the unit begins operation, and records of the results shall be kept according to section B109.B. This test shall be performed even if the engine is removed prior to 15 days on site. i. These compliance tests are not required for an engine certified under 40CFR60, subparts IIII, or JJJJ, or 40CFR63, subpart ZZZZ if the permittee demonstrates that one of these requirements causes such engine to comply with all emission limits of this permit. The permittee shall submit this demonstration to the Department within 48 hours of placing the new unit into operation. This submittal shall include documentation that the engine is certified, that the engine is within its useful life, as defined and specified in the applicable requirement, and shall include calculations showing that the applicable emissions standards result in compliance with the permit limits. ii. These compliance tests are not required if a test was conducted by portable analyzer or by EPA Method test (including any required by 40CFR60, subparts IIII and JJJJ and 40CFR63, subpart ZZZZ) within the last 12 months. These previous tests are valid only if EPA Inspection Report - Page 967 of 1969 conducted at the same or lower elevation as the existing engine location prior to commencing operation as a temporary replacement. A copy of the test results shall be kept according to section B109.B. (d) Compliance tests for NOx and CO shall be conducted if requested by the Department in writing to determine whether the replacement engine is in compliance with applicable regulations or permit conditions. (e) Upon determining that emissions data developed according to B116.A.1(c) fail to indicate compliance with either the NOx or CO emission limits, the permittee shall notify the Department within 48 hours. Also within that time, the permittee shall implement one of the following corrective actions: i. The engine shall be adjusted to reduce NOx and CO emissions and tested per B116.A.1(c) to demonstrate compliance with permit limits. ii. The engine shall discontinue operation or be replaced with a different unit. (2) Short term replacement engines, whether of the same manufacturer, model, and horsepower, or of a different manufacturer, model, or horsepower, are subject to all federal and state applicable requirements, regardless of whether they are set forth in this permit (including monitoring and recordkeeping), and shall be subject to any shield afforded by this permit. (3) The permittee shall maintain a contemporaneous record documenting the unit number, manufacturer, model number, horsepower, emission factors, emission test results, and serial number of any existing engine that is replaced, and the replacement engine. Additionally, the record shall document the replacement duration in days, and the beginning and end dates of the short term engine replacement. (4) The permittee shall maintain records of a regulatory applicability determination for each replacement engine (including 40CFR60, subparts IIII and JJJJ and 40CFR63, subpart ZZZZ) and shall comply with all associated regulatory requirements. B. Additional requirements for replacement of engines at sources that are major as defined in regulation 20.2.74 NMAC, Permits – Prevention of Significant Deterioration, section 7.AG. For sources that are major under PSD, the total cumulative operating hours of the replacement engine shall be limited using the following procedure: (1) Daily, the actual emissions from the replacement engine(s) of each pollutant regulated by this permit for the existing engine shall be calculated and recorded. (2) The sum of the total actual emissions since the commencement of operation of the replacement engine(s) shall not equal or exceed the significant emission rates in EPA Inspection Report - Page 968 of 1969 Table 2 of 20.2.74 NMAC, section 502 for the time that the replacement engine is located at the facility. C. All records required by this section shall be kept according to section B109. EPA Inspection Report - Page 969 of 1969 PART C MISCELLANEOUS C100 Supporting On-Line Documents A. Copies of the following documents can be downloaded from NMED’s web site under Compliance and Enforcement or requested from the Bureau. (1) Excess Emission Form (for reporting deviations and emergencies) (2) Universal Stack Test Notification, Protocol and Report Form and Instructions (3) SOP for Use of Portable Analyzers in Performance Tests C101 Definitions A. “Daylight” is defined as the time period between sunrise and sunset, as defined by the Astronomical Applications Department of the U.S. Naval Observatory. (Data for one day or a table of sunrise/sunset for an entire year can be obtained at http://aa.usno.navy.mil/. Alternatively, these times can be obtained from a Farmer’s Almanac or from http://www.almanac.com/rise/). B. “Exempt Sources” and “Exempt Activities” is defined as those sources or activities that are exempted in accordance with 20.2.72.202 NMAC. Note; exemptions are only valid for most 20.2.72 NMAC permitting actions. C. “Fugitive Emission” means those emissions which could not reasonably pass through a stack, chimney, vent, or other functionally equivalent opening. D. “Insignificant Activities” means those activities which have been listed by the department and approved by the administrator as insignificant on the basis of size, emissions or production rate. Note; insignificant activities are only valid for 20.2.70 NMAC permitting actions. E. “Malfunction” for the requirements under 20.2.7 NMAC, means any sudden and unavoidable failure of air pollution control equipment or process equipment beyond the control of the owner or operator, including malfunction during startup or shutdown. A failure that is caused entirely or in part by poor maintenance, careless operation, or any other preventable equipment breakdown shall not be considered a malfunction. (20.2.7.7.E NMAC) F. “Natural Gas” is defined as a naturally occurring fluid mixture of hydrocarbons that contains 20.0 grains or less of total sulfur per 100 standard cubic feet (SCF) and is either composed of at least 70% methane by volume or has a gross calorific value of between 950 and 1100 Btu per standard cubic foot. (40 CFR 60.631) EPA Inspection Report - Page 970 of 1969 G. “Natural Gas Liquids” means the hydrocarbons, such as ethane, propane, butane, and pentane, that are extracted from field gas. (40 CFR 60.631) H. “National Ambient air Quality Standards” means, unless otherwise modified, the primary (health-related) and secondary (welfare-based) federal ambient air quality standards promulgated by the US EPA pursuant to Section 109 of the Federal Act. I. “Night” is the time period between sunset and sunrise, as defined by the Astronomical Applications Department of the U.S. Naval Observatory. (Data for one day or a table of sunrise/sunset for an entire year can be obtained at http://aa.usno.navy.mil/. Alternatively, these times can be obtained from a Farmer’s Almanac or from http://www.almanac.com/rise/). J. “Night Operation or Operation at Night” is operating a source of emissions at night. K. “NO2” or "Nitrogen dioxide" means the chemical compound containing one atom of nitrogen and two atoms of oxygen, for the purposes of ambient determinations. The term "nitrogen dioxide," for the purposes of stack emissions monitoring, shall include nitrogen dioxide (the chemical compound containing one atom of nitrogen and two atoms of oxygen), nitric oxide (the chemical compound containing one atom of nitrogen and one atom of oxygen), and other oxides of nitrogen which may test as nitrogen dioxide and is sometimes referred to as NOx or NO2. (20.2.2 NMAC) L. “NOx” see NO2 M. “Paved Road” is a road with a permanent solid surface that can be swept essentially free of dust or other material to reduce air re-entrainment of particulate matter. To the extent these surfaces remain solid and contiguous they qualify as paved roads: concrete, asphalt, chip seal, recycled asphalt and other surfaces approved by the Department in writing. N. “Potential Emission Rate” means the emission rate of a source at its maximum capacity to emit a regulated air contaminant under its physical and operational design, provided any physical or operational limitation on the capacity of the source to emit a regulated air contaminant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored or processed, shall be treated as part of its physical and operational design only if the limitation or the effect it would have on emissions is enforceable by the department pursuant to the Air Quality Control Act or the federal Act. O. “Restricted Area” is an area to which public entry is effectively precluded. Effective barriers include continuous fencing, continuous walls, or other continuous barriers approved by the Department, such as rugged physical terrain with a steep grade that would require special equipment to traverse. If a large property is completely enclosed EPA Inspection Report - Page 971 of 1969 by fencing, a restricted area within the property may be identified with signage only. Public roads cannot be part of a Restricted Area. P. "Shutdown" for requirements under 20.2.72 NMAC, means the cessation of operation of any air pollution control equipment, process equipment or process for any purpose, except routine phasing out of batch process units. Q. "SSM" for requirements under 20.2.7 NMAC, means routine or predictable startup, shutdown, or scheduled maintenance. R. (1) "Shutdown" for requirements under 20.2.7 NMAC, means the cessation of operation of any air pollution control equipment or process equipment. (2) "Startup" for requirements under 20.2.7 NMAC, means the setting into operation of any air pollution control equipment or process equipment. "Startup" for requirements under 20.2.72 NMAC, means the setting into operation of any air pollution control equipment, process equipment or process for any purpose, except routine phasing in of batch process units. C102 Acronyms 2SLB ........................................................................................................ 2-stroke lean burn 4SLB ........................................................................................................ 4-stroke lean burn 4SRB ......................................................................................................... 4-stroke rich burn acfm........................................................................................... actual cubic feet per minute AFR .................................................................................................................... air fuel ratio AP-42 ...........................................................................EPA Air Pollutant Emission Factors AQB ........................................................................................................ Air Quality Bureau AQCR ....................................................................................... Air Quality Control Region ASTM ............................................................. American Society for Testing and Materials Btu ......................................................................................................... British thermal unit CAA ............................................................. Clean Air Act of 1970 and 1990 Amendments CEM ................................................................................. continuous emissions monitoring cfh ........................................................................................................... cubic feet per hour cfm ....................................................................................................... cubic feet per minute CFR ........................................................................................... Code of Federal Regulation CI ........................................................................................................ compression ignition CO ............................................................................................................ carbon monoxides COMS ...................................................................... continuous opacity monitoring system EIB ............................................................................... Environmental Improvement Board EPA .......................................................... United States Environmental Protection Agency gr/100 cf ........................................................................... grains per one hundred cubic feet gr/dscf .............................................................................. grains per dry standard cubic foot GRI .....................................................................................................Gas Research Institute EPA Inspection Report - Page 972 of 1969 HAP................................................................................................... hazardous air pollutant hp ....................................................................................................................... horsepower H2S ..............................................................................................................hydrogen sulfide IC .......................................................................................................... internal combustion KW/hr ...................................................................................................... kilowatts per hour lb/hr ..............................................................................................................pounds per hour lb/MMBtu ............................................................... pounds per million British thermal unit MACT ............................................................. Maximum Achievable Control Technology MMcf/hr ...................................................................................... million cubic feet per hour MMscf ......................................................................................... million standard cubic feet N/A.................................................................................................................. not applicable NAAQS ................................................................. National Ambient Air Quality Standards NESHAP ................................. National Emission Standards for Hazardous Air Pollutants NG ....................................................................................................................... natural gas NGL ......................................................................................................... natural gas liquids NMAAQS ......................................................New Mexico Ambient Air Quality Standards NMAC............................................................................ New Mexico Administrative Code NMED ..................................................................... New Mexico Environment Department NMSA .................................................................................New Mexico Statues Annotated NOx ............................................................................................................... nitrogen oxides NSCR .................................................................................non-selective catalytic reduction NSPS ............................................................................. New Source Performance Standard NSR .......................................................................................................New Source Review PEM .................................................................................. parametric emissions monitoring PM ................................ particulate matter (equivalent to TSP, total suspended particulate) PM10 ....................................................... particulate matter 10 microns and less in diameter PM2.5 ..................................................... particulate matter 2.5 microns and less in diameter pph................................................................................................................pounds per hour ppmv ......................................................................................... parts per million by volume PSD ......................................................................... Prevention of Significant Deterioration RATA ........................................................................... Relative Accuracy Test Assessment RICE .................................................................... reciprocating internal combustion engine rpm .................................................................................................... revolutions per minute scfm ....................................................................................... standard cubic feet per minute SI ................................................................................................................... spark ignition SO2 .................................................................................................................. sulfur dioxide SSM................................................... Startup Shutdown Maintenance (see SSM definition) TAP ........................................................................................................ Toxic Air Pollutant TBD............................................................................................................. to be determined THC.......................................................................................................... total hydrocarbons TSP.......................................................................................... Total Suspended Particulates tpy ..................................................................................................................... tons per year ULSD ..................................................................................................ultra low sulfur diesel USEPA ..................................................... United States Environmental Protection Agency EPA Inspection Report - Page 973 of 1969 UTM ...................................................... Universal Transverse Mercator Coordinate system UTMH ................................................................ Universal Transverse Mercator Horizontal UTMV .................................................................... Universal Transverse Mercator Vertical VHAP................................................................................... volatile hazardous air pollutant VOC .......................................................................................... volatile organic compounds EPA Inspection Report - Page 974 of 1969 ÿ 23345627589ÿ 8 ÿ3 57ÿ 9 24ÿ ÿ ÿ 7574 ÿ ÿ83 2759 ÿ3 57ÿ98 ÿ3 ÿ 3 57ÿ9 ÿ2 7 ÿ 9 24 ÿ ÿ ÿ !"ÿ$%ÿ ÿ &'(ÿ*'+,-.ÿ/01,2.03'04ÿ5'67243'04ÿ 8 9ÿ: ;< =ÿ> 9!; ÿ ?@?ÿA; B$ÿ"!ÿ<$CÿD;9E !FGÿ !ÿHÿ ;B;ÿI!GÿJDÿÿKL?M?ÿ ÿ ÿ ÿ N9!O;9!"ÿP$9%ÿ ÿ ÿ ÿ ÿ Q24'R,7ÿS'T,0'2Uÿ V.WWUX2.04,'2ÿ&717Y.ÿS'T,0,0Zÿ[[\ÿ ?MHÿ];CÿD; Bÿ 9!!ÿ 89!C ;Gÿ]""=ÿA$ B=GÿJ!^ÿD!_ `$ÿ 8a!B`=ÿbB!9!CÿJ$cÿHdKÿ ÿ ÿ ÿ N9!O;9!"ÿ =%ÿ ÿ e7R-.R7ÿQWW,70-'ÿ\.3670Uÿ fdH?ÿA9$CCÿA9!!gÿA$ 9ÿ 89< Ba$BGÿh!_;CÿÿLiMHLÿ KHLcL@icidfdÿ ÿ ÿ h;C`$C;ÿN9$j!`ÿJ$%ÿÿHMKkHHÿ *7Uÿlmnoÿ ÿ ÿ ÿ EPA Inspection Report - Page 975 of 1969 ÿ ;<=ÿ>?ÿ@ABCÿ ÿÿ ;EFÿGHIÿJKLMMNH=ÿ OHEPQRRQSTÿJHKRQMSÿULQHV?ÿWQEÿXY@>Cÿdj>Cÿ J?ÿ@ABdFÿÿŸRÿL?ÿ@A@AFÿÿŸSÿ?ÿ@ABC™Fÿÿÿ ÿ Z=ÿRLQeÿeYšPQRR™ÿ;?@ÿAÿBC=DÿGGH87ÿ I6J6KÿJLGMNN88ÿAÿO==PQRRSSSTOUVVWXCU@=?DCTYUZÿ EPA Inspection Report - Page 977 of 1969 012ÿ456ÿ789 5 ÿ 5 ÿ05 8 ÿ 1 5 ÿ 5 1 5 ÿ \ÿ4 ^ 5ÿ _2̀aÿb5c 56ÿ7 c185dÿe d ÿÿ \ÿ4 ^ 5ÿ 2̀ÿ̀ ^ 5ÿ dd ÿe dÿ 0 ÿ ÿ ÿ 5ÿ!ÿ "ÿ ÿ ÿ _2ÿghijkljmnopjlqrÿituvwwxtytz{ÿg v}tzwÿkh~ÿh€yz‚ywÿ~tƒ„vyÿÿjÿÿ… ÿ 9 dÿdc^ ÿ † ÿ15‡c5d 56ÿ 6ÿ 0 ÿ 1 56ÿ c 9 1 ˆ ÿ" 1ÿ5 dd dÿ"1 ÿ 1 85ddÿ5‡c 5 ÿ 6 " 8 dÿ ÿ 815 d5ÿ 1 6c8 ÿ ÿ 95ÿ" ÿc daÿÿÿ \ÿ‰ ÿŠ‰‹Œ Œ  ‰ÿŽÿ 9 9 ÿ 61 65dc "c1 ˆ ÿ‰ ÿÿÿ \ÿ‰ ÿŠ‰‹Œ !Œ  ‰ÿŽÿ 9 9 ÿ 61 65dc "c1 ˆ ÿ‰ ÿÿÿ \ÿ‰ ÿŠ‰‹Œ Œ70ÿŽÿ…5 Š155ÿ‰ ÿ‘ 15 cd ÿ 65 " 56ÿ dÿd ÿ‰ ’ÿÿÿ \ÿ‰ ÿŠ‰‹Œ!!Œ 74ÿ ‰ÿŽÿ 5d5 ÿ 61 65dc "c1 ˆ ÿ‰ ÿÿÿ \ÿ`66 ÿ1 c ÿ "ÿ ÿd 15 ÿ"1 ÿ‰ ÿ__ÿ‘‹ dÿ ÿ 61 15 51’ÿ ÿ‰ ÿ!!2ÿÿÿ  ÿ 66 ÿ 95ÿ" ÿ89 5dÿ ÿ 95ÿ 7bÿ 51 ÿ 515ÿ 5 5 562ÿÿÿ \ÿb5 56ÿ 95ÿ" ÿd 1 5ÿ “daÿÿ4Œ ! ÿ4Œ ”• ÿ4Œ _ _ ÿ4Œ _ ” ÿ4Œ _ ÿ4Œ • ÿ 6ÿ4Œ –•ÿÿÿ \ÿ—9 56ÿ “ÿ ÿ 2ÿ4˜Œ ™ 4` eÿ ÿ4Œ _” ÿ 6ÿ89 56ÿ dd 8 56ÿ “ÿ 5ÿ "1 ÿ5 51 ÿ" ÿ1 "ÿ “ÿ ÿ 51 ÿ" ÿ1 "ÿ “ÿÿÿ \ÿ—9 56ÿ “ÿ ÿ 2ÿ4˜Œÿ…  7 eÿ ÿ4Œ _” ÿ 6ÿ89 56ÿ dd 8 56ÿ “ÿ 5ÿ "1 ÿ" 56ÿ1 "ÿ “ÿ ÿ 51 ÿ" ÿ1 "ÿ “ÿÿÿ \ÿb5 56ÿ770ÿ4Œ –• ÿ770ÿ4Œ – ÿ770ÿ4Œ –!–ÿ 6ÿ770ÿ4Œ ”2ÿÿ770ÿ “ÿ 5 dd dÿ 515ÿ 8 c656ÿc 651ÿ ÿš770ÿ4 “d›ÿ 9 89ÿ dÿc 6 56ÿ dÿ 1 ÿ "ÿ 95ÿ 1 †58 ÿÿÿ \ÿ0 56ÿ770ÿ0 d8ÿ ÿ" 1ÿ8 d ÿ9 6 ÿ5 dd dÿ"1 ÿ 95ÿb5c 56ÿ dd ÿ 7 c185dÿ‘ 51ÿ 8 ÿ4 ^ 5ÿ `’ÿ ÿ 95ÿ 5 56ÿ ‡c 5 œ d " 8 ÿ̀8 5dÿ ‘ 51ÿ 8 ÿ4 ^ 5ÿ …’ÿÿÿ ™ 9ÿ15d 58 ÿ ÿ 95ÿ4 5ÿÿ 51 ÿ 9 dÿ 51 ÿ 8 ÿ ÿ^5ÿ15" 58 56ÿ dÿ89 5dÿ ÿ 95ÿ " ÿ dÿ 8 c656ÿ ÿ 95ÿ5 58 1 8ÿ 51 ÿ 1“c ÿdc^ 56ÿ 9ÿ 9 dÿ 8 ÿ 6ÿ 15"515 856ÿ ÿ̀ 89 5 ÿ aÿÿÿÿ \ÿ 51 ÿ8 6 ÿ̀ 2—ÿÿÿ \ÿ4 ^ 5ÿ 2̀aÿ4 ÿ 5 ÿ c ÿ dd dÿ"1 ÿ 15ÿŠ 8 ÿÿÿ \ÿ 51 ÿ8 6 dÿ̀ –2 ÿ 91 c9ÿŠÿÿÿ \ÿ 51 ÿ8 6 ÿ̀ !2 ÿÿÿ \ÿ 51 ÿ8 6 ÿ̀ _2 ÿ \ÿ 51 ÿ8 6 ÿ̀ 2…ÿ \ÿ 51 ÿ8 6 ÿ̀ 2̀ÿ 91 c9ÿ ÿÿÿ \ÿ4 ^ 5ÿ !2… ÿ7c 1 ÿ̀ 8 ^ ÿŽÿŠc 5dÿÿ \ÿ4 ^ 5ÿ !2— ÿ7c 1 ÿ̀ 8 ^ ÿŽÿ4 “dÿ \ÿ4 ^ 5ÿ 2̀ÿ̀ ^ 5ÿ dd ÿe dÿ \ÿ4 ^ 5ÿ 2…‘ ’ÿ 51 ÿŠ ÿb "ÿ7 1 5ÿ4 “d ÿ 1ÿ 15ddc15ÿe dÿ" 1ÿ b5" 51 ÿ Œ— ^cd ÿ7 c185dÿ "ÿ 5ÿ1 8ÿ— c 6dÿ‘—’ÿÿÿ \ÿ4 ^ 5ÿ 2…‘ ’ÿ 51 ÿŠ ÿb "ÿ7 1 5ÿ4 “d ÿ 1ÿ 15ddc15ÿe dÿ" 1ÿ b5" 51 ÿ Œ— ^cd ÿ7 c185dÿ "ÿ 5ÿ1 8ÿ— c 6dÿ‘—’ÿÿÿ \ÿ4 ^ 5ÿ 2—ÿŠ 56ÿb "ÿ7 1 5ÿ4 “d ÿ 1ÿ 15ddc15ÿe dÿ" 1ÿb5" 51 ÿ Œ — ^cd ÿ7 c185dÿ "ÿ 5ÿ1 8ÿ— c 6dÿ‘—’ÿÿÿ #$%%&'($)*+,(ÿ./0/1$ÿ2,3+)+)4ÿ556ÿ 789ÿ;<=>ÿ?<@AÿBÿCD>E=@>QRSSTTTUPVWWXYDVA>@EDUZV[ÿ EPA Inspection Report - Page 978 of 1969 012ÿ456ÿ789 5 ÿ 5 ÿ05 8 ÿ 1 5 ÿ 5 1 5 ÿ 0 ÿ ÿ ÿ 5ÿ!ÿ "ÿ ÿ \ÿ4 ^ 5ÿ 2 ÿ7 1 5ÿ4 _ÿ491 `9 ` ÿ 6ÿ45 51 `15ÿa bÿÿÿ \ÿ4 ^ 5ÿ 2 ÿ7 1 5ÿ4 _ÿcdeÿ 6ÿf 7ÿ bb ÿa bÿÿÿ \ÿ4 ^ 5ÿ 2gÿg` 5ÿ bb bÿ"1 ÿ h` 5 ÿa5 _b ÿ bb ÿa bÿ" 1ÿi5" 51 ÿ je ^`b ÿ7 `185bÿ "ÿc 5ÿd1 8ÿe ` 6bÿkcdelÿÿÿ \ÿ4 ^ 5ÿ m2nÿ0 5 85 ÿ7 1 ` ÿ 6ÿ79` 6 ÿ bb ÿa bÿ ÿ p2ÿqrstuvtwxyztv{ ÿq~€ÿ‚ÿq~ƒ„…†ÿur‡ÿrˆ‰Š…‹‰†ÿ‡Œƒ‰ÿÿtÿÿŽ ÿ 9 bÿb`^ ÿ  ÿ 15h`5b 56ÿ 6ÿ 0 ÿ 1 56ÿ ` 9 1  ÿ" 1ÿ5 bb bÿ"1 ÿ ÿ 5 ÿ 1 5ÿ‘ÿ 51 ÿ̀ 2ÿÿ 495ÿ 1 58 ÿ 8 `656’ÿÿ \ÿ“ b ÿ "ÿ ÿ15 8 1ÿ89 15ÿ95 51ÿfjp! ÿÿÿ \ÿ“ b ÿ "ÿ ÿ5 51 ÿ" ÿ1 "ÿ _ÿ" 1ÿ ""jb 58ÿ 51 ÿ4jp! ÿ \ÿn66 ÿ ÿ8 5 ÿ"` 5ÿ5 bb bÿ \ÿ” 6 ÿ 95ÿ5 bb ÿ8 8` bÿ" 1ÿ 95ÿ b 5 51ÿ̀ ÿ • 9ÿ15b 58 ÿ ÿ 95ÿ4 5ÿcÿ 51 ÿ 9 bÿ 51 ÿ 8 ÿ ÿ^5ÿ15" 58 56ÿ bÿ89 5bÿ ÿ 95ÿ " ÿ bÿ 8 `656ÿ ÿ 95ÿ5 58 1 8ÿ 51 ÿ 1_` ÿb`^ 56ÿ 9ÿ 9 bÿ 8 ÿ 6ÿ 15"515 856ÿ ÿn 89 5 ÿ ’ÿÿÿ \ÿ 51 ÿ8 6 ÿn 2eÿÿÿ \ÿ4 ^ 5ÿ 2n’ÿ4 ÿ 5 ÿ ` ÿ bb bÿ"1 ÿ 15ÿg 8 ÿÿÿ \ÿ 51 ÿ8 6 ÿn !2Žÿ \ÿ4 ^ 5ÿ –2Ž ÿ7` 1 ÿn 8 ^ ÿ—ÿg` 5bÿ \ÿ4 ^ 5ÿ –2e ÿ7` 1 ÿn 8 ^ ÿ—ÿ4 _bÿ \ÿ4 ^ 5ÿ –2 ÿ7` 1 ÿn 8 ^ ÿ—ÿf5 51bÿ 6ÿŽ 51bÿ \ÿ4 ^ 5ÿ !2n’ÿi5` 56ÿ7 `185bÿa b ÿ \ÿ4 ^ 5ÿ 2nÿn ^ 5ÿ bb ÿa bÿ \ÿ4 ^ 5ÿ 2Žk lÿ 51 ÿg ÿi "ÿ7 1 5ÿ4 _b ÿc 1ÿ 15bb`15ÿa bÿ" 1ÿ i5" 51 ÿ je ^`b ÿ7 `185bÿ "ÿc 5ÿd1 8ÿe ` 6bÿkcdelÿÿÿ \ÿ4 ^ 5ÿ 2 ÿ7 1 5ÿ4 _ÿ491 `9 ` ÿ 6ÿ45 51 `15ÿa bÿÿÿ \ÿ4 ^ 5ÿ 2 ÿ7 1 5ÿ4 _ÿcdeÿ 6ÿf 7ÿ bb ÿa bÿÿÿ \ÿ4 ^ 5ÿ 2gÿg` 5ÿ bb bÿ"1 ÿ h` 5 ÿa5 _b ÿ bb ÿa bÿ" 1ÿi5" 51 ÿ je ^`b ÿ7 `185bÿ "ÿc 5ÿd1 8ÿe ` 6bÿkcdelÿÿÿ \ÿ4 ^ 5ÿ 2“ÿn “ÿd ˜• 51ÿ75 1 1b ÿ bb ÿa bÿ" 1ÿi5" 51 ÿ je ^`b ÿ 7 `185bÿ "ÿc 5ÿd1 8ÿe ` 6bÿkcdelÿÿ ÿ 2ÿqrstuvtwxyztv{z‡™ÿš‹†›‹†~ÿr†ƒ~‹ˆÿœ‹‰ÿœtžxwžÿur‡ÿŸ €‰†~‹†Œÿ‡Œƒ‰ÿÿtÿÿ Ž ÿ 9 bÿb`^ ÿ  ÿ15h`5b 56ÿ 6ÿ 0 ÿ 1 56ÿ ` 9 1  ÿ" 1ÿ5 bb bÿ"1 ÿ ÿ 5 ÿ b 5 51ÿ _ ÿ4jm m ÿ 9 89ÿ bÿ5 5 ÿ"1 ÿ8 b 1`8 ÿ 51 ÿ15h` 15 5 bÿ 51ÿ 2 2m 2 2Ž2k lÿ 0ne2ÿÿnbÿ15" 58 56ÿ ÿ 95ÿ 8 ÿ4 ^ 5ÿ jŽ ÿ 95ÿ _ÿ6 5bÿ ÿ9 5ÿ 8 ^ 5ÿ15h` 15 5 bÿ 6ÿ 55 bÿ 95ÿ81 51 ÿ "ÿ 0 ÿ4 5ÿcÿ“ b " 8 ÿn8 ÿ 2^ÿk 252 ÿ 9 bÿ 5 ÿ ÿ5 ÿ ÿ 15ÿ 9 ÿ 95ÿ 5bb 1ÿ "ÿ 5ÿ 1ÿ 95ÿ65ÿ bÿ 5 5 ÿ "ÿf  16 `bÿn 1ÿ ` ÿ¡fn ¢l2ÿÿ49515" 15ÿ 9ÿ15b 58 ÿ ÿ 95ÿ4 5ÿcÿ 51 ÿ ÿ89 5bÿ 15ÿ15h` 1562ÿÿÿ ÿ m2ÿœ†£ÿ¤ÿ¥¦~‹†‰ˆÿq~€†ÿuƒ§ÿqwzxt‡™vxÿ¥›‰~q̈~€††ÿu‹€ÿ©ª‹‰ˆÿŸ €‰†~‹†Œÿ ‡Œƒ‰ÿÿtÿÿŽ ÿ 9 bÿb`^ ÿ  ÿ15h`5b 56ÿ 6ÿ 0 ÿ 1 56ÿ 95ÿ 5ÿ89 5ÿ ÿ 95ÿ 51 ÿ"1 ÿ  ÿi5" ÿe ÿa2a2e2ÿ ÿf g1 51ÿ  ÿi5" ÿaae2ÿÿÿ #$%%&'($)*+,(ÿ./0/1$ÿ2,3+)+)4ÿ556ÿ 789ÿ;<=>ÿ?<@AÿBÿCD>E=@>QRSSTTTUPVWWXYDVA>@EDUZV[ÿ EPA Inspection Report - Page 979 of 1969 012ÿ456ÿ789 5 ÿ 5 ÿ05 8 ÿ 1 5 ÿ 5 1 5 ÿ 0 ÿ ÿ ÿ 5ÿ!ÿ "ÿ ÿ \ ÿ 66 ÿ ] ÿ15^_5` `ÿ 0 ÿ8 1158 ÿ ÿ 1 9 8 ÿ511 1ÿ ÿ 95ÿ4 5ÿaÿ 51 ÿ `ÿ" `bÿ ÿ d2ÿfggÿijkjljmnopmÿqrsÿtpumvwÿxyz{{zplÿ zyzoÿ}ÿÿ~5 `5ÿ 95ÿ€€ÿ~55 51 1ÿ ‚ÿ9 _1 ÿ 5 `` ÿ ÿ ÿ4 ƒ 5ÿ 2„ÿ ÿ…†2 ÿ ƒ‡91ÿ ` 5 6ÿ "ÿ 95ÿ8_115 } ` 56ÿ…!2 ÿ ƒ‡91 ÿ8 ` ` 5 ÿ 9ÿ 95ÿ ^_ 5 ÿ7 58 " 8ÿ~5^_ 15 5 ÿ„ 2„2ˆ ‰ˆ ‰2ÿÿÿ ÿ _1 951 ÿ ] ÿ15^_5` `ÿ 0 ÿ_ 6 5ÿ 95ÿ4 5ÿaÿ 51 ÿ ÿ15" 58 ÿ 95ÿ" ÿ15_ 1 ÿ_ 6 5`ÿ 6ÿ 89 5`ÿ̀ 85ÿ 95ÿ ` ÿ4 5ÿaÿ 51 ÿ ``_ 85‡15 5 ÿˆ ` ÿ `ÿ15 5 56ÿ ÿ758 ÿ…ÿ "ÿ 95ÿ 8 ÿ " 1 ‰2ÿÿ495`5ÿ_ 6 5`ÿ 6ÿ89 5`ÿ 15ÿ 8 _656ÿ ÿ 95ÿ5 58 1 8ÿ 51 ÿ 1Š_ ÿ̀_ƒ 56ÿ 9ÿ 9 `ÿ 8 2ÿÿÿ ÿ 2ÿ‹iŒÿq‹Ž‹ÿnÿ‘‘vz’n“zvzowÿ}ÿ€9 5ÿ 95ÿ 8 ƒ ÿ" 1ÿ7~” ÿ"1 ÿ 7 7ÿ•ÿ ÿ 7 7ÿ• ÿ ˆ ^_ 5 ÿ7 58 " 8ÿ~5^_ 15 5 `ÿ„ –2 ÿ8 ` ` 5 ÿ 9ÿ ÿ "ÿ 9 `ÿ8 6 ÿ" 1ÿ7~”…ÿˆ 95ÿ ÿ_ `ÿ158 51ÿ̀_ "_1ÿ"1 ÿ ÿ8 ÿ̀ _185ÿ "ÿ̀ _1ÿ `‰—ÿ Š5ÿ8 115` 6 ÿ89 5`ÿ ÿ 4 ƒ 5ÿ …2\ÿ ÿ 95ÿ 51 ‰2ÿÿÿ ÿ 2ÿij‘jnvÿp˜ÿ™šš›œÿqgÿŽjompvjuyÿij˜zljmwÿ‹uv˜umÿžÿÿ~5 5ÿ 1ÿ_ 6 5ÿ 95ÿ15"515 85`ÿ ÿ 2 2… ÿ 0„€ÿ 9 89ÿ 0 ÿ15 5 56ÿ5""58 5ÿ5ƒ1_ 1 ÿ ! ÿ 2ÿÿÿ ÿ 2ÿij‘jnvÿp˜ÿ™šš›ŸÿŽjompvjuyÿŽmp’j{{zlkÿfn’zvzozj{ÿžÿÿ~5 5ÿ 1ÿ_ 6 5ÿ 95ÿ15"515 85`ÿ ÿ 2 2…–ÿ 0„€ÿ 9 89ÿ 0 ÿ15 5 56ÿ5""58 5ÿ75 5 ƒ51ÿ ÿ 2ÿÿÿ ÿ 2ÿ™ššœ ÿqgÿ‘‘vz’n“zvzowÿ}ÿÿ _5ÿ ÿ 95ÿ15 5 ÿ "ÿ 2 2…–2 ÿ 0„€ÿ 1 8_ 5ÿ0 51ÿ 15^_ 15 5 ` ÿ 2 2 ÿ 0„€ÿ7 Š5ÿ 6ÿa ` ƒ 5ÿ `` `ÿ15^_ 15 5 `ÿˆ` 58 " 8 ÿ 2 2 2 ÿ 8 ÿ15^_ 15 5 `‰ÿ ÿ ÿ ÿ̀ 1 ÿ8 ƒ_` ÿ5^_ 5 ÿ 6ÿ 5ÿ 15^_5` ÿ 9 ÿ 0 ÿ_ 6 5ÿ 95ÿ4 5ÿaÿ 51 ÿ ÿ15" 58 ÿ 9 `2ÿÿÿ ÿ …2ÿij˜zljmwÿ‹j’opmÿiuvjÿ‘‘vz’n“zvzowÿ}ÿÿÿ495ÿ65 56ÿ 8 ƒ ÿ̀_ƒ}8 `ÿ ÿ 95ÿ ` 15 6`955 `ÿ 8 _656ÿ ÿ 95ÿ5 58 1 8ÿ̀_ƒ ÿ 88 ÿ 9 `ÿ 8 ÿ 6615``ÿ 8 ƒ ÿ65 51 `ÿ ÿ6 5ÿ `ÿ15 56ÿ ÿ 95ÿ~5" 51 ÿ758 1ÿ~_ 5ÿˆ~7~‰2ÿÿ495ÿ ` 15 6`955 `ÿ15" 58 ÿ 7 7ÿ• ÿ 7 7ÿ• ÿ0„€4ÿ€€ ÿ 6ÿ0„€4ÿ”””ÿ 8 ƒ ÿ65 51 `ÿ 9 ÿ9 5ÿƒ55 ÿ15^_ 156ÿ ÿƒ5ÿ8 5 56ÿ 9_`ÿ" 1ÿ_ 651ÿ 95ÿ~7~2ÿÿÿ ÿ ÿ „ 6ÿ" ÿ 95ÿ" ÿ15 15`5 `ÿ 15ÿ 8 _656ÿ ÿ 9 `ÿ 8 ÿƒ_ ÿ6 ÿ ÿ15`_ ÿ ÿ89 5`ÿ ÿ 95ÿ4 5ÿaÿ 51 ÿˆ `ÿ15 5 56ÿ ÿ758 ÿ ÿ "ÿ 95ÿ 8 ÿ" 1 ‰bÿÿÿ 2ÿ” 6 56ÿ 6ÿ8 1158 56ÿ4 ƒ 5ÿ }¡ÿ7 8Šÿ ÿ€ 6 `ÿ 2ÿ” 6 56ÿ4 ƒ 5ÿ }•bÿ_5 ÿ ÿ 1 65ÿ 5 ÿ " 1 ÿ ÿ 5 ÿ¢_5 ÿ7 _185£ÿ8 _ ÿ 6ÿ ÿ 66ÿ 15^_ 156ÿ " 1 ÿ" 1ÿ 95ÿ 5 ÿ751 51ÿ¤ 8Š_ ÿ¥5 51 1ÿ …2ÿ” 6 56ÿ4 ƒ 5ÿ } bÿ€ 0ÿ ^_ 5 ÿ †2ÿ” 6 56ÿ758 ÿ –ÿ€ 85ÿ¡ ` 1 ÿ ÿ ÿ \ ÿ 88 16 85ÿ 9ÿ 2 2– 2… ÿ 0„€ ÿ5 8 `56ÿ 15ÿ 95ÿ 1 1 5ÿ 0 ÿ 8 ÿ" 1 `ÿ 9ÿ `_ 1 ÿ6 8_ 5 2ÿÿ\ ÿ `ÿ _1ÿ_ 651` 6 ÿ ÿ 51 ÿ 8 ÿ" ÿ"55ÿ `ÿ ÿ15^_ 156—ÿ1 951ÿ 1 85`` ÿ "ÿ 95ÿ4 5ÿaÿ15 5 ÿ 8 ÿ `ÿ"_ 656ÿƒ ÿ 95ÿ _ ÿ4 5ÿaÿ 51 ÿ"55`2ÿÿ 8 `56ÿ 15bÿÿÿ 2ÿ„ ÿ 1 ÿ̀ 56ÿ 6ÿ 1 ¦56ÿ 8 ÿ 1 56ÿ6 _ƒ 5}` 656ÿˆ95 6} } 5‰ÿ5 85 ÿ" 1ÿ 95ÿ 758 ÿ ÿ ƒ 5`ÿ 9 ÿ 15ÿ 1 56ÿ95 6} }95 62ÿÿ495ÿ 8 ÿ `ÿ }9 5ÿ _ 8956ÿ 6ÿ 8 _65`ÿ _ ƒ5156ÿ ƒÿ̀5 1 1`2ÿÿÿ #$%%&'($)*+,(ÿ./0/1$ÿ2,3+)+)4ÿ556ÿ 789ÿ;<=>ÿ?<@AÿBÿCD>E=@>QRSSTTTUPVWWXYDVA>@EDUZV[ÿ EPA Inspection Report - Page 980 of 1969 MI. Ted Schooley Mayr 6, 2019 New Mexico Environment Page 6 of 6 2. A copy of the application printed double-aided but not hole-punched. 3. Two with all the application electronic ?les, including a PDF ?le of the entire application. We would like to thank you in advance for your review of this permit renewal application. lf'you have any questions regarding the information presented in this application, please do not hesitate to contact Gabriela Mellow-Combs at (575) or h-ianait-Mtacc i-{ullt-Frunucr corn. or Brian Gunzelman of Tascosa Alliance Company, our consultant on this project, at (317) ?26?6949 or buuiwelmanm meadow Sincerely. ?mum Scott M. Danton Environmental Manager cc: Melinda Owens Title Permit Program Manager, Major Source Permits Section. Air Quality Em New Mexico Environment Department. 525 Banana do 105 Marquez. Suite 1. Sanla Fe. NM 87505. {505] it's?4346. via email to I P. Miller, G. Combs. T. Wheeler, S. Golehalc Tasecca: Brian L. Gunniman. RE. HollyanlieI Navaio Re?ning LLC 501535th . Arl??ia. 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•&ÿ ÿ / (/—ÿ ˜$ÿ & ÿ*&!ÿ & !ÿ EPA Inspection Report - Page 990 of 1969 Delayed Repairs Report HollyFrontier Artesia From: 9/1/2019 To: 10/3/2019, All Records Tag: Unit: 29082000 Unit: 1366-000 Unit: Date Delayed: Expected Date of Repair: 08-TK-FARM 2/13/2018 Area: 12/31/2019 09-N ALKY 8/28/2018 Area: 8/23/2018 12/1/2019 8/23/2023 1842-000 2/21/2019 12/31/2019 2/21/2024 Unit: 166000000 Unit: 10-FCCU 1/29/2019 Area: 1/29/2024 12/31/2019 13-NHD 10 D-502 Area: NSPS 2820-000 11/22/2017 12/31/2019 11/22/2022 2898-000 11/22/2017 12/31/2019 11/22/2022 Unit: 77709000 Unit: 2720-000 13-NHD 9/19/2017 Area: 5/13/2009 9/19/2022 12/31/2019 30-SRU #2 Area: 12/31/2019 Page 1 of 3 on 10/3/2019 8:31 :03 AM PR SW H-9 NSPS 5/13/2014 Repaired?: MACT JASON VILLA/ RAYSMALTS REPAIR IS TECHNICALLY INFEASIBLE WITHOUT A PROCESS 09-D-642/643 Equipment: No JASON REYES/ RAYSMALTS EQUIPMENT IS ISOLATED FROM THE PROCESS AND DOES NO Equipment: NSPS No NSPS 1696-000 Reason: Equipment: 09-D-642 8/28/2023 12/1/2019 Authorized By: MACT 2/13/2023 Area: 09-N ALKY Due Date: JASON REYES/ EQUIPMENT IS ISOLATED FROM RAYSMALTS THE PROCESS AND DOES NO JASON REYES & REPAIR IS TECHNICALLY RAYSMALTS INFEASIBLE WITHOUT A PROCESS Equipment: 10 D-502 No RAY SMALTS / REPAIR IS TECHNICALLY JESUS ACOSTA INFEASIBLE WITHOUT A PROCESS Equipment: NSPS No ROBERT REPAIR IS TECHNICALLY GURROLA/ RAY INFEASIBLE WITHOUT A PROCESS SMALTS ROBERT REPAIR IS TECHNICALLY GURROLA/ RAY INFEASIBLE WITHOUT A PROCESS SMALTS Equipment: PR SW H-9 No STACI HAMMOND/TIM DUNCAN No REPAIR IS TECHNICALLY INFEASIBLE WITHOUT A PROCESS Equipment: DANNY PANZER/AARONS TRANGE No No NSPS REPAIR IS TECHNICALLY INFEASIBLE WITHOUT A PROCESS No Printed By: ALeger HFNA-000005928 EPA Inspection Report - Page 991 of 1969 Delayed Repairs Report HollyFrontier Artesia From: 9/1/2019 To: 10/3/2019, All Records Tag: Unit: 20159000 Unit: 3839-000 Unit: 3751-000 Unit: Date Delayed: Expected Date of Repair: 31-SRU #3-CVS 10/23/2018 12/31/2019 35-SAT-GAS 1/8/2014 12/31/2019 12/31/2019 N/S PR 3/26/2020 Area: 35-SAT-GAS E/WPR 1/8/2020 Area: 11/24/2018 12/31/2019 11/24/2023 3354-000 11/24/2018 12/31/2019 11/24/2023 Area: 35-SAT-GAS W-58 3695-000 3/26/2015 12/31/2019 3/26/2020 3707-000 3/26/2015 12/31/2019 3/26/2020 Unit: 3655-000 Unit: 3577-000 Area: 35-SAT-GAS 6/18/2015 12/31/2019 3/26/2015 6/18/2020 Area: 35-SAT-GAS 12/31/2019 Page 2 of 3 on 10/3/2019 8:31 :03 AM W-60 X-217 3/26/2020 Reason: Equipment: Repaired?: H-3101 ROBERT REPAIR IS TECHNICALLY GURROLA/ RAY INFEASIBLE WITHOUT A PROCESS SMALTS Equipment: E/W PR No DANNY PANZER/ REPAIR IS TECHNICALLY RAY SMALTS INFEASIBLE WITHOUT A PROCESS Equipment: N/S PR No REPAIR IS TECHNICALLY INFEASIBLE WITHOUT A PROCESS No RAY SMALTS/DAVID HAMMOND PMP-AllY 3349-000 Unit: Authorized By: H-3101 10/23/2023 Area: 35-SAT-GAS 3/26/2015 Area: Due Date: Equipment: PMP-AllY TODD BARELA/ REPAIR IS TECHNICALLY RAYSMALTS INFEASIBLE WITHOUT A PROCESS TODD BARELA/ REPAIR IS TECHNICALLY RAYSMALTS INFEASIBLE WITHOUT A PROCESS W-58 Equipment: No RAY REPAIR IS TECHNICALLY SMALTS/DAVID INFEASIBLE WITHOUT A PROCESS HAMMOND RAY REPAIR IS TECHNICALLY SMALTS /DAVID INFEASIBLE WITHOUT A PROCESS HAMMOND W-60 Equipment: No DAIVD REPAIR IS TECHNICALLY HAMMOND/RAY INFEASIBLE WITHOUT A PROCESS SMALTS X-217 Equipment: No RAY SMALTS/DAVID HAMMOND No REPAIR IS TECHNICALLY INFEASIBLE WITHOUT A PROCESS No No Printed By: ALeger HFNA-000005929 EPA Inspection Report - Page 992 of 1969 Delayed Repairs Report HollyFrontier Artesia From: 9/1/2019 To: 10/3/2019, All Records Tag: Unit: 4117 A000 4125-000 Unit: Date Delayed: Expected Date of Repair: 41-PBC Area: Due Date: 41 W-113 5/14/2019 12/31/2019 5/14/2024 5/14/2019 12/31/2019 5/14/2024 44-DHDU Area: 44 C-421 1478-000 5/1/2019 12/31/2019 5/1/2024 1489-000 5/1/2019 12/31/2019 5/1/2024 Unit: 1158-000 44-DHDU 5/12/2017 Area: 12/31/2019 Authorized By: 44 D-478 5/12/2022 Reason: Equipment: Repaired?: 41 W-113 TODD BARELA/ REPAIR IS TECHNICALLY RAYSMALTS INFEASIBLE WITHOUT A PROCESS EQUIPMENT IS ISOLATED FROM ROMAN AGULAR/ RAYSMALTS THE PROCESS AND DOES NO 44 C-421 Equipment: No JIM REPAIR IS TECHNICALLY MCFATRIDGE/RAY INFEASIBLE WITHOUT A PROCESS SMALTS JIM MCFATRIDGE/ REPAIR IS TECHNICALLY RAYSMALTS INFEASIBLE WITHOUT A PROCESS Equipment: 44 D-478 No ERIC HARDEN/ RAY SMALTS No EQUIPMENT IS ISOLATED FROM THE PROCESS AND DOES NO No No Signature of Owner or Operator Responsible for Delay of Repair Decision Page 3 of 3 on 10/3/2019 8:31 :03 AM Printed By: ALeger HFNA-000005930 EPA Inspection Report - Page 993 of 1969 Inspection History HollyFrontier Artesia From: 1/1/2016 To: 12/31/2019, All Inspections Under NSPS - Wa/GGGa Unit: 30-SRU #2 Area: NSPS Equipment: NSPS Inspection: Tag: Component Type: Location Description: Size: Repair: Applicable Leak Std. Rel nspection: Service: Date & Time: PPM: DPM: Date & Time: Date & Time: PPM: PPM: DPM: Taken Out of Service: 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 1/11/2016 4:06:46 PM 814 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 2/17/2016 2:59:05 PM 863 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 3/16/2016 3:35:20 PM 1362 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 4/5/2016 2:38:28 PM 998 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 5/25/2016 9:09:17 AM 742 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 7/11/2016 1 :34:37 PM 17 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 8/3/2016 10:13:53 AM 2 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 9/8/2016 10:28:39 AM 262 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 10/14/2016 8:17:05AM 190 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 11/7/2016 2:36:40 PM 520 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 12/21/2016 2:25:16 PM 677 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 1/12/2017 9:03:57 AM 660 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 2/13/2017 10:28:51 AM 557 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 3/24/2017 11:02:28AM 6266 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 4/25/2017 10:51:38AM 4226 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 5/31/2017 8:13:57 AM 4498 0 None None N/A 500 1 N Page 1 of 3 on 10/2/2019 1:58:18 PM Printed By: ALeger HFNA-000005890 EPA Inspection Report - Page 994 of 1969 Inspection History HollyFrontier Artesia From: 1/1/2016 To: 12/31/2019, All Inspections Under NSPS - Wa/GGGa Unit: 30-SRU #2 Area: NSPS Equipment: NSPS Inspection: Tag: Component Type: Location Description: Size: Repair: Applicable Leak Std. Rel nspection: Service: Date & Time: PPM: DPM: Date & Time: Date & Time: PPM: PPM: DPM: Taken Out of Service: 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 6/2/2017 11 :26:02 AM 1401 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 6/8/2017 2:54:05 PM 16400 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 7/26/2017 9:59:13 AM 127700 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 9/13/2017 2:45:52 PM 27400 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 10/30/2017 3:21:37 PM 4584 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 11/7/2017 11:56:37 AM 5964 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 12/12/2017 9:33:08AM 10700 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 1/10/2018 3:08:12 PM 30500 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 2/8/2018 8:52:03 AM 6694 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 3/9/201811:06:17 AM 20 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 4/20/2018 8:40:14 AM 500000 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 5/15/2018 11:09:03AM 6081 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 6/11/2018 9:59:04 AM 6580 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 7/30/2018 11:11:25AM 1922 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 8/2/2018 9:25:17 AM 5865 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 9/19/2018 8:00:44 AM 7720 0 None None N/A 500 1 N Page 2 of 3 on 10/2/2019 1:58:18 PM Printed By: ALeger HFNA-000005891 EPA Inspection Report - Page 995 of 1969 Inspection History HollyFrontier Artesia From: 1/1/2016 To: 12/31/2019, All Inspections Under NSPS - Wa/GGGa Unit: 30-SRU #2 Area: NSPS Equipment: NSPS Inspection: Tag: Component Type: Location Description: Size: Repair: Applicable Leak Std. Rel nspection: Service: Date & Time: PPM: DPM: Date & Time: Date & Time: PPM: PPM: DPM: Taken Out of Service: 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 10/9/2018 2:05:00 PM 8866 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 11/2/2018 10:41:52AM 12600 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 12/10/2018 1:43:46 PM 4722 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 1/15/2019 11:14:18AM 8617 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 2/15/2019 11:26:47AM 3413 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 3/21/2019 1 :41 :29 PM 2837 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 4/15/2019 9:21 :50 AM 21300 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 5/2/2019 8:46:10 AM 6999 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 6/10/2019 2:50:37 PM 559 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 7/26/2019 7:39:05 AM 1764 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 8/5/2019 2:24:24 PM 720 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 8/29/2019 11:04:24AM 2768 0 None None N/A 500 1 N 2720-000 VALVE FG LOOP NW D-469 ORN NW 12.1 0.75 GASNAPOR 9/18/2019 3:03:39 PM 602 None None N/A 500 1 N Page 3 of 3 on 10/2/2019 1:58:18 PM Printed By: ALeger HFNA-000005892 EPA Inspection Report - Page 996 of 1969 2018 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Jan 2-Jan 3-Jan 4-Jan 5-Jan 6-Jan 7-Jan 8-Jan 9-Jan 10-Jan 11-Jan 12-Jan 13-Jan 14-Jan 15-Jan 16-Jan 17-Jan 18-Jan 19-Jan 20-Jan 21-Jan 22-Jan 23-Jan 24-Jan 25-Jan 26-Jan 27-Jan 28-Jan 29-Jan 30-Jan 31-Jan 137.0 56.0 89.0 12.0 4.0 17.0 245.0 103.0 272.0 90.0 4.0 7.0 6.0 30.0 112.0 61.0 78.0 125.0 455.0 236.0 119.0 126.0 109.0 244.0 390.0 400.0 112.0 233.0 539.0 211.0 340.0 Old System Lead Filter Outlet 10.0 1.0 2.0 3.0 2.0 3.0 2.0 6.0 5.0 6.0 3.0 4.0 4.0 4.0 8.0 5.0 6.0 4.0 2.0 10.0 8.0 4.0 5.0 6.0 7.0 9.0 9.0 10.0 4.0 5.0 8.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 10.0 1.0 2.0 2.0 2.0 3.0 2.0 4.0 5.0 6.0 3.0 3.0 3.0 4.0 8.0 5.0 6.0 3.0 2.0 10.0 8.0 4.0 4.0 6.0 5.0 7.0 9.0 10.0 3.0 5.0 8.0 5.0 1.0 1.0 2.0 1.0 3.0 3.0 3.0 3.0 4.0 1.0 3.0 1.0 4.0 5.0 3.0 4.0 3.0 2.0 5.0 3.0 4.0 4.0 3.0 4.0 4.0 5.0 4.0 3.0 5.0 6.0 January Old System Background Minimum Old System Background Maximum Old System Background Average 6.0 1.0 1.0 2.0 4.0 4.0 5.0 7.0 14.0 7.0 4.0 5.0 5.0 4.0 3.0 3.0 2.0 5.0 4.0 6.0 4.0 3.0 1.0 2.0 6.0 3.0 4.0 5.0 3.0 9.0 7.0 19.0 1.0 8.0 5.0 6.0 8.0 18.0 10.0 19.0 15.0 7.0 6.0 7.0 6.0 12.0 6.0 12.0 7.0 5.0 15.0 10.0 6.0 4.0 16.0 8.0 5.0 11.0 21.0 7.0 12.0 17.0 12.5 1.0 4.5 3.5 5.0 6.0 11.5 8.5 16.5 11.0 5.5 5.5 6.0 5.0 7.5 4.5 7.0 6.0 4.5 10.5 7.0 4.5 2.5 9.0 7.0 4.0 7.5 13.0 5.0 10.5 12.0 Old System Net Reading Control Efficiency (%) New System Lead Filter Inlet 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 96.35% 98.21% 98.88% 83.33% 75.00% 82.35% 98.78% 97.09% 98.90% 95.56% 75.00% 57.14% 83.33% 86.67% 95.54% 95.08% 94.87% 97.60% 99.56% 97.88% 97.48% 96.83% 96.33% 98.77% 98.97% 99.00% 95.54% 98.28% 99.44% 97.63% 98.24% 18.0 6.0 28.0 3.0 8.0 20.0 8.0 12.0 20.0 20.0 36.0 24.0 20.0 17.0 23.0 16.0 12.0 15.0 19.0 26.0 17.0 19.0 12.0 31.0 13.0 16.0 16.0 28.0 11.0 24.0 15.0 New New System System Between Lag Filter Filters Outlet 7.0 1.0 10.0 2.0 8.0 6.0 4.0 6.0 10.0 8.0 3.0 4.0 5.0 3.0 11.0 10.0 7.0 7.0 7.0 12.0 9.0 4.0 4.0 12.0 4.0 7.0 8.0 11.0 5.0 4.0 5.0 4.0 1.0 6.0 2.0 2.0 5.0 4.0 4.0 9.0 6.0 2.0 3.0 4.0 4.0 4.0 6.0 5.0 5.0 8.0 3.0 5.0 3.0 3.0 9.0 4.0 6.0 4.0 5.0 4.0 4.0 4.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 2.0 4.0 4.0 1.0 3.0 11.0 3.0 24.0 13.0 8.0 1.0 7.0 6.0 4.0 6.0 7.0 4.0 11.0 17.0 7.0 2.0 5.0 2.0 8.0 6.0 3.0 3.0 4.0 7.0 5.0 3.0 9.0 5.0 16.0 2.0 4.0 50.0 10.0 72.0 19.0 12.0 6.0 12.0 8.0 6.0 24.0 12.0 9.0 15.0 18.0 19.0 11.0 8.0 5.0 21.0 24.0 56.0 15.0 17.0 36.0 22.0 15.0 5.5 4.5 10.0 1.5 3.5 30.5 6.5 48.0 16.0 10.0 3.5 9.5 7.0 5.0 15.0 9.5 6.5 13.0 17.5 13.0 6.5 6.5 3.5 14.5 15.0 29.5 9.0 10.5 21.5 13.5 9.0 0.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 77.78% 83.33% 78.57% 33.33% 75.00% 75.00% 50.00% 66.67% 55.00% 70.00% 94.44% 87.50% 80.00% 76.47% 82.61% 62.50% 58.33% 66.67% 57.89% 88.46% 70.59% 84.21% 75.00% 70.97% 69.23% 62.50% 75.00% 82.14% 63.64% 83.33% 73.33% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Oni Ruiz Israel Estrella Eduardo Chavez Jewel Husselman Jewel Husselman Theo Rodriguez Theo Rodriguez Jewel Husselman Jewel Husselman Jewel Husselman Jewel Husselman Jewel Husselman Jewel Husselman Jewel Husselman Oni Ruiz Eduardo Chavez Eduardo Chavez Israel Estrella Israel Estrella Oni Ruiz Oni Ruiz Jewel Husselman Jewel Husselman Eduardo Chavez Homer Trujillo Homer Trujillo Oni Ruiz Oni Ruiz Carlos Martinez Homer Trujillo Homer Trujillo EPA Inspection Report - Page 997 of 1969 2018 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Feb 318.0 2-Feb 338.0 3-Feb 330.0 4-Feb 357.0 5-Feb 457.0 6-Feb 383.0 7-Feb 255.0 8-Feb 273.0 9-Feb 279.0 10-Feb 249.0 11-Feb 324.0 12-Feb 397.0 13-Feb 365.0 14-Feb 268.0 15-Feb 247.0 16-Feb 308.0 17-Feb 281.0 18-Feb 326.0 19-Feb 451.0 20-Feb 647.0 21-Feb 279.0 22-Feb 347.0 23-Feb 572.0 24-Feb 389.0 25-Feb 274.0 26-Feb 597.0 27-Feb 126.0 28-Feb 510.0 Old System Lead Filter Outlet 8.0 9.0 8.0 10.0 8.0 3.0 4.0 4.0 4.0 3.0 9.0 9.0 5.0 9.0 8.0 10.0 6.0 9.0 6.0 5.0 4.0 16.0 8.0 8.0 7.0 3.0 8.0 4.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 8.0 9.0 8.0 10.0 5.0 3.0 4.0 4.0 4.0 3.0 9.0 9.0 4.0 9.0 8.0 10.0 6.0 9.0 6.0 5.0 4.0 16.0 2.0 8.0 7.0 3.0 8.0 4.0 6.0 6.0 4.0 5.0 4.0 3.0 4.0 4.0 5.0 3.0 4.0 5.0 3.0 6.0 3.0 6.0 2.0 5.0 6.0 4.0 3.0 17.0 2.0 4.0 3.0 2.0 3.0 4.0 February Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 2.0 5.0 3.0 4.0 2.0 2.0 3.0 5.0 2.0 1.0 2.0 2.0 3.0 2.0 2.0 4.0 4.0 3.0 10.0 2.0 4.0 17.0 2.0 3.0 2.0 7.0 4.0 3.0 10.0 12.0 9.0 16.0 4.0 5.0 12.0 8.0 6.0 6.0 7.0 9.0 4.0 17.0 15.0 13.0 6.0 7.0 13.0 5.0 4.0 24.0 3.0 14.0 10.0 10.0 14.0 6.0 6.0 8.5 6.0 10.0 3.0 3.5 7.5 6.5 4.0 3.5 4.5 5.5 3.5 9.5 8.5 8.5 5.0 5.0 11.5 3.5 4.0 20.5 2.5 8.5 6.0 8.5 9.0 4.5 0.0 0.0 0.0 0.0 1.0 0.0 0.0 0.0 1.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 98.11% 98.22% 98.79% 98.60% 99.12% 99.22% 98.43% 98.53% 98.21% 98.80% 98.77% 98.74% 99.18% 97.76% 98.79% 98.05% 99.29% 98.47% 98.67% 99.38% 98.92% 95.10% 99.65% 98.97% 98.91% 99.66% 97.62% 99.22% New System Lead Filter Inlet 26.0 23.0 24.0 21.0 9.0 10.0 12.0 10.0 11.0 9.0 22.0 15.0 53.0 19.0 38.0 28.0 31.0 57.0 18.0 15.0 17.0 47.0 11.0 14.0 17.0 11.0 59.0 10.0 New New System System Between Lag Filter Filters Outlet 13.0 14.0 12.0 10.0 3.0 3.0 5.0 7.0 5.0 4.0 11.0 9.0 5.0 11.0 13.0 11.0 5.0 14.0 6.0 9.0 4.0 23.0 6.0 9.0 10.0 6.0 6.0 4.0 4.0 5.0 5.0 3.0 2.0 2.0 4.0 6.0 4.0 3.0 3.0 5.0 4.0 5.0 4.0 5.0 2.0 4.0 5.0 6.0 4.0 19.0 4.0 3.0 3.0 5.0 3.0 4.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 6.0 4.0 5.0 5.0 2.0 6.0 10.0 10.0 4.0 5.0 5.0 4.0 8.0 3.0 5.0 2.0 7.0 1.0 5.0 11.0 9.0 18.0 12.0 2.0 5.0 11.0 2.0 3.0 14.0 13.0 13.0 13.0 4.0 14.0 37.0 15.0 7.0 8.0 13.0 12.0 14.0 8.0 17.0 17.0 19.0 13.0 9.0 21.0 13.0 34.0 18.0 12.0 14.0 22.0 7.0 4.0 10.0 8.5 9.0 9.0 3.0 10.0 23.5 12.5 5.5 6.5 9.0 8.0 11.0 5.5 11.0 9.5 13.0 7.0 7.0 16.0 11.0 26.0 15.0 7.0 9.5 16.5 4.5 3.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 84.62% 78.26% 79.17% 85.71% 77.78% 80.00% 66.67% 40.00% 63.64% 66.67% 86.36% 66.67% 92.45% 73.68% 89.47% 82.14% 93.55% 92.98% 72.22% 60.00% 76.47% 59.57% 63.64% 78.57% 82.35% 54.55% 94.92% 60.00% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Eduardo Chavez Oni Ruiz Oni Ruiz Oni Ruiz Jewel Husselman Jewel Husselman Carlos Martinez Jewel Husselman Jewel Husselman Carlos Martinez Oni Ruiz Oni Ruiz Homer Trujillo Oni Ruiz Oni Ruiz Oni Ruiz Eduardo Chavez Oni Ruiz Jewel Husselman Carlos Martinez Israel Estrella Theo Rodriguez Carlos Martinez Oni Ruiz Oni Ruiz Carlos Martinez Oni Ruiz Carlos Martinez EPA Inspection Report - Page 998 of 1969 2018 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Mar 500.0 2-Mar 217.0 3-Mar 362.0 4-Mar 321.0 5-Mar 244.0 6-Mar 120.0 7-Mar 281.0 8-Mar 118.0 9-Mar 138.0 10-Mar 275.0 11-Mar 298.0 12-Mar 878.0 13-Mar 550.0 14-Mar 330.0 15-Mar 1038.0 16-Mar 921.0 17-Mar 519.0 18-Mar 322.0 19-Mar 90.0 20-Mar 763.0 21-Mar 51.0 22-Mar 371.0 23-Mar 252.0 24-Mar 171.0 25-Mar 496.0 26-Mar 421.0 27-Mar 379.0 28-Mar 285.0 29-Mar 670.0 30-Mar 212.0 500.0 31-Mar Old System Lead Filter Outlet 2.0 4.0 9.0 6.0 6.0 4.0 3.0 5.0 7.0 8.0 11.0 4.0 3.0 5.0 8.0 9.0 6.0 4.0 3.0 3.0 3.0 4.0 3.0 4.0 4.0 5.0 3.0 9.0 5.0 4.0 5.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 2.0 4.0 9.0 6.0 6.0 4.0 3.0 5.0 7.0 8.0 11.0 4.0 3.0 5.0 8.0 9.0 6.0 4.0 3.0 3.0 2.0 4.0 7.0 4.0 3.0 4.0 2.0 7.0 5.0 4.0 5.0 2.0 3.0 3.0 5.0 4.0 3.0 2.0 3.0 3.0 3.0 5.0 3.0 2.0 4.0 6.0 2.0 4.0 2.0 2.0 2.0 3.0 8.0 3.0 3.0 4.0 3.0 3.0 3.0 4.0 6.0 4.0 March Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 2.0 2.0 5.0 2.0 2.0 2.0 4.0 4.0 2.0 2.0 4.0 3.0 2.0 2.0 4.0 4.0 3.0 2.0 1.0 9.0 2.0 7.0 5.0 3.0 2.0 4.0 2.0 4.0 5.0 7.0 2.0 3.0 6.0 13.0 9.0 6.0 3.0 6.0 6.0 6.0 9.0 12.0 7.0 3.0 3.0 6.0 11.0 12.0 9.0 1.0 25.0 2.0 21.0 10.0 3.0 3.0 3.0 5.0 8.0 13.0 13.0 38.0 2.5 4.0 9.0 5.5 4.0 2.5 5.0 5.0 4.0 5.5 8.0 5.0 2.5 2.5 5.0 7.5 7.5 5.5 1.0 17.0 2.0 14.0 7.5 3.0 2.5 4.0 3.5 6.0 9.0 10.0 20.0 0.0 0.0 0.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.5 1.0 0.0 0.0 0.0 1.0 0.0 1.0 0.0 0.0 0.0 1.5 0.0 0.0 0.0 0.0 0.0 0.0 99.60% 98.62% 99.17% 98.44% 98.36% 97.50% 99.29% 97.46% 97.83% 98.91% 98.32% 99.66% 99.64% 98.79% 99.42% 99.78% 99.23% 99.38% 97.78% 99.74% 94.12% 97.84% 98.81% 98.25% 99.19% 99.29% 99.21% 98.95% 99.40% 97.17% 99.20% New System Lead Filter Inlet 8.0 31.0 29.0 25.0 28.0 18.0 23.0 29.0 14.0 21.0 34.0 12.0 8.0 22.0 26.0 34.0 41.0 23.0 9.0 10.0 4.0 13.0 7.0 12.0 13.0 12.0 12.0 50.0 17.0 7.0 13.0 New New System System Between Lag Filter Filters Outlet 8.0 6.0 11.0 11.0 8.0 8.0 10.0 9.0 11.0 14.0 17.0 8.0 3.0 12.0 9.0 13.0 12.0 11.0 4.0 5.0 3.0 7.0 5.0 6.0 7.0 7.0 5.0 18.0 8.0 5.0 8.0 5.0 2.0 4.0 2.0 6.0 6.0 8.0 6.0 4.0 2.0 2.0 6.0 4.0 9.0 3.0 4.0 9.0 7.0 3.0 7.0 2.0 6.0 4.0 4.0 6.0 5.0 4.0 8.0 6.0 5.0 7.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 14.0 3.0 8.0 4.0 3.0 9.0 7.0 7.0 5.0 4.0 6.0 18.0 3.0 3.0 6.0 8.0 8.0 2.0 6.0 19.0 2.0 12.0 7.0 5.0 11.0 6.0 4.0 7.0 6.0 7.0 8.0 16.0 14.0 21.0 7.0 12.0 17.0 10.0 14.0 10.0 7.0 10.0 30.0 5.0 4.0 12.0 36.0 17.0 8.0 6.0 24.0 2.0 14.0 13.0 6.0 17.0 9.0 10.0 9.0 19.0 16.0 21.0 15.0 8.5 14.5 5.5 7.5 13.0 8.5 10.5 7.5 5.5 8.0 24.0 4.0 3.5 9.0 22.0 12.5 5.0 6.0 21.5 2.0 13.0 10.0 5.5 14.0 7.5 7.0 8.0 12.5 11.5 14.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 5.5 0.0 0.0 0.0 2.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 37.50% 93.55% 86.21% 92.00% 78.57% 66.67% 65.22% 79.31% 71.43% 90.48% 94.12% 50.00% 50.00% 59.09% 88.46% 88.24% 78.05% 69.57% 66.67% 30.00% 50.00% 53.85% 42.86% 66.67% 53.85% 58.33% 66.67% 84.00% 64.71% 28.57% 46.15% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Jewel Husselman Eduardo Chavez Oni Ruiz Oni Ruiz Eduardo Chavez Eduardo Chavez Eduardo Chavez Eduardo Chavez Oni Ruiz Oni Ruiz Oni Ruiz Carlos Martinez Jose Nava Jose Nava Oni Ruiz Oni Ruiz Eduardo Chavez Eduardo Chavez Jewel Husselman Israel Estrella Israel Estrella Israel Estrella Israel Estrella Israel Estrella Israel Estrella Carlos Martinez Eduardo Chavez Homer Trujillo Oni Ruiz Carlos Martinez Theo Rodriguez EPA Inspection Report - Page 999 of 1969 2018 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Apr 420.0 2-Apr 1178.0 3-Apr 121.0 4-Apr 304.0 5-Apr 438.0 6-Apr 478.0 7-Apr 335.0 8-Apr 746.0 9-Apr 162.0 10-Apr 819.0 11-Apr 378.0 12-Apr 303.0 13-Apr 238.0 14-Apr 635.0 15-Apr 374.0 16-Apr 297.0 17-Apr 334.0 18-Apr 197.0 19-Apr 379.0 20-Apr 182.0 21-Apr 197.0 22-Apr 116.0 23-Apr 241.0 24-Apr 560.0 25-Apr 362.0 26-Apr 349.0 27-Apr 337.0 28-Apr 378.0 29-Apr 501.0 30-Apr 303.0 Old System Lead Filter Outlet 5.0 9.0 2.0 5.0 8.0 5.0 3.0 4.0 4.0 4.0 11.0 4.0 9.0 11.0 8.0 6.0 8.0 10.0 14.0 3.0 6.0 4.0 9.0 4.0 11.0 4.0 3.0 3.0 4.0 5.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 5.0 9.0 2.0 5.0 8.0 4.0 3.0 3.0 4.0 4.0 11.0 4.0 9.0 11.0 8.0 6.0 8.0 10.0 14.0 5.0 6.0 4.0 9.0 4.0 8.0 3.0 3.0 3.0 3.0 5.0 3.0 5.0 1.0 3.0 7.0 4.0 2.0 3.0 3.0 3.0 9.0 5.0 3.0 5.0 5.0 2.0 4.0 5.0 7.0 4.0 3.0 2.0 2.0 3.0 7.0 3.0 2.0 2.0 3.0 5.0 April Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 3.0 3.0 3.0 3.0 7.0 6.0 1.0 3.0 2.0 4.0 4.0 7.0 4.0 6.0 3.0 3.0 2.0 3.0 47.0 3.0 3.0 4.0 3.0 2.0 6.0 2.0 5.0 3.0 4.0 4.0 19.0 19.0 9.0 12.0 18.0 11.0 4.0 6.0 8.0 5.0 19.0 11.0 8.0 19.0 13.0 9.0 9.0 11.0 59.0 4.0 8.0 5.0 17.0 3.0 6.0 6.0 6.0 4.0 5.0 4.0 11.0 11.0 6.0 7.5 12.5 8.5 2.5 4.5 5.0 4.5 11.5 9.0 6.0 12.5 8.0 6.0 5.5 7.0 53.0 3.5 5.5 4.5 10.0 2.5 6.0 4.0 5.5 3.5 4.5 4.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 0.0 0.0 0.0 0.5 1.0 0.0 0.0 0.0 0.0 1.0 99.29% 99.58% 99.17% 99.01% 98.40% 99.16% 99.40% 99.60% 98.15% 99.63% 97.62% 98.35% 98.74% 99.21% 98.66% 99.33% 98.80% 97.46% 98.15% 97.80% 98.48% 98.28% 99.17% 99.46% 98.07% 99.14% 99.41% 99.47% 99.40% 98.35% New System Lead Filter Inlet 21.0 15.0 16.0 28.0 23.0 11.0 8.0 14.0 22.0 8.0 15.0 10.0 17.0 31.0 19.0 15.0 17.0 19.0 26.0 9.0 11.0 9.0 19.0 17.0 10.0 10.0 13.0 13.0 21.0 21.0 New New System System Between Lag Filter Filters Outlet 10.0 7.0 14.0 6.0 8.0 5.0 6.0 9.0 7.0 6.0 11.0 6.0 12.0 12.0 12.0 9.0 9.0 13.0 13.0 5.0 6.0 4.0 11.0 7.0 7.0 6.0 5.0 5.0 6.0 6.0 8.0 4.0 2.0 4.0 7.0 4.0 3.0 7.0 4.0 7.0 9.0 5.0 4.0 4.0 4.0 5.0 3.0 4.0 3.0 5.0 4.0 2.0 4.0 7.0 6.0 3.0 3.0 2.0 3.0 6.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 10.0 2.0 3.0 2.0 9.0 4.0 7.0 33.0 3.0 17.0 8.0 6.0 2.0 2.0 6.0 4.0 6.0 2.0 12.0 8.0 6.0 3.0 5.0 5.0 10.0 4.0 3.0 4.0 3.0 6.0 21.0 11.0 12.0 17.0 31.0 6.0 18.0 46.0 12.0 22.0 11.0 8.0 11.0 8.0 10.0 12.0 10.0 7.0 24.0 10.0 12.0 9.0 10.0 7.0 45.0 5.0 5.0 7.0 4.0 7.0 15.5 6.5 7.5 9.5 20.0 5.0 12.5 39.5 7.5 19.5 9.5 7.0 6.5 5.0 8.0 8.0 8.0 4.5 18.0 9.0 9.0 6.0 7.5 6.0 27.5 4.5 4.0 5.5 3.5 6.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.0 0.0 0.0 0.0 0.0 0.0 0.0 61.90% 73.33% 87.50% 85.71% 69.57% 63.64% 62.50% 50.00% 81.82% 12.50% 40.00% 50.00% 76.47% 87.10% 78.95% 66.67% 82.35% 78.95% 88.46% 44.44% 63.64% 77.78% 78.95% 58.82% 40.00% 70.00% 76.92% 84.62% 85.71% 71.43% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Theo Rodriguez Oni Ruiz Eduardo Chavez Eduardo Chavez Theo Rodriguez Jose Nava Carlos Martinez Carlos Martinez Eduardo Chavez Israel Estrella Homer Trujillo Jerid Heath Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Jewel Husselman Eduardo Chavez Eduardo Chavez Oni Ruiz Jose Nava Homer Trujillo Jose Nava Jose Nava Jose Nava Jose Nava Jerid Heath EPA Inspection Report - Page 1000 of 1969 2018 API Carbon Canister Monitoring for Month: Old System Lead Monitoring Date Filter Inlet 1-May 418.0 2-May 188.0 3-May 232.0 4-May 162.0 5-May 981.0 6-May 476.0 7-May 378.0 8-May 378.0 9-May 263.0 10-May 423.0 11-May 483.0 12-May 396.0 13-May 418.0 14-May 571.0 15-May 141.0 16-May 265.0 17-May 376.0 18-May 117.0 19-May 193.0 20-May 211.0 21-May 193.0 22-May 278.0 23-May 365.0 24-May 388.0 25-May 388.0 26-May 193.0 27-May 218.0 28-May 248.0 29-May 872.0 30-May 712.0 31-May 1713.0 Old System Lead Filter Outlet 6.0 8.0 7.0 5.0 3.0 9.0 3.0 8.0 8.0 9.0 8.0 10.0 6.0 5.0 6.0 7.0 10.0 23.0 5.0 4.0 5.0 9.0 4.0 9.0 9.0 4.0 5.0 6.0 10.0 7.0 6.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 5.0 8.0 6.0 4.0 3.0 9.0 3.0 8.0 8.0 9.0 8.0 9.0 6.0 4.0 6.0 7.0 10.0 7.0 5.0 4.0 5.0 9.0 5.0 9.0 9.0 4.0 5.0 6.0 7.0 7.0 6.0 5.0 9.0 6.0 4.0 2.0 3.0 4.0 4.0 4.0 5.0 2.0 5.0 3.0 4.0 4.0 4.0 6.0 3.0 3.0 3.0 3.0 3.0 5.0 6.0 6.0 2.0 4.0 4.0 8.0 5.0 4.0 May Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 4.0 9.0 10.0 4.0 1.0 6.0 3.0 3.0 3.0 7.0 7.0 2.0 2.0 7.0 3.0 3.0 5.0 6.0 3.0 4.0 5.0 6.0 4.0 4.0 4.0 4.0 3.0 5.0 13.0 8.0 3.0 5.0 11.0 12.0 7.0 4.0 14.0 9.0 9.0 7.0 18.0 12.0 7.0 7.0 10.0 8.0 12.0 18.0 10.0 9.0 8.0 9.0 12.0 4.0 6.0 6.0 8.0 8.0 8.0 15.0 10.0 5.0 4.5 10.0 11.0 5.5 2.5 10.0 6.0 6.0 5.0 9.8 9.5 4.5 4.5 8.5 5.5 7.5 11.5 8.0 6.0 6.0 7.0 9.0 4.0 5.0 5.0 6.0 5.5 6.5 14.0 9.0 4.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.0 1.0 1.0 0.0 0.0 0.0 0.0 0.0 0.0 98.80% 95.21% 97.41% 97.53% 99.80% 99.37% 98.94% 98.94% 98.48% 98.82% 99.59% 98.74% 99.28% 99.30% 97.16% 98.49% 98.40% 97.44% 98.45% 98.58% 98.45% 98.92% 98.63% 98.45% 98.45% 98.96% 98.17% 98.39% 99.08% 99.30% 99.77% New System Lead Filter Inlet 12.0 13.0 24.0 23.0 19.0 18.0 23.0 23.0 27.0 29.0 21.0 19.0 23.0 24.0 14.0 21.0 28.0 32.0 27.0 23.0 22000.0 3377.0 4805.0 3146.0 3146.0 2831.0 4652.0 5703.0 4500.0 2831.0 2243.0 New New System System Between Lag Filter Filters Outlet 7.0 9.0 7.0 12.0 11.0 11.0 9.0 9.0 16.0 18.0 13.0 12.0 15.0 8.0 7.0 13.0 18.0 13.0 14.0 16.0 10.0 14.0 7.0 16.0 16.0 13.0 10.0 8.0 19.0 9.0 9.0 6.0 9.0 6.0 7.0 6.0 5.0 8.0 8.0 4.0 6.0 5.0 3.0 4.0 6.0 5.0 2.0 5.0 9.0 7.0 8.0 7.0 5.0 4.0 10.0 10.0 7.0 5.0 3.0 16.0 8.0 11.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 10.0 12.0 5.0 6.0 12.0 4.0 13.0 13.0 5.0 10.0 3.0 4.0 5.0 7.0 6.0 2.0 7.0 2.0 6.0 12.0 8.0 2.0 7.0 8.0 8.0 6.0 8.0 4.0 17.0 13.0 34.0 11.0 13.0 6.0 12.0 40.0 12.0 18.0 18.0 26.0 26.0 12.0 8.0 17.0 8.0 10.0 9.0 23.0 17.0 18.0 19.0 16.0 8.0 14.0 14.0 14.0 12.0 10.0 13.0 20.0 15.0 42.0 10.5 12.5 5.5 9.0 26.0 8.0 15.5 15.5 15.5 18.0 7.5 6.0 11.0 7.5 8.0 5.5 15.0 9.5 12.0 15.5 12.0 5.0 10.5 11.0 11.0 9.0 9.0 8.5 18.5 14.0 38.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 50.00% 30.77% 75.00% 69.57% 68.42% 72.22% 65.22% 65.22% 85.19% 79.31% 76.19% 84.21% 82.61% 75.00% 64.29% 90.48% 82.14% 71.88% 74.07% 65.22% 99.97% 99.85% 99.92% 99.68% 99.68% 99.75% 99.89% 99.95% 99.64% 99.72% 99.51% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Jerid Heath Jerid Heath Jerid Heath Carlos Martinez Carlos Martinez Oni Ruiz Jewel Husselman Jewel Husselman Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Jose Nava Eduardo Chavez Oni Ruiz Oni Ruiz Jewel Husselman Carlos Martinez Carlos Martinez Oni Ruiz Oni Ruiz Israel Estrella Eduardo Chavez Eduardo Chavez Eduardo Chavez Eduardo Chavez Eduardo Chavez Jerid Heath Jerid Heath Israel Estrella EPA Inspection Report - Page 1001 of 1969 2018 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Jun 332.0 2-Jun 304.0 3-Jun 485.0 4-Jun 485.0 5-Jun 610.0 6-Jun 731.0 7-Jun 578.0 8-Jun 608.0 9-Jun 731.0 10-Jun 516.0 11-Jun 523.0 12-Jun 478.0 13-Jun 465.0 14-Jun 481.0 15-Jun 556.0 16-Jun 487.0 17-Jun 697.0 18-Jun 233.0 19-Jun 408.0 20-Jun 276.0 21-Jun 676.0 22-Jun 261.0 23-Jun 312.0 24-Jun 375.0 25-Jun 756.0 26-Jun 480.0 27-Jun 460.0 28-Jun 295.0 29-Jun 571.0 30-Jun 673.0 Old System Lead Filter Outlet 5.0 6.0 6.0 5.0 5.0 5.0 6.0 6.0 7.0 4.0 5.0 9.0 6.0 4.0 7.0 8.0 10.0 6.0 5.0 10.0 6.0 14.0 7.0 9.0 23.0 9.0 3.0 4.0 7.0 7.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 5.0 6.0 6.0 4.0 5.0 4.0 4.0 6.0 7.0 4.0 5.0 9.0 8.0 4.0 5.0 8.0 10.0 6.0 4.0 10.0 6.0 14.0 9.0 10.0 23.0 9.0 3.0 4.0 5.0 7.0 8.0 5.0 6.0 4.0 4.0 4.0 4.0 5.0 5.0 3.0 4.0 8.0 6.0 7.0 7.0 3.0 6.0 4.0 7.0 7.0 5.0 10.0 7.0 9.0 13.0 7.0 4.0 6.0 5.0 4.0 June Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 8.0 7.0 5.0 4.0 5.0 6.0 4.0 4.0 6.0 5.0 4.0 6.0 7.0 6.0 6.0 4.0 9.0 2.0 8.0 5.0 4.0 9.0 8.0 8.0 3.0 3.0 2.0 4.0 4.0 5.0 17.0 8.0 6.0 5.0 8.0 9.0 6.0 6.0 8.0 6.0 5.0 8.0 8.0 6.0 7.0 9.0 34.0 7.0 9.0 5.0 7.0 10.0 9.0 9.0 4.0 4.0 3.0 5.0 13.0 9.0 12.5 7.5 5.5 4.5 6.5 7.5 5.0 5.0 7.0 5.5 4.5 7.0 7.5 6.0 6.5 6.5 21.5 4.5 8.5 5.0 5.5 9.5 8.5 8.5 3.5 3.5 2.5 4.5 8.5 7.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.0 0.0 1.0 0.5 0.0 0.0 0.0 0.0 2.0 0.0 0.5 0.0 0.5 9.5 3.5 1.5 1.5 0.0 0.0 97.59% 98.36% 98.76% 99.18% 99.34% 99.45% 99.31% 99.18% 99.32% 99.42% 99.24% 98.33% 98.71% 98.54% 98.74% 99.38% 99.14% 98.28% 98.28% 97.46% 99.26% 96.17% 97.76% 97.60% 98.28% 98.54% 99.13% 97.97% 99.12% 99.41% New System Lead Filter Inlet 2561.0 2750.0 2371.0 1648.0 1962.0 1972.0 2079.0 1310.0 1997.0 1713.0 1653.0 1276.0 2529.0 2856.0 3517.0 2654.0 3658.0 2496.0 2345.0 1200.0 1465.0 2400.0 2315.0 3219.0 2400.0 3500.0 1745.0 3700.0 1200.0 2738.0 New New System System Between Lag Filter Filters Outlet 8.0 9.0 6.0 12.0 14.0 12.0 14.0 10.0 15.0 9.0 6.0 12.0 8.0 7.0 8.0 14.0 17.0 12.0 4.0 3.0 15.0 6.0 12.0 13.0 7.0 5.0 6.0 5.0 4.0 13.0 5.0 9.0 5.0 7.0 8.0 5.0 5.0 5.0 10.0 5.0 6.0 10.0 9.0 7.0 8.0 5.0 5.0 8.0 5.0 3.0 7.0 5.0 10.0 11.0 7.0 5.0 3.0 6.0 3.0 4.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 8.0 10.0 9.0 8.0 9.0 8.0 5.0 3.0 7.0 4.0 5.0 17.0 10.0 9.0 9.0 2.0 12.0 4.0 10.0 4.0 8.0 9.0 10.0 10.0 9.0 5.0 13.0 11.0 6.0 2.0 9.0 11.0 10.0 11.0 12.0 11.0 7.0 4.0 10.0 5.0 6.0 18.0 12.0 11.0 11.0 12.0 39.0 9.0 12.0 7.0 14.0 24.0 12.0 12.0 14.0 7.0 17.0 13.0 10.0 12.0 8.5 10.5 9.5 9.5 10.5 9.5 6.0 3.5 8.5 4.5 5.5 17.5 11.0 10.0 10.0 7.0 25.5 6.5 11.0 5.5 11.0 16.5 11.0 11.0 11.5 6.0 15.0 12.0 8.0 7.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.5 1.5 0.5 0.5 0.0 0.0 0.0 0.0 0.0 0.0 1.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 99.80% 99.67% 99.79% 99.58% 99.59% 99.75% 99.76% 99.62% 99.50% 99.71% 99.64% 99.22% 99.64% 99.75% 99.77% 99.81% 99.86% 99.68% 99.79% 99.75% 99.52% 99.79% 99.57% 99.66% 99.71% 99.86% 99.83% 99.84% 99.75% 99.85% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Israel Estrella Jerid Heath Jerid Heath Jose Nava Jose Nava Jose Nava Jose Nava Jose Nava Jose Nava Jerid Heath Jerid Heath Jerid Heath Jerid Heath Jerid Heath Jerid Heath Oni Ruiz Oni Ruiz Eduardo Chavez Jerid Heath Homer Trujillo Eduardo Chavez Homer Trujillo Jerid Heath Jerid Heath Homer Trujillo Homer Trujillo Carlos Martinez Jerid Heath Carlos Martinez Oni Ruiz EPA Inspection Report - Page 1002 of 1969 2018 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Jul 739.0 2-Jul 365.0 3-Jul 473.0 4-Jul 551.0 5-Jul 228.0 6-Jul 169.0 7-Jul 706.0 8-Jul 465.0 9-Jul 639.0 10-Jul 724.0 11-Jul 425.0 12-Jul 691.0 13-Jul 589.0 14-Jul 547.0 15-Jul 625.0 16-Jul 544.0 17-Jul 566.0 18-Jul 490.0 19-Jul 619.0 20-Jul 681.0 21-Jul 541.0 22-Jul 695.0 23-Jul 369.0 24-Jul 425.0 25-Jul 457.0 26-Jul 463.0 27-Jul 379.0 28-Jul 393.0 29-Jul 453.0 30-Jul 965.0 31-Jul 245.0 Old System Lead Filter Outlet 8.0 7.0 5.0 9.0 5.0 2.0 5.0 5.0 8.0 9.0 6.0 8.0 7.0 9.0 7.0 5.0 4.0 4.0 5.0 4.0 5.0 6.0 7.0 5.0 7.0 7.0 7.0 9.0 7.0 7.0 9.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 8.0 7.0 5.0 9.0 4.0 2.0 5.0 5.0 8.0 9.0 5.0 8.0 7.0 9.0 7.0 5.0 4.0 4.0 5.0 4.0 5.0 6.0 7.0 5.0 7.0 8.0 8.0 10.0 7.0 7.0 9.0 5.0 8.0 7.0 7.0 4.0 2.0 3.0 3.0 5.0 4.0 6.0 3.0 3.0 3.0 3.0 4.0 3.0 3.0 3.0 3.0 4.0 4.0 6.0 6.0 8.0 8.0 8.0 11.0 9.0 5.0 5.0 July Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 2.0 8.0 6.0 4.0 5.0 1.0 2.0 3.0 3.0 7.0 4.0 4.0 4.0 4.0 2.0 4.0 4.0 7.0 3.0 4.0 3.0 3.0 8.0 7.0 8.0 9.0 9.0 7.0 8.0 2.0 4.0 12.0 9.0 8.0 8.0 13.0 3.0 4.0 5.0 10.0 19.0 5.0 7.0 6.0 13.0 6.0 7.0 5.0 8.0 5.0 5.0 5.0 5.0 10.0 9.0 9.0 10.0 10.0 12.0 10.0 4.0 11.0 7.0 8.5 7.0 6.0 9.0 2.0 3.0 4.0 6.5 13.0 4.5 5.5 5.0 8.5 4.0 5.5 4.5 7.5 4.0 4.5 4.0 4.0 9.0 8.0 8.5 9.5 9.5 9.5 9.0 3.0 7.5 0.0 0.0 0.0 1.0 0.0 0.0 0.0 0.0 0.0 0.0 1.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.5 0.0 2.0 0.0 99.32% 97.81% 98.52% 98.73% 98.25% 98.82% 99.58% 99.35% 99.22% 99.45% 98.59% 99.57% 99.49% 99.45% 99.52% 99.26% 99.47% 99.39% 99.52% 99.56% 99.26% 99.42% 98.37% 98.59% 98.25% 98.27% 97.89% 97.20% 98.01% 99.48% 97.96% New System Lead Filter Inlet 3500.0 3765.0 2870.0 2896.0 1456.0 1055.0 1557.0 1145.0 2764.0 2136.0 2315.0 2880.0 3500.0 3500.0 2478.0 1423.0 1937.0 1368.0 1372.0 1648.0 1237.0 1472.0 3135.0 3719.0 4379.0 5679.0 5239.0 5342.0 5362.0 1532.0 2774.0 New New System System Between Lag Filter Filters Outlet 17.0 10.0 8.0 14.0 17.0 6.0 12.0 8.0 12.0 12.0 8.0 13.0 21.0 21.0 12.0 14.0 10.0 13.0 12.0 11.0 9.0 15.0 13.0 13.0 11.0 13.0 10.0 8.0 12.0 10.0 15.0 4.0 9.0 10.0 8.0 8.0 5.0 8.0 7.0 2.0 2.0 9.0 5.0 5.0 5.0 4.0 9.0 5.0 4.0 5.0 4.0 5.0 5.0 10.0 10.0 10.0 11.0 11.0 12.0 9.0 6.0 3.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 2.0 10.0 13.0 6.0 13.0 5.0 28.0 16.0 4.0 3.0 12.0 2.0 6.0 8.0 4.0 11.0 5.0 8.0 7.0 6.0 5.0 5.0 10.0 10.0 10.0 13.0 10.0 12.0 11.0 11.0 2.0 12.0 12.0 14.0 10.0 28.0 14.0 72.0 38.0 13.0 6.0 13.0 10.0 17.0 17.0 9.0 13.0 6.0 11.0 11.0 8.0 9.0 7.0 12.0 12.0 12.0 14.0 13.0 16.0 13.0 14.0 8.0 7.0 11.0 13.5 8.0 20.5 9.5 50.0 27.0 8.5 4.5 12.5 6.0 11.5 12.5 6.5 12.0 5.5 9.5 9.0 7.0 7.0 6.0 11.0 11.0 11.0 13.5 11.5 14.0 12.0 12.5 5.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 99.89% 99.76% 99.65% 99.72% 99.45% 99.53% 99.49% 99.39% 99.93% 99.91% 99.61% 99.83% 99.86% 99.86% 99.84% 99.37% 99.74% 99.71% 99.64% 99.76% 99.60% 99.66% 99.68% 99.73% 99.77% 99.81% 99.79% 99.78% 99.83% 99.61% 99.89% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Oni Ruiz Jerid Heath Jerid Heath Eduardo Chavez Carlos Martinez Carlos Martinez Carlos Martinez Carlos Martinez Oni Ruiz Oni Ruiz Jerid Heath Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Jose Nava Jose Nava Jose Nava Jose Nava Jose Nava Jose Nava Jose Nava Jerid Heath Jerid Heath Jerid Heath Jerid Heath Jerid Heath Jewel Husselman Jewel Husselman Jose Nava Oni Ruiz EPA Inspection Report - Page 1003 of 1969 2018 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Aug 415.0 2-Aug 732.0 3-Aug 445.0 4-Aug 279.0 5-Aug 683.0 6-Aug 263.0 7-Aug 436.0 8-Aug 332.0 9-Aug 427.0 10-Aug 114.0 11-Aug 186.0 12-Aug 127.0 13-Aug 397.0 14-Aug 341.0 15-Aug 396.0 16-Aug 368.0 17-Aug 77.0 18-Aug 238.0 19-Aug 278.0 20-Aug 368.0 21-Aug 312.0 22-Aug 439.0 23-Aug 373.0 24-Aug 471.0 25-Aug 567.0 26-Aug 479.0 27-Aug 673.0 28-Aug 573.0 29-Aug 111.0 30-Aug 341.0 31-Aug 387.0 NOTE: Old System Lead Filter Outlet 12.0 8.0 5.0 8.0 8.0 4.0 8.0 4.0 7.0 2.0 3.0 3.0 7.0 6.0 7.0 7.0 4.0 9.0 6.0 9.0 7.0 8.0 9.0 6.0 4.0 5.0 9.0 8.0 2.0 8.0 8.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 12.0 8.0 5.0 8.0 8.0 4.0 5.0 4.0 7.0 2.0 2.0 2.0 7.0 6.0 7.0 9.0 4.0 9.0 6.0 8.0 7.0 7.0 7.0 6.0 4.0 5.0 9.0 9.0 2.0 8.0 8.0 5.0 4.0 4.0 3.0 3.0 3.0 7.0 4.0 6.0 1.0 2.0 2.0 2.0 5.0 3.0 7.0 3.0 5.0 3.0 8.0 5.0 7.0 7.0 4.0 3.0 4.0 3.0 5.0 1.0 4.0 4.0 August Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 4.0 6.0 2.0 6.0 4.0 3.0 6.0 3.0 8.0 1.0 3.0 6.0 3.0 6.0 8.0 3.0 2.0 2.0 4.0 9.0 5.0 8.0 8.0 8.0 3.0 4.0 4.0 7.0 2.0 2.0 6.0 7.0 9.0 6.0 17.0 13.0 4.0 8.0 4.0 10.0 2.0 6.0 9.0 12.0 14.0 24.0 9.0 3.0 12.0 17.0 11.0 8.0 9.0 9.0 13.0 4.0 5.0 8.0 10.0 3.0 2.0 10.0 5.5 7.5 4.0 11.5 8.5 3.5 7.0 3.5 9.0 1.5 4.5 7.5 7.5 10.0 16.0 6.0 2.5 7.0 10.5 10.0 6.5 8.5 8.5 10.5 3.5 4.5 6.0 8.5 2.5 14.0 8.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 98.80% 99.45% 99.10% 98.92% 99.56% 98.86% 98.39% 98.80% 98.59% 99.12% 98.92% 98.43% 99.50% 98.53% 99.24% 98.10% 96.10% 97.90% 98.92% 97.83% 98.40% 98.41% 98.12% 99.15% 99.47% 99.16% 99.55% 99.13% 99.10% 98.83% 98.97% 8/8/18 ‐ Lower than normal readings due to purging of covers & lids of API sump tank. New System Lead Filter Inlet 7600.0 1681.0 3200.0 2439.0 2864.0 7873.0 3725.0 697.0 5764.0 1100.0 1213.0 2018.0 2386.0 40260.0 20600.0 6724.0 837.0 3500.0 20400.0 5624.0 12000.0 6734.0 7293.0 1136.0 1349.0 1122.0 2247.0 2176.0 1356.0 2448.0 2497.0 New New System System Between Lag Filter Filters Outlet 12.0 15.0 12.0 16.0 17.0 7.0 8.0 9.0 12.0 4.0 7.0 9.0 13.0 9.0 15.0 12.0 5.0 17.0 13.0 11.0 16.0 10.0 12.0 16.0 11.0 15.0 14.0 16.0 5.0 17.0 14.0 9.0 8.0 7.0 2.0 5.0 6.0 10.0 6.0 10.0 3.0 4.0 3.0 4.0 4.0 6.0 10.0 3.0 3.0 4.0 12.0 14.0 11.0 10.0 8.0 4.0 4.0 5.0 6.0 3.0 3.0 3.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 6.0 10.0 5.0 4.0 3.0 12.0 9.0 11.0 8.0 5.0 6.0 8.0 7.0 8.0 12.0 11.0 3.0 3.0 3.0 9.0 5.0 10.0 11.0 7.0 3.0 4.0 2.0 3.0 5.0 4.0 5.0 11.0 19.0 9.0 10.0 11.0 16.0 11.0 20.0 9.0 8.0 11.0 10.0 23.0 19.0 38.0 13.0 6.0 14.0 6.0 10.0 13.0 12.0 13.0 10.0 4.0 7.0 7.0 9.0 10.0 12.0 17.0 8.5 14.5 7.0 7.0 7.0 14.0 10.0 15.5 8.5 6.5 8.5 9.0 15.0 13.5 25.0 12.0 4.5 8.5 4.5 9.5 9.0 11.0 12.0 8.5 3.5 5.5 4.5 6.0 7.5 8.0 11.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.5 5.0 0.0 0.0 0.0 0.5 0.0 0.5 0.0 0.0 0.0 0.0 99.88% 99.52% 99.78% 99.92% 99.83% 99.92% 99.73% 99.14% 99.83% 99.73% 99.67% 99.85% 99.83% 99.99% 99.97% 99.85% 99.64% 99.91% 99.98% 99.79% 99.88% 99.84% 99.86% 99.30% 99.70% 99.64% 99.78% 99.72% 99.78% 99.88% 99.88% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Eduardo Chavez Jose Nava Eduardo Chavez Oni Ruiz Oni Ruiz Carlos Martinez Jerid Heath Carlos Martinez Jerid Heath Carlos Martinez Carlos Martinez Carlos Martinez Oni Ruiz Oni Ruiz Oni Ruiz Jerid Heath Carlos Martinez Oni Ruiz Oni Ruiz Jerid Heath Eduardo Chavez Jerid Heath Jerid Heath Jose Nava Jose Nava Jose Nava Oni Ruiz Jewel Husselman Carlos Martinez Oni Ruiz Oni Ruiz EPA Inspection Report - Page 1004 of 1969 2018 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Sep 487.0 2-Sep 681.0 3-Sep 294.0 4-Sep 374.0 5-Sep 328.0 6-Sep 119.0 7-Sep 342.0 8-Sep 297.0 9-Sep 429.0 10-Sep 210.0 11-Sep 374.0 12-Sep 297.0 13-Sep 142.0 14-Sep 136.0 15-Sep 181.0 16-Sep 155.0 17-Sep 110.0 18-Sep 315.0 19-Sep 151.0 20-Sep 343.0 21-Sep 321.0 22-Sep 342.0 23-Sep 277.0 24-Sep 669.0 25-Sep 661.0 26-Sep 66.0 27-Sep 348.0 28-Sep 160.0 29-Sep 189.0 30-Sep 732.0 Old System Lead Filter Outlet 9.0 9.0 6.0 9.0 5.0 3.0 6.0 8.0 8.0 2.0 9.0 2.0 2.0 2.0 3.0 5.0 3.0 6.0 2.0 7.0 6.0 9.0 8.0 16.0 6.0 3.0 8.0 2.0 5.0 4.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 9.0 9.0 6.0 9.0 4.0 3.0 6.0 8.0 8.0 2.0 9.0 2.0 2.0 2.0 3.0 5.0 3.0 6.0 2.0 7.0 6.0 9.0 8.0 16.0 4.0 3.0 7.0 2.0 5.0 4.0 4.0 3.0 3.0 8.0 5.0 3.0 4.0 3.0 3.0 3.0 3.0 3.0 6.0 3.0 5.0 3.0 5.0 2.0 5.0 6.0 5.0 4.0 3.0 8.0 4.0 7.0 1.0 5.0 4.0 3.0 September Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 2.0 6.0 2.0 8.0 8.0 6.0 4.0 4.0 6.0 2.0 4.0 4.0 4.0 4.0 2.0 6.0 7.0 3.0 3.0 8.0 8.0 6.0 2.0 10.0 6.0 9.0 8.0 4.0 4.0 3.0 17.0 18.0 7.0 10.0 9.0 8.0 9.0 12.0 14.0 8.0 11.0 7.0 6.0 9.0 5.0 11.0 9.0 8.0 8.0 9.0 10.0 17.0 9.0 11.0 9.0 20.0 10.0 8.0 7.0 4.0 9.5 12.0 4.5 9.0 8.5 7.0 6.5 8.0 10.0 5.0 7.5 5.5 5.0 6.5 3.5 8.5 8.0 5.5 5.5 8.5 9.0 11.5 5.5 10.5 7.5 14.5 9.0 6.0 5.5 3.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.0 0.0 1.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 99.18% 99.56% 98.98% 97.86% 98.48% 97.48% 98.83% 98.99% 99.30% 98.57% 99.20% 98.99% 95.77% 97.79% 97.24% 98.06% 95.45% 99.37% 96.69% 98.25% 98.44% 98.83% 98.92% 98.80% 99.39% 89.39% 99.71% 96.88% 97.88% 99.59% New System Lead Filter Inlet 5500.0 3398.0 4745.0 7659.0 6775.0 4380.0 4500.0 4568.0 3500.0 3500.0 4428.0 4375.0 3213.0 3516.0 3256.0 3400.0 6743.0 2211.0 3100.0 6245.0 6324.0 2478.0 3500.0 1800.0 6713.0 3113.0 6743.0 1200.0 3748.0 23000.0 New New System System Between Lag Filter Filters Outlet 16.0 17.0 13.0 11.0 11.0 2.0 14.0 13.0 15.0 12.0 16.0 6.0 3.0 3.0 5.0 13.0 10.0 16.0 5.0 10.0 10.0 12.0 15.0 7.0 7.0 5.0 11.0 5.0 5.0 11.0 5.0 3.0 5.0 12.0 12.0 3.0 6.0 4.0 5.0 3.0 4.0 4.0 5.0 4.0 7.0 6.0 12.0 5.0 7.0 11.0 8.0 2.0 4.0 7.0 6.0 3.0 10.0 8.0 7.0 9.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 2.0 4.0 3.0 10.0 9.0 6.0 6.0 2.0 4.0 5.0 5.0 6.0 7.0 7.0 9.0 5.0 10.0 4.0 6.0 9.0 10.0 3.0 6.0 9.0 8.0 5.0 11.0 46.0 4.0 26.0 10.0 14.0 11.0 11.0 11.0 8.0 12.0 10.0 17.0 10.0 17.0 10.0 11.0 11.0 12.0 13.0 11.0 13.0 13.0 11.0 12.0 9.0 18.0 10.0 13.0 7.0 13.0 112.0 12.0 67.0 6.0 9.0 7.0 10.5 10.0 7.0 9.0 6.0 10.5 7.5 11.0 8.0 9.0 9.0 10.5 9.0 10.5 8.5 9.5 10.0 11.0 6.0 9.0 9.5 10.5 6.0 12.0 79.0 8.0 46.5 0.0 0.0 0.0 1.5 2.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.5 0.0 0.0 1.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 99.91% 99.91% 99.89% 99.84% 99.82% 99.93% 99.87% 99.91% 99.86% 99.91% 99.91% 99.91% 99.84% 99.89% 99.79% 99.82% 99.82% 99.77% 99.77% 99.82% 99.87% 99.92% 99.89% 99.61% 99.91% 99.90% 99.85% 99.33% 99.81% 99.96% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Oni Ruiz Oni Ruiz Oni Ruiz Jerid Heath Jerid Heath Isaac Sanchez Eduardo Chavez Oni Ruiz Oni Ruiz Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Jerid Heath Oni Ruiz Isaac Sanchez Jerid Heath Jerid Heath Oni Ruiz Oni Ruiz Homer Trujillo Carlos Martinez Carlos Martinez Jerid Heath Isaac Sanchez Carlos Martinez Carlos Martinez EPA Inspection Report - Page 1005 of 1969 2018 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Oct 147.0 2-Oct 286.0 3-Oct 156.0 4-Oct 224.0 5-Oct 299.0 6-Oct 223.0 7-Oct 201.0 8-Oct 98.0 9-Oct 92.0 10-Oct 92.0 11-Oct 204.0 12-Oct 146.0 13-Oct 198.0 14-Oct 238.0 15-Oct 483.0 16-Oct 621.0 17-Oct 579.0 18-Oct 181.0 19-Oct 674.0 20-Oct 628.0 21-Oct 577.0 22-Oct 628.0 23-Oct 30.0 24-Oct 411.0 25-Oct 536.0 26-Oct 517.0 27-Oct 673.0 28-Oct 863.0 29-Oct 254.0 30-Oct 1024.0 31-Oct 362.0 Old System Lead Filter Outlet 2.0 4.0 4.0 8.0 6.0 2.0 3.0 9.0 8.0 7.0 6.0 2.0 7.0 9.0 8.0 5.0 6.0 6.0 4.0 4.0 5.0 5.0 7.0 7.0 7.0 8.0 7.0 7.0 4.0 9.0 6.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 6.0 4.0 4.0 8.0 6.0 2.0 3.0 9.0 8.0 7.0 6.0 2.0 7.0 9.0 8.0 5.0 6.0 6.0 4.0 4.0 5.0 5.0 7.0 7.0 6.0 7.0 7.0 6.0 4.0 9.0 6.0 2.0 2.0 3.0 4.0 2.0 3.0 5.0 3.0 4.0 2.0 5.0 5.0 3.0 3.0 6.0 4.0 3.0 4.0 3.0 3.0 3.0 6.0 3.0 6.0 8.0 7.0 4.0 1.0 8.0 8.0 4.0 OCTOBER Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 4.0 5.0 4.0 3.0 6.0 5.0 3.0 2.0 6.0 3.0 3.0 4.0 4.0 6.0 3.0 3.0 3.0 3.0 3.0 3.0 3.0 7.0 3.0 4.0 7.0 7.0 3.0 3.0 6.0 7.0 4.0 11.0 14.0 17.0 18.0 12.0 9.0 9.0 7.0 10.0 9.0 8.0 7.0 6.0 7.0 5.0 4.0 5.0 6.0 11.0 5.0 5.0 6.0 4.0 7.0 8.0 7.0 9.0 9.0 9.0 12.0 5.0 7.5 9.5 10.5 10.5 9.0 7.0 6.0 4.5 8.0 6.0 5.5 5.5 5.0 6.5 4.0 3.5 4.0 4.5 7.0 4.0 4.0 6.5 3.5 5.5 7.5 8.0 6.0 6.0 7.5 9.5 4.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 0.5 0.0 0.0 0.0 0.5 0.0 0.0 98.64% 99.30% 98.08% 98.21% 99.33% 98.65% 97.51% 96.94% 95.65% 97.83% 97.55% 96.58% 98.48% 98.74% 98.76% 99.36% 99.48% 97.79% 99.55% 99.52% 99.48% 99.04% 90.00% 98.54% 98.51% 98.65% 99.41% 99.88% 96.85% 99.22% 98.90% New System Lead Filter Inlet 1200.0 3910.0 5590.0 3500.0 2364.0 3879.0 2416.0 1764.0 2549.0 2278.0 2231.0 2011.0 2362.0 2766.0 2337.0 1638.0 2762.0 2499.0 3127.0 2488.0 1488.0 6432.0 1200.0 3212.0 6219.0 7431.0 7267.0 3217.0 4413.0 3414.0 1648.0 New New System System Between Lag Filter Filters Outlet 3.0 5.0 14.0 16.0 14.0 5.0 4.0 11.0 18.0 14.0 15.0 10.0 10.0 13.0 14.0 14.0 17.0 18.0 4.0 16.0 17.0 10.0 3.0 6.0 7.0 13.0 16.0 9.0 3.0 9.0 5.0 5.0 8.0 9.0 5.0 7.0 4.0 7.0 3.0 5.0 5.0 5.0 4.0 54.0 3.0 9.0 7.0 6.0 3.0 7.0 7.0 9.0 10.0 3.0 4.0 9.0 11.0 9.0 3.0 5.0 7.0 5.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 13.0 9.0 7.0 2.0 4.0 10.0 13.0 4.0 2.0 6.0 7.0 13.0 4.0 2.0 10.0 8.0 8.0 2.0 8.0 9.0 7.0 10.0 3.0 3.0 10.0 9.0 5.0 5.0 7.0 6.0 3.0 20.0 16.0 20.0 7.0 18.0 23.0 26.0 12.0 17.0 11.0 12.0 26.0 12.0 8.0 12.0 12.0 9.0 5.0 22.0 10.0 9.0 11.0 4.0 8.0 12.0 10.0 14.0 11.0 16.0 8.0 5.0 16.5 12.5 13.5 4.5 11.0 16.5 19.5 8.0 9.5 8.5 9.5 19.5 8.0 5.0 11.0 10.0 8.5 3.5 15.0 9.5 8.0 10.5 3.5 5.5 11.0 9.5 9.5 8.0 11.5 7.0 4.0 0.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 46.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.0 0.0 0.0 0.0 0.0 1.5 0.0 0.0 0.0 0.0 1.0 99.58% 99.80% 99.84% 99.86% 99.70% 99.90% 99.71% 99.83% 99.80% 99.78% 99.78% 99.80% 97.71% 99.89% 99.61% 99.57% 99.78% 99.88% 99.78% 99.72% 99.40% 99.84% 99.75% 99.88% 99.86% 99.85% 99.88% 99.91% 99.89% 99.79% 99.70% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Isaac Sanchez Eduardo Chavez Eduardo Chavez Oni Ruiz Oni Ruiz Isaac Sanchez Isaac Sanchez Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Isaac Sanchez Oni Ruiz Oni Ruiz Jose Nava Jose Nava Jose Nava Oni Ruiz Isaac Sanchez Jose Nava Jose Nava Jerid Heath Homer Trujillo Homer Trujillo Jerid Heath Jerid Heath Isaac Sanchez Isaac Sanchez Isaac Sanchez Homer Trujillo Jose Nava EPA Inspection Report - Page 1006 of 1969 2018 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Nov 930.0 2-Nov 837.0 3-Nov 827.0 4-Nov 4344.0 5-Nov 1312.0 6-Nov 803.0 7-Nov 1471.0 8-Nov 605.0 9-Nov 987.0 10-Nov 791.0 11-Nov 912.0 12-Nov 13-Nov 14-Nov 15-Nov 16-Nov 17-Nov 18-Nov 19-Nov 20-Nov 21-Nov 22-Nov 23-Nov 24-Nov 25-Nov 26-Nov 27-Nov 28-Nov 29-Nov 30-Nov 891.0 979.0 528.0 680.0 516.0 793.0 879.0 581.0 629.0 582.0 664.0 504.0 738.0 582.0 871.0 667.0 297.0 225.0 416.0 Old System Lead Filter Outlet 5.0 7.0 7.0 5.0 10.0 7.0 5.0 4.0 4.0 4.0 5.0 6.0 8.0 7.0 7.0 6.0 8.0 8.0 6.0 5.0 8.0 9.0 6.0 9.0 8.0 4.0 9.0 4.0 5.0 7.0 November 5.0 7.0 7.0 5.0 10.0 4.0 5.0 4.0 5.0 4.0 5.0 4.0 3.0 4.0 2.0 3.0 3.0 6.0 3.0 6.0 5.0 6.0 3.0 5.0 4.0 3.0 2.0 2.0 5.0 3.0 4.0 2.0 4.0 5.0 7.0 11.0 10.0 3.0 3.0 3.0 5.0 6.0 5.0 6.0 4.0 6.0 7.5 6.5 2.5 2.5 4.0 4.0 5.0 3.5 5.0 0.0 0.0 0.0 0.0 0.5 0.5 2.0 0.0 1.0 1.5 1.0 99.57% 99.64% 99.52% 99.95% 99.77% 99.63% 99.59% 99.50% 99.39% 99.37% 99.34% New System Lead Filter Inlet 3510.0 460.0 3711.0 4615.0 4512.0 2453.0 3243.0 2350.0 4711.0 3211.0 4112.0 6.0 7.0 8.0 6.0 6.0 8.0 8.0 6.0 5.0 8.0 9.0 6.0 9.0 8.0 4.0 9.0 3.0 6.0 7.0 4.0 5.0 8.0 8.0 4.0 4.0 5.0 4.0 2.0 5.0 3.0 3.0 6.0 3.0 3.0 3.0 5.0 2.0 5.0 2.0 2.0 7.0 4.0 3.0 4.0 9.0 4.0 4.0 7.0 4.0 2.0 3.0 4.0 8.0 4.0 3.0 3.0 5.0 4.0 3.0 9.0 5.0 6.0 6.0 16.0 8.0 9.0 11.0 7.0 9.0 5.0 6.0 10.0 8.0 3.0 8.0 9.0 3.0 2.5 8.0 4.5 4.5 5.0 12.5 6.0 6.5 9.0 5.5 5.5 4.0 5.0 9.0 6.0 3.0 5.5 7.0 1.0 2.5 0.0 3.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.0 0.0 0.0 0.0 2.0 0.0 0.0 99.55% 99.49% 98.48% 98.82% 99.22% 99.50% 99.43% 99.31% 99.68% 99.14% 99.55% 99.40% 99.19% 99.48% 99.66% 99.55% 98.32% 99.11% 98.80% 7893.0 7916.0 5284.0 6308.0 7612.0 2278.0 2169.0 7912.0 6127.0 2828.0 3436.0 2166.0 3374.0 2677.0 6371.0 6132.0 3241.0 4295.0 5020.0 Old Old System System Lag Filter Lag Filter Inlet Outlet Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 6.0 4.0 4.0 3.0 12.0 8.0 9.0 5.0 9.0 8.0 10.0 4.0 5.0 6.0 4.0 8.0 6.0 7.0 4.0 5.0 4.0 5.0 7.0 7.0 6.0 8.0 17.0 11.0 13.0 5.0 12.0 5.0 12.0 13.0 15.0 18.0 15.0 25.0 31.0 21.0 6.0 23.0 16.0 23.0 10.0 11.0 12.0 11.5 21.0 21.0 17.0 5.5 17.5 10.5 17.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 99.89% 98.91% 99.84% 99.91% 99.82% 99.76% 99.78% 99.83% 99.89% 99.88% 99.88% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 13.0 21.0 10.0 11.0 17.0 13.0 10.0 12.0 17.0 6.0 19.0 9.0 13.0 18.0 10.0 6.0 3.0 3.0 3.0 7.0 9.0 11.0 12.0 10.0 5.0 2.0 9.0 8.0 4.0 4.0 4.0 4.0 5.0 5.0 7.0 5.0 4.0 4.0 8.0 7.0 9.0 7.0 9.0 3.0 6.0 7.0 4.0 7.0 6.0 4.0 4.0 7.0 12.0 18.0 4.0 4.0 3.0 14.0 14.0 10.0 8.0 14.0 12.0 7.0 12.0 18.0 16.0 13.0 10.0 12.0 9.0 23.0 24.0 10.0 12.0 10.0 11.0 10.5 9.5 7.5 11.5 7.5 6.5 9.5 11.0 11.5 9.5 7.0 8.0 8.0 17.5 21.0 7.0 8.0 6.5 0.0 0.0 1.5 4.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 99.91% 99.89% 99.79% 99.81% 99.87% 99.78% 99.91% 99.89% 99.87% 99.86% 99.88% 99.82% 99.88% 99.81% 99.92% 99.89% 99.85% 99.91% 99.92% 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 New New System System Between Lag Filter Filters Outlet New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Carlos Martinez Carlos Martinez Carlos Martinez Carlos Martinez Carlos Martinez Carlos Martinez Carlos Martinez 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Eduardo Chavez Eduardo Chavez Jerid Heath Jerid Heath Eduardo Chavez Oni Ruiz Oni Ruiz Eduardo Chavez Jewel Husselman Homer Trujillo Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Carlos Martinez Josh Beydo Josh Beydo Josh Beydo Josh Beydo EPA Inspection Report - Page 1007 of 1969 2018 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Dec 835.0 2-Dec 630.0 3-Dec 225.0 4-Dec 467.0 5-Dec 512.0 6-Dec 548.0 7-Dec 397.0 8-Dec 468.0 9-Dec 421.0 10-Dec 463.0 11-Dec 419.0 12-Dec 426.0 13-Dec 319.0 14-Dec 321.0 15-Dec 571.0 16-Dec 643.0 17-Dec 444.0 18-Dec 418.0 19-Dec 437.0 20-Dec 451.0 21-Dec 165.0 22-Dec 323.0 23-Dec 335.0 24-Dec 523.0 25-Dec 381.0 26-Dec 246.0 27-Dec 181.0 28-Dec 215.0 29-Dec 17.0 30-Dec 203.0 31-Dec 187.0 Old System Lead Filter Outlet 6.0 9.0 10.0 5.0 5.0 5.0 5.0 5.0 4.0 6.0 4.0 4.0 5.0 6.0 9.0 7.0 8.0 6.0 9.0 6.0 7.0 6.0 5.0 11.0 12.0 9.0 7.0 10.0 11.0 9.0 8.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 6.0 9.0 11.0 5.0 5.0 5.0 5.0 5.0 4.0 6.0 4.0 4.0 5.0 6.0 9.0 7.0 8.0 6.0 9.0 5.0 7.0 6.0 5.0 13.0 12.0 8.0 7.0 10.0 10.0 6.0 8.0 3.0 4.0 5.0 3.0 4.0 4.0 4.0 4.0 3.0 5.0 6.0 6.0 4.0 5.0 3.0 2.0 2.0 9.0 3.0 5.0 4.0 2.0 3.0 11.0 6.0 4.0 4.0 8.0 5.0 5.0 4.0 December Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 2.0 3.0 3.0 3.0 4.0 4.0 3.0 3.0 3.0 4.0 6.0 6.0 6.0 5.0 5.0 2.0 4.0 9.0 4.0 7.0 3.0 4.0 4.0 4.0 3.0 4.0 4.0 2.0 3.0 3.0 3.0 4.0 10.0 13.0 5.0 5.0 5.0 4.0 4.0 5.0 6.0 7.0 5.0 8.0 7.0 7.0 4.0 9.0 11.0 7.0 12.0 6.0 6.0 7.0 11.0 9.0 9.0 11.0 9.0 7.0 9.0 6.0 3.0 6.5 8.0 4.0 4.5 4.5 3.5 3.5 4.0 5.0 6.5 5.5 7.0 6.0 6.0 3.0 6.5 10.0 5.5 9.5 4.5 5.0 5.5 7.5 6.0 6.5 7.5 5.5 5.0 6.0 4.5 0.0 0.0 0.0 0.0 0.0 0.0 0.5 0.5 0.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 3.5 0.0 0.0 0.0 2.5 0.0 0.0 0.0 99.64% 99.37% 97.78% 99.36% 99.22% 99.27% 98.99% 99.15% 99.29% 98.92% 98.57% 98.59% 98.75% 98.44% 99.47% 99.69% 99.55% 97.85% 99.31% 98.89% 97.58% 99.38% 99.10% 97.90% 98.43% 98.37% 97.79% 96.28% 70.59% 97.54% 97.86% New System Lead Filter Inlet 2633.0 4468.0 1426.0 1175.0 3566.0 1844.0 2148.0 1148.0 1139.0 3278.0 5241.0 4284.0 4263.0 4265.0 2155.0 2471.0 2353.0 3716.0 2467.0 4711.0 2400.0 2451.0 2641.0 1386.0 1113.0 2023.0 2418.0 9461.0 4210.0 4652.0 2414.0 New New System System Between Lag Filter Filters Outlet 16.0 17.0 5.0 8.0 5.0 6.0 7.0 10.0 7.0 9.0 8.0 10.0 8.0 10.0 13.0 13.0 9.0 5.0 7.0 8.0 2.0 2.0 4.0 7.0 2.0 2.0 2.0 4.0 0.0 2.0 7.0 4.0 5.0 5.0 5.0 3.0 4.0 3.0 3.0 3.0 8.0 7.0 8.0 7.0 12.0 4.0 4.0 5.0 6.0 5.0 5.0 3.0 2.0 2.0 8.0 3.0 3.0 2.0 2.0 1.0 1.0 5.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 3.0 4.0 4.0 4.0 7.0 8.0 2.0 3.0 3.0 5.0 8.0 7.0 9.0 7.0 2.0 5.0 6.0 14.0 11.0 12.0 4.0 5.0 4.0 7.0 4.0 4.0 3.0 3.0 3.0 4.0 5.0 7.0 8.0 11.0 5.0 18.0 16.0 3.0 5.0 8.0 6.0 9.0 9.0 10.0 8.0 18.0 10.0 14.0 25.0 18.0 19.0 11.0 11.0 13.0 10.0 13.0 13.0 8.0 6.0 9.0 11.0 7.0 5.0 6.0 7.5 4.5 12.5 12.0 2.5 4.0 5.5 5.5 8.5 8.0 9.5 7.5 10.0 7.5 10.0 19.5 14.5 15.5 7.5 8.0 8.5 8.5 8.5 8.5 5.5 4.5 6.0 7.5 6.0 0.0 0.0 0.0 0.5 0.0 0.0 0.5 0.0 0.0 2.5 0.0 0.0 0.0 4.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 99.85% 99.89% 99.65% 99.57% 99.92% 99.78% 99.86% 99.74% 99.74% 99.76% 99.87% 99.81% 99.84% 99.72% 99.81% 99.84% 99.79% 99.84% 99.80% 99.89% 99.88% 99.92% 99.92% 99.42% 99.73% 99.85% 99.92% 99.98% 99.98% 99.98% 99.79% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Oni Ruiz Oni Ruiz Josh Beydo Jose Nava Jose Nava Jose Nava Jose Nava Jose Nava Jose Nava Jerid Heath Jerid Heath Jerid Heath Jerid Heath Jerid Heath Oni Ruiz Oni Ruiz Isaac Sanchez Carlos Martinez Isaac Sanchez Carlos Martinez Isaac Sanchez Isaac Sanchez Isaac Sanchez Josh Beydo Josh Beydo Josh Beydo Josh Beydo Eduardo Chavez Josh Beydo Josh Beydo Isaac Sanchez EPA Inspection Report - Page 1008 of 1969 2019 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Jan 2-Jan 3-Jan 4-Jan 5-Jan 6-Jan 7-Jan 8-Jan 9-Jan 10-Jan 11-Jan 12-Jan 13-Jan 14-Jan 15-Jan 16-Jan 17-Jan 18-Jan 19-Jan 20-Jan 21-Jan 22-Jan 23-Jan 24-Jan 25-Jan 26-Jan 27-Jan 28-Jan 29-Jan 30-Jan 31-Jan 361.0 111.0 102.0 154.0 147.0 118.0 122.0 91.0 95.0 142.0 260.0 418.0 318.0 188.0 210.0 190.0 190.0 155.0 164.0 101.0 261.0 380.0 253.0 98.0 562.0 319.0 386.0 512.0 165.0 121.0 322.0 Old System Lead Filter Outlet 7.0 9.0 4.0 5.0 6.0 6.0 6.0 5.0 6.0 5.0 9.0 6.0 7.0 6.0 5.0 6.0 8.0 7.0 6.0 8.0 9.0 8.0 18.0 2.0 6.0 6.0 9.0 5.0 5.0 9.0 4.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 7.0 6.0 4.0 5.0 6.0 6.0 5.0 5.0 6.0 5.0 8.0 6.0 6.0 6.0 5.0 5.0 8.0 7.0 6.0 7.0 9.0 8.0 16.0 4.0 6.0 6.0 9.0 5.0 6.0 8.0 4.0 4.0 3.0 4.0 2.0 2.0 4.0 3.0 2.0 3.0 6.0 4.0 4.0 6.0 4.0 3.0 3.0 4.0 2.0 3.0 3.0 5.0 4.0 8.0 6.0 4.0 2.0 6.0 4.0 7.0 6.0 3.0 January Old System Background Minimum Old System Background Maximum Old System Background Average 3.0 3.0 3.0 3.0 3.0 4.0 4.0 1.0 3.0 4.0 4.0 3.0 5.0 5.0 4.0 4.0 3.0 4.0 5.0 5.0 3.0 3.0 5.0 4.0 3.0 4.0 7.0 5.0 4.0 4.0 4.0 8.0 10.0 8.0 4.0 7.0 7.0 19.0 8.0 8.0 8.0 7.0 10.0 8.0 8.0 7.0 6.0 7.0 8.0 6.0 7.0 14.0 4.0 9.0 9.0 6.0 7.0 13.0 6.0 5.0 11.0 5.0 5.5 6.5 5.5 3.5 5.0 5.5 11.5 4.5 5.5 6.0 5.5 6.5 6.5 6.5 5.5 5.0 5.0 6.0 5.5 6.0 8.5 3.5 7.0 6.5 4.5 5.5 10.0 5.5 4.5 7.5 4.5 Old System Net Reading Control Efficiency (%) New System Lead Filter Inlet 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 1.0 0.0 0.0 0.0 0.0 0.0 2.5 0.0 0.0 98.89% 97.30% 96.08% 98.70% 98.64% 96.61% 97.54% 97.80% 96.84% 95.77% 98.46% 99.04% 98.11% 97.87% 98.57% 98.42% 97.89% 98.71% 98.17% 97.03% 98.08% 98.95% 96.84% 93.88% 99.29% 99.37% 98.45% 99.22% 95.76% 95.04% 99.07% 2960.0 816.0 2537.0 6412.0 5312.0 4317.0 1431.0 2539.0 8966.0 8257.0 4671.0 37916.0 4112.0 3211.0 2515.0 3316.0 6317.0 3317.0 4610.0 6317.0 2469.0 3500.0 1700.0 6473.0 1496.0 1873.0 2658.0 1372.0 5243.0 2148.0 1395.0 New New System System Between Lag Filter Filters Outlet 11.0 1.0 1.0 2.0 2.0 3.0 5.0 2.0 2.0 5.0 3.0 6.0 7.0 3.0 3.0 2.0 3.0 3.0 3.0 2.0 17.0 15.0 4.0 3.0 12.0 14.0 18.0 14.0 12.0 5.0 11.0 2.0 2.0 3.0 3.0 4.0 5.0 4.0 3.0 3.0 3.0 3.0 4.0 6.0 4.0 5.0 4.0 6.0 4.0 5.0 7.0 4.0 4.0 3.0 3.0 6.0 5.0 4.0 9.0 11.0 7.0 5.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 2.0 2.0 2.0 2.0 3.0 4.0 7.0 3.0 4.0 5.0 5.0 7.0 8.0 6.0 5.0 4.0 5.0 5.0 6.0 8.0 6.0 6.0 5.0 2.0 5.0 6.0 10.0 5.0 13.0 6.0 6.0 7.0 9.0 6.0 6.0 8.0 12.0 11.0 9.0 10.0 11.0 11.0 12.0 12.0 10.0 7.0 9.0 11.0 6.0 10.0 11.0 10.0 9.0 9.0 10.0 9.0 8.0 19.0 6.0 15.0 13.0 9.0 4.5 5.5 4.0 4.0 5.5 8.0 9.0 6.0 7.0 8.0 8.0 9.5 10.0 8.0 6.0 6.5 8.0 5.5 8.0 9.5 8.0 7.5 7.0 6.0 7.0 7.0 14.5 5.5 14.0 9.5 7.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 3.5 0.0 0.0 0.0 99.93% 99.75% 99.88% 99.95% 99.92% 99.88% 99.72% 99.88% 99.97% 99.96% 99.94% 99.99% 99.85% 99.88% 99.80% 99.88% 99.91% 99.88% 99.89% 99.89% 99.84% 99.89% 99.82% 99.95% 99.60% 99.73% 99.85% 99.34% 99.79% 99.67% 99.64% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Oni Ruiz Josh Baydo Josh Baydo Josh Baydo Isaac Sanchez Isaac Sanchez Carlos Martinez Josh Baydo Josh Baydo Josh Baydo Isaac Sanchez Carlos Martinez Carlos Martinez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Oni Ruiz Oni Ruiz Homer Trujillo Josh Baydo Jose Nava Oni Ruiz Oni Ruiz Jose Nava Jerid Heath Josh Baydo Jose Nava EPA Inspection Report - Page 1009 of 1969 2019 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Feb 247.0 2-Feb 427.0 3-Feb 359.0 4-Feb 143.0 5-Feb 321.0 6-Feb 284.0 7-Feb 236.0 8-Feb 201.0 9-Feb 396.0 10-Feb 461.0 11-Feb 171.0 12-Feb 233.0 13-Feb 246.0 14-Feb 205.0 15-Feb 295.0 16-Feb 177.0 17-Feb 330.0 18-Feb 291.0 19-Feb 412.0 20-Feb 341.0 21-Feb 451.0 22-Feb 271.0 23-Feb 337.0 24-Feb 276.0 25-Feb 622.0 26-Feb 221.0 27-Feb 345.0 28-Feb 304.0 Old System Lead Filter Outlet 6.0 5.0 5.0 5.0 6.0 5.0 5.0 5.0 7.0 9.0 10.0 10.0 6.0 7.0 11.0 9.0 12.0 8.0 4.0 5.0 5.0 5.0 9.0 6.0 4.0 4.0 14.0 12.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 6.0 5.0 5.0 5.0 6.0 5.0 5.0 5.0 7.0 9.0 10.0 10.0 6.0 7.0 10.0 9.0 12.0 7.0 4.0 4.0 6.0 4.0 9.0 6.0 4.0 4.0 14.0 12.0 4.0 4.0 3.0 6.0 7.0 7.0 7.0 2.0 3.0 6.0 3.0 4.0 5.0 3.0 6.0 2.0 2.0 4.0 3.0 4.0 6.0 4.0 4.0 4.0 5.0 3.0 7.0 13.0 February Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 3.0 3.0 2.0 6.0 6.0 6.0 6.0 3.0 5.0 3.0 3.0 4.0 5.0 3.0 4.0 3.0 3.0 4.0 3.0 4.0 4.0 3.0 5.0 2.0 4.0 7.0 4.0 14.0 4.0 4.0 4.0 8.0 7.0 7.0 7.0 5.0 18.0 27.0 5.0 9.0 7.0 5.0 13.0 9.0 9.0 8.0 5.0 10.0 7.0 6.0 13.0 7.0 8.0 10.0 17.0 19.0 3.5 3.5 3.0 7.0 6.5 6.5 6.5 4.0 11.5 15.0 4.0 6.5 6.0 4.0 8.5 6.0 6.0 6.0 4.0 7.0 5.5 4.5 9.0 4.5 6.0 8.5 10.5 16.5 0.5 0.5 0.0 0.0 0.5 0.5 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 98.38% 99.06% 99.16% 95.80% 97.82% 97.54% 97.03% 99.00% 99.24% 98.70% 98.25% 98.28% 97.97% 98.54% 97.97% 98.87% 99.39% 98.63% 99.27% 98.83% 98.67% 98.52% 98.81% 98.55% 99.20% 98.64% 97.97% 95.72% New System Lead Filter Inlet 1169.0 1782.0 1168.0 3219.0 2464.0 3243.0 2393.0 4316.0 3781.0 2650.0 3519.0 4616.0 5219.0 3317.0 2671.0 2331.0 2651.0 3411.0 1258.0 2378.0 3246.0 3220.0 3960.0 2871.0 7090.0 4371.0 4637.0 3511.0 New New System System Between Lag Filter Filters Outlet 15.0 12.0 14.0 11.0 11.0 11.0 13.0 3.0 19.0 10.0 6.0 7.0 8.0 4.0 6.0 17.0 11.0 9.0 14.0 15.0 12.0 14.0 17.0 18.0 12.0 9.0 8.0 7.0 6.0 6.0 5.0 10.0 9.0 10.0 11.0 5.0 5.0 4.0 7.0 8.0 6.0 3.0 5.0 5.0 4.0 5.0 7.0 7.0 5.0 6.0 3.0 5.0 7.0 5.0 8.0 10.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 7.0 5.0 9.0 10.0 9.0 10.0 10.0 4.0 6.0 2.0 10.0 10.0 10.0 5.0 7.0 6.0 4.0 7.0 7.0 12.0 7.0 8.0 7.0 3.0 6.0 9.0 13.0 11.0 10.0 9.0 13.0 12.0 10.0 11.0 12.0 13.0 15.0 12.0 16.0 17.0 13.0 13.0 17.0 20.0 15.0 12.0 10.0 18.0 16.0 16.0 19.0 34.0 10.0 17.0 20.0 21.0 8.5 7.0 11.0 11.0 9.5 10.5 11.0 8.5 10.5 7.0 13.0 13.5 11.5 9.0 12.0 13.0 9.5 9.5 8.5 15.0 11.5 12.0 13.0 18.5 8.0 13.0 16.5 16.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 99.49% 99.66% 99.57% 99.69% 99.63% 99.69% 99.54% 99.88% 99.87% 99.85% 99.80% 99.83% 99.89% 99.91% 99.81% 99.79% 99.85% 99.85% 99.44% 99.71% 99.85% 99.81% 99.92% 99.83% 99.90% 99.89% 99.83% 99.72% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Jose Nava Jose Nava Jose Nava Jerid Heath Jerid Heath Jerid Heath Jerid Heath Isaac Sanchez Oni Ruiz Oni Ruiz Oni Ruiz Isaac Sanchez Jerid Heath Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Carlos Martinez Jose Nava Carlos Martinez Carlos Martinez Carlos Martinez Oni Ruiz Oni Ruiz Eduardo Chavez Carlos Martinez Carlos Martinez Isaac Sanchez EPA Inspection Report - Page 1010 of 1969 2019 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Mar 154.0 2-Mar 189.0 3-Mar 253.0 4-Mar 179.0 5-Mar 140.0 6-Mar 450.0 7-Mar 342.0 8-Mar 276.0 9-Mar 394.0 10-Mar 274.0 11-Mar 99.0 12-Mar 122.0 13-Mar 379.0 14-Mar 379.0 15-Mar 150.0 16-Mar 171.0 17-Mar 137.0 18-Mar 361.0 19-Mar 101.0 20-Mar 92.0 21-Mar 233.0 22-Mar 141.0 23-Mar 64.0 24-Mar 147.0 25-Mar 171.0 26-Mar 362.0 27-Mar 217.0 28-Mar 241.0 29-Mar 210.0 30-Mar 261.0 31-Mar 311.0 Old System Lead Filter Outlet 11.0 10.0 15.0 9.0 10.0 6.0 7.0 11.0 6.0 9.0 6.0 7.0 8.0 8.0 5.0 5.0 6.0 7.0 4.0 5.0 10.0 6.0 4.0 10.0 7.0 5.0 5.0 6.0 12.0 7.0 8.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 11.0 10.0 15.0 9.0 10.0 9.0 7.0 10.0 6.0 9.0 5.0 6.0 8.0 8.0 5.0 5.0 6.0 7.0 4.0 5.0 10.0 6.0 4.0 10.0 7.0 5.0 5.0 6.0 7.0 7.0 8.0 4.0 2.0 6.0 5.0 7.0 7.0 6.0 6.0 5.0 3.0 4.0 5.0 4.0 4.0 3.0 4.0 4.0 2.0 3.0 3.0 4.0 4.0 2.0 4.0 3.0 3.0 4.0 3.0 7.0 5.0 4.0 March Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 3.0 3.0 10.0 3.0 5.0 5.0 6.0 2.0 6.0 2.0 3.0 4.0 6.0 6.0 3.0 4.0 5.0 2.0 2.0 2.0 3.0 2.0 2.0 3.0 5.0 4.0 2.0 3.0 7.0 2.0 9.0 7.0 6.0 17.0 11.0 11.0 12.0 8.0 3.0 7.0 14.0 9.0 7.0 27.0 27.0 4.0 9.0 11.0 7.0 5.0 3.0 7.0 7.0 3.0 7.0 9.0 6.0 4.0 5.0 13.0 6.0 17.0 5.0 4.5 13.5 7.0 8.0 8.5 7.0 2.5 6.5 8.0 6.0 5.5 16.5 16.5 3.5 6.5 8.0 4.5 3.5 2.5 5.0 4.5 4.0 5.0 7.0 4.0 3.0 4.0 10.0 4.0 13.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 3.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.0 0.0 1.0 0.0 0.0 1.0 0.0 97.40% 98.94% 97.63% 97.21% 95.00% 98.44% 98.25% 97.83% 98.73% 98.91% 95.96% 95.90% 98.94% 98.94% 98.00% 97.66% 97.08% 99.45% 97.03% 96.74% 98.28% 97.16% 96.88% 97.28% 98.25% 99.17% 98.16% 98.76% 96.67% 98.08% 98.71% New System Lead Filter Inlet 2569.0 6314.0 6123.0 20100.0 9184.0 9365.0 7234.0 3246.0 3479.0 3500.0 3124.0 6327.0 2868.0 2868.0 8658.0 3678.0 3361.0 3317.0 4371.0 2719.0 4671.0 1799.0 3213.0 3310.0 2749.0 6941.0 2043.0 2093.0 7132.0 2287.0 2463.0 New New System System Between Lag Filter Filters Outlet 10.0 11.0 19.0 5.0 5.0 6.0 11.0 5.0 13.0 15.0 2.0 4.0 13.0 13.0 4.0 6.0 7.0 14.0 7.0 8.0 11.0 9.0 8.0 13.0 3.0 11.0 10.0 10.0 3.0 18.0 14.0 3.0 7.0 5.0 4.0 5.0 7.0 10.0 5.0 4.0 3.0 4.0 5.0 5.0 5.0 3.0 4.0 4.0 8.0 3.0 5.0 6.0 4.0 3.0 8.0 4.0 8.0 7.0 7.0 5.0 4.0 3.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 6.0 3.0 13.0 6.0 6.0 4.0 9.0 9.0 3.0 3.0 4.0 5.0 9.0 9.0 4.0 8.0 8.0 5.0 2.0 7.0 6.0 6.0 4.0 7.0 6.0 8.0 6.0 8.0 8.0 4.0 5.0 13.0 13.0 24.0 14.0 12.0 14.0 11.0 17.0 9.0 19.0 11.0 11.0 12.0 12.0 5.0 13.0 14.0 11.0 10.0 16.0 13.0 19.0 6.0 19.0 13.0 10.0 9.0 12.0 11.0 6.0 12.0 9.5 8.0 18.5 10.0 9.0 9.0 10.0 13.0 6.0 11.0 7.5 8.0 10.5 10.5 4.5 10.5 11.0 8.0 6.0 11.5 9.5 12.5 5.0 13.0 9.5 9.0 7.5 10.0 9.5 5.0 8.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 99.88% 99.89% 99.92% 99.98% 99.95% 99.93% 99.86% 99.85% 99.89% 99.91% 99.87% 99.92% 99.83% 99.83% 99.97% 99.89% 99.88% 99.76% 99.93% 99.82% 99.87% 99.78% 99.91% 99.76% 99.85% 99.88% 99.66% 99.67% 99.93% 99.83% 99.88% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Isaac Sanchez Isaac Sanchez Isaac Sanchez Josh Baydo Josh Baydo Josh Baydo Jerid Heath Carlos Martinez Oni Ruiz Oni Ruiz Josh Baydo Josh Baydo Oni Ruiz Oni Ruiz Carlos Martinez Carlos Martinez Carlos Martinez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Josh Baydo Eduardo Chavez Eduardo Chavez Eduardo Chavez Josh Baydo Oni Ruiz Oni Ruiz EPA Inspection Report - Page 1011 of 1969 2019 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Apr 419.0 2-Apr 115.0 3-Apr 121.0 4-Apr 422.0 5-Apr 349.0 6-Apr 412.0 7-Apr 527.0 8-Apr 563.0 9-Apr 400.0 10-Apr 423.0 11-Apr 295.0 12-Apr 271.0 13-Apr 350.0 14-Apr 337.0 15-Apr 249.0 16-Apr 401.0 17-Apr 241.0 18-Apr 167.0 19-Apr 172.0 20-Apr 247.0 21-Apr 265.0 22-Apr 267.0 23-Apr 329.0 24-Apr 162.0 25-Apr 356.0 26-Apr 257.0 27-Apr 121.0 28-Apr 214.0 29-Apr 340.0 30-Apr 335.0 Old System Lead Filter Outlet 10.0 5.0 8.0 8.0 4.0 5.0 4.0 8.0 10.0 9.0 8.0 7.0 4.0 9.0 6.0 3.0 5.0 4.0 5.0 9.0 8.0 6.0 5.0 8.0 6.0 5.0 7.0 7.0 10.0 8.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 6.0 5.0 8.0 8.0 4.0 4.0 4.0 8.0 10.0 9.0 8.0 7.0 4.0 9.0 6.0 3.0 5.0 4.0 5.0 9.0 8.0 6.0 5.0 8.0 6.0 5.0 7.0 7.0 10.0 7.0 10.0 2.0 6.0 6.0 3.0 3.0 4.0 5.0 6.0 3.0 4.0 4.0 2.0 5.0 4.0 1.0 3.0 2.0 8.0 5.0 4.0 4.0 7.0 6.0 4.0 6.0 5.0 3.0 6.0 5.0 April Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 5.0 2.0 2.0 5.0 9.0 3.0 4.0 4.0 4.0 3.0 4.0 3.0 3.0 3.0 4.0 2.0 3.0 2.0 9.0 7.0 3.0 5.0 7.0 4.0 4.0 5.0 4.0 4.0 2.0 3.0 13.0 4.0 7.0 10.0 11.0 5.0 6.0 11.0 8.0 8.0 9.0 9.0 7.0 10.0 5.0 6.0 5.0 7.0 25.0 18.0 16.0 9.0 9.0 7.0 10.0 6.0 8.0 12.0 8.0 7.0 9.0 3.0 4.5 7.5 10.0 4.0 5.0 7.5 6.0 5.5 6.5 6.0 5.0 6.5 4.5 4.0 4.0 4.5 17.0 12.5 9.5 7.0 8.0 5.5 7.0 5.5 6.0 8.0 5.0 5.0 1.0 0.0 1.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 0.0 0.5 0.0 0.0 1.0 0.0 97.61% 98.26% 95.04% 98.58% 99.14% 99.27% 99.24% 99.11% 98.50% 99.29% 98.64% 98.52% 99.43% 98.52% 98.39% 99.75% 98.76% 98.80% 95.35% 97.98% 98.49% 98.50% 97.87% 96.30% 98.88% 97.67% 95.87% 98.60% 98.24% 98.51% New System Lead Filter Inlet 2722.0 2314.0 2139.0 5132.0 1478.0 4687.0 2346.0 15500.0 1748.0 5138.0 10000.0 7320.0 5320.0 4341.0 6981.0 8600.0 3314.0 4716.0 8114.0 9942.0 8963.0 5243.0 4289.0 6640.0 4766.0 3386.0 4728.0 8661.0 732.0 8433.0 New New System System Between Lag Filter Filters Outlet 2.0 2.0 4.0 6.0 15.0 17.0 15.0 4.0 7.0 7.0 5.0 6.0 7.0 7.0 12.0 15.0 11.0 16.0 23.0 34.0 21.0 10.0 12.0 11.0 5.0 10.0 14.0 19.0 7.0 6.0 5.0 5.0 5.0 5.0 7.0 8.0 8.0 4.0 6.0 7.0 5.0 6.0 6.0 6.0 8.0 9.0 8.0 10.0 17.0 11.0 7.0 7.0 11.0 9.0 5.0 12.0 11.0 14.0 5.0 10.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 4.0 5.0 7.0 6.0 6.0 8.0 9.0 3.0 5.0 4.0 3.0 4.0 4.0 7.0 8.0 5.0 5.0 5.0 14.0 13.0 19.0 9.0 9.0 9.0 3.0 9.0 10.0 8.0 5.0 6.0 12.0 8.0 13.0 12.0 9.0 9.0 10.0 12.0 13.0 12.0 11.0 11.0 11.0 19.0 10.0 9.0 11.0 13.0 31.0 26.0 24.0 11.0 10.0 13.0 11.0 11.0 16.0 15.0 11.0 8.0 8.0 6.5 10.0 9.0 7.5 8.5 9.5 7.5 9.0 8.0 7.0 7.5 7.5 13.0 9.0 7.0 8.0 9.0 22.5 19.5 21.5 10.0 9.5 11.0 7.0 10.0 13.0 11.5 8.0 7.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.0 0.0 1.0 0.0 0.0 0.0 0.0 1.5 0.0 0.0 2.0 0.0 2.5 0.0 3.0 99.82% 99.78% 99.77% 99.90% 99.53% 99.83% 99.66% 99.97% 99.66% 99.86% 99.95% 99.92% 99.89% 99.86% 99.89% 99.90% 99.76% 99.79% 99.79% 99.89% 99.92% 99.87% 99.74% 99.86% 99.90% 99.65% 99.77% 99.84% 99.32% 99.88% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Josh Baydo Isaac Sanchez Isaac Sanchez Josh Baydo Jose Nava Jose Nava Jose Nava Josh Baydo Marcus Morris Josh Baydo Josh Baydo Josh Baydo Isaac Sanchez Isaac Sanchez Eduardo Chavez Eduardo Chavez Isaac Sanchez Eduardo Chavez Eduardo Chavez Oni Ruiz Oni Ruiz Jerid Heath Jerid Heath Eduardo Chavez Josh Baydo Jerid Heath Eduardo Chavez Eduardo Chavez Marcus Morris Marcus Morris EPA Inspection Report - Page 1012 of 1969 2019 API Carbon Canister Monitoring for Month: Old System Lead Monitoring Date Filter Inlet 1-May 394.0 2-May 169.0 3-May 413.0 4-May 261.0 5-May 385.0 6-May 181.0 7-May 70.0 8-May 236.0 9-May 298.0 10-May 212.0 11-May 391.0 12-May 284.0 13-May 341.0 14-May 157.0 15-May 203.0 16-May 328.0 17-May 332.0 18-May 281.0 19-May 298.0 20-May 211.0 21-May 346.0 22-May 177.0 23-May 214.0 24-May 208.0 25-May 198.0 26-May 168.0 27-May 493.0 28-May 542.0 29-May 290.0 30-May 385.0 31-May 247.0 Old System Lead Filter Outlet 9.0 5.0 11.0 8.0 9.0 6.0 9.0 8.0 10.0 7.0 9.0 7.0 6.0 4.0 3.0 6.0 6.0 5.0 9.0 7.0 7.0 9.0 8.0 6.0 8.0 6.0 10.0 6.0 14.0 7.0 13.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 5.0 5.0 10.0 8.0 9.0 6.0 9.0 8.0 10.0 7.0 9.0 7.0 6.0 4.0 3.0 6.0 7.0 5.0 9.0 7.0 7.0 9.0 8.0 6.0 8.0 6.0 10.0 5.0 13.0 7.0 13.0 10.0 3.0 6.0 4.0 6.0 4.0 3.0 3.0 3.0 3.0 6.0 5.0 5.0 6.0 5.0 5.0 6.0 6.0 5.0 4.0 6.0 6.0 5.0 4.0 5.0 4.0 5.0 8.0 8.0 4.0 5.0 May Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 3.0 2.0 7.0 3.0 7.0 4.0 2.0 3.0 2.0 2.0 8.0 3.0 8.0 7.0 5.0 6.0 5.0 4.0 6.0 4.0 4.0 3.0 2.0 5.0 3.0 3.0 3.0 4.0 15.0 4.0 2.0 7.0 8.0 9.0 14.0 10.0 6.0 7.0 9.0 8.0 7.0 25.0 14.0 14.0 9.0 7.0 10.0 9.0 7.0 23.0 6.0 12.0 7.0 7.0 7.0 6.0 9.0 7.0 11.0 165.0 12.0 7.0 5.0 5.0 8.0 8.5 8.5 5.0 4.5 6.0 5.0 9.8 16.5 8.5 11.0 8.0 6.0 8.0 7.0 5.5 14.5 5.0 8.0 5.0 4.5 6.0 4.5 6.0 5.0 7.5 90.0 8.0 4.5 5.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 0.0 0.0 0.0 1.0 0.5 0.0 0.5 0.0 0.0 0.5 0.0 0.0 0.5 97.46% 98.22% 98.55% 98.47% 98.44% 97.79% 95.71% 98.73% 98.99% 98.58% 98.47% 98.24% 98.53% 96.18% 97.54% 98.48% 98.19% 97.86% 98.32% 98.10% 98.27% 96.61% 97.66% 98.08% 97.47% 97.62% 98.99% 98.52% 97.24% 98.96% 97.98% New System Lead Filter Inlet 8495.0 5876.0 8116.0 3659.0 4341.0 5682.0 3126.0 3120.0 3516.0 3014.0 4687.0 2571.0 3671.0 1781.0 2361.0 3211.0 4327.0 3211.0 3877.0 4619.0 3648.0 5699.0 4512.0 3410.0 4368.0 3481.0 3616.0 6492.0 4378.0 4905.0 3027.0 New New System System Between Lag Filter Filters Outlet 5.0 17.0 7.0 17.0 15.0 16.0 5.0 6.0 5.0 4.0 23.0 16.0 8.0 5.0 7.0 7.0 5.0 7.0 16.0 8.0 10.0 15.0 11.0 14.0 9.0 15.0 9.0 4.0 13.0 5.0 5.0 4.0 12.0 5.0 5.0 3.0 10.0 5.0 5.0 5.0 4.0 7.0 4.0 6.0 4.0 5.0 5.0 4.0 5.0 3.0 4.0 6.0 12.0 8.0 11.0 6.0 10.0 9.0 4.0 10.0 7.0 5.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 4.0 10.0 6.0 6.0 10.0 5.0 6.0 3.0 4.0 6.0 10.0 3.0 10.0 8.0 9.0 8.0 5.0 8.0 10.0 6.0 8.0 7.0 9.0 6.0 7.0 7.0 5.0 5.0 10.0 5.0 11.0 9.0 17.0 8.0 19.0 19.0 8.0 16.0 21.0 18.0 13.0 21.0 10.0 19.0 21.0 17.0 15.0 12.0 15.0 13.0 12.0 15.0 14.0 12.0 16.0 12.0 14.0 13.0 13.0 11.0 14.0 19.0 6.5 13.5 7.0 12.5 14.5 6.5 11.0 12.0 11.0 9.5 15.5 6.5 14.5 14.5 13.0 11.5 8.5 11.5 11.5 9.0 11.5 10.5 10.5 11.0 9.5 10.5 9.0 9.0 10.5 9.5 15.0 0.0 0.0 0.0 0.0 0.0 3.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 99.95% 99.80% 99.94% 99.86% 99.93% 99.82% 99.84% 99.84% 99.86% 99.87% 99.85% 99.84% 99.84% 99.78% 99.79% 99.84% 99.91% 99.84% 99.92% 99.91% 99.84% 99.79% 99.82% 99.68% 99.86% 99.71% 99.75% 99.94% 99.77% 99.86% 99.83% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Marcus Morris Eduardo Chavez Marcus Morris Oni Ruiz Oni Ruiz Eduardo Chavez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Oni Ruiz Oni Ruiz Carlos Martinez Carlos Martinez Carlos Martinez Marcus Morris Marcus Morris Carlos Martinez Oni Ruiz Eduardo Chavez Eduardo Chavez Eduardo Chavez Eduardo Chavez Eduardo Chavez Eduardo Chavez Eduardo Chavez Isaac Sanchez Josh Baydo Marcus Morris Josh Baydo Isaac Sanchez EPA Inspection Report - Page 1013 of 1969 2019 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Jun 315.0 2-Jun 234.0 3-Jun 201.0 4-Jun 366.0 5-Jun 274.0 6-Jun 384.0 7-Jun 388.0 8-Jun 231.0 9-Jun 291.0 10-Jun 329.0 11-Jun 349.0 12-Jun 426.0 13-Jun 439.0 14-Jun 328.0 15-Jun 717.0 16-Jun 412.0 17-Jun 300.0 18-Jun 201.0 19-Jun 199.0 20-Jun 379.0 21-Jun 189.0 22-Jun 416.0 23-Jun 560.0 24-Jun 184.0 25-Jun 318.0 26-Jun 411.0 27-Jun 432.0 28-Jun 518.0 29-Jun 396.0 30-Jun 281.0 Old System Lead Filter Outlet 9.0 11.0 4.0 7.0 8.0 9.0 9.0 8.0 5.0 6.0 7.0 5.0 7.0 8.0 4.0 6.0 7.0 7.0 9.0 8.0 11.0 12.0 14.0 6.0 5.0 8.0 6.0 4.0 9.0 7.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 9.0 11.0 4.0 7.0 8.0 9.0 9.0 8.0 5.0 6.0 7.0 5.0 7.0 8.0 4.0 6.0 7.0 7.0 9.0 8.0 11.0 12.0 14.0 6.0 5.0 8.0 6.0 4.0 9.0 7.0 3.0 3.0 3.0 4.0 3.0 4.0 3.0 4.0 4.0 5.0 6.0 7.0 9.0 1.0 2.0 4.0 3.0 3.0 3.0 3.0 4.0 3.0 4.0 4.0 6.0 3.0 5.0 3.0 4.0 4.0 June Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 2.0 3.0 3.0 4.0 6.0 2.0 2.0 3.0 6.0 5.0 5.0 6.0 8.0 7.0 4.0 7.0 2.0 2.0 4.0 3.0 2.0 4.0 6.0 4.0 4.0 6.0 2.0 3.0 6.0 3.0 7.0 11.0 9.0 10.0 7.0 4.0 6.0 5.0 12.0 7.0 7.0 8.0 10.0 9.0 7.0 12.0 7.0 7.0 6.0 7.0 6.0 11.0 12.0 10.0 10.0 11.0 8.0 10.0 18.0 8.0 4.5 7.0 6.0 7.0 6.5 3.0 4.0 4.0 9.0 6.0 6.0 7.0 9.0 8.0 5.5 9.5 4.5 4.5 5.0 5.0 4.0 7.5 9.0 7.0 7.0 8.5 5.0 6.5 12.0 5.5 0.0 0.0 0.0 0.0 0.0 1.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 99.05% 98.72% 98.51% 98.91% 98.91% 98.96% 99.23% 98.27% 98.63% 98.48% 98.28% 98.36% 97.95% 99.70% 99.72% 99.03% 99.00% 98.51% 98.49% 99.21% 97.88% 99.28% 99.29% 97.83% 98.11% 99.27% 98.84% 99.42% 98.99% 98.58% New System Lead Filter Inlet 3316.0 2141.0 5342.0 5329.0 2751.0 3311.0 3891.0 2219.0 4781.0 5287.0 3433.0 4289.0 6749.0 4306.0 4378.0 4356.0 3117.0 2132.0 2117.0 2617.0 2014.0 3714.0 3416.0 3680.0 5362.0 6429.0 7612.0 3512.0 3261.0 2469.0 New New System System Between Lag Filter Filters Outlet 4.0 7.0 6.0 8.0 11.0 19.0 22.0 13.0 7.0 11.0 11.0 10.0 12.0 10.0 7.0 8.0 7.0 5.0 4.0 4.0 5.0 16.0 6.0 17.0 4.0 9.0 4.0 3.0 18.0 17.0 4.0 7.0 6.0 5.0 5.0 5.0 7.0 4.0 4.0 10.0 9.0 8.0 10.0 9.0 4.0 4.0 4.0 5.0 4.0 5.0 6.0 9.0 5.0 11.0 4.0 6.0 4.0 3.0 5.0 3.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 5.0 5.0 4.0 7.0 10.0 7.0 9.0 7.0 8.0 8.0 8.0 9.0 10.0 10.0 8.0 9.0 5.0 4.0 7.0 6.0 2.0 8.0 14.0 6.0 5.0 8.0 3.0 3.0 7.0 6.0 13.0 16.0 11.0 14.0 18.0 10.0 24.0 10.0 19.0 9.0 9.0 11.0 13.0 11.0 19.0 17.0 13.0 17.0 14.0 14.0 14.0 19.0 19.0 18.0 13.0 13.0 10.0 13.0 14.0 9.0 9.0 10.5 7.5 10.5 14.0 8.5 16.5 8.5 13.5 8.5 8.5 10.0 11.5 10.5 13.5 13.0 9.0 10.5 10.5 10.0 8.0 13.5 16.5 12.0 9.0 10.5 6.5 8.0 10.5 7.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.5 0.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 99.88% 99.67% 99.89% 99.91% 99.82% 99.85% 99.82% 99.82% 99.92% 99.81% 99.74% 99.81% 99.85% 99.79% 99.91% 99.91% 99.87% 99.77% 99.81% 99.81% 99.70% 99.76% 99.85% 99.70% 99.93% 99.91% 99.95% 99.91% 99.85% 99.88% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Isaac Sanchez Isaac Sanchez Josh Baydo Marcus Morris Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Carlos Martinez Jerid Heath Jerid Heath Jerid Heath Jerid Heath Jerid Heath Carlos Martinez Carlos Martinez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Isaac Sanchez Eduardo Chavez Josh Baydo Marcus Morris Josh Baydo Josh Baydo Oni Ruiz Oni Ruiz EPA Inspection Report - Page 1014 of 1969 2019 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Jul 420.0 2-Jul 387.0 3-Jul 342.0 4-Jul 276.0 5-Jul 345.0 6-Jul 377.0 7-Jul 291.0 8-Jul 342.0 9-Jul 422.0 10-Jul 487.0 11-Jul 424.0 12-Jul 241.0 13-Jul 316.0 14-Jul 562.0 15-Jul 310.0 16-Jul 274.0 17-Jul 321.0 18-Jul 19-Jul 216.0 20-Jul 388.0 21-Jul 469.0 22-Jul 192.0 23-Jul 203.0 24-Jul 312.0 25-Jul 198.0 26-Jul 203.0 27-Jul 201.0 28-Jul 233.0 29-Jul 274.0 30-Jul 293.0 31-Jul 261.0 Old System Lead Filter Outlet 7.0 8.0 8.0 8.0 6.0 9.0 7.0 8.0 7.0 5.0 4.0 4.0 10.0 8.0 8.0 9.0 4.0 5.0 8.0 10.0 6.0 6.0 6.0 5.0 6.0 4.0 5.0 8.0 6.0 7.0 Old Old System System Lag Filter Lag Filter Inlet Outlet July Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading 6.5 9.5 8.0 4.5 7.5 17.0 4.5 8.5 8.0 7.0 5.5 5.5 7.0 7.0 7.0 4.5 6.5 No Data 5.5 6.5 23.0 7.5 5.5 7.5 5.0 6.0 6.5 4.0 7.5 5.5 4.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 No Data 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 7.0 9.0 9.0 8.0 6.0 9.0 7.0 7.0 7.0 5.0 4.0 4.0 10.0 8.0 8.0 9.0 4.0 4.0 5.0 5.0 4.0 4.0 5.0 4.0 5.0 8.0 6.0 3.0 5.0 4.0 6.0 5.0 3.0 5.0 2.0 6.0 4.0 2.0 4.0 8.0 3.0 5.0 5.0 3.0 2.0 3.0 3.0 5.0 4.0 3.0 3.0 11.0 13.0 12.0 7.0 11.0 26.0 6.0 12.0 11.0 11.0 9.0 8.0 11.0 9.0 10.0 6.0 10.0 5.0 8.0 10.0 6.0 6.0 7.0 5.0 6.0 4.0 5.0 8.0 6.0 7.0 3.0 4.0 8.0 4.0 5.0 5.0 4.0 6.0 3.0 4.0 3.0 5.0 4.0 3.0 6.0 14.0 3.0 4.0 6.0 4.0 4.0 4.0 3.0 6.0 4.0 2.0 8.0 7.0 32.0 12.0 7.0 9.0 6.0 8.0 9.0 5.0 9.0 7.0 7.0 18‐Jul Plant was down due to power outage.  Units were not giving permits for the day. 99.05% 98.71% 98.54% 98.55% 98.84% 98.67% 98.63% 98.54% 98.10% 98.77% 99.29% 97.93% 98.73% 98.93% 98.39% 98.91% 98.44% New System Lead Filter Inlet 5121.0 6482.0 7843.0 2654.0 4920.0 3376.0 2618.0 5328.0 5331.0 6138.0 5123.0 5124.0 3617.0 3714.0 2771.0 2891.0 6941.0 98.61% 98.97% 98.29% 97.92% 97.54% 98.40% 97.98% 97.04% 98.51% 98.28% 98.91% 98.29% 98.47% 3650.0 3744.0 4955.0 1653.0 2365.0 2763.0 3311.0 2789.0 2789.0 2781.0 2861.0 2789.0 3114.0 Control Efficiency (%) New New System System Between Lag Filter Filters Outlet New System Background Minimum New System Background Maximum New System Background Average New System Net Reading 31.0 11.5 12.5 9.5 7.5 5.5 13.0 10.0 9.5 8.0 7.0 8.5 11.0 18.0 12.0 9.5 8.5 No Data 9.0 19.0 31.0 6.5 10.5 13.5 8.5 10.0 9.5 8.5 10.0 8.5 6.5 0.0 0.0 0.0 45.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 No Data 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.5 11.0 10.0 9.0 11.0 5.0 13.0 11.0 7.0 5.0 6.0 5.0 6.0 4.0 8.0 18.0 16.0 5.0 10.0 6.0 6.0 55.0 4.0 3.0 6.0 4.0 4.0 6.0 5.0 6.0 4.0 8.0 4.0 4.0 5.0 22.0 8.0 9.0 5.0 3.0 4.0 10.0 7.0 7.0 4.0 3.0 4.0 3.0 14.0 10.0 7.0 4.0 40.0 15.0 16.0 14.0 12.0 7.0 16.0 13.0 12.0 12.0 11.0 13.0 19.0 22.0 14.0 12.0 13.0 12.0 18.0 27.0 7.0 8.0 8.0 10.0 10.0 7.0 9.0 22.0 9.0 16.0 9.0 5.0 6.0 5.0 4.0 5.0 7.0 5.0 5.0 5.0 5.0 7.0 7.0 6.0 12.0 23.0 5.0 8.0 12.0 7.0 7.0 7.0 7.0 7.0 7.0 5.0 12.0 26.0 39.0 8.0 13.0 15.0 10.0 13.0 12.0 10.0 13.0 10.0 8.0 Control Efficiency (%) 99.80% 99.91% 99.92% 97.93% 99.92% 99.91% 99.77% 99.92% 99.92% 99.90% 99.90% 99.88% 99.89% 99.78% 99.86% 99.86% 99.93% 99.75% 99.87% 99.88% 99.70% 99.83% 99.82% 99.79% 99.82% 99.82% 99.82% 99.83% 99.75% 99.78% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Monitoring Technician Name Isaac Sanchez Marcus Morris Marcus Morris Oni Ruiz Josh Baydo Oni Ruiz Oni Ruiz Marcus Morris Marcus Morris Josh Baydo Josh Baydo Josh Baydo Isaac Sanchez Isaac Sanchez Oni Ruiz Oni Ruiz Marcus Morris Eduardo Chavez Oni Ruiz Oni Ruiz Carlos Martinez Carlos Martinez Carlos Martinez Carlos Martinez Carlos Martinez Carlos Martinez Carlos Martinez Oni Ruiz Carlos Martinez Eduardo Chavez EPA Inspection Report - Page 1015 of 1969 2019 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Aug 384.0 2-Aug 311.0 3-Aug 377.0 4-Aug 359.0 5-Aug 281.0 6-Aug 264.0 7-Aug 413.0 8-Aug 437.0 9-Aug 357.0 10-Aug 411.0 11-Aug 375.0 12-Aug 211.0 13-Aug 330.0 14-Aug 271.0 15-Aug 281.0 16-Aug 370.0 17-Aug 316.0 18-Aug 380.0 19-Aug 315.0 20-Aug 395.0 21-Aug 430.0 22-Aug 179.0 23-Aug 193.0 24-Aug 497.0 25-Aug 856.0 26-Aug 375.0 27-Aug 347.0 28-Aug 381.0 29-Aug 412.0 30-Aug 357.0 31-Aug 387.0 Old System Lead Filter Outlet 8.0 8.0 9.0 7.0 9.0 6.0 7.0 9.0 8.0 7.0 9.0 5.0 10.0 8.0 5.0 6.0 9.0 13.0 6.0 9.0 11.0 6.0 4.0 10.0 8.0 9.0 10.0 11.0 7.0 4.0 9.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 8.0 8.0 9.0 7.0 9.0 6.0 7.0 9.0 8.0 7.0 9.0 5.0 10.0 8.0 5.0 9.0 9.0 13.0 6.0 9.0 11.0 6.0 4.0 11.0 7.0 8.0 10.0 9.0 7.0 4.0 9.0 5.0 3.0 6.0 3.0 5.0 3.0 2.0 4.0 4.0 4.0 3.0 4.0 3.0 4.0 4.0 5.0 3.0 3.0 4.0 5.0 2.0 4.0 3.0 4.0 5.0 6.0 3.0 5.0 4.0 3.0 5.0 August Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 5.0 4.0 7.0 2.0 7.0 7.0 6.0 7.0 3.0 3.0 4.0 5.0 3.0 3.0 7.0 4.0 2.0 2.0 4.0 5.0 3.0 6.0 4.0 2.0 3.0 6.0 2.0 6.0 5.0 5.0 6.0 12.0 9.0 13.0 6.0 9.0 8.0 9.0 8.0 6.0 6.0 5.0 9.0 7.0 9.0 9.0 12.0 8.0 4.0 6.0 11.0 9.0 10.0 9.0 11.0 7.0 11.0 10.0 19.0 9.0 10.0 18.0 8.5 6.5 10.0 4.0 8.0 7.5 7.5 7.5 4.5 4.5 4.5 7.0 5.0 6.0 8.0 8.0 5.0 3.0 5.0 8.0 6.0 8.0 6.5 6.5 5.0 8.5 6.0 12.5 7.0 14.0 12.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 98.70% 99.04% 98.41% 99.16% 98.22% 98.86% 99.52% 99.08% 98.88% 99.03% 99.20% 98.10% 99.09% 98.52% 98.58% 98.65% 99.05% 99.21% 98.73% 98.73% 99.53% 97.77% 98.45% 99.20% 99.42% 98.40% 99.14% 98.69% 99.03% 99.16% 98.71% New System Lead Filter Inlet 7329.0 2179.0 2965.0 2391.0 2311.0 2589.0 2855.0 2988.0 2614.0 2987.0 2714.0 3321.0 3014.0 2614.0 2374.0 5576.0 3671.0 3124.0 3912.0 6437.0 3019.0 3244.0 2457.0 4617.0 5714.0 7329.0 4617.0 2659.0 3146.0 5126.0 2954.0 New New System System Between Lag Filter Filters Outlet 9.0 16.0 19.0 16.0 14.0 17.0 23.0 28.0 16.0 9.0 17.0 8.0 7.0 4.0 6.0 6.0 5.0 4.0 12.0 8.0 5.0 7.0 12.0 5.0 9.0 7.0 5.0 17.0 15.0 4.0 19.0 7.0 2.0 4.0 4.0 3.0 4.0 5.0 6.0 3.0 4.0 5.0 5.0 5.0 4.0 4.0 6.0 4.0 4.0 9.0 5.0 4.0 5.0 6.0 5.0 8.0 4.0 6.0 3.0 5.0 3.0 4.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 9.0 10.0 4.0 7.0 7.0 13.0 12.0 14.0 10.0 6.0 10.0 7.0 8.0 7.0 10.0 8.0 4.0 8.0 9.0 7.0 6.0 7.0 12.0 10.0 6.0 6.0 7.0 4.0 6.0 5.0 10.0 15.0 14.0 10.0 16.0 7.0 24.0 20.0 17.0 11.0 10.0 12.0 12.0 15.0 14.0 13.0 17.0 12.0 19.0 14.0 14.0 20.0 13.0 16.0 24.0 23.0 13.0 19.0 26.0 11.0 13.0 27.0 12.0 12.0 7.0 11.5 7.0 18.5 16.0 15.5 10.5 8.0 11.0 9.5 11.5 10.5 11.5 12.5 8.0 13.5 11.5 10.5 13.0 10.0 14.0 17.0 14.5 9.5 13.0 15.0 8.5 9.0 18.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 99.90% 99.91% 99.87% 99.83% 99.87% 99.85% 99.82% 99.80% 99.89% 99.87% 99.82% 99.85% 99.83% 99.85% 99.83% 99.89% 99.89% 99.87% 99.77% 99.92% 99.87% 99.85% 99.76% 99.89% 99.86% 99.95% 99.87% 99.89% 99.84% 99.94% 99.86% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Marcus Morris Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Oni Ruiz Carlos Martinez Isaac Sanchez Isaac Sanchez Carlos Martinez Jewel Hussalman Isaac Sanchez Isaac Sanchez Eduardo Chavez Marcus Morris Isaac Sanchez Carlos Martinez Carlos Martinez Isaac Sanchez Isaac Sanchez Marcus Morris Isaac Sanchez Oni Ruiz Josh Baydo Josh Baydo Oni Ruiz EPA Inspection Report - Page 1016 of 1969 2019 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Sep 478.0 2-Sep 416.0 3-Sep 289.0 4-Sep 295.0 5-Sep 286.0 6-Sep 239.0 7-Sep 243.0 8-Sep 253.0 9-Sep 412.0 10-Sep 386.0 11-Sep 410.0 12-Sep 331.0 13-Sep 370.0 14-Sep 291.0 15-Sep 398.0 16-Sep 411.0 17-Sep 263.0 18-Sep 377.0 19-Sep 271.0 20-Sep 198.0 21-Sep 311.0 22-Sep 355.0 23-Sep 317.0 24-Sep 203.0 25-Sep 316.0 26-Sep 197.0 27-Sep 178.0 28-Sep 197.0 29-Sep 210.0 30-Sep 193.0 Old System Lead Filter Outlet 9.0 8.0 5.0 6.0 9.0 5.0 7.0 10.0 9.0 7.0 9.0 7.0 8.0 6.0 9.0 8.0 7.0 9.0 6.0 4.0 8.0 9.0 10.0 6.0 10.0 5.0 6.0 4.0 4.0 5.0 Old Old System System Lag Filter Lag Filter Inlet Outlet 9.0 8.0 5.0 6.0 9.0 5.0 7.0 9.0 9.0 7.0 9.0 7.0 8.0 6.0 9.0 8.0 7.0 9.0 6.0 4.0 8.0 9.0 10.0 6.0 9.0 5.0 6.0 4.0 4.0 5.0 6.0 4.0 4.0 5.0 3.0 4.0 6.0 8.0 5.0 4.0 6.0 3.0 4.0 4.0 5.0 5.0 3.0 6.0 5.0 3.0 3.0 4.0 4.0 5.0 4.0 4.0 5.0 4.0 3.0 5.0 September Old System Background Minimum Old System Background Maximum Old System Background Average Old System Net Reading Control Efficiency (%) 10.0 12.0 7.0 8.0 6.0 6.0 8.0 10.0 10.0 8.0 6.0 4.0 4.0 3.0 7.0 6.0 5.0 3.0 7.0 3.0 6.0 3.0 7.0 5.0 2.0 6.0 6.0 5.0 4.0 4.0 36.0 25.0 15.0 14.0 13.0 8.0 15.0 17.0 18.0 16.0 14.0 9.0 20.0 7.0 14.0 10.0 4.0 15.0 13.0 9.0 10.0 7.0 9.0 8.0 9.0 12.0 7.0 7.0 7.0 6.0 23.0 18.5 11.0 11.0 9.5 7.0 11.5 13.5 14.0 12.0 10.0 6.5 12.0 5.0 10.5 8.0 4.5 9.0 10.0 6.0 8.0 5.0 8.0 6.5 5.5 9.0 6.5 6.0 5.5 5.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 98.74% 99.04% 98.62% 98.31% 98.95% 98.33% 97.53% 96.84% 98.79% 98.96% 98.54% 99.09% 98.92% 98.63% 98.74% 98.78% 98.86% 98.41% 98.15% 98.48% 99.04% 98.87% 98.74% 97.54% 98.73% 97.97% 97.19% 97.97% 98.57% 97.41% New System Lead Filter Inlet 3351.0 2795.0 8952.0 9842.0 4817.0 3247.0 3272.0 3294.0 2761.0 3961.0 4716.0 2477.0 2638.0 2266.0 3247.0 2963.0 2140.0 2659.0 3276.0 5711.0 2173.0 2369.0 2172.0 4711.0 3015.0 3487.0 4678.0 3411.0 4387.0 3246.0 New New System System Between Lag Filter Filters Outlet 21.0 19.0 6.0 6.0 9.0 17.0 15.0 18.0 17.0 12.0 12.0 16.0 19.0 14.0 19.0 17.0 13.0 17.0 7.0 5.0 19.0 17.0 17.0 9.0 5.0 8.0 6.0 10.0 8.0 10.0 5.0 4.0 6.0 4.0 5.0 8.0 7.0 9.0 4.0 6.0 7.0 5.0 5.0 5.0 5.0 4.0 4.0 4.0 4.0 3.0 4.0 5.0 6.0 5.0 5.0 6.0 4.0 8.0 4.0 7.0 New System Background Minimum New System Background Maximum New System Background Average New System Net Reading Control Efficiency (%) 16.0 12.0 8.0 6.0 7.0 7.0 8.0 14.0 7.0 6.0 9.0 10.0 4.0 10.0 13.0 11.0 8.0 5.0 10.0 8.0 4.0 10.0 4.0 7.0 10.0 8.0 12.0 7.0 8.0 6.0 41.0 30.0 18.0 12.0 18.0 19.0 23.0 32.0 9.0 19.0 15.0 13.0 20.0 12.0 21.0 18.0 10.0 17.0 15.0 12.0 26.0 11.0 32.0 16.0 17.0 14.0 19.0 18.0 13.0 9.0 28.5 21.0 13.0 9.0 12.5 13.0 15.5 23.0 8.0 12.5 12.0 11.5 12.0 11.0 17.0 14.5 9.0 11.0 12.5 10.0 15.0 10.5 18.0 11.5 13.5 11.0 15.5 12.5 10.5 7.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 99.85% 99.86% 99.93% 99.96% 99.90% 99.75% 99.79% 99.73% 99.86% 99.85% 99.85% 99.80% 99.81% 99.78% 99.85% 99.87% 99.81% 99.85% 99.88% 99.95% 99.82% 99.79% 99.72% 99.89% 99.83% 99.83% 99.91% 99.77% 99.91% 99.78% Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas Monitoring Technician Name 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Oni Ruz Oni Ruz Marcus Morris Marcus Morris Marcus Morris Jerid Heath Jewel Husselman Jewel Husselman Eduardo Chavez Eduardo Chavez Eduardo Chavez Oni Ruz Oni Ruz Oni Ruz Oni Ruz Oni Ruz Oni Ruz Oni Ruz Carlos Martinez Carlos Martinez Oni Ruz Oni Ruz Jewel Husselman Carlos Martinez Isaac Sanchez Carlos Martinez Carlos Martinez Carlos Martinez Carlos Martinez Marcus Morris EPA Inspection Report - Page 1017 of 1969 2019 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Oct 2-Oct 3-Oct 4-Oct 5-Oct 6-Oct 7-Oct 8-Oct 9-Oct 10-Oct 11-Oct 12-Oct 13-Oct 14-Oct 15-Oct 16-Oct 17-Oct 18-Oct 19-Oct 20-Oct 21-Oct 22-Oct 23-Oct 24-Oct 25-Oct 26-Oct 27-Oct 28-Oct 29-Oct 30-Oct 31-Oct Old System Lead Filter Outlet Old Old System System Lag Filter Lag Filter Inlet Outlet Old System Background Minimum Old System Background Maximum OCTOBER Old System Background Average Old System Net Reading No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data 8.0 No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data 0.0 No Data No Data No Data No Data No Data Control Efficiency (%) New System Lead Filter Inlet New New System System Between Lag Filter Filters Outlet New System Background Minimum New System Background Maximum New System Background Average New System Net Reading No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data Control Efficiency (%) Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Monitoring Technician Name EPA Inspection Report - Page 1018 of 1969 2019 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Nov 2-Nov 3-Nov 4-Nov 5-Nov 6-Nov 7-Nov 8-Nov 9-Nov 10-Nov 11-Nov 12-Nov 13-Nov 14-Nov 15-Nov 16-Nov 17-Nov 18-Nov 19-Nov 20-Nov 21-Nov 22-Nov 23-Nov 24-Nov 25-Nov 26-Nov 27-Nov 28-Nov 29-Nov 30-Nov Old System Lead Filter Outlet Old Old System System Lag Filter Lag Filter Inlet Outlet Old System Background Minimum Old System Background Maximum November New System Background Average New System Net Reading No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 Old System Background Average Old System Net Reading No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data Control Efficiency (%) New System Lead Filter Inlet New New System System Between Lag Filter Filters Outlet New System Background Minimum New System Background Maximum Control Efficiency (%) High Range Monitoring Calibration Gas 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Monitoring Technician Name EPA Inspection Report - Page 1019 of 1969 2019 API Carbon Canister Monitoring for Month: Old System Monitoring Date Lead Filter Inlet 1-Dec 2-Dec 3-Dec 4-Dec 5-Dec 6-Dec 7-Dec 8-Dec 9-Dec 10-Dec 11-Dec 12-Dec 13-Dec 14-Dec 15-Dec 16-Dec 17-Dec 18-Dec 19-Dec 20-Dec 21-Dec 22-Dec 23-Dec 24-Dec 25-Dec 26-Dec 27-Dec 28-Dec 29-Dec 30-Dec 31-Dec Old System Lead Filter Outlet Old Old System System Lag Filter Lag Filter Inlet Outlet Old System Background Minimum Old System Background Maximum December Old System Background Average Old System Net Reading No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data Control Efficiency (%) New System Lead Filter Inlet New New System System Between Lag Filter Filters Outlet New System Background Minimum New System Background Maximum New System Background Average New System Net Reading No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data No Data Control Efficiency (%) Low Range Monitoring Calibration Gas 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 50.00 High Range Monitoring Calibration Gas 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 Monitoring Technician Name EPA Inspection Report - Page 1020 of 1969 ( REFINING COMPANY, L.P. FAX FAX (505) 746-5283 DIV. ORDERS (505) 746-5481 TRUCKING (505) 746-5458 PERSONNEL 501 EAST MAIN STREET • P. 0. BOX 159 ARTESIA, NEW MEXICO 88211-0159 TELEPHONE (506) 748-3311 (505) 746"5419 ACCOUNTING (505) 746-5451 EXEC/MKTG (505) 746-5421 ENGINEERING (505) 746-5480 PIPELINE March 31; 2004 U.S. Environmental Protection Agency Director, Air Enforcement Division Ariel Rios Building 1200 Pennsylvania Avenue, N.W. Mail Code 2242-A Washington, DC 20460 CERTIFIED MAIL/RETURN RECElPT Re: Revi~ed EOL Sampling Plan Pursuant to the Consent Decree entered March 5, 2002 by the U.S. District Court/or the District of New Mexico in United States ofAmerica et al v. Navajo Refining Company, LP. et al. Dear Director: Enclosed, please find Navajo Refining Company, L.P.'s revised End of Line (EOL) sampling plan for our Artesia, New Mexico facility. This EOL sampling plan is being submitted per the above referenced consent decree, paragraph 22.J.ii. This revised EOL sampling plan reflects 1) the change in sampling points due to a reconfiguration of the wastewater treatment system for purposes of meeting NSPS Subpart QQQ, 2) a cJarification of the method of calculating total API water effluent volume, and 3) EPA's comments on the proposed sampling plan provided in EPA's letter dated January 23, 2004. We would be pleased to answer any questions EPA may have about this submission. If you have any questions, please contact me at 505-748-3311 or e-mail me at darrell.moore@navajorefining.com Sincerely, NAVAJO REFINING COMPANY, LP ~M#U i Darrell Moore Environmental Manager for Water and Waste An Independent Refinery Serving •.. NEW MEXICO • ARIZONA • WEST TEXAS • NORTHERN MEXICO HFNA-000000039 EPA Inspection Report - Page 1021 of 1969 ( ( Director EPA · March·19, 2004 Page2 Enclosures cc: Bureau Chief Air Quality Bureau New Mexico Environment Department 20411 Galiste[) St.. Santa Fe, New Mexico 87505 Chief Air, Toxics, and Inspections Coordinmion Branch Environmental l>rotection Agency, Region 6 1445 Ross Avenue Dallas; TX 75202-2733 cc: Navajo: PLY, JER, DEW, FOG, RAS, SLB Holly: WJG Elec. cc: neichlin@.matrix\:Ilgjpeering.com (letter with Enclosures) J1;m:mr.ra.mario(@.epa.gov (letter with Enclosures) Cannon.elizabelh@i:Jti.\,@.Y (letter with Enclosures) General Counsel Office of General Counsel New Mexico Enviromnent Department P.O. Box261l0 Santa Fe, New Mexico 87502-6110 Director, Air Enforcement Division U.S. Environmental Prntection Agency· c/o Matrix Environmental & Geotechnical Services 120 Eagle Rock Avenue, 2nd Floor East Hanover, NJ 07936 Envr. File: HFNA-000000040 EPA Inspection Report - Page 1022 of 1969 ( PROPOSED END-OF-LINE (EOL) DETERMINATION PLAN NAVAJO REFINING COMPANY ARTESIA, NEW MEXICO March 2004 I. INTRODUCTION As required by its Consent Decree with EPA lodged on March 5, 2001, Navajo Refining Company (Navajo) is required to develop an End-Of-Line (EOL) Determination for any facility that has a Benzene Waste Operations NESHAP (BWON) Total Annual Benzene (TAB) Quantity greater than 1 Mg, but less than 10 Mg. Navajo's Artesia, New Mexico refinery has a TAB Quantity greater than 1 Mg, but less than 10 Mg. Therefore, this EOL Determination Plan was prepared for the Artesia refinery. The EOL determination calculates a benzene quantity used by EPA to corroborate that the TAB quantity calculated at the point of generation of benzene wastes is roughly equivalent to the benzene quantity of wastes and wastewater collected at the outlet of the HFNA-000000041 EPA Inspection Report - Page 1023 of 1969 ( facility after taking into account some volatilization of benzene in the oily sewer system and from handling of waste streams. The total EOL benzene quantity shall be determined by quantifying the total mass of benzene in various streams exiting the wastewater treatment system and adding benzene quantities. leaving the refinery in other streams, including that from aqueous wastes that are managed in a contractor owned and operated oil recovery process for wastewater sludges along with other oily wastes generated in the refinery. This contractor process recovers oil and water from the waste streams and returns it to the WW API and generates a semi-solid sludge that is reconstituted with slurry oil (for heating value) and is sent off-site as supplemental fuel for cement kilns. The final cement kiln fuel product generated by the contractor process will be quantified and sampled for benzene concentration and will be added to the EOL benzene quantity. Additionally, waste caustic, generated in some of the refinery processes and then sent offsite for recovery, ,vill be assessed for total benzene and that quantity will be added to the total mass of benzene. / The mathematical representation of the EOL Determination Plan can be found in the equation below: EOL = (QAP1 Discharge Water X Cnen:rene) + (QAPI Recovered Oil X Cnenzene) + (QAqueous Waste Caustic X Cnenzene) + (Qwaste Caustic Hydrocarbon + (Qcentrifuge Sludge X CBenzene) X Caenzene) EOL = End-of-Line benzene quantity (pounds per quarter) Q = Flow (pounds per quarter) C = Concentration Benzene (ppmw) II. EOL SAMPLING POINTS The Artesia facility is a nominal 75,000 crude barrel per calendar day petroleum refinery that utilizes the distillate capacities of its 45,000 crude barrel per calendar day crude unit and that of a 30,000 crude barrel per calendar day topping plant refinery owned by Navajo in Lovington, New Mexico to produce motor fuels and a full range of distillate products for transfer via truck loading racks and pipeline. The majority of the crude feedstock is sour and the facility has an extensive sour water treatment system to reduce the sulfur and ammonia in wastewater streams for subsequent reuse in the process or final treatment in its wastewater treatment facility. The Artesia facility does not have the traditional slop oil management facilities normaHy found in,a petroleum refinery due to the design of the crude unit and major distillate receiver and accumulator process vessels HFNA-000000042 EPA Inspection Report - Page 1024 of 1969 ( that route the organic streams recovered back into crude unit process vessels without subsequent storage or introduction to the atmosphere. Additionally, oil recovered in its sour water system is routed back to crude unit process vessels without subsequent storage or introduction to the atmosphere. The BOL management of benzene waste streams is limited to: (1) the main wastewater API, hereinafter referred to as the WW API, (2) the Alky API that serves both the Alkylation Unit and the Reformer Unit, (3) waste caustic and skimmed hydrocarbon at Tank 40 and Tank 41, and (4) tank cleaning wastes, sewer cleaning wastes and sludges generated in the two API systems, all of which are processed in a contractor owned and operated centrifuge/heating system. For the purposes of the EOL, the skimmed oil from the APis will be routed to surge tanks that are fitted with a calibrated volumetric sight glass, where the accumulated recovered oil wiH be held for the duration of the EOL sampling timeframe. Additionally, the centrifuge/heating system routes the recovered oil and water to the WW APL Water separating from the oil in the surge tanks will be decanted back to the APis and a final measurement of recovered oil will be made at the end of the EOL sampling period. A schematic of the EOL sampling plan for the API system and the contractor centrifuge/heating system is presented as Figure 1 on the following page. HFNA-000000043 EPA Inspection Report - Page 1025 of 1969 { FIGURE 1 DIAGRAM INDICATING EOL SAMPLING OF API AND CONTRACTOR CENTRIFUGE/HEATING SYSTEMS ALKV API Surgel Biologic:al Treatment Tanks W.Rtnr Q,urge Tank Water was~. water , - - - - - -... Treated APi Oil& Water water OAF and Filtration OH&Wm:er ~nd · injection Wells Surge Tank OH to Crude Shut~s Contractor from A.Pl, Oentrifug·t Se~r, - - - - /Heating and Tank CJeanouts System Come:tit - ~ - J I - Kiln ~_,,.,H,.......,..io !'l < fuel Product (s11~1e· 1 ·,._Pt,S4 .I '~ "'"•,,rt~-,. - • • • • _Generatof;;!Off~ror'.Pii~ff~ Name i dt" ·. ' _: :._c " ' ,. '. •-;: ' . LJ Import to U.S. ' 0 Port of ent~iex~: Exportirom U,S. Dale leaving UsS.: ''····s::. ._Signature. ··, ····-·1·....:..... .... _·._·:)j ,... .. ..,-~.,,···· 'Sig&r)i{L,, Ooilan!ity (or Generator) Monll'! Day Year. HFNA-000003520 EPA Inspection Report - Page 1032 of 1969 U.S. EPA ID Number NMROOOfi23952 U.S. EPA 10 Number . ·U;S, EPA IDNumber 9b. U.S. DOT Description (including Proper Shipping Name, Hazarrl Class, ID Number, and Packing Group (ifany)) · · · . 10. Conminers Type ~. 4, ., .... , ~~~~'-'-~,~~~~--r - ! l''t:14:r,J/50:,:rtHt:'.an'."'.dm'.lir:'.'.:19'i.ln=strt::-:::;ct1e'.::·o".'.:ns:-:a::n,dA'"d'-'d'"ilic::n:::;_al"'ln::.:fo::rm:::ia:,!i;:::on' 1} 00Jit1.'475-0 V . Hlb?. SEWER !lh.UOGE 0 Export l'mm'.u.s. Port of ent')'lexit '" " ""'--···· .. _Date leaving U.S.: St_·~_r:~~u~ ..-·.....~~ ,,/ ~ <.•.::>~- =-"'f"'"""iM"s """~=,-.-=~-~ """'----~------ -~wm,,;Sign a!ura . ----I "~ 1Sa. Discrepancy indicati9n Spaoe . 0 Quantity . .', 0Residue. 0 Partial Rejeciion • Plione: Facility's 18c. Signature of AJten,a!e Facili!y (or Generator) Year Waste Report Management Method Codes (i.e., codes for hazardous waste lreatrnsnt," disposal, and recycling systemsf '(''. 't"'·' HFNA-000003521 EPA Inspection Report - Page 1033 of 1969 F.oml'Approved. 0MB No. 2050-0039 ·.·,·,..,.,.,,.M~lN U.S. EPA ID Number -'\'.);$, EPA ID·Number 1"1. Total· 12. Unit · Quantity W!.NoL D Import tz,.u.s: Transporter sigr.atiire (for exports only): 17. Transporter Ackr\owledgrnen! oJ Receip! of Maierials edName :.,,.,..., I" :ti {, /' ..) r"" (f n rnscrepancy ' Refection [ ] Fu~ Rejection Month Day Year --------------------------------------------~ rodes Hazarifous Wasie Report Management Meihoct Codes (Le., for hazardous waste trea\ment, disposal, 'and racycling systems) HFNA-000003522 EPA Inspection Report - Page 1034 of 1969 .:i·,x,.i-' } . 2,Page 1 d 1,::: ~~<~ ir- &•.' . U.S. EPA ID 1,/umher ~, •,. > i !, ,t··.; .• . • , , ,. ;:,_, NMR000023952 u .s. EPA ID Numoor ,· ......,. · -~ ·· .,,,·. ··.z..,.· -~.J;.-. _,,,: .-:,.,+-.. . ~:~'4~--,.-w-·,~'f )"""1~+<-..,.-··'"· -:...:;.:*"':,·~-..:..,,~~~~~-~.;,.. ;~~. . .~.~~,.,; ···*·""....,., JJ.~.??.~J;J:~ io»wn.~w:~.-~~~-~~ -"l"•-~~... A-.,.;. ~-~,:_ ,,:,,...:.:;;;....,."'. ~ cl,:f tf" .,:, .. ~~> -l', 4 "'f:!\~. t~(t TXDOOS4!52340 ! 1(), Conminern. No.·· · Type 4. ...,~ .. . •.·, ,,,;;.;,, ,., . ;_,, ,;~.....:.>: '. . . . . ·. . ..tl1at the conlen!s of !his consignment. are fully and accurately described above by !he proper shipping name, and are classified, pac~aged, marked ahd label,Wplacartled, a~d are .in 'all respects in)roµer cqnd:!ion for tmnSP,Ort acmrding tp aiplicable in\emau0ri.a?,ano naijo~ar govemme'ntal mgulalior;s. 1i port shipment and I am ttm Prim~~ . · &porter; I certify,(MMhe oonlanls of !])is oonsignme\l\ (X)nform fo:lliiHerms of !he alt.lched 'EP~Acknrwll1tig!T\ert ofC!)nsin!. . . . . . . . . . .·' J certify !hat the wimle minitl)izatiDli $!$lament identified. in 40 CFR 262.27(a} (if I ani a'iarge qu~11Ut',{9iirjera!or}or (b){ff l '1m a. srnilll 'quahtity geherato ax 0 Hi.' Discrepancy · .. D.· ~-c·,.·. --.::., . Full Rejection 1Bb. Alternate Facility (or Generator} j " '. 'Manifest Refurer,oe Number: U.S. EPA !tl Number Facility's Phone: ale facility (or Generamr) Mon!h Day·,· Year pehfor: CertffiMtion of receipt of 11azardaus 11iaterials covered by the man~est exce. SignaMe. : HFNA-000003523 EPA Inspection Report - Page 1035 of 1969 •. ,,/ /\ ..... 9a. HM 9b. U.S. DOT Description (including Proper Shlpping Name, Hazan:I Class, ID Number, and Packing Group (if any)) 1" PA &1So. O \l I'-, /\ X ~ No. ;~f) ;! '. ~,:., 01.:..._, t:;::::' ./ . '. x,J,/ { ' ffi-f---........+-------------------~----~~_/_·- - f - - - - + - - - - - + 2. :z: w G I """-=----------------------"""""-"-""" -~""-""----------0-----------"-------~ ---, 3. :I 4. ; ~ ·~'\_ ... ... q;,_ t ~/~ . 1 w l,.. ~ '\:.;- -~ ------~----- 15. ·GENERATCIR'S/OFFEROR'S CERTIFICATION: I hereby ntenbl of lh~signmenl are fully and accurately described above by the proper shipping name, an::! am cla_ssified, par-kaged, marked and labeleo/placarded, and are in al! mspects in proper condition for lmnspml ;3ccj:1!ding lo ;ippl1cable inlemalianal and national govemmental regulations. !f export shipment and ram file Primary fapmter, I certify !hat the contents of !his cimsign.ment conform tot.he tenns of the atlachea EPAAcknowledgmenl of Consmi. I certify that the waste minimi2ati()n stltemenl identified in 40 CFR 262.27(a) (ff I am a !arg?quantity generator) or (b) (ii I am a small quantify generator) is true. Mmfil Day Year .,.... .::~~i D EKport from u.s: ,4 ' u:r //~:1~:;bzrt:o Porl of entry/extt: l .3L271.lq -----------------===--l Transporter sign~,ture (!or exports only): ........,............,....,....-------------------D-at_e_la_av_in_,,g'-U-._s._. 17. Transporter Acknowledgment of Receipt of Materials Transporler 1 Printed/Typed Name ;t,.,:-1/1 r·>:: ro f. /L . / Transporter 2 Plin!edliypeo Name ~ ·1 18 · Discrepancy 18a.-Discrepancy lnciicalion Spac.e D · - - - - - - - - - · - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -..-·-················ o .... ''n"'' 0Typ·"v D·R ' ti on o···· r··uII Re1ec . 1·mn ··"" "'' :.... em'd ue ..... pa,~,,aIReJec ! !,·, ' i .-J ' <" ·'' (()· •'j 4, LJ. r.; Cd,./ '-'',,. ,,',. h,,., .' . > __ . ';c.1/.J;.,'-i 'J <;- .. I . ~ .. ~"' . ., _ , , : , ' I r .. / ,·-- •'- [·· · 1 . !}~w, !4.'. f'r,11'..,I ,hifl_:;<.t·L; '' . Manifest Reference Number: ~ 16b. Allemate Facilify (or Genenalor) ::- / J. -~ U.S. EPA I[) Number ~~rmmmh) rng:ib~:((:'i~, lf 0xport f:hiprr:0:it ~rd l ,~rt E11J rnm0ry Ex~crtff,: Gfrlify trd Ge (mimb i)1 tliiJ wnfo,111 b liw leim1 0f c~f 11\bdld EPAAd:mw!m\1H1ent 6f I i:;.ir/y baithB wisie min\;;intm stJINmd ldm;1.;1hd in 40 CFR 262.27/a) iii I Bm a large q1;1,i,+; g·mBmbr) ,:)r 1/) I)! w1 " :;1111ill qwr%y grrnra!rn) b rn;~ .. GGrcdgnmB\ G$ {fl 01mrc,rt ts) U $. (for eworti rd;): · ~,,,,;;.-- ~"---~~ ~-~.,;.:_ ,.- 0:ln1mnt. . . . .. ~'.~:SignffetJj(QA(?!>,<~-j'.~~~~;~-f-~-/-..>---~--~--,-1 3bf;,rtifirn1JS.· :'· · · '"'\,, Jq t· · Ywr Pn:td~illl)'M:. 2JS>OC:W ·40 JJtc GerefrdIT's f'h>r;n: 6 I (fi1tf).A ¥7~4 !?'rii115W.t~"WASTE SEHV!CES H\!C ·~~t·~""""-. '.t :: ~-·--"'0. _ ~ _ ~""--J·~~-,.b,-,_·,,..l · - ~ - - ~ - " - - ~ - ·- ·:S.-·"""!_ _ Q,nnny LJr,w:;· '·*"">§;·'"'· 10, J;fr<} pJvt\.iJ I IY:,J.t+:; . ! /j)A r""c ChI ; :~ '~>t "S+i HFNA-000003527 EPA Inspection Report - Page 1039 of 1969 >< . 0MB No. Xi50V :::,;~-.v.·.. , P:s,r.it0 prt1t1r '.\Ts? I ·1, . :: - r'llMJS&1£i~stm s Rr~cll&B!)f~f@@1tJ\S~l:·1:1J;. ' Rt). Bff!HS AA7ES!A %. U.S. md Pa1:b1J %. HM Pmpr 3Hppir,g Nm<1t, h1wd Clim, ID 1 4. I [ ] PsrMI fbt~tiGn ; ···.·1· , ,'- ... \ HFNA-000003529 EPA Inspection Report - Page 1041 of 1969 SERVICES !NC ?tZi1 VOUNYY ROAD GS ROCTSTCfAfW . .. @00) 24.Z.Jili:m -k----r----,-·. - . "--·-"""' -----------------------.---=-----c ; . 10. t)::ni3bi;\:-s ir;:._:'s::P:.hc::r;::tB:::;__·_~--.:.:':.·· i;F..;~:':o:::.'l1 tti 0 i!ti b,-,~----~---------.·. ·/··· ,. UJ 91 4. k=::-:-:;;;::::;'T,;,::::'i2::0:~:-:::'~~~-"'-~~;_;,,,,..------~---"" "'.~;;;,i;;"'~°'.'7'.""'""".'--:.--------~··--""'·········-r,-;o-d~h!-J" "p-y---0 L{ //) "·;«')" L.J J: ,_.. ·J.•.. . ',: '., HFNA-000003530 EPA Inspection Report - Page 1042 of 1969 ::·. ed for use on elite (12-pi!ch) typewriter.) t Ge11emtor,ID Nwmoor ,es _:.. 2. Page 1 of NMP04Blil188'! 7 1 lhan mailing address) !\IAVAJO NEF!MMG CO , L!...C.. 001 i:::AfilT-W!NN A.lt'fESL#i 6: Tran~porter 1 Company Name U.S. EPA ID Numbl!f $ EJR.rrrHERS V1?\STE Sf;Fi}ii'C"ES !NC NMROCt00.2:3962 U.S. EPA ID Number 7. Transporter 2.Company Name .. ~ ~ ~ ~ ~ - - - - - - ~ - - - - - 1 - . ~ .~,,,,,,,,,,_"""'-""'-11. l.\dg~e!ild F;:;Gility Name.and. Sit.a Addr~w · \;. ? EQ;l'.Jt.OGY i\S), ING U,S; EPA ID NQmber rex 32.P'Y C®f>HY ROAD 69 . m:w5Tcr,i'#J . . . Facill~ s Phone: ~) ffl•:f'.i!:$ -----"-- Sb. U.S. bCirne;criptkm (including Proper Shipping Name, Hazard Class, ID Number, and Packing Group (if any)) . . . nten1s·of this consl{Ament are fully and accurately described above by the proper shipping naine, aoo are classified, packaged, ma.ked and labeledlp!acarded; and are in respeG':S in proper condition far transport accordjng to applicable inlemalional and r,aiional governmental regulations. If export shipmen! and I am the Plimary Exporter, I certify that the contents of this coosignmenl conform to the terms of the.attached EPA Acknowledgment of Consent. . I certlly that the waste minimization sratement idenimoo In 40 CFR 2o2.27(a) (if I am a large quantity generator) or (b) (iii am a small quantity. generator) is true. " !Typed Name " all A0w Port of entry/exit: . Daie lem,ing U.S.: ~· Sign&.di.:\,•·•·· "'''' ... · I )' D TYfte D Residue I /' c'"'...>'ftove..,,.t o.et'.· ... ,!\ :: ::. ... -~ ::. ,,c :( :) ' C D Full Rejection ,L.J partial Rejection t. 1:..·"· Se~,il1,A<\C\b.i.""' ...·.,:. :.r.' · l · 1'1 ci:c €'.' ...·.··.Ge.tx)l'.R?. ":c::-·,.::.·.·.]jr,,:o"' . 10.· -r:r . . . ·'. ,·. ·. :::':':'iti.n!fehl ecere ca um e .:-:...· 1 :.•.:. . .. / / ·:;t ~ ~ C' ~ G ~ .''(';1" U.S. EPA ID Number Facility's Phone: 18c. Signature Q! Alternate Facility (or Generator) (i.e., rodes fur hazardous waste treatment, dlspo.sal, and recycling systems) 4. HFNA-000003531 EPA Inspection Report - Page 1043 of 1969 F?iiFORM HAZARlX)UE , WAJTE fs1ANlFEST .. 5, f#WAW#1WNTNflW.tv:f611;WLC. Per sex ARTS:iiHA . ($7%} 7GlHX%J4 flRT£01A MM @42Kt i· ------------------------,~= 1 ,,,::.G;;;,,~;;;;,',t::,:·m::,:x;;;,,i,::.'c;;;,P;;;,h;;;,01;;;,'";;;,,:'~· 8 {31M()Tftllil~'1~'10;srs.sERVICE8 7. ~r a: rffl1mndst;'ffl&~1;1rfl1!:% · ·:!i2T? GGUNT\' fh}AU GR HGB@TU'$iV $XW} 3(0.JZ}B ~=;_,_---'------------·------------------,,----· 10. Corctili'lers Mo. i 2: "'~· ·.l .\.:,,,,:. . ··~ hdlilv's Hmm: Wt. S\w~Lrn d !%,milt~ fJdl'tf (rr Gum~mlu) "'~ ,__ _ _ _ _ _, . ' -~,,,,........-.---·----.~.·------"-'-""""'''''..,.,.,._,.~.--··----k---'---'----l'. 19. Hsz;J~}QU5 V:{t=;k R:_::vin ri..tm,.:(it:611:::rit Mh="K:' tenn:i cfthe alticlieo EPAAr.know:eagment of Consent .,. · · I cei-/ily u,at th~ 1\iast£ iJ:,inimlta!iofstiit!i~ilnl identified in 40 Cf'R 262.27/a) (If! arrl' ;i la/ge qUanfify generator, or'(bi (ffl am.a Sinilil qt!mlt/ty ge11~iator) is lr\ie, . .. . .. . . we . . -- Signature ~, · ~--'~-,;,'- ~c....--=- -~,,,,,,--" --b-<0-~0 -,,,- · '\ <~"r='''"'-= · HFNA-000003534 EPA Inspection Report - Page 1046 of 1969 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO UNITED STATES OF AMERICA, Plaintiff, and STATE OF NEW MEXICO, STATE OF MONTANA Plaintiff-Intervenors, v. NAVAJO REFINING COMPANY, L.P. , MONTANA REFINING COMPANY Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Civil No. CONSENT DECREE EPA Inspection Report - Page 1047 of 1969 after Navajo and/or Montana Refining, as applicable, receives the results of the Third-Party TAB Study and Compliance Review, Navajo and/or Montana Refining, as applicable, shall submit the results to the Applicable Federal and State Agencies. EPA, the Applicable State Agency, Navajo and/or Montana Refining, as applicable, subsequently shall discuss informally the results of the Third-Party TAB Study and Compliance Review. By no later than one-hundred twenty (120) days after Navajo and/or Montana Refining, as applicable, receives the results of the Third-Party TAB Study and Compliance Review, or such other time as Navajo and/or Montana Refining, as applicable, and EPA may agree, Navajo and/or Montana Refining, as applicable, shall submit to EPA for approval a plan that addresses any deficiencies identified in the Third-Party TAB Study and Compliance Review and any deficiencies that EPA brought to the attention of Navajo and/or Montana Refining, as applicable, as a result of the Third-Party TAB Study and Compliance Review. A copy of this plan shall be submitted to the Applicable State Agency. The review and approval of this Plan shall be done in accordance with Paragraph 22.D.iii of this Decree. Certification of Compliance shall be done in accordance with Paragraph 22.D.iv. J. End of Line Sampling (TAB is equal to or greater than 1 Mg/yr but less than 10 Mg/yr). The provisions of this Paragraph 22.J shall apply from the date that the final BWN Compliance Review and Verification Report submitted for any Covered Refinery pursuant to Paragraph 22.C shows that a Covered Refinery’s TAB is equal to or greater than 1 Mg/yr but less than 10 Mg/yr, through the earlier of: (1) the time that the Covered Refinery reaches a TAB of 10 Mg/yr or more (in which case, the provisions of Paragraph 22.I shall begin to apply); or (2) termination of the Consent Decree. i. Navajo and/or Montana Refining, as applicable, shall, once per calendar year, conduct sampling, consistent with the requirements of 40 C.F.R. § 61.355(c)(1) and (3), of all waste 67 EPA Inspection Report - Page 1048 of 1969 streams containing benzene that contributed 0.05 Mg/yr or more to the TAB set forth in the final BWN Compliance Review and Verification Report or in the previous year’s TAB, whichever is later; ii. By no later than ninety (90) days after the date of submitting the final BWN Compliance Review and Verification Report, representatives from EPA and the Applicable State Agency shall meet at the Covered Refinery with representatives from Navajo and/or Montana Refining, as applicable, for the purpose of identifying an appropriate procedure for conducting EOL sampling and measuring EOL benzene quantities at that Covered Refinery. EPA, the Applicable State Agency, and Navajo and/or Montana Refining, as applicable, shall confer about potential EOL sample locations and shall review process and flow information and oil movement transfers. By no later than thirty (30) days after EPA and the Applicable State Agency have met with Navajo and/or Montana, as applicable, at the Covered Refinery, Navajo and/or Montana Refining, as applicable, shall submit a plan to EPA for approval that contains proposed sampling locations and methods for flow calculations to be used in the EOL determination of benzene quantity. A copy of this plan shall be submitted to the Applicable State Agency. Any disputes regarding plan approval under this Paragraph 22.J shall be resolved in accordance with the dispute resolution provisions of this Consent Decree. If, during the life of this Consent Decree, changes in processes, operations, or other factors lead Navajo and/or Montana Refining, as applicable, to conclude that either the approved sampling locations and/or the approved methods for determining flow calculations no longer provide an accurate measure of the Covered Refinery’s EOL benzene quantity, Navajo and/or Montana Refining, as applicable, shall submit a revised plan to EPA for approval. A copy of this revised plan also shall be submitted to the Applicable State Agency. 68 EPA Inspection Report - Page 1049 of 1969 HOL[)FFRON'IlER" January 30, 2018 U,S, Environmental Protection Agency Director, Air Enforcement Division Ariel Rios Building 1200 Pennsylvania Avenue, N.W. Mail Code 2242-A Washington, DC 20460 Re: Cenified.. Mail/Rernm __ R,~ceipl 7014 3490 0000 6269 7233 Quarterly lm_plemeutatkm Progress Report Pursuant to the CoM.seut Decree entered JVfo.rch 5~ 2002 by the U.S. District Court for the District of New Mexico in Unitt!d States of America et at v. Navajo .Refining Company~ LLC et al. Dear Director; Pursuant to Paragraphs 37 and 23.0 of the subject consent decree, lhis subi.TJ.ittal provides the status of implementation of consent decree requirements through the calendar quarter ending December 31, 20 l 7 frir Hollyfrontier Navajo Refining LLC (formerly Navajo Refining Company, LLC), (Nava,jo's) Artesia and Lovington, NM refineries. As specified by Paragraph 37, a statement of certification is provided on the following page, In accordance ,vith the notice pro vi skms of Paragraph 91, copies of this report are being mailed to EPA Region 6 (Le,, the Applicable EPA Region) and to both addresses listed for the State of New Mexico. Navajo ts also providing an additional hardcopy to EPA\; contractor and electronic-mail copies to the addresses provided in EPA's letter dated August 1, 2002, provided by electronic mail on January 3 l, 2008, and EPA's electronic e-mail update dated J'vfarch 19, 2013, ff you have any questions regarding this submittaL. please contact me at the address below or by phone at 575-748-3311. Sincerely, Scott M. Denton Environmental Manager HollyFrontier Navajo Refining LLC Holly.FmDtkr Navajo Rdi:afa.g U.,C 501 East Main• Artesia, NM 83210 (575) 748-331 l • htt:p://www.holl:yfrontier.com HFNA-000001711 EPA Inspection Report - Page 1050 of 1969 By signature bdow, the undersigned hereby ce1tifies to the following: _Statement of Ce1tification I certify under penalty of law that this inforrnation was prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the inforrnation submitted, Based on my directions and my inquiry of the person(s) who manage the system, or the person(s) directly responsible fr)r gathering the ini(mm1tion, the information submitted is, to the best of my knowledge and belief, tnw, accurate, and complete . .,...,,7 ./.;:~(~/ch;/1:-.. . t)/~I~ ····;,·· .(...,.;~ ·····························································/.····················"·--- R~ibert O'Bden Vice President & Refinery Manager HollyFrontier Navajo Refrt1ing LLC Enclosure cc (w/enc.): Bureau Chief Air Quality Bmeau New Mexico Environment Deparlment 525 Camino de los Marquez, Suite 1 Santa Fe. NM 87507 General Counsel Otlice of General Counsel New Mexico Envirnnment Dcpanmenl P.O. Box 261 ](I Santa Fe, NM 87502~61 W Chi<:f lJ.S. Environmenwl Protection Agency Air, Toxics, illld Inspection, Coordit1at.irn1 Brnnch Environmental Protection Agency, Region 6 l445 Ross Ave1111c Dallas, TX 752.02,2733 c:/o Matrix Environmemal & Geutechnical Services Electrot1i;; cc (w/enc ): Matrix New World E11gineering, lnc. 26 Culnmhia Turnpike Florham Park NJ 07932 1-lollyFrontier: R. O'Brien. B. Romine, J. Stump, I. Jones, T. Wlieelcr, A. Beard Envirm1mental File: Omsent Decree.Suhm·Re,p.Quarterly .Reports.2018.01.3() HollyFn::mtki: Navajo Refining LLC 50 l Ea;;t l'vfain ' .i\Jtcsia, NM 882 JO (575) 743-33 I 1 • l:)j;j:p://'i\"IVW.hollyfrontier.com HFNA-000001712 EPA Inspection Report - Page 1051 of 1969 New Mexko Envi.rom:ne.nt Depa:rt:ment Air Quality Bureau Compliance and Enforcement Section 525 Camino de los JV[arquez, Stlite 1 Santa Fe, NM 87505 Phone (505) 476-4300 Fax (505) 476-4375 Vern.ion 05.02.13 ·······························-···························· NMED USE ONLY '-,,· ~p~rD·USE.ONLY--- RE PO RTIN (; SUBrvUTTA.L FO RIVI :::::··::::. A._::_~:~1--_-_-_-_-.. .: : : : : : : : : : : : SECTION IM GENERAL COMPANY AND FACILITY INFORMATION --------•v-~~-·-···················· ······ A. ® Company Name: HollyFmntier Navajo Refining LLC B.1 ® Companv Address: PO Box 159 0. ® Fadiitv Name: HollyFrontier Navajo Refining LLC E.1 ® Facility Address: 501 E.Main St I B.2 ®City: Artesia C.1 ® Compi.my Er111imnmr.mtal Coritact: Scott f\/t Denton C.3@ Phone Number: 13.3@ Skte: BA® Zip: NM 88211-01591- 1 E.2 ® City: 575-746-5451 • 575-746-5487 F.5 ® Email Address; 575-746-5487 C.5@ Email Address: ---Scott_Denl.on@hollyfrontier.corn --------------------------------------------=-----=---,-=---=----=-~ = = = - A. [·----] • Title V Annual Compliance .Permit Conditionts}: Certification Dascrlption: • Permit Conciitionis}: •Descr\ption: NSPS Requirement (40CFR.60) o. D MACT Requirement (40CFR63) E. D NMAC Requirement (20.2.KK) or N!2SHAP Requirement {40CFR61) F. D Permit or Notice of Intent (NOi) Requirement Requirement of an Enforcement Action 575-746-545·1 J~8/~2~~1~~rmit ls_sim--~-~-t:~_'._____ \ ---- • NP~5~-1~~g~J~:~X~be~: ~-~~T.IQ_~__!_l___~__!_'fPE OF SUBMITTAL (?..~-~-9.-~---~-i:i-~_ that applies} C. [] _____ __I =,'"-----:----,-------------.--========',<~c-,==,e---:---:-•----,--------:"'--------,·-----------'-•------.-----.••=~-.-,,-==-~====.,-,-------------------------.---,•=----=---=----=---===acl 1 J. Fax Number: . Title: L Phone Number: 'ice President & Refinery 575-·748-3311 1 575-746--5451 naqer ~=====""====--,=---·=----=---=---=----=---=----=----=---=----=----=---=----=----=-------_-_ _ _ _ _ _ _ _ _ _L._ _________________________ ._ ____ ------------------------------"'-------------------------= _}'rii0_Ai_ Number:________________ j\,Jht~~R~ Permit Number:_______T_-~~;-J~}~~r5e~nlt !mme D11te: ~; ~~po~~~g1j;~~;d: To: 12i31/2017 • I 0 Title V Semi-amn.iai Monitoring Report NM 88210 F.2 ® Title: Environmental Manager F.4@Fax Number: ScottDenton@hollytrontier.com G. Resoonslb!s Official: IT Robert O'Brien a. D E.3 @ State: • EA@ Zip: Arteslz C.2 ® Title: F. 1 @ Facility Contact: Environmental Manager • Scott fvL Denton C.4 ® Fax Number:-----------------------,.1-~F-.3-®~"_P_h_o_n_e_N_u_n-1b_e_r_:- - - I --···------------------------------------------------------------------------------------------------- ReQulatlon: Sectionfai: Description: 'ReQu!ation: Section{s); Descrimion: Rer.w!ation: Section fa}; Description: Permit No,0: or NO! No.0: Condition(s): Om;cription: NOV No, [J: or SFO No, [J; Section(s): Description: or CD No. Q: or Other [J; EPA Consent Decree Quarterly Report for HollyFrontier Navajo Refining (Artesia and Lovington) Cl\f--01 1422LH Pam.graphs 37 and 2:3,0 SECTION IV CERTIFICATION !---------------------·------------ --------------------- -----------··---------------------------------------------M ----------------------------------------------------------------------------- !® iks~~l"lsfole Offai~I for Tlt!e V? [ ] No Reviewed By: ---------······························---- Date Reviewed: --------------------------------- HFNA-000001713 EPA Inspection Report - Page 1052 of 1969 New Mexico Enviromnernt Depa.rtrnwnt Air Quality Bu..reau. Compliance and Enforcement Section 525 C:amfao ik Jos Marquez, Suite i Santa Fe, NM 87505 PboEJe {505) 476-4300 Fax (505) 476-4375 ~~ j REPORTING SUBMITTAL FORM SECTION I GENERAL COMPANY AND FACILITY INFORMATION w A, ® Company Name: B-2@City: r.~~:g~~:t ~J-,clt!-,'R)c-Scccta,-t~e:~~1!2~)1~~;5gJ Artesia C. 1 ® Compmy Envlmnmenfai Contact: Co2®Titie: Environmental Manager C.4@ Fax Number: 575-746-5451 Scott M. Denton C.3@ Phone Number: 575-746-5487 .......................................................... C.5@ Email Address: ~cott Drnton(alhollyfmnli,,r· com . ~,Re~oo~sible Official: /Title·v-'o-n-iv-l:==.=H-.fiti";t···-·.·.·.·.·.•.•.•.•.•.•.•.·w··=·= = = = = = ' Robert O'Brien -----·····················-·---- ® Fac!!!tv Name: HollyFrontier Navajo Refining LLC E1@ Fadlity Address: 7406 South Main !), HollyFrontier Navajo Refining LLC B,1 @Company Address; PO Box 159 ·----·························............................... ············_···_···-_-_··-_·_··~~~~~~~~-l,~-J./~..®..StateT~~ti~Zip·:····· F.1@Facl!ltyContact: F.2®Tltie; 1 Scott M. Denton ... -~.r_1!1r.:'.12i:11.~~_l:3..1...~anager F,3 ® Phone Number: FA@ Fax Number: 575-746-li4ffi' 575.745 .. 5451 ············································· -----< F.5@ Email Address: ScottDentor llyfrontier.com ........·.·.·.·.·.·.·.·.·.·.·.·....·.·.·.·.·.·.·.·.. . - ........... Number: .!. F""a=x=N7 l=im=,cb=er: 1. Vice President & Refinery 575 _74 G~!:i 451 ,= .....= ....=.....=....J ....,~ ... ~~)gf~==f' ,==~=====,cc=cc,,cc==b==,,,.w.w.w.w.w.·.·.·.•. •.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.·.·==· .. = ....= ....· = = = 4 L Title V Permit Number: M. Tltie V Permit issrn, Date: N. NSR Permit Number: 0. NSR Permit Issue Dale; P020-R2 07/13/2015 0273-1\/19 05/06/2014 I •.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.w.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•., ......... , •. IC@ Al Number: 622 P, Reporting Period: From: 10/01/2017 ----~--····· ··················································· - - - - · · · · · · ·············•······················································· fo: 12i31/20'1? SECTION ii - TYPE OF SUBMITTAL (checkone_that_appiies) ............ A.[".] Title V Annual Compliance Permit CondWon{s}: Certification Description: Permit Condition/Si: Description: D Tille V Semi-m1mial Monitoring Report C. [·.] NSPS Requirement (40CFR60) B. D. LJ MACT Requirement (40CFR63) E, [ .... ] NMAC Requirement (20.2,xx) or NESHAP Requirement (40CFR61) F.O Permit or Notice of Intent (NOi) Requirement Reiwiation: .... ........ Rem.liation: Requlation: .-........ -~···~·································· Description: Sectionfol: Description; ·- Sectionlsl: DescripUon: - Description: I NOV No. D: m SFO No. G" [SJ ',, Requirement of an Enforcement Action Cl\/"01 1422LH SECTION IV~ CERTIFICATION After reasonable inquiry, I 0: I Section(s): or CD No, 0: orOtlier 0: 1 Parngrnphs 37 and 23.0 '" -·················----················································ Robert O'Brien ..... SecUonlsl: Permit No.D: or !110! 1\!o.D: Condition(s): Description: ···········-·· -··· ·- EPA Consent Decree C!uarterly Report for HollyFrontier Navajo Refining (Artesia and Lovington) · - - - - - - - - - - - - - · ·---····························· certiiy that lhe iniormation in this submittal is true, accurate and complete, ---c(~-~-,rm of rnp~ftl~g ~ffki~I) ----······································································ Cf!) Tit~e; Vice President & Refinery Manager Reviewed By: _____ ................................................... . 01/30/2018 Date Reviewed: HFNA-000001714 EPA Inspection Report - Page 1053 of 1969 CALENDAR QUARTERlY REPORT ro SUBMITTED PURSUANT SECTION IX OF THE CONSENT DECREE ENTERED IN UNITED STA TES OF AMERICA ET AL V: NAVAJO REFINING COMPANY, LA, AND MONTANA REFINING COMPANY (ENTERED MARCH 5, 2002} Cumulative from Lodging (December 20, 2001) Through December 31, 2017 Ho!lyFrontier Navajo Refining LLC (formerly Navajo Refining Company, LLC,) Artesia and Lovington, NM Refineries PoOo Box 159 Artesia, NM 8S211~(H59 HFNA-000001715 EPA Inspection Report - Page 1054 of 1969 Calendar Quarterly Re12ort _4th Quarter 2017 Hoi!yFrontier Navajo Refining LLC, Artesia and Lovington Refineries TABLE OF CONTENTS 1 oO INTRODUCTION o, "•oo, " ..................... , •• oo," ........... ".oo, ••••••• ,,,00,,,.,00,"···· " ' ... " ................... 1 :2o0 PROGRESS REPORT ON IMPLEMENTATION OF SECTION V OF THE CONSENT DECREE. o.... 00 ••• oo•••• oo .... 00." o00 ..... , ••• , ••••• ,,. " •••• ". 00 •••• 00.".,, ••••• ,,.". 00 •••• ,, ••••• 00 ..... , ••••• , •• ,, ................... 2 3o0 SUMMARY OF ACTUAL OR ANTICIPATED PROBLEMS IN IMPLEMENTING THE REQUIREMENTS OF SECTION Vo o,,,,oo,"ooo,"·····•oo,,,,.oo,"·······oo,,,,.oo,,,.oo .. ,,.oo,,, •• ,.".oo,"''''''"''"'21 4.0 SUMMARY OF EMISSIONS DATA .... ,. .......... ,. ... ,. ............ ,. ............ ,, ......... ,,,.0, .. ,0 .... ,o .. :22 5.0 IMPLEMENTATION OF ENVIRONMENTALLY BENEFICIAL PROJECTfL .. o.......... .,.:26 6.0 OTHER MATTERS ""o .... 00.-,.00, ..... " ' ... " ' 00.-,.00.-,.00 .... ,00 ' " ,oo '"·oo· " .. oo .... 00.-,,00·"· ..... ,..,., .... 30 ATTACHMENTS ATTACHMENT 1 - APPENDIX G SUMMARY REPORT ATTACHMENT :2 -APPENDIX H SUMMARY REPORT ATTACHMENT 3 - QUARTERLY EOL SUMMARY ATTACHMENT 4-ANALYTICAL REPORTS EOL SAMPLING ii HFNA-000001716 EPA Inspection Report - Page 1055 of 1969 Calendar Quarterly Regort -41ri Quarter 2017 HoiiyFrontier Navajo Refining LLC, Artesia and Lovington Refineries CALENDAR QUARTERLY REPORT Cumulative from Lodging (DECEMBER 20, 2001) Through December, 2017 HoilyFrontier Navajo Refining LLC (Navajo} Artesia and Lovington, NM Refineries 1.0 INTRODUCTION In accordance with the requirements of Section IX of the Consent Decree entered in UNITED STA TES OF AMERICA ET AL, D, V.M NAVAJO REFINING COMPANY, LP, AND MONTANA REFINING COMPANY(entered March 5, 2002), Navajo submits the following "calendar quarterly report" for the Artesia and Lovington, NM refineries. Section !X requires that the quarterly report be submitted within 30 days following the calendar quarteL Today's report covers actions through the fourth quarter 2017. For completeness, this report addresses relevant actions or activities not just within the current quarter but anytime after the December 20, 2001 Date of Lodging, The contents of this report include: 1. 2. 3. 4. 5, A progress report on the implementation of the requirements of Section V (Section 2,0) A description of any problems antlclpated with respect to meeting the requirements of Section V (Section 3.0) A summary of the emissions data as required by Section V (Section 4.0); A description of environmentally beneficial projects and SEP implementation activity during this reporting period (Section 5.0); and Such other matters as Navajo believes should be brought to the attention of EPA (Section 6.0). Summaries showing the progress on Consent Decree Appendices G and H are provided as Attachments 1 and 2, respectively. 1 HFNA-000001717 EPA Inspection Report - Page 1056 of 1969 Hol!yFrontier Navajo Refining LLC, 2.0 rtesia and Lovington Refineries PROGRESS REPORT ON IMPLEMENTATION OF SECTION V OF THE CONSENT DECREE A. Section V, Paragraphs 11 and 14: NOx and CO Emission Reductions from FCCUs Paragraph 12: S02 Emission Reductions from FCCUs Paragraph 13: PM Emission Reductions from FCCUs Artesia FCCU (No FCCU at lovinqton): Requirement CD Status/Comment Para.graph -----,+---""--.!L---;f.---------------········································· Begin baseline period, Requirement completed. The optimization period 11.B perform notices of low- NOx was completed and the optimized addition rate to be used during the demonstration period was promoter and optimization study. Baseline period data submitted to EPA with supporting documentation on collection from 1/1/04 -2/24/05, 6/30/04. Optimization period to commence no later than _)une ..30.,...2004 ................................................................... 11.D ······-·r-As·-,;-g·reed-between Nava}o···and EPA, the Commencement of NOx Additive Demonstration Demonstration Period ended 05/31/2006. Navajo Period and reporting submitted proposed concentration-based NOx limits beginning 3/31/05, on 07/27/2006. '--------------"'------..L------------·-·-······················································· 2 HFNA-000001718 EPA Inspection Report - Page 1057 of 1969 -----------------~w--------- Requirement CD Status/Comment Paragraph ! Install/certify CEMS to monitor FCCU NOx and 02 by 12/31/03. 11 .F CEMS installed and certification RATA performed 11/13/03. Report showing initial certification submitted to NMED on 1/7/04. Pursuant to 40 CFR 60 App F, annual RATA performed 02/14 and 02/i 5/06. Report showing certification submitted to NMED on 03/15/06. Pursuant to 40 CFR 60 App F, annual RATA performed 01/24/07. Report showing certification submitted to NMED on 02/22/07, Pursuant to 40 CFR 60 App F, annual RATA performed 01/22/08. Report showing certification submitted to NMED on 02/18/08. Pursuant to 40 CFR 60 App F, annual RATA performed 03/03/09, Report showing certification submitted to NMED on 03/30/09. Pursuant to 40 CFR 60 App F, annual RATA performed 03/02/2010 and 03/03/2010. Report showing certification submitted to NMEO on 04/05/2010, Pursuant to 40 CFR 60 App F, annual RATA performed 03/01/2011. Report showing certificatlon submitted to NMED on 03/28/2011. Pursuant to 40 CFR 60 App F, annual RATA performed Oi /17/2012, Report showing certification submitted to NMEO on 02/17/2012, Pursuant to 40 CFR 60 App F, annual RATA performed 01/08/2013, Report showing certification submitted to NMED on 02/07/2013. Pursuant to 40 CFR 60 App F, annual RATA performed 01/08/2014. Report showing certification submitted to NMED on 02/04/2014, Annual RATA performed Oi/06/2015. Report submitted to NMED on 02/05/2015. Annual RATA performed 01/05/2016, Report submitted to NMED on 02/04/2016. Annual RATA performed 01/03/2017, Report submitted to NMED on 02/04/2017. A review of documentation of QC procedures under 40 CFR 60 App. F was recently undertaken. Documentation of a!I QC procedures in accordance with 40 CFR 60 App. F was completed as of 12/31/2017, 3 HFNA-000001719 EPA Inspection Report - Page 1058 of 1969 Calendar Quarterly Re13ort -4th Quarter 2017 HoliyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirement ----~-- Submit plan to minimize NOx from FCCU during GOHT outages within 180 days of lodqinq Date, Install and operate wet gas scrubber on FCCU to meet 25 ppmv (annual avg) and 50 ppmv (7-day) S02 by 12/31/03.-~----Install and calibrate S0 2 GEMS in accordance wlth 40 CFR60,11, 60,13and Part 60 App. F CD Paragraph 11,G 12,8 12,D Status/Comment Submitted 6/18/02, EPA's response letter dated 12/9/04 enumerated the requirements for Navajo to have relief from the short term NOx emission limit ·-~--~---····························································--························ Wet gas scrubber installed and operational during 4th Quarter 2003, S0 2 performance testing done i 0/16/03; report submitted 1/7 /04, ··•··························· CEMS installed and certification RATA performed 11 /13/03, Report showing initial certification submitted to NMED on 1/7/04, Pursuant to 40 CFR 60 App F, annual RATA performed 02/i 4 and 02/15/06. Report showing certification submitted to NMED on 03/15/06, ! Pursuant to 40 CFR 60 App F, annual RATA i performed 01/24/07, Report showing certification submitted to NMED on 02/22/07, Pursuant to 40 CFR 60 App F, annual RATA performed Oi/22/08. Report showing certification submitted to NMED on 02/i 8/08, Pursuant to 40 CFR 60 App F, armuai RATA performed 03/03/09, Report showing certification submitted to NMED on 03/30/09, Pursuant to 40 CFR 60 App F, annual RATA performed 03/02/2010 and 03/03/2010. Report showing certification submitted to NMED on 04/05/2010 Pursuant to 40 CFR 60 App F, annual RATA performed 03/01/2011. Report showing certmcation submitted to NMED on 03/28/201 i. Pursuant to 40 CFR 60 App F, annual RATA performed 01/17/2012, Report showing certification , submitted to NMED on 02/17/2012. I Pursuant to 40 CFR 60 App F, annual RATA performed Oi/08/2013, Report showing certification 1 submitted to NMED on 02/07/2013, Pursuant to 40 CFR 60 App F, annual RATA performed 01 /08/20i 4. Report showing certification submitted to NMED on 02/04/2014, Annual RATA performed 01/06/2015, Report submitted to NMED on 02/05/2015. Annual RATA performed 01/05/2016, Report submitted to NMED on 02/04/2016, Annual RATA performed 01/03/2017. Report submitted to NMED on 02/04/2017 0 See entry for Paragraph 11 .F. regarding 40 CFR 60 A(l[!, F QC procedures, ·---······················································· 4 HFNA-000001720 EPA Inspection Report - Page 1059 of 1969 Calendar Quarterly Re9ort -4111 Quarter 2017 HoliyFrontier Navajo Refining LLC, Artesia and Lovington Refineries - -------------------------------------------------------------,-----------,----------------------............., Requirement ••••••••••••••• CD Paragraph Status/Comment 13.B Wet gas scrubber installed and operational during 4th Quarter 2003. PM testing completed 11 /13/03 and report submitted 1/7/04. Results of 0.5-0.6 lb PM per 1,000 lb coke bum compared to <1.0 lb PM per 1,000 lb coke bum standard. Additional testing was performed 3/3/04 foHowing repairs to the scrubber. These test results indicate <0.25 lb PM per 1,000 !b coke burn (Le., 25% of standard), •••••••••••••••••••••••••••••••••••••••••••••••••••••••••--•A------~~~-+-----------------------------------1 WGS shall achieve 1 lb PM per 1000 lb coke bum on 3-hr basis by 12/31 /03. 5 HFNA-000001721 EPA Inspection Report - Page 1060 of 1969 Calendar Quarterly Report _4th Quarter 2017 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries ·· ················Requ°fr®m®"i,r·····-····················· ·············· ctf·············:·····························································s1:afiis1i;"6"inm®ni"····· ··················-·············· . Meet 500 ppmv CO on 1-hr basis and 100 ppmv on annual avg. by 12/31/03. Install/Certify CEMS for FCCU CO and 02 by 12/31/03. ............. Paragraph ....i.................................. 14.B and 14.C ····················-···-! ···················································-························· ··································-.:::-1 CO performance testing conducted 10/16/03. CEMS • installed and RATA performed 11/13/03. Report · showing certification submitted to NMED on 1/7/04. Pursuant to 40 CFR 60 App F, annual RATA performed 02/14 and 02/15/06. Report showing certification submitted to NMED on 03/15/06. Pursuant to 40 CFR 60 App F, annual RATA performed 01/24/07. Report showing certification submitted to NMED on 02/22/07. Pursuant to 40 CFR 60 App F, annual RATA performed Oi/22/08. Report showing certification submitted to NMED on 02/18/08. Pursuant to 40 CFR 60 App F, annual RATA petformed 03/03/09, Report showing certification submitted to NMED on 03/30/09. Pursuant to 40 CFR 60 App F, annual RATA performed 03/02/2010 and 03/03/2010. Report showing certification submitted to NMED on 04/05/2010. Pursuant to 40 CFR 60 App F, annual RATA performed 03/01/2011. Report showing certification submitted to NMED on 03/28/2011. Pursuant to 40 CFR 60 App F, annual RATA performed 01/17/2012. Report showing certification submitted to NMED on 02/17/2012. Pursuant to 40 CFR 60 App F, annual RATA performed 01/08/2013. Report showing certification submitted to NMED on 02/07/2013. Pursuant to 40 CFR 60 App F, annual RATA performed 01/08/2014. Report showing certification submitted to NMED on 02/04/2014. Annual RATA performed 01/06/2015. Report submitted to NMED on 02/05/2015. Annual RATA performed 01/05/2016. Report submitted to NMED on 02/04/2016. Annual RATA performed 01/03/2017. Report submitted to NMED on 02/03/2017. See entry for Paragraph 11.F. regarding 40 CFR 60 App. F QC procedures. 6 HFNA-000001722 EPA Inspection Report - Page 1061 of 1969 Calendar Quarterly Report _4th Quarter 2017 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries EL Section V, Paragraph 15: NSPS Applicability of FCCUs Artesia FCCU No FCCU _at.Lovington): .............................................. Requirements CD Status/Comment ,........------------+------P_aragraph................................................................................................................ NSPS becomes applicable to 15 Wet gas scrubber installed and operational during 4th Quarter 2003. PM performance testing, initial FCCU for S0 2 , PM, CO and opacity on 12/31/03. CEMS cetiification RATA for S02 and CO completed 11/13/03 and report submitted 1/7/04. AMP for opacity submitted 12/31/03; pending wrttten approval. Method 9 readings indicate O 5°/o opacity. Annual PM testing per AMP was performed 2/8/05 indicating 0. 11 lb PM/1000 lb coke. Annual PM testing per AMP was performed 2/15/06 indicating 0.19 lb PM/1000 lb coke. Annual PM testing per AMP was performed 1/24/07 indicating 0.34 lb PM/1000 lb coke. Annual PM testing per AMP was perforrned 1/22/08 indicating 0.13 lb PM/1000 lb coke. Annual PM testing per AMP was performed 3/3/09 indicating 0.47 lb PM/1000 lb coke burned, Annual PM testing per AMP was performed 03/02/2010 and 03/03/201 OJndlcatlng 0.54 lb PM/1000 lb coke burned, Annual PM testing per AMP was performed 03/01/2011 indicating 0.23 lb PM/1000 lb coke burned, Annual PM testing per AMP was performed 01/17/2012 indicating 0.39 lb PM/1000 lb coke burned. Annual PM testing per AMP was performed 01/08/2013, which did not show compliance, and again on 3/04/2013 indicating 0.204 lb PM/1000 lb coke burned. Annual PM testing per AMP performed 01/08/2014 indicating 0,71 !b PM/1000 lb coke burned, Report showing certification submitted to NMED on 02/04/2014. Annual PM testing per AMP performed 01/06/2015 indicating 0. 11 lb PM/1000 lb coke burned, Report submitted to NMED on 02/05/2015, Annual PM testing per AMP performed 01/05/2016 indicating 0.35 lb PM/1000 lb coke burned, Report submitted to Nrv1ED on 02/04/2016. Annual PM testing per AMP performed 01/03/2017 indicating 0.03 lb PM/1000 lb coke burned. Report submitted to NMED on 02/03/2017. ··························· ··············································· .... ............................... . .......................................... · · · · · · · - - - · · - - · - - - - - - . . . . J -·-·-·····················---- - - - - - 7 HFNA-000001723 EPA Inspection Report - Page 1062 of 1969 Calendar Quarterly Reeort -41h Quarter 2017 Ho!!yFrontier Navajo Refining LLC, Artesia and Lovington Refineries ......... Co Section V, Parn9meh 16:...N.9~.. !:;.~i.~.~io.~~R~.c.l~s;tigr,i~Jr..?.!!l... !j.1?.§t.1?.!~...and Bo_i_!_er_s_ _----. Requirements CD Status/Comment ........... ..............................Paragraph ................................................................................................................................. _ _ _ ____, Install NOx control on B-7 by 16.B.iL and FGR started up on 12/17/2002. CEMS installed 12/31/02 to meet 0.06 16.C.i. and was successfully certified by a RATA lb/MMBtu and operate CEMS performed 12/18/2002. Test results and CEMS on B-7 for NOx and 02. indicate B-7 meets NOx control requirement. Pursuant to 40 CFR 60 App F, annual RATA performed 09/26/2006, 09/13/2007, 09/09/2008, 09/17/2009, 08/24/2010, 08/16/2011, 08/i 5/2012, 08/07/2013. RATA periormed 07/30/2014. Certification report submitted to NMED on 09/11/2014. RATA performed 07 /23/20 i 5. Certification report submitted to NMED on 08/20/2015. RATA performed 07/13/2016. Certification report submitted to NMED on 08/05/2016. RATA performed 06/21/2017. Certification report submitted to NMED on 07/20/2017. ; . . . . . . . . . - - - - - - - - - - - + - - - - - · · · · ·····-······································-····················-························-·····-···-·························································· Install NOx control on 8-8 by 16-8.!i. and B-8 began actual initial startup and shakedown 12/31/03 to meet 0.06 16.C.i. period on 7/23/03. NOx contmts and CEMS !b/MMBtu and operate CEMS operational. CEMS RATA and B-8 performance on B-8 for NO.x and 02. testing done 10/29/03. Test report submitted 12/8/03. Pursuant to 40 CFR 60 App F, annual RATA performed 09/26/2006, 09/13/2007, 09/09/2008, 09/i?/2009, 08/24/2010 08/i 6/2011, 08/15/2012, 08/06/2013, 07/30/2014. RATA was performed 07/29/2014. Certification report submitted to NMEO on 09/i 1/2014. RATA was performed 07/13/2016. Certificatlon report submitted to NMED on 08/05/2016. RATA performed 06/2i/2017. Certification report submitted to NMED on 07/20/2017. ! - - - - - - - - - - - - - ~ - - · · · · · · · · ···········································································································--································· Install next-generation ultra16.B.i., H-601 burners installed. Testing conducted on low NOx control on H-20 and 16.C.tii., and 3/2/04. Report including proposed compliance H-601 at Artesia refinery. Appendix C indicators and permit limits was submitted 5/14/04. Performance test H-20 and H-20 burners installed prior to 12/31/05 deadline H-601. Establish compliance and heater resumed operation 12/29/05. indicators by an initial H-20 performance test conducted on 02/16/06. performance test. Report submitted to NMED on 03/23/06. Permit limit proposed in air perrnit application submitted to NMED on 4/27/06. NMED issued permit 6/23/06. ·---············································· 8 HFNA-000001724 EPA Inspection Report - Page 1063 of 1969 Calendar Quarterlx;; Reeort _4th Quarter 2017 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements Install next-generation ultralow NOx control on H-101 at Lovington refinery. Operate CEMS or PEMS on H-101 by i 2/31/05. Install next-generation ultralow NOx control on H-600 and 70-H1/H2/H3 at Artesia refinery, Performance test H600, and 70-H1/H2/H3. Establish compliance indicators by 12/31/09. ------- - ---------------------------------------- CD Paragraph 16B.i., 16,C.!L, and Appendix C 16.B.L, 16.C.iiL, and Appendix C Status/Comment ..••............ ....... ~ Heater H-101 was removed from service November 2003, Navajo installed NGULN8s in the new Crude Oil Charge Heater (H-103) that replaced H-i 01. H103 was completed during December 2003 turnaround and began operation after 4th Quarter turnaround. As-installed duty of NGULNBs was< 150 MM Btu/hr, but > 100 MM Btu/hr. H-103 initial testing done 03/04/04, Test report, including proposed parametric monitoring plan and permit limits, was submitted 05/14/04. In 02/2009, Navajo installed eight additional NGULNBs in the Crude Oil Charge Heater (H-103) that replaced H-101. As-installed duty of NGULNBs was > 150 MM Btu/hr, so a NOx CEMS was tnstalled. An initial performance test and the NOx CEMS RATA were conducted 05/21/2009. Pursuant to 40 CFR 60 App F, annual RATA performed 05/20/2010, 08/16/2011, 05/24/2012. RATA was performed 05/14/2013, CertificaUon report submitted to NMED on 06/10/2013, RATA was performed 05/13/2014. Certification report submitted to NMED on 06/12/2014. RATA was performed 05/06/2015, Certification report submitted to NMED on 06/04/2015. RATA was performed 05/04/2016, Certification report submitted to NMED on 06/03/2016. RATA was performed 04/25/2017, Certification report submitted to NMED on 05/16/2017, See entry for Paragraph 11 .F regarding 40 CFR 60 App. F QC procedures. ------··------············ H~600: Air permit 0195-M25-R3 authorizing the burner retrofit was issued by NMED on 05/14/08, The retrofit was completed in 02/2009. The performance test was conducted 03/04/09 and the test report submitted 03/30/09. Administrative permit revision 0195-M26-Ri effective 04/14/2009. 70~H1!H2/H3: NGULNBs were installed in CCR Heaters 70-H 1/H2/H3 in May 2006 and heaters resumed operation on 6/2/0EL Performance test conducted 7/11/06 and test report submitted 8/15/06. An application for a proposed permit limit was submitted to NMED 9/28/06, NMED issued permit PSD-NM-0195-!V125 on 12/14/2007, 9 HFNA-000001725 EPA Inspection Report - Page 1064 of 1969 Calendar Quarterly Reeort -4111 Quarter 2017 Hol!yFrontier Navajo Refining LLC, Artesia and Lovington Refineries -------------------------------------------------------- ---------------------------~----~------------------------------------------------------------------- Requirements CO Status/Comment Paragraph ------------············ ----------------------------------------------------------+-----=~---·····-·········································· ---------------················--------------~ Install next-generation ultralow NOx control on B-SG1 i 01A and B-SG-1101 Bat Lovington refinery by 12/31 /09. Conduct performance test B-SG1101 A and B-SG-1101B and establish compliance indicators. 16.EU., i6.CJiL, and Appendix C An air permit application proposing the installation of NGUlNBs in SG-1101A and SG-1101B was submitted to NMED on 12/21/2007. Permit 0273-M? authorizing the retrofit with NGULNBs was issued by NMED on 05/06/2008. Navajo subsequently decided to replace the existing boilers with new boilers using NGUlNBs. Permit 0273-M7-R1 authorizing the replacement boilers was issued by NMED on ·10/14/2009. Boiler SG-11 OB was permanently shut down on 12/05/2009. its replacement, BO-i 104, began operation on 12/17/2009, Initial performance testing was conducted 01/28/2010 on B0-1104 and the report submitted to NMED on 02/24/2010. Because of initial operating problems with B0-1104, the second boiler, SG-1101A was not permanently shut down until 01/04/2010. Its replacement, B01105, began operation on 01/15/2010. Initial performance testing was conducted 01/26/2010 on B0-1105 and the report submitted to NMED on 2/24/2010_ The B0-1105 initial performance test was conducted on i/26/2010, and the report submitted to the AQB on 02/24/2010. The 80-i 104 initial performance test was conducted on 01/28/2010, and the report submitted to the AQB on 02/24/2010. The burners installed with B0-1105 and 80-1104, were subsequently found to not meet the NGULNB performance specification in the Consent Decree, The installation or NGULNB in B0-1 i05 was completed 06/20/2013, The installation of B0-1104 NGULNB was completed 07/29/2013. BO-ii 05 NOx Pmiormance Test was completed 07 /i 2/2013. 80-1104 NOx Perfom1ance Test was completed 09/04/2013. !U HFNA-000001726 EPA Inspection Report - Page 1065 of 1969 Calendar Quarterly Report _4th Quarter 2017 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries -------------------------------------------------------------------------------------------------------------------------------------------------------...., Requirements --------------------------------------------------------------------------------------------- Submit proposed NOx permit limits within 120 days of NOx control technology installation. Submit annual progress report on NOx control technology ~~ CD Status!Comment __Paragraph _-------------------------------------------16. D Requirement completed. BM7: Proposed B-7 NOx limit submitted to NMED 01/31/03. BMf!: Proposed B-8 NOx limit submitted to NMED 12/8/03. t-MW1: Proposed H-601 NOx limit submitted 5/14/04 in stack test report and permitted in i 95M17 as issued 12/15/04. H-103 (Lovington Refinery}: Proposed H-103 NOx limit submitted 5/14/04 in stack test report; on 2/21/06 NMED issued 0273-M4 to add the NOx limit After installing additional NGULNBs in 02/2009, the limits were confirmed in the 05/21/2009 test and included in Permit 0273-M7Ri issued by NMED on 10/14/2009H-20: Proposed H-20 NOx limit submitted to NMED in air permit application on 04/27/06; permit 0195-M24 issued 06/23/06. 70~H1/H2/H3: Proposed 70-H1/H2/H3 NOx limit submitted to NMED in air permit application on 09/28/06; permit PS0-NM-0195-M25 issued 12/14/2007. HM800: Proposed H-600 NOx limit author1zed by NMED air permit administrative revision effective on 04/14/09, B0~1104 and B0-1105: (replacement boilers for B-SG-110A and B-SG-1101 B)_ Proposed 80-1104 and BO-i 105 NOx lirnits submitted to NMED in air permit application on 04/13/201 O; permit 0273-M8 issued 07/19/2010. 1 --------------1-iLE----------------+ l=frsf-i:E;-p;;rt--wa_s_ _s_i:i"bm"it°fea---f~i"h97o"iCThe---;:e-;;-;;ruor_ _ _ _ _ 2003 was submitted 12/29/03 with supp!ementa! information provided 1/8/04. 2004 report submitted 12/31/2004. 2005 report submitted 12/31/2005. 2006 report submitted 12/1 1/2006. 2007 report submitted i 2/20/2007. 2008 report submitted 12/19/2008. 2009 report submitted 12/28/20092010 report submitted 12/15/2010_ 2011 report submitted 12/31/2011. 2012 report submitted 12/11 /2012_ 2013 report submitted 12/i 8/2013. 2014 report submitted 12/19/2014. 2015 report submitted 12/31/2015 . . 2016 report submitted 12/30/2016 ortsubmitted 12/28/2017. 2017 re~ .......................- - - - - - - - - - - - - ~•-------------~ 1 11 HFNA-000001727 EPA Inspection Report - Page 1066 of 1969 Calendar Quarterly Re,,2ort _4th Quarter 2017 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries CL Section V, Paragraph 17: S0 2 Emissions Reductions from Heaters and Boilers and .....................J'1SPS ~cability········· Requirements ,_P_a_ra-":q=~-a~p_h----+--------S-ta_t_us_1_c_o_m_m_e_nt--------l. NSPS Subparts A and J 17,B Commenced 12/20/01 become applicable to Heaters See entry for Paragraph i 1.F. regarding 40 CFR and Boilers by Date of 60 App. F QC procedures. Lodging. --------····--~~~---·····---~----- ··•·•································ E Section V, Paragraphs 18 and 19 NSPS Applicability for SRP and Flari.ng .Pevices ........... Requirements CD Status!Comment ;..............................................................................................................+..... Para.graph SRP shall comply with NSPS 18.C.l. and Commenced 12/20/01. See entry for Paragraph 11,F. regarding 40 CFR J limit and monitor tall gas 18.CJL emissions by Date of 60 App. F QC procedures. Lodging. f------------..J······························· NSPS Subparts A and J become applicable to Flares by Date of Lodging. Appendix E ------------------------------------------------------------~---~----------j Commenced i 2/20/01, The recent implementation of flare monitoring requirements under NSPS Ja resulted in the identification and repair of several relief valves that were leaking to the flare. In addition, three flare gas streams with higher sulfur levels were identified as routed to the Lovington flare. These three streams were rerouted to the fuel gas system. As of November 1 i, 2015, ail gas streams currently routed to the flares are monitored for compliance with the NSPS Ja requirements. Excess emission information for the flares at Artesia and Lovington for the semiannual period: January-June 2016 was included in Attachment 4 to the 3rd quarter 20i6 Consent Decree Progress Report The excess emission information for events occurring during the semiannual period: July-December 20i 6 was included in the semiannual NSPS monitoring report submitted on January 30, 2017, and was attached to the 1st quarter 2017 Consent Decree Progress Report, Excess emission information for events occurring during the semiannual period: January-June 2017 was reported in the semiannual NSPS Ja monitoring report submitted on July 28, 2017, and were attached to the 3rc quarter Consent Decree Progress Report The excess emission information for events occurring during the semiannual period: July-December 20i 7 will be included in the semiannual NSPS monitoring report due on January 30, 2018, and will be attached to the 1st ,..............................------··--················'············································ ...... quarter .201.8 ..consent ..Decree .. Progress Report. 12 HFNA-000001728 EPA Inspection Report - Page 1067 of 1969 Calendar Quarterl:t; Reeort -41h Quarter 2017 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries ~----------~-·····························~--~··················································~·························································· ·····----------------------- CD Status/Comment I Paragraph S-ubmiTAMP---p-iardci"r_ _Fi"~:i"res---+------A-p_p......,en"'---d-i--'----x-E------+---S-u_b_m_it-te_d_3_/_19_/_0_2__------------------·-·----------------------Requirements FL-400, FL-401, FL-402 and FL-403 within 90 days of Lodging Date. --·--------------------- I----------------------------------------------;-------------------------------------------------------------------------------------------------1 NSPS Subparts A and J become applicable to Flare FL-1001 at Lovington refinery on 12/31/06. Appendix E Off-Gas Scrubber system for sweetening sour LPG before combusting in flare completed by 12/31/06. ,-......--------------,-----------------------·---·------------------------+----------------------------------------------·-----·---------------------------------------·----------------------------------------1 Submit AMP plan for Fla.re Appendix E An approvabie AMP was submitted 02/14/07. AMP i Fl--1001 at Lovington refinery is pending EPA approval. U?_y7/30/07. ________________________________________________----+-----+----------------------------------------------------18,D Submit enhanced Plan submitted on 9/16/02 and updated on Maintenance and Operation 03/24/05, The last revision was completed on pian for SRP (PMO plan) 09/2017 within 270 days of Date of ___ Lodging. _________________________________________________________________ _ ----+-----------------------------············ Begin optimization study on 18-E Study commenced by 1/1/04 deadline. SRP by 1/1/04. Complete optimization study on SRP and report results by 12/31/04. 18.E Navajo retained a third party to coordinate performance testing for the optimization study and prepare a report which was submitted to EPA on 12/31/04. 10-day prior notice required : for scheduled Duke Energy • shutdowns affecting • Lovington refinery by Date of • Lodging. 19.E Commenced 12/20/01. F. Section V, Paragraphs :20 and 21: Control of Acid Gas Flaring, Tail Gas Incidents and Hydrocarbon Flaring ---------------------------------------------------------------------------------------- Requirements ---------"--·-------~---,--------------- CD Paragraph Status/Comment ------------------------- ------- ------------------------------------------------------------------- - ~ - - - - - + - - - - - - - - - - - - - - - ····················································· Perform root cause analyses 20 Commenced 12/20/01. for acid gas and tail gas incidents beginning on lod in Date. ---~-----~-------------·--·-························································ Perform root cause analyses 21 • Commenced 12/20/01. for hydrocarbon flaring incidents beginning on Lodging Date. -----------------------------------------------------·- __ J G, Section V, Paragraph 22: Benzene Waste NESHAP 13 HFNA-000001729 EPA Inspection Report - Page 1068 of 1969 Calendar Quarterly Regort _4th Quarter 2017 Ho!lyFrontier Navajo Refining LLC, Artesia and Lovington Refineries ------------------------------ ----------------·· Requirements CD Paragraph • Complete Phase One of the •. review and verification of the TAB by 9/16/02. ~--·············--~~~---······--·~·-······························--- Status/Comment - .... 22.C.i. Completed 09/11/02, ............. -------------------------- f - - - - - - - - - - - - - ~ - - - - . . . . . , . . . . . - - , - - .......................................................................................... Submit BWN Phase One 22.CJ, Report of results submitted on 10/09/02. Compliance Review and Verification report for EPA approval by i 0/16/02. Suliinit amended..tA·--ccs,--re_p_o_rt---+--2-2-.~D-.i.-.....,.....A~m_e_n-de_d_T_A_B_r_e_p_ort_w_a_s-in-c·iided.."in. the 10/09/02 if BWN Compliance Review submittal. shows reporting applied. ---------······························································ ----------------------------·--->-----~------·--------~--- --------------------- Establish annual review program Completed as part of Phase One review and is now ongoing, 22.E --------------~~-w--••----•----------------------------- -------------------------------------·----------------------- •------------------ Train employees who conduct sampling. Submit schematics of Waste/Slop/Off-Spec Oil Management by 03/20/02, 22.G and 22,M.iLa(1) ...............:2°:i":FLC............ A training plan was developed on 12/06/02 for the Artesia Refinery (i,e,, since its TAB is greater than 1.0 Mg/yr). The first training session was held 01/07/03 at both the Artesia and Lovington refineries. The second training session for the two refineries was he!d 1/27/04 and 01/28/04, Annual refresher training for the two refineries was performed the weeks of 02/08/05, 03/27/06, 03/05/07, 02/25/08 (Lov), 11/07/08 (Art), 12/18/09, 12/17/10 and 12/20/2011, BWON TAB training was conducted on 11/08/2012 at the Artesia and Lovington refineries BWON sampling training was conducted on 01/14/2013and 04/18/2013, i1/12to 11/14/2013, 05/24/2014, 06/22/2014, 12/12/2014, 3/16/2015, 4/1/2015, 5/15/2015, 2/29/2016, 3/8/2016, 3/17/2016, and 09/25/2017. Submitted on 03/19/o"f. . .RevEiiicfschematics reflecting NSPS QQQ were submitted 04/29104. Schematics am awaiting approval by EPA --.................................................................................................................... Conduct annual sampling of waste streams which the BWN Compliance Review and Verification Report showed to be 0.05 Mg/yr or greater. 22.J.i. and 22.M.ii.a(2) -----1 The annual sampling was performed in February 2005. The results were in Attachment 4 to the first quarter 2005 report, Annual sampling performed in February 2006. The results were in Attachment 4 of the first quarter 2006 report Annual sampling was prniormed in September and December 2007, The results were submitted in attachment 4 of the first quarter 2008 report as required by 1f22.M.iLa(2), Annual sampling was performed in December 2008. The resu!ts were in attachment 4 of the first quarter 2009 report as required by 1f22.MJLa(2). Annual sampling was performed in December 2009. The results were submitted in attachment 4 _ . . . L . . . . , ._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ................................... , 14 HFNA-000001730 EPA Inspection Report - Page 1069 of 1969 Calendar Quartertx; Report _4t", Quarter 2017 Ho!lyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements CD Paragraph Status/Comment ------------·------~·-···················· ---------------------------------------------------------································- of the first quarter 2010 report as required by ,T22.MJi.a(2)_ Annual sampling was performed in December 2010. The results were in attachment 4 of the first quarter 201 i report as required by ,I22.MJLa(2), Annual sampling was performed in December 201 i, The results are in Attachment 4 of the first quarter 2012 report as required by 8'122.M.iLa(2), Annual sampling was performed in December 2012. The results were submitted in Attachment 4 of the first quarter 2013 report as required by ,T22JvLia(2). Annual sampling was performed in December 2013. The results were submitted in Attachment 4 of the first quarter 2014 report as required by 1[22.M.iLa(2), Annual sampling was performed in December 2014. The results were submitted in Attachment 4 of the f"t quarter 2015 report as required by 1f22.M.!La(2). Annual sampling was performed in December 2015. The results were included in Attachment 4 of the 1st quarter 2016 report as required by ,T22. M, iLa(2). Annual sampling was performed in October 2016. The results were included in Attachment 4 of the 1st quarter 2017 report as required by 1f22.M.iLa(2). Annual sampling was performed in December 2017. The results will be included in Attachment 4 of the 1st quarter 2018 report as required by f------------------------------------------------ ___________________________ JJ22.M.ii.a(2). Meet with NMED and EPA at the refinery and submit an annual end of line (EOL) sampling p!an - applicable to Artesia Refinery (Le., TAB is equal to or greater than i Mg/yr but less than 10 Mg/yr)- 22.J.ii ------------------------------------------- Navajo was notified by NMED and EPA via email dated 12/9/02 that the ,I22.J.ii visit by the agencies would not occura Navajo met the deadline by submitting the EOL sampling plan on 2/6/03. Conditional approval of the plan was received from EPA by letter dated 1/23/04. Navajo responded by submitting a revised EOL sampling plan by letter dated 3/31 /04. ---~------------------------------------------- 15 HFNA-000001731 EPA Inspection Report - Page 1070 of 1969 Ho!lyFrontier Navajo Re ining LLC, Artesia and Lovington Refineries -~----~---······················································ Requirnmonts Status/Comment CD Paragraph ------······················· Conduct quarterly EOL sampling and submit the results to EPA in quarterly report --+-----+----······-················································· 22.J.HL and 22,MJLa(3) These requirements are not applicable until EPA approves the sampling plan, Although EPA has not approved or commented on the revised sampling plan submitted 03/31/2004, Navajo conducted its first EOL sampling during the week of 3/22/2004. The EOL benzene quantity (BO) for the fourth quarter of 2004 was 0.8 Mg (projected annual< 10 Mg}. The annual TAB, submitted 4/05 was 4.9 Ma for Artesia and 1.5 Mg for Lovington. The 1"\ 2n~ 3rd, and 4tr, quarter 2005 EOL BQs were each <25 Mg. The 1'"', 2nd, 3rd, and 4th quarter 2006 EOL BQs were each <2.5 Mg. The 1st, 2nd, and 3rd quarter 2007 EOL BQs were each <2.5 Mg. The 4,n quarter 2007 EOL BQ result was greater than2.5 Mg. The rsr quarter 2008 EOL BQ result was less than 2.5 Mg. The 2"ct and 3rd quarter 2008 EOL BQ results were both greater than2.5 Mg. The EOL BQ for the 4th quarter of 2008 was <2.5 Mg and the projected 2008 TAB was 85°/o was developed internal leak definition of and c. and these pumps are using the 2,000 ppm leak : 2,000 ppm in accordance with definition for all monitoring subsequent to 12/20/03. • phased-in schedule - i.e., Ail pump monitoring using internal leak definition of Ji 50%, by 6/20/03, 85% by 2,000 ppm after 4/20/05. ------------·»·-----'------..L.....--------------····· ··-~---································ 18 HFNA-000001734 EPA Inspection Report - Page 1073 of 1969 Calendar Quarterly Report _4th Quarter 2017 ..... "',,. HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements - - - - - - - - - - - - - - - · - · · · · · · · · · · · · · · · · · · · · ·................................................ CD Paragraph ---<-------------·····················------------------------········· ····· 12/20/03, and 100°/o by \ 4/20/05 .......................................................................................................... -------------------- NSPS Subpart GGG becomes applicable to Crude vent compressor at Lovington refinery as of Date of Status/Comment 23.E!ii ·--------------··························································· ···· • This was completed upon CD lodging, Crude Vent • Compressor (C-150A/B) is now included in the • LOAR monitoring program. ..lodging. ·---················································ ............................................................................................. ................................................ First attempt at repairs on 23.G i Commenced with January 2002 quarterly valves that have voe reading I monitoring. > 200 ppm within 90 days of ~ I lodninn Date. I ............... ~.....n ............................................................................. t,.......... ............................ ................................ . --·················· Quarterly monitoring of valves · 23.H.iL Completed by i 2/20/01, - no Skip Period by Date of Lodging~_ _ -------<---········································································································ .................................................................... LOAR database to include 23.1.i, Commenced with May 2002 monitoring, date, time, operator, and instrument within 6 months of ················-----------~ Date of Lodging. ································- ......................................................................................................................................................... • Submit operational 23.1.iL, and Submitted 6/19/02. • spedfications designed to 23.0.Lb . • minimize non-electronic data • collection and transfer within 6 months of Date of Lod. in. .;........................................... ······································································································································ Develop/ implement 23.J Procedure developed on 3/19/02 and included as procedure for LOAR data an appendix in the written LDAR program. QA/QC within 90 days of • .. Lodginfl_.Date,_............................................................................................................................................................................................................ Establish accountable LDAR 23.K Completed by 12/20/0i. personnel by Date of Lodging. . .................................. Establish tracking program for This program was established by 4/i 9/02 and is 23.L adding new pumps and described in the written LOAR program, valves to LDAR program within 120 days of Date of L. .. lodginn.... ··························-··----+-----·-········ ........................................................................................................................................................ Conduct calibration/drift Commenced on i2/20/01, assessments of monitoring instruments at the end of each shift by the Date of ...Lodging ........................................................ Com me need on 12/20/0 i. : More stringent delay of repair 23.N.ii. • requirements including drill • and tap for valves reading • >10,000 ppm by Date of Lodging. ··············································································································'········································-···~--·····--------····--·--··-········---·-·······················································' i9 HFNA-000001735 EPA Inspection Report - Page 1074 of 1969 £.aiendar Quarterly Report -41h Quarter 2017 Ho!lyFrontier Navajo Refining LLC, Artesla and Lovington Refineries --------·-······················· Requirements Status/Comment CD Paragraph ----------····························· ........................• ·································-····· ··········-······ Submit written facility-wide 23.0.i.2t I Submitted 05/i 3/2002. LOAR compliance program b 5/19/02. ----------------------------------------+--------+----------- --·······································--· Submit LOAR report with 23. O,iLc. The monitoring results were incorporated into the MACT Periodic reports. periodic reports submitted pursuant to 40 CFR 63.654 on: 3/15/02, 9/13/02, 3/15/03, 9/i 5/03, 3/15/04, 9/15/04, 3/14/05 (3/15/05 for Lovington), 9/i 3/05 (9/15/05 for Lovington), 3/17 /06, 9/13/06 (9/06/06 for Lovington), 3/16/07, 09/14/07, 3/17/08, 9/12/08, 03/16/09, 08/27/09, 03/16/2010, 09/13/2010_, 03/16/2011, 03/09/2012 and 09/06/2012 (09/06/2012 for Lovington), 03/15/2013, 09/16/2013, 02/25/2014 (Artesia), 08/26/2014 (Lovington), 02/26/2015 (Artesia and Lovington), 08/27/2015 (Artesia and Lovington), 02/18/2016 (Artesia and Lovington), 08/29/2016 (Artesia and Lovington), 02/28/2017 (Artesia and Lovington), and 08/29/2017 (Artesia and Lovington). ~---------~---······························································································ ········································································ L .......~§1.~ti.?.~...Y.\. F..?E.?.SE.i:!P.~?4: Incorporate CD Requirements into Enfon::eabl~..:P..~.r..~.it~. . . . . . . . . . . . Requirements CD Status/Comment -----------------------------------------------------~ ············································--·-····-······································· ..... Parngrnph • Within 180 days of Date of 24.A Applications to revise the NSR permits for the · Lodging, submit an Artesia and Lovington refineries were submitted \ application for Federally II 5/28/02. Permit revision issued for Lovington on . enforceable NSR permit to • 10/15/03. Permit revision for Artesia issued incorporate of limits, • 12/15/04. standards, or schedules effective on the Date of Lodging. Submit applications within 30 24.B • Navajo's understanding is that 'fri6 NOx limits for days of the effective date or : boilers and heaters, which require permit establishment of limits, application filing within 120 days after start-up standards, or schedules under 1T16.D, are not subject to ,I24$. No other pursuant to the CD. limits under Section V have occurred to date. L..L------------~----········-'-·-·················-·-····-·-·············-··················· ··········································································· Section V, Paragraph 25: ..... r · Obtaining Construction Permits ························----··--~-~-----·························· ····································· Requirements CD Status/Comment Paragraph ················-- ········································ ························-·--------+------+------------··················· ········································· Requirement Completed, • Utilize best efforts to obtain 25 • construction permits to • implement control projects The 5/28/02 NSR permit revision application for the : • required by the_C_D_._ _ _ _~ - - - - - __!2rtesia_refinery represented_the ..instal!ation.of.the..... · 20 HFNA-000001736 EPA Inspection Report - Page 1075 of 1969 Calendar Quarterly Reeort -4'h Quarter 2017 HoliyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements ----------------------~~~··························. CD Status/Comment Paragraph •------------------------------------------------------------------------------------------------------------------•------t---------------------······························· FCCU wet gas scrubber, Navajo submitted an application to NMED on 4/9/03 to install a new crude heater (H-103) at the Lovington refinery. The permit was issued 10/15/03. H-103 began operation in 12/03. Since heater H-103 replaced H-101 (Le., the existing crude heater whlch requires burner retrofit by 12/05 under the CD) and uses NGULNBs, this effectively achieves early implementation of the NOx emission reductions sought by the CD, In order to retrofit heater H-20 with NGULNB by 12/31/05, Navajo submltted a significant revision air permit application to NMED on 04/12/05. Since NMED had not completed the application review, a waiver allowing limited construction activities to begin was granted on 10/i 1/05. Permit 0195-M21, authorizing NGULNB for H-20, was issued by NMED on 11/18/05. An air permit application proposing the installation of NGULNBs in 80-1105 (formerly SG-1101A) and B0-1104 (formerly SG-1 i 018) was submitted to NMED on 12/21/2007. Permit 0273-M? authorizing the NGULNBs in SG-1101A and SG-1101 B was issued by NMED on 05/06/2008. Navajo subsequently decided to replace the mdstlng boilers with new boilers using NGULNBs. Permit I 0273-M7-R1 authorizing the replacement boilers ' was issued by NMED on 10/14/2009. The installation of NGULNB in B0-1105 was completed 06/20/2013. The installation of B0-1104 NGULNB was completed 07/29/2013. H-600: Air permit Oi95-M25-R3 authorizing the 051 I___________________________________________________________________________________________________________________________ - - .. ~--~~-~-~-:____________ _ ~~~n~;t~~;rt1~::~~;~~~:ri1 ~~j~~o~~ 3.0 SUMMARY OF ANTICIPATED PROBLEMS IN IMPLEMENTING THE REQUIREMENTS OF SECTION V. None at this time. 21 HFNA-000001737 EPA Inspection Report - Page 1076 of 1969 Calendar Quarterly Regort -41ti Quarter 2017 HollyFrontier Navajo Refining LlC, Artesia and Lovington Refineries 4J) SUMMARY OF EMISSIONS DATA @ @ @ @ @ @ * * * @ * @ @ ® ® * @ @ $ @ ® The Boiler B-7 initial performance stack test and CEfV1S RATA was conducted on 12/18/2002 and the results submitted to the NMED on Oi/31/2003. The Boiler B-8 initial performance stack test and CEfV1S RATA was conducted on i 0/29/2003 and the results submitted to the NMED on 12/08/2003. The Heater H-601 initial performance stack test was conducted on 03/02/2004 and the results were submitted to the NfV1ED on 05/14/2004. The Heater H-103 (replacement for H-101) initial performance stack test was conducted on 03/04/2004 and the results were submitted to the NMED on 05/14/2004. Data was collected for reporting pursuant to Paragraph 11 (e.g., FCCU NOx optimization and demonstration period data.) NOx Additive Demonstration Period report with proposed NOx concentration-based limits submitted 07/27/2006. The FGCU Regenerator Scrubber GEMS RATA was conducted on February i 4 and i 5, 2006 and the results were submitted to the NMED on 03/i 5/2006. The FGCU Regenerator Scrubber annual PM test was conducted on 02/15/2006 and the results were submitted to the NMED on 03/15/2006< Heater H-20 was retrofit with NGULNBs in December 2005. A peiformance stack test was conducted on 02/16/2006 and the results were submitted to the NMED on 03/23/2006. Heaters H-352, H-353, and H-354 (formerly identified as 70-Hi/H2/H3) were retrofit with NGULNBs in June 2006. A performance stack test was conducted on 07/11/2006 and the results were submitted to the NMED on 08/15/2006. The Boller B-7and Boiler B-8 annual GEMS RATAs were conducted on 09/26/2006 and the results submitted to the NMED on 10/17/2006. The FCCU Regenerator Scrubber GEMS RATA was conducted on 01/24/2007 and the results were submitted to the NMED on 02/22/2007. The FCCU Regenerator Scrubber annual PM test was conducted on 01/24/2007 and the results were submitted to the NMED on 02/22/2007. The Heater H-20 annual pe1iormance stack test was conducted on 01/25/2007 and the results were submitted to the NMED on 02/22/2007. The Boiler B-7and Boiler B-8 annual CEMS RATAs were conducted on 09/13/2007 and 09/12/2007 respectively, and the results submitted to the NMED on i0/1 i/2007. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/22/2008 and the results were submitted to the NMED on 02/18/2008. The FCCU Regenerator Scrubber annual PM test was conducted on 01/22/2008 and the results were submitted to the NMED on 02/18/2008, The Heater H-20 annual performance stack test was conducted on 01/23/2008 and the results were submitted to the NMED on 02/i 8/2008. The Boiler B-7and Boiler B-8 annual CEMS RATAs were conducted on 09/09/2008 and the results submitted to the NMED on 10/09/200!3The FCCU Regenerator Scrubber GEMS RA TA was conducted on 03/03/2009 and the results were submitted to the NMED on 03/30/2009. The FCCU Regenerator Scrubber annual PM test was conducted on 03/03/2009 and the results were submitted to the NMED on 03/30/2009, Heater H-600 was retrofit with NGULNBs in 02/2009. The Heater H-600 initial performance stack test was conducted on 03/04/2009 and the results were submitted to the NMED on 03/30/2009, 22 HFNA-000001738 EPA Inspection Report - Page 1077 of 1969 Calendar Quarterly Report _4th Quarter 2017 Ho!lyFrontier Navajo Refining LLC, Artesia and Lovington Refineries @ @ @ 1111 1111 1111 e e @ @ @ @ @ @ @ 1111 1111 e e @ @ @ @ @ The Heater H-20 annual performance stack test was conducted on 03/05/2009 and the results were submitted to the NMED on 03/30/2009. After adding additional burners, the Heater H-103 (replacement for H-101) performance stack test and NOx CEMS RATA was conducted on 05/21/2009 and the results were submitted to the NMED on 06/22/2009. The Boller B-?and Boiler B-8 annual CEMS RATAs were conducted on 09/17/2009 and the results submitted to the NMED on 10/14/2009. The B0-1105 (replacement boiler for Lovington boiler BSG-110iA) initial performance testing was conducted 01/26/2010 and the report submitted to NMED on 02/24/2010. The B0-1 i 04 (replacement boiler for Lovington boiler BSG-1101 B) initial performance testing was conducted 01/28/2010 and the report submitted to NMED on 02/24/2010. The FCCU Regenerator Scrubber CEMS RATA was conducted on 03/02 and 03/2010 and the results were submitted to the NMED on 04/05/2010, The FCCU Regenerator Scrubber annual PM test was conducted on 03/02 and 03/2010 and the results were submitted to the NMED on 04/05/2010, The Heater H-20 annual performance stack test was conducted on 03/04/2010 and the results were submitted to the NMED on 04/05/2010. The Heater H-103 (replacement for H-101) NOx CEMS RATA was conducted on 05/19/2010 and 05/20/2010, and the results were submitted to the NMED on 06/16/2010. The Boiler B-7and Boiler B-8 annual CEMS RATAs were conducted on 08/24/2010 and the results submitted to the NMED on 09/14/2010, The FCCU Regenerator Scrubber CEMS RATA was conducted on 03/01/201 i and the results were submitted to the NMED on 03/28/2011, The FCCU Regenerator Scrubber annual PM test was conducted on 03/01/2011 and the results were submitted to the NMED on 03/28/2011. The Heater H-20 annual performance stack test was conducted on 03/02/2011 and the results were submitted to the NMED on 03/28/2011, The Boiler 8-7and Boiler B-8 annual CEMS RATA's were conducted on 08/16/2011 and the results submitted to the NMED on 09/16/201 i. The Heater H-103 (replacement for H-101) NOx CEMS RATA was conducted on 05/3/2011 and the results were submitted to the NMED on 05/31/2011, The Heater H-20 annual performance stack test was conducted 011 01/19/2012 and the results were submitted to the NMED on 02/27/2012. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/17/2012. Report showing certification submitted to NMED on 02/17/2012. The FCCU Regenerator Scrubber annual PM test was conducted on Oi/17/2012, Report showing crniification submitted to NMED on 02/17/2012, The Heater H-i03 (replacement for H-i01) NOx GEMS RATA was conducted on 05/24/2012, and the results were submitted to the NMED on 06/20/2012, The Boller B-7and Boiler 8-8 annual CEMS RATA's were conducted on 08/15/2012 and the results subrnitted to the NMED on 09/13/2012, The Heater H-20 annual performance stack test was conducted on 01/09/2013 and the results were submitted to the NMED on 02/07/2013, The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/08/2013. Report showing certification submitted to NMED on 02/07/2013, The FCCU Regenerator Scrubber annual PM test was conducted on 01/08/2013. Report showing certification submitted to NMED on 02/07/2013. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATA was conducted on 05/14/2013, and the results were submitted to the NMED 011 06/10/2013. 23 HFNA-000001739 EPA Inspection Report - Page 1078 of 1969 Calendar Quarterly Report _4th Quarter 2017 Ho!lyFrontier Navajo Refining LLC, Artesia and Lovington Refineries ® ® ® ® ® ® e e e * * @ @ ® ® ® ® ® e e * @ ® ® The FCCU Regenerator Scrubber annual PM was retested on 03/05/2013. Report showing certification submitted to NMED on 04/0i/20i3. The Boiler B-7annual GEMS RATA's was conducted on 08/07/2013 and the results submitted to the NMED on 09/17/2013. The Boiler B-8 annual CEMS RATA's was conducted on 08/06/2013 and the results submitted to the NMED on 09/17/2013. The Heater H-20 annual petformance stack test was conducted on 01/09/2044 and the results were submitted to the NMED on 02/04/2014, The FCCU Regenerator Scrubber annual PM was tested on 01/08/2014. Report showing certification submitted to NMED on 02/04/2014. The FCCU Regenerator Scrubber CEMS RATA was conducted on Oi/08/2014. Report showing certification submitted to NMED on 02/04/2014. After the instaHation of NGULNB was completed, the B0-1105 (replacement boiler for Lovington boiler 8SG-1101A) initial performance testing was conducted 07/12/2013 and the report submitted to NMED on 08/06/2013. After the 1nstal!ation of NGULNB was completed, the BO-i 104 (replacement boiler for Lovington boiler BSG-11018) 1nitial performance testing was conducted 09/04/2013 and the report submitted to NMED on 12/05/2013. The Heater H-103 (replacement for H-10i) NOx and CO GEMS RATA was conducted on 05/13/2014, and the results were submitted to the NMED on 06/12/2014. The Boiler B-7annual CEMS RATA's was conducted on 07/30/2014 and the results submitted to the NMED on 09/11/2014. The Boiler B-8 annual CEMS RATA's was conducted on 07/29/2014 and the results submitted to the NMED on 09/11/2014. The Heater H-20 annual performance stack test was conducted on 02/17/2015 and the results were submitted to the NMED on 03/09/2015. The FCCU Regenerator Scrubber annual PM was tested on 01/06/2015. Report showing certification submitted to NMED on 02/05/2015. The FGCU Regenerator Scrubber CEMS RATA was conducted on 01/06/2015. Report showing certification submitted to NMED on 02/05/2015. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATA was conducted on 05/06/2015, and the results were submitted to the NMED on 06/04/2015. The Boiler 8-7 annual CEMS RATA's was conducted on 07/23/2015 and the results submitted to the NMED on 08/20/2015. The Boiler 8-8 annual CEMS RATA's was conducted on 07/22/2015 and the results submitted to the NMED on 08/20/2015. The Heater H-20 annual performance stack test was conducted on 01/07/2016 and the results were submitted to the NMED on 02/05/2016. The FCCU Regenerator Scrubber annual PM was tested on 01/05/2016, Report showing certification submitted to NMED on 02/04/2016, The FCCU Regenerator Scrubber GEMS RATA was conducted on 01/05/2016. Report showing certiflcatlon subrnitted to NMED on 02/04/2016. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATA was conducted on 05/04/2016, and the results were submitted to the NMED on 06/03/2016. The Boiler B-7 annual CEMS RATA's was conducted on 07/13/2016 and the results submitted to the NMED on 08/05/2016. The Boller 8-8 annual GEMS RATA's was conducted on 07/13/2016 and the results submitted to the NMED on 08/05/2016, The Heater H-20 annual performance stack test was conducted on 01/05/2017 and the results were submitted to the NMED on 02/03/2017. 24 HFNA-000001740 EPA Inspection Report - Page 1079 of 1969 Calendar Quarterly Reeort _4th Quarter 2017 HoliyFrontier Navajo Refining LLC, Artesia and Lovington Refineries "' "' • • • The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/03/2017. Report showing certification submitted to NMED on 02/03/2017 The FCCU Regenerator Scrubber annual PM was conducted on 01/03/2017, Report showing certification submitted to NMED on 02/04/2017. The Boiler B-7 annual CEMS RATA's was conducted on 06/21/2017 and the results submitted to the NMED on 06/20/2017 The Boiler B-8 annual CEMS RATA's was conducted on 06/21/2017 and the results submitted to the NMED on 06/20/2017, The Heater H-103 (replacement for H-101} NOx and CO CEMS RATA was conducted on 04/25/2017, and the results were submitted to the NMED on 05/16/2017, Consistent with past reports, any emissions excursions from Consent Decree llmits have generally been reported to NMED pursuant to the NSPS, MACT and/or Title V programs semiannually (as well as pursuant to NMED's excess emissions reporting program} We are in this report identifying emissions excursions that occurred in the 4th quarter 2017 for the emission limits and units below. For the flares at Artesia and Lovington, excess emission information for events occurring during the semiannual period: July-December 2017 will be reported in the semiannual NSPS Ja monitoring report due on January 30, 2018, and will be attached to the 1st quarter 20i 8 Consent Decree Progress ReporL Consent Decree Condition V.13.B FCCU PM Emission Umits 1 lb PM/ 1,000 lb Coke Bum 3-hr average . Start Time End Tirne -------------------···-·······----- Maximum recorded 3-·hour average (lb PM/ '1,000 lb Coke Bum) f-.----------··············································----- 20'17-1 i-i i '19:00 2017-11-12 06:00 7,54 2017-11-24 10:00 20'17-11-25 04:00 6BJ4 ~---+--------~---------································································ ·· Consent Decree Condition V.14.B FCCU CO Emission Limits CO 500 ppm 1-llr average r· e:,ta,,. ,. 1rne '"' ,,,._.,.., nd ·i--irn""' · Excess Emissions per Event f---------······································································•····························· ..........(lbs) ... 2017-11-ii '18:00 2017-11-12 06:00 f---_2_-·0_17_-i_i_-2_.8_07_:0_0_ _ ··············2017·.1.1·28.08:00............1.................................. 2017-12-28 18:00 2017.12-29 20:00 3,584.31 0.68 56.48 Consent Decree Condit.ion V.18. B: SRU S0 2 Emission Hmits SRU-2 ··-······························································································································· ·············1 I SOZ 250 ppm 12·hr average Excess Emissions per Event Start Time End Time lbs ···················································· ····················-···---------+-----..,__..,___ _ __ 2017-10-07 13:00 2017·10·08 08:()0 186.19 25 HFNA-000001741 EPA Inspection Report - Page 1080 of 1969 Calendar Quarterlx:; Report-4th Quarter 2017 HoiiyFrontier Navajo Refining LLC, Artesia and Lovington Refineries 5. Implementation of ENVIRONMENTAllY beneficial Projects [Changes from Prior Quarter Italicfzed] Paragraph 35 requires certain information to be submitted for each project which has been completed, The projects for Paragraphs 30 and 32 have been completed, The foHowing summarizes the status of the completed and ongoing projects, and highlights actions taken thus far: ~=t~:i~~!~~r:;rt E~ir~~~:.,";,.~iy":~~:'~= 29: _Re~~ery-wide Compliance QQQ ] 1 L____ Pro~rj_,e_ct_ _ _ _-----+_P_a_r_agrnph _____ -------------------------------------------------------------··---! I Submit Compliance Pian I within 180 days of CD Date of I Lodging. ' NSPS QQQ becomes applicable to Artesia and Lovington individual drain systems, oil-water separators, and aggregate facilities by 12/31/03 29.A I i The plan was submitted on May 29, 2002 -----+---------------------------------------- -- 2flB Prior to 12/31 /03, Navajo began operation of the new covered wastewater separator, completed the bypass of the South Plant AP!, installed covers on Junction boxes and initiated drain inspections for the Artesia refinery. Junction boxes at the Lovington refinery were also covered and the routine inspection of drains (to assure proper water sea!) was begun, Navajo otherwise ceased the use of an open culvert for draining oily process wastewater into the sewer. !nearly September 2010, it was discovered that the storm water catch basin of the A!kylation Unit Tar Pit could still receive some oily-water and therefore could be considered as a junction box, A cover for the storm water basin was designed, constructed, and installed by 11/12/2010, !n July 2014, it was discovered that visual inspections were not conducted initially and semiannually as required by 40CFR 60.692-2 (07/11/2014 self-disclosure letter to NMED, Certified Receipt Number: 70073020000030288246). A recent third party review of the QQQ program indicated that there may be a potential issue regarding certain aspects of the drain systems at the refinery. This is currently under further evaluation, 26 HFNA-000001742 EPA Inspection Report - Page 1081 of 1969 HoHyFrontier Navajo Refining LLC, Artesia and Lovington Refineries EL Section V, Paragraph 30: Operation of the 40 LTPD SRU {SRU1} on Standby Artesia SRP (No SRU at Lovington): ·······--·---"··- - - - - - ......................................................................... ,........................................................................................................................................... Environmentally Beneficial CD Status/Comment _ _ _ _P_ro~j_ec_t_ _ _ _·-+-···Paragraph..... ,......................................................................................................................................................................... 30 i SRU1 was started up again on 5/10/03 operating at Complete installation of I a reduced rate in backup service. equiprnent on SRU 1 to allow A new i 00 long ton per day sulfur recovery unit operation in standby service by 12/31/03 (SRU3) began operating 05/11/2009, The combined capadty of SRU2 and SRU3 provides excess sulfur recovery capacity. Therefore, as an energy and emissions conservation measure, SRU1 is no ion er operatqci in standby sery_ig~.:.................. 30 Acid Gas Flaring and TGU Excess Emissions • Complete study plan on how • to limit excess TGLJ Study Pian submitted 2/27/04. Pursuant to the plan, Navajo completed the study and submitted a • emissions and Acid Gas 3/24/05 summary of the study including actions • Flaring by 2/28/04 taken and recommendations. The study results were used to update the PMO plan with the modified PMO plan included with the 3/24/05 submittal. C, Section V, Paragraph 31: !nstaiiation of Spare FCCU Wet Gas Compressor .........................Artesia .. FCC U .(No __FCCUJ:lt. Lovington): Environmentally Beneficial CD Project Paragraph ................................................................................... Status/Comment ····-····································---------·-······················ ··········································································-------------------------···························································-·----- Complete installation of spare wet gas compressor by 12/31 /03. Operate so as to • minimize the duration of AG • or HC flaring incidents during • outages of the original • compressor. 31 A spare wet gas compressor was installed during the 4th Quarter of 2003 FCCU turnaround. On 01 /07 /201 '1, Navajo's outside legal counsel submitted a request to modify or remove this paragraph, Operating procedures to minimize the duration of AG flaring were updated 04/30/2015. A preventive maintenance plan for the spare compressor C-0950 was completed on 05/11/2015. 1..................................................................................................... 27 HFNA-000001743 EPA Inspection Report - Page 1082 of 1969 falendar,,Oqg[):er!y Report _4th Quarter 2017 HollyFrontier Navajo Refining L.lC, Artesia and Lovington Refineries CL Section V, Paragraph 32: Supplemental Environmental Project (SEP) Benefiting the ________ Artesia _ Com__m_u_n_i~ty~--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- ----------------------------------Environmentally Beneficial CD Status/Comment Project Paragraph _..,______________ 32 Navajo completed the community SEP prior to the revised 9/29/03 deadline and submitted cost -certification data on 9/23/03 pursuant to Paragraph 9i. The SEP installed mechanical mixers to replace air mixers on nine asphalt storage tanks to reduce odors. The tanks were T-01·10, T-0404, T-0405, T0406, T-0409, T-0410, T-0428, T-0431, and T0432. T-0404, T-0405, T-0406, and T-0409, and T-0428 ~-----------------------'--""'---------------------------------------------•---have_been __permanent!y __removed __from __ se_rv_ic_e_._--------' Complete implementation of SEP to benefit the Artesia community by June 30, 2003 E Section V, Paragraph 33: ____ EMS_Base!_ine_Assessment_ for_Artesia_ _ Refinery ___ _ Environmentally Beneficial CD ' Status/Comment Project Paragraph ··········································································································-· --- ~----------------------------------------------······················ · Obtain NMED approval for 33.C • Completed via letter from NMED dated 4/19/02. Independent Contractor to perform the baseline assessment -------+------.-------------------------------------------------------------------------------------------------------------------------------------------------------------------Execute contract with 33.D • Completed as of 4/15/02 ___!ndependent __Contractor -+----------,...-----------------------------------------------------------------------------------------------------------------------------------------------------------Baseline Assessment Report 33.E I Navajo received the baseline assessment report on \ to be received by Navajo 7/17/02. · within 2i O days of Date of Lodging I i 33_F Navajo has accepted the recommendations and Navajo to implement schedule deadlines provided in the baseline report . recormnendatlons in (the 8 recommendations are numbered in • accordance with the baseline parenthesis in the discussion below). For the two • report schedule (i.e., 1A and 5) recommendations with 10/1/02 deadlines, Navajo implemented both on time (i.e., prior to the deadline). The report to file requked by CD 1[33.F.H was completed 12/27/02. 1 . l ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- 28 HFNA-000001744 EPA Inspection Report - Page 1083 of 1969 Calendar Quarterly Report _4th Quarter 2017 Ho!lyFrontier Navajo Refining LLC, Artesia and Lovington Refineries ···········-·············---~·······················-·····-· -----------------------------------·······-- --- Environmentally Beneficial Project CD Paragraph Status/Comment r - - - - - - - - - - - - - - f . . . - - - · · · · · · · · · · · · · · · ------------------------------------------------------·-·-c--c---c---cc----cc-c--~-----········· ·················· Navajo to implement recommendations in accordance with the baseline report schedule - Cont'd ----------························ Navajo to implement recommendations in accordance with the baseline report schedule -Cont'd 33.F Navajo did the roll-out of the refinery environmental policy (1 B) and put environmental responsibilities (3) into a new specifically developed operator's manual prior to the baseline report recommendation deadline (i.e., 2/i/03 and 3/1/03, respectively). - - - + - - - - - - - - - - - - - - - - · · · · · · · · · · · · · · · · · --------------------------------· 33.F The position descriptions (6) which were recommended for Navajo's Environmental Affairs Department staff were prepared and distributed prior to the 7/1/03 deadline. An independent consultant performed an on-site evaluation of Navajo's implementation of the recommendations and prepared a 6/23/03 evaluation report prior to the 6/30/03 deadline. ------<----·-··························· ···························································--··------·-· -----------·---------·-·· Navajo to implement 33. F recommendations in accordance with the basel!ne report schedule - Cont'd f - - - - - - - - - - - - - ------------------------··········-------Navajo to implement recommendations in accordance with the baseline report schedule -Cont'd Navajo to implement recommendations in accordance with the basel!ne report schedule -Cont'd 33.F _ _ _. . . J . __ _ _ _ _ _ _ _ _ _ _ Per the independent consultant's June 2003 evaluation report, the 9/1/03 original deadline for the recommended CBT training module (2) was revised to 3/1/04. Work commenced in November 2003 on developing the CBT training module (2). The CBT module was completed and rolled out on 2/27/04, thus meeting the 3/1/04 deadline. The decision was made to implement (7) via the electronic option (6/1/04 deadline). Recommendation No. 8A, "Develop Environmental Records Retention Policy and Document Control Procedures"' was implemented prior to the 12/1/03 deadline. Completed the evaluation of the LOAR program, process and procedures ( 4) on 6/3/04 and determined that the program is working as intended. Integrated compliance requirements calendar (7) was implemented prior to the 6/1/04 deadline, Completed work to implement the environmental records management system (SB) during May 2004 with the aid of an outside consultant. The records management system is in place and working, An independent consultant conducted the implementation evaluation presented in a June 30, 2004 report, thus meeting the deadline. A final closure letter on the EMS improvement recommendations was issued September 30, 2004 by the consultant concluding no remaining EMS improvement actions for Navajo. --------- -----------------------------------------------------·--··············································------ 29 HFNA-000001745 EPA Inspection Report - Page 1084 of 1969 Calendar Quarterly Reeort -41h Quarter 2017 HoilyFrontier Navajo Refining LLC, Artesia and Lovington Refineries 6Jl OTHER MATTERS The recent implementation of flare monitoring requirements under NSPS Ja resulted in the identification and repair of several relief valves that were leaking to the flare. In addition, three flare gas streams with higher sulfur levels were identified as routed to the Lovington flare. These three streams were rerouted to the fuel gas system. As of November 11, 2015, all gas streams currently routed to the flares are being monitored for compliance with the NSPS Ja requirements. Excess emission information for the flares at Artesia and Lovington for the semiannual period: January-June 2016 was included in Attachment 4 to the 3'0 quarter 2016 Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: July-December 2016 was included in the semiannual NSPS monitoring report submitted on January 30, 2017, and was attached to the 1st quarter 2017 Consent Decree Progress Report. Excess emission information for events occurring during the sernlannual period: January-June 2017 was reported in the semiannual NSPS Ja monitoring report submitted on July 28, 2017, and was attached to the 3 10 quarter Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: July-December 2017 wrn be included in the semiannual NSPS monitoring report due on January 30, 2018, and will be attached to the 1"1 quarter 2018 Consent Decree Progress Report Pursuant to CD Paragraph 20A.viH, Navajo is submitting a follow-up for those corrective actions that were identified in the following Hydrocarbon Fladng and Tail Gas Incident Reports and that have since been completed, Incident Ending r HCI/ TGI ,--------------.,--------------------------------------- --------------- Corrective Actions Identified in HCI/TGI Reports Status/Comment i. Establish Tower top minimum temp to drive salt and dew point out of tower, Establish dynamic dew point calculator on DCS for low alarm. Set tower top temp LL at 350 F until then. 2, Monitor and report salt point and dew point on monthly unit report and ensure top temp is above salt and dew point 3. Evaluate oil/water separation in D3405 and D-3411. 4. Create inspection plan for stripper tower to monitor if corrosion is occurring. 5. Evaluate need for inspection of the lower at next cat change. 6. Complete comparison with sister units. Items 1 and 2 were completed on 06/29/2017 and 12/15/2016, respectively and were previously reported. Item 4 completed on 01/23/2017. Item 5 was completed on 08/29/2017. The completion of items 3 and 6 ls scheduled for 07/22/2018. i e-----------------i----------------1---------------------------------------------------------------------------------------------------...... ___ .... _...... --...... _.. ____________ .......... _.. _______ _ 07/27/201(3 HCI 30 HFNA-000001746 EPA Inspection Report - Page 1085 of 1969 08/25/2046 ..... ·············H°ci" ............ i . Create Matrix to provide guidance i Corrective on conserving H2, BFW, and steam. 2. Identify potential capita! improvements to steam system. 3. Install governor to better control act\"ons···f·Z:ncf"2 were completed on 12/21/2017. !t~rn 3 was completed during the last unit turnaround, on 03/34/2017. P-831 speed. 31 HFNA-000001747 EPA Inspection Report - Page 1086 of 1969 ATTACHMENT 1 APPENDIX G SUMMARY REPORTS HFNA-000001748 EPA Inspection Report - Page 1087 of 1969 Ho11yFrontier Navqjo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 4th QC ARTER 2017 STAlTS REPORT APPENDIX G STATUS SFMMARY REPORT REPORTS, PLANS AND CERTIFICATIONS UNDER THE BENZENE WASTE NESHAP ENHANCED PROGRAJ\f PROVISIONS OF PARA.GR4.PH 22 OF THE CONSENT DECREE JN UNITED STATES ET AL, V, NAVA,JO REFINING CO. ET AL 1 Name or Summary of the Report Plan, or Certification CD SubPara No, Rqd. ("R") v. Contingent ("C"1 -~---/. BWN Compliance Rcvicv,; and Verification Report C.L R Amended B WN Compliance Review and Verification Repmi Cii. C One~Time (''l")v. Quarterly or w/ §63.654 Reports ("> l ") Due Date 270 days after Lodging Status ! Revicvr completed 09/11/2002. Report submitted 10/0912002 1 90 days after Not Yet Applicable. EPA has not requested additional sampling. completing additional sampling requested by EPA I "Tl z Amended TAB Repmi I)j Flan to comply \VI 6 BQ if T l\B equals or is greater than 10 D.ii; J.vi. C ,(' l 1 60 days after completing B\\lN Compliance Revie,v and Verification Report A.n 1-\mcnded Reporl for the itrtesia Refinery(> 1 Mg, <10 Mg) ,vas Submitted 10/09/2002 with the Verification Report 180 days after completing BVv'N Compliance Review and Verificalion Report Not Applicable unless the .4.rtesia or Lovington Refinery exceeds l O Mg/yr in the annual TAB report :r0 0 0 0 0 ..... -..,J .i:,,. (!) Pagel of 12 EPA Inspection Report - Page 1088 of 1969 HoHyFrontier Navajo Refining LLC Artesia and Lovin6Ji:on Refineries ATTACHMENT 1 TO 4th QUARTER 2017 STATUS REPORT APPENDIX G STATUS SU1Vf\fARY REPORT Name or Summary of the Report, Plan, or Certification CD !Rqd. One-Time (''] '') V. Sub- (''R") Para v. Cont- Quarterly No. ingcn! orw/ ("C") Due Date Status i R63.654 iReports I">· 1"} Compliance Ce11ification ID.iv iC ... days atter completing a11 actions necessary to come into compliance Not Applicable unless the Artesia or Lovington Refinery exceeds 10 Mg/yr in the annual TAB report · IU. R 90 days aikr Lodging Submitted on 03/! 9/2002. Revised plan reflecting plant modifications submitted 04/29/2004. Schcrnatics arc mvaiting vnitten approval by EPA. Submit revised Waste/Slop/Off-Spec Oil Schematics reflecting agreement 'Nith EPA on comments. H.i. C Mntna!iy-agreed upon time between Navajo and/or Montana Refining and EPA Not Applicable until EPA confors with Navajo on the \VashdSlop/Off-Spcc Oil Schematics. Schedule to complete installation of controls on waste management units handling organic benzene ltii. C Mutually-agreed upon time bchvccn Navajo andior Montana Refining and EPA., not to exceed 2 years Not Applicable unless the Artesia or Lovington Refinery exceeds 10 ivfg/yr in the annua 1TAB report ! Plan to quantify uncontrolled ,vastcislop/off-spec oil movements I ~ ' 5() 'vVaste/Slop/Off-Spec Oil Schematics \'i./asic "Tl i Riv. ! R I 90 days r;ftcr EPl\has Not Applicable u~til EI;~\ provides wriUcn approval of the Wastc/Slop/C:ff· approved schematlcs . Spec 011 Schematlcs. Aithough EPA has not commented on or approved · the schematics submitted under paragraph 22.1-Li, Navajo has quantified the uncontrolled waste/slop/off.spec oil rnovements in the annual NTSHAP Subpart FF Total /umual Benzene {Ti\B) report. z :r0 0 0 0 0 ..... -..,J 01 0 Page 2 of 12 EPA Inspection Report - Page 1089 of 1969 HollyFrnntier Nav11jo Refining LLC Artesia and Lovin&,.ii:on Refineries ATTACHT\'lENT l TO 4th QUARTER 2017 STATUS REPORT APl1'ENDTX G STA'TlTS SUMMARY REPORT Name or Sumrnary of the Renort, .. Plan, qr CertiJkat ion CD SubPara Rqd. ("R"') v. Contingent Onc~Timt: ("1 '') V. Quarkrly or 1vi §63.654 Reports ("> l ") Due Date Status 1 •»••········+························+··································+·····································»························»•·····"' +....,..,....,.....,...,.,...,.,...,.,,.,._,__,__. EOL Sampling Plan Li; C J.ii EOL Revised Sampling Plan LiL C .LiL As needed 2 months afrer the 22.D.iii Certification (if TAB is 10 mg/yr or greater); 90 days after submitting final B\VN Review and Verification Report (if TAB is 1 Mg/yr or more but kss than 10) EOL Sampling Plan submitted on 02/06/:?00:t If and when Naw~jo and/or Montana Refining become aware of factors Revised EOL Sampling Pian submitted 03/31 plan no longer accurately reflects EOL benzene quantity I "Tl z :r0 0 0 0 0 ->. --.J 01 ->. Applicable after refinery TAB exceeds 10 Mg!yr Plan to ensure that uncontrol)ed benzene does not equal or exceed, 6 Mg/yr or that it is minimized Lvii; C As needed 30 days aikr the (md of the quarter in which the pr~jected calendar year benzene quantity is equal to or greater ; than 6 Mg. I Not Applicable unless the Artesia or Lovington Refinery exceeds 10 in the annual TAB reporL ·- Page 3 of] 1 EPA Inspection Report - Page 1090 of 1969 HollyFronticr Navajo Refining LLC Artesia and Lovin 61:on Refineries ATTACHMENT 1 TO 4th 01JARTER 2017 STATUS REPORT APPENDIX G STATUS SUIVlMARY REPORT Name or Summary of the Report, Plan, or Certification CD Sub.Para No, One-Time Rqd. (''R") (" 1'') V, v. Cont- Quarterly ingen1 or ,v/ ("C") ; ~63 .654 Reports Due Date Status I C>t') Applicable if refinery TAB is > 1 but< l 0 Mg/yr - Plan to ensure that uncontrolled benzene docs not cqua 1 or exceed, as applicable, l O Mg./yr or that it is rninimiz.cd I "Tl z :r0 0 0 0 0 --"' -..,J 01 N J.ivJ.v C As needed 1 30 days after the end ' The 2007 4 h quarter EOL benzene quanlity exceeded 2.5 Iv1g, but the of the quarter in 1,vhich calendar year 2007 TAB did NOT exceed JO Mg. Because the calendar year is over, and the 'L\B did not exceed 10 J'vig in the calendar year, the projected calendar submittal of a plan to prevent the calendar year TAB from exceeding 10 year benzene quantity Mg, as required under 1[ 22J ,iv, becomes moot As required by 11 is equal to or greater 22.M.ii.a(3), Navajo specifically soughl EPA\; concmTcnce with this than 10 !:Vlg. interpretation but no response has been received. The FOL BQ for the 1" quarter of 2003 was <2,5 Mg and the projected 2003 TAB was < 10 Mg/yr so no plan was required. The EOL BQ for the 2"d quarter of 2008 was> 2.5 Mg and the projected tab was >· 10 lvlg/yr. The required plan was included as a supplement lo ilie 2nd quarter report Navajo specifkaUy sought EPA's concurrence with this plan but no response has been received, The FOL BQ for the 3rd quarter of 2003 \Vas> 2.5 Mg and the projected tab was> 10 lvig/yr (sec Attachment 3). The required plan was included as a supplement to the 3"' quarter report As required hyT 22JvLii.a(3), Navajo specifically sought EPA's concurrence with this plan but no response has been received. The EOL BQ for the 4th quarter of 2008 was <2.5 ?vig and the prc:jected 2008 TAB was< 10 Mg/yr so no plan was required. The EOL BQs i(X the 1"1, 2"'\ J'd and 4;h quarters of 2009 were <2-5 fv1g and the projected 2009 TAB 1,vas < 10 Mglyr so no plan was required. The EOL BQ for the 1si, 2 11d, 3", and 4th qua._rters of 2010 was <2.5 Mg and the projected 2010 TAB ,vas < 10 Mg/yT so no plan was required. The EOL BQ for the 1", 2nd, 3'd and 4ih quarters of 2011 was <2.5 Mg and the projected 2010 TAB was< i O Mg/yr so no plan is required. 11 ~ B'' . the . '"' ' h quarters o f"2f '"' " 1v:tg ···1"'ne "E'{.)L ~ '--<' ior i ··, 2''ct · , ,,,ct _1· and 4t · J 1'"'L was <1...1 am1 the projected 2010 TAB was< 10 Mg!yr so no plan is required. Paoe 4 of 12 0 EPA Inspection Report - Page 1091 of 1969 HoHyFrnntier Navajo Refining LLC J\1tesia and Lovington Refineries ATTACHMENT 1 TO 4th QUARTER 2017 STATUS REPORT APPENDIX G STATUS SUMl\iARY REPORT Name or Sumrn.ary of the Report P1an, or Certification CD SubFara No. Rqd. ("R") v. Contingent ("C") One-Time (" l ") V Quarterly or \V/ §63.654 Reports ('"> 1") Due Date Status • ., I "Tl z :r0 0 0 0 0 ..... -..,J 01 (,) •· · c t. ··' . ·· Ine EOL BQ ,or tJJe 1,: , 2rd· , 3'' and 4·'I·· quarters o! , 2013 were each <2.:i~ Mg and the projected 2012 L\B was< 10 Mg/yr so no plan was required. T' ., tne ., 1,,,· an d"'"d 1 ne E'()LBQ . J tor L quarters OT''""14 Lt/ · was < 2 ,)--.., lV.1.g anu1 t l1e proj1xtcd 2014 L\B \Vas ·<_10 MglyT so no p1an 'Nas required. 1 "l'hC(.)II3')f' i''·,'Klrs J") (aHaduncnt 4). The EOL BQ for the 4th quarter of 2016 was <2.5 Mg and lhc projected TAB for 2016 was <10 Mg/yr. The EOL BQ fr,r the 1st quarlcr of 2017 was <2.5 Mg and the projected TAB for 20 l 7 was < 10 M giyr. The EOL BQ for the 2nd quarter of 2017 was <2.5 h'Ig and the projected TAB fr)r 2017 was 1_") Due.Date IC Last day of 4°' Quarter as set forth in ~[ I. viiL (if TAB is IO mg/yr or greater); As agreed hy EPA and Navajo and./or Montana Refining (if TAB is 1 Mgiyr or more but less than 10) J.vi I- C Not i\.pplicablc unless refinery cannot take actions to keep TAB be!mv l 0 Mg./yr, I C 30 -~~y_s after receipt of No_-_:_ Applicable unless refinery cannot take actions to keep TAG belmv l 0 the Third-Party Study Mg/yr. and Compliance Revinv v1u; J.vi I J.vi; Status l 120 days after receipt of the Third-Party T./\B Study and ! Compliance Review Not Applicabk unless refiriery cannot take actions to keep TAG beknv 10 rvlgiyr. l I "Tl z :r0 0 0 0 0 ..... --.J 01 01 Page 7 of 12 EPA Inspection Report - Page 1094 of 1969 HolJyFrontier Navajo Refining LLC Artesia and Lovington Refineries A1"fAC[IIV[ENT 1 TO 4th QUARTER 2017 S1'ATLS REPORT APPENDIX G STATUS SFMMARY REPORT Name or Summary of the Reporc Plan, or Certification Report on training done in that Quarter I CD I Sub~ Pam No. CUiii.; Miia(l) Rqd. One-Time ("R'.) (" ! '') V, v. Cont-! Quarterly ingcnt or w/ C'C~'J §63.654 Rcporls ('>l'J C Q Due Date Each Quarterly Report due under the Consent Decree Status A training plan -,vas developed 12/6/02 for the Artesia Refinery (i.e., since its TAB is greater than 1.0 rvfg/yr). The first training session was held l/7/03 at both the Artesia and Lovington refineries. The second training session for the two refineries was held l/27i04 and 1/28/04. A.1111ual refresher training perfrlrmed the weeks of 2/8/05, 3127 /06, 3/5/07, 2125108 (Lov), 11/07/08 (Art), 12/18/09, 12/17/2010 and 12/20/2011, 11/08/2012, 01i14/2013, 04/18/2013 11/12 to 11/14/2013, 05/24/2014, 06/19/2014, 06/20/2014, 12/02/2014, 3/16/2015, 4/1/2015, 5/15/2015, 2/29/2016, 3/812016, 3/17/2016 (Art and Lov), 02/2812017 (Artesia and Lovington) and 08/29/20! 7 (Artesia and Lovington), I "Tl z :r0 0 0 0 0 ..... -..,J 01 0) Page 8 of 12 EPA Inspection Report - Page 1095 of 1969 HollyFrontier Nav:rjo Refining LLC Artesia and Lovin&:>ton Refineries ATTACH1VIENT 1 TO 4th QCARfER 2017 S1ATUS REPORT APPENDIX G STATUS SCMlV[ARY REPORT Resu1ts of annual sampling of >0<05 Mg/yr benzene streams I J.i; Miia(2) C () The annual sampling was performed in February 2005. The results were presented \vith the first quarter 2005 report Annual sampling was performed in February 2006. The results were presented in Attachment 4 \Vith the first quarter 2006 report i\.nmwl sampling was performed in September and December 2007, The resu1ts were submitted in attachment 4 of the first quarter 2008 report as required by 1i22.1vLii.a(2)< Annual sampling was perforrned in December 2008. The results were submitted in attachment 4 of the first quarter 2009 report as required by 122. M. ii.a(2). Annual sampling was perfon11ed in December 2009< The results were submitted in Attachment 4 of the first quarter 2010 report as required by t'2-"> ""1 .11.h ;;, i .c.lY' Annual samp1ing was performed in Decernher 2010. The results \Vere submitted in Attachrnent 4 of the first quarter 2011 report as required by 922.M.ii.a(2). iumual sampling v:as perfrnmed in December 2011. The results were submitted in Attachment 4 of the first quarter 2012 report as required by In the first Quarterly Report for the first calendar quarter of eachyem 0' '(')) < ®'Y) ·•; c,/1) Ii..::..,,;..· "-;f :\! 1 · ~ i .~ ... ,.;.... ~ • Annual sampling was performed in December 2012< The results were submitted in Attachment 4 of the first qumter 2013 report as required by 92LM.iia(2). Annual sampling was performed in December 2013. The results were subrnitted in Attachment 4 of the first quarter 2014 report as required r-1 ,. ' )\ Oy; ~?? 11""~-JY .lLt(~}- 1 , Annual sampling was perfonned in December 2014. The results were submitted in Attachment 4 of the l 5'quarter 2015 report as required by ~)') r,, ·1 '' ,· '')\ ll""'"''JY <1Ld\"'}· I I "Tl z :r0 0 0 0 0 ..... -..,J 01 -..,J Page 9 of 12 EPA Inspection Report - Page 1096 of 1969 Hollyfrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHlV[ENT 1 TO 4th OUA.RTKR 2017 STATUS REPORT APPENDIX G STA'l'US SlJMlViARY REPORT Results of annual sampling of >0.05 Mg.!yr benzene streams In the first Ouarterlv Report for the first • calendar quarter of each year Q C J.i; Miia(2) ' '' I ' J.iii: iVUL a(3); Mji~ b{2) Results of Quarterly EOL Sampling Q ' I "Tl z :r0 0 0 0 0 ...... -..,J 01 OJ I ,:;,,,,«L' Each Quarterly Report due under the Consent Decree (after written EPA approval ofEOL sampling plan) ''' I I The results \Vere included in Attachment 4 of the 1'\1uarter 2016 report as required by 422JvULa(2), Annual sampling was perfonned in October 20! 6, The results \Vere included in Altachn1ent 4 of the 1st quarter 2017 report as required by T22JvL ii .a{2), Annual sampling was perfrm11ed in December 2017. The results \VU! be included in Attachment 4 of the 1st quarter 2018 report as required t1y-9p-i M ,lLU(.L'1) . 1 C ! Annual sampling \Vas performed in December 2015, "° 2004: Under the assumption that the sampling plan \Vas accepted by EPA upon the 03/31/2004 submittal of the revised EOL Sampling Plan, Navajo conducted its first EOL sampling during the 1,,veek of 3/22/04, The anmm1 TAB, submitted 4/05 was 4,9 Mg for Artesia and 15 ?vig for Lovington, 1 2005: The FOL benzene quanti;,, (BQ) for the 1"\ 2"'1, J"\ and 4 b q~mrter of 2005 1,,vere each -<2.5 Mg. 2006 . : Th, e EOI \ . , BQ . .for t11e I'', 2"d , .yc1 , an d 4'1, quarters o f ,;,"l() ()(, ·were eac h <2.5 Mg. "007· esml , and ,.,,d tl , B, r t er 2007 ' 5 1M'. g. Tl1e ,. • Thi;;· 1't , L ' _, . E01 -, . , BQ _ . s were eacl1 ~-.. "'· 2007 4 1" quarter EOL benzene quantity exceeded 2.5 Mg, but the cakndar year 2007 TAB did NOT exceed 10 iv1g. 2008: The EOL BQ for the 1st quarter of 2008 was <2.5 Mg and the projected 2008 TAB was < l O lV[g/yr. The EOL BQ for the 2"d quarter of 2008 was> 2,5 Mg and the projected tab was> 10 T:Vfg/yr. TI1e EOL BQ for the 3"' quarter of 2008 was> 2.5 Mg and the projected t.ab was> 10 Mg/yr. The FOL BQ for the 4th quarter of 2008 ,vas <2.5 Mg and the projecte1 In each Section 63.654 Report Training addressed in 63.654 Repmt suhm itted 9/13/02, 3/ 15/03, 9115/03, 3! 15/04, 9/ 15/04, 3/14/05 (3/15/05 for Lovington), 9/13/05 (9/15/05 fix Lovington), 3/17/06, 9/13/06 (9/6/06 for Lovington), 3/16/07, 09/14/07, 03/ 17/08, 09/12/08, 03/16/09, 08/27/09, 03/16/2010, 09/13/2010, 03/16/2011 06/0EV201l, 07/10/2012, 09/10/12, l 1/06/2012, 12/11/2012, 01/13/2013, 05/02/2013, 05/08/2013, 05/15/2013, 02/08/2013 03/09/2013 and 09/ l 6/2014 (tt1r A.ttesia and Lovington). New hire training was conducted 06/08/2011, 07/10/2012, 09/10/12, 11/06/2012, 12/11/2012, 01/13/2013, 05/02/2013, 05/08/2013, 05/15/2013, 02/08/2013, 12/9/2013, 03/22/2014, 03/3112014, 04/01/2014, 06/18/14, 06/ 19/14, and 06/20/2014. Anrmal LOAR Computer Based Training (CBT) implemented during the frimth quarter 2014 for all refinery and contractor personnel. First training completed befrJre 12/31i2014. /umual LD AR Computer Based Training (CBT) for new personnel completed during 2015. Annual CBT completed du.ring 2016, and also on 4/23/2016, 05/11/2016. Training completed on 01-1/13/2017, 04/25/2017, 05/20/2017, and 12/01/2017 _ _ __ _ ,_ _ _ _-L....,_______________________ ------------------------------------- ~-------------------------------------- Page 2 of 9 HFNA-000001763 EPA Inspection Report - Page 1102 of 1969 Ho11yFrcntier Navajo Refining LLC A1iesia and Lovington Refineries ATTACH1VIENT 2 TO 4HB QUARTER 2017 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT Name or Summary of the Report, Plan, or Certification CD Nos, ("R'') v, Contingent C.'.C~) Report on annual training for LOAR personnel Rii; R ,,,,,,,,,,,,,,,,,,,,,_,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, Sub-,I Rqd, O.iic(l) ······---'-··················· One-Tirne (''l")v, Quarterly orw/ §63,654 Reports (">l.") >l Due ..Date In each Section 63,654 Report Training addressed in 63.654 Report submitted 9/13/02, 3/15/03, 9/15/03, 3115/04, 9/15/04, 3/14/05 (3/15/05 for Lovington), 9/13/05 (9/15/05 for Lovington), 3/17/06, 9/13N)6 (9/6/06 for Lovington), 3/16/07, 09/14/07, 03/17/08, 09/12/08, 03/16/09, 08/27/09, 03/16/2010, 09/13/2010, (for Artesia and Lovington),1\ru1ual training was conducted on the following dates by the on-site LDAR contractor: 06!29/2011, 06/14/2012, 06/24/2013, 06/26/2013, 11/12 tol 1/14/20143, 01/12/2014, 01/16/2014, OJ/20/2014, 01/21/2014, 02/08/20 l 4, 02/10/2014, 6/18/2014, 6/19/2014, and 06/20/2014. Annual LDAR Computer Based Training (C'BT) implemented during the fourth qnarler 2014 for a 11 refinery and contractor personnel, Annual LDAR (CBT) conducted during 2015, Annual LDAR (CBT) conducted during 2016. Additional 2016 training held on 1/3/2016, 1/6/2016, 1/14/2016, and 1/19/2016, 1/31/2016, 04/28/2016, 05/11/2016, 09/2016, l 0/2016, 11/201 6, and 12/2016. Training completed on 04/13/2017, 04/25/2017, 05/20/2017, and 12/01/2017. ............, ....,., ---'----~-,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, ________ ,,,,,,,,,,,,, Page 3 of9 HFNA-000001764 EPA Inspection Report - Page 1103 of 1969 HollyFrontier Nav,:~jo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO 4tn QUARTER 2017 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT Name or Summary of the Report, Plan, or Certific,1!:imi Report on LD /\.R training fix refinety and operations personnel who hold positions relevant to LDAR CD Nos. Rqd. (''K') v. Contingent ("C") One-Time ("l'') V. Quarterly orw/ §63.654 Reports {"> l ") Riii; R >1 Sub-~ O.iic(l) Due Date In each Section 63.654 Repent Status Initial training program implemented. Training addressed in 63.654 Report submitted 9/13/02, 3/15/03, 9/15/03, 3/15/04, 9/15/04, 3/14/05 (3/15/05 for Lovington), 9/13/05 (9/15/05 for Lovington), 3117/06, 9/13/06 (9/6/06 for Lovington), 3/16/07, 09/14/07, 03/17/08, 09/12/08, 03/16/09, 08/27/09, 03/16/2010, 09/13/2010, 03/16/2011, 03/14/2012 and 09/16/2013. Training was conducted on the following dates frir refinery environmental personnel: 11/06/2012, 08/13 08/15/2013, 05/19- 5/2I/20l4, 8/21/2014, 10/02/2014. Annual LDAR Computer Based Training (CBT) implemented dudng the fourth quarter 2014 for all refinery and contractor personnel. Annual LDAR (CBT) conducted during 2015. Annual LO.AR (CBT) conducted during 2016. Additional 2016traininghddon 1/3/2016, 1/6/2016, 1/14/2016, and 1/19/2016, 1/31/2016, 04/28/2016, and 05/11/2016. Training completed on 04/13/2017, 04/25/2017, 05!20/2017, and 12/01/2017. ... ·~·-···~-~ Page 4 of 9 HFNA-000001765 EPA Inspection Report - Page 1104 of 1969 HoUyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTA_{]lMENT 2 TO 4m QUARI'~!{2017 STATUS REPORT APPENDIX H STATUS SlJMlVI.ARY REPORT Name or Summary of the Report, Plan, or Certification CD Sub-TI Nos, LDAR audit D; reports and records O.ii-b. of corrective actions. Audits are required every Hvo vears. Rqd. (''K') v. Contingent _(''C") R One-Time ("] ") V. Quarterly orwi §63.654 Reports f'> l") >1 Due_Date Status In the Quarterly Report for the 1" calendar Quarter of each year Included in the 1st Qtr 2003 report (submitted 04/17/2003) as Attachment 3. 3rd party audits for Artesia and Lovington were perfrmned during December 2004, January 2007 . January 2009, and January 2011. Included in the r:i Qtr 2012 report a copy of the Ol/201 J Audit Repmt and the comxtive actions taken were included with the 1''1 Quarter 2012 report as Attachment 5. The 2013 3rd party audit was conducted from 09/16 to 09/20/2013, after major refinery turnaround, and a complete quarter worth of normal operation data has been collected for comparative monitoring, A copy of the audit rep(nt and resolutions were presented in the 1'; 1 Quarter 2014 reprni. yet party audits frn- Artesia and Lovington were performed during the week of October 5u1 to ~f·, 2015. A copy of the 2015 LDA.R 3rd party audil report and resolutions are included in Attachment 5 of the 1st Quarter 2016 report. The 2017 LDAR 3'11 party audit was conducted fi·om 05/l 7 to 05/18i201 7, A copy of the audit report was attached to the 3rd Quarter Consent Decree Progress Report, The audit resolutions be included as Attachrnen1 4 to the ,vm ~-·--------·---·-··--·-'-----'-------•---···--- --'-----~-1_st_(~)_uc_ar_te_''r_·2_· O\?._re,.,,.;,_o_r_t.._ _ _ _......., Page 5 of9 HFNA-000001766 EPA Inspection Report - Page 1105 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTA.CHMENT 2 TO 4th QUARTER 2Q17 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT Name or Summary of the Report Plan, or Certification CD Rqd. ("R") v. Comi.ngent e.G'.) Sub-11 No~,. One-Ti.me (''l ") V. Quarterly orw/ §63.654 Reports Due_Date Statg_~ t'?:J5 Certification of implementation of the first attempt at repair program G; R l O.iia(l) .... Operational specifications fr)r electronic LDAR data colledi.on and transfer I.ii.; .. R l 6 mos. afler Lodging for Navajo; l yr. after Lodging for Montana Refining Submitted 06/19/2002 1 In Lhe first Qtrly report due under the CD or the first Otrlv ., , report in which the rqmL becomes due. Provided with Initial Quarterly Status Report submitted for 2"d Quarter 2002 on July 30, 2002. O.i-b ----······· .... ··~- ...... Certification of implememation of QAJQC procedures for review of data generated by LDAR monitoring technicians ········~ J: In the Provided with Initial Quarterly first Qtdy Status Report submitted fi.1r 2"J report Quarter 2002 on July 30, 2002 due under the CD or the first Qtrly report in which the rqmL becomes due R O.iia(2) .. --- -- -· Page 6 of9 HFNA-000001767 EPA Inspection Report - Page 1106 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHJUENT 2 TO 4m QUARTER 2017 STATUS REPORT APP.EN.DIX H STATUS SUMIVIARY REPORT Name or Summary of the Report, Plan, or Certification CD Nos. Rqd. ("K') v. Contingent ('_'C') One-Time ("l ") v. Quarterly orw! §63.654 Reports C'> 1"} Identification of each Refinery's LDAR ''point" person. K· R l Certification of the development of a tracking program for new valves and pumps L; Sub-,T ' O.iia(3) ...... ~--~~-~-----~ ........ R l O.iia(4) Due_Date Status In the Provided with Initial Quarterly first Qtdy Status Report submitted frn- 2nd report Quarter 2002 on July 30, 2002 due under the CD or the first Qtrly report in which the rqmt. becomes due .. ln the Provided with lni1ial Quarterly first Qtr!y Status Report submitted frr 2"d report Quarter 2002 on July 30, 2002 due under the CD or the first Qtdy report in which the rqmt becomes due -- ~--··· ................... Page 7 of9 HFNA-000001768 EPA Inspection Report - Page 1107 of 1969 HoliyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHl\fENT 2 TO 4th QUARTER 2017 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT Name or Summary of the Report, Plan, or Certification Certification of implementation of calibration drift assessment procedures CD Nos. Rqd. ("R'') v, Contina"nt ··es;;__ ("'C") . M: R Sub-11 One-Time ('' J ") V. Quarterly orw/ §63.654 Reports ("> l ''} Due Date Status l In the Provided with Initial Quarterly . d for"'.-,nd· first Qtrly S ,. tatm; R epon su t,nutte report Quarter 2002 on July 30, 2002 due under the CD or the first Qtrly report in which the requirem ent becomes due 1 In the Provided with hlitial Quarterly first Qtrly Status Report submitted for 2nd report Quarter 2002 on July 30, 2002 due under the CD or the first Qtrly report in which the requirem ent becomes due O.iia(5) ... Certification of implernentation of Lhe '·delay of repair'' procedures N; R ()ji- a(6) ···~ ~--·· ~--·· Page 8 of9 HFNA-000001769 EPA Inspection Report - Page 1108 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO 4th QUARTER20l7 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT Name or Summary CD of the Report, Sub-1'[ Plan, or Nos. Certification RqcL One-Time C'R'') v. Contingent e.(.'.') (''] ") V. Quarterly orw/ §63.654 Reports Due Date Status C?..L'.') LDitR monitoring report submitted with MAGI periodic reports O; R >1 O.iic(2) In each Section 63.654 Report Provided in MA.CT 63.654 Reports submitted: 3/15/02, 9/13/02, 3/15/03, 9/15/03, 3/15/04, 9/15/04, 3/14/05 (3/15/05 for Lovington 9/13/05 (9/15/05 for Lovington), 3/17/06, 9/ 13/06 (9/6/06 for Lovington), 3116/07, 09/14/07, 03/17/08, 09/12/08, 03/16/09, 08/27/09, 03/16/2010, 09/13/2010, 03/16/2011, 09/15/2011, 03/09/2012, 0/06/2012 (09/06/2012 frff Lovington), and 03/15/2013, 09/16/2013, (Lovington and i-\Jtesia) 02/25/2014 (.Artesia), 08/26/2014 (Lovington), and 02/26/2015 (Ariesia and Lovington), 08/27/2015, 2/18/2016 (Artesia and Lovington), 08/29/2016 (A1tesia and Loving1on}, 02/2812017 (Artesia and Lovington), and 08/29/2017 (Artesia and Lovington) . ... Page 9 of9 HFNA-000001770 EPA Inspection Report - Page 1109 of 1969 ATTACHMENT 3 QUARTERLY EOL AND SAMPUNG RESULTS (Paragraph 22JV!.ii.a(3}) HFNA-000001771 EPA Inspection Report - Page 1110 of 1969 HollyFrontier Navajo Refining LLC Artesia, NI\i Refinery End of Line Sampling Report 4th Quarler 2017 A'fTACHI\TENT 3 TO 4th 0UARTER2017 STATUS REPORT OUAUTERLY END OF LINE SAl\iPLING RESULTS On October Hi\ October 19°1, November 2nd, and December 51\ 2017, Navajo Refining's Artesia facility perfonned the End of Line (EOL) sampling pursuant to the Consent Decree, following the protocol described in Navajo's EOL sampling plan that was revised by a letter dated March 31, 2004, except as noted below for Cement Ki1n Fuel (S-4). Due to changes in our wastewater systern, the slop oiI frorn our Alky API is diverted through the new wastewater APL Therefore, that stream is now factored into the calculations for the Wastewater APL As a result, Navajo has identified six (6) sampling points that were monitored during the EOL sampling. This included three representative samples for each sampling site, volume measure1nents, and specific gravity values, collected once a month during the quarter where applicable. Three representative samples of API sludge material generated during the 4th Quarter of 2017 were collected on 12/19/2017, and the test results are included in this report The fi.,llowing calculations estimate the quarterly FOL and calendar year benzene quantities; Oil from \:Vastewater APT FOL (Mg/qtr} weeks/quarter x Oil Volmne (gal/wk) x lbs. water/gallon x Specific Gravity of oil (dimensionless) x average benzene concentration in oil (ppmw) x grams/lb --,- 1fl-' g/Mg Oil from 'Wastewater API EOL (l'v1g/qtr) ,-, . 13 \Vks/qtr x 46,109 gals/wk x 8,34 Tbs)gaUon x: (t99 (dimensionless) x 10.8 lb/106 x 454 g/1b --,-- 1(/' g/Mg Oil front Wastewater API EOL = 0.02 lVl.g/qtr 'Wastewater - EOL (Mg/qtr) = days/qtr x A.verage Flow (gaJ/day) x Water Density (1bs. water/gal) x Average Benzene Concentration in wastewater (ppmw) x grams/lb ··;- 106 g/\{g \Vaste'fi'ater - EOL (Mg/qtr) = 92 days/qtr x 720,000 gal/day x 8.34 lbs/gal x 0.70 lb/106 }b X 454 2:/}b ··,· l 06 g/Mg:r ~ ~ <. \Vastewater - EOL = 0.18 Mg/qtr Cement KUrn Fuel Product EOL (J'v1g/qtr) = Amount of cement kiln fuel shipped m quarter (lbs/qtr) x Average Benzene Concentration (ppnn:v) x g/lb + t 06 g/Mg Cement Kiln. Fuel Product EOL (Mg/qtr) ,-,,, 17,940 (lbs/qtr) x 5.0 lb/Hf' x 454 g/1b -,-106 g/Mg Cement Ki.In. Fuel Product EOL = 0J)9 Mg/qt.r N:\Cmscnt Decree\Subm-Resp\Quarterly Reports\2017 4QT- Att3-EOL Repo1t.d•.Jc Page 1 of3 HFNA-000001772 EPA Inspection Report - Page 1111 of 1969 BOllyfrontier Navajo Refining LLC A.rtesia, NM Refinery End of Line Sampling Report 4th Quarter 2('.) 17 ATTAClilVlENT 3 TO 4tti QUARTER 2017 STATUS REPOR'l' QUARTERLY END OF LINE SAMPLING RESl.JLTS Aqueous \Vaste ~austic EOL (l\rfg!qtr) = Amount of aqueous \vaste caustic shipped in the quarter (total of Tanks 40 and 41) (gal) x lbs/gal x Average Benzene Concentration (ppmw) x g/lb 0- Hi g!Mg Aqueous ,vaste Caustic EOL (Iv1g/qtr) = 18,759 gal/qtr x 9,64 lbs/gal x OJ;,25 lb/106 lb x 454 g/lb-;- 1(}1' g/Mg Aqueous ,vaste Caustic EOL = 2.0 E (-6) Mg/qt/ \Vaste Caustic Uvdrocarl:wn EOL (!vfg!qtr) = days/qtr x avg flow (gal/day) x water density (lbs/ gal) x Specific Gravity (dimensionless) x Average Benzene Concentration (ppmw) x g/lb + l 06 g!Mg Waste Caustic Hvdrncarbon EOL (Mg/qtr) = 92 days/qtr x 42 gal/day x 8.34 1bs/ga1 x I. I7 (dimensionless) x 023 lb/Hi lb x 454 g/1b ·'· H/' g/Mg Waste Caustic :n:vdrncarbon EOL = 4.0 E(-6) l'Hg/qtr Therefore, estimated total quarterly benzene equals benzene in Oil fro.m \Vastewater AP'I (Mg/qtr) + benzene in \Vastewater (Mg/qtr) + benzene in Cement Kiln Fuel Product (Iv1g/qtr) + benzene in Aqueous \Vaste Caustic (Mg!qtr) + benzene in \Vaste Caustic Hydrocarbon (Mg/qtr). Estimated Total Quarterly Benzene= 0.02 Mg/qtr + 6) lVig/qtr-'- 4.0 E(-6) Mg/q_tr o.rn Mg/qtr + 0.09 Mg/qtr + 2.0 E (- Estimated Quarterly EOL Benzene= 0,29 :Vig/qtr Therefore, the Artesia Refinery's quarterly EOL benzene quantity did not exceed 2.5 Mg!qtr. Estirnate~LA@V.i.t.LB._enzene {AB) Quantitv_..f~\L~:.?l~!.mJ?.T.Y01:lf 2016 Estimated 2017 TAB== [(1 5 lQ + 2 116Q+3rdQ+4th QT)/ 4] * 4 = [(0,84 + OJO+(U l-'-0.29) / 4] * 4 Estimated 2017 TAB = 1.34 Mg The Artesia Refinery's projected calendar year 2017 total annual benzene quantity does not exceed IO Mg/yr. The above calculations ,,:vere determined using the values from the frJl1owing table and the attached analyses. Page:2 of 3 HFNA-000001773 EPA Inspection Report - Page 1112 of 1969 End of Line Sampling Report 4th Quarter 20 l 7 HollyFrontier Navajo Refining LLC Artesia, NM Refinery ATTACHMENT 3 TO 4m QUARTER 2017 STATUS REPORT QUARTERLY END OF LINE SAMPLING RESULTS TABLE 1 QUARTERLY EOL SAMPLING NAVAJO REFINING Volume Sampling Point Test results Sample Co1kctcd 10/03/2017 Test results Sample Collected 11/02/2017 Tesl results Sample Collected 12/05/20 ! 7 Test results Samples Collected 12/19/2017 Average of Samples NA 10.84 ppm Specific '[''''''''''''''''''''''''•·········1 Gravity or I Density I ' 0.99 ' Oil from W astcwaler APl (S-1) 46,109 gal/wk 27.00 ppm 5.50 ppm (),()LJ Wastewater Tanks (S-3) 720,000 gal/day 0.58 ppm 1.50ppm OJ)25ppm NA 0.70 ppm 1.00 Cement Kiln Fuel (S-4 )'" 17,940 His NA NA NA. S4 (1) = 4.76 ppm S4 (2) = 4.85 ppm S4 (3) = 5.39 ppm 5.00 ppm NA Aqueous Wasle Caustic Tank 40 (S-5) 18,759 gal/qtr 0.025 ppm -c+ M~ ppm+ 0.024 ppm 0.024 ppm NA 0.024 ppm U3 0.025 ppm . 0.02)- ppm+ NA 0.025 ppm 1.14 0.025ppm 0.025 ppm 0.025 ppm NA 0.25 ppm Ll4 0.23# 0.23ii 0.23 11 NA --·· Aqueous Waste Caustic Tank 41 (S-6) "' (),()24 ppm++ e-------···-•"""""""""" ---+-------+----- A vernge of Aqueous \Vastc Caustic Tanks (S-5 and S-6) . W astc Caustic ! • i f_ _fiydrocarbon (S-7) * / 42 gal/dav , / ' ""1'" I 0.23# *The volume for Caustic Tank 41 is ref1ected in the value assigned to Tank 40. Tiie quantity assigm:d to Tank 40 is ,he rnmbined volume from BOTH tanks that was shipped o.;t in lhe quarter. ·'The Benzene result was below the method detection limit (MDL) of0.025 ppm. 11,c MDL wa, used as a rnnservative aproach. -T'nt Benzene result was below the method dekclion limit (MDL) of0.024 ppm. The MDL was used as a conservative aproach. "No sample C(mld be collected because the hydro0arhon layer was between ,he sample point draws on the tank. The l QT average Benzene of 0.23 ppm, spccitfo gravity of l 17 was used. "'*Benzene srnnpks w;;,re collected at less than th 4 times amount spiked P Dual Column results percent difference > 40% R RPO above laboratory control limit S Spike Recovery outside laboratory control limits U Analyzed but not detected above the MDL/SOL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Unit Reported Description mg/Kg Milligrams per Kilogram mg/L Milligrams per Liter Page 21 of27 HFNA-000001796 EPA Inspection Report - Page 1135 of 1969 ALS Group USA, Corp Date: 13-0ct-17 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date Arkansas 17-027-0 27-Mar-2018 California 2919 2016-2018 31-Jul-2018 Illinois 004112 09-May-2018 Kentucky 123043 30-Apr-2018 Louisiana 03087 2017-2017 30-Jun-2018 North Carolina 624-2017 31-Dec-2017 North Dakota R193 2017-2017 30-Apr-2018 Oklahoma 2017-088 31-Aug-2018 Texas T104704231-17-19 30-Apr-2018 Page 22 of27 HFNA-000001797 EPA Inspection Report - Page 1136 of 1969 ALS Group USA, Corp Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS17100323 Date: 13-0ct-17 SAMPLE TRACKING Lab Sarnp ID Client Sample ID Action Date Person New Location HS17100323-01 S-1 (API HG) Login 10/6/2017 11:10:12 AM CL VOA120 HS17100323-02 S-3 (API Water) Login 10/6/2017 11:10:12 AM CL VOA120 HS17100323-03 S-5 (T-40) Login 10/6/2017 11:10:12 AM CL VOA120 HS17100323-04 S-6 (T-41) Login 10/6/2017 11:10:12 AM CL VOA120 HS17100323-05 Field Blank Login 10/6/2017 11:10:12 AM CL VOA120 HS17100323-06 EQ Blank Port 1 Login 10/6/2017 11:10:12 AM CL VOA120 HS17100323-07 EQ Blank Port 2 Login 10/6/2017 11:10:12 AM CL VOA120 HS17100323-08 Duplicate Login 10/6/2017 11:10:12 AM CL VOA120 HS17100323-09 Trip Blank Login 10/6/2017 11:10:12 AM CL VOA120 Page 23 of27 HFNA-000001798 EPA Inspection Report - Page 1137 of 1969 ALS Group USA, Corp Date: 13-0ct-17 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 05-0ct-2017 08:25 Work Order: HS17100323 Received by: JRM Checklist completed by: Reviewed by: Cesar A. Lira 6-0ct-2017 -e,:-S,-ig_n_a,-tu-re--------.---,D=-a..,.t_e_ _ liquid. oils Matrices: Nicole Edwards eSignature 9-0ct-2017 Date Carrier name: ~ ~ Shipping container/cooler in good condition? Yes Custody seals intact on shipping container/cooler? Yes Custody seals intact on sample bottles? Yes Chain of custody present? Yes Chain of custody signed when relinquished and received? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes TX1005 solids received in hermetically sealed vials? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Container/Temp Blank temperature in compliance? Yes Temperature(s)/Thermometer(s): .8c/3.1c UC/C D ~ ~ ~ ~ ~ D ~ ~ ~ Cooler( s)/Kit( s): IR11 Date/Time sample(s) sent to storage: 10/5/2017 19: 00 No No No No No No No No No No No No D Not Present D D Not Present ~ Not Present N/A ~ D D D IR11 Water - VOA vials have zero headspace? Yes 4 No Water - pH acceptable upon receipt? Yes D Yes D No pH adjusted? D D D D D D D D No No VOA vials submitted D D N/A ~ N/A ~ pH adjusted by: Login Notes: fsamples refrigerated prior to login. Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 24 of27 HFNA-000001799 EPA Inspection Report - Page 1138 of 1969 D Chain of Custody Form Page _1_ Enuironmental of D D _L_ Cincinnati, OH +l 513 733 5336 Everett, WA +l 425 356 2600 ALS Project Manager: Erica Padilla D Holland, Ml +1616 399 6070 D D Houston, TX +l 281 530 5656 D D Middletown, PA +l 717 944 5541 D Salt lake City, UT +l 801 266 7700 Spring City, PA +1610948 4903 Work Order#: ·•:•:•:•: •: ::•:•: :•::P.fojeitlnfottriati6n::•:-.. ·•·· . P.rojei.t << • • wciri< orcier :•:•:-::::~··-·,::···:···:··:·:·:·:·:· . } :)::nm~aiiy~a!Tle Navajo Refining Company LLC Tyler Tumer I . . ~afu.~ BWON Monthly Sampling (EOL) . . . . . : :~,~i$4i~elZ/p Artesia, NM 88211-0159 / •·•·•· : : j='~it BWON Monthly Sampling (EOL) <}){t:il:yJStatetZip Artesia, New Mexico 88210 >Phone (575) 748-3311 <:<: :\ / (575) 746-5451 P~~~a > : ::::::: .· I> - Navajo Refining Company I< •:•/ I> - Gabi Combs (575) 748-3311 :H: :f::a~ (575) 746-5451 : I_< 111111111111 H 11111111 lffl >a . ?oaie:<: :: : - .. ·. • ••• ••• ....... : T1rii{< ... :•"_Matriii:: :•_: Pres:: •1Hioti1i/s< : C: i < E) iF ... G:: i :>9< · Trip Blank 10/03/17 XXX Liquid HCI <:10: Temperature Blank 10/03/17 :•/ Liquid 1 ! D STD 10 Wk Days Relinquished by: Br~~ flvbbJlrJ? (J(9,,,,.JJ. Date: rza~ :· :_:'/·,,., Date: > ., .. , . ' "·· ., •.• l°l\t&: • -i." Time: Received by: Time: Received by (Laboratory): 0 5 Wk Days Oother _ _ __ D 2 Wk Days D 24 Hour Notes: r I .·. . ...... .· J(J·.s·/7 Relinquished by:/ ~~gtid Dl4 ',' / X 2 Required Turnaround Time: !Shipment Method: . 9-$035 Gl~P:ackagii:(~hec:k!3oJ(Bel~wv: :: Level ll: Standard QC Level III: Std QC+ Raw Data Level IV: SW846 CLP-Like ·. •• "· ·" jTRRP-Checklist ITRRP Level IV Other: Copyright 2009 by ALS Laboratory Group Page 25 of27 HFNA-000001800 EPA Inspection Report - Page 1139 of 1969 ALS I 10450 Stanciiff de Houston, Texas' 3.7098 +1 231 5305653; Fax. +1 281 5305881; {site Page 26 of 2 I CUSTODY SEAL HFNA-000001801 EPA Inspection Report - Page 1140 of 1969 Use of this system constitutes your agreement to the service conditions in the current FedExSer.Jice Guide, available on fedex.com. FedEx wlll not be responsible for any claim in excess of $100 per package, whether the result of loss, damage1 delay, non-delivery, m!sdelivery, or misinformation, unless you declare a higher value, pay an additional charge, document your actual loss and file a timely claim. Limitations found in the current FedEx Service Guide apply. Your right to recover from FedEx for any loss, including Intrinsic value of the package, loss of sales, income interest, profit, attorney's fees, costs, and other forms of damage whether direct, !ncidental, consequential, or special is limited to the greater ot $100 or the authorized declared value. Recovery cannot exceed actual documented loss. Maximum for items of extraordinary value is $1,000, e.g. jewelry, precious metals, negotiable instruments and other items listed in our Service Gulde. Written claims must be fl!ed within strict time !lmits, see current FedEx Service Guide . •~fter pnnt111g this label: CONSIGNEE COPY· PLEASE PLACE IN FRONT OF POUCH i. Fo;d ~t·,e µdnii:Ci page along the harizon!ei line. 2. Place label in 5hipping pouch :,rid affix it tc your shipment fw~ )> d"" OJ c.o-a Q en G) Al )> (,;) Q 00 01 c.o 0 ~ .s:,. Page 27 of27 HFNA-000001802 EPA Inspection Report - Page 1141 of 1969 10450 Stancliff Rd. Suite 210 Houston, TX 77099 T: +1 281 530 5656 F: +1 281 530 5887 October 12, 2017 Gabriela Combs Navajo Refining Company PO Box 1490 Artesia, NM 88211-1490 Work Order: HS17100324 Laboratory Results for: BWON Monthly Sampling (EOL) Dear Gabriela, ALS Environmental received 4 sample(s) on Oct 05, 2017 for the analysis presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Results are expressed as "as received" unless otherwise noted. QC sample results for this data met EPA or laboratory specifications except as noted in the Case Narrative or as noted with qualifiers in the QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained by ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. If you have any questions regarding this report, please feel free to call me. Sincerely, Generated By: Jumoke.Lawal Nicole Edwards Project Manager Right Solutions · Right Partnu www.a!sg!obaLcom Pagel of25 HFNA-000001803 EPA Inspection Report - Page 1142 of 1969 ALS Group USA, Corp Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS17100324 Date: 12-0ct-17 SAMPLE SUMMARY lab Samp ID Client Sample ID Matrix HS17100324-01 S-1 (API HC) HS17100324-02 TagNo Collection Date Date Received Liquid 03-0ct-2017 09:29 05-0ct-2017 08:25 S-3 (API Water) Liquid 03-0ct-2017 09:51 05-0ct-2017 08:25 HS17100324-03 S-5 (T-40) Liquid 03-0ct-2017 09:01 05-0ct-2017 08:25 HS17100324-04 S-6 (T-41) Liquid 03-0ct-2017 09:05 05-0ct-2017 08:25 Hold D D D D Page 2 of25 HFNA-000001804 EPA Inspection Report - Page 1143 of 1969 ALS Group USA, Corp Client: Project: Work Order: Dale: Navajo Refining Company 12-0cl-17 CASE NARRATIVE BWON Monthly Sampling (EOL) HS17100324 Work Order Comments • The analysis for Specific Gravity was subcontracted lo ALS Environmental in Holland, Ml. Final report attached. Page 3 of25 HFNA-000001805 EPA Inspection Report - Page 1144 of 1969 ALS Group USA, Corp Client: Project: Sample ID: Collection Date: ANALYSES Date: 12-0ct-17 RESULT QUAL SUBCONTRACTED ANALYSIS Miscellaneous Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-1 (API HC) 03-0ct-2017 09:29 MDL Work0rder:HS17100324 Lab ID:HS17100324-01 Matrix: Liquid REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED Method:NA See Attached 0 12-0ct-2017 09:05 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 4 of25 HFNA-000001806 EPA Inspection Report - Page 1145 of 1969 ALS Group USA, Corp Client: Project: Sample ID: Collection Date: ANALYSES Date: 12-0ct-17 RESULT QUAL SUBCONTRACTED ANALYSIS Miscellaneous Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-3 (API Water) 03-0ct-2017 09:51 MDL Work0rder:HS17100324 Lab ID:HS17100324-02 Matrix: Liquid REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED Method:NA See Attached 0 12-0ct-2017 09:05 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 5 of25 HFNA-000001807 EPA Inspection Report - Page 1146 of 1969 ALS Group USA, Corp Client: Project: Sample ID: Collection Date: ANALYSES Date: 12-0ct-17 RESULT QUAL SUBCONTRACTED ANALYSIS Miscellaneous Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-5 (T-40) 03-0ct-2017 09:01 MDL Work0rder:HS17100324 Lab ID:HS17100324-03 Matrix: Liquid REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED Method:NA See Attached 0 12-0ct-2017 09:05 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 6 of25 HFNA-000001808 EPA Inspection Report - Page 1147 of 1969 ALS Group USA, Corp Client: Project: Sample ID: Collection Date: ANALYSES Date: 12-0ct-17 RESULT QUAL SUBCONTRACTED ANALYSIS Miscellaneous Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-6 (T-41) 03-0ct-2017 09:05 MDL Work0rder:HS17100324 Lab ID:HS17100324-04 Matrix: Liquid REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED Method:NA See Attached 0 12-0ct-2017 09:05 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 7 of25 HFNA-000001809 EPA Inspection Report - Page 1148 of 1969 ALS Group USA, Corp BWON Monthly Sampling (EOL) R303247 HS17100324-01 DA TES REPORT HS17100324 Client Samp ID Sample ID 12-0ct-17 Navajo Refining Company Client: Project: WorkOrder: Batch ID Date: Collection Date TCLP Date Test Name : SUBCONTRACTED ANALYSIS Analysis Date Prep Date DF Matrix: Liquid S-1 (API HC) 03 Oct 2017 09:29 12 Oct 2017 09:05 HS17100324-02 S-3 (API Water) 03 Oct 2017 09:51 12 Oct 2017 09:05 HS17100324-03 S-5 (T-40) 03 Oct 2017 09:01 12 Oct 2017 09:05 HS17100324-04 S-6 (T-41) 03 Oct 2017 09:05 12 Oct 2017 09:05 Page 8 of25 HFNA-000001810 EPA Inspection Report - Page 1149 of 1969 ALS Group USA, Corp Client: Project: WorkOrder: Qualifier Date: Navajo Refining Company BWON Monthly Sampling (EOL) HS17100324 12-0ct-17 QUALIFIERS, ACRONYMS, UNITS Description Value exceeds Regulatory Limit a Not accredited B Analyte detected in the associated Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time J Analyte detected below quantitation limit M Manually integrated, see raw data for justification n Not offered for accreditation ND Not Detected at the Reporting Limit 0 Sample amount is> 4 times amount spiked p Dual Column results percent difference > 40% R RPO above laboratory control limit s u Spike Recovery outside laboratory control limits Analyzed but not detected above the MDL/SOL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Page 9 of25 HFNA-000001811 EPA Inspection Report - Page 1150 of 1969 ALS Group USA, Corp Date: 12-0ct-17 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date Arkansas 17-027-0 27-Mar-2018 California 2919 2016-2018 31-Jul-2018 Illinois 004112 09-May-2018 Kentucky 123043 30-Apr-2018 Louisiana 03087 2017-2017 30-Jun-2018 North Carolina 624-2017 31-Dec-2017 North Dakota R193 2017-2017 30-Apr-2018 Oklahoma 2017-088 31-Aug-2018 Texas T104704231-17-19 30-Apr-2018 Page 10 of25 HFNA-000001812 EPA Inspection Report - Page 1151 of 1969 ALS Group USA, Corp Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS17100324 Date: 12-0ct-17 SAMPLE TRACKING Lab Sarnp ID Client Sample ID Action Date Person New Location HS17100324-01 S-1 (API HG) Login 10/6/2017 11:10:28 AM CL Sub HS17100324-02 S-3 (API Water) Login 10/6/2017 11:10:28 AM CL Sub HS17100324-03 S-5 (T-40) Login 10/6/2017 11:10:28 AM CL Sub HS17100324-04 S-6 (T-41) Login 10/6/2017 11:10:28 AM CL Sub Page 11 of25 HFNA-000001813 EPA Inspection Report - Page 1152 of 1969 ALS Group USA, Corp Date: 12-0ct-17 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 05-0ct-2017 08:25 Work Order: HS17100324 Received by: JRM Checklist completed by: Reviewed by: Cesar A. Lira 6-0ct-2017 -e,:-S,-ig_n_a,-tu-re--------.---,D=-a..,.t_e_ _ Nicole Edwards eSignature Matrices: 9-0ct-2017 Date Carrier name: ~ ~ Shipping container/cooler in good condition? Yes Custody seals intact on shipping container/cooler? Yes Custody seals intact on sample bottles? Yes Chain of custody present? Yes Chain of custody signed when relinquished and received? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes TX1005 solids received in hermetically sealed vials? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Container/Temp Blank temperature in compliance? Yes Temperature(s)/Thermometer(s): .8c/3.1c UC/C Cooler( s)/Kit( s): D ~ ~ ~ ~ ~ D ~ ~ ~ No No No No No No No No No No No No D D D D D D D D D Not Present D D Not Present ~ Not Present N/A ~ D D D IR11 tyrofoam cooler Date/Time sample(s) sent to storage: 10/05/2017 1900 Water - VOA vials have zero headspace? Yes ;# No Water - pH acceptable upon receipt? Yes D Yes D No pH adjusted? No No VOA vials submitted D D N/A ~ N/A ~ pH adjusted by: Login Notes: fsamples refrigerated prior to login. Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 12 of25 HFNA-000001814 EPA Inspection Report - Page 1153 of 1969 Chain of Custody Form A I Page _1_ of I --1.__ O D D Cincinnati, OH +1 513 733 5336 Everett, WA +1425 356 2600 D Holland, Ml +1616 3996070 D D Houston, TX +1 281 530 5656 D D Middletown, PA +1 717 944 5541 D Salt Lake City, UT +1801256 7700 Spring City, PA +1610 948 4903 Enuironmental ALS Project M~nager: Erica Padilla Work Order#: ·. ·. ·. •·•·•·• <• • ·• • ParameterlMetnc:;d REfoifo:st tor.Anah;sit{ • •• ·.· ··· ··· .· ···········. ·. ·. ·. ··••·•• .. PfoJee:t:111tormatfon .. •• ••· · pJfchas.e:or.ti~i· · ·'. .... ,., //Pr6j~cfNa,rie BWON Monthly Sampling (EOL) ' •·•·••••wi)riiorcier : >p~~J~tjtr-i~~i¥ ~P:rripa~(Naine Navajo Refining Company LLC < Tyler Turner •·•·••· ·.· .. Phone r I . > ·>•·• L· >• • : : • • . •No/ .. : ............. s.···.~.m.·:·.P.le.... o.•.e.s.t..n.• ;P.·.u.o.•.n.·.•······ Navajo Refining Company . .... ;;,.;;~ /: ri;;t.. ,~~'.". . . BWON Monthly Sampling (EOL) cs15> 14a.3311 • •'•':'~ (575) 746-5451 ·.·.·.· ·.·.·.·.·.·cc.·.·.·.·.·c.·.·.· >>••••.e.:•.;M.:.a.1.1:.Ad.:.a.:.rn.:.s.s.•Suzanne.Aguilar@hollyfrontier.com · · · •• >•: •<•t ••.. ·. . . . ·.· >j:::. Cii:y)SfafolZii> Artesia, New Mexico 88210 ....... . .......... }iio~~ (575) 748-3311 Thno 1. ... II 1111111111111111 :J .. . N(t···· ·.· . ·p· .. ·.•.• •iii/:•:: ••. ./ •• >i::i •·>>·.ii r:UC >>.res,....... tl!~s\> . . . • .; < .. •.u"~ •• ... S-1 (API HC) 10/03/17 9:29AM liquid Neat X [ { S-3 (API Water) 10/03/17 9;51 AM Liquid Neat X , <:( i >,( S-5 (T-40) 10/03/17 9:01 AM Liquid Neat X S-6 (T-41) 10/03/17 9:05AM Liquid Neat X rrt~r(s)::sr~•?tf:s~f~Ifs~···· Relinquished by: lfri! • . - ·. · ·. ·........ ·. Gabnela. Combs'"" holl!lvf,ronber.com .. ·.... I .o. 88211-0159 F~~ (575) 746-5451 ·.·.•.•.•.e<;.M·.·a•·1·1<.A·:d•·d.·r.ttume.r.am@gmail.com ••>>• a• Biff T:o Company Holly Frontier Navajo Refining LLC Gabi Combs P.O. Box 159 ::/<:> 9ifY.1!5tatel~ip Artesia, NM "' Specific Gravity ·-----+-'4--------------------------1 0 : ••..:.:•·• >:V j. 1· . . . · >:r.. '. Ji/ ·I=·. ·.: ·:·:.. . .j >°7>> r•. ·. 1.:.:c• , . . . . . Oother _ _ __ 0 5 Wk Days 2 Wk Days IIIIII - •·.• ••. Rold .·. .. .. :. O 24 Hour Notes: 'lfJ()O fM Time: 0 ~ ::;.. S Received by (Laboratory): .::J;v..,1 Cl,')Olet1'e111p; / , .· ·• · :a~ S:,:atj~ilgEl:(Cf!ei;k 13~~ EIE!~Ow).: >•• LevelII: Standard QC TRRP-Checklist TRRP Level IV Note: Any changes must be made in writing once samples and COC Form have been submitted to ALS Laboratory Group. Copyright 2009 by ALS Laboratory Group Page 13 of 25 HFNA-000001815 EPA Inspection Report - Page 1154 of 1969 Use of this system constitutes your agreement to the service conditions in the current FedEx Service Guide, available on fedex,com. FedEx will not be responsible for any claim in excess of $100 per package, whether the result of loss, damage, delay, non--de!ivery, misde!ivery, or misinformation, unlessvou declare a higher value, pay an additional charge, document your actual loss and file a timely dalm. limitations found tn the current FedEx Service Guide apply. Your right to recover from FedEx for any loss, induding intrinsic value of the package, loss ot sales, income interest, profit, attorney's fees, cost:., and other forms of damage whether direct, incidental, consequential, or special is limited to the greater of $100 or the authorized dedared value. Recovery cannot exceed actual documented loss. Maximum for items of extraordinary value ;s $1,000, e.g. jewelry, precious metals, negotiable instruments and other items listed in our Service Guide. Written claims must be filed within strict time limits, see current FedEx Service Guide. ft.Jter printing this labei. CONSIGNEE COPY· PLEASE PLACE IN FRONT OF POUCH '1. Foh::i ~ile p1 t. 1i1::d p~ge a:or1g the honzonlal !in~, 2. Place label in shipping pouch and affix it to your shipment. --·-·············-··· ·············•·•·•··••····••·•••••• · · · · · · · · · · · · · · · · · · · - · · - · - - · - - · · · - - - - - - - - - - - - - - - - - - - - - - - - - - ~ > DJ CJ) G) ~ "'0 I"'......."'"" :,:, 0 U) w 0 ClO (J'I U) 0 ~ ~ = = =~ 540C3/PB99/727F Page 14 of 25 HFNA-000001816 EPA Inspection Report - Page 1155 of 1969 . . Seai?ruktm By: ALS 10450 Houston, Te}. +1 281 CUSTODY SEAL Time: Qate: (0/5/55- Page 15 of 25 HFNA-000001817 EPA Inspection Report - Page 1156 of 1969 12-0ct-2017 Erica Howard ALS Environmental 10450 Stancliff Rd Suite 210 Houston, TX 77099 Re: Work Order: HS17100324 1710534 Dear Erica, ALS Environmental received 4 samples on 07-0ct-2017 09:30 AM for the analyses presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Sample results are compliant with industry accepted practices and Quality Control results achieved laboratory specifications. Any exceptions are noted in the Case Narrative, or noted with qualifiers in the report or QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained from ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. The total number of pages in this report is 10. If you have any questions regarding this report, please feel free to contact me. Sincerely, Electronically approved by: Chad Whelton Chad Whelton Project Manager Certificate No: MN 998501 Report of Laboratory Analysis HFNA-000001818 EPA Inspection Report - Page 1157 of 1969 ALS Group, USA Client: Project: Work Order: Date: 12-0ct-17 ALS Environmental HS17100324 Work Order Sample Summary 1710534 Lab Samp ID Client Sample ID Matrix Tag Number Collection Date Date Received 1710534-01 1710534-02 1710534-03 1710534-04 Liquid Liquid Liquid Liquid S-1 S-3 S-5 S-6 10/3/2017 09:29 10/3/2017 09:51 10/3/2017 09:01 10/3/2017 09:05 10/7/2017 09:30 10/7/2017 09:30 10/7/2017 09:30 10/7/2017 09:30 HS17100324-0l HS l 7100324-02 HS17100324-03 HS17100324-04 Page 17 of25 (API HC) (API Water) (T-40) (T-41) Hold Sample Summary Pagel of 1 HFNA-000001819 EPA Inspection Report - Page 1158 of 1969 Date: 12-0ct-17 ALS Group, USA Client: Project: WorkOrder: Qualifier ALS Environmental HS17100324 1710534 QUALIFIERS, ACRONYl\1S, UNITS Description Value exceeds Regulatory Limit ** Estimated Value a Analyte is non-accredited B Anal)1e detected in the associakd Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time J ND Analyte is present at an estimated concentration between the MDL and Report Limit Not Detected at the Reporting Limit 0 Sample amount is> 4 times amount spiked p Dual Column results percent difference > 40% R RPD above laboratory control limit s Spike Recovery outside laboratory control limits u Analyzed but not detected above the MDL X Analyte was detected in the Method Blank between the MDL and Repo1ting Limit, sample results may exhibit background or reagent contamination at the observed level. Acronvm Description DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate LOD Limit of Detection (see MDL) LOQ Limit ofQuantitation (see PQL) MBLK MDL MS Method Blank Method Detection Limit Matrix Spike MSD Matrix Spike Duplicate PQL Practical Quantitation Limit RPD Relative Percent Difference TDL Target Detection Limit TNTC Too Numerous To Count A APHA Standard Methods D ASTM E EPA SW Units Reported SW-846 Update III Description none Page 18 of25 QFPage 1 o/1 HFNA-000001820 EPA Inspection Report - Page 1159 of 1969 Date: 12-0ct-l 7 ALS Group, USA Client: ALS Environmental Project: HS17100324 Sample ID: HS 17100324-01 WorkOrder: 1710534 Lab ID: 1710534-01 Collection Date: 10/3/2017 09:29 AM Matrix: LIQUID Result Analyses Qual Note: Units D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit 0.980 none Dilution Factor Date Analyzed Analyst: RZM 10/11/2017 04:38 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page l of 4 Page 19 of25 HFNA-000001821 EPA Inspection Report - Page 1160 of 1969 Date: 12-0ct-l 7 ALS Group, USA Client: ALS Environmental Project: HS17100324 Sample ID: HS l 7100324-02 WorkOrder: 1710534 Lab ID: 1710534-02 Collection Date: 10/3/2017 09:51 AM Matrix: LIQUID Result Analyses Qual Note: Units D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit 1.00 none Dilution Factor Date Analyzed Analyst: RZM 10/11/2017 04:38 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 2 of 4 Page 20 of25 HFNA-000001822 EPA Inspection Report - Page 1161 of 1969 Date: 12-0ct-l 7 ALS Group, USA Client: ALS Environmental Project: HS17100324 Sample ID: HS l 7100324-03 WorkOrder: 1710534 Lab ID: 1710534-03 Collection Date: 10/3/2017 09:01 AM Matrix: LIQUID Result Analyses Qual Note: Units D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit 1.13 none Dilution Factor Date Analyzed Analyst: RZM 10/11/2017 04:38 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 3 of 4 Page 21 of25 HFNA-000001823 EPA Inspection Report - Page 1162 of 1969 Date: 12-0ct-l 7 ALS Group, USA Client: ALS Environmental Project: HS17100324 Sample ID: HS l 7100324-04 WorkOrder: 1710534 Lab ID: 1710534-04 Collection Date: 10/3/2017 09:05 AM Matrix: LIQUID Result Analyses Qual Note: Units D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit 1.13 none Dilution Factor Date Analyzed Analyst: RZM 10/11/2017 04:38 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 4 of 4 Page 22 of25 HFNA-000001824 EPA Inspection Report - Page 1163 of 1969 Date: 12-0ct-17 ALS Group, USA Client: Work Order: Project: ALS Environmental 1710534 HS17100324 Batch ID: R222011 DUP QC BATCH REPORT Instrument ID WETCHEM D5057-90 Sample ID: 1710534-02A DUP Client ID: HS17100324-02 Analyte Specific Gravity Units: none Run ID: WETCHEM_1710110 Result PQL SPKVal 1.006 0 0 The following samples were analyzed in this batch: Note: Method: SeqNo: 4692983 SPK Ref Value 1710534-01A 171 0534-04A Analysis Date: 10/11/2017 04:38 PM %REC 0 0 1710534-02A OF: 1 Prep Date: Control Limit 0-0 RPO Ref Value 1.003 %RPO 0.279 RPO Limit Qual 20 1710534-03A See Qualifiers Page for a list of Qualifiers and their explanation. QC Page: 1 of 1 Page 23 of25 HFNA-000001825 EPA Inspection Report - Page 1164 of 1969 10450 St:andlff Rd, Ste 210 Houston, TX. 77099 T: +1 281 530 5656 F: +1 261 530 5687 www.alsglobal.com Subcontract Chain of Custody COC ID: 7733 SUBCONTRACT TO: ALS Laboratory Group 3352 UBth Ave. Phone: · +1 616 399 6070 Holland, MI 494249263 ~NVOICE . INFORMATION: CUSTOMER INFORMATION: Company: ALS Houston Company: ALS Houston Contact:: Erica Howard Contact Accounts Payable Address: 10450 Stancliff Rd, Ste 210 Address: 10450 Standlff Rd, Ste 210 _?h__oj1e: + 1 281 Phone: + 1 281 E:_maH: Alternate _erlca. l}o'!"ard@alsglobal ,com Contact Email: 1. 530 5656 Jumi:Jke M. Lawal •• TSR.: Houston House Acct -· - jumoke.lawal@alsglobal.com HS17100324-01 S-1 (API HC) Uquld HS17100324-02 S-3 (API :Wat~r) HS17100324-03 S-5 (T-40) HS17100324-04 s-6 {T-41) 03 Ocl: 2017 09:29 12 Oct 2017 Liquid 03 Oct: 2017 09:51 12 Oct 2017 Uquld- 03 Oct: 2017 09:01 12 Oct 2017 Specific Gravity Sub to ALS Holland 4. •<•<•"• HS17100324 . -· ... - . . ,.c Specific Gravity sub to ALS-Holland 3. 530 5656 ·-•c Reference: Specific Gravity sub to ALS Holland 2. """ Uquld 03 Oct: 2017 09:05 12 act 2017 Specific Gravity sub to ALS Holland Comments: Please analyze for l:he analysis listed above. Send rep·ort to the emails shown above. QC level: STD (Laboratory Standard QC: method blank. and LCS required) : : : :": ,By,~1Y t:· Cooler ID(s): Date/Time: Date/T]me: Temperature(s): £:>el-- c; 2 4 times amount spiked P Dual Column results percent difference > 40% R RPO above laboratory control limit S Spike Recovery outside laboratory control limits U Analyzed but not detected above the MDL/SOL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Unit Reported Description mg/Kg Milligrams per Kilogram mg/L Milligrams per Liter Page 21 of26 HFNA-000001848 EPA Inspection Report - Page 1187 of 1969 ALS Group USA, Corp Date: 1O-Nov-17 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date Arkansas 17-027-0 27-Mar-2018 California 2919 2016-2018 31-Jul-2018 Illinois 004112 09-May-2018 Kentucky 123043 30-Apr-2018 Louisiana 03087 2017-2017 30-Jun-2018 North Carolina 624-2017 31-Dec-2017 North Dakota R193 2017-2017 30-Apr-2018 Oklahoma 2017-088 31-Aug-2018 Texas T104704231-17-19 30-Apr-2018 Page 22 of26 HFNA-000001849 EPA Inspection Report - Page 1188 of 1969 ALS Group USA, Corp Date: 1O-Nov-17 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 03-Nov-2017 09:10 Work Order: HS17110177 Received by: JRM Checklist completed by: Raegen Giga Reviewed by: 3-Nov-2017 Date eSignature Nicole Edwards eSignature Carrier name: Matrices: Shipping container/cooler in good condition? Yes Custody seals intact on shipping container/cooler? Yes Custody seals intact on sample bottles? Yes Chain of custody present? Yes Chain of custody signed when relinquished and received? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes TX1005 solids received in hermetically sealed vials? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Container/Temp Blank temperature in compliance? Yes Temperature(s)/Thermometer(s): ~ ~ D ~ ~ ~ ~ ~ D ~ ~ ~ 1O-Nov-2017 Date FedEx Priority Overnight No No No No No No No No No No No No D D D D D D D D D Not Present D D Not Present ~ Not Present N/A ~ D D D 1.8c/2.1 C uc/c IR 11 ox Cooler( s)/Kit( s): Date/Time sample(s) sent to storage: 11/03/2017 15:39 Water - VOA vials have zero headspace? Yes ;# No Water - pH acceptable upon receipt? Yes D Yes D No pH adjusted? No No VOA vials submitted D D N/A ~ N/A ~ pH adjusted by: Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 23 of26 HFNA-000001850 EPA Inspection Report - Page 1189 of 1969 D Chain of Custody Form I Page _1_ of +1 513 733 5336 I ___j__ Cincinnati, OH D Holland, Ml + 1 616 399 6070 Salt lake City, UT D +1801 266 7700 D Everett, WA D Houston, TX +1 281 530 5656 D Spring City, PA D +1425356 2600 D Middletown, PA D + 1 510 948 4903 +1 717 944 5541 Enuironme ntal ALS Project Manager: Erica Padilla ··.·.·.·.········•cusfomef i11tonriatfon••••• ·····. ••••• A VOLATILES (8260) Benzene ................... •:•••••• Ji~oj~c( N4~b~r •>{Ct.iin~~ily t• •·.:·: ·.· ·.·. } 1 Date 1IH 1111111111111IH 11111111111111 H: Fax (575) 746-5451 .«·>>»:M:: ~I~:;,;~«:: S .". r~ss Gabrieia.Combs6'lhollvfrontiercom ·.·.·. S-1 (API HC) ' Navajo Refining Company BWON Monthly Sampling (EOL) ¢lfvi~tatel~ip Artesia, NM 88211-0159 ,~~; ·:·:·:·: :·>>: ··:·:·: 1 HS17110177 :E: 501 East Main <:•»:•:> :M·:;l:A:,;dc.:,:::• tlurner.am@gmail.com .. ::ec aJ ·.·.·.· ·.· >C ·• •. •)n~oi~{4itt11. Susie Aguilar Gabi Combs P.O. Box 159 :< \ . . \BiliJi{¢oiripariy Holly Frontier Navajo Refining LLC Navajo Refining Company LLC - - A ·1 ""'h II f 1· uzanne. gu1 ar\W o y ron ier.com <<.> 11/02/17 Liquid 9:55AM B X C.,..:,..'-'-i-- --------------- --l-----------i -----1----+-- ---+---i----l-- --+----,1---+ ---+--!----+-- !----1-----: • S-3 (API Water) Liquid 11/02/17 9:18 AM X 8,1 :: S-5 (T-40) 11/02/17 8:45AM Liquid ·• ::: S-6 (T-41) 11!02/17 8:50AM Liquid 8 X 11/02/17 9:06AM Liquid 8,1 X EQ Blank Port 1 >{ 1{ EQ Blank Port 2 Duplicate 11/02/17 9:41 AM Liquid 8,1 X 11/02/17 9:41 AM Liquid 8,1 X 11/02/17 XXX XXX Liquid 8,1 X Liquid 8,1 f • Trip Blank 11/02/17 lO 11/02/17 Temperature Blank X 8 X 2 Liquid 1 Required Turnaround Time: D STD 10 Wk Days IJ'ate: Time: 0 Received by: Dother _ _ __ S Wk Days D 2 Wk Days D 24 Hour Notes: I::- .: "":t . . . . . . . . . . . .>. . . . . . 4:00 Relinquished by:f Date: Time: Received by (Laboratory): ' _,.,,--- u.-..,1··7 ( / t,1..-. logged by (laboratory): Date: Time: Checked by (laboratory): .· Preservative Kl:)y: 1.-HCL 2-HN03 3·H2S04 4-NaOH Cooler Temp. ,""ll'.::.~io 5-Na2S203 s~NaHS04 .C,~ 7.other ,fJ4rrVf 8-4 degrees C Note: Any changes must be made in writing once samples and COC Form have been submitted to ALS laboratory Group. }.g905035 Level II: Standard QC Level III: Std QC+ Raw Data Level IV: SW846 CLP-Like TRRP-Checklis! TRRP Level IV Other: Copyright 2009 by ALS Laboratory Group Page 24 of26 HFNA-000001851 EPA Inspection Report - Page 1190 of 1969 Use of this system constitutes your agreement to the service conditions in the current FedEx Service Guide, available on fedex.com. FedEx will not be responsible for any claim in excess of $100 per package, V'lhether the result of loss, damage, delay, non~delivery, misdelivery, or misinformation, unless you declare a higher va!ue, pay an additional charge, document your actual !oss and flle a timely claim. Limitations found in the current FedEx Service Guide apply. Your right to recover from FedEx for any lms1 including intrinsic value of the pack.age, loss of sales, income interest 1 profit, attorney's fees, costs, and other forms of damage whether direct, incidental, cons:equentia!, or special ls limlted tothe greater of $100 or the authorized declared value. Recovery cannot exceed actual documented !oss. Maximum for items of extraordinary value is $1,000, e.g. jewelry, precious metals, negotiable instruments and other items listed in our Service Guide. Written claims must be filed within strict time !imits1 see current FedEx Service Guide. After ptinting this !abel: CONSIGNEE COPY· PLEASE PLACE IN FRONT OF POUCH 1 Fo!ct the printed page i:'long t~e hofr.:;:.mt2! l!:"le 2., Place labe,I iii shipping pow:h and affix \t to your shipment -l 0 ~!§ .... r :Z:,,Z ~rn~ - ~! )> 0 CD .....<.O ~ UI c:, 0 en CJ (.,.) ~ 0 G) co (J'I w ~ 0 ~ i .i::,. m ..... <.O ~ ~ en ~ z C') r ,; "'T1 en o 0 r ~c - m 0< ;:o ..... ...... ...... z 0 c5 c.:, >O >c::, ::x:: .... <,) ::< C _ :c~ G') -l ~ Page 25 of26 HFNA-000001852 EPA Inspection Report - Page 1191 of 1969 ALS Enuir onme ntal 10450 Stancliff Rd., Suite 210 Houston, Texas 77099 ~ 1;,1. +1 2a1 530 5656 Fax. +1 281 530 5887 "" !(·) Date: t? Page 26 of26 HFNA-000001853 EPA Inspection Report - Page 1192 of 1969 10450 Stancliff Rd. Suite 210 Houston, TX 77099 T: +1 281 530 5656 F: +1 281 530 5887 November 10, 2017 Gabriela Combs Navajo Refining Company PO Box 1490 Artesia, NM 88211-1490 Work Order: HS17110184 Laboratory Results for: BWON Monthly Sampling (EOL) Dear Gabriela, ALS Environmental received 4 sample(s) on Nov 03, 2017 for the analysis presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Results are expressed as "as received" unless otherwise noted. QC sample results for this data met EPA or laboratory specifications except as noted in the Case Narrative or as noted with qualifiers in the QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained by ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. If you have any questions regarding this report, please feel free to call me. Sincerely, Generated By: Dayna.Fisher Nicole Edwards Project Manager Right Solutions · Right Partnu www.a!sg!obaLcom Pagel of25 HFNA-000001854 EPA Inspection Report - Page 1193 of 1969 ALS Group USA, Corp Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS17110184 Date: 10-Nov-17 SAMPLE SUMMARY lab Samp ID Client Sample ID Matrix HS17110184-01 S-1 (API HC) HS17110184-02 TagNo Collection Date Date Received Liquid 02-Nov-2017 09:55 03-Nov-2017 09: 1O S-3 (API Water) Liquid 02-Nov-2017 09: 18 03-Nov-2017 09: 1O HS17110184-03 S-5 (T-40) Liquid 02-Nov-2017 08:45 03-Nov-2017 09: 1O HS17110184-04 S-6 (T-41) Liquid 02-Nov-2017 08:50 03-Nov-2017 09: 1O Hold D D D D Page 2 of25 HFNA-000001855 EPA Inspection Report - Page 1194 of 1969 ALS Group USA, Corp Client: Project: Work Order: Dale: 1O-Nov-17 Navajo Refining Company CASE NARRATIVE BWON Monthly Sampling (EOL) HS17110184 Work Order Comments • The analysis for Specific Gravity was subcontracted lo ALS Environmental in Holland, Ml. Final report attached. Page 3 of25 HFNA-000001856 EPA Inspection Report - Page 1195 of 1969 ALS Group USA, Corp Client: Project: Sample ID: Collection Date: ANALYSES Date: 1O-Nov-17 RESULT QUAL SUBCONTRACTED ANALYSIS Miscellaneous Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-1 (API HC) 02-Nov-2017 09:55 MDL Work0rder:HS17110184 Lab ID:HS17110184-01 Matrix: Liquid REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED Method:NA See Attached 0 1O-Nov-2017 13:56 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 4 of25 HFNA-000001857 EPA Inspection Report - Page 1196 of 1969 ALS Group USA, Corp Date: 1O-Nov-17 Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Sample ID: Collection Date: S-3 (API Water) ANALYSES Work0rder:HS17110184 Lab ID:HS17110184-02 Matrix: Liquid 02-Nov-2017 09: 18 RESULT QUAL SUBCONTRACTED ANALYSIS Miscellaneous Analysis ANALYTICAL REPORT MDL REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED Method:NA See Attached 0 1O-Nov-2017 13:56 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 5 of25 HFNA-000001858 EPA Inspection Report - Page 1197 of 1969 ALS Group USA, Corp Date: 1O-Nov-17 Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Sample ID: Collection Date: S-5 (T-40) ANALYSES Work0rder:HS17110184 Lab ID:HS17110184-03 Matrix: Liquid 02-Nov-2017 08:45 RESULT QUAL SUBCONTRACTED ANALYSIS Miscellaneous Analysis ANALYTICAL REPORT MDL REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED Method:NA See Attached 0 1O-Nov-2017 13:56 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 6 of25 HFNA-000001859 EPA Inspection Report - Page 1198 of 1969 ALS Group USA, Corp Date: 1O-Nov-17 Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Sample ID: Collection Date: S-6 (T-41) ANALYSES Work0rder:HS17110184 Lab ID:HS17110184-04 Matrix: Liquid 02-Nov-2017 08:50 RESULT QUAL SUBCONTRACTED ANALYSIS Miscellaneous Analysis ANALYTICAL REPORT MDL REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED Method:NA See Attached 0 1O-Nov-2017 13:56 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 7 of25 HFNA-000001860 EPA Inspection Report - Page 1199 of 1969 ALS Group USA, Corp Navajo Refining Company Client: Project: WorkOrder: BWON Monthly Sampling (EOL) R305229 HS17110184-01 DA TES REPORT HS17110184 Client Samp ID Sample ID Batch ID Date: 1O-Nov-17 Collection Date TCLP Date Test Name : SUBCONTRACTED ANALYSIS Analysis Date Prep Date DF Matrix: Liquid S-1 (API HC) 02 Nov 2017 09:55 10 Nov 201713:56 HS17110184-02 S-3 (API Water) 02 Nov 2017 09:18 10 Nov 201713:56 HS17110184-03 S-5 (T-40) 02 Nov 2017 08:45 10 Nov 201713:56 HS17110184-04 S-6 (T-41) 02 Nov 2017 08:50 10 Nov 201713:56 Page 8 of25 HFNA-000001861 EPA Inspection Report - Page 1200 of 1969 ALS Group USA, Corp Client: Project: WorkOrder: Qualifier Date: 1O-Nov-17 Navajo Refining Company BWON Monthly Sampling (EOL) HS17110184 QUALIFIERS, ACRONYMS, UNITS Description Value exceeds Regulatory Limit a Not accredited B Analyte detected in the associated Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time J Analyte detected below quantitation limit M Manually integrated, see raw data for justification n Not offered for accreditation ND Not Detected at the Reporting Limit 0 Sample amount is> 4 times amount spiked p Dual Column results percent difference > 40% R RPO above laboratory control limit s u Spike Recovery outside laboratory control limits Analyzed but not detected above the MDL/SOL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Page 9 of25 HFNA-000001862 EPA Inspection Report - Page 1201 of 1969 ALS Group USA, Corp Date: 1O-Nov-17 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date Arkansas 17-027-0 27-Mar-2018 California 2919 2016-2018 31-Jul-2018 Illinois 004112 09-May-2018 Kentucky 123043 30-Apr-2018 Louisiana 03087 2017-2017 30-Jun-2018 North Carolina 624-2017 31-Dec-2017 North Dakota R193 2017-2017 30-Apr-2018 Oklahoma 2017-088 31-Aug-2018 Texas T104704231-17-19 30-Apr-2018 Page 10 of25 HFNA-000001863 EPA Inspection Report - Page 1202 of 1969 ALS Group USA, Corp Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS17110184 Date: 10-Nov-17 SAMPLE TRACKING Lab Sarnp ID Client Sample ID Action Date Person New Location HS17110184-01 S-1 (API HG) Login 11/3/2017 3:48:05 PM RPG Sub HS17110184-02 S-3 (API Water) Login 11/3/2017 3:48:05 PM RPG Sub HS17110184-03 S-5 (T-40) Login 11/3/2017 3:48:05 PM RPG Sub HS17110184-04 S-6 (T-41) Login 11/3/2017 3:48:05 PM RPG Sub Page 11 of25 HFNA-000001864 EPA Inspection Report - Page 1203 of 1969 ALS Group USA, Corp Date: 1O-Nov-17 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 03-Nov-2017 09:10 Work Order: HS17110184 Received by: JRM Checklist completed by: Raegen Giga Reviewed by: 3-Nov-2017 Date eSignature Nicole Edwards eSignature Carrier name: Matrices: Shipping container/cooler in good condition? Yes Custody seals intact on shipping container/cooler? Yes Custody seals intact on sample bottles? Yes Chain of custody present? Yes Chain of custody signed when relinquished and received? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes TX1005 solids received in hermetically sealed vials? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Container/Temp Blank temperature in compliance? Yes Temperature(s)/Thermometer(s): ~ ~ D ~ ~ ~ ~ ~ D ~ ~ ~ FedEx Priority Overnight No No No No No No No No No No No No D D D D D D D D D Not Present D D Not Present ~ Not Present N/A ~ D D D 1.8c/2.1 C uc/c Cooler( s)/Kit( s): 1O-Nov-2017 Date IR 11 ox Date/Time sample(s) sent to storage: 11/03/2017 16:00 Water - VOA vials have zero headspace? Yes ;# No Water - pH acceptable upon receipt? Yes D Yes D No pH adjusted? No No VOA vials submitted D D N/A ~ N/A ~ pH adjusted by: Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 12 of25 HFNA-000001865 EPA Inspection Report - Page 1204 of 1969 D Chain of Custody Form Page _1_ of ____j_ Cincinnati, OH +1 513 733 5336 D Holland, Ml D + 1 616 399 6070 D D Houston, TX Everett, WA D +l 425 356 2500 D Middletown, PA +1 281 530 5656 +1 717 944 5541 Salt Lake City, UT +l 801 266 7700 D Spring City, PA D +1610 948 4903 Enuironme ntal ALS ProjectManager: Erica Padilla ··•·•·•·•·•·•••••••••••••••••••customer iijf()rmatfon ••••••·•·•···· .............. \():~ojectNartie BWON Monthly Sampling (EOL) • •••••••P~r~nase dicier • C~m~~ny Name Navajo Refining Company LLC Tyler Turner ~iUTo}k.n1pan)i Holly Frontier Navajo Refining LLC HS17110184 Navajo Refining Company P.O. Box 159 501 East Main > ~ity/~tatel#ii> Artesia, NM 88211-0159 . ·········· ........ . > C I. ........................Address •••••••••••••••• • Pii~iie > J".c1x >>> . Work Order#: Artesia, New Mexico 88210 . .•.<'.iityJSfate/Zip .. .... .. (575) 145.5451 1111111111111111 , .... <<.• (575) 748-3311 ... Ptiona (575) 748-3311 >: > .•<>>: .. · • <: : :: ••:.. • Notes: '-f:~IJ Time: Time: Received by {Laboratory): ' Cooler Temp. Level II: Standard QC Level III: Std QC+ Raw Data Level IV: SW846 CLP-Like Checked by {Laborato,:y): 5-Na2S203 6,NaHS04 . :7 . Note: Any changes must be made in writing once samples and COC Form have been submitted to ALS Laboratory Group. .·.< ·.·.·.·.· CIC PackagEi:(Chei;.1(139:x.~EllC!vv}.·······:·•······ .<· .· . <<< TR RP-Checklist TRRP Level IV Other: Copyright 2009 by ALS Laboratory Group Page 13 of 25 HFNA-000001866 EPA Inspection Report - Page 1205 of 1969 Use of this system constitutes your agreement to the service conditions in the current FedEx Service Guide, available on fedex:.com. FedEx will not be responsible for any daim in excess of $100 per package, whether the result of !ass, damage, delay, non--deliverv, misde!ivery, or misinformation, unless you declare a higher value, pay an additional charge, document your actual loss and file a timely claim. limitations found in the current FedEx Service Guide apply. Your right to recover from FedEx for any loss, including intrinsic value of the package, loss of sales, income interest, profit, attorne/s fees, costs, and other forms of damage whether direct, incidental, consequentia I, or special is fimlted to the greater of $100 or the authorized declared value. Recovery cannot exceed actual documented loss. rvlaximum for items of extraordinary value is $1,000, e.g. jewelry, precious metals, negotlab!e Instruments and other items listed in our Service Guide. Written claims must be filed within strict time limits, see current FedEx Service Guide. After printing ttiis label: CONSIGNEE COPY· PLEASE PLACE IN FRONT OF POUCH 1 Fold the piinted page along the Mnz.ontal lme 2. Place label in shipping pouch and affix it 10 your shJpment ------------------------------------------ )> CD ... )>Z .-(/) 8 i~. 0 ....... 0 ~ ....... rm m i ~ (/) ~ !'l I 0 ri> '"t] 22 0 ,, ei 0 :::0 22 -< (.,) =i ... Q g 0 z m ~ X C: _....,-.a "' ::0 ):>O > i5 w ::c 0 :r:~ C G) z ..... 0 -l )> Page 14 of 25 HFNA-000001867 EPA Inspection Report - Page 1206 of 1969 (?C~ ",L I ALS enu lron men tal · 10450 Stancliff Rd., Suite 210 Housto n, Texas 77099 Tai. +1 281 530 5656 Fax. +1 281 530 5887' Page 15 of 25 HFNA-000001868 EPA Inspection Report - Page 1207 of 1969 1O-Nov-2017 Nicole Edwards ALS Environmental 10450 Stancliff Rd Suite 210 Houston, TX 77099 Re: Work Order: HS17110184 1711345 Dear Nicole, ALS Environmental received 4 samples on 04-Nov-2017 09:45 AM for the analyses presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Sample results are compliant with industry accepted practices and Quality Control results achieved laboratory specifications. Any exceptions are noted in the Case Narrative, or noted with qualifiers in the report or QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained from ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. The total number of pages in this report is 10. If you have any questions regarding this report, please feel free to contact me. Sincerely, Electronically approved by: Chad Whelton Chad Whelton Project Manager Certificate No: MN 998501 Report of Laboratory Analysis HFNA-000001869 EPA Inspection Report - Page 1208 of 1969 ALS Group, USA Client: Project: Work Order: Date: 10-Nov-17 ALS Environmental HS17110184 Work Order Sample Summary 1711345 Lab Samp ID Client Sample ID Matrix Tag Number 1711345-01 1711345-02 1711345-03 1711345-04 Liquid Liquid Liquid Liquid S-1 S-2 S-5 S-6 HS17l l0184-0l HS17110184-02 HS17110184-03 HS17110184-04 Page 17 of25 (API HC) (API Water) (T-40) (T-41) Collection Date Date Received 11/2/2017 09:55 11/2/2017 09:18 11/2/2017 08:45 11/2/2017 08:50 11/4/2017 09:45 11/4/2017 09:45 11/4/2017 09:45 11/4/2017 09:45 Hold Sample Summary Pagel of 1 HFNA-000001870 EPA Inspection Report - Page 1209 of 1969 Date: 10-Nov-l 7 ALS Group, USA Client: Project: WorkOrder: Qualifier ALS Environmental HS17110184 1711345 QUALIFIERS, ACRONYl\1S, UNITS Description Value exceeds Regulatory Limit ** Estimated Value a Analyte is non-accredited B Anal)1e detected in the associakd Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time J ND Analyte is present at an estimated concentration between the MDL and Report Limit Not Detected at the Reporting Limit 0 Sample amount is> 4 times amount spiked p Dual Column results percent difference > 40% R RPD above laboratory control limit s Spike Recovery outside laboratory control limits u Analyzed but not detected above the MDL X Analyte was detected in the Method Blank between the MDL and Repo1ting Limit, sample results may exhibit background or reagent contamination at the observed level. Acronvm Description DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate LOD Limit of Detection (see MDL) LOQ Limit ofQuantitation (see PQL) MBLK MDL MS Method Blank Method Detection Limit Matrix Spike MSD Matrix Spike Duplicate PQL Practical Quantitation Limit RPD Relative Percent Difference TDL Target Detection Limit TNTC Too Numerous To Count A APHA Standard Methods D ASTM E EPA SW Units Reported SW-846 Update III Description none Page 18 of25 QFPage 1 o/1 HFNA-000001871 EPA Inspection Report - Page 1210 of 1969 Date: JO-Nov-17 ALS Group, USA Client: ALS Environmental Project: HS17110184 Sample ID: HS17110184-0l Work Order: 1711345 Lab ID: 1711345-01 Collection Date: 11/2/2017 09:55 AM Matrix: LIQUID Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 1.00 none Dilution Factor Date Analyzed Analyst: RZM 11/9/2017 04:50 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page l of 4 Page 19 of25 HFNA-000001872 EPA Inspection Report - Page 1211 of 1969 Date: JO-Nov-17 ALS Group, USA Client: ALS Environmental Project: HS17110184 Sample ID: HS17110184-02 Work Order: 1711345 Lab ID: 1711345-02 Collection Date: 11/2/2017 09: 18 AM Matrix: LIQUID Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 1.01 none Dilution Factor Date Analyzed Analyst: RZM 11/9/2017 04:50 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 2 of 4 Page 20 of25 HFNA-000001873 EPA Inspection Report - Page 1212 of 1969 Date: JO-Nov-17 ALS Group, USA Client: ALS Environmental Project: HS17110184 Sample ID: HS17110184-03 Work Order: 1711345 Lab ID: 1711345-03 Matrix: LIQUID Collection Date: 11/2/2017 08:45 AM Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 1.13 none Dilution Factor Date Analyzed Analyst: RZM 11/9/2017 04:50 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 3 of 4 Page 21 of25 HFNA-000001874 EPA Inspection Report - Page 1213 of 1969 Date: JO-Nov-17 ALS Group, USA Client: ALS Environmental Project: HS17110184 Sample ID: HS17110184-04 Work Order: 1711345 Lab ID: 1711345-04 Matrix: LIQUID Collection Date: 11/2/2017 08:50 AM Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 1.13 none Dilution Factor Date Analyzed Analyst: RZM 11/9/2017 04:50 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 4 of 4 Page 22 of25 HFNA-000001875 EPA Inspection Report - Page 1214 of 1969 Date: 10-Nov-l 7 ALS Group, USA Client: ALS Environmental Work Order: Project: 1711345 HS17110184 Batch ID: R224230 DUP QC BATCH REPORT Instrument ID WETCHEM D5057-90 Sample ID: 1711345-02A DUP Client ID: HS17110184-02 Analyte Specific Gravity Units: none Run ID: WETCHEM_171109M Result PQL SPKVal 1.007 0 0 The following samples were analyzed in this batch: Note: Method: SeqNo: 4751313 SPK Ref Value 1711345-01A 1711345-04A Analysis Date: 11/9/2017 04:50 PM %REC 0 0 1711345-02A OF: 1 Prep Date: Control Limit 0-0 RPO Ref Value 1.006 %RPO 0.139 RPO Limit Qual 20 1711345-03A See Qualifiers Page for a list of Qualifiers and their explanation. QC Page: 1 of 1 Page 23 of25 HFNA-000001876 EPA Inspection Report - Page 1215 of 1969 -- A 10450 Stancllff Rd, Ste 210 Hou_ston, TX 77099 T: +1 281 530 5656 - - s F: +1 2~! 530 58~7 www.als§1lobal.com Subcontract Chain of Custody COC ID: 7991 SUBCONTRACT TO: ALS Laboratory Group 3352 128th Ave. Phone: Holland, Ml 494249263 - CUSTOMER INFORMATION: +1 616 399 6070 INVOICE INFORMATION: Company: ALS Houston Company: ALS Houston Contact: Nicole Edwards Accounts Payable +1 281 530 5656 Address: 10450 stanclllf Rd, Ste 210 Contact: Addrus: Phone: +1 281 530 5656 Phone: - sEmaHL -- - - Nlcole.Edwards@alsglobal.com-- Alternate Contact: Emall: 1. 10450 Stancliff Rd, Ste 210 ___ , __ -" Reference:__ HS17-ll0184 - _ TSR: J1J111ok_E! M. Lawal Houston House Acct jumoke.lawal@alsgJobal.com HS17110184-01 Uquld S-1 (API HC) Specific Gravity Sub to ALS Holland 2. 10 Nov 2017 L,lquld HS17110184-02 Specific Gravity Sub to ALS Holland 3, - HSl.7110184-03 s~s (T-40) HS17110184--04 02 Nov 2017 09:18 10 Nov 2017 - UqiJld Specific Gravity Sub to ALS Holland 4. 02 Nov 2017 09:55 02 Nov 2017 08:45 10 Nov 2017 Uquld S-6 (T-41) Specific Gravity Sub to ALS Holland 02 Nov 2017 08:50 10 Nov 2017 eo·mments: Please analyze for the analysis listed above. Send report to the emalls shown above. QC Level: STD (Laboratory Standard QC: method blank and LCS required) Rellnqulshed By: Date/Time: Received By: Date/Time: Cooler ID(s): Temperature(s): IJ }(? 1 } (,,.. ( ~ Y-( ) O 4 times amount spiked p Dual Column results percent difference > 40% R RPO above laboratory control limit s u Spike Recovery outside laboratory control limits Analyzed but not detected above the MDL/SOL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Page 9 of25 HFNA-000001887 EPA Inspection Report - Page 1226 of 1969 ALS Group USA, Corp Date: 14-Dec-17 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date Arkansas 17-027-0 27-Mar-2018 California 2919 2016-2018 31-Jul-2018 Illinois 004112 09-May-2018 Kentucky 123043 30-Apr-2018 Louisiana 03087 2017-2017 30-Jun-2018 North Carolina 624-2017 31-Dec-2017 North Dakota R193 2017-2017 30-Apr-2018 Oklahoma 2017-088 31-Aug-2018 Texas T104704231-17-19 30-Apr-2018 Page 10 of25 HFNA-000001888 EPA Inspection Report - Page 1227 of 1969 ALS Group USA, Corp Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS17120448 Date: 14-Dec-17 SAMPLE TRACKING Lab Sarnp ID Client Sample ID Action Date Person New Location HS17120448-01 S-1 (API HG) Login 12/8/2017 1:24:53 PM RPG Sub HS17120448-02 S-3 (API Water) Login 12/8/2017 1:24:53 PM RPG Sub HS17120448-03 S-5 (T-40) Login 12/8/2017 1:24:53 PM RPG Sub HS17120448-04 S-6 (T-41) Login 12/8/2017 1:24:53 PM RPG Sub Page 11 of25 HFNA-000001889 EPA Inspection Report - Page 1228 of 1969 ALS Group USA, Corp Date: 14-Dec-17 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 06-Dec-2017 09:50 Work Order: HS17120448 Received by: JRM Checklist completed by: Raegen Giga Reviewed by: 8-Dec-2017 Date eSignature Nicole Edwards eSignature Carrier name: Matrices: ~ ~ Shipping container/cooler in good condition? Yes Custody seals intact on shipping container/cooler? Yes Custody seals intact on sample bottles? Yes Chain of custody present? Yes Chain of custody signed when relinquished and received? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes TX1005 solids received in hermetically sealed vials? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Container/Temp Blank temperature in compliance? Yes Temperature(s)/Thermometer(s): .1 c/2.4c uc/c Cooler( s)/Kit( s): D ~ ~ ~ ~ ~ D ~ ~ ~ 8-Dec-2017 Date FedEx Priority Overnight No No No No No No No No No No No No D D D D D D D D D Not Present D D Not Present ~ Not Present N/A ~ D D D IR 11 oam Date/Time sample(s) sent to storage: 12/06/2017 13:51 Water - VOA vials have zero headspace? Yes ;# No Water - pH acceptable upon receipt? Yes D Yes D No pH adjusted? No No VOA vials submitted D D N/A ~ N/A ~ pH adjusted by: Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 12 of25 HFNA-000001890 EPA Inspection Report - Page 1229 of 1969 Ch ain of Cu sto dy Fo rm HS 171 204 48 1 c'="~'"". . . :"":' .7"":"l~"" . . ~-: :::""'o~-lll-;'"T:tit"'"o'"'.... ": ·.,.,.·::"'"'·:·:'""·........... ..,..............·"'".··:__ :e..,.:::,.,.::n-: 11 A-.L-:: ;-.'."'".;-o""l'·~~-e--:.-e~:-:t"l"!l:-·~;-0,.,... .::,-: ..... -:-:n""'c........ a--P,..,.a. .:-' . . .__ .ll-a .....-__ ....---j__ __ --+.....: .. -......::-:""':::-:- :-.-r~;i- ·"""::::"""•::'!"":<_,.,..:::: ... ,..,. .. :..,.• :..-·"""': :.............. ·• : Pt6je~{~arne BWON Monthly Sampling (EOL) >: (;Jln1pa11yJ1laltle Navajo Refining Company LLC Tyler Turne r Bili>To Coniµany . •. •:A: Specific Gravity .JIHfft'.1]nnJrm1 111 Holly Frontier Navajo Refin ing LLC ...... Gabl Comb s .. : P.O. Box 159 501 East Main > \(:;ify/$tatei2ip Artesia, NM 88211-0159 1 • i• • .·:·:· ..... : ·. :.;.."'-~ ~ ·>'. "'.".'.'.'~• > ,: (575) 748-3311 .· .. . ·.·.:· Fax (s1s1746-5451 .·.·.·::::·. ·>: : : Fax .. H (s1sJ 746-5451 Suzanne.Aguilar@lhollyfrontier.com ·.·. > :fi!J:1~ ...... Mat~x> : ;J • 11fti1es I Liqui d 8 1 X 9:36A M liqui d 8 1 X 12/0 5/17 9:00A M Liqui d 8 X 12/0 5/17 9:05AM liqui d 8 X i> ~ ·•· >: . Pres: S-3 (API Water) S-5 (T-40) : S-6 (T-41) G •:-··~ (575) 748-3311 ))af e . '.1/ S-1 (API HC) 1:>~ .· . ::::.::··· e"MaUA;dd~ss .... Gab~[a.Combs .. .·.· : : ·,: . .. ::·::· .·~Ma li Aciciress uume, am@gmailcorn ... :..... . . . ........ : <{: ·.· 12/05/17 9:48A M 12/05/17 .· ·.· .· . o EE:: ::: .: .. H J ::,: • H<>ict 1,: ( .· ·.·.· . :: .~:: .-.~ <10 > ! Requ ired Turn arou nd Time: 0 Relinq uished by: ' Date: Received by {Labo ratory ): Time: Checked by (Laborato!Y): J.:?/c:/1/ Logged by (Laboratory): Preservative Key: Time: 1~HCL 2-HN03 3~H2S04 STD IO Wk Days E) 5 Wk Days 0 5-Na2S203 6-NaHS04 7-0tfler O 24 Hour Notes: Coole r Temp. 4-NaOH Omher _ _ __ 2 Wk Days 1 8-4 degr ees C Note: Any changes must be made in writin g once samples and COC Form have been submitted to ALS Laboratory Group. ' 9-503 5 F:,-,:,,,,.'1_ (J,z;,f~ I .· <: •••• / . .·. . q9 P.arikag~: (9he~~ B~JC ~elov,i). / < : .. Level II: Standard QC Level Ill: Std QC+ Raw Data Level IV: SW8 46 CLP- Like ITRRP-Checklist ITRR P Level IV Othe r: Copyright 2009 by ALS Laboratory Grou p Page 13 of 25 HFNA-000001891 EPA Inspection Report - Page 1230 of 1969 Use of thls system constitutes your agreement to the service condltlons in the current FedEx Service Guide, available on fedex.com. FedEx will not be responsible for any claim in excess of $100 per package, whether the result of loss, damage, deiay, non-delivery, misdelivery, er misinformation, unless you declare a h!gher value, pay an additional charge, document your actual !ass and file a timely claim. limitations fourid in the current FedEx Service Guide apply. Your right to recover from FedEx for any loss, including intrinsic value of the package, loss of sales, income interest, profit, attorney's fees, costs, and [~Ji CD ...... en w 0 (,I) 0 CIO G) 01 ::t: :::c ~ 0 -i ~ )>O ;:o 0 Page 14 of 25 HFNA-000001892 EPA Inspection Report - Page 1231 of 1969 SHIPPER'S DECLARATION FOR DANGEROUS GOODS (Provide at least three copies to airline.) Shipper 709308590512 Air Waybill No. Brady Hubbard AQUA MICROBICS 501 E MAIN C/0 AQUA MICROBICS ARTESIA NM88210 US Page 1 of 1 Page(s) ~:x Shipper's Reference Number (optional) Consignee Nicole Edwards ALS 10450 Stancliff Suite 210 HOUSTON 18 Compliant Express CAFE3108 TX77099 US Two completed and signed copies of this Declaration must be handed to the operator WARNING TRANSPORT DETAILS Failure to comply with all respects with the applicable Dangerous Goods Regulations may be in breach of the applicable law ,subject to legal penalties. This shipment is within the !imitations prescribed for: {delete non applicable) Airport of Departure ARTESIA ~ T V Airport of Destination: HOUSTON Shinment tvne: ABSGRA ,,. •n•. (delete non appllcable) NATURE AND QUANTITY OF DANGEROUS GOODS UN Number or identification Number, proper shipping name, ('.Jass or Division (subsidiary risk), packing group (if required), and all other required Information. UN UN 3266. Corrosive liquid, basic, inorganic, n.o.s.(Sodium Hydroxide),8,1// 1268, Petroleum distillates, n.o.s.,3,1111/ 0.04 U/366 0.08 U/854 All Packed In One FIBREBOARD BOX Q =0.1 -·---------------------------------------------------------------------------------------------------------------~--------~-----Additional Handling Information 24-Hour Emergency Response- CHEMTREC 1·800-424·9300, CCN 201319 I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged, marked and labelled/placarded, and are in all respects in proper condition for transport according to applicable International and National Governmental Regulations. I declare that all of the applicable air transport requirements have been met. Name/Title of Signatory Brady Hubbard/Environmental Coordinator Place and Date Artesia.NM 12/05i2017 Signature (see warning above) 18004249300 EmergMcy 1'elophone Number Brady Hubbard l r~ 1.J;..Lt-1 FOR RAOIOACTIVE MATERIAL SHIPMENT ACCEPTABLE FOR ?ASSENGER AIRCRAFT, THE SHIPMENT CONTAINS RAOlOACTIVE MATERIAL INTENDED FOR USE IN OR INC!nENTTO RESEARCH, MEDICAL DIAGNOSIS OR TREATMENT. AOR EUROPEAN TRANSPORT STATEMENT: CARRIAGE IN ACCORDANCE WITH 1.1.4.2.1 LOGOS !i157295 11/12 Page 15 of 25 HFNA-000001893 EPA Inspection Report - Page 1232 of 1969 14-Dec-2017 Nicole Edwards ALS Environmental 10450 Stancliff Rd Suite 210 Houston, TX 77099 Re: Work Order: HS17120448 1712629 Dear Nicole, ALS Environmental received 4 samples on 09-Dec-2017 11 :30 AM for the analyses presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Sample results are compliant with industry accepted practices and Quality Control results achieved laboratory specifications. Any exceptions are noted in the Case Narrative, or noted with qualifiers in the report or QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained from ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. The total number of pages in this report is 10. If you have any questions regarding this report, please feel free to contact me. Sincerely, Electronically approved by: Chad Whelton Chad Whelton Project Manager Certificate No: MN 998501 Report of Laboratory Analysis HFNA-000001894 EPA Inspection Report - Page 1233 of 1969 ALS Group, USA Client: Project: Work Order: Date: 14-Dec-17 ALS Environmental HS 17120448 Work Order Sample Summary 1712629 Lab Samp ID Client Sample ID Matrix Tag Number Collection Date Date Received 1712629-01 1712629-02 1712629-03 1712629-04 Liquid Liquid Liquid Liquid S-1 S-3 S-5 S-6 12/5/2017 09:48 12/5/2017 09:36 12/5/2017 09:00 12/5/2017 09:05 12/9/2017 12/9/2017 12/9/2017 12/9/2017 HS17120448-0l HS l 7120448-02 HSI 7120448-03 HS17120448-04 Page 17 of25 (API HC) (API Water) (T-40) (T-41) Hold 11:30 11:30 11:30 11:30 Sample Summary Pagel of 1 HFNA-000001895 EPA Inspection Report - Page 1234 of 1969 Date: 14-Dec-17 ALS Group, USA Client: Project: WorkOrder: Qualifier ALS Environmental HS17120448 1712629 QUALIFIERS, ACRONYl\1S, UNITS Description Value exceeds Regulatory Limit ** Estimated Value a Analyte is non-accredited B Anal)1e detected in the associakd Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time J ND Analyte is present at an estimated concentration between the MDL and Report Limit Not Detected at the Reporting Limit 0 Sample amount is> 4 times amount spiked p Dual Column results percent difference > 40% R RPD above laboratory control limit s Spike Recovery outside laboratory control limits u Analyzed but not detected above the MDL X Analyte was detected in the Method Blank between the MDL and Repo1ting Limit, sample results may exhibit background or reagent contamination at the observed level. Acronvm Description DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate LOD Limit of Detection (see MDL) LOQ Limit ofQuantitation (see PQL) MBLK MDL MS Method Blank Method Detection Limit Matrix Spike MSD Matrix Spike Duplicate PQL Practical Quantitation Limit RPD Relative Percent Difference TDL Target Detection Limit TNTC Too Numerous To Count A APHA Standard Methods D ASTM E EPA SW Units Reported SW-846 Update III Description none Page 18 of25 QFPage 1 o/1 HFNA-000001896 EPA Inspection Report - Page 1235 of 1969 Date: 14-Dec-l 7 ALS Group, USA Client: ALS Environmental Project: HS17120448 Sample ID: HS17120448-0l WorkOrder: 1712629 Lab ID: 1712629-01 Collection Date: 12/5/2017 09:48 AM Matrix: LIQUID Result Analyses Qual Note: Units D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit 1.00 none Dilution Factor Date Analyzed Analyst: RZM 12/13/2017 04: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page l of 4 Page 19 of25 HFNA-000001897 EPA Inspection Report - Page 1236 of 1969 Date: 14-Dec-l 7 ALS Group, USA Client: ALS Environmental Project: HS17120448 Sample ID: HS l 7120448-02 WorkOrder: 1712629 Lab ID: 1712629-02 Collection Date: 12/5/2017 09:36 AM Matrix: LIQUID Result Analyses Qual Note: Units D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit 1.00 none Dilution Factor Date Analyzed Analyst: RZM 12/13/2017 04: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 2 of 4 Page 20 of25 HFNA-000001898 EPA Inspection Report - Page 1237 of 1969 Date: 14-Dec-l 7 ALS Group, USA Client: ALS Environmental Project: HS17120448 Sample ID: HS l 7120448-03 WorkOrder: 1712629 Lab ID: 1712629-03 Collection Date: 12/5/2017 09:00 AM Matrix: LIQUID Result Analyses Qual Note: Units D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit 1.14 none Dilution Factor Date Analyzed Analyst: RZM 12/13/2017 04: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 3 of 4 Page 21 of25 HFNA-000001899 EPA Inspection Report - Page 1238 of 1969 Date: 14-Dec-l 7 ALS Group, USA Client: ALS Environmental Project: HS17120448 Sample ID: HS17120448-04 WorkOrder: 1712629 Lab ID: 1712629-04 Collection Date: 12/5/2017 09:05 AM Matrix: LIQUID Result Analyses Qual Note: Units D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit 1.15 none Dilution Factor Date Analyzed Analyst: RZM 12/13/2017 04: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 4 of 4 Page 22 of25 HFNA-000001900 EPA Inspection Report - Page 1239 of 1969 Date: 14-Dec-l 7 ALS Group, USA Client: Work Order: Project: ALS Environmental Batch ID: R226448 DUP QC BATCH REPORT 1712629 HS17120448 Instrument ID WETCHEM D5057-90 Sample ID: 1712629-02A DUP Client ID: HS17120448-02 Analyte Specific Gravity Analysis Date: 12/13/2017 04:15 PM Units: none Run ID: WETCHEM_171213R. Result PQL SPKVal 1.002 0 0 The following samples were analyzed in this batch: Note: Method: SPK Ref Value 1712629-01A 1712629-04A %REC 0 0 1712629-02A OF: 1 Prep Date: SeqNo: 4809420 Control Limit 0-0 RPO Ref Value 1.003 %RPO 0.0299 RPO Limit Qual 20 1712629-03A See Qualifiers Page for a list of Qualifiers and their explanation. QC Page: 1 of 1 Page 23 of25 HFNA-000001901 EPA Inspection Report - Page 1240 of 1969 ,· . -·~ •:- .• ' -- . ··-· -~. -: ,;;,:-:~ .:-···· 10450 Stancliff Rd, Ste 210 Houston, TX 77099 +1 281 530 5656 +1 281 530 5887 T: F: www.alsglobal.com Subcontract Chain of Custody COC ID: 8189 SUBCONTRACT TO: ALS Laboratory Group 3352 128th Ave. Phone: Holland, MI 494249263 +1 616 399 6070 INVOICE INFORMATION: CUSTOMER INFORMATION: company: ALS Houston Company: ALS Houston Contact: Nicole Edwards contact: Accounts Payable Address: 10450 Stancliff Rd, Ste 210 Address: 10450 Stancliff Rd, Ste 210 Phone: + 1 281 530 5656 Phone: + 1 281 530 5656 Email: Nicole. Edwa rds@alsglobal.com Refm-ence: HS17120448 TSR: Houston House Acct Alternate Contact: Jumoke M. Lawal Email: jumoke.lawal@alsglobal.com 1. Liquid HS17120448-01 13 Dec 2017 Specific Gravity Sub to ALS Holland 2. HS17120448-02 Liquid S-3 (API Water) HS17120448-03 Liquid S-5 (T-40) HS17120448--04 05 Dec 2017 09:00 13 Dec 2017 Specific Gravity Sub to ALS Holland 4, 05 Dec 2017 09:36 13 Dec 2017 Specific Gravity Sub to ALS Holland 3. 05 Dec 2017 09:48 Liquid S-6 (T-41} 05 Dec 2017 09:05 13 Dec 2017 Specific Gravity Sub to ALS Holland Comments: Please analyze for the analysis listed above. Send report to the emails shown above. QC level: STD (Laboratory Standard QC: method blank and LCS required) Relinquished By: Date/Tlme: Received By: Date/Time: Cooler ID(s): Tern perature( s): '~filf 1~;: 1 .n 3R,2 2 (;, C SOS SHEETS ATTACHED Page 24 of25 HFNA-000001902 EPA Inspection Report - Page 1241 of 1969 ALS Group, USA Sample Receipt Checklist Client Name: ALS - HOUSTON Date/Time Received: Work Order: 1712629 Received by: Checklist completed by _LlULK 4 times amount spiked P Dual Column results percent difference > 40% R RPO above laboratory control limit S Spike Recovery outside laboratory control limits U Analyzed but not detected above the MDL/SOL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Unit Reported Description mg/Kg Milligrams per Kilogram mg/L Milligrams per Liter Page 21 of26 HFNA-000001924 EPA Inspection Report - Page 1263 of 1969 ALS Group USA, Corp Date: 13-Dec-17 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date Arkansas 17-027-0 27-Mar-2018 California 2919 2016-2018 31-Jul-2018 Illinois 004112 09-May-2018 Kentucky 123043 30-Apr-2018 Louisiana 03087 2017-2017 30-Jun-2018 North Carolina 624-2017 31-Dec-2017 North Dakota R193 2017-2017 30-Apr-2018 Oklahoma 2017-088 31-Aug-2018 Texas T104704231-17-19 30-Apr-2018 Page 22 of26 HFNA-000001925 EPA Inspection Report - Page 1264 of 1969 ALS Group USA, Corp Date: 13-Dec-17 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 06-Dec-2017 09:50 Work Order: HS17120451 Received by: JRM Checklist completed by: Raegen Giga Reviewed by: 8-Dec-2017 Date eSignature Nicole Edwards eSignature Carrier name: Matrices: ~ ~ Shipping container/cooler in good condition? Yes Custody seals intact on shipping container/cooler? Yes Custody seals intact on sample bottles? Yes Chain of custody present? Yes Chain of custody signed when relinquished and received? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes TX1005 solids received in hermetically sealed vials? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Container/Temp Blank temperature in compliance? Yes Temperature(s)/Thermometer(s): .1 c/2.4c uc/c Cooler( s)/Kit( s): D ~ ~ ~ ~ ~ D ~ ~ ~ 8-Dec-2017 Date FedEx Priority Overnight No No No No No No No No No No No No D D D D D D D D D Not Present D D Not Present ~ Not Present N/A ~ D D D IR 11 tyrafoam Date/Time sample(s) sent to storage: 12/06/2017 18:00 Water - VOA vials have zero headspace? Yes ;# No Water - pH acceptable upon receipt? Yes D Yes D No pH adjusted? No No VOA vials submitted D D N/A ~ N/A ~ pH adjusted by: Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 23 of26 HFNA-000001926 EPA Inspection Report - Page 1265 of 1969 D Chain of Custody Form A Page _1_ of D __j__ D Cincinnati, OH +1 513 733 5336 [] Holland, Ml +16163996070 D Everett, WA +1 425 356 2600 D Houston, TX +1 2815305656 D Fort Collins, CO +19704901511 D Middletown, PA +1717944 5541 D Salt Lake City, UT +1 801 266 7700 Spring City, PA + I 610 948 4903 York, PA +I 717 505 5280 Enuiranme ntal Wotk Order#: ALS Project Mamager: Erica Padilla .. ........ ······ · .. · << •> i:,roiectl nfottriatfon < · . Pibjectriiaiti~ BWON Monthly Sampling (EOL} :•: ••••. •: P.~rchase Order ~ompa~y ·· ~ania Navajo Refining Company LLC Tyler Turner }Bili Tei Corripany < •: ..... · A; VOLATILES (8260) Benzene Holly Frontier Navajo Refining LLC HS17120451 Gabi Combs Navajo Refining Company P.O. Box 159 501 East Main i ~ityl~tatelllp Artesia, NM 88211-0159 ....... >:: ..• ..... << < > Phone (575J 748-3311 > < QityJStat~l?IP Artesia, New Mexico 88210 •••••• ....... / ·.·.·.·. Fait (575J 746-5451 <<•: fax f S-1 (API HC) i S-3 (AP! Water) 12/05/17 ) S-5 (T-40) 12/05/17 12/05/17 <·~ • • 9:48AM Liquid 8 9:36AM Liquid 8,1 1 X 9:00AM Liquid 8 1 X 8 1 X 12/05/17 9:05AM Liquid 9:31 AM Liquid 8,1 1 X Liquid 8,1 1 X Field Blank if EQ Blank Port 1 :7:< 12/05/17 9:55AM EQ Blank Port 2 12/05/17 9:55AM Liquid 8,1 1 X >>a Duplicate 12/05/17 Liquid 8,1 1 X •: :9••:• Trip Blank 12/05/17 XXX XXX Liquid 8,1 2 X Temperature Blank 12/05/17 Liquid Relinquished H1.16bcircf "JliuA...JJ '-1/J 11- fj bl'.;.-.HrGI. ~ Relinquished by: ' Date: • . Time: Received by: Time: Received by (Laboratory): Time: .· 0 5 Wk Days 2~HN03 Oother _ _ __ D 2 Wk Days D 24Hour •••• Notes: CQOlerTemp. • Cllooked by (Laboratory): .· .•. 1-HCL D STD 10 Wk Days l~•S-•('7 - Loggea•by:(l:.aboratoryJ: Preservative Key: Date: - 1 Required Turnaround Time: ( - X 1 12/05/17 1(C mr11rirnnn1111 J ec~alLAd~#s Suzanne.Aguilar@hollyfrontier.com 4:: S-6 (T-41) 11, , >H: ;''::::'"' (575) 748-3311 (575) 746-5451 3-H2S04 4-NaOH .. 5-Na2S203 6-NaHS04 7-0ther • 8,4 degrees C • 9-5035 .· Note: Any changes must be made in writing once samples and COC Form have been submitted to ALS Laboratory Group. 9~ ~ackagiH~heck !3ox Bel6iNF Level II: Standard QC Level Ill: Std QC+ Raw Data Level !V: SW846 CLP-Like · ITRRP-Checklist ITRRP Level IV Other: Copyright 2009 by ALS Laboratory Group Page 24 of26 HFNA-000001927 EPA Inspection Report - Page 1266 of 1969 Use of this system constitutes your agreement to the serulce conditions in the current FedEx Service GlJ!de, avail.able on fedex.com. FedEx will not be responsible for any daim in excess of $10D per package, whether the result of loss, damage, delay, non--delivery, misdellvery, or misinformation, unless you declare a higher value, pay an additional charge, document your actual los.s and file a timely claim. limitations found in the current FedEx Service Guide apply. Your right to recover from FedEx for any loss, including intrinsic value of the package, loss of sales, income interest, profit, attorney's fees, costs, and C?ther forms of damage whether direct, incidental, consequentlal 1 ars.peclai is limited to the greater of $100 or the aJ.Jthorized declared value. Recovery cannot exceed actual documented less. Maximum for items of elctraordinary value ls $1,000, e.g. jewelry, precious metals, negotiable instruments and other items listed in our Service Gulde. Written claims must be flied wlthin strict time limits, see current Fed Ex Service GtJide. _i After printing this f::1be1· CONSIGN5e COPY· Pl.5AS5 Pl.ACE IN FRONT OF POUCH 1. Fold the printed page along the Mnzontal ill'!& 2. Plac& iab'=i in shipping pouch a!'ld affix it to y"our shipment )> [~Ji CD 0 -.i en G) ~ ~ w 0 CIO U1 ~ Q ..... N U1 ... 0 )>Z r-CI) 8 r- m m ~ ;:o Cl (/) Page 25 of26 HFNA-000001928 EPA Inspection Report - Page 1267 of 1969 SHIPPER'S DECLARATION FOR DANGEROUS GOODS (Provide at least three copies to airline.) Shipper Air Waybill No. Brady Hubbard AQUA MICRQBICS 501 E MAIN C/0 AQUA MICROBICS ARTESIA NM86210 US 709308590512 Page 1 of 1 Page(s) Shipper's Reference Number (optional) Consignee Nicole Edwards ALS 10450 Stancliff Suite 210 HOUSTON ~ :x 18 Compliant Express CAFE3108 TX77099 US Two completed and signed copies of this Declaration must be handed to the operator WARNING TRANSPORT DETAILS Failure to comply with all respects with the applicable Dangerous Goods Regulations may be in breach of the applicable law ,subject to legal penalties. This shipment is within the Airport of Departure limitations prescribed for: ARTESIA (delete non applicable) ~ T y Alrport of Destination: HOUSTON Shioment !voe: ABSGRA (delete non applicable) NATURE AND QUANTITY OF DANGEROUS GOODS UN Number or idetJtificatian Number, proper shipping name, Class or Division (subsidiary risk), packing group (if required), and all other required Information. UN 3266. Corrosive liquid, basic, inorganic, n.o.s.(Sodium Hydroxide),8,1/1 UN 1268, Petroleum distillates, n.o.s.,3,111// 0.08 Li/854 0.04 Li/366 All PacKed In One FIBREBOARD BOX Q=0.1 --------------------------------------------------------------------------------------------~------------------------------------Additional Handling Information 24-Hour Emergency Response- CHEMTREC i-800-424-9300, CCN 201319 I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged, marked and labelled/placarded, and are in all respects in proper condition tor transport according to applicable international and National Governmental Regulations. I declare that all of the applicable air transport requirements have been met Name/Title of Signatory Brady Hubbard/Environmental Coordinator Place and Date Artesia, NM 12/05/2017 Signature (see w:flrning above) 18004249300 Emergency Telephone Number Brady Hubbard JJr"-",~ FOR RAOlOACTIVE'. MATERIAL. SHIPMENT ACCEPTABLE FOR PASSENGER AIRCRAFT, THE SHIPMENT CONTAINS RADIOACTIVE MATERIAL INTENDED FOR use: IN OR INCIDENT TO RESEARCH, MEDICAL DIAGNOSIS OR TREATMENT. ADR EUROPEAN TRANSPORT STATEMENT: CARRIAGE IN ACCORDANCE WITH 1.1.4 2.1 t. 100 MM Btu/hr. H-103 initial testing done 03/04/04. Test report, including proposed parametric monitoring plan and permit limits, was submitted 05/14/04. The permit with new limits was approved on 02/21/2006. In 02/2009, Navajo installed eight additional NGULNBs in the Crude Oil Charge Heater (H-103) that replaced H-101. As-installed duty of NGULNBs was> 150 MM Btu/hr, so a NOx CEMS was installed. An initial performance test and the NOx CEMS RATA were conducted 05/21/2009. Pursuant to 40 CFR 60 App F, annual RATA performed 05/20/2010, 08/16/2011, 05/24/2012. RA TA was performed 05/14/2013. Certification report submitted to NMED on 06/10/2013. RATA was performed 05/13/2014. Certification report submitted to NMED on 06/12/2014. RA TA was performed 05/06/2015. Certification report submitted to NMED on 06/04/2015. RA TA was performed 05/04/2016. Certification report submitted to NMED on 06/03/2016. RATA was performed 04/25/2017. Certification report submitted to NMED on 05/16/2017. RA TA was performed 02/14/2018. Certification report submitted to NMED on 03/14/2018. RA TA was performed 03/05/2019. Certification report submitted to NMED on 04/08/2019. Based on a review, not all QC procedures for heaters and boilers with CEMS may be documented in accordance with 40 CFR 60 App. F. The 4th quarter 2017 Consent Decree progress report inadvertently cross-referenced the entry for Paragraph 11. F. (pertaining to the FCCU) and did not explain that QC procedures for heaters and boilers with CEMS may not have been fully documented. A review of documentation of QC procedures under 40 CFR 60 App F was undertaken. A draft QA/QC manual was prepared and was finalized in January 2019. 11 HFNA-000002832 EPA Inspection Report - Page 1283 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements Install next-generation ultralow NOx control on H-600 and 70-H1/H2/H3 at Artesia refinery. Performance test H600, and 70-H1/H2/H3. Establish compliance indicators by 12/31/09. Install next-generation ultralow NOx control on 8-SG1101A and B-SG-1101 Bat Lovington refinery by 12/31/09. Conduct performance test 8-SG1101A and B-SG-1101 Band establish compliance indicators. CD Paragraph 16.8.i., 16.C.iii., and Appendix C 16.8.i., 16.C.iii., and Appendix C Status/Comment H-600: Air permit 0195-M25-R3 authorizing the burner retrofit was issued by NMED on 05/14/08. The retrofit was completed in 02/2009. The performance test was conducted 03/04/09 and the test report submitted 03/30/09. Administrative permit revision 0195-M26-R1 effective 04/14/2009. 70-H1/H2/H3: NGULNBs were installed in CCR Heaters 70-H1/H2/H3 in May 2006 and heaters resumed operation on 6/2/06. Performance test conducted 7/11/06 and test report submitted 8/15/06. An application for a proposed permit limit was submitted to NMED 9/28/06. NMED issued permit PSD-NM-0195-M25 on 12/14/2007. An air permit application proposing the installation of NGULNBs in SG-1101A and SG-1101 B was submitted to NMED on 12/21/2007. Permit 0273M7 authorizing the retrofit with NGULNBs was issued by NMED on 05/06/2008. Navajo subsequently decided to replace the existing boilers with new boilers using NGULNBs. Permit 0273-M7-R 1 authorizing the replacement boilers was issued by NMED on 10/14/2009. Boiler SG11 OB was permanently shut down on 12/05/2009. Its replacement, 80-1104, began operation on 12/17/2009. Initial performance testing was conducted 01/28/2010 on 80-1104 and the report submitted to NMED on 02/24/2010. Because of initial operating problems with 80-1104, the second boiler, SG-1101A was not permanently shut down until 01/04/2010. Its replacement, BO1105, began operation on 01/15/2010. Initial performance testing was conducted 01/26/2010 on 80-1105 and the report submitted to NMED on 2/24/2010. The 80-1105 initial performance test was conducted on 1/26/2010, and the report submitted to the AQB on 02/24/2010. The BO1104 initial performance test was conducted on 01/28/2010, and the report submitted to the AQB on 02/24/2010. The burners installed with BO1105 and 80-1104, were subsequently found to not meet the NGULNB performance specification in the Consent Decree. The installation of NGULNB in 80-1105 was completed 06/20/2013. The installation of 80-1104 NGULNB was completed 07/29/2013. 80-1105 NOx Performance Test was completed 07/12/2013 and the results were submitted to NMED on 08/06/2013. 80-1104 NOx Performance Test was completed 09/04/2013 and the results were submitted to NMED on 12/05/2013. 12 HFNA-000002833 EPA Inspection Report - Page 1284 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements Submit proposed NOx permit limits within 120 days of NOx control technology installation. CD Paragraph 16.D Status/Comment Requirement completed. B-7: Proposed B-7 NOx limit submitted to NMED 01/31/03. B-8: Proposed B-8 NOx limit submitted to NMED 12/8/03. H-601: Proposed H-601 NOx limit submitted 5/14/04 in stack test report and permitted in 195M17 as issued 12/15/04. H-103 (Lovington Refinery): Proposed H-103 NOx limit submitted 5/14/04 in stack test report; on 2/21/06 NMED issued 0273-M4 to add the NOx limit. After installing additional NGULNBs in 02/2009, the limits were confirmed in the 05/21/2009 test and included in Permit 0273-M7R1 issued by NMED on 10/14/2009. H-20: Proposed H-20 NOx limit submitted to NMED in air permit application on 04/27/06; permit 0195-M24 issued 06/23/06. 70-H1/H2/H3: Proposed 70-H1/H2/H3 NOx limit submitted to NMED in air permit application on 09/28/06; permit PS0-NM-0195-M25 issued 12/14/2007. H-600: Proposed H-600 NOx limit authorized by NMED air permit administrative revision effective on 04/14/09. B0-1104 and B0-1105: (replacement boilers for B-SG-11 OA and B-SG-1101 B). Proposed B0-1104 and B0-1105 NOx limits submitted to NMED in air permit application on 04/13/2010; permit 0273-M8 issued 07/19/2010. 13 HFNA-000002834 EPA Inspection Report - Page 1285 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Submit annual progress report on NOx control technology 16.E First report was submitted 12/19/02. The report for 2003 was submitted 12/29/03 with supplemental information provided 1/8/04. 2004 report submitted 12/31/2004. 2005 report submitted 12/31/2005. 2006 report submitted 12/11/2006. 2007 report submitted 12/20/2007. 2008 report submitted 12/19/2008. 2009 report submitted 12/28/2009. 2010 report submitted 12/15/2010. 2011 report submitted 12/31/2011. 2012 report submitted 12/11/2012. 2013 report submitted 12/18/2013. 2014 report submitted 12/19/2014. 2015 report submitted 12/31/2015. 2016 report submitted 12/30/2016 2017 report submitted 12/28/2017. 2018 report submitted 12/27/2018. D. Section V, Paragraph 17: S0 2 Emissions Reductions from Heaters and Boilers and NSPS Applicability CD Requirements Status/Comment Paragraph NSPS Subparts A and J 17.B Commenced 12/20/01 become applicable to Heaters See entry for Paragraph 16.B.i., 16.C.ii., and Appendix C on p. 12 of this report regarding 40 and Boilers by Date of Lodging. CFR 60 App. F QC procedures. E. Section V, Paragraphs 18 and 19: NSPS Applicability for SRP and Flaring Devices CD Requirements Status/Comment Paragraph SRP shall comply with NSPS 18.C.i. and Commenced 12/20/01. J limit and monitor tail gas 18.C.ii. See entry for Paragraph 11. F. regarding 40 CFR 60 App. F QC procedures. emissions by Date of Lodging. 14 HFNA-000002835 EPA Inspection Report - Page 1286 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements NSPS Subparts A and J become applicable to Flares by Date of Lodging. Submit AMP plan for Flares FL-400, FL-401, FL-402 and FL-403 within 90 days of Lodging Date. CD Paragraph Appendix E Appendix E Status/Comment Commenced 12/20/01. The recent implementation of flare monitoring requirements under NSPS Ja resulted in the identification and repair of several relief valves that were leaking to the flare. In addition, three flare gas streams with higher sulfur levels were identified as routed to the Lovington flare. These three streams were rerouted to the fuel gas system. As of November 11, 2015, all gas streams currently routed to the flares are monitored for compliance with the NSPS Ja requirements. Excess emission information for the flares at Artesia and Lovington for the semiannual period: January-June 2016 was included in Attachment 4 to the 3rd quarter 2016 Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: July-December 2016 was included in the semiannual NSPS monitoring report submitted on January 30, 2017, and was attached to the 1st quarter 2017 Consent Decree Progress Report. Excess emission information for events occurring during the semiannual period: January-June 2017 was included in the semiannual NSPS Ja monitoring report submitted on July 28, 2017, and was attached to the 3rd quarter Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: July-December 2017 was included in the semiannual NSPS monitoring report submitted on January 30, 2018, and was attached to the 1st quarter 2018 Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: JanuaryJune 2018 was included in the semiannual NSPS monitoring report submitted on July 30, 2018, and was attached to the 3rd quarter 2018 Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: JulyDecember 2018 was included in the NSPS monitoring report submitted on January 30, 2019, and is attached to this 1st quarter Consent Decree Progress Report. Submitted 3/19/02. 15 HFNA-000002836 EPA Inspection Report - Page 1287 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements NSPS Subparts A and J become applicable to Flare FL-1001 at Lovington refinery on 12/31/06. CD Paragraph Appendix E Submit AMP plan for Flare FL-1001 at Lovington refinery by 7/30/07. Submit enhanced Maintenance and Operation plan for SRP (PMO plan) within 270 days of Date of Lodging. Begin optimization study on SRP by 1/1/04. Appendix E Status/Comment Off-Gas Scrubber system for sweetening sour LPG before combusting in flare completed by 12/31/06. An approvable AMP was submitted 02/14/07. AMP is pending EPA approval. 18.D Plan submitted on 9/16/02 and updated on 03/24/05. The last revision was completed on 09/2017 18.E Study commenced by 1/1/04 deadline. Complete optimization study on SRP and report results by 12/31/04. 18.E Navajo retained a third party to coordinate performance testing for the optimization study and prepare a report which was submitted to EPA on 12/31/04. 10-day prior notice required for scheduled Duke Energy shutdowns affecting Lovington refinery by Date of Lodging. 19.E Commenced 12/20/01. F. Section V, Paragraphs 20 and 21: Control of Acid Gas Flaring, Tail Gas Incidents and Hydrocarbon Flaring Requirements Perform root cause analyses for acid gas and tail gas incidents beginning on Lodging Date. Perform root cause analyses for hydrocarbon flaring incidents beginning on Lodging Date. CD Paragraph Status/Comment 20 Commenced 12/20/01. 21 Commenced 12/20/01. G. Section V, Paragraph 22: Benzene Waste NESHAP Requirements CD Paragraph Status/Comment 16 HFNA-000002837 EPA Inspection Report - Page 1288 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements Complete Phase One of the review and verification of the TAB by 9/16/02. Submit BWN Phase One Compliance Review and Verification report for EPA approval by 10/16/02. Submit amended TAB report if BWN Compliance Review shows reporting applied. Establish annual review program Train employees who conduct sampling. Submit schematics of Waste/Slop/Off-Spec Oil Management by 03/20/02. Conduct annual sampling of waste streams which the BWN Compliance Review and Verification Report showed to be 0.05 Mg/yr or greater. CD Paragraph 22.C.i. Status/Comment Completed 09/11/02. 22.C.i. Report of results submitted on 10/09/02. 22.D.i. Amended TAB report was included in the 10/09/02 submittal. 22.E 22.G and 22.M.ii.a(1) 22.H.i. 22.J.i. and 22.M.ii.a(2) Completed as part of Phase One review and is now ongoing. A training plan was developed on 12/06/02 for the Artesia Refinery (i.e., since its TAB is greater than 1.0 Mg/yr). The first training session was held 01/07/03 at both the Artesia and Lovington refineries. The second training session for the two refineries was held 1/27/04 and 01/28/04. Annual refresher training for the two refineries was performed the weeks of 02/08/05, 03/27/06, 03/05/07, 02/25/08 (Lov), 11/07/08 (Art), 12/18/09, 12/17/10 and 12/20/2011. BWON TAB training was conducted on at the Artesia and Lovington refineries on 11/08/2012 01/14/2013 and 04/18/2013, 11/12 to 11/14/2013, 05/24/2014, 06/22/2014, 12/12/2014, 3/16/2015, 4/1/2015, 5/15/2015, 2/29/2016, 3/8/2016, 3/17/2016, 09/25/2017, 11/08/2018, and 11/12/2018. Submitted on 03/19/02. Revised schematics reflecting NSPS QQQ were submitted 04/29/04. Schematics are awaiting approval by EPA. The annual sampling was performed in February 2005. The results were in Attachment 4 to the first quarter 2005 report. Annual sampling performed in February 2006. The results were in Attachment 4 of the first quarter 2006 report. Annual sampling was performed in September and December 2007. The results were submitted in attachment 4 of the first quarter 2008 report as required by ,T22.M.ii.a(2). Annual sampling was performed in December 2008. The results were in attachment 4 of the first quarter 2009 report as required by ,T22.M.ii.a(2). Annual sampling was performed in December 2009. The results were submitted in attachment 4 of the first quarter 2010 report as required by 17 HFNA-000002838 EPA Inspection Report - Page 1289 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements Meet with NMED and EPA at the refinery and submit an annual end of line (EOL) sampling plan - applicable to Artesia Refinery (i.e., TAB is equal to or greater than 1 Mg/yr but less than 10 Mg/yr). CD Paragraph 22.J.ii Status/Comment ,I22.M.ii.a(2). Annual sampling was performed in December 2010. The results were in attachment 4 of the first quarter 2011 report as required by ,I22.M.ii.a(2). Annual sampling was performed in December 2011. The results are in Attachment 4 of the first quarter 2012 report as required by ,I22.M.ii.a(2). Annual sampling was performed in December 2012. The results were submitted in Attachment 4 of the first quarter 2013 report as required by ,I22.M.ii.a(2). Annual sampling was performed in December 2013. The results were submitted in Attachment 4 of the first quarter 2014 report as required by ,I22.M.ii.a(2). Annual sampling was performed in December 2014. The results were submitted in Attachment 4 of the 1st quarter 2015 report as required by ,I22.M.ii.a(2). Annual sampling was performed in December 2015. The results were included in Attachment 4 of the 1st quarter 2016 report as required by ,I22.M.ii.a(2). Annual sampling was performed in October 2016. The results were included in Attachment 4 of the 1st quarter 2017 report as required by ,I22.M.ii.a(2). Annual sampling was performed in December 2017. The results were included in Attachment 4 and 7 of the 1st quarter 2018 report as required by ,I22.M.ii.a(2). Annual sampling was performed in December 2018. The results are included in this 1st quarter 2019 report as required by ,I22.M.ii.a(2). Navajo was notified by NMED and EPA via email dated 12/9/02 that the ,I22.J.ii visit by the agencies would not occur. Navajo met the deadline by submitting the EOL sampling plan on 2/6/03. Conditional approval of the plan was received from EPA by letter dated 1/23/04. Navajo responded by submitting a revised EOL sampling plan by letter dated 3/31/04. 18 HFNA-000002839 EPA Inspection Report - Page 1290 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements Conduct quarterly EOL sampling and submit the results to EPA in quarterly report. CD Paragraph 22.J.iii. and 22.M.ii.a(3) Status/Comment These requirements are not applicable until EPA approves the sampling plan. Although EPA has not approved or commented on the revised sampling plan submitted 03/31/2004, Navajo conducted its first EOL sampling during the week of 3/22/2004. The EOL benzene quantity (BQ) for the fourth quarter of 2004 was 0.8 Mg (projected annual< 10 Mg). The annual TAB, submitted 4/05 was 4.9 M~ for Artesia and 1.5 Mg for Lovington. The 1st, 2n , 3rd, and 4th quarter 2005 EOL BQs were each <2.5 Mg. The 1st, 2nd, 3rd, and 4th quarter 2006 EOL BQs were each <2.5 Mg. The 1st, 2nd, and 3rd quarter 2007 EOL BQs were each <2.5 Mg. The 4tn quarter 2007 EOL BQ result was greater than 2.5 Mg, but the projected 2007 TAB was< 10 Mg. The 1st quarter 2008 EOL BQ result was less than 2.5 Mg. The 2nd and 3rd quarter 2008 EOL BQ results were both greater than 2.5 Mg. The EOL BQ for the 4th quarter of 2008 was <2.5 Mg and the projected 2008 TAB was <10 Mg/yr. The EOL BQ for the 1s1, 2nd, 3rd and 4th quarters of 2009 was <2.5 Mg and the projected 2009 TAB was <10 Mg/yr. The EOL BQ for the 1s1, 2nd, 3rd, and 4th quarters of 2010 was <2.5 Mg and the projected 2010 TAB was <10 Mg/yr. The EOL BQ for the 1st, 2nd, 3rd and 4th quarters of 2011 was <2.5 Mg and the projected 2011 TAB was <10 Mg/yr. The EOL BQ for the 1st, 2nd, 3rd and 4th quarters of 2012 were each <2.5 Mg and the projected 2012 TAB was <10 Mg/yr. The EOL BQ for the 1st, 2nd, 3rd, and 4th quarters of 2013 were each <2.5 Mg and the projected 2013 TAB was <10 Mg/yr. The projected 2013 TAB was < 10 Mg/yr. The EOL BQ for the 1st, 2nd, 3rd, and 4th quarters of 2014 were each <2.5 Mg and the projected 2014 TAB was <10 Mg/yr. The EOL BQ for the 1st, 2nd, 3rd, and 4th quarters of 2015 were <2.5 Mg and the projected TAB for 2015 was <10 Mg/yr. The EOL BQ for the 1st quarter of 2016 was <2.5 Mg and the projected TAB for 2016 was <10 Mg/yr. The EOL BQ for the 2nd quarter of 2016 was <2.5 Mg and the projected TAB for 2016 was <10 Mg/yr. The EOL BQ for the 3rd quarter of 2016 exceeded 2.5 Mg. As required by paragraph 22.J.iv, Navajo submitted a plan with the fourth quarter Consent 19 HFNA-000002840 EPA Inspection Report - Page 1291 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements CD Paragraph Status/Comment Decree report that identified the specific actions to be taken and the schedule for such actions to ensure that the TAB does not exceed 10 Mg in the calendar year. The EOL BQ for the 4th quarter of 2016 was <2.5 Mg and the projected TAB for 2016 was <10 Mg/yr. The EOL BQ for the 1st quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. The EOL BQ for the 2nd quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. The EOL BQ for the 3rd quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. The EOL BQ for the 4th quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. The EOL BQ for the 1st quarter of 2018 was <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr. The EOL BQ for the 2nd quarter of 2018 was <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr. The EOL BQ for the 3rd quarter of 2018 was <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr. The EOL BQ for the 4th quarter of 2018 was <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr. The EOL BQ for the 1st quarter of 2019 was <2.5 Mg and the projected TAB for 2019 was <10 Mg/yr. H. Section V, Paragraph 23: LOAR Requirements CD Paragraph Develop and maintain written facility-wide LOAR compliance program by 04/19/02. LOAR Training within 1 year of Date of Lodging. Perform initial LOAR 3rd party/internal audits by 12/20/02 and correct deficiencies. Repeat audits every two years. Status/Comment 23.A Completed before 4/19/02. 23.B Newly assigned personnel (both 3ra party and Navajo) are receiving training. On going training programs have been implemented. 23.C and 23.D 3ra party audits for Artesia and Lovington were conducted on 10/2002 and deficiencies were corrected per Paragraph 23.D. 3rd party audits for Artesia and Lovington were performed during 12/2004, 01/2007, 01/2009, and 01/2011. The Artesia and Lovington refineries underwent maintenance turnaround from January to March, 2013. The 2013 LOAR 3rd party audit was conducted from 09/16 to 09/20/2013, after the refinery was back online and normal operation data 20 HFNA-000002841 EPA Inspection Report - Page 1292 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements Valves use 500 ppm leak definition by 2 years after Date of Lodging NSPS Subpart GGG becomes applicable to FCCU wet gas compressor on 12/31/03. Pump monitoring using internal leak definition of 2,000 ppm in accordance with phased-in schedule - i.e., 50% by 6/20/03, 85% by 12/20/03, and 100% by 4/20/05 NSPS Subpart GGG becomes applicable to Crude vent compressor at Lovington refinery as of Date of Lodging. First attempt at repairs on valves that have voe reading > 200 ppm within 90 days of Lodging Date. Quarterly monitoring of valves - no Skip Period by Date of Lodging. LOAR database to include date, time, operator, and instrument within 6 months of Date of Lodging. Submit operational specifications designed to minimize non-electronic data collection and transfer within CD Paragraph 23.E.i. 23.E.iii Status/Comment had been collected for 1 complete quarter for comparative monitoring. A copy of the 2013 LOAR 3rd party audit report and resolutions were submitted in Attachment 5 of the 1st Quarter 2014 report. 3rd party audits for Artesia and Lovington were performed during the week of October 5th to 9th, 2015. A copy of the 2015 LOAR 3rd party audit report and resolutions are included in Attachment 5 of the 1st Quarter 2016 report. The 2017 LOAR 3rd party audit was conducted from 05/17 to 05/18/2017. A copy of the audit report was attached to the 3rd Quarter 2017 Consent Decree Progress Report. The audit resolutions were included as Attachment 5 to the 151 Quarter 2018 report. Completed prior to 12/20/03. Compressor seal system was upgraded during 2003 FCCU turnaround. Operational beginning December 2003. 23.E.ii.a., b., and c. List of pumps comprising >85% was developed and these pumps are using the 2,000 ppm leak definition for all monitoring subsequent to 12/20/03. All pump monitoring using internal leak definition of 2,000 ppm after 4/20/05. 23.E.iii This was completed upon CD lodging. Crude Vent Compressor (C-150A/B) is now included in the LOAR monitoring program. 23.G 23.H.ii. 23.1.i. 23.1.ii., and 23.0.i.b. Commenced with January 2002 quarterly monitoring. Completed by 12/20/01. Commenced with May 2002 monitoring. Submitted 6/19/02. 21 HFNA-000002842 EPA Inspection Report - Page 1293 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements CD Paragraph Status/Comment 6 months of Date of Lodging Develop/ implement procedure for LOAR data QA/QC within 90 days of Lodging Date. Establish accountable LOAR personnel by Date of Lodging. Establish tracking program for adding new pumps and valves to LOAR program within 120 days of Date of Lodging Conduct calibration/drift assessments of monitoring instruments at the end of each shift by the Date of Lodging. More stringent delay of repair requirements including drill and tap for valves reading >10,000 ppm by Date of Lodging. Submit written facility-wide LOAR compliance program by 5/19/02. Submit LOAR report with MACT Periodic reports. 23.J Procedure developed on 3/19/02 and included as an appendix in the written LOAR program. 23.K Completed by 12/20/01. 23.L This program was established by 4/19/02 and is described in the written LOAR program. 23.M Commenced on 12/20/01. 23.N.ii. Commenced on 12/20/01. 23.0.i.a. Submitted 05/13/2002. 23. O.ii.c. The monitoring results were incorporated into the periodic reports submitted pursuant to 40 CFR 63.654 on: 3/15/02, 9/13/02, 3/15/03, 9/15/03, 3/15/04, 9/15/04, 3/14/05 (3/15/05 for Lovington), 9/13/05 (9/15/05 for Lovington), 3/17/06, 9/13/06 (9/06/06 for Lovington), 3/16/07, 09/14/07, 3/17/08, 9/12/08, 03/16/09, 08/27/09, 03/16/2010, 09/13/2010, 03/16/2011, 03/09/2012 and 09/06/2012 (09/06/2012 for Lovington), 03/15/2013, 09/16/2013, 02/25/2014 (Artesia), 08/26/2014 (Lovington), 02/26/2015 (Artesia and Lovington), 08/27/2015 (Artesia and Lovington), 02/18/2016 (Artesia and Lovington), 08/29/2016 (Artesia and Lovington), 02/28/2017 (Artesia and Lovington), 08/29/2017 (Artesia and Lovington), 08/30/2018 (Artesia and Lovington), and 02/28/2019 (Artesia and Lovington). 22 HFNA-000002843 EPA Inspection Report - Page 1294 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries I. Section V, Paragraph 24: Incorporate CD Requirements into Enforceable Permits Requirements CD Status/Comment Paragraph Within 180 days of Date of Lodging, submit an application for Federally enforceable NSR permit to incorporate of limits, standards, or schedules effective on the Date of Lodging. Submit applications within 30 days of the effective date or establishment of limits, standards, or schedules pursuant to the CD. Section V, Paragraph 25: Requirements Utilize best efforts to obtain construction permits to implement control projects required by the CD. 24.A Applications to revise the NSR permits for the Artesia and Lovington refineries were submitted 5/28/02. Permit revision issued for Lovington on 10/15/03. Permit revision for Artesia issued 12/15/04. 24.B Navajo's understanding is that ,T16 NOx limits for boilers and heaters, which require permit application filing within 120 days after start-up under ,T16.D, are not subject to ,T24.B. No other limits under Section V have occurred to date. Obtaining Construction Permits CD Paragraph 25 Status/Comment Requirement Completed. The 5/28/02 NSR permit revision application for the Artesia refinery represented the installation of the FCCU wet gas scrubber. Navajo submitted an application to NMED on 4/9/03 to install a new crude heater (H-103) at the Lovington refinery. The permit was issued 10/15/03. H-103 began operation in 12/03. Since heater H-103 replaced H-101 (i.e., the existing crude heater which requires burner retrofit by 12/05 under the CD) and uses NGULNBs, this effectively achieves early implementation of the NOx emission reductions sought by the CD. In order to retrofit heater H-20 with NGULNB by 12/31/05, Navajo submitted a significant revision air permit application to NMED on 04/12/05. Since NMED had not completed the application review, a waiver allowing limited construction activities to begin was granted on 10/11/05. Permit 0195-M21, authorizing NGULNB for H-20, was issued by NMED on 11/18/05. An air permit application proposing the installation of NGULNBs in B0-1105 (formerly SG-1101A) and B0-1104 (formerly SG-1101 B) was submitted to NMED on 12/21/2007. Permit 0273-M? authorizing 23 HFNA-000002844 EPA Inspection Report - Page 1295 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Requirements CD Paragraph Status/Comment the NGULNBs in SG-1101A and SG-1101Bwas issued by NMED on 05/06/2008. Navajo subsequently decided to replace the existing boilers with new boilers using NGULNBs. Permit 0273-M7-R 1 authorizing the replacement boilers was issued by NMED on 10/14/2009. The installation of NGULNB in B0-1105 was completed 06/20/2013. The installation of B0-1104 NGULNB was completed 07/29/2013. H-600: Air permit 0195-M25-R3 authorizing the burner retrofit was issued by NMED on 05/14/08. The retrofit was completed in 02/2009. 3.0 SUMMARY OF ANTICIPATED PROBLEMS IN IMPLEMENTING THE REQUIREMENTS OF SECTION V. None at this time. 4.0 SUMMARY OF EMISSIONS DATA • • • • • • • • • • • • The Boiler B-7 initial performance stack test and CEMS RAT A was conducted on 12/18/2002 and the results submitted to the NMED on 01/31/2003. The Boiler B-8 initial performance stack test and CEMS RAT A was conducted on 10/29/2003 and the results submitted to the NMED on 12/08/2003. The Heater H-601 initial performance stack test was conducted on 03/02/2004 and the results were submitted to the NMED on 05/14/2004. The Heater H-103 (replacement for H-101) initial performance stack test was conducted on 03/04/2004 and the results were submitted to the NMED on 05/14/2004. Data was collected for reporting pursuant to Paragraph 11 (e.g., FCCU NOx optimization and demonstration period data.) NOx Additive Demonstration Period report with proposed NOx concentration-based limits submitted 07/27/2006. The FCCU Regenerator Scrubber CEMS RATA was conducted on February 14 and 15, 2006 and the results were submitted to the NMED on 03/15/2006. The FCCU Regenerator Scrubber annual PM test was conducted on 02/15/2006 and the results were submitted to the NMED on 03/15/2006. Heater H-20 was retrofit with NGULNBs in December 2005. A performance stack test was conducted on 02/16/2006 and the results were submitted to the NMED on 03/23/2006. Heaters H-352, H-353, and H-354 (formerly identified as 70-H1/H2/H3) were retrofit with NGULNBs in June 2006. A performance stack test was conducted on 07/11/2006 and the results were submitted to the NMED on 08/15/2006. The Boiler B-7and Boiler B-8 annual CEMS RATAs were conducted on 09/26/2006 and the results submitted to the NMED on 10/17/2006. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/24/2007 and the results were submitted to the NMED on 02/22/2007. The FCCU Regenerator Scrubber annual PM test was conducted on 01/24/2007 and the results were submitted to the NMED on 02/22/2007. 24 HFNA-000002845 EPA Inspection Report - Page 1296 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries • • • • • • • • • • • • • • • • • • • • • • • The Heater H-20 annual performance stack test was conducted on 01/25/2007 and the results were submitted to the NMED on 02/22/2007. The Boiler B-7and Boiler B-8 annual CEMS RATAs were conducted on 09/13/2007 and 09/12/2007 respectively, and the results submitted to the NMED on 10/11/2007. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/22/2008 and the results were submitted to the NMED on 02/18/2008. The FCCU Regenerator Scrubber annual PM test was conducted on 01/22/2008 and the results were submitted to the NMED on 02/18/2008. The Heater H-20 annual performance stack test was conducted on 01/23/2008 and the results were submitted to the NMED on 02/18/2008. The Boiler B-7and Boiler B-8 annual CEMS RATAs were conducted on 09/09/2008 and the results submitted to the NMED on 10/09/2008. The FCCU Regenerator Scrubber CEMS RA TA was conducted on 03/03/2009 and the results were submitted to the NMED on 03/30/2009. The FCCU Regenerator Scrubber annual PM test was conducted on 03/03/2009 and the results were submitted to the NMED on 03/30/2009. Heater H-600 was retrofit with NGULNBs in 02/2009. The Heater H-600 initial performance stack test was conducted on 03/04/2009 and the results were submitted to the NMED on 03/30/2009. The Heater H-20 annual performance stack test was conducted on 03/05/2009 and the results were submitted to the NMED on 03/30/2009. After adding additional burners, the Heater H-103 (replacement for H-101) performance stack test and NOx CEMS RATA was conducted on 05/21/2009 and the results were submitted to the NMED on 06/22/2009. The Boiler B-7and Boiler B-8 annual CEMS RATAs were conducted on 09/17/2009 and the results submitted to the NMED on 10/14/2009. The B0-1105 (replacement boiler for Lovington boiler BSG-1101 A) initial performance testing was conducted 01/26/2010 and the report submitted to NMED on 02/24/2010. The B0-1104 (replacement boiler for Lovington boiler BSG-1101 B) initial performance testing was conducted 01/28/2010 and the report submitted to NMED on 02/24/2010. The FCCU Regenerator Scrubber CEMS RA TA was conducted on 03/02 and 03/2010 and the results were submitted to the NMED on 04/05/2010. The FCCU Regenerator Scrubber annual PM test was conducted on 03/02 and 03/2010 and the results were submitted to the NMED on 04/05/2010. The Heater H-20 annual performance stack test was conducted on 03/04/2010 and the results were submitted to the NMED on 04/05/2010. The Heater H-103 (replacement for H-101) NOx CEMS RATA was conducted on 05/19/2010 and 05/20/2010, and the results were submitted to the NMED on 06/16/2010. The Boiler B-7and Boiler B-8 annual CEMS RATAs were conducted on 08/24/2010 and the results submitted to the NMED on 09/14/2010. The FCCU Regenerator Scrubber CEMS RATA was conducted on 03/01/2011 and the results were submitted to the NMED on 03/28/2011. The FCCU Regenerator Scrubber annual PM test was conducted on 03/01/2011 and the results were submitted to the NMED on 03/28/2011. The Heater H-20 annual performance stack test was conducted on 03/02/2011 and the results were submitted to the NMED on 03/28/2011. The Boiler B-7and Boiler B-8 annual CEMS RATA's were conducted on 08/16/2011 and the results submitted to the NMED on 09/16/2011. 25 HFNA-000002846 EPA Inspection Report - Page 1297 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries • • • • • • • • • • • • • • • • • • • • • • • • The Heater H-103 (replacement for H-101) NOx CEMS RATA was conducted on 05/3/2011 and the results were submitted to the NMED on 05/31/2011. The Heater H-20 annual performance stack test was conducted on 01/19/2012 and the results were submitted to the NMED on 02/27/2012. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/17/2012. Report showing certification submitted to NMED on 02/17/2012. The FCCU Regenerator Scrubber annual PM test was conducted on 01/17/2012. Report showing certification submitted to NMED on 02/17/2012. The Heater H-103 (replacement for H-101) NOx CEMS RATA was conducted on 05/24/2012, and the results were submitted to the NMED on 06/20/2012. The Boiler B-7and Boiler B-8 annual CEMS RATA's were conducted on 08/15/2012 and the results submitted to the NMED on 09/13/2012. The Heater H-20 annual performance stack test was conducted on 01/09/2013 and the results were submitted to the NMED on 02/07/2013. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/08/2013. Report showing certification submitted to NMED on 02/07/2013. The FCCU Regenerator Scrubber annual PM test was conducted on 01/08/2013. Report showing certification submitted to NMED on 02/07/2013. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATA was conducted on 05/14/2013, and the results were submitted to the NMED on 06/10/2013. The FCCU Regenerator Scrubber annual PM was retested on 03/05/2013. Report showing certification submitted to NMED on 04/01/2013. The Boiler B-7annual CEMS RAT A's was conducted on 08/07/2013 and the results submitted to the NMED on 09/17/2013. The Boiler B-8 annual CEMS RA TA's was conducted on 08/06/2013 and the results submitted to the NMED on 09/17/2013. The Heater H-20 annual performance stack test was conducted on 01/09/2014 and the results were submitted to the NMED on 02/04/2014. The FCCU Regenerator Scrubber annual PM was tested on 01/08/2014. Report showing certification submitted to NMED on 02/04/2014. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/08/2014. Report showing certification submitted to NMED on 02/04/2014. After the installation of NGULNB was completed, the B0-1105 (replacement boiler for Lovington boiler BSG-1101A) initial performance testing was conducted 07/12/2013 and the report submitted to NMED on 08/06/2013. After the installation of NGULNB was completed, the B0-1104 (replacement boiler for Lovington boiler BSG-1101 B) initial performance testing was conducted 09/04/2013 and the report submitted to NMED on 12/05/2013. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATA was conducted on 05/13/2014, and the results were submitted to the NMED on 06/12/2014. The Boiler B-7annual CEMS RATA's was conducted on 07/30/2014 and the results submitted to the NMED on 09/11/2014. The Boiler B-8 annual CEMS RATA's was conducted on 07/29/2014 and the results submitted to the NMED on 09/11/2014. The Heater H-20 annual performance stack test was conducted on 02/17/2015 and the results were submitted to the NMED on 03/09/2015. The FCCU Regenerator Scrubber annual PM was tested on 01/06/2015. Report showing certification submitted to NMED on 02/05/2015. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/06/2015. Report showing certification submitted to NMED on 02/05/2015. 26 HFNA-00000284 7 EPA Inspection Report - Page 1298 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries • • • • • • • • • • • • • • • • • • • • • • • • • The Heater H-103 (replacement for H-101) NOx and CO CEMS RATA was conducted on 05/06/2015, and the results were submitted to the NMED on 06/04/2015. The Boiler B-7 annual CEMS RATA's was conducted on 07/23/2015 and the results submitted to the NMED on 08/20/2015. The Boiler B-8 annual CEMS RATA's was conducted on 07/22/2015 and the results submitted to the NMED on 08/20/2015. The Heater H-20 annual performance stack test was conducted on 01/07/2016 and the results were submitted to the NMED on 02/05/2016. The FCCU Regenerator Scrubber annual PM was tested on 01/05/2016. Report showing certification submitted to NMED on 02/04/2016. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/05/2016. Report showing certification submitted to NMED on 02/04/2016. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATA was conducted on 05/04/2016, and the results were submitted to the NMED on 06/03/2016. The Boiler B-7 annual CEMS RATA's was conducted on 07/13/2016 and the results submitted to the NMED on 08/05/2016. The Boiler B-8 annual CEMS RATA's was conducted on 07/13/2016 and the results submitted to the NMED on 08/05/2016. The Heater H-20 annual performance stack test was conducted on 01/05/2017 and the results were submitted to the NMED on 02/03/2017. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/03/2017. Report showing certification submitted to NMED on 02/03/2017. The FCCU Regenerator Scrubber annual PM was conducted on 01/03/2017. Report showing certification submitted to NMED on 02/04/2017. The Boiler B-7 annual CEMS RATA's was conducted on 06/21/2017 and the results submitted to the NMED on 06/20/2017. The Boiler B-8 annual CEMS RA TA's was conducted on 06/21/2017 and the results submitted to the NMED on 06/20/2017. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATA was conducted on 04/25/2017, and the results were submitted to the NMED on 05/16/2017. The Heater H-20 annual performance stack test was conducted on 01/11/2018 and the results were submitted to the NMED on 02/09/2018. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/09/2018. Report showing certification submitted to NMED on 02/09/2018. The FCCU Regenerator Scrubber annual PM stack test was conducted on 01/09/2018. Report showing certification submitted to NMED on 02/09/2018. The Boiler B-7 annual CEMS RATA's was conducted on 03/06/2018 and the results submitted to the NMED on 03/29/2018. The Boiler B-8 annual CEMS RATA's was conducted on 03/07/2018 and the results submitted to the NMED on 03/29/2018. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATA was conducted on 02/14/2018, and the results were submitted to the NMED on 03/14/2018.The Heater H-20 annual performance stack test was conducted on 02/20/2019 and the results were submitted to the NMED on 03/21/2019.• The FCCU Regenerator Scrubber CEMS RA TA was conducted on 02/13/2019. Report showing certification submitted to NMED on 03/23/2019. The FCCU Regenerator Scrubber annual PM stack test was conducted on 02/13/2019. Report showing certification submitted to NMED on 03/23/2019. The Boiler B-7 annual CEMS RATA's was conducted on 03/19/2019 and the results submitted to the NMED on 04/18/2019. 27 HFNA-000002848 EPA Inspection Report - Page 1299 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries • • The Boiler 8-8 annual CEMS RA TA's was conducted on 03/19/2019 and the results submitted to the NMED on 04/18/2019. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATA was conducted on 03/05/2019, and the results were submitted to the NMED on 04/08/2019. Consistent with past reports, any emissions excursions from Consent Decree limits have generally been reported to NMED pursuant to the NSPS, MACT and/or Title V programs semiannually (as well as pursuant to NMED's excess emissions reporting program). We are in this report identifying emissions excursions that occurred in the 4th quarter 2018 for the emission limits and units below. For the flares at Artesia and Lovington, excess emission information for events occurring during the semiannual period: July-December 2018 was included in the semiannual NSPS Ja monitoring report submitted on January 30, 2019, and is attached to this 1st quarter Consent Decree Progress Report. Consent Decree Condition V.18. B: SRU S0 2 Emission limits SRU-2 S02 250 ppm 12-hr average Start Time Excess Emissions per Event (lbs) End Time 2019-01-0510:00 2019-01-0512:00 0.47 2019-01-0513:00 2019-01-0514:00 0.16 2019-01-21 21 :00 2019-01-22 09:00 14.40 2019-01-26 15:00 2019-01-27 03:00 22.31 2019-01-28 17:00 2019-01-29 03:00 9.84 2019-03-12 20:00 2019-03-1315:00 76.60 5. Implementation of ENVIRONMENTALLY beneficial Projects [Changes from Prior Quarter Italicized] Paragraph 35 requires certain information to be submitted for each project which has been completed. The projects for Paragraphs 30 and 32 have been completed. The following summarizes the status of the completed and ongoing projects, and highlights actions taken thus far: A. Section V, Paragraph 29: Refinery-wide Compliance with NSPS Subpart QQQ Environmentally Beneficial CD Status/Comment Project Paragraph Submit Compliance Plan 29.A The plan was submitted on within 180 days of CD Date of May 29, 2002 Lodging. 28 HFNA-000002849 EPA Inspection Report - Page 1300 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Environmentally Beneficial Project NSPS QQQ becomes applicable to Artesia and Lovington individual drain systems, oil-water separators, and aggregate facilities by 12/31/03 CD Paragraph 29.B Status/Comment Prior to 12/31/03, Navajo began operation of the new covered wastewater separator, completed the bypass of the South Plant API, installed covers on junction boxes and initiated drain inspections for the Artesia refinery. Junction boxes at the Lovington refinery were also covered and the routine inspection of drains (to assure proper water seal) was begun. Navajo otherwise ceased the use of an open culvert for draining oily process wastewater into the sewer. In early September 2010, it was discovered that the storm water catch basin of the Alkylation Unit Tar Pit could still receive some oily-water and therefore could be considered as a junction box. A cover for the storm water basin was designed, constructed, and installed by 11/12/2010. In July 2014, it was discovered that visual inspections were not conducted initially and semiannually as required by 40CFR 60.692-2 (07/11/2014 self-disclosure letter to NMED. Certified Receipt Number: 70073020000030288246). Navajo Started semiannual inspections on 07/01/2015. A third party review of the QQQ program indicated that there may be a potential issue regarding certain aspects of the drain systems at the refinery, in particular, the status of catch basins in these drain systems. Subpart QQQ exempts drain systems that have catch basins in their existing configuration prior to the rule's applicability date. Navajo is nevertheless evaluating the proactive retrofit of these catch basins with covers (inserts), and has initiated a capital project to address this. Retrofit work is currently scheduled to begin shortly. 29 HFNA-000002850 EPA Inspection Report - Page 1301 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries B. Section V, Paragraph 30: Operation of the 40 LTPD SRU (SRU1) on Standby Artesia SRP (No SRU at Lovington): Environmentally Beneficial Project Complete installation of equipment on SRU1 to allow operation in standby service by 12/31/03 CD Paragraph 30 Complete study plan on how to limit excess TGU emissions and Acid Gas Flaring by 2/28/04 30 Status/Comment SRU1 was started up again on 5/10/03 operating at a reduced rate in backup service. A new 100 long ton per day sulfur recovery unit (SRU3) began operating 05/11/2009. The combined capacity of SRU2 and SRU3 provides excess sulfur recovery capacity. Therefore, as an energy and emissions conservation measure, SRU1 is no longer operated in standby service. Acid Gas Flaring and TGU Excess Emissions Study Plan submitted 2/27/04. Pursuant to the plan, Navajo completed the study and submitted a 3/24/05 summary of the study including actions taken and recommendations. The study results were used to update the PMO plan with the modified PMO plan included with the 3/24/05 submittal. C. Section V, Paragraph 31: Installation of Spare FCCU Wet Gas Compressor Artesia FCCU (No FCCU at Lovington): Environmentally Beneficial CD Status/Comment Project Paragraph Complete installation of spare wet gas compressor by 12/31/03. Operate so as to minimize the duration of AG or HC flaring incidents during outages of the original compressor. 31 A spare wet gas compressor was installed during the 4th Quarter of 2003 FCCU turnaround. On 01/07/2011, Navajo's outside legal counsel submitted a request to modify or remove this paragraph. Operating procedures to minimize the duration of AG flaring were updated 04/30/2015. A preventive maintenance plan for the spare compressor C-0950 was completed on 05/11/2015. 30 HFNA-000002851 EPA Inspection Report - Page 1302 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries D. Section V, Paragraph 32: Supplemental Environmental Project (SEP) Benefiting the Artesia Community Environmentally Beneficial CD Status/Comment Project Paragraph Complete implementation of SEP to benefit the Artesia community by June 30, 2003 32 Navajo completed the community SEP prior to the revised 9/29/03 deadline and submitted cost certification data on 9/23/03 pursuant to Paragraph 91. The SEP installed mechanical mixers to replace air mixers on nine asphalt storage tanks to reduce odors. The tanks were T-0110, T-0404, T-0405, T0406, T-0409, T-0410, T-0428, T-0431, and T0432. T-0404, T-0405, T-0406, and T-0409, and T-0428 have been permanently removed from service. E. Section V, Paragraph 33: EMS Baseline Assessment for Artesia Refinery Environmentally Beneficial CD Status/Comment Project Paragraph Obtain NMED approval for Independent Contractor to perform the baseline assessment Execute contract with Independent Contractor Baseline Assessment Report to be received by Navajo within 210 days of Date of Lodging Navajo to implement recommendations in accordance with the baseline report schedule 33.C Completed via letter from NMED dated 4/19/02. 33.D Completed as of 4/15/02 33.E Navajo received the baseline assessment report on 7/17/02. 33.F Navajo has accepted the recommendations and schedule deadlines provided in the baseline report (the 8 recommendations are numbered in parenthesis in the discussion below). For the two (i.e., 1A and 5) recommendations with 10/1/02 deadlines, Navajo implemented both on time (i.e., prior to the deadline). The report to file required by CD ,T33.F.ii was completed 12/27/02. Navajo to implement recommendations in accordance with the baseline report schedule -Cont'd 33.F Navajo did the roll-out of the refinery environmental policy (1 B) and put environmental responsibilities (3) into a new specifically developed operator's manual prior to the baseline report recommendation deadline (i.e., 2/1/03 and 3/1/03, respectively). 31 HFNA-000002852 EPA Inspection Report - Page 1303 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries Environmentally Beneficial Project CD Paragraph Status/Comment Navajo to implement recommendations in accordance with the baseline report schedule -Cont'd 33.F The position descriptions (6) which were recommended for Navajo's Environmental Affairs Department staff were prepared and distributed prior to the 7/1/03 deadline. An independent consultant performed an on-site evaluation of Navajo's implementation of the recommendations and prepared a 6/23/03 evaluation report prior to the 6/30/03 deadline. Navajo to implement recommendations in accordance with the baseline report schedule -Cont'd Navajo to implement recommendations in accordance with the baseline report schedule -Cont'd 33.F Per the independent consultant's June 2003 evaluation report, the 9/1/03 original deadline for the recommended CBT training module (2) was revised to 3/1/04. 33.F Work commenced in November 2003 on developing the CBT training module (2). The CBT module was completed and rolled out on 2/27/04, thus meeting the 3/1/04 deadline. The decision was made to implement (7) via the electronic option (6/1/04 deadline). Recommendation No. SA, "Develop Environmental Records Retention Policy and Document Control Procedures" was implemented prior to the 12/1/03 deadline. Navajo to implement recommendations in accordance with the baseline report schedule -Cont'd 33.F Completed the evaluation of the LOAR program, process and procedures (4) on 6/3/04 and determined that the program is working as intended. Integrated compliance requirements calendar (7) was implemented prior to the 6/1/04 deadline. Completed work to implement the environmental records management system (88) during May 2004 with the aid of an outside consultant. The records management system is in place and working. An independent consultant conducted the implementation evaluation presented in a June 30, 2004 report, thus meeting the deadline. A final closure letter on the EMS improvement recommendations was issued September 30, 2004 by the consultant concluding no remaining EMS improvement actions for Navajo. 32 HFNA-000002853 EPA Inspection Report - Page 1304 of 1969 Calendar Quarterly Report - 1st Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries 6.0 OTHER MATTERS The recent implementation of flare monitoring requirements under NSPS Ja resulted in the identification and repair of several relief valves that were leaking to the flare. In addition, three flare gas streams with higher sulfur levels were identified as routed to the Lovington flare. These three streams were rerouted to the fuel gas system. As of November 11, 2015, all gas streams currently routed to the flares are being monitored for compliance with the NSPS Ja requirements. Excess emission information for the flares at Artesia and Lovington for the semiannual period: January-June 2016 was included in Attachment 4 to the 3rd quarter 2016 Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: July-December 2016 was included in the semiannual NSPS monitoring report submitted on January 30, 2017, and was attached to the 1st quarter 2017 Consent Decree Progress Report. Excess emission information for events occurring during the semiannual period: January-June 2017 was included in the semiannual NSPS Ja monitoring report submitted on July 28, 2017, and was attached to the 3rd quarter Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: January-June 2018 was included in the semiannual NSPS Ja monitoring report submitted on July 30, 2018, and was attached to the 3rd quarter 2018 Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: July-December 2018 was included in the semiannual NSPS Ja monitoring report submitted on January 30, 2019, and is attached to this 1st quarter Consent Decree Progress Report. 33 HFNA-000002854 EPA Inspection Report - Page 1305 of 1969 ATTACHMENT 1 APPENDIX G SUMMARY REPORTS HFNA-000002855 EPA Inspection Report - Page 1306 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 1st QUARTER2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT REPORTS, PLANS AND CERTIFICATIONS UNDER THE BENZENE WASTE NESHAP ENHANCED PROGRAM PROVISIONS OF PARA GRAPH 22 OF THE CONSENT DECREE IN UNITED STATES ET AL. V. NAVAJO REFINING CO. ET AL. Name or Summary of the Re12ort, Plan, or Certification CD SubPara No. Rqd. ("R") v. Contingent ("C") One-Time ("l ") V. Quarterly orw/ §63.654 Reports ("> l ") BWN Compliance Review and Verification Report C.i. R ] 270 days after Lodging Review completed 09/11/2002. Report submitted l 0/09/2002 AmendedBWN Compliance Review and Verification Report C.ii. C l 90 days after completing additional sampling requested by EPA Not Yet Applicable. EPA has not requested additional sampling. Amended TAB Report D.i C 1 60 days after completing BWN Compliance Review and Verification Report An Amended Report for the Artesia Refinery(> 1 Mg, <10 Mg) was Submitted 10/09/2002 with the Verification Report Plan to comply w/ 6 BQ if TAB equals or is greater than ] 0 D.ii; J.vi. C 1 180 days after completing BWN Compliance Review and Verification Report Not Applicable unless the Artesia or Lovington Refinery exceeds 10 Mg/yr in the annual TAB report Due Date Status Page 1 of 12 HFNA-000002856 EPA Inspection Report - Page 1307 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 1st QUARTER2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT Name or Summary of the Re11ort, Plan, or Certification CD SubPara No. Rqd. ("R") v. Contingent ("C") Compliance Certification D.iv C Waste/Slop/Off-Spec Oil Schematics H.i. Submit revised Waste/Slop/Off-Spec Oil Schematics reflecting agreement with EPA on comments. One-Time ("l ") V. Quarterly orw/ §63.654 Reports ("> l ") Due Date Status l 30 days after completing all actions necessary to come into compliance Not Applicable unless the Artesia or Lovington Refinery exceeds 10 Mg/yr in the annual TAB report. R l 90 days after Lodging Submitted on 03/19/2002. Revised plan reflecting plant modifications submitted 04/29/2004. Schematics are awaiting written approval by EPA. H.i. C l Mutually-agreed upon time between Navajo and/or Montana Refining and EPA Not Applicable until EPA confers with Navajo on the Waste/Slop/Off-Spec Oil Schematics. Schedule to complete installation of controls on waste management units handling organic benzene waste H.ii. C l Mutually-agreed upon time between Navajo and/or Montana Refining and EPA, not to exceed 2 years Not Applicable unless the Artesia or Lovington Refinery exceeds 10 Mg/yr in the annual TAB report Plan to quantify uncontrolled waste/slop/off-spec oil movements H.iv. R l 90 days after EPA has approved schematics Not Applicable until EPA provides written approval of the Waste/Slop/OffSpec Oil Schematics. Although EPA has not commented on or approved the schematics submitted under paragraph 22.H.i, Navajo has quantified the uncontrolled waste/slop/off-spec oil movements in the annual NESHAP Subpart FF Total Annual Benzene (TAB) report. Page 2 of 12 HFNA-000002857 EPA Inspection Report - Page 1308 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 1st QUARTER2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT Name or Summary of the Re11ort, Plan, or Certification CD SubPara No. Rqd. ("R") v. Contingent ("C") One-Time ("l ") V. Quarterly orw/ §63.654 Reports ("> l ") EOL Sampling Plan I.i; C l 2 months after the 22.D.iii Certification (if TAB is 10 mg/yr or greater); 90 days after submitting final BWN Compliance Reviewand Verification Report (if TAB is l Mg/yr or more but less than 10) EOL Sampling Plan submitted on 02/06/2003. J .ii Due Date Status EOL Revised Sampling Plan I.ii; J.ii. C As needed If and when Navajo and/or Montana Refining become aware of factors indicating original plan no longer accurately reflects EOL benzene quantity Revised EOL Sampling Plan submitted 03/31/2004. Applicable after refinery TAB exceeds 10 Mg/yr Plan to ensure that uncontrolled benzene does not equal or exceed, 6 Mg/yr or that it is minimized I.vii; C As needed 30 days after the end of the quarter in which the projected calendar year benzene quantity is equal to or greater than 6 Mg. Not Applicable unless the Artesia or Lovington Refinery exceeds 10 Mg/yr in the annual TAB report. Page 3 of 12 HFNA-000002858 EPA Inspection Report - Page 1309 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 1st QUARTER2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT Name or Summary of the Report, Plan, or Certification CD SubPara No. Rqd. ("R") v. Contingent ("C") One-Time ("l ") V. Quarterly orw/ §63.654 Reports ("> l ") Applicable if refinery TAB is > 1 but < 10 Mg/yr - Plan to ensure that uncontrolled benzene does not equal or exceed, as applicable, 10 Mg/yr or that it is minimized J.ivJ.v C As needed Due Date Status 30 days after the end of the quarter in which the projected calendar year benzene quantity is equal to or greater than 10 Mg. The 2007 4th quarter EOL benzene quantity exceeded 2.5 Mg, but the calendar year 2007 TAB did NOT exceed 10 Mg. Because the calendar year is over, and the TAB did not exceed IO Mg in the calendar year, submittal of a plan to prevent the calendar year TAB from exceeding 10 Mg, as required under 122.J.iv, becomes moot. As required by 1 22.M.ii.a(3), Navajo specifically sought EPA's concurrence with this interpretation but no response has been received. The EOL BQ for the 1st quarter of 2008 was <2.5 Mg and the projected 2008 TAB was < 10 Mg/yr so no plan was required. The EOL BQ for the 2nd quarter of 2008 was> 2.5 Mg and the projected tab was > l O Mg/yr. The required plan \Vas included as a supplement to the 2nd quarter report. Navajo specifically sought EPA 's concurrence with this plan but no response has been received. The EOL BQ for the 3rd quarter of2008 was> 2.5 Mg and the projected tab was> 10 Mg/yr (see Attachment 3). The required plan was included as a supplement to the 3rd quarter report. As required by 122.M.ii.a(3), Navajo specifically sought EPA's concurrence with this plan but no response has been received. The EOL BQ for the 4th quarter of 2008 \Vas <2.5 Mg and the projected 2008 TAB was < 10 Mg/yr so no plan was required. The EOL BQs for the l si, 2 d, 3rd and 4th quarters of 2009 were <2.5 Mg and the projected 2009 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the 1si, 2 d, 3', and 4th quarters of 20 l Owas <2.5 Mg and the projected 2010 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the ls\ 2nd, 3rd and 4th quarters of20ll was <2.5 Mg and the projected 2010 TAB was< 10 Mg/yr so no plan is required. The EOL BQ for the ls\ 2nd, 3rd and 4th quarters of2012 was <2.5 Mg and the projected 2010 TAB was< 10 Mg/yr so no plan is required. The EOL BQ for the ls\ 2nd, 3rd and 4th quarters of2013 were each <2.5 Mg 11 11 Page 4 of 12 HFNA-000002859 EPA Inspection Report - Page 1310 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 1st QUARTER2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT Name or Summary of the Re11ort, Plan, or Certification CD SubPara No. Rqd. ("R") v. Contingent ("C") One-Time ("l ") V. Quarterly orw/ §63.654 Reports ("> l ") Due Date Status and the projected 2012 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the l st and 2 d quarters of 2014 was <2.5 Mg and the projected 2014 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the ls\ 2 d, 3rd' and 4th quarters of2014 were <2.5 Mg and the projected 2014 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the 1st quarter of2015 was <2.5 Mg and the projected 2015 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the 2 d quarter of 2015 was <2.5 Mg and the projected 2015 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the 2nd quarter of 2015 was <2.5 Mg and the projected 2015 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the 3rd quarter of 2015 was <2.5 Mg and the projected 2015 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the 4th quarter of 2015 was <2.5 Mg and the projected 2015 TAB was < l O Mg/yr so no plan was required. The EOL BQ for the 1st quarter of2016 was <2.5 Mg and the projected 2016 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the 2nd quarter of 2016 was <2.5 Mg and the projected 2016 TAB was < l O Mg/yr so no plan was required. The EOL BQ for the 3rd quarter of 2016 exceeded 2.5 Mg but the calendar year 2016 TAB did NOT exceed 10 Mg. As the firsttwo quarters of2016 indicated significantly lower concentrations of benzene in the wastewater, the projected TAB remained below 10 Mg for the calendar year, and as such no specific actions need to be taken to ensure the TAB does not exceed lOMg. Regardless of that, however, Navajo developed a plan of targeted monitoring to help identify and address the benzene contributions during the third quarter. The plan was implemented by November 4, 2016 (attachment 4). 11 11 11 Page 5 of 12 HFNA-000002860 EPA Inspection Report - Page 1311 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 1st QUARTER 2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT Name or Summary of the Regort. Plan, or Certification CD SubPara No. Rqd. ("R") v. Contingent ("C") One-Time ("l ") V. Quarterly orw/ §63.654 Reports ("> l ") Due Date Status The EOL BQ for the 4th quarter of 2016 was <2.5 Mg and the projected TAB for 2016 was <10 Mg/yr. The EOL BQ for the l st quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. The EOL BQ for the 2nd quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. The EOL BQ for the 3rd quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. The EOL BQ for the 4th quarter of2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. The EOL BQ for the 1st quarter of 2018 was <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr, so no plan was required. The EOL BQ for the 2nd quarter of 2018 \Vas <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr, so no plan was required. The EOL BQ for the 3rd quarter of 2018 was <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr, so no plan was required. The EOL BQ for the 4th quarter of 20 l 8 was <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr, so no plan was required. The EOL BQ for the 1st quarter of 2019 was <2.5 Mg and the projected TAB for 2019 was <10 Mg/yr, so no plan was required. Page 6 of 12 HFNA-000002861 EPA Inspection Report - Page 1312 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 1st QUARTER2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT Name or Summary of the Re11ort, Plan, or Certification CD SubPara No. Rqd. ("R") v. Contingent ("C") One-Time ("l ") V. Quarterly orw/ §63.654 Reports ("> l ") Proposal for Third-Party TAB Study and Compliance Review I-viii; J.vi C l Last day of 4th Quarter as set forth in il I.viii. (if TAB is 10 mg/yr or greater); As agreed by EPA and Navajo and/or Montana Refining (if TAB is l Mg/yr or more but less than 10) Third-Party TAB Study and Compliance Review I... vm; J.vi C l 30 days after receipt of Not Applicable unless refinery cannot take actions to keep TAB below 10 the Third-Party Study Mg/yr. and Compliance Review Plan to implement the results of the Third-Party TAB Study and Compliance Review J.vi; C l 120 days after receipt of the Third-Party TAB Study and Compliance Review Due Date Status Not Applicable unless refinery cannot take actions to keep TAB below 10 Mg/yr. Not Applicable unless refinery cannot take actions to keep TAB below 10 Mg/yr. Page 7 of 12 HFNA-000002862 EPA Inspection Report - Page 1313 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 1st QUARTER2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT Name or Summary of the Re11ort, Plan, or Certification CD SubPara No. Rqd. ("R") v. Contingent ("C") One-Time ("l ") V. Quarterly orw/ §63.654 Reports ("> l ") Report on training done in that Quarter G.i... m.; Miia(l) C Q Due Date Each Quarterly Report due under the Consent Decree Status A training plan was developed 12/6/02 for the Artesia Refinery (i.e., since its TAB is greater than 1.0 Mg/yr). The first training session was held 1/7/03 at both the Artesia and Lovington refineries. The second training session for the two refineries \Vas held 1/27/04 and 1/28/04. Annual refresher training performed the weeks of 2/8/05, 3/2 7/06, 3/5/07, 2/25/08 (Lov), 11/07/08 (Art), 12/18/09, 12/17/2010 and 12/20/2011, 11/08/2012, 01/14/2013, 04/18/2013 11/12 to 11/14/2013, 05/24/2014, 06/19/2014, 06/20/2014, 12/02/2014, 3/16/2015, 4/1/2015, 5/15/2015, 2/29/2016, 3/8/2016, 3/17/2016 (Art. and Lov), 02/28/2017 (Artesia and Lovington), 08/29/2017 (Artesia and Lovington), 09/30/2018 (Artesia and Lovington) and 02/28/2019 (Artesia and Lovington). Page 8 of 12 HFNA-000002863 EPA Inspection Report - Page 1314 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 1st QUARTER2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT Results of annual sampling of>0.05 Mg/yr benzene streams J.i; Miia(2) C Q In the first Quarterly Report for the first calendar quarter of each year TI1e annual sampling was performed in Febmary 2005. The results were presented with the first quarter 2005 report. Annual sampling was performed in Febmary 2006. The results were presented in Attachment 4 with the first quarter 2006 report. Annual sampling was performed in September and December 2007. The results were submitted in attachment 4 of the first quarter 2008 report as required by i122.M.ii.a(2). Annual sampling was performed in December 2008. The results \Vere submitted in attachment 4 of the first quarter 2009 report as required by iJ22.M.ii.a(2). Annual sampling was performed in December 2009. The results were submitted in Attachment 4 of the first quarter 2010 report as required by ,22.M.ii.a(2). Annual sampling was performed in December 2010. The results were submitted in Attachment 4 of the first quarter 2011 report as required by ,22.M.ii.a(2). Annual sampling was performed in December 2011. The results \Vere submitted in Attachment 4 of the first quarter 2012 report as required by iJ22.M.ii.a(2). Annual sampling was perfonned in December 2012. The results were submitted in Attachment 4 of the first quarter 2013 report as required by ,22.M.ii.a(2). Annual sampling was performed in December 2013. The results were submitted in Attachment 4 of the first quarter 2014 report as required by ,22.M.ii.a(2). Annual sampling was performed in December 2014. The results were submitted in Attachment 4 of the 1stquarter 2015 report as required by iJ22.M.ii.a(2). Page 9 of 12 HFNA-000002864 EPA Inspection Report - Page 1315 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 1st QUARTER2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT Results of annual sampling of>0.05 Mg/yr benzene streams Results of Quarterly EOL Sampling J.i; C Q In the first Quarterly Report for the first calendar quarter of each year Annual sampling was performed in December 2015. TI1e results were included in Attachment 4 of the l stquarter 2016 report as required by ,122.M.ii.a(2). Annual sampling was performed in October 2016. The results were included in Attachment 4 of the 1st quarter 2017 report as required by i122.M.ii.a(2). Annual sampling was perfonned in December 2017. The results were included in Attachment 4 of the 1st quarter 2018 report as required by ,22.M.ii.a(2). Annual sampling was performed in December 2018. The results are included in this l st quarter 2019 report as required by iJ22.M.ii.a(2). C Q Each Quarterly Report due under the Consent Decree (after written EPA a1212roval of EOL sampling plan) 2004: Under the assumption that the sampling plan was accepted by EPA upon the 03/31/2004 submittal of the revised EOL Sampling Plan, Navajo conducted its first EOL sampling during the week of 3/22/04. The annual TAB, submitted 4/05 \Vas 4.9 Mg for Artesia and 1.5 Mg for Lovington. 2005: TI1e EOL benzene quantity (BQ) for the ls\ 2nd, 3rd, and 4th quarter of 2005 were each <2.5 Mg. 2006: The EOL BQ for the l si, 2nd, 3rd, and 4th quarters of 2006 were each <2.5 Mg. 2007: The ls\ 2nd, and 3rd quarter 2007 EOL BQs were each< 2.5 Mg. The 2007 4th quarter EOL benzene quantity exceeded 2.5 Mg, but the calendar year 2007 TAB did NOT exceed 10 Mg. 2008: The EOL BQ for the l st quarter of 2008 was <2.5 Mg and the projected 2008 TAB was < l O Mg/yr. The EOL BQ for the 2nd quarter of 2008 was> 2.5 Mg and the projected tab was> 10 Mg/yr. The EOL BQ for the 3rd quarter of 2008 was > 2.5 Mg and the projected tab was > 10 Mg/yr. TI1e EOL BQ for the 4th quarter of 2008 was <2.5 Mg and the projected 2008 TAB was < l O Mg/yr. 2009: The EOL BQ for the l si, 2nd, 3rd and 4th quarters of 2009 \Vere <2.5 Mg and the projected 2009 TAB was< 10 Mg/yr so no plan was required. 2010: The EOL BQ for the l si, 2 d, 3', and 4th quarters of 2010 was <2.5 Mg and the projected 2010 TAB was< 10 Mg/yr so no plan was required. 2011: The EOL BQ for the ls\ 2 d, 3rd and 4th quarters of201 l was <2.5 Mg and the projected 2010 TAB was< 10 Mg/yr so no plan is required. Miia(2) J .iii; M.ii. a(3); M.iib(2) 11 11 Page 10 of 12 HFNA-000002865 EPA Inspection Report - Page 1316 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 1st QUARTER 2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT 11 2012: The EOL BQ for the ls1, 2 d, 3rd and 4th quarters of2012 was <2.5 Mg and the projected 2012 TAB was< 10 Mg/yr so no plan is required. 2013: The EOL BQ for the 1si, 2 d, 3rd and 4th quarters of 2013 \Vas <2.5 Mg and the projected 2012 TAB was< 10 Mg/yr so no plan is required. 2014: The EOL BQ for the ls\ 2nd, 3rd and 4th quarters of 2014 were <2.5 Mg and the projected 2014 TAB was< 10 Mg/yr so no plan was required. 2015: The EOL BQ for the 1st quarter of2015 was <2.5 Mg and the projected 2015 TAB \Vas< 10 Mg/yr so no plan \Vas required. The EOL BQ for the 2nd quarter of 2015 was <2.5 Mg and the projected 2015 TAB \Vas < 10 Mg/yr so no plan \Vas required. The EOL BQ for the 3rd quarter of 2015 was <2.5 Mg and the projected 2015 TAB was < l O Mg/yr so no plan was required. 11 The EOL BQ for the 4t quarter of 2015 was <2.5 Mg and the projected 2015 TAB was< 10 Mg/yr so no plan was required. 2016: The EOL BQ for the 1st quarter of 2016 \Vas <2.5 Mg and the projected 2016 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the 2nd quarter of 2016 was <2.5 Mg and the projected 2016 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the 3rd quarter of 2016 exceeded 2.5 Mg. As required by paragraph 22.J.iv, Navajo submits the following plan that identifies the specific actions that will be taken, and the schedule for such actions, to ensure the TAB does not exceed l OMg in the calendar year. As the first two quarters of 2016 indicated significantly lower concentrations of benzene in the wastewater, the projected TAB remained below 10 Mg for the calendar year, and as such no specific actions need to be taken to ensure the TAB does not exceed lOMg. Regardless of that, however, Navajo developed a plan of targeted monitoring to help identify and address the benzene contributions during the third quarter. The plan was implemented by November 4, 2016 (attachment 4). The EOL BQ for the 4th quarter of 2016 was <2.5 Mg and the projected TAB for 2016 was <10 Mg/yr. 2017: The EOL BQ for the 1st quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. The EOL BQ for the 2 d quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. 11 11 Page 11 of 12 HFNA-000002866 EPA Inspection Report - Page 1317 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 1st QUARTER2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT TI1e EOL BQ for the 3rct quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. The EOL BQ for the 4th quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. 2018: The EOL BQ for the 1st quarter of2018 was <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr. The EOL BQ for the 2nd quarter of 2018 was <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr. The EOL BQ for the 3rd quarter of 2018 was <2.5 Mg and the projected TAB for 20] 8 was <10 Mg/yr. The EOL BQ for the 4th quarter of 2018 was <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr. 2019: The EOL BQ for the l st quarter of 2019 was <2.5 Mg and the projected TAB for 2019 was <10 Mg/yr. Page 12 of 12 HFNA-000002867 EPA Inspection Report - Page 1318 of 1969 ATTACHMENT 2 APPENDIX H SUMMARY REPORTS HFNA-000002868 EPA Inspection Report - Page 1319 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO 1st QUARTER2019 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT REPORTS, PLANS AND CERTIFICATIONS UNDERTHELDARENHANCEDPROGRAM PROVISIONS OF PARA GRAPH 23 OF THE CONSENT DECREE IN UNITED STATES, ET AL. V. NAVAJO REFINING CO., ET AL. Name or Summary of the Report, Plan, or Certification CD Written RefineryWide LDAR Program A' Updated RefineryWide LDAR Program A Sub-,J Nos. Rqd. ("R") v. Contingent ("C") One-Time ("l ") V. Quarterly or w-/ §63.654 Reports ("> l ") R 1 150 D after Lodging Prepared by 4/19/02 and Submitted 5/13/02 C 1 As needed LDAR plan updated 11/19/2009, 01/05/2011, 04/28/2014 (approved 7/22/2014). O.i.a Due Date Status Page 1 of 9 HFNA-000002869 EPA Inspection Report - Page 1320 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO 1st QUARTER2019 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT Name or Summary CD of the Report, Sub-,I Plan, or Nos. Certification Rqd. ("R") v. Contingent ("C") One-Time ("1 ") V. Quarterly orw/ §63.654 Reports ("> l ") Report on training for new LDAR personnel R >l B.i; O.iic(l) Due Date In each Section 63.654 Report Status Training addressed in 63.654 Report submitted 9/ 13/02, 3/15/03, 9/15/03, 3/15/04, 9/15/04, 3/14/05 (3/15/05 for Lovington), 9/13/05 (9/15/05 for Lovington), 3/17/06, 9/13/06 (9/6/06 for Lovington), 3/16/07, 09/14/07, 03/17/08, 09/12/08, 03/16/09, 08/27/09, 03/16/2010, 09/13/2010, 03/16/2011 06/08/2011, 07/10/2012, 09/10/12, 11/06/2012, 12/11/2012, 01/13/2013, 05/02/2013, 05/08/2013, 05/15/2013, 02/08/2013 03/09/2013 and 09/16/2014 (for Artesia and Lovington). New hire training was conducted 06/08/2011, 07/10/2012, 09/10/12, 11/06/2012, 12/11/2012, 01/13/2013, 05/02/2013, 05/08/2013, 05/15/2013, 02/08/2013, 12/9/2013, 03/22/2014, 03/31/2014, 04/01/2014, 06/18/14, 06/19/14, and 06/20/2014. Annual LDAR Computer Based Training (CBT) implemented during the fourth quarter 2014. First training completed before 12/31/2014. Annual CBT for new personnel completed during 2015. Annual CBT completed in 2016; additional training on 4/28/2016, 05/11/2016. Annual CBT completed in 2017; additional training on 04/13/2017, 04/25/2017, 05/20/2017, 12/01/2017. Annual CBT completed during 2018, additional training on 01/2018, 02/2018, and 03/2018. 2019 training on 01/08/2019, 01/11/2019, 02/20/2019, 03/05/2019, and 03/22/2019. Page 2 of 9 HFNA-000002870 EPA Inspection Report - Page 1321 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO 1st QUARTER2019 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT Name or Summary CD of the Report, Sub-,I Plan, or Nos. Certification Report on annual training for LDAR personnel B.ii; O.iic(l) Rqd. ("R") v. Contingent ("C") R One-Time ("1 ") V. Quarterly orw/ §63.654 Reports ("> l ") >l Due Date In each Section 63.654 Report Status Training addressed in 63.654 Report submitted 9/13/02, 3/15/03, 9/15/03, 3/15/04, 9/15/04, 3/14/05 (3/15/05 for Lovington), 9/13/05 (9/15/05 for Lovington), 3/17/06, 9/13/06 (9/6/06 for Lovington), 3/16/07, 09/14/07, 03/17/08, 09/12/08, 03/16/09, 08/27/09, 03/16/2010, 09/13/2010, (for Artesia and Lovington).Annual training was conducted on the following dates by the on-site LDAR contractor: 06/29/2011, 06/14/2012, 06/24/2013, 06/26/2013, 11/12 tol l/14/20143, 01/12/2014, 01/16/2014, 01/20/2014, 01/21/2014, 02/08/2014, 02/10/2014, 6/18/2014, 6/19/2014, and 06/20/2014. Annual LDAR Computer Based Training (CBT) implemented during the fourth quarter 2014 for all refinery and contractor personnel. Annual CBT conducted during 2015. Annual CBT in 2016; additional 2016 training on l/3/2016, l/6/2016, 1/14/2016, and 1/19/2016, l/31/2016, 04/28/2016, 05/11/2016, 09/2016, 10/2016, 11/2016, and 12/2016. Annual CBT in 2017; additional training on 04/13/2017, 04/25/2017, 05/20/2017, 12/01/2017. Annual CBT in 2018; additional training on 01/2018, 02/2018, and 03/2018. Page 3 of 9 HFNA-000002871 EPA Inspection Report - Page 1322 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO 1st QUARTER2019 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT Name or Summary CD of the Report, Sub-,I Plan, or Nos. Certification Rqd. ("R") v. Contingent ("C") One-Time ("1 ") V. Quarterly orw/ §63.654 Reports ("> l ") Report on LDAR training for refinery and operations personnel who hold positions relevant to LDAR R >l B.iii; O.iic(l) Due Date In each Section 63.654 Report Status Initial training program implemented. Training addressed in 63.654 Report submitted 9/13/02, 3/15/03, 9/15/03, 3/15/04, 9/15/04, 3/14/05 (3/15/05 for Lovington), 9/13/05 (9/15/05 for Lovington), 3/17/06, 9/13/06 (9/6/06 for Lovington), 3/16/07, 09/14/07, 03/17/08, 09/12/08, 03/16/09, 08/27/09, 03/16/2010, 09/13/2010, 03/16/2011, 03/14/2012 and 09/16/2013. Training was conducted on the following dates for refinery environmental personnel: 11/06/2012, 08/13 - 08/15/2013, 05/19 - 5/21/2014, 8/21/2014, l 0/02/2014 . Annual LDAR Computer Based Training (CBT) implemented during the fourth quarter 2014 for all refinery and contractor personnel. Annual CBT in 2015. Annual CBT in 2016: additional training on 1/3/2016, 1/6/2016, 1/14/2016, and 1/19/2016, l/31/2016, 04/28/2016, and 05/11/2016. Annual CBT in 2017; additional training on 04/13/2017, 04/25/2017, 05/20/2017, 12/01/2017. Annual CBT in 2018; additional training on Ol/2018, 02/2018, and 03/2018. Page 4 of 9 HFNA-000002872 EPA Inspection Report - Page 1323 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO 1st QUARTER2019 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT Name or Summary CD of the Report, Sub-,I Plan, or Nos. Certification LDARaudit reports and records of corrective actions. Audits are required every two years. D·, O.ii-b. Rqd. ("R") v. Contingent ("C") One-Time ("1 ") V. Quarterly orw/ §63.654 Reports ("> l ") R >l Due Date Status In the Quarterly Report forthe 1st calendar Quarter of each year [ncluded in the 1st Qtr 2003 report (submitted 04/17/2003) as Attachment 3. 3rd party audits for Artesia and Lovington were perfonned during December 2004, January 2007, January 2009, and January 2011. Included in the l st Qtr 2012 report, a copy of the 01/2011 Audit Report and the corrective actions taken were included with the 1st Quarter 2012 report as Attachment 5. The 2013 3rd party audit was conducted from 09/16 to 09/20/2013, after major refinery turnaround, and a complete quarter \vorth of normal operation data has been collected for comparative monitoring. A copy of the audit report and resolutions were presented in the 1st Quarter 2014 report. 3rd party audits for Artesia and Lovington were performed during the week of October 5th to 9t\ 2015. A copy of the 2015 LDAR 3rd party audit report and resolutions are included in Attachment 5 of the 1st Quarter 2016 report. The 2017 LDAR 3rd party audit was conducted from 05/17 to 05/18/2017. A copy of the audit report was attached to the 3rd Quarter Consent Decree Progress Report. The audit resolutions were included as Attachment 5 to the 1st Quarter 2018 report. Page 5 of 9 HFNA-000002873 EPA Inspection Report - Page 1324 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO 1st QUARTER2019 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT Name or Summary CD of the Report, Sub-,I Plan, or Nos. Certification Certification of implementation of the first attempt at repa1r program G·, Operational specifications for electronic LDAR data collection and transfer I.ii.; Certification of implementation of QA/QC procedures for review of data generated by LDAR monitoring technicians r, Rqd. ("R") v. Contingent ("C") One-Time ("1 ") V. Quarterly orw/ §63.654 Reports ("> l ") R 1 In the Provided \vith Initial Quarterly first Qtrly Status Report submitted for 2nd report Quarter 2002 on July 30, 2002 due under the CD or the first Qtrly report in which the rqmt. becomes due R 1 6mos. after Lodging for Navajo; 1 yr. after Lodging for Montana Refining R 1 In the Provided with Initial Quarterly first Qtrly Status Report submitted for 2nd report Quarter 2002 on July 30, 2002. due under the CD or the first Qtrly report in which the rqmt. becomes due. O.iia(l) O.i-b O.iia(2) Due Date Status Submitted 06/19/2002 Page 6 of 9 HFNA-00000287 4 EPA Inspection Report - Page 1325 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO 1st QUARTER2019 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT Name or Summary CD of the Report, Sub-,I Plan, or Nos. Certification Rqd. ("R") v. Contingent ("C") One-Time ("1 ") V. Quarterly orw/ §63.654 Reports ("> l ") Identification of each Refinery's LDAR "point" person K; R 1 In the Provided \vith Initial Quarterly first Qtrly Status Report submitted for 2nd report Quarter 2002 on July 30, 2002 due under the CD or the first Qtrly report in which the rqmt. becomes due Certification of the development of a tracking program for new valves and pumps L; R 1 In the Provided \vith Initial Quarterly first Qtrly Status Report submitted for 2nd report Quarter 2002 on July 30, 2002 due under the CD or the first Qtrly report in which the rqmt. becomes due O.iia(3) O.iia(4) Due Date Status Page 7 of 9 HFNA-000002875 EPA Inspection Report - Page 1326 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO 1st QUARTER2019 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT Name or Summary CD of the Report, Sub-,I Plan, or Nos. Certification Certification of implementation of calibration drift assessment procedures Certification of implementation of the "delay of repair" procedures M· Rqd. ("R") v. Contingent ("C") One-Time ("1 ") V. Quarterly orw/ §63.654 Reports ("> l ") R 1 In the Provided \vith Initial Quarterly first Qtrly Status Report submitted for 2nd report Quarter 2002 on July 30, 2002 due under the CD or the first Qtrly report in which the reqmrem ent becomes due R l [n the Provided with Initial Quarterly first Qtrly Status Report submitted for 2nd report Quarter 2002 on July 30, 2002 due under the CD or the first Qtrly report in which the reqmrem ent becomes due O.iia(5) N·, O.iia(6) Due Date Status Page 8 of 9 HFNA-000002876 EPA Inspection Report - Page 1327 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO 1st QUARTER2019 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT Name or Summary CD of the Report, Sub-,I Plan, or Nos. Certification LDAR monitoring report submitted withMACT periodic reports O· ' O.iic(2) Rqd. ("R") v. Contingent ("C") One-Time ("1 ") V. Quarterly orw/ §63.654 Reports ("> l ") R >l Due Date In each Section 63.654 Report Status Provided in MACT 63.654 Reports submitted: 3/15/02, 9/13/02, 3/15/03, 9/15/03, 3/15/04, 9/15/04, 3/14/05 (3/ 15/05 for Lovington 9/13/05 (9/15/05 for Lovington), 3/17/06, 9/13/06 (9/6/06 for Lovington), 3/16/07, 09/14/07, 03/17 /08, 09/12/08, 03/16/09, 08/27/09, 03/16/2010, 09/13/2010, 03/16/2011, 09/15/2011, 03/09/2012, 0/06/2012 (09/06/2012 for Lovington), and 03/15/2013, 09/16/2013, (Lovington and Artesia) 02/25/2014 (Artesia), 08/26/2014 (Lovington), and 02/26/2015 (Artesia and Lovington), 08/27/2015, 2/18/2016 (Artesia and Lovington), 08/29/2016 (Artesia and Lovington), 02/28/2017 (Artesia and Lovington), 08/29/2017 (Artesia and Lovington) and 08/30/2018 (Artesia and Lovington). Page 9 of 9 HFNA-000002877 EPA Inspection Report - Page 1328 of 1969 ATTACHMENT 3 QUARTERLY EOL SUMMARY (Paragraph 22.M .ii.a(3)) HFNA-000002878 EPA Inspection Report - Page 1329 of 1969 End of Line Sampling Report ls1 Quarter 2019 HollyFrontier Navajo Refining LLC Artesia, NM Refinery ATTACHMENT 3 TO 1st QUARTER 2019 STATUS REPORT OUARTERL Y END OF LINE SAMPLING RESULTS On January 1011\ February ?11\ and March 3rd, 2019, Navajo Refining's Artesia facility performed the End of Line (EOL) sampling pursuant to the Consent Decree, following the protocol described in Navajo's EOL sampling plan that was revised by a letter dated March 31, 2004. Due to changes in our wastewater system, the slop oil from our Alky API is diverted through the new wastewater API. Therefore, that stream is now factored into the calculations for the Wastewater API. As a result, Navajo has identified six (6) sampling points that were monitored during the EOL sampling. This included three representative samples for each sampling site, volume measurements, and specific gravity values, collected once a month during the quarter where applicable. The following calculations estimate the quarterly EOL and calendar year benzene quantities: Oil from Wastewater API EOL (Mg/qtr) = weeks/quarter x Oil Volume (gal/wk) x lbs. water/gallon x Specific Gravity of oil (dimensionless) x average benzene concentration in oil (ppmw) x grams/lb -c- 10 6 g/Mg Oil from Wastewater API EOL (Mg/qtr) = l3 wks/qtr x 92,387 gals/wk x 8.34 lbs./gallon x 0.97 (dimensionless) x 14.5 lb/106 x 454 g/lb -c- 106 gft,;Ig Oil from Wastewater API EOL = 0.06 Mg/qtr Wastewater - EOL (Mg/qtr) = days/qtr x Average Flow (gal/day) x Water Density (lbs. water/gal) x Average Benzene Concentration in wastewater (ppmw) x grams/lb -c- 10 6 g/Mg Wastewater - EOL (Mg/qtr) = 92 days/qtr x 720,000 gal/day x 8.34 lbs/gal x 0.98 lb/10 6 lb X 454 g/lb 7 l 06 g/Mg Wastewater - EOL = 0.25 Mg/qtr Cement Kiln Fuel Product EOL (Mg/qtr) = Amount of cement kiln fuel shipped m quarter (lbs/qtr) x Average Benzene Concentration (ppmw) x g/lb -c- 10 6 gftvig Cement Kiln Fuel Product EOL (Mg/qtr) = 0 (lbs/qtr) x 5.0 lb/10 6 x 454 g/lb -c- 106 g/Mg There was no sludge generated during the l st quarter 2019. Cement Kiln Fuel Product EOL = 0.00 Mg/qtr Aqueous Waste Caustic EOL (Mg/qtr) = Amount of aqueous waste caustic shipped in the quarter (total of Tanks 40 and 41) (gal) x lbs/gal x Average Benzene Concentration (ppm w) x g/1 b -c- 106 gft,;Ig Page 1 of3 HFNA-000002879 EPA Inspection Report - Page 1330 of 1969 End of Line Sampling Report ls1 Quarter 2019 HollyFrontier Navajo Refining LLC Artesia, NM Refinery ATTACHMENT 3 TO 1st QUARTER 2019 STATUS REPORT OUARTERL Y END OF LINE SAMPLING RESULTS Aqueous Waste Caustic lb X 454 g/lb -:- 10 6 g/Mg EOL (Mg/qtr) = 18,603 gal/qtr x 9.69 lbs/gal x 0.327 lb/10 6 Aqueous Waste Caustic EOL = 2.7 E (-5) :Mg/qtr Waste Caustic Hydrocarbon EOL (Mg/qtr) = days/qtr x avg flow (gal/day) x water density (lbs/ gal) x Specific Gravity (dimensionless) x Average Benzene Concentration (ppmw) x g/lb-;- 106 g/Mg Waste Caustic Hydrocarbon EOL (Mg/qtr) = 92 days/qtr x 42 gal/day x 8.34 lbs/gal x 1.17 (dimensionless) x 0.23 lb/10 6 lb x 454 g/lb--:-10 6 g/Mg Waste Caustic Hydrocarbon EOL = 4.0 E(-6) Mg/qtr Therefore, estimated total quarterly benzene equals benzene in Oil from Wastewater API (Mg/qtr) + benzene in Wastewater (Mg/qtr) + benzene in Cement Kiln Fuel Product (Mg/qtr) + benzene in Aqueous Waste Caustic (Mg/qtr) + benzene in Waste Caustic Hydrocarbon (Mg/qtr). Estimated Total Quarterly Benzene= 0.06 l\fg/qtr + 0.25 l\fg/qtr + 0.0 Mg/qtr + 2.7 E (-5) Mg/qtr + 4.0 E(-6) Mg/qtr Estimated Quarterly EOL Benzene= 0.311\-fg/qtr Therefore, the Artesia Refinery's quarterly EOL benzene quantity did not exceed 2.5 Mg/qtr. Estimated Annual Benzene (AB) Quantity for calendar year 2018 Estimated 2019 TAB= 1stQ * 4=0.31 *4 Estimated 2019 TAB= 1.24 l\1Ig The Artesia Refinery's projected calendar year 2019 total annual benzene quantity does not exceed l O Mg/yr. The above calculations were determined using the values from the following table and the attached analyses. Page 2 of3 HFNA-000002880 EPA Inspection Report - Page 1331 of 1969 HollyFrontier Navajo Refining LLC Artesia, ~I Refinery End of Line Sampling Report 1st Quarter 2019 ATTACHMENT 3 TO lstQUARTER2019 STATUS REPORT QUARTERLY END OF LINE SAMPLING RESULTS TABLE 1 QUARTERLY EOL SAMPLING NAVAJO REFINING Sampling Point Volume Test results Sample Collected 01/10/2019 Test results Sample Collected 02/07/2019 Test results Sample Collected 05/03/2019 Average of Samples Specific Gravity or Density Oil from Wastewater API(S-1) 92,387 gal/wk 36ppm 5.50 ppm 1.9 ppm 14.47 ppm 0.97 Wastewater Tanks (S-3) 720,000 gal/day 1.70 ppm 0.46 ppm 0.78 ppm 0.98 ppm 1.01 Cement Kiln Fuel (S-4) *" 0 lbs NA NA NA NA NA Aqueous Waste Caustic Tank 40 (S-5) 18,603 gal/qtr 0.024 ppm+ 0.024ppm+ 0.024 ppm+ 0.024 ppm 1.15 Aqueous Waste Caustic Tank 41 (S-6) * 0.480 ppm 0.210 ppm 0.290ppm 0.327 ppm 1.14 * 0.252 ppm 0.117 ppm 0.157 ppm 0.175ppm 1.14 42 gal/day 0.23# 0.23# 0.23# 0.23# 1.17# Average of Aqueous Waste Caustic Tanks (S-5 and S-6) Waste Caustic Hydrocarbon (S-7) *The volume for Caustic Tank 41 is reflected in the value assigned to Tank 40. The quantity assigned to Tank 40 is the combined volume from BOTH tanks that was shipped out in the quarter. ** There was no sludge generated during the 1st quarter 2018. +The Benzene result was below the method detection limit (MDL) of0.024 ppm. The MDL was used as a conservative aproach. #No sample could be collected because the hydrocarbon layer was between the sample point draws on the tank. 4 QT 2017 average Benzene of0.23 ppm, specific gravity of 1.17 was used. Page 3 of3 HFNA-000002881 EPA Inspection Report - Page 1332 of 1969 ATTACHMENT 4- CD 2018 TAB SUMMARY (Paragraph 22.J) HFNA-000002882 EPA Inspection Report - Page 1333 of 1969 I st Quarter 2019 HollyFrontier Navajo Refining LLC Artesia, NM Refinery ATTACHMENT 4 TO l't QUARTER 2019 STATUS REPORT ANNUAL TAB RESULTS 2018 Annual Sampling Results for Streams Contributing~ 0.05 Mg/yr to the 2018 TAB As required by paragraph 22.J.i of the Consent Decree, Navajo identified the streams in the 2018 Total Annual Benzene (TAB) report for the Artesia Refinery that contributed 0.05 Mg/yr benzene or more. These streams were: Process Unit No. Unit Name Streams Identified. Number of TAB Streams 2018 TAB (Mg/yr) 02 CRUDE (ATMOSPHERIC) UNIT 52 16 0.91 08 TANKFARM 21 12 0.05 13 NAPHTHA HYDROTREATING UNIT 28 5 0.29 16 SKID TREATERS 31 16 0.18 29 BLENDING AREAS 7 4 0.25 34 HYDROCRACKING UNIT 45 21 0.11 LAB LAB SAJvIPLE WASTE 22 19 0.6 VACTRUCKS VACUUM TRUCKS 2 l 1.45 TANK WATER DRAW TANK WATER DRAW 2 1 2.27 wsos WASTE SHIPPED OFFSITE 2 1 0.25 PUMPS PUMP MAINTENANCE 2 l 0.43 EXCHANGERS EXCHANGER MAINTENANCE 3 2 0.23 Of these streams, "Lab " and "Vacuum Trucks" were not sampled because they are aggregate samples made up of many individual samples. For instance, the Lab Samples number is an aggregate of several thousand product samples, none of which individually would be greater than 0.05 Mg/yr. Similarly, the Vacuum Trucks Movements are an aggregate of all the gathering stations, none of which individually would be over the 0.05 Mg/yr limit. No additional samples were taken from tanks T-40 and T-41. The oil layer in these spent caustic tanks is sampled as part of the quarterly end-of-line sampling. Therefore, the HFNA-000002883 EPA Inspection Report - Page 1334 of 1969 HollyFrontier Navajo Refining LLC Artesia, NM Refinery I st Quarter 2019 ATTACHMENT 4 TO l't QUARTER 2019 STATUS REPORT ANNUAL TAB RESULTS results of sampling tanks T-40 and T-41 have been in included in the" Attachment 3" results in each quarterly report for the calendar year. Navajo sampled each of the remaining streams to get a representative average number for each stream's benzene concentration. Because the waste stream flows are not consistent, it is not always possible to obtain a sample. HFNA-000002884 EPA Inspection Report - Page 1335 of 1969 ATTACHMENT 5 - Provided in Enclosed CD 2019 1QT EOL ANALYTICAL REPORTS (Paragraph 22.M .ii.a(3)) HFNA-000002885 EPA Inspection Report - Page 1336 of 1969 10450 Stancliff Rd. Suite 210 Houston, TX 77099 T: +1 281 530 5656 F: +1 281 530 5887 January 17, 2019 Gabriela Combs Navajo Refining Company PO Box 1490 Artesia, NM 88211-1490 Work Order: HS19010541 Laboratory Results for: BWON Monthly Sampling (EOL) Dear Gabriela, ALS Environmental received 9 sample(s) on Jan 11, 2019 for the analysis presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Results are expressed as "as received" unless otherwise noted. QC sample results for this data met EPA or laboratory specifications except as noted in the Case Narrative or as noted with qualifiers in the QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained by ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. If you have any questions regarding this report, please feel free to call me. Sincerely, ~:::~:::::::~=·--z,. .· · · · t-{;-;...-,·· Generated By: JUMOKE.LAWAL Corey Grandits Project Manager Right Solutions · Right Partnu www.a!sg!obaLcom Pagel of28 HFNA-000002886 EPA Inspection Report - Page 1337 of 1969 ALS Houston, US Date: Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS19010541 17-Jan-19 SAMPLE SUMMARY lab Samp ID Client Sample ID Matrix HS19010541-01 S-1 (API HC) HS19010541-02 TagNo Collection Date Date Received Liquid 1O-Jan-2019 08:53 11-Jan-2019 09:00 S-3 (API Water) Liquid 10-Jan-2019 09:13 11-Jan-2019 09:00 HS19010541-03 S-5 (T-40) Liquid 1O-Jan-2019 08:32 11-Jan-2019 09:00 HS19010541-04 S-6 (T-41) Liquid 1O-Jan-2019 08:35 11-Jan-2019 09:00 HS19010541-05 Field Blank Water 1O-Jan-2019 09:04 11-Jan-2019 09:00 HS19010541-06 EQ Blank Port 1 Water 1O-Jan-2019 09:35 11-Jan-2019 09:00 HS19010541-07 EQ Blank Port 2 Water 1O-Jan-2019 09:35 11-Jan-2019 09:00 D HS19010541-08 Duplicate Liquid 1O-Jan-2019 00:00 11-Jan-2019 09:00 HS19010541-09 Trip Blank Water 1O-Jan-2019 00:00 11-Jan-2019 09:00 D D CG 101618 -95 Hold D D D D D D Page 2 of28 HFNA-000002887 EPA Inspection Report - Page 1338 of 1969 ALS Houston, US Client: Project: Work Order: Date: Navajo Refining Company 17-Jan-19 CASE NARRATIVE BWON Monthly Sampling (EOL) HS19010541 GCMS Volatiles by Method SW8260 Batch ID: R331086 Sample ID: S-5 (T-40) (HS19010541-03) • Surrogate failure for HS19010541-03 due to sample matrix. Sample ID: S-6 (T-41) (HS19010541-04) • Surrogate failure for HS19010541-04 due to sample matrix. Batch ID: R331013 Sample ID: HS19010527-01 MS • MSD is for an unrelated sample Batch ID: R331105 Sample ID: HS19010487-02MSD • MSD is for an unrelated sample Batch ID: R331187 • The test results meet requirements of the current NELAP standards, state requirements or programs where applicable. Page 3 of28 HFNA-000002888 EPA Inspection Report - Page 1339 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 17-Jan-19 ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-1 (API HC) 1O-Jan-2019 08:53 RESULT QUAL VOLATILES BY SW8260C MDL Work0rder:HS19010541 Lab ID:HS19010541-01 Matrix: Liquid 0.24 2.4 mg/Kg 500 15-Jan-2019 18:38 %REC %REC %REC %REC 500 15-Jan-2019 18:38 500 15-Jan-2019 18:38 500 15-Jan-2019 18:38 500 15-Jan-2019 18:38 Analyst: WLR Surr: 1, 2-0ichloroethane-d4 98.1 70-126 Surr: 4-Bromofluorobenzene 101 70-130 101 70-130 96.6 70-130 Surr: Toluene-dB DATE ANALYZED UNITS Method:SW8260 36 Benzene Surr: Dibromofluoromethane DILUTION FACTOR REPORT LIMIT Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 4 of28 HFNA-000002889 EPA Inspection Report - Page 1340 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 17-Jan-19 ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-3 (API Water) 10-Jan-2019 09:13 RESULT QUAL VOLATILES - SW8260C 1.7 Benzene MDL Method:SW8260 0.030 Work0rder:HS19010541 Lab ID:HS19010541-02 Matrix: Liquid REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED Analyst: PC 0.25 Surr: 1, 2-0ichloroethane-d4 98.8 70-126 Surr: 4-Bromofluorobenzene 99.9 82-124 Surr: Dibromofluoromethane 98.8 77-123 Surr: Toluene-dB 99.9 82-127 mg/L 50 17-Jan-2019 01:52 %REC %REC %REC %REC 50 17-Jan-2019 01:52 50 17-Jan-2019 01:52 50 17-Jan-2019 01:52 50 17-Jan-2019 01:52 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 5 of28 HFNA-000002890 EPA Inspection Report - Page 1341 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 17-Jan-19 ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-5 (T-40) 1O-Jan-2019 08:32 RESULT QUAL VOLATILES BY SW8260C MDL Work0rder:HS19010541 Lab ID:HS19010541-03 Matrix: Liquid DILUTION FACTOR UNITS 0.24 mg/Kg 50 16-Jan-2019 09:53 %REC %REC %REC %REC 50 16-Jan-2019 09:53 50 16-Jan-2019 09:53 50 16-Jan-2019 09:53 50 16-Jan-2019 09:53 Analyst: WLR Method:SW8260 Benzene < 0.024 Surr: 1, 2-0ichloroethane-d4 91.8 70-126 Surr: 4-Bromofluorobenzene 110 70-130 Surr: Dibromofluoromethane 68.2 Surr: Toluene-dB 91.5 0.024 s DATE ANALYZED REPORT LIMIT 70-130 70-130 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 6 of28 HFNA-000002891 EPA Inspection Report - Page 1342 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 17-Jan-19 RESULT QUAL VOLATILES BY SW8260C Benzene ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-6 (T-41) 1O-Jan-2019 08:35 MDL Work0rder:HS19010541 Lab ID:HS19010541-04 Matrix: Liquid DILUTION FACTOR UNITS 0.24 mg/Kg 50 16-Jan-2019 10:17 %REC %REC %REC %REC 50 16-Jan-2019 10:17 50 16-Jan-2019 10:17 50 16-Jan-2019 10:17 50 16-Jan-2019 10:17 Analyst: WLR Method:SW8260 0.48 0.024 Surr: 1, 2-0ichloroethane-d4 92.2 70-126 Surr: 4-Bromofluorobenzene 111 70-130 Surr: Dibromofluoromethane 66.2 Surr: Toluene-dB 91.8 s DATE ANALYZED REPORT LIMIT 70-130 70-130 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 7 of28 HFNA-000002892 EPA Inspection Report - Page 1343 of 1969 ALS Houston, US Date: 17-Jan-19 Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Sample ID: Collection Date: Field Blank 1O-Jan-2019 09:04 ANALYSES RESULT QUAL VOLATILES - SW8260C Benzene ANALYTICAL REPORT Work0rder:HS19010541 Lab ID:HS19010541-05 Matrix:Water MDL REPORT LIMIT UNITS DILUTION FACTOR Analyst: PC Method:SW8260 < 0.00060 0.00060 DATE ANALYZED 0.0050 mg/L %REC %REC %REC %REC Surr: 1, 2-0ichloroethane-d4 95.8 70-126 Surr: 4-Bromofluorobenzene 101 82-124 Surr: Dibromofluoromethane 98.3 77-123 Surr: Toluene-dB 98.0 82-127 15-Jan-2019 17:07 1 15-Jan-2019 17:07 1 15-Jan-2019 17:07 1 15-Jan-2019 17:07 1 15-Jan-2019 17:07 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 8 of28 HFNA-000002893 EPA Inspection Report - Page 1344 of 1969 ALS Houston, US Date: 17-Jan-19 Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Sample ID: Collection Date: EQ Blank Port 1 1O-Jan-2019 09:35 ANALYSES RESULT QUAL VOLATILES - SW8260C Benzene ANALYTICAL REPORT Work0rder:HS19010541 Lab ID:HS19010541-06 Matrix:Water MDL REPORT LIMIT DILUTION FACTOR 0.00060 DATE ANALYZED Analyst: PC Method:SW8260 < 0.00060 0.0050 mg/L %REC %REC %REC %REC Surr: 1, 2-0ichloroethane-d4 97.2 70-126 Surr: 4-Bromofluorobenzene 98.6 82-124 Surr: Dibromofluoromethane 98.0 77-123 105 82-127 Surr: Toluene-dB UNITS 15-Jan-2019 17:31 1 15-Jan-2019 17:31 1 15-Jan-2019 17:31 1 15-Jan-2019 17:31 1 15-Jan-2019 17:31 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 9 of28 HFNA-000002894 EPA Inspection Report - Page 1345 of 1969 ALS Houston, US Date: 17-Jan-19 Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Sample ID: Collection Date: EQ Blank Port 2 1O-Jan-2019 09:35 ANALYSES RESULT QUAL VOLATILES - SW8260C Benzene ANALYTICAL REPORT Work0rder:HS19010541 Lab ID:HS19010541-07 Matrix:Water MDL REPORT LIMIT UNITS DILUTION FACTOR Analyst: PC Method:SW8260 < 0.00060 0.00060 DATE ANALYZED 0.0050 mg/L %REC %REC %REC %REC Surr: 1, 2-0ichloroethane-d4 97.0 70-126 Surr: 4-Bromofluorobenzene 102 82-124 Surr: Dibromofluoromethane 99.5 77-123 Surr: Toluene-dB 98.8 82-127 15-Jan-2019 17:55 1 15-Jan-2019 17:55 1 15-Jan-2019 17:55 1 15-Jan-2019 17:55 1 15-Jan-2019 17:55 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 10 of28 HFNA-000002895 EPA Inspection Report - Page 1346 of 1969 ALS Houston, US Date: 17-Jan-19 Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Sample ID: Collection Date: Duplicate 1O-Jan-2019 00:00 ANALYSES RESULT QUAL VOLATILES BY SW8260C Benzene ANALYTICAL REPORT Work0rder:HS19010541 Lab ID:HS19010541-08 Matrix: Liquid MDL 0.24 mg/Kg 50 15-Jan-2019 19:00 %REC %REC %REC %REC 50 15-Jan-2019 19:00 50 15-Jan-2019 19:00 50 15-Jan-2019 19:00 50 15-Jan-2019 19:00 Analyst: WLR Method:SW8260 0.97 0.024 97.9 70-126 Surr: 4-Bromofluorobenzene 101 70-130 Surr: Toluene-dB DATE ANALYZED UNITS Surr: 1, 2-0ichloroethane-d4 Surr: Dibromofluoromethane DILUTION FACTOR REPORT LIMIT 103 70-130 96.1 70-130 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 11 of28 HFNA-000002896 EPA Inspection Report - Page 1347 of 1969 ALS Houston, US Date: 17-Jan-19 Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Sample ID: Collection Date: Trip Blank 1O-Jan-2019 00:00 ANALYSES RESULT QUAL VOLATILES - SW8260C Benzene ANALYTICAL REPORT Work0rder:HS19010541 Lab ID:HS19010541-09 Matrix:Water MDL REPORT LIMIT DILUTION FACTOR 0.00060 DATE ANALYZED Analyst: PC Method:SW8260 < 0.00060 0.0050 mg/L %REC %REC %REC %REC Surr: 1, 2-0ichloroethane-d4 98.4 70-126 Surr: 4-Bromofluorobenzene 99.0 82-124 Surr: Dibromofluoromethane 98.8 77-123 102 82-127 Surr: Toluene-dB UNITS 15-Jan-2019 16:43 1 15-Jan-2019 16:43 1 15-Jan-2019 16:43 1 15-Jan-2019 16:43 1 15-Jan-2019 16:43 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 12 of28 HFNA-000002897 EPA Inspection Report - Page 1348 of 1969 ALS Houston, US Date: 17-Jan-19 WEIGHT LOG Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) WorkOrder: HS19010541 Batch ID: 2867 SamplD HS19010541-01 HS19010541-03 HS19010541-04 HS19010541-08 Method: Container VOLA Tl LES BY SW8260C Sample Wt/Vol 5.222 5.104 5.12 5.296 (g) (g) (g) (g) Final Volume 5 5 5 5 (ml) (ml) (ml) (ml) Weight Factor 0.96 0.98 0.98 0.94 Container Type Bulk Bulk Bulk Bulk (5030B) (5030B) (5030B) (5030B) Page 13 of28 HFNA-000002898 EPA Inspection Report - Page 1349 of 1969 ALS Houston, US BWON Monthly Sampling (EOL) DA TES REPORT HS19010541 Client Samp ID Sample ID 17-Jan-19 Navajo Refining Company Client: Project: WorkOrder: Batch ID Date: R331013 Collection Date TCLP Date Test Name : VOLATILES BY SW8260C Analysis Date Prep Date DF Matrix: Liquid HS19010541-01 S-1 (API HC) 1O Jan 2019 08:53 15 Jan 201918:38 500 HS19010541-08 Duplicate 1O Jan 2019 00:00 15 Jan 201919:00 50 Batch ID R331086 Test Name: VOLATILES BY SW8260C Matrix: Liquid HS19010541-03 S-5 (T-40) 1O Jan 2019 08:32 16 Jan 2019 09:53 50 HS19010541-04 S-6 (T-41) 1O Jan 2019 08:35 16 Jan 201910:17 50 Batch ID R331105 Test Name : VOLATILES - SW8260C Matrix: water HS19010541-05 Field Blank 1O Jan 2019 09:04 15 Jan 201917:07 HS19010541-06 EQ Blank Port 1 1O Jan 2019 09:35 15 Jan 201917:31 HS19010541-07 EQ Blank Port 2 1O Jan 2019 09:35 15 Jan 201917:55 HS19010541-09 Trip Blank 1O Jan 2019 00:00 15 Jan 201916:43 Batch ID R331187 HS19010541-02 Test Name ; VOLATILES - SW8260C S-3 (API Water) 10 Jan 2019 09:13 Matrix; Liquid 17 Jan 2019 01 :52 50 Page 14 of28 HFNA-000002899 EPA Inspection Report - Page 1350 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 17-Jan-19 Navajo Refining Company HS19010541 R331013 MBLK QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: MBLKW1-011519 Client ID: Run ID: Analyte Result Method; VOA8 Units: ug/Kg VOA8_331013 PQL SW8260 Analysis Date: 15-Jan-2019 09:44 SeqNo: 4908042 SPKVal SPK Ref Value %REC PrepDate: Control Limit Benzene < 25 250 Surr: 1,2-0ichloroethane-d4 2381 0 2500 0 95.2 76 - 125 Surr: 4-Bromofluorobenzene 2473 0 2500 0 98.9 80 - 120 Surr: Dibromofluoromethane 2446 0 2500 0 97.8 80 - 119 Surr: Toluene-dB 2470 0 2500 0 98.8 81 - 118 LCS Sample ID: VLCSW1-011519 Client ID: Run ID: Units: ug/Kg VOA8_331013 PrepDate: SPKVal SPK Ref Value %REC Control Limit 49.08 5.0 50 0 98.2 75 - 124 Surr: 1,2-0ichloroethane-d4 46.54 0 50 0 93.1 76 - 125 Surr: 4-Bromofluorobenzene 51.67 0 50 0 103 80 - 120 Surr: Dibromofluoromethane 49.37 0 50 0 98.7 80 - 119 Surr: Toluene-dB 48.51 0 50 0 97.0 81 - 118 Result Benzene MS Sample ID: HS19010527-01 MS Client ID: Analyte Run ID: Result Units: ug/Kg VOA8_331013 RPO Ref RPO Value %RPO Limit Qual Analysis Date: 15-Jan-2019 08:58 SeqNo: 4908041 PQL Analyte OF: 50 OF: 1 RPO Ref RPO Value %RPO Limit Qual Analysis Date: 15-Jan-2019 11:14 SeqNo: 4908303 Prep Date: PQL SPKVal SPK Ref Value %REC Control Limit Benzene 3404 240 2450 638 113 70 - 130 Surr: 1,2-0ichloroethane-d4 2453 0 2450 0 100 70 - 126 Surr: 4-Bromofluorobenzene 2618 0 2450 0 107 70 - 130 Surr: Dibromofluoromethane 2478 0 2450 0 101 70 - 130 Surr: Toluene-dB 2336 0 2450 0 95.3 70 - 130 OF: 50 RPO Ref RPO Value %RPO Limit Qual Page 15 of28 HFNA-000002900 EPA Inspection Report - Page 1351 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 17-Jan-19 Navajo Refining Company HS19010541 R331013 MSD QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: Analyte Units: ug/Kg HS19010527-01 MSD Client ID: Run ID: Result Method; VOA8 VOA8_331013 SW8260 Analysis Date: 15-Jan-2019 11:35 SeqNo: 4908304 PrepDate: PQL SPKVal SPK Ref Value %REC Control Limit OF: 50 RPO Ref RPO Value %RPO Limit Qual Benzene 3986 240 2450 638 137 70 -130 Surr: 1,2-0ichloroethane-d4 2510 0 2450 0 102 70 - 126 2453 2.29 30 Surr: 4-Bromofluorobenzene 2627 0 2450 0 107 70 - 130 2618 0.317 30 Surr: Dibromofluoromethane 2399 0 2450 0 97.9 70 - 130 2478 3.24 30 Surr: Toluene-dB 2275 0 2450 0 92.8 70 - 130 2336 2.64 30 3404 15.8 30 s The following samples were analyzed in this batch: ~f_s_19_0_10_s_4_1-_0_1_ _ _ H_s_19_0_1o_s_4_1-_o_s- - - - - - - - - - - - - - - - - - - ~ Page 16 of28 HFNA-000002901 EPA Inspection Report - Page 1352 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 17-Jan-19 Navajo Refining Company HS19010541 R331086 MBLK QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: MBLKW1-011619 Client ID: Units: ug/Kg Run ID: Analyte Method; VOA8 Result VOA8_331086 PQL SW8260 Analysis Date: 16-Jan-2019 09:32 SeqNo: 4909866 SPKVal SPK Ref Value %REC PrepDate: Control Limit Benzene < 25 250 Surr: 1,2-0ichloroethane-d4 2366 0 2500 0 94.7 76- 125 Surr: 4-Bromofluorobenzene 2511 0 2500 0 100 80 - 120 Surr: Dibromofluoromethane 2310 0 2500 0 92.4 80 - 119 Surr: Toluene-dB 2383 0 2500 0 95.3 81 - 118 LCS Sample ID: VLCSW1-011619 Client ID: Units: ug/Kg Run ID: VOA8_331086 PrepDate: PQL SPKVal SPK Ref Value %REC Control Limit 57.91 5.0 50 0 116 75 - 124 Surr: 1,2-0ichloroethane-d4 49.23 0 50 0 98.5 76 - 125 Surr: 4-Bromofluorobenzene 50.12 0 50 0 100 80 - 120 Surr: Dibromofluoromethane 49.81 0 50 0 99.6 80 - 119 Surr: Toluene-dB 47.62 0 50 0 95.2 81 - 118 Benzene MS Sample ID: HS19010443-06MS Client ID: Analyte Units: ug/Kg Run ID: Result VOA8_331086 RPO Ref RPO Value %RPO Limit Qual Analysis Date: 16-Jan-2019 08:48 SeqNo: 4909865 Result Analyte OF: 50 OF: 1 RPO Ref RPO Value %RPO Limit Qual Analysis Date: 16-Jan-2019 11:23 SeqNo: 4910168 PrepDate: PQL SPKVal SPK Ref Value %REC Control Limit Benzene 50370000 2400000 2.45e+007 22950000 112 70 - 130 Surr: 1,2-0ichloroethane-d4 23160000 O 2.45e+007 0 94.5 70 - 126 Surr: 4-Bromofluorobenzene 25690000 O 2.45e+007 0 105 70 - 130 Surr: Dibromofluoromethane 24350000 O 2.45e+007 0 99.4 70 - 130 Surr: Toluene-dB 23320000 O 2.45e+007 0 95.2 70 - 130 OF: 500000 RPO Ref RPO Value %RPO Limit Qual Page 17 of28 HFNA-000002902 EPA Inspection Report - Page 1353 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 17-Jan-19 Navajo Refining Company HS19010541 R331086 MSD QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: HS19010443-06MSD Client ID: Analyte Units: ug/Kg Run ID: Result Method; VOAS VOA8_331086 SW8260 Analysis Date: 16-Jan-2019 11:45 SeqNo: 4910169 PrepDate: PQL SPKVal SPK Ref Value %REC Control Limit OF: 500000 RPO Ref RPO Value %RPO Limit Qual Benzene 49680000 2400000 2.45e+007 22950000 109 70 - 130 50370000 Surr: 1,2-0ichloroethane-d4 23450000 0 2.45e+007 0 95.7 70 - 126 23160000 1.26 30 Surr: 4-Bromofluorobenzene 25940000 0 2.45e+007 0 106 70 - 130 25690000 0.962 30 Surr: Dibromofluoromethane 24830000 0 2.45e+007 0 101 70 - 130 24350000 1.92 30 Surr: Toluene-dB 23320000 0 2.45e+007 0 95.2 70 - 130 23320000 0.00119 30 The following samples were analyzed in this batch: rs 19010541-03 1.37 30 HS19010541-04 Page 18 of28 HFNA-000002903 EPA Inspection Report - Page 1354 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 17-Jan-19 Navajo Refining Company HS19010541 R331105 MBLK QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: Units: ug/L VBLKW-190115 Client ID: Run ID: Analyte Result Benzene Method; VOA6 VOA6_331105 PQL SW8260 Analysis Date: SeqNo: 4909977 SPKVal SPK Ref Value %REC Prep Date: Control Limit < 0.60 5.0 Surr: 1,2-0ichloroethane-d4 48.23 0 50 0 96.5 70 - 130 Surr: 4-Bromofluorobenzene 50.01 0 50 0 100 82 - 115 Surr: Dibromofluoromethane 48.71 0 50 0 97.4 73 - 126 Surr: Toluene-dB 50.84 0 50 0 102 81 - 120 LCS Sample ID: Units: ug/L VLCSW-190115 Client ID: Run ID: VOA6_331105 Analysis Date: SeqNo: 4909976 Prep Date: PQL SPKVal SPK Ref Value %REC Control Limit 18.16 5.0 20 0 90.8 74 - 120 Surr: 1,2-0ichloroethane-d4 47.74 0 50 0 95.5 70 - 130 Surr: 4-Bromofluorobenzene 50.14 0 50 0 100 82 - 115 Surr: Dibromofluoromethane 49.46 0 50 0 98.9 73 - 126 Surr: Toluene-dB 49.83 0 50 0 99.7 81 - 120 Analyte Result Benzene MS Sample ID: HS19010487-02MS Client ID: Analyte Run ID: Result Units: ug/L VOA6_331105 Analysis Date: SeqNo: 4909980 Prep Date: PQL SPKVal SPK Ref Value %REC Control Limit 71.1 70 - 127 Benzene 14.23 5.0 20 0 Surr: 1,2-0ichloroethane-d4 48.93 0 50 0 97.9 70 - 126 Surr: 4-Bromofluorobenzene 49.94 0 50 0 99.9 82 - 124 Surr: Dibromofluoromethane 49.23 0 50 0 98.5 77 - 123 Surr: Toluene-dB 49.65 0 50 0 99.3 82 - 127 15-Jan-2019 12:19 OF: 1 RPO Ref RPO Value %RPO Limit Qual 15-Jan-2019 11:31 OF: 1 RPO Ref RPO Value %RPO Limit Qual 15-Jan-2019 15:07 OF: 1 RPO Ref RPO Value %RPO Limit Qual Page 19 of28 HFNA-000002904 EPA Inspection Report - Page 1355 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 17-Jan-19 Navajo Refining Company HS19010541 R331105 MSD QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: HS19010487-02MSD Client ID: Run ID: Method; VOA6 Units: ug/L VOA6_331105 SW8260 Analysis Date: 15-Jan-2019 15:31 SeqNo: 4909981 OF: 1 PrepDate: PQL SPK Val SPK Ref Value %REC Control Limit 13.92 5.0 20 0 69.6 70 -127 14.23 Surr: 1,2-0ichloroethane-d4 48. 19 0 50 0 96.4 70- 126 48.93 1.52 20 Surr: 4-Bromofluorobenzene 51. 18 0 50 0 102 82 - 124 49.94 2.46 20 Surr: Dibromofluoromethane 49.6 0 50 0 99.2 77 - 123 49.23 0.749 20 48.62 0 50 0 97.2 82 - 127 49.65 2. 1 20 Analyte Benzene Surr: Toluene-dB Result RPO Ref RPO Value %RPO Limit Qual 2.19 20 s The following samples were analyzed in this batch: ~F_s_19_0_10_s_4_1-_o_s_ _ _ H_s_19_0_1o_s_4_1-_06_ _ _ _ H_s_19_0_1o_s_4_1-_07 ____ H_s_19_0_10_s_4_1-_0_9- - - - ~ Page 20 of28 HFNA-000002905 EPA Inspection Report - Page 1356 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 17-Jan-19 Navajo Refining Company HS19010541 R331187 MBLK QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: Units: ug/L VBLKW-190116 Client ID: Run ID: Analyte Result Benzene Method; VOA6 VOA6_331187 PQL SW8260 Analysis Date: 16-Jan-2019 23:03 SeqNo: 4911965 SPKVal SPK Ref Value %REC Prep Date: Control Limit < 0.60 5.0 Surr: 1,2-0ichloroethane-d4 49.26 0 50 0 98.5 70 - 130 Surr: 4-Bromofluorobenzene 49.99 0 50 0 100.0 82 - 115 Surr: Dibromofluoromethane 49.65 0 50 0 99.3 73 - 126 Surr: Toluene-dB 49.21 0 50 0 98.4 81 - 120 LCS Sample ID: Units: ug/L VLCSW-190116 Client ID: Run ID: Analyte Result VOA6_331187 Prep Date: PQL SPKVal SPK Ref Value %REC Control Limit 88.9 74 - 120 17.79 5.0 20 0 Surr: 1,2-0ichloroethane-d4 50.45 0 50 0 101 70 - 130 Surr: 4-Bromofluorobenzene 49.57 0 50 0 99. 1 82 - 115 Surr: Dibromofluoromethane 50.02 0 50 0 100 73 - 126 Surr: Toluene-dB 49.62 0 50 0 99.2 81 - 120 MS Sample ID: HS19010524-22MS Run ID: SeqNo: 4911967 Prep Date: PQL SPKVal SPK Ref Value %REC Control Limit 20.03 5.0 20 0 100 70 - 127 Surr: 1,2-0ichloroethane-d4 49. 18 0 50 0 98.4 70 - 126 Surr: 4-Bromofluorobenzene 50.24 0 50 0 100 82 - 124 Surr: Dibromofluoromethane 49.79 0 50 0 99.6 77 - 123 Surr: Toluene-dB 49.76 0 50 0 99.5 82 - 127 Analyte Benzene Result OF: 1 RPO Ref RPO Value %RPO Limit Qual Analysis Date: 17-Jan-2019 00:16 Units: ug/L VOA6_331187 RPO Ref RPO Value %RPO Limit Qual Analysis Date: 16-Jan-2019 22:15 SeqNo: 4911964 Benzene Client ID: OF: 1 OF: 1 RPO Ref RPO Value %RPO Limit Qual Page 21 of28 HFNA-000002906 EPA Inspection Report - Page 1357 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 17-Jan-19 Navajo Refining Company HS19010541 R331187 MSD QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: Analyte Units: ug/L HS19010524-22MSD Client ID: Run ID: Result Method; VOA6 VOA6_331187 Analysis Date: 17-Jan-2019 00:40 SeqNo: 4911968 SPKVal SPK Ref Value %REC Control Limit 0 97.2 70 - 127 19.43 5.0 20 Surr: 1,2-0ichloroethane-d4 49.22 0 50 0 98.4 Surr: 4-Bromofluorobenzene 49.85 0 50 0 99.7 Surr: Dibromofluoromethane 49.87 0 50 0 99.7 49.6 0 50 0 99.2 OF: 1 Prep Date: PQL Benzene Surr: Toluene-dB SW8260 RPO Ref RPO Value %RPO Limit Qual 20.03 3.01 20 70 - 126 49.18 0.0921 20 82 - 124 50.24 0.79 20 77 - 123 49.79 0.162 20 82 - 127 49.76 0.32 20 The following samples were analyzed in this batch: ~f_s_19_0_10_s_4_1-_02_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _~ Page 22 of28 HFNA-000002907 EPA Inspection Report - Page 1358 of 1969 ALS Houston, US Client: Project: WorkOrder: Qualifier Date: Navajo Refining Company BWON Monthly Sampling (EOL) 17-Jan-19 QUALIFIERS, ACRONYMS, UNITS HS19010541 Description Value exceeds Regulatory Limit a Not accredited B Analyte detected in the associated Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time J Analyte detected below quantitation limit M Manually integrated, see raw data for justification n Not offered for accreditation ND Not Detected at the Reporting Limit O Sample amount is> 4 times amount spiked P Dual Column results percent difference > 40% R RPO above laboratory control limit S Spike Recovery outside laboratory control limits U Analyzed but not detected above the MDL/SOL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Unit Reported Description mg/Kg Milligrams per Kilogram mg/L Milligrams per Liter Page 23 of28 HFNA-000002908 EPA Inspection Report - Page 1359 of 1969 ALS Houston, US Date: 17-Jan-19 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date Arkansas 88-0356 27-Mar-2019 Texas T10470231-18-21 30-Apr-2019 North Dakota R193 2018-2019 30-Apr-2019 Illinois 004438 29-Jun-2019 Louisiana 03087 30-Jun-2019 Kentucky 123043 - 2018 30-Apr-2019 Kansas E-10352 2018-2019 31-Jul-2019 Oklahoma 2018-156 31-Aug-2019 Page 24 of28 HFNA-000002909 EPA Inspection Report - Page 1360 of 1969 ALS Houston, US Date: Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS19010541 17-Jan-19 SAMPLE TRACKING Lab Sarnp ID Client Sample ID Action Date Person New Location HS19010541-01 S-1 (API HG) Login 1/12/2019 2:25:39 PM JRM B070 HS19010541-02 S-3 (API Water) Login 1/12/2019 2:25:39 PM JRM B070 HS19010541-03 S-5 (T-40) Login 1/12/2019 2:25:39 PM JRM B070 HS19010541-04 S-6 (T-41) Login 1/12/2019 2:25:39 PM JRM B070 HS19010541-05 Field Blank Login 1/12/2019 2:25:39 PM JRM B070 HS19010541-06 EQ Blank Port 1 Login 1/12/2019 2:25:39 PM JRM B070 HS19010541-07 EQ Blank Port 2 Login 1/12/2019 2:25:39 PM JRM B070 HS19010541-08 Duplicate Login 1/12/2019 2:25:39 PM JRM B070 HS19010541-09 Trip Blank Login 1/12/2019 2:25:39 PM JRM B070 Page 25 of28 HFNA-000002910 EPA Inspection Report - Page 1361 of 1969 ALS Houston, US Date: 17-Jan-19 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 11-Jan-2019 09:00 Work Order: HS19010541 Received by: JRM Checklist completed by: Reviewed by: Jared R. Makan 12-Jan-2019 -e,:-S,-ig_n_a,-tu-re-------...---,D=-a..,.t_e_ _ Corey Grandits Matrices: Carrier name: Shipping container/cooler in good condition? Yes Custody seals intact on shipping container/cooler? Yes Custody seals intact on sample bottles? Yes Chain of custody present? Yes Chain of custody signed when relinquished and received? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes TX1005 solids received in hermetically sealed vials? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Container/Temp Blank temperature in compliance? Yes Temperature(s)/Thermometer(s): 14-Jan-2019 Date eSignature ~ ~ D ~ ~ ~ ~ ~ D ~ ~ ~ FedEx Priority Overnight No No No No No No No No No No No No D D D D D D D D D Not Present D D Not Present ~ Not Present N/A ~ D D D 1.0c/1.4c UC/C Cooler( s)/Kit( s): oam cooler Date/Time sample(s) sent to storage: 1/11/2019 20:40 Water - VOA vials have zero headspace? Yes ;# Water - pH acceptable upon receipt? Yes pH adjusted? Yes ~ D IR11 No No VOA vials submitted D N/A No~ N/A No D D pH adjusted by: Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 26 of28 HFNA-000002911 EPA Inspection Report - Page 1362 of 1969 Chain of Custod y Form A Page _1_ of __j__ D Cincinnati, OH +/ 513 733 5336 D Holland, Ml +1616399607 0 D Everett, WA +1425356 2600 D +I 287 530 5656 D Fort Collins, CO + I 970 490 757 7 D Enuir anme ntal ALS Project Manager: Erica Padilla : >Pi6ie~fNaifje BWON Monthly Sampling \< . .Goni p . . . .tilairie . . . .a11y . . . Navajo Refining Company lLC Tyler Turner ... ... ... - ::: .· ::: - Navajo Refining Company BWON Monthly Sampling (EOL) (575) 748-3311 _<< :<> ......... . fax (575) 746-5451 :F~~ (575) 146-5451 11111111111111111 : J_ ·.· S-1 (API HC) 01/10/19 8:53 AM Liquid 8 01/10/19 9:13 AM Liquid 8,1 1 X 01/10/19 8:32 AM Liquid 8 1 X 01/10/19 8:35AM Liquid 8 1 X 01/10/19 9:04AM Liquid 8,1 1 X 1 X 3 ::: S-5 (T-40) S-6 (T-41) .: ~ <· Field Blank ••~• EQ Blank Port 1 01/10/19 9:35AM Liquid 8,1 •7: EQB1ankPo rt2 01/10/19 9:35AM Liquid 8,1 Duplicate 01/10/19 XXX XXX Liquid 8,1 Liquid 8,1 · 9:: • Trip Blank 01/10/19 • 10 01/10/19 Temperature Blank 1 X liquid 1 X 2 X 1 Oother _ _ __ Relinquished by: Date: Logged by !Laboratory): Oaf&: 1-HCL . 2-HN03 Time: Received by (laboratory): Cool_erTemp 1 t.,;, I 3~H2S04; . Time: 4-NaOH Checked by (Laboratory): 5-Na2S203 6•NaHS04. 7-0ffier I Ill II - X D 2 Wk Days Preservative Key: York, PA +I 717 505 5280 HS19010541 501 East Main, :-: : <<. S-3 (API Water) ,. ?om.i:iany Holly Frontier Navajo Refining LLC P.O. Box 159 , :;-'~;;.;;; Middletown, PA +l 717944 5541 Salt Lake City, UT +7 801 266 7700 Work Order#: . .·. ·.··.······· ....... . >:: ·.··. >> Houston, TX D ... LO ~-4d>ees C .· Note: Any changes must be made in writing once samples and COC Form have been submitted to ALS laboratory Group. Page 27 of28 . 9.0035 1.::.1"0t,-i. /!,(' /; ::::- <.. ·.·.•}O.·...:>·. •:•: : .. . . .. •<:< Cl9 P:ackage:(CheC:k E3ox:BetoW,_::::::: Level II: Standard QC Level III: Std QC+ Raw Data Level IV: SW846 CLP-Like ITRRP-Checklist ITRRP Level IV Other: (;,,,c.~ /[::Cd' · D 24 Hour Copyright 2009 by ALS laboratory Group (l HFNA-000002912 EPA Inspection Report - Page 1363 of 1969 Use of this system constitutes your agreement to the service conditions in the current FedEx Service Guide, available on fedex.com. FedEx will not be responsible for any claim in excess of $100 per package, whether the result of loss, damage, de!av, non-dell very, misdelivery, or ~is1nformation, unless you declare a higherva!ue, pay an additional charge, document your actual loss and file a timely claim. Limitations found in the current FedEx Service Guide apply. Your right to recover from FedEx for any loss, induding intrinsic value of the package, loss of sales, income interest, profit, attorney's fees, costs, and other forms of damage whether direct, incidental, consequential, or sped al is limited to the greater of $100 or the authorized declared value, Recovery cannot exceed actual documented loss. Maximum for items of extraordinary value is $1,000, e.g. jewelry, precious metals, negotiable instruments and other items listed in our Service Guide. Written claims must be filed within strict time limits, see current Fed Ex Service Gulde. ;'"'\t.~-d 1'13S AOOl.SOO L889 oss ,81: (+ ···~ 9ggg 0£9 Ul1: \+ ·1a1. 660LL Sl?X0J. 'UO\SnoH V S, V 0 (i; a11ns ''Pl:l JJ!PU1'1S 091'0 I 1•-e::iuawuoJ1nu3 s,'1 CONSIGNEE COPY· PLEASE PLACE !N FRONT OF POUCH 1 Feld the printed page along th~ Moriwntel line. 2. Prace label in shipping pouch end affix i.t to your shipment = = - ~o )> CD --=.... CJ) ;;;;; G) == ;;;;;; ,,,,. ~ -I .... 0 :;; 0 :::::j CJ> z::o 6~~ ::,-1 -='::C en 0 )>(") mm ol< """ """ 0 ;;;;; "'"' z ~ (") z r "Tl tJ1"" en ~ ~ ~ 1i! = = ~~ ~ 55iC2JD74C/i04C Page 28 of28 HFNA-000002913 EPA Inspection Report - Page 1364 of 1969 10450 Stancliff Rd. Suite 210 Houston, TX 77099 T: +1 281 530 5656 F: +1 281 530 5887 January 18, 2019 Gabriela Combs Navajo Refining Company PO Box 1490 Artesia, NM 88211-1490 Work Order: HS19010542 Laboratory Results for: BWON Monthly Sampling (EOL) Dear Gabriela, ALS Environmental received 4 sample(s) on Jan 11, 2019 for the analysis presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Results are expressed as "as received" unless otherwise noted. QC sample results for this data met EPA or laboratory specifications except as noted in the Case Narrative or as noted with qualifiers in the QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained by ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. If you have any questions regarding this report, please feel free to call me. Sincerely, ~:::~:::::::~=·--z,. .· · · · t-{;-;...-,·· Generated By: JUMOKE.LAWAL Corey Grandits Project Manager Right Solutions · Right Partnu www.a!sg!obaLcom Pagel of25 HFNA-000002914 EPA Inspection Report - Page 1365 of 1969 ALS Houston, US Date: Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS19010542 18-Jan-19 SAMPLE SUMMARY lab Samp ID Client Sample ID Matrix HS19010542-01 S-1 (API HC) HS19010542-02 TagNo Collection Date Date Received Liquid 1O-Jan-2019 09:53 11-Jan-2019 09:00 S-3 (API Water) Liquid 10-Jan-2019 09:13 11-Jan-2019 09:00 HS19010542-03 S-5 (T-40) Liquid 1O-Jan-2019 08:32 11-Jan-2019 09:00 HS19010542-04 S-6 (T-41) Liquid 1O-Jan-2019 08:35 11-Jan-2019 09:00 Hold D D D D Page 2 of25 HFNA-000002915 EPA Inspection Report - Page 1366 of 1969 ALS Houston, US Client: Project: Work Order: Dale: Navajo Refining Company 18-Jan-19 CASE NARRATIVE BWON Monthly Sampling (EOL) HS19010542 Work Order Comments • The analysis for Specific Gravity was subcontracted lo ALS Environmental in Holland, Ml. Final report attached. Page 3 of25 HFNA-000002916 EPA Inspection Report - Page 1367 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 18-Jan-19 RESULT QUAL SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY Subcontract Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-1 (API HC) 1O-Jan-2019 09:53 MDL Work0rder:HS19010542 Lab ID:HS19010542-01 Matrix: Liquid REPORT LIMIT UNITS Method:NA See Attached 0 NA DILUTION FACTOR DATE ANALYZED Analyst: SUBHO 18-Jan-2019 09:41 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 4 of25 HFNA-000002917 EPA Inspection Report - Page 1368 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 18-Jan-19 RESULT QUAL SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY Subcontract Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-3 (API Water) 10-Jan-2019 09:13 MDL Work0rder:HS19010542 Lab ID:HS19010542-02 Matrix: Liquid REPORT LIMIT UNITS Method:NA See Attached 0 NA DILUTION FACTOR DATE ANALYZED Analyst: SUBHO 18-Jan-2019 09:41 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 5 of25 HFNA-000002918 EPA Inspection Report - Page 1369 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 18-Jan-19 RESULT QUAL SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY Subcontract Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-5 (T-40) 1O-Jan-2019 08:32 MDL Work0rder:HS19010542 Lab ID:HS19010542-03 Matrix: Liquid REPORT LIMIT UNITS Method:NA See Attached 0 NA DILUTION FACTOR DATE ANALYZED Analyst: SUBHO 18-Jan-2019 09:41 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 6 of25 HFNA-000002919 EPA Inspection Report - Page 1370 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 18-Jan-19 RESULT QUAL SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY Subcontract Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-6 (T-41) 1O-Jan-2019 08:35 MDL Work0rder:HS19010542 Lab ID:HS19010542-04 Matrix: Liquid REPORT LIMIT UNITS Method:NA See Attached 0 NA DILUTION FACTOR DATE ANALYZED Analyst: SUBHO 18-Jan-2019 09:41 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 7 of25 HFNA-000002920 EPA Inspection Report - Page 1371 of 1969 ALS Houston, US BWON Monthly Sampling (EOL) R331272 HS19010542-01 DA TES REPORT HS19010542 Client Samp ID Sample ID 18-Jan-19 Navajo Refining Company Client: Project: WorkOrder: Batch ID Date: Collection Date TCLP Date Analysis Date Prep Date Test Name: SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY DF Matrix: Liquid S-1 (API HC) 1O Jan 2019 09:53 18 Jan 2019 09:41 HS19010542-02 S-3 (API Water) 10 Jan 2019 09:13 18 Jan 2019 09:41 HS19010542-03 S-5 (T-40) 1O Jan 2019 08:32 18 Jan 2019 09:41 HS19010542-04 S-6 (T-41) 1O Jan 2019 08:35 18 Jan 2019 09:41 Page 8 of25 HFNA-000002921 EPA Inspection Report - Page 1372 of 1969 ALS Houston, US Client: Project: WorkOrder: Qualifier Date: Navajo Refining Company BWON Monthly Sampling (EOL) 18-Jan-19 QUALIFIERS, ACRONYMS, UNITS HS19010542 Description Value exceeds Regulatory Limit a Not accredited B Analyte detected in the associated Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time J Analyte detected below quantitation limit M Manually integrated, see raw data for justification n Not offered for accreditation ND Not Detected at the Reporting Limit 0 Sample amount is> 4 times amount spiked p Dual Column results percent difference > 40% R RPO above laboratory control limit s u Spike Recovery outside laboratory control limits Analyzed but not detected above the MDL/SOL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Page 9 of25 HFNA-000002922 EPA Inspection Report - Page 1373 of 1969 ALS Houston, US Date: 18-Jan-19 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date Arkansas 88-0356 27-Mar-2019 Texas T10470231-18-21 30-Apr-2019 North Dakota R193 2018-2019 30-Apr-2019 Illinois 004438 29-Jun-2019 Louisiana 03087 30-Jun-2019 Kentucky 123043 - 2018 30-Apr-2019 Kansas E-10352 2018-2019 31-Jul-2019 Oklahoma 2018-156 31-Aug-2019 Page 10 of25 HFNA-000002923 EPA Inspection Report - Page 1374 of 1969 ALS Houston, US Date: Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS19010542 18-Jan-19 SAMPLE TRACKING Lab Sarnp ID Client Sample ID Action Date Person New Location HS19010542-01 S-1 (API HG) Login 1/12/2019 2:33:43 PM JRM WET255 HS19010542-02 S-3 (API Water) Login 1/12/2019 2:33:43 PM JRM WET255 HS19010542-03 S-5 (T-40) Login 1/12/2019 2:33:43 PM JRM WET255 HS19010542-04 S-6 (T-41) Login 1/12/2019 2:33:43 PM JRM WET255 Page 11 of25 HFNA-000002924 EPA Inspection Report - Page 1375 of 1969 ALS Houston, US Date: 18-Jan-19 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 11-Jan-2019 09:00 Work Order: HS19010542 Received by: JRM Checklist completed by: Reviewed by: Jared R. Makan 12-Jan-2019 -e,:-S,-ig_n_a,-tu-re-------...---,D=-a..,.t_e_ _ Corey Grandits Matrices: Carrier name: Shipping container/cooler in good condition? Yes Custody seals intact on shipping container/cooler? Yes Custody seals intact on sample bottles? Yes Chain of custody present? Yes Chain of custody signed when relinquished and received? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes TX1005 solids received in hermetically sealed vials? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Container/Temp Blank temperature in compliance? Yes Temperature(s)/Thermometer(s): 14-Jan-2019 Date eSignature ~ ~ D ~ ~ ~ ~ ~ D ~ ~ ~ FedEx Priority Overnight No No No No No No No No No No No No D D D D D D D D D Not Present D D Not Present ~ Not Present N/A ~ D D D 1.0c/1.4c UC/C Cooler( s)/Kit( s): oam cooler Date/Time sample(s) sent to storage: 1/11/2019 20:40 Water - VOA vials have zero headspace? IR11 No D Yes D Water - pH acceptable upon receipt? Yes pH adjusted? No No No VOA vials submitted D D N/A N/A 4 ~ ~ pH adjusted by: Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 12 of25 HFNA-000002925 EPA Inspection Report - Page 1376 of 1969 Chain of Custody Form Page _1_ of -1_ Cincinnati, OH D +1513733 5336 D Holland, Ml +l 616 399 6070 D Salt Lake City, UT +I 801 266 7700 D Everett, WA +I 425 356 2600 D Houston, TX +1 2815305656 D Spring City, PA +I 610 948 4903 D Fort Collins, CO + I 970 490 1511 D Middletown, PA +I 717944 5541 D York, PA +I 717 505 5280 Enuironme ntal ALS Project Manager: Erica Padilla Work Order#: .. ·.·. ·. ·. ·. ·. · .. •·••••••• •• ···• .... Pfoiect lnform~tion •• •••.. ·· · ···. •· .. •••.•. ·. •..... •.. ... ·•...... ••• ...... >parameter/Method RequesH6rAnalysis •· . • / < F'~ojecf~anie •>>•••·••••• ••. w.or~ orci~t : ){ Specific Gravity ··.··.·.·.·.·.·.·.···.·.··· .... Cornpari{Nam.e Navajo Refining Company LLC . . . . . . . . - . . . . . . .. Tyler Turner . . . . . . . .< ..... ••{13ill T:~C:Ollli>any Holly Frontier Navajo Refining LLC Gabl Combs . ... HS19010542 , P.O. Box 159 ,501 East Main .... ... <> ·•···•· •.• •I< 1 S-1 (API HC) :2 >3 < S-3 (API Water) 01110/19 9:13 AM liquid 8 1 X S-5 (T-40) 01110/19 8:32 AM liquid 8 1 X •:•·-- ••• S-6 (T-41) 01110/19 8:35AM liquid 8 01/10/19 Liquid 9:53AM - BWON Monthly Sampling (EOL) :: : :> - Navajo Refining Company 8 - X X ····~ .. ·. .·. !Required Turnaround Time: ID 0 STD 10 Wk Days Oother _ _ __ 5 Wk Days Received by: D 2 Wk Days D 24 Hour Notes: -----~-,··-Relinquished by: I Time: oc:Packa· e:•'Check:Box•Betow,:•.• ••·• Received by (Laboratory): ·Cooler Logged by (Laboratory): . . .. Oat(!; / Time: 3,,H2S04 Level III: Std QC + Raw Data Level IV: SW846 CLP-Like ·. . .. ..· 4~NaOH s;.Na2S203 6-NaHS04 7-0tner .. .·. : Note: Any changes must be made in writing once samples and COC Form have been submitted to ALS Laboratory Group. . [~me' · \~~;:i rt St~~dard QC ... ·.. •·.· TRRP-Checklist TRRP Level IV Other: Copyright 2009 by ALS Laboratory Group Page 13 of 25 HFNA-000002926 EPA Inspection Report - Page 1377 of 1969 SHIPPER'S DECLARATION FOR DANGEROUS GOODS (Provide at least three copies to airline.) Shipper NAVAJO REFINING COMPANY C/0 AQUA MICROBICS 501 E MAIN ARTESIA Air Waybill No. 709308590729 Page 1 of 1 Page(s) ~:x Shipper's Reference Number NM88210 US (optional) Consignee Corey Grandits ALS 10450 Stancliff Suite 210 HOUSTON 18 Compliant Express CAFE3211 TX77099 US Two completed and signed copies of this Declaration must be handed to the operator WARNING TRANSPORT DETAILS Failure to comply with all respects with the applicable Dangerous Goods Regulations may be in breach of the applicable law ,subject to legal penalties. This shipment is within the Airport of Departure limitations prescribed for: {delete non applicable) ARTESIA ~ y T Airport ofDostlnation: HOUSTON . Shloment !voe: ABSGRA .o, (delete non applicable) NATURE AND QUANTITY OF DANGEROUS GOODS UN Number or identification Number, proper shipping name, Class or Division (subs;diary risk}, packing group (If required), and all other required information. UN 3266, Corrosive liquid, basic, inorganic, n.o.s.(Sodium Hydroxide),8,111 UN 1268, Petroleum distillates, n.o.s.,3,1111/ 0.04 U/366 All Packed In One FIBREBOARD BOX Q = 0.1 0.08 U/854 ------------...---------------------------------~------------------------------------~----------------~----------~----------------Additional Handling Information 24-Hour Emergency Response- CHEMTREC f-800-424-9300. CCN 201319 I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged, marked and labelled/placarded, and are in all respects in proper condition for transport according to applicable International and National Governmental RQgu!ations. I declare that all of the applicable air transport requirements have been met. Name/Title of Signatory Brady Hubbard/Environmental Coordinator Place and Date Artesia, NM 01/10/2019 Signature {&lfrms of damage whether direct, incidental, consequential, or special is limited to the greater of $100 or the authorized declared value. Recovery cannot exceed actual documented loss. Maximum far items of extraordinar1 value is $1,000, e.g. jewelry, precious meta is, negotiable instruments and other items listed in our Service Guide. Written claims must be Wed within strict time limits, see current Pt:dEx Service Guide. ---------:7'-t::==r.:;f.;;;;r,~, :aweN oc·.J, :aiea 1V3S A ~ ;,o "'"" 0 en G) ~ w = = 0 c» u, 0 ::z = """ -I >< -= (,0 .... -.I -.I 0 = = 0 N (,0 ~ u:> =i m ..... 0 .i::,. (J'I ....0 )> (') ro en :;o 0 .... "' > 0 en -< "T1 =i en (D' "'"' G) c~ (J)O (") r"ii ~;ii - m -l .... X t: g; (I) g;-l (,0 ,, .... z z ..... 0 )>,O > c5 w :c~ 0C ::x: -l !i; "' ::::o ,, c:: c:: - -i (/) ::0 _-i I 551C21D74Cn04c Page 15 of 25 HFNA-000002928 EPA Inspection Report - Page 1379 of 1969 18-Jan-2019 Corey Grandits ALS Environmental 10450 Stancliff Rd Suite 210 Houston, TX 77099 Re: Work Order: HS19010542 1901729 Dear Corey, ALS Environmental received 4 samples on 15-Jan-2019 12:00 PM for the analyses presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental - Holland and for only the analyses requested. Sample results are compliant with industry accepted practices and Quality Control results achieved laboratory specifications. Any exceptions are noted in the Case Narrative, or noted with qualifiers in the report or QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained from ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. The total number of pages in this report is 10. If you have any questions regarding this report, please feel free to contact me: ADDRESS: 3352 128th Avenue, Holland, Ml, USA PHONE: +1 (616) 399-6070 FAX: +1 (616) 399-6185 Sincerely, Electronically approved by: Chad Whelton Chad Whelton Project Manager Report of Laboratory Analysis Certificate No: MN 026-999-449 ~·:>.c:Bf}H'J %Ul.t.t'J~t:3P% ::·:·:::::·. :.:: ·:· .,.... Page 16 of25 HFNA-000002929 EPA Inspection Report - Page 1380 of 1969 ALS Group, USA Client: Project: \VorkOrder: Date: 18-Jan-19 ALS Environmental HS19010542 Work Order Sample Summary 1901729 Lab Samp ID Client Sample ID Matrix Tag Number Collection Date Date Received 1901729-01 1901729-02 1901729-03 1901729-04 Liquid Liquid Liquid Liquid S-1 S-3 S-5 S-6 1/10/2019 09:53 1/10/2019 09: 13 1/10/2019 08:32 1/10/2019 08:35 1/15/2019 1/15/2019 1/15/2019 1/15/2019 HS19010542-0l HS19010542-02 HS19010542-03 HS19010542-04 Page 17 of25 (API HC) (API Water) (T-40) (T-41) Hold 12:00 12:00 12:00 12:00 Sample Summary Pagel of 1 HFNA-000002930 EPA Inspection Report - Page 1381 of 1969 Date: 18-Jan-19 ALS Group, USA Client: Project: WorkOrder: Qualifier ALS Environmental HS19010542 1901729 QUALIFIERS, ACRONYl\1S, UNITS Description Value exceeds Regulatory Limit ** Estimated Value a Analyte is non-accredited B Analyle detected in the associakd Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time Hr BOD/CBOD - Sample was reset outside Hold Time, value should be considered estimated. J ND Anal)1e is present al an estimated concentration between the MDL and Report Limit Not Detected at the Reporting Limit 0 Sample amount is > 4 times amount spiked p Dual Column results percent difference > 40% R RPD above laboratory control limit s u Analyzed but not detected above the MDL X Acronym Spike Recovery outside laboratory control limits Analyte was detected in the Method Blank between the MDL and Reporting Limit, sample results may exhibit background or reagent contamination at the observed level. Description DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate LOD Limit of Detection (see MDL) LOQ Limit ofQuantitation (see PQL) MBLK MDL MS Method Blank Method Detection Limit Matrix Spike MSD Matrix Spike Duplicate PQL Practical Quantitation Limit RPD Relative Percent Difference TDL Target Detection Limit TNTC Too Numerous To Count A APHA Standard Methods D ASTM E EPA SW Units Reported SW-846 Update III Description none Page 18 of25 QFPage 1 o/1 HFNA-000002931 EPA Inspection Report - Page 1382 of 1969 Date: J8-Jan-19 ALS Group, USA Client: ALS Enviromnental Project: HS19010542 Sample ID: HS19010542-0l Work Order: 1901729 Lab ID: 1901729-01 Collection Date: 1/10/2019 09:53 AM Matrix: LIQUID Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 0.944 none Dilution Factor Date Analyzed Analyst: RZM 1/17/201901:15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page l of 4 Page 19 of25 HFNA-000002932 EPA Inspection Report - Page 1383 of 1969 Date: J8-Jan-19 ALS Group, USA Client: ALS Enviromnental Project: HS19010542 Sample ID: HS19010542-02 Work Order: 1901729 Lab ID: 1901729-02 Collection Date: 1/10/2019 09:13 AM Matrix: LIQUID Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 1.01 none Dilution Factor Date Analyzed Analyst: RZM 1/17/201901:15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 2 of 4 Page 20 of25 HFNA-000002933 EPA Inspection Report - Page 1384 of 1969 Date: J8-Jan-19 ALS Group, USA Client: ALS Enviromnental Project: HS19010542 Sample ID: HS19010542-03 Work Order: 1901729 Lab ID: 1901729-03 Collection Date: 1/10/2019 08:32 AM Matrix: LIQUID Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 1.15 none Dilution Factor Date Analyzed Analyst: RZM 1/17/201901:15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 3 of 4 Page 21 of25 HFNA-000002934 EPA Inspection Report - Page 1385 of 1969 Date: J8-Jan-19 ALS Group, USA Client: ALS Enviromnental Project: HS19010542 Sample ID: HS19010542-04 Work Order: 1901729 Lab ID: 1901729-04 Collection Date: 1/10/2019 08:35 AM Matrix: LIQUID Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 1.14 none Dilution Factor Date Analyzed Analyst: RZM 1/17/201901:15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 4 of 4 Page 22 of25 HFNA-000002935 EPA Inspection Report - Page 1386 of 1969 Date: 18-Jan-19 ALS Group, USA Client: Work Order: Project: ALS Environmental QC BATCH REPORT 1901729 HS19010542 Batch ID: R253305 Instrument ID WETCHEM Method: D5057-90 Sample ID: 1901550-01A DUP DUP Client ID: Units: none Run ID: WETCHEM_190117K Analyte Specific Gravity Result PQL SPK Val 1.001 0 0 Analysis Date: 1/17/2019 01:15 PM SeqNo: 5484733 SPK Ref Value %REC 0 0 OF: 1 Prep Date: Control Limit 0-0 RPO Ref Value 1.001 %RPO 0.02 RPO Limit Qual 20 ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------1 Sample ID: 1901729-02A DUP DUP Client ID: HS19010542-02 Units: none Analyte Result PQL SPK Val Specific Gravity 0.9931 0 0 The following samples were analyzed in this batch: Note: SPK Ref Value 1901729-01A 1901729-04A Analysis Date: 1/17/2019 01:15 PM %REC 0 0 1901729-02A OF: 1 Prep Date: SeqNo: 5484748 Run ID: WETCHEM_190117K Control Limit RPO Ref Value 0-0 1.01 %RPO 1.71 RPO Limit Qual 20 1901729-03A See Qualifiers Page for a list of Qualifiers and their explanation. QC Page: 1 of 1 Page 23 of25 HFNA-000002936 EPA Inspection Report - Page 1387 of 1969 10450 Stancliff Rd, Ste 210 Houston, TX 77099 T: + 1 281 530 5656 F: +1 281 530 5887 www.alsglobal.com Subcontract Chain of Custody 10595 COC ID: SUBCONTRACT TO: ALS Laboratory Group 3352 128th Ave. Phone: Holland, MI 494249263 + 1 616 399 6070 INVOICE INFORMATION: CUSTOMER INFORMATION: Company: ALS Houston Company: ALS Houston Contact: Corey Grandits Contact: Accounts Payable Address: 10450 Stancliff Rd, Ste 210 Address: 10450 Stancliff Rd, Ste 210 Phone: + 1 281 530 5656 Phone: +1 281 530 5656 Corey.Grandits@alsglobal.com Reference: HS19010542 TSR: Houston House Acct Email: Alternate Contact: Email: Jumoke M. Lawal jumoke.lawal@alsglobal.com LA~ SAMPLE 10 . cLIENT SAMPLE· ···. ANALYSIS REQUESTED 1. HS19010542-01 ~er•. ..MATRIX HS19010542-02 HS19010542-03 Liquid S-3 (API Water) ~'" 10 Jan 2019 09:53 10 Jan 2019 09:13 18 Jan 2019 Liquid S-5 (T-40) 10 Jan 2019 08:32 18 Jan 2019 Sub Specific Gravity to ALS Holland Liquid S-6 {T-41) 4. . ·bweoire: 18 Jan 2019 Sub Specific Gravity to ALS Holland 3. COLLECT JDATE '" Liquid S-1 (API HC) Sub Specific Gravity to ALS Holland 2. ..·. 10 Jan 2019 08:35 18 Jan 2019 Sub Specific Gravity to ALS Holland Comments: Please analyze for the analysis listed above. Send report to the emails shown above. QC Level: STD (Laboratory Standard QC: method blank and LCS required} Relinquished By: Received By: Cooler ID(s): ~ Date/Time: Date/Time: 'J 1ttj;e; UaA1 J&:o::> 1200 Ternperature(s): ~&\ Page 24 of25 5Rl fu15 HFNA-000002937 EPA Inspection Report - Page 1388 of 1969 ALS Group, USA Sample Receipt Checklist Client Name: ALS - HOUSTON Date/Time Received: Work Order: 1901729 Received by: Checklist completed by CA:'ue yJ~-z:u-u 15-Jan-19 15-Jan-19 Reviewed by: Date eSignature 15-Jan-19 12:00 Date eSignature Matrices: Carrier name: Shipping container/cooler in good condition? Yes [i,] No Not Present D Custody seals intact on shipping container/cooler? Yes [i,] No Not Present D Custody seals intact on sample bottles? Yes No Not Present [i,] Chain of custody present? Yes [i,] No Chain of custody signed when relinquished and received? Yes [i,] No D Chain of custody agrees with sample labels? Yes [i,] No D Samples in proper container/bottle? Yes [i,] No D Sample containers intact? Yes [i,] No Sufficient sample volume for indicated test? Yes [i,] No All samples received within holding time? Yes [i,] No Container/Temp Blank temperature in compliance? Yes [i,] No Sample(s) received on ice? Yes [i,] No Temperature(s)/Thermometer(s): Cooler(s)/Kit(s): r1/15/2019 3:09:08 PM Date/Time sample(s) sent to storage: Water - VOA vials have zero headspace? Yes Water - pH acceptable upon receipt? Yes pH adjusted? Yes No VOA vials submitted No D No [i,] N/A D N/A pH adjusted by: Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: CorrectiveAction: ~agc=of'.15~ SRC Page 1 of 1 HFNA-000002938 EPA Inspection Report - Page 1389 of 1969 10450 Stancliff Rd. Suite 210 Houston, TX 77099 T: +1 281 530 5656 F: +1 281 530 5887 February 18, 2019 Gabriela Combs Navajo Refining Company PO Box 1490 Artesia, NM 88211-1490 Work Order: HS19020431 Laboratory Results for: BWON Monthly Sampling (EOL) Dear Gabriela, ALS Environmental received 9 sample(s) on Feb 08, 2019 for the analysis presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Results are expressed as "as received" unless otherwise noted. QC sample results for this data met EPA or laboratory specifications except as noted in the Case Narrative or as noted with qualifiers in the QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained by ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. If you have any questions regarding this report, please feel free to call me. Sincerely, ~:::~:::::::~=·--z,. .· · · · t-{;-;...-,·· Generated By: JUMOKE.LAWAL Corey Grandits Project Manager Right Solutions · Right Partnu www.a!sg!obaLcom Pagel of33 HFNA-000002939 EPA Inspection Report - Page 1390 of 1969 ALS Houston, US Date: Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS19020431 18-Feb-19 SAMPLE SUMMARY lab Samp ID Client Sample ID Matrix HS19020431-01 S-1 (API HC) HS19020431-02 TagNo Collection Date Date Received Hold Liquid 07-Feb-2019 09:08 08-Feb-2019 09:00 S-3 (API Water) Liquid 07-Feb-2019 09:25 08-Feb-2019 09:00 HS19020431-03 S-5 (T-40) Liquid 07-Feb-2019 08:46 08-Feb-2019 09:00 HS19020431-04 S-6 (T-41) Liquid 07-Feb-2019 08:51 08-Feb-2019 09:00 HS19020431-05 Field Blank Water 07-Feb-2019 09:21 08-Feb-2019 09:00 HS19020431-06 EQ Blank Port 1 Water 07-Feb-2019 09:40 08-Feb-2019 09:00 HS19020431-07 EQ Blank Port 2 Water 07-Feb-2019 09:40 08-Feb-2019 09:00 D HS19020431-08 Duplicate Liquid 07-Feb-2019 00:00 08-Feb-2019 09:00 HS19020431-09 Trip Blank Water 07-Feb-2019 00:00 08-Feb-2019 09:00 D D D D D D D D Page 2 of33 HFNA-000002940 EPA Inspection Report - Page 1391 of 1969 ALS Houston, US Client: Project: Work Order: Date: Navajo Refining Company 18-Feb-19 CASE NARRATIVE BWON Monthly Sampling (EOL) HS19020431 GCMS Volatiles by Method SW8260 Batch ID: R332681,R332699,R332762,R332986 • The test results meet requirements of the current NELAP standards, state requirements or programs where applicable. Batch ID: R332646 Sample ID: S-5 (T-40) (HS19020431-03) • Lowest practical dilution for HS19020431-03 due to sample matrix. Surrogate failure due to matrix. Sample ID: S-6 (T-41) (HS19020431-04) • Lowest practical dilution for HS19020431-04 due to sample matrix Page 3 of33 HFNA-000002941 EPA Inspection Report - Page 1392 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 18-Feb-19 ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-1 (API HC) 07-Feb-2019 09:08 RESULT QUAL VOLATILES BY SW8260C MDL Work0rder:HS19020431 Lab ID:HS19020431-01 Matrix: Liquid 0.024 DATE ANALYZED UNITS 0.24 mg/Kg 50 12-Feb-2019 17:41 %REC %REC %REC %REC 50 12-Feb-2019 17:41 50 12-Feb-2019 17:41 50 12-Feb-2019 17:41 50 12-Feb-2019 17:41 Analyst: WLR Method:SW8260 5.5 Benzene Surr: 1, 2-0ichloroethane-d4 93.9 70-126 Surr: 4-Bromofluorobenzene 96.8 70-130 Surr: Dibromofluoromethane 90.4 70-130 104 70-130 Surr: Toluene-dB DILUTION FACTOR REPORT LIMIT Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 4 of33 HFNA-000002942 EPA Inspection Report - Page 1393 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 18-Feb-19 RESULT QUAL VOLATILES - SW8260C Benzene ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-3 (API Water) 07-Feb-2019 09:25 MDL Work0rder:HS19020431 Lab ID:HS19020431-02 Matrix: Liquid REPORT LIMIT UNITS DILUTION FACTOR Analyst: PC Method:SW8260 0.46 0.030 DATE ANALYZED 0.25 Surr: 1, 2-0ichloroethane-d4 87.9 70-126 Surr: 4-Bromofluorobenzene 97.1 82-124 Surr: Dibromofluoromethane 93.4 77-123 Surr: Toluene-dB 98.3 82-127 mg/L 50 15-Feb-2019 16:07 %REC %REC %REC %REC 50 15-Feb-2019 16:07 50 15-Feb-2019 16:07 50 15-Feb-2019 16:07 50 15-Feb-2019 16:07 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 5 of33 HFNA-000002943 EPA Inspection Report - Page 1394 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 18-Feb-19 ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-5 (T-40) 07-Feb-2019 08:46 RESULT QUAL VOLATILES BY SW8260C MDL Work0rder:HS19020431 Lab ID:HS19020431-03 Matrix: Liquid DILUTION FACTOR UNITS 0.24 mg/Kg 50 11-Feb-2019 22:54 %REC %REC %REC %REC 50 11-Feb-2019 22:54 50 11-Feb-2019 22:54 50 11-Feb-2019 22:54 50 11-Feb-2019 22:54 Analyst: WLR Method:SW8260 Benzene < 0.024 Surr: 1, 2-0ichloroethane-d4 92.5 70-126 Surr: 4-Bromofluorobenzene 103 70-130 Surr: Dibromofluoromethane 68.9 Surr: Toluene-dB 97.4 0.024 s DATE ANALYZED REPORT LIMIT 70-130 70-130 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 6 of33 HFNA-000002944 EPA Inspection Report - Page 1395 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 18-Feb-19 RESULT QUAL VOLATILES BY SW8260C Benzene ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-6 (T-41) 07-Feb-2019 08:51 MDL Work0rder:HS19020431 Lab ID:HS19020431-04 Matrix: Liquid DILUTION FACTOR UNITS 0.24 mg/Kg 50 11-Feb-2019 23:19 %REC %REC %REC %REC 50 11-Feb-2019 23:19 50 11-Feb-2019 23:19 50 11-Feb-2019 23:19 50 11-Feb-2019 23:19 Analyst: WLR Method:SW8260 0.21 J 0.024 DATE ANALYZED REPORT LIMIT Surr: 1, 2-0ichloroethane-d4 98.2 70-126 Surr: 4-Bromofluorobenzene 100 70-130 Surr: Dibromofluoromethane 77.3 70-130 Surr: Toluene-dB 97.0 70-130 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 7 of33 HFNA-000002945 EPA Inspection Report - Page 1396 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 18-Feb-19 RESULT QUAL VOLATILES - SW8260C Benzene ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) Field Blank 07-Feb-2019 09:21 MDL Work0rder:HS19020431 Lab ID:HS19020431-05 Matrix:Water REPORT LIMIT UNITS DILUTION FACTOR Analyst: PC Method:SW8260 < 0.00060 0.00060 DATE ANALYZED 0.0050 mg/L %REC %REC %REC %REC Surr: 1, 2-0ichloroethane-d4 86.5 70-126 Surr: 4-Bromofluorobenzene 99.8 82-124 Surr: Dibromofluoromethane 94.1 77-123 Surr: Toluene-dB 95.1 82-127 12-Feb-2019 10:18 1 12-Feb-2019 10:18 1 12-Feb-2019 10:18 1 12-Feb-2019 10:18 1 12-Feb-2019 10:18 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 8 of33 HFNA-000002946 EPA Inspection Report - Page 1397 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 18-Feb-19 RESULT QUAL VOLATILES - SW8260C Benzene ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) EQ Blank Port 1 07-Feb-2019 09:40 MDL Work0rder:HS19020431 Lab ID:HS19020431-06 Matrix:Water REPORT LIMIT UNITS DILUTION FACTOR Analyst: PC Method:SW8260 < 0.00060 0.00060 DATE ANALYZED 0.0050 mg/L %REC %REC %REC %REC Surr: 1, 2-0ichloroethane-d4 85.9 70-126 Surr: 4-Bromofluorobenzene 97.9 82-124 Surr: Dibromofluoromethane 93.6 77-123 Surr: Toluene-dB 97.6 82-127 12-Feb-2019 10:42 1 12-Feb-2019 10:42 1 12-Feb-2019 10:42 1 12-Feb-2019 10:42 1 12-Feb-2019 10:42 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 9 of33 HFNA-00000294 7 EPA Inspection Report - Page 1398 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 18-Feb-19 RESULT QUAL VOLATILES - SW8260C Benzene ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) EQ Blank Port 2 07-Feb-2019 09:40 MDL Work0rder:HS19020431 Lab ID:HS19020431-07 Matrix:Water REPORT LIMIT UNITS DILUTION FACTOR Analyst: PC Method:SW8260 < 0.00060 0.00060 DATE ANALYZED 0.0050 mg/L %REC %REC %REC %REC Surr: 1, 2-0ichloroethane-d4 86.4 70-126 Surr: 4-Bromofluorobenzene 97.2 82-124 Surr: Dibromofluoromethane 92.5 77-123 Surr: Toluene-dB 97.3 82-127 12-Feb-2019 16:29 1 12-Feb-2019 16:29 1 12-Feb-2019 16:29 1 12-Feb-2019 16:29 1 12-Feb-2019 16:29 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 10 of33 HFNA-000002948 EPA Inspection Report - Page 1399 of 1969 ALS Houston, US Date: 18-Feb-19 Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Sample ID: Collection Date: Duplicate 07-Feb-2019 00:00 ANALYSES RESULT QUAL VOLATILES - SW8260C Benzene ANALYTICAL REPORT Work0rder:HS19020431 Lab ID:HS19020431-08 Matrix: Liquid MDL REPORT LIMIT UNITS DILUTION FACTOR Analyst: PC Method:SW8260 0.43 0.030 DATE ANALYZED 0.25 Surr: 1, 2-0ichloroethane-d4 87.8 70-126 Surr: 4-Bromofluorobenzene 99.7 82-124 Surr: Dibromofluoromethane 94.4 77-123 Surr: Toluene-dB 95.4 82-127 mg/L 50 15-Feb-2019 16:31 %REC %REC %REC %REC 50 15-Feb-2019 16:31 50 15-Feb-2019 16:31 50 15-Feb-2019 16:31 50 15-Feb-2019 16:31 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 11 of33 HFNA-000002949 EPA Inspection Report - Page 1400 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 18-Feb-19 RESULT QUAL VOLATILES - SW8260C Benzene ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) Trip Blank 07-Feb-2019 00:00 MDL Work0rder:HS19020431 Lab ID:HS19020431-09 Matrix:Water REPORT LIMIT UNITS DILUTION FACTOR Analyst: PC Method:SW8260 < 0.00060 0.00060 DATE ANALYZED 0.0050 mg/L %REC %REC %REC %REC Surr: 1, 2-0ichloroethane-d4 86.1 70-126 Surr: 4-Bromofluorobenzene 96.6 82-124 Surr: Dibromofluoromethane 93.0 77-123 Surr: Toluene-dB 97.5 82-127 12-Feb-2019 16:53 1 12-Feb-2019 16:53 1 12-Feb-2019 16:53 1 12-Feb-2019 16:53 1 12-Feb-2019 16:53 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 12 of33 HFNA-000002950 EPA Inspection Report - Page 1401 of 1969 ALS Houston, US Date: 18-Feb-19 WEIGHT LOG Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) WorkOrder: HS19020431 Batch ID: 2910 SamplD HS19020431-01 HS19020431-03 HS19020431-04 Method: Container VOLA Tl LES BY SW8260C Sample Wt/Vol Final Volume Weight Factor 5.127 (g) 5.16 (g) 5.188 (g) 5 (ml) 5 (ml) 5 (ml) 0.98 0.97 0.96 Container Type Bulk (5030B) Bulk (5030B) Bulk (5030B) Page 13 of33 HFNA-000002951 EPA Inspection Report - Page 1402 of 1969 ALS Houston, US BWON Monthly Sampling (EOL) DA TES REPORT HS19020431 Client Samp ID Sample ID 18-Feb-19 Navajo Refining Company Client: Project: WorkOrder: Batch ID Date: R332646 Collection Date TCLP Date Test Name : VOLATILES BY SW8260C Prep Date Analysis Date DF Matrix: Liquid HS 19020431-03 S-5 (T-40) 07 Feb 2019 08:46 11 Feb 2019 22:54 50 HS19020431-04 S-6 (T-41) 07 Feb 2019 08:51 11 Feb201923:19 50 Batch ID R332681 HS19020431-01 Batch ID Test Name: VOLATILES BY SW8260C S-1 (API HC) R332699 07 Feb 2019 09:08 Test Name : VOLATILES - SW8260C Matrix: Liquid 12 Feb 2019 17:41 Matrix: water HS19020431-05 Field Blank 07 Feb 2019 09:21 12 Feb201910:18 HS19020431-06 EQ Blank Port 1 07 Feb 2019 09:40 12 Feb 2019 10:42 Batch ID R332762 Test Name ; VOLATILES - SW8260C Matrix; Water HS19020431-07 EQ Blank Port 2 07 Feb 2019 09:40 12 Feb 2019 16:29 HS19020431-09 Trip Blank 07 Feb 2019 00:00 12 Feb 2019 16:53 Batch ID R332986 Test Name: VOLATILES- SW8260C 50 Matrix: Liquid HS19020431-02 S-3 (API Water) 07 Feb 2019 09:25 15 Feb 2019 16:07 50 HS19020431-08 Duplicate 07 Feb 2019 00:00 15 Feb 2019 16:31 50 Page 14 of33 HFNA-000002952 EPA Inspection Report - Page 1403 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 18-Feb-19 Navajo Refining Company HS19020431 R332646 MBLK QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: Run ID: Analyte Units: ug/Kg MBLKW1-021119 Client ID: Result Method; VOA8 VOA8_332646 PQL Benzene < 25 250 SW8260 Analysis Date: 11-Feb-2019 14:08 SeqNo: 4944906 SPKVal SPK Ref Value %REC Prep Date: Control Limit Surr: 1,2-0ichloroethane-d4 2859 0 2500 0 114 76 - 125 Surr: 4-Bromofluorobenzene 2473 0 2500 0 98.9 80 - 120 Surr: Dibromofluoromethane 2576 0 2500 0 103 80 - 119 Surr: Toluene-dB 2643 0 2500 0 106 81 - 118 LCS Sample ID: Units: ug/Kg VLCSW1-021119 Client ID: Run ID: VOA8_332646 Prep Date: SPKVal SPK Ref Value %REC Control Limit 46.92 5.0 50 0 93.8 75 - 124 Surr: 1,2-0ichloroethane-d4 46.99 0 50 0 94.0 76 - 125 Surr: 4-Bromofluorobenzene 50.17 0 50 0 100 80 - 120 Surr: Dibromofluoromethane 50.53 0 50 0 101 80 - 119 Surr: Toluene-dB 49.17 0 50 0 98.3 81 - 118 Result Benzene MS Sample ID: HS19011582-02MS Client ID: Analyte Run ID: Result OF: 1 RPO Ref RPO Value %RPO Limit Qual Analysis Date: 11-Feb-2019 17:04 Units: ug/Kg VOA8_332646 RPO Ref RPO Value %RPO Limit Qual Analysis Date: 11-Feb-2019 13:18 SeqNo: 4944905 PQL Analyte OF: 50 SeqNo: 4945581 Prep Date: PQL SPKVal SPK Ref Value %REC Control Limit Benzene 20400 1900 19250 216.2 105 70 - 130 Surr: 1,2-0ichloroethane-d4 18040 0 19250 0 93.7 70 - 126 Surr: 4-Bromofluorobenzene 18770 0 19250 0 97.5 70 - 130 Surr: Dibromofluoromethane 18990 0 19250 0 98.6 70 - 130 Surr: Toluene-dB 18700 0 19250 0 97.1 70 - 130 OF: 500 RPO Ref RPO Value %RPO Limit Qual Page 15 of 33 HFNA-000002953 EPA Inspection Report - Page 1404 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 18-Feb-19 Navajo Refining Company HS19020431 R332646 MSD QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: HS19011582-02MSD Client ID: Analyte Run ID: Result Method; VOA8 Units: ug/Kg VOA8_332646 SW8260 Analysis Date: 11-Feb-2019 17:29 Seq No: 4945582 OF: 500 PrepDate: PQL SPKVal SPK Ref Value %REC Control Limit RPO Ref RPO Value %RPO Limit Qual Benzene 21380 1900 19250 216.2 110 70 - 130 20400 4.7 30 Surr: 1,2-0ichloroethane-d4 17420 0 19250 0 90.5 70 - 126 18040 3.45 30 Surr: 4-Bromofluorobenzene 19850 0 19250 0 103 70 - 130 18770 5.6 30 Surr: Dibromofluoromethane 18620 0 19250 0 96.7 70 - 130 18990 1.97 30 Surr: Toluene-dB 19230 0 19250 0 99.9 70 - 130 18700 2.81 30 HS _ 19020431-04 The following samples were analyzed in this batch: ~f_s_19_0_20_4_3_1-_03_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _~ Page 16 of33 HFNA-000002954 EPA Inspection Report - Page 1405 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 18-Feb-19 Navajo Refining Company HS19020431 R332681 MBLK QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: Units: ug/Kg MBLKW1-021219 Client ID: Run ID: Analyte Method; VOA8 Result VOA8_332681 PQL Benzene < 25 250 SW8260 Analysis Date: 12-Feb-2019 10:12 SeqNo: 4945869 SPKVal SPK Ref Value %REC Prep Date: Control Limit Surr: 1,2-0ichloroethane-d4 2687 0 2500 0 107 76 - 125 Surr: 4-Bromofluorobenzene 2524 0 2500 0 101 80 - 120 Surr: Dibromofluoromethane 2508 0 2500 0 100 80 - 119 Surr: Toluene-dB 2565 0 2500 0 103 81 - 118 LCS Sample ID: Units: ug/Kg VLCSW1-021219 Client ID: Run ID: Analyte Result VOA8_332681 Prep Date: PQL SPKVal SPK Ref Value %REC Control Limit 75 - 124 42.79 5.0 50 0 85.6 Surr: 1,2-0ichloroethane-d4 46.34 0 50 0 92.7 76 - 125 Surr: 4-Bromofluorobenzene 49.09 0 50 0 98.2 80 - 120 Surr: Dibromofluoromethane 50.35 0 50 0 101 80 - 119 Surr: Toluene-dB 49.69 0 50 0 99.4 81 - 118 MS Sample ID: HS19020429-01 MS Analyte Result VOA8_332681 OF: 1 RPO Ref RPO Value %RPO Limit Qual Analysis Date: 12-Feb-2019 12:17 Units: ug/Kg Run ID: RPO Ref RPO Value %RPO Limit Qual Analysis Date: 12-Feb-2019 09:22 SeqNo: 4945868 Benzene Client ID: OF: 50 SeqNo: 4946400 Prep Date: PQL SPKVal SPK Ref Value %REC Control Limit Benzene 4216000 250000 2.5e+006 1722000 99.7 70 - 130 Surr: 1,2-0ichloroethane-d4 2332000 0 2.5e+006 0 93.3 70 - 126 Surr: 4-Bromofluorobenzene 2402000 0 2.5e+006 0 96. 1 70 - 130 Surr: Dibromofluoromethane 2497000 0 2.5e+006 0 99.9 70 - 130 Surr: Toluene-dB 2534000 0 2.5e+006 0 101 70 - 130 OF: 50000 RPO Ref RPO Value %RPO Limit Qual Page 17 of33 HFNA-000002955 EPA Inspection Report - Page 1406 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 18-Feb-19 Navajo Refining Company HS19020431 R332681 MSD QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: Analyte Units: ug/Kg HS19020429-01 MSD Client ID: Run ID: Result Method; VOAS VOA8_332681 SW8260 Analysis Date: 12-Feb-2019 12:42 SeqNo: 4946401 Prep Date: OF: 50000 PQL SPKVal SPK Ref Value %REC Control Limit 98.5 70 - 130 4216000 Benzene 4185000 250000 2.5e+006 1722000 RPO Ref RPO Value %RPO Limit Qual 0.736 30 Surr: 1,2-0ichloroethane-d4 2245000 0 2.5e+006 0 89.8 70 - 126 2332000 3.83 30 Surr: 4-Bromofluorobenzene 2455000 0 2.5e+006 0 98.2 70 - 130 2402000 2.19 30 Surr: Dibromofluoromethane 2438000 0 2.5e+006 0 97.5 70 - 130 2497000 2.38 30 Surr: Toluene-dB 2481000 0 2.5e+006 0 99.2 70 - 130 2534000 2.12 30 The following samples were analyzed in this batch: rs 19020431-01 Page 18 of 33 HFNA-000002956 EPA Inspection Report - Page 1407 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 18-Feb-19 Navajo Refining Company HS19020431 R332699 MBLK QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: Units: ug/L VBLKW-190211 Client ID: Run ID: Analyte Result Benzene Method; VOA6 VOA6_332699 PQL SW8260 Analysis Date: 12-Feb-2019 01 :04 SeqNo: 4946079 SPKVal SPK Ref Value %REC Prep Date: Control Limit < 0.60 5.0 Surr: 1,2-0ichloroethane-d4 44.55 0 50 0 89.1 70 - 130 Surr: 4-Bromofluorobenzene 48.48 0 50 0 97.0 82 - 115 Surr: Dibromofluoromethane 47.15 0 50 0 94.3 73 - 126 Surr: Toluene-dB 49.21 0 50 0 98.4 81 - 120 LCS Sample ID: Units: ug/L VLCSW-190211 Client ID: Run ID: Analyte Result VOA6_332699 Prep Date: PQL SPKVal SPK Ref Value %REC Control Limit 97.3 74 - 120 19.46 5.0 20 0 Surr: 1,2-0ichloroethane-d4 44.14 0 50 0 88.3 70 - 130 Surr: 4-Bromofluorobenzene 49.62 0 50 0 99.2 82 - 115 Surr: Dibromofluoromethane 48.02 0 50 0 96.0 73 - 126 Surr: Toluene-dB 48.72 0 50 0 97.4 81 - 120 MS Sample ID: HS19020131-01MS Analyte Run ID: Result OF: 1 RPO Ref RPO Value %RPO Limit Qual Analysis Date: 12-Feb-2019 01 :52 Units: ug/L VOA6_332699 RPO Ref RPO Value %RPO Limit Qual Analysis Date: 12-Feb-2019 00:16 SeqNo: 4946078 Benzene Client ID: OF: 1 SeqNo: 4946081 Prep Date: PQL SPKVal SPK Ref Value %REC Control Limit 103 70 - 127 Benzene 20.57 5.0 20 0 Surr: 1,2-0ichloroethane-d4 43.86 0 50 0 87.7 70 - 126 Surr: 4-Bromofluorobenzene 48.28 0 50 0 96.6 82 - 124 Surr: Dibromofluoromethane 47.71 0 50 0 95.4 77 - 123 Surr: Toluene-dB 49.68 0 50 0 99.4 82 - 127 OF: 1 RPO Ref RPO Value %RPO Limit Qual Page 19 of33 HFNA-000002957 EPA Inspection Report - Page 1408 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 18-Feb-19 Navajo Refining Company HS19020431 R332699 MSD QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: HS19020131-01MSD Client ID: Analyte Run ID: Result Method; VOAG Units: ug/L VOA6_332699 SW8260 Analysis Date: 12-Feb-2019 02:16 SeqNo: 4946082 OF: 1 PrepDate: PQL SPKVal SPK Ref Value %REC Control Limit RPO Ref RPO Value %RPO Limit Qual 99.7 70 - 127 20.57 3.1 20 Benzene 19.94 5.0 20 0 Surr: 1,2-0ichloroethane-d4 43.46 0 50 0 86.9 70 - 126 43.86 0.921 20 Surr: 4-Bromofluorobenzene 49.53 0 50 0 99.1 82 - 124 48.28 2.56 20 Surr: Dibromofluoromethane 47.34 0 50 0 94.7 77 - 123 47.71 0.774 20 Surr: Toluene-dB 48.22 0 50 0 96.4 82 - 127 49.68 2.99 20 The following samples were analyzed in this batch: ~f_s_19_0_20_4_3_1-_o_s- - -HS -19020431-06 -----------------------~ Page 20 of33 HFNA-000002958 EPA Inspection Report - Page 1409 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 18-Feb-19 Navajo Refining Company HS19020431 R332762 MBLK QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: Units: ug/L VBLKW-190212 Client ID: Run ID: Analyte Result Benzene Method; VOA6 VOA6_332762 PQL SW8260 Analysis Date: SeqNo: 4947689 SPKVal SPK Ref Value %REC Prep Date: Control Limit < 0.60 5.0 Surr: 1,2-0ichloroethane-d4 43.28 0 50 0 86.6 70 - 130 Surr: 4-Bromofluorobenzene 48.21 0 50 0 96.4 82 - 115 Surr: Dibromofluoromethane 46.64 0 50 0 93.3 73 - 126 Surr: Toluene-dB 48.57 0 50 0 97.1 81 - 120 LCS Sample ID: Units: ug/L VLCSW-190212 Client ID: Run ID: Analyte Result VOA6_332762 Analysis Date: SeqNo: 4947688 Prep Date: PQL SPKVal SPK Ref Value %REC Control Limit 91.3 74 - 120 Benzene 18.26 5.0 20 0 Surr: 1,2-0ichloroethane-d4 42.61 0 50 0 85.2 70 - 130 Surr: 4-Bromofluorobenzene 47.72 0 50 0 95.4 82 - 115 Surr: Dibromofluoromethane 47.29 0 50 0 94.6 73 - 126 Surr: Toluene-dB 49.32 0 50 0 98.6 81 - 120 MS Sample ID: HS19020369-01 MS Client ID: Run ID: Units: ug/L VOA6_332762 Analysis Date: SeqNo: 4947692 Prep Date: Result PQL SPKVal SPK Ref Value %REC Control Limit Benzene 20.51 5.0 20 0 103 70 - 127 Surr: 1,2-0ichloroethane-d4 43.13 0 50 0 86.3 70 - 126 Surr: 4-Bromofluorobenzene 48.79 0 50 0 97.6 82 - 124 Surr: Dibromofluoromethane 47.1 0 50 0 94.2 77 - 123 49.49 0 50 0 99.0 82 - 127 Analyte Surr: Toluene-dB 12-Feb-2019 13:40 OF: 1 RPO Ref RPO Value %RPO Limit Qual 12-Feb-2019 12:52 OF: 1 RPO Ref RPO Value %RPO Limit Qual 12-Feb-2019 14:53 OF: 1 RPO Ref RPO Value %RPO Limit Qual Page 21 of33 HFNA-000002959 EPA Inspection Report - Page 1410 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 18-Feb-19 Navajo Refining Company HS19020431 R332762 MSD QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: HS19020369-01 MSD Client ID: Analyte Run ID: Result Method; VOA6 Units: ug/L VOA6_332762 SW8260 Analysis Date: 12-Feb-2019 15:17 SeqNo: 4947693 OF: 1 PrepDate: PQL SPKVal SPK Ref Value %REC Control Limit RPO Ref RPO Value %RPO Limit Qual 97.7 70 - 127 20.51 4.83 20 Benzene 19.54 5.0 20 0 Surr: 1,2-0ichloroethane-d4 43.69 0 50 0 87.4 70 - 126 43.13 1.28 20 Surr: 4-Bromofluorobenzene 49.59 0 50 0 99.2 82 - 124 48.79 1.63 20 Surr: Dibromofluoromethane 47.71 0 50 0 95.4 77 - 123 47.1 1.28 20 Surr: Toluene-dB 48.11 0 50 0 96.2 82 - 127 49.49 2.83 20 19020431-09 The following samples were analyzed in this batch: ~ f _ s _ 1 9 _ 0 _HS 20 _4_3_1-_07---------------------------~ Page 22 of33 HFNA-000002960 EPA Inspection Report - Page 1411 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 18-Feb-19 Navajo Refining Company HS19020431 R332986 MBLK QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: Units: ug/L VBLKW-190215 Client ID: Run ID: Analyte Result Benzene Method; VOA6 VOA6_332986 PQL SW8260 Analysis Date: 15-Feb-2019 12:30 SeqNo: 4952463 SPKVal SPK Ref Value %REC Prep Date: Control Limit < 0.60 5.0 Surr: 1,2-0ichloroethane-d4 43.57 0 50 0 87.1 70 - 130 Surr: 4-Bromofluorobenzene 49.02 0 50 0 98.0 82 - 115 Surr: Dibromofluoromethane 47.09 0 50 0 94.2 73 - 126 Surr: Toluene-dB 48.27 0 50 0 96.5 81 - 120 LCS Sample ID: Units: ug/L VLCSW-190215 Client ID: Run ID: Analyte Result VOA6_332986 Prep Date: PQL SPKVal SPK Ref Value %REC Control Limit 91.5 74 - 120 18.29 5.0 20 0 Surr: 1,2-0ichloroethane-d4 43.43 0 50 0 86.9 70 - 130 Surr: 4-Bromofluorobenzene 49.96 0 50 0 99.9 82 - 115 Surr: Dibromofluoromethane 47.65 0 50 0 95.3 73 - 126 Surr: Toluene-dB 48.08 0 50 0 96.2 81 - 120 MS Sample ID: HS19020270-01 MS Analyte Run ID: Result OF: 1 RPO Ref RPO Value %RPO Limit Qual Analysis Date: 15-Feb-2019 15:18 Units: ug/L VOA6_332986 RPO Ref RPO Value %RPO Limit Qual Analysis Date: 15-Feb-2019 11:42 SeqNo: 4952462 Benzene Client ID: OF: 1 SeqNo: 4952468 Prep Date: PQL SPKVal SPK Ref Value %REC Control Limit 101 70 - 127 Benzene 20.15 5.0 20 0 Surr: 1,2-0ichloroethane-d4 43.32 0 50 0 86.6 70 - 126 Surr: 4-Bromofluorobenzene 48.59 0 50 0 97.2 82 - 124 Surr: Dibromofluoromethane 47.44 0 50 0 94.9 77 - 123 Surr: Toluene-dB 48.76 0 50 0 97.5 82 - 127 OF: 1 RPO Ref RPO Value %RPO Limit Qual Page 23 of33 HFNA-000002961 EPA Inspection Report - Page 1412 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 18-Feb-19 Navajo Refining Company HS19020431 R332986 MSD QC BATCH REPORT BWON Monthly Sampling (EOL) Sample ID: Instrument: HS19020270-01 MSD Client ID: Analyte Run ID: Result Method; VOA6 Units: ug/L VOA6_332986 SW8260 Analysis Date: 15-Feb-2019 15:42 SeqNo: 4952469 OF: 1 PrepDate: PQL SPKVal SPK Ref Value %REC Control Limit RPO Ref RPO Value %RPO Limit Qual 98.7 70 - 127 20.15 2.05 20 Benzene 19.74 5.0 20 0 Surr: 1,2-0ichloroethane-d4 43.73 0 50 0 87.5 70 - 126 43.32 0.929 20 Surr: 4-Bromofluorobenzene 49.43 0 50 0 98.9 82 - 124 48.59 1.71 20 Surr: Dibromofluoromethane 47.29 0 50 0 94.6 77 - 123 47.44 0.33 20 Surr: Toluene-dB 48.07 0 50 0 96.1 82 - 127 48.76 1.41 20 HS19020431-08 The following samples were analyzed in this batch: ~f_s_19_0_20_4_3_1-_02_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _~ Page 24 of33 HFNA-000002962 EPA Inspection Report - Page 1413 of 1969 ALS Houston, US Client: Project: WorkOrder: Qualifier Date: 18-Feb-19 Navajo Refining Company BWON Monthly Sampling (EOL) QUALIFIERS, ACRONYMS, UNITS HS19020431 Description Value exceeds Regulatory Limit a Not accredited B Analyte detected in the associated Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time J Analyte detected below quantitation limit M Manually integrated, see raw data for justification n Not offered for accreditation ND Not Detected at the Reporting Limit O Sample amount is> 4 times amount spiked P Dual Column results percent difference > 40% R RPO above laboratory control limit S Spike Recovery outside laboratory control limits U Analyzed but not detected above the MDL/SOL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Unit Reported Description mg/Kg Milligrams per Kilogram mg/L Milligrams per Liter Page 25 of33 HFNA-000002963 EPA Inspection Report - Page 1414 of 1969 ALS Houston, US Date: 18-Feb-19 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date Arkansas 88-0356 27-Mar-2019 Texas T10470231-18-21 30-Apr-2019 North Dakota R193 2018-2019 30-Apr-2019 Illinois 004438 29-Jun-2019 Louisiana 03087 30-Jun-2019 Dept of Defense ANAB L2231 20-Dec-2021 Kentucky 123043 - 2018 30-Apr-2019 Kansas E-10352 2018-2019 31-Jul-2019 Oklahoma 2018-156 31-Aug-2019 North Carolina 624-2019 31-Dec-2019 California 2919, 2018-2019 30-Apr-2019 Maryland 343, 2018-2019 30-Jun-2019 Page 26 of33 HFNA-000002964 EPA Inspection Report - Page 1415 of 1969 ALS Houston, US Date: Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS19020431 18-Feb-19 SAMPLE TRACKING Lab Sarnp ID Client Sample ID Action Date Person New Location HS19020431-01 S-1 (API HG) Login 2/8/2019 3:02:47 PM PMG VOA060 HS19020431-02 S-3 (API Water) Login 2/8/2019 3:02:47 PM PMG VOA060 HS19020431-03 S-5 (T-40) Login 2/8/2019 3:02:47 PM PMG VOA060 HS19020431-04 S-6 (T-41) Login 2/8/2019 3:02:47 PM PMG VOA060 HS19020431-05 Field Blank Login 2/8/2019 3:02:47 PM PMG VOA060 HS19020431-06 EQ Blank Port 1 Login 2/8/2019 3:02:47 PM PMG VOA060 HS19020431-07 EQ Blank Port 2 Login 2/8/2019 3:02:47 PM PMG VOA060 HS19020431-08 Duplicate Login 2/8/2019 3:02:47 PM PMG VOA060 HS19020431-09 Trip Blank Login 2/8/2019 3:02:47 PM PMG VOA060 Page 27 of33 HFNA-000002965 EPA Inspection Report - Page 1416 of 1969 ALS Houston, US Date: 18-Feb-19 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 08-Feb-2019 09:00 Work Order: HS19020431 Received by: NDR Checklist completed by: Pare sh M. Giga eSignature Matrices: Reviewed by: 8-Feb-2019 Date Corey Grandits 13-Feb-2019 Date eSignature Carrier name: Soil/water ~ FedEx No Shipping container/cooler in good condition? Yes Custody seals intact on shipping container/cooler? Yes Custody seals intact on sample bottles? D D Yes D No Yes No Chain of custody present? Yes No Chain of custody signed when relinquished and received? Yes Samplers name present on COG? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Container/Temp Blank temperature in compliance? Yes VOA/TX1005/TX1006 Solids in hermetically sealed vials? ~ ~ [£] ~ ~ ~ @ ~ @ Temperature(s)/Thermometer(s): 0.8c/1.1 c U/C Cooler( s)/Kit( s): Hazmatpac Date/Time sample(s) sent to storage: 2/8/19 15:20 No No No No No No No No No D D D D D D D D D D D D D Not Present Not Present Not Present Not Present D ~ ~ @ 1 Page(s) COC 1Ds:None ll1R25 Water - VOA vials have zero headspace? Yes~ No Water - pH acceptable upon receipt? Yes~ No pH adjusted? Yes D No D D ~ No VOA vials submitted N/A N/A D D D pH adjusted by: Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 28 of33 HFNA-000002966 EPA Inspection Report - Page 1417 of 1969 Page _1_ of Enu iron men taa •::•••• P.urc;tiase Oi:der >•~~rnpaWNarrie .......... Pr6j~i:tNani~ BWON Monthly Samplin g (EOL) , ......... >< <: ~ityiS:t~tet#ip Artesia, NM 88211-0159 >< ::i>~ciiie (575) 748-3311 ' ·· .....< :~ax (575) 746-5451 S-1 (API HC) < : I ·.·.·. . ·.·. ): >~ityJS1ateiZip Artesia, New Mexico 88210 > Phone (575) 748-3311 ••.. if: ,aJ A.'. VOLATI LES (8260) Benzen e <•~il(ToCcimpany Holly Frontier Navajo Refining LLC .·· .. ··.· ·. 4 ·or Gabi Combs P.O. Box 159 f Navaj o Refining Comp any · .. · .. ·.·.·.·.·.·.·. ·.·.··.·.·.·.· .·. Navajo Refining Compan y LLC Tyler Turner I Uf BWON Monthly Samplin g (EOL) 1111111111111 ALS Project Manager: Eric.a Padilla I HS19020431 Chai n of Cust ody Form . 5-Na2S203 Note: Any changes must be made in writing once samples and COC Form have < : · .·. ' ••• 6-NaHS04 ' ·1-Qther •·· 8-4 degrees C .. ·. been submitte d to ALS Laborato ry Group. ~.:~!is:"" ' • ·'11: 2,.-; :Gl~ f>:ackag:e: (C.he61d3ox Below}::::••:•·•· jTRRP-C hecklist Level III: Std QC+ Raw Data Level IV: SW846 CLP-Like ITRRP Level IV Other: Copyrig ht 2009 by ALS Laborato ry Group Page 29 of33 HFNA -00000 2967 EPA Inspection Report - Page 1418 of 1969 (Provide at least three copies to airline.) Shipper Air Waybill No. NAVAJO REFINING COMPANY C/0 AQUA MICROBICS 501 E MAIN ARTESIA 709308590740 Page 1 of 1 Page(s) ~:x Shipper's Reference Number NM88210 US {optional) Consignee Corey Grandits ALS 10450 Stancliff Suite 210 HOUSTON 18 Compliant Express CAFE3211 TX77099 US Two completed and signed copies of this Declaration must be handed to the operator WARNING TRANSPORT DETAILS Failure to comply with all respects with the applicable Dangerous Goods Regulations may be in breach of the applicable law ,subject to legal penalties. This shipment is within the limitations prescribed for: Airport of Departure ARTESIA (delete non applicable) ~ 1' FT Airport ofDestination: HOUSTON Shioment tvoe: ABSGRA I (delete 11011 applicable) NON. NATURE AND QUANTITY OF DANGEROUS GOODS UN Number or identification Number, proper shipping riame, Class or Division (subsidiary risk), packing group (if required), and all other required information. UN 3266, Corrosive liquid. basic, inorganic, n.o.s.(Sodium Hydroxide),8,1/1 UN 1268, Petroleum distillates, n.o.s.,3,!11// 0.04 U/366 All Packed In One FIBREBOARD BOX Q = 0.1 0.08 U/854 . -----~--------------------------------------------------------------------------------------------------------------------------Additional Handling Information 24Hour Emergency Respcnse-CHEMTREC 1~800-424-9300, CCN 201319 I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified1 packaged, marked and labelledlplacarded, and are in all respects in proper condition for transport according to applicable !nte-mational and National Governmental Regulations. I declare that all of the applicable alr transport requirements have been met. Name/Title of Signatory Brady Hubbard/Environmenia! Coordinator Place and Date Artesia, NM 02/07/2019 Signature (:res warning above) 18004249300 Emo;gency Telephone Number Brady Hubbard i~~ FOR RADIOACTIVE MATERIAL SHIPMENT ACCEPTABLE FOR PASSENGER AIRCRAFT, THE SHIPMENT CONTAINS RAOlOACTlVE MATERIAL INTENDED FOR. USE !NOR INCIDENT TO RESEARCH, MEDICAL DIAGNOSIS OR TR.EAThllENT. ADR EUROPEAN TRANSPORT STATEMENT: CARRIAGE IN ACCORDANCE WlTH 1.1.4.2.1 LOG05 J/1S7295 11112 Page 30 of33 HFNA-000002968 EPA Inspection Report - Page 1419 of 1969 --------- ·~---··· :::::~R'S DECLARATION FOR DANGEROUS GOODS Air Waybill No. NAVAJO REFINING COMPANY C/0 AQUA MICROBICS 5D1 E MAIN - ARTESIA (Provide at least three copies to airline.) 7093085907 40 Page 1 of 1 Page(s) Shipper's Reference Number NM88210 US (optional} Consignee Corey Grandits ALS 10450 Stancliff Suite 210 HOUSTON ~:X18Compliant Express CAFE3211 TX77099 US Two completed and signed copies of this Declaration must be handed to the operator WARNING TRANSPORT DETAILS Failure to comply with all respects with the applicable Dangerous Goods Regulations may be in breach of the applicable law ,subject to legal penalties. This shipment is within the limitations orescribed for:: Airport of Departure ARTESIA (delete non· applicable} Airport of Destioation: HOUSTON Shiomen! tvoe: ABSGRA (delete non applicable) NATURE AND QUANTITY OF DANGEROUS GOODS UN Number or ;de11tifir:ation Number, proper shipping name, Class or Division (subsidiary risk), packing group (if required}, and ali other required informaUon. UN 3266, Corrosive liquid, basic, inorganic, n.o.s.(Sodium Hydroxide),8,1// 0.04 U/366 All Packed In One FIBREBOARD BOX Q = 0.1 0.08 U/854 UN 1268, Petroleum distillates. n.Q.S.,3,111/1 Additional Handling Information 24-Hour Emergency Response-- CHEMTREC 1-800-424-9300, CCN 201319 I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged, marked and labelled/placarded, and are in all respects in proper condition for transport according to applicable International and National Governmental Regulations. l declare that all of the appHcable air transport requirements have been met. Name/Title of Signatory Brady Hubbard/Environmenta! Coordinator Place and Date Artesia, NM 02/07/2019 Signature 1------------------ ---1 (seewamingabovej 18004249300 Emergency Telephone Numb6r Brady Hubbard ~~ FOR RADIOACTIVE MATERIAi.. SHlPMENT ACCEPTABLE FOR PASSENGERAIRCRA.FT, THE SHIPMENT CONTAINS RAO!OACTIVE MATERIAL INTENDED FOR USE IN OR INC!OENTTO RESEARCH, MEDICAL DIAGNOSIS OR TREATMENT. AOR EUROPEAN TRANSPORT STATEMENT: CARR1AGE IN ACCORDANCE WITH 1.1.4.2.1 tOG0,#15729511/12 Page 31 of33 HFNA-000002969 EPA Inspection Report - Page 1420 of 1969 (Provide at least three copies to airline.) Shipper Air Waybill No. NAVAJO REF!NING COMPANY C/0 AQUA MICROBICS 501 E MAIN ARTESIA 709308590740 Page 1 of 1 Page(s) ~:x NM85210 US Shipper's Reference Number (optional) Consignee . Corey Grandits ALS 10450 Stancliff Express Suite 210 HOUSTON 18 Compliant CAFE3211 TX77099 US Two completed and signed copies of this Declaration mu$t be handed to the operator WARNING I Failure to comply with all respects with the applicable Dangerous Goods Regulations may be in breach of the applicable law ,subject to legal penalties. TRANSPORT DETAILS This shipment ls within the limitations prescribed for: (delete non applicable) Airport of Departure ARTESIA ~ FT y Airport of Destination: HOUSTON . Shioment tvno; ABSGRA (delete non applicable) •n•. NATURE AND QUANTITY OF DANGEROUS GOODS UN Number or identification Numbe,~ proper shipping name, Class or Division (subsidiary risk), packing group (if required), and all other required information. UN 3266, Corrosive liquid, basic, i[lorganic, n.o.s.(Sodium Hydroxide).8,11/ UN 1268, Petroleum distillates, n.o.s .. 3,llli/ 0.04 U/366 All Packed In One FIBREBOARD BOX Q =0.1 0.08 U/854 --------------------------------~-----------------------------------------------------------------------------------------------Additional Handling Information 24-Hour Emergency Response-- CHEMTREC 1--800-424·9300, CCN 201319 I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged, marked and labelled/placarded:, and are in all respects in proper condition tor transport according to applicable International and National Governmental Regulations. I declare that all of the applicable air transport requireffients have been met. Name/Tltle of Signatory Brady Hubbard/Environmental Coordinator Place and Date Artesia. NM 02/07/2019 Signature 18004249300 (soe w:1ming abovo) Emergor1cy Tolophone Numb&r Brady Hubbard ~~ FOR RADIOACTIVE MATERIAL SHIPMENT ACCEPTABLE FOR PASSENGER AIR.CRAFT, THE SHIPMENT CONTAINS RADIOACTIVE MATERIAL INTENDED FOR USE IN OR !NC!OENT TO RESEARCH, MEDICAL DIAGNOSIS OR TREATMENT. AOR EUROPEAN TRANSPORT STATEMENT: CARRIAGE IN ACCORDANCE WITH 1.1.4.2.1 LOGOS #157295 11/i2 Page 32 of33 HFNA-000002970 EPA Inspection Report - Page 1421 of 1969 Use of this system constitutes your agreement to the service conditions in the current Fed Ex Service Guide, available on fedex.com. FedEx will not be responsible for any claim in excess of $100 per package, whether the result of !oss, damage, delav, non-delivery, rnisdelivery, or misinformation, unless you declare a higher vaiue, pay an additional charge, document your actual loss and fne a timely c!aim. Limitations found in the current FedEx Service Guide apply. Your right to recover from FedEx for any loss, induding intrinsic value of the package, loss of sales, income interest. profit, attorney's fees, costs, and other forms of damage whether direct, incidental, consequential, or special ts limited to the greater of $100 or the authorized declared va!ue. Recovery cannot exceed actual documented loss. Maximum for items of extraordinary value is $1,000, e.g. jewelry, precious metals, negotiable instruments and other items listed in our Service Guide. Written claims must be filed within strict time limits, see current FedEx Service Gulde. After printir:g this label. CONSIGNEE COPY· PLEASE Pl.ACE lij FRONT OF POUCH 1, ~o!d lh~ printed page along the noriioma! !ine. 2 Place !abal m shfpplrrg pouch and affix it to your -shipme-nt ~t t r C: )> DJ en G) ~ ::,: ~;;j ....."" 0 U) w co 0 00 ......, = c.o ~ <.n ~ 0 f U) ....... ~ ~ 1 I 0 G) <;J '"ti ;;o ~ 0 "Tl 2!:! ~ 0 -< co "'Tl m to ~ 0 ... ~ z X C: _ "' ....... ....... )>O ::c: ~ -n m m ;;o CD > 5 0 G') ::i:: -I .... 0 i:., !i; Page 33 of33 HFNA-000002971 EPA Inspection Report - Page 1422 of 1969 10450 Stancliff Rd. Suite 210 Houston, TX 77099 T: +1 281 530 5656 F: +1 281 530 5887 March 13, 2019 Gabriela Combs Navajo Refining Company PO Box 1490 Artesia, NM 88211-1490 Work Order: HS19030263 Laboratory Results for: BWON Monthly Sampling (EOL) Dear Gabriela, ALS Environmental received 4 sample(s) on Mar 06, 2019 for the analysis presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Results are expressed as "as received" unless otherwise noted. QC sample results for this data met EPA or laboratory specifications except as noted in the Case Narrative or as noted with qualifiers in the QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained by ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. If you have any questions regarding this report, please feel free to call me. Sincerely, ~:::~:::::::~=·--z,. .· · · · t-{;-;...-,·· Generated By: DAYNA.FISHER Corey Grandits Project Manager Right Solutions · Right Partnu www.a!sg!obaLcom Pagel of25 HFNA-000002972 EPA Inspection Report - Page 1423 of 1969 ALS Houston, US Date: Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS19030263 13-Mar-19 SAMPLE SUMMARY lab Samp ID Client Sample ID Matrix HS 19030263-01 S-1 (API HC) HS 19030263-02 TagNo Collection Date Date Received Liquid 05-Mar-201910:13 06-Mar-2019 12:50 S-3 (API Water) Liquid 05-Mar-2019 10:21 06-Mar-2019 12:50 HS 19030263-03 S-5 (T-40) Liquid 05-Mar-2019 09:39 06-Mar-2019 12:50 HS 19030263-04 S-6 (T-41) Liquid 05-Mar-2019 09:45 06-Mar-2019 12:50 Hold D D D D Page 2 of25 HFNA-000002973 EPA Inspection Report - Page 1424 of 1969 ALS Houston, US Client: Project: Work Order: Dale: Navajo Refining Company 13-Mar-19 CASE NARRATIVE BWON Monthly Sampling (EOL) HS19030263 Work Order Comments • The analysis for Specific Gravity was subcontracted lo ALS Environmental in Holland, Ml. Final report attached. Page 3 of25 HFNA-00000297 4 EPA Inspection Report - Page 1425 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 13-Mar-19 RESULT QUAL SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY Subcontract Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-1 (API HC) 05-Mar-2019 10:13 MDL Work0rder:HS19030263 Lab ID:HS19030263-01 Matrix: Liquid REPORT LIMIT UNITS Method:NA See Attached 0 NA DILUTION FACTOR DATE ANALYZED Analyst: SUBHO 13-Mar-2019 10:14 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 4 of25 HFNA-000002975 EPA Inspection Report - Page 1426 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 13-Mar-19 RESULT QUAL SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY Subcontract Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-3 (API Water) 05-Mar-2019 10:21 MDL Work0rder:HS19030263 Lab ID:HS19030263-02 Matrix: Liquid REPORT LIMIT UNITS Method:NA See Attached 0 NA DILUTION FACTOR DATE ANALYZED Analyst: SUBHO 13-Mar-2019 10:14 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 5 of25 HFNA-000002976 EPA Inspection Report - Page 1427 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 13-Mar-19 RESULT QUAL SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY Subcontract Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-5 (T-40) 05-Mar-2019 09:39 MDL Work0rder:HS19030263 Lab ID:HS19030263-03 Matrix: Liquid REPORT LIMIT UNITS Method:NA See Attached 0 NA DILUTION FACTOR DATE ANALYZED Analyst: SUBHO 13-Mar-2019 10:14 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 6 of25 HFNA-000002977 EPA Inspection Report - Page 1428 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 13-Mar-19 RESULT QUAL SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY Subcontract Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-6 (T-41) 05-Mar-2019 09:45 MDL Work0rder:HS19030263 Lab ID:HS19030263-04 Matrix: Liquid REPORT LIMIT UNITS Method:NA See Attached 0 NA DILUTION FACTOR DATE ANALYZED Analyst: SUBHO 13-Mar-2019 10:14 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 7 of25 HFNA-000002978 EPA Inspection Report - Page 1429 of 1969 ALS Houston, US BWON Monthly Sampling (EOL) R334423 HS19030263-01 DA TES REPORT HS19030263 Client Samp ID Sample ID 13-Mar-19 Navajo Refining Company Client: Project: WorkOrder: Batch ID Date: Collection Date TCLP Date Analysis Date Prep Date Test Name: SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY DF Matrix: Liquid S-1 (API HC) 05 Mar201910:13 13 Mar201910:14 HS19030263-02 S-3 (API Water) 05 Mar 2019 10:21 13 Mar201910:14 HS 19030263-03 S-5 (T-40) 05 Mar 2019 09:39 13 Mar201910:14 HS 19030263-04 S-6 (T-41 ) 05 Mar 2019 09:45 13 Mar201910:14 Page 8 of25 HFNA-000002979 EPA Inspection Report - Page 1430 of 1969 ALS Houston, US Client: Project: WorkOrder: Qualifier Date: Navajo Refining Company BWON Monthly Sampling (EOL) 13-Mar-19 QUALIFIERS, ACRONYMS, UNITS HS19030263 Description Value exceeds Regulatory Limit a Not accredited B Analyte detected in the associated Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time J Analyte detected below quantitation limit M Manually integrated, see raw data for justification n Not offered for accreditation ND Not Detected at the Reporting Limit 0 Sample amount is> 4 times amount spiked p Dual Column results percent difference > 40% R RPO above laboratory control limit s u Spike Recovery outside laboratory control limits Analyzed but not detected above the MDL/SOL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Page 9 of25 HFNA-000002980 EPA Inspection Report - Page 1431 of 1969 ALS Houston, US Date: 13-Mar-19 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date Arkansas 88-0356 27-Mar-2019 Texas T10470231-18-21 30-Apr-2019 North Dakota R193 2018-2019 30-Apr-2019 Illinois 004438 29-Jun-2019 Louisiana 03087 30-Jun-2019 Dept of Defense ANAB L2231 20-Dec-2021 Kentucky 123043 - 2018 30-Apr-2019 Kansas E-10352 2018-2019 31-Jul-2019 Oklahoma 2018-156 31-Aug-2019 North Carolina 624-2019 31-Dec-2019 California 2919, 2018-2019 30-Apr-2019 Maryland 343, 2018-2019 30-Jun-2019 Page 10 of25 HFNA-000002981 EPA Inspection Report - Page 1432 of 1969 ALS Houston, US Date: Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS19030263 13-Mar-19 SAMPLE TRACKING Lab Sarnp ID Client Sample ID Action Date Person New Location HS 19030263-01 S-1 (API HG) Login 3/6/2019 2:52:28 PM JRM Sub HS 19030263-02 S-3 (API Water) Login 3/6/2019 2:52:28 PM JRM Sub HS 19030263-03 S-5 (T-40) Login 3/6/2019 2:52:28 PM JRM Sub HS 19030263-04 S-6 (T-41) Login 3/6/2019 2:52:28 PM JRM Sub Page 11 of25 HFNA-000002982 EPA Inspection Report - Page 1433 of 1969 ALS Houston, US Date: 13-Mar-19 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 06-Mar-2019 12:50 Work Order: HS19030263 Received by: JRM Checklist completed by: Reviewed by: Jared R. Afakan 6-Mar-2019 -e,:-S,-ig_n_a,-tu-re-------...---=--,--Date Corey Grandits Matrices: Carrier name: Shipping container/cooler in good condition? Yes Custody seals intact on shipping container/cooler? Yes Custody seals intact on sample bottles? D D Yes D No Yes No Chain of custody present? Yes No Chain of custody signed when relinquished and received? Yes Samplers name present on COG? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Container/Temp Blank temperature in compliance? Yes VOA/TX1005/TX1006 Solids in hermetically sealed vials? ~ ~ ~ [£] ~ ~ ~ @ ~ @ Temperature(s)/Thermometer(s): 0.4c/0.4c UC/C Cooler( s)/Kit( s): ==oam cooler Date/Time sample(s) sent to storage: 03/06/2019 14:55 D Yes D Yes D Water - VOA vials have zero headspace? Yes Water - pH acceptable upon receipt? pH adjusted? 7-Mar-2019 Date eSignature ALS Courier No No No No No No No No No No D D D D D D D D D D D D D Not Present Not Present Not Present Not Present D ~ ~ @ 1 Page(s) ll1R11 No No No D D D No VOA vials submitted N/A N/A ~ ~ ~ pH adjusted by: Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 12 of25 HFNA-000002983 EPA Inspection Report - Page 1434 of 1969 Chain of Custody Form Page _1_ of ___1__J Cincinnati, OH D +I 513 733 5336 D fiollcmd, Ml +1616399607 0 D Everett, WA +I 425 356 2600 0 +I 2815305656 D Fort Collins, CO +I 970 490 1511 D Enuir anme ntal ···· ·• •·• •. . . >• Cu$tomer lt1formatt6n •• •• .. ·· · . >• >~oifrpa~{~arrie Navajo Refining Company LLC .. . . .. . . . . . . . . Houston, TX Middletown, PA +I 717 944 5541 Salt Lake City, UT D + I 801 266 7700 D Spring City, PA +1610948490 3 D York, PA +J n 7 505 5280 ... Projec(tJl:lnie )i: Specific Gravity BWON Monthly Sampling (EOL) : Bili i:~ ¢:on:i~~ny Holly Frontier Navajo Refining LLC { S~rti:( R~pi>rt T(i Tyler Turner, Gabi Combs P.O. Box 159 · ~· 50~ East Main } ¢1fy1is;tat~IZ!i> Artesia, New Mexico 88210 << >< >:>: . <: Fa~ {575) 746-5451 Navajo Refining Company B1NON Monthly Sampling (EOL) >P.h~n~ (575) 748-3311 1111111111111111111 11111111 II -:-:-: :·:-:-:-·-·-:-~-:-·-.·:··-:-:-:-:- tturner.am@gmail.com :·::::::.: e~M3:1l:)\d<:ires1>: Gabriela.Combs@hollyfrontier.com S-1 (API HC) 03/05/19 10:13AM Liquid 8 1 S-3 (API Water) 03/05/19 10:21AM liquid 8 1 X 03/05/19 9:39AM liquid 8 1 X 03/05/19 9:45AM liquid 8 1 X S-6 (T-41) HS19030263 X Required Turnaround Time: FedEx D SID 10 Wk Days Oother _ _ __ D 2 Wk Days D 24Hour Received by: Level JI: Standard QC Level Ill: Std QC+ Raw Data Level IV: SW846 CLP-Like Other: Note: Any changes must be made in writing once samples and COC Form have been submitted to ALS Laboratory Group. Page 13 of 25 TRRP-Checklist TRRP level IV Copyright 2009 by ALS Laboratory Group !kt HFNA-000002984 EPA Inspection Report - Page 1435 of 1969 SHIPPER'S DECLARATION FOR DANGEROUS GOODS (Provide at least three copies to airline.) Shipper NAVAJO REFINING COMPANY C/0 AQUA MICROBICS 501 E MAIN ARTESIA 709308590751 AirWaybil! No. Page 1 of 1 Page(s) ~: x NM88210 US Shipper's Reference Number (optional) Consignee Corey Grandits ALS 10450 Stancliff Suite 210 HOUSTON 18 Compliant Express CAFE3211 TX 77099 US Two completed and signed copies of this Declaration must be handed to the operator WARNING TRANSPORT DETAILS Failure to comply with all respects with the applicable Dangerous Goods Regulations may be in breach of the applicable law ,subject to legal penalties. This shipment is within the Umitations prescribed for: (delete non appllcable} Airport of Departure ARTESIA ~ y FT Airport of Destination: HOUSTON ffi!•:iivE Sh~ment J NN-RA010 ABSGRA (delete non applicable} NATURE AND QUANTITY OF DANGEROUS GOODS UN Number or ldentificatiOn Number, prdper shipping name, Class or Division {subsidiary risk), packing group (if required), and all other required information. UN 3266, Corrosive liquid, basic, inorganic, n.o.s.(Sodium Hydroxide),8,1// UN 1268, Petroleum distillates, n.o.s.,3,111/i 0.04 U/366 All Packed In One FIBREBOARD BOX Q =0.1 0.08 U/854 . . -------------------~--------------------------------------~-------------------~-------------------------------------------------Additional Handling Information 24~Hour Emergency Response- CHEr..>ITREC 1~80D-424-9300, CCN 201319 I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged, marked and labelled/placarded, and are in all respects in proper condition for transport according to applicable International and National Governmental Regulations.! declare that all of the app!!c:able air transport requirements have been met. I Name/Title of Signatory Brady Hubbard/Enviror:menta! Coordinator Place and Dale Artesia, NM 03!05/2019 Signature 18004249300 Emergency Tefophone Number (soe warning abow1) Brad?J;~ AJJ ,,,_ - 7 vJb {? FOR RADIOACTIVE MATERIAL SHIPMENT ACCEPrABLE FOR PASSENGER AJRCR.AFT, THE SH!PMENTCONTAINS RADIOACTIVE MATERIAL !NTENOED FOR USE IN OR !NC!OENTTO RESEARCH.MEDICAL DIAGNOSIS OR TREATMENT.AOR EUROPEAN TRANSPORTSTATFMENT: CARRIAGE IN ACCORDANCE WITH 1.1.4.2.1 LOGO~ U~',729'> 11/12 Page 14 of 25 HFNA-000002985 EPA Inspection Report - Page 1436 of 1969 Use of this system const\tutes your agreement to the service conditions in the current FedEx Service Guide, availabfe on fedex.Com. FedEx wil! not be responsible for any claim in excess of $100 per package, whether the result of loss, damage, deiay, non-delivery, misdelivery, or ffiisinformatlon, unless you declare a higher value, pay an addltional charge, document your actual !os.s and file a timely claim. Limitations found in the current FedEx Service Guide apply. Your rJght to recover from FedEx for any loss, Including intrinsic value of the package 1 loss of sales, income !nteres.t, profit, attorney's fees, costs, and other forms of damage whether direct, !n~idental, consequential, or special is limited to the greater of $100 or the authorized declared value. Recovery cannot exceed actual documented loss. Maximum for items of extraordina1y value ls $1,000, e.g. jewelry, precious metals, negotiable instruments and other Items listed ln our Service Guide. Written claims must beflled within strict time ltmits, see current FedEx Service Guide. After printing this 'fubs!: CONSIGNEE COPY • PLEASE PLACE IN FRONT OF POUCH 1. P"old the p1inleci page along the horiz.onta! l!ne 2. P!ace label !n shipping pouch and affix ii to your shlpmeni ························--. )> CD f ~ :;::i:i ." l ;;o ~-< -.j 0 (,I) w (/) 0 G) CIO ~ 0 [ ..... ,,: -.j ~ ""' = .... -< 0 -..I 0 O :,,, G) ..:, :r.: ~ 0 Q :::t: C -I )> -< G) ~ z mm ;;o ;;CJ ..... z C C: lJ'IO:ZO mw ~(D "':,, 0 0m 0 :::0 c» S'.O~~ ·~~ ffi:t»>fil ... rom 8£ 0 )>O = ~§ 0 G) :::0 :;E t::O C ?C ::::j ~ t .,, C') fl) m N en """ ~~ = 0 _.. -I = . -Iz 0 ::t>z >< r(") '""' -..I m ()'I 25~~:c -= i (II (,I) = "" ..... = = -- ~ ~~~ ;::~[D ~~~ >,-i "TIO, ~if Jtt11lll)&l>S~11l1 ~~$ :::z 551 C1 /46D3/1C4C Page 15 of 25 HFNA-000002986 EPA Inspection Report - Page 1437 of 1969 13-Mar-2019 Corey Grandits ALS Environmental 10450 Stancliff Rd Suite 210 Houston, TX 77099 Re: Work Order: HS19030263 1903326 Dear Corey, ALS Environmental received 4 samples on 07-Mar-2019 10:00 AM for the analyses presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental - Holland and for only the analyses requested. Sample results are compliant with industry accepted practices and Quality Control results achieved laboratory specifications. Any exceptions are noted in the Case Narrative, or noted with qualifiers in the report or QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained from ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. The total number of pages in this report is 10. If you have any questions regarding this report, please feel free to contact me: ADDRESS: 3352 128th Avenue, Holland, Ml, USA PHONE: +1 (616) 399-6070 FAX: +1 (616) 399-6185 Sincerely, Electronically approved by: Chad Whelton Chad Whelton Project Manager Report of Laboratory Analysis Certificate No: MN 026-999-449 ~·:>.c:Bf}H'J %Ul.t.t'J~t:3P% ::·:·:::::·. :.:: ·:· .,.... Page 16 of25 HFNA-000002987 EPA Inspection Report - Page 1438 of 1969 ALS Group, USA Client: Project: Work Order: Date: 13-Mar-19 ALS Environmental HS 19030263 Work Order Sample Summary 1903326 Lab Samp ID Client Sample ID Matrix Tag Number Collection Date Date Received 1903326-01 1903326-02 1903326-03 1903326-04 Liquid Liquid Liquid Liquid S-1 S-3 S-5 S-6 3/5/2019 3/5/2019 3/5/2019 3/5/2019 3/7/2019 3/7/2019 3/7/2019 3/7/2019 HS19030263-0l HS l 9030263-02 HS19030263-03 HS l 9030263-04 Page 17 of25 (API-HC) (API Water) (T-40) (T-41) 10:13 10:13 10:13 10:13 10:00 10:00 10:00 10:00 Hold D Sample Summary Pagel of l HFNA-000002988 EPA Inspection Report - Page 1439 of 1969 Date: 13-Mar-19 ALS Group, USA Client: Project: WorkOrder: Qualifier ALS Environmental HS19030263 1903326 QUALIFIERS, ACRONYMS, UNITS Description Value exceeds Regulatory Limit ** Estimated Value a Analyte is non-accredited B Analyte detected in the associated Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time Hr BOD/CBOD - Sample was reset outside Hold Time, value should be considered estimated. J ND Analyte is present at an estimated concentration between the MDL and Report Limit Not Detected at the Reporting Limit 0 Sample amount is > 4 times amount spiked p Dual Column results percent difference > 40% R RPD above laboratory control limit s u Analyzed but not detected above the MDL X Acronym Spike Recovery outside laboratory control limits Analyte was detected in the Method Blank between the MDL and Reporting Limit, sample results may exhibit background or reagent contamination at the observed level. Description DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate LOD Limit of Detection (see MDL) LOQ Limit ofQuantitation (see PQL) MBLK MDL MS Method Blank Method Detection Limit Matrix Spike MSD Matrix Spike Duplicate PQL Practical Quantitation Limit RPD Relative Percent Difference TDL Target Detection Limit TNTC Too Numerous To Count A APHA Standard Methods D ASTM E EPA SW Units Reported SW-846 Update III Description none Page 18 of25 QFPage 1 of 1 HFNA-000002989 EPA Inspection Report - Page 1440 of 1969 Date: 13-A1ar-19 ALS Group, USA Client: ALS Enviromnental Project: HS19030263 Sample ID: HS19030263-0l Work Order: 1903326 Lab ID: 1903326-01 Collection Date: 3/5/2019 10:13 AM Matrix: LIQUID Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 1.00 none Dilution Factor Date Analyzed Analyst: RZM 3/12/2019 02:50 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page l of 4 Page 19 of25 HFNA-000002990 EPA Inspection Report - Page 1441 of 1969 Date: 13-A1ar-19 ALS Group, USA Client: ALS Enviromnental Project: HS19030263 Sample ID: HS19030263-02 Work Order: 1903326 Lab ID: 1903326-02 Collection Date: 3/5/2019 10:13 AM Matrix: LIQUID Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 1.01 none Dilution Factor Date Analyzed Analyst: RZM 3/12/2019 02:50 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 2 of 4 Page 20 of25 HFNA-000002991 EPA Inspection Report - Page 1442 of 1969 Date: 13-A1ar-19 ALS Group, USA Client: ALS Enviromnental Project: HS19030263 Sample ID: HS19030263-03 Work Order: 1903326 Lab ID: 1903326-03 Collection Date: 3/5/2019 10:13 AM Matrix: LIQUID Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 1.15 none Dilution Factor Date Analyzed Analyst: RZM 3/12/2019 02:50 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 3 of 4 Page 21 of25 HFNA-000002992 EPA Inspection Report - Page 1443 of 1969 Date: 13-A1ar-19 ALS Group, USA Client: ALS Enviromnental Project: HS19030263 Sample ID: HS19030263-04 Work Order: 1903326 Lab ID: 1903326-04 Collection Date: 3/5/2019 10:13 AM Matrix: LIQUID Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 1.13 none Dilution Factor Date Analyzed Analyst: RZM 3/12/2019 02:50 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 4 of 4 Page 22 of25 HFNA-000002993 EPA Inspection Report - Page 1444 of 1969 Date: 13-Mar-19 ALS Group, USA Client: Work Order: Project: ALS Environmental 1903326 HS19030263 Batch ID: R256327 DUP QC BATCH REPORT Instrument ID WETCHEM D5057-90 Sample ID: 1903326-02A DUP Client ID: HS19030263-02 Analyte Specific Gravity Analysis Date: 3/12/2019 02:50 PM Units: none Run ID: WETCHEM_190312K Result PQL SPK Val 1.011 0 0 The following samples were analyzed in this batch: Note: Method: SPK Ref Value 1903326-01A 1903326-04A %REC 0 0 1903326-02A OF: 1 Prep Date: SeqNo: 5555297 Control Limit 0-0 RPO Ref Value 1.014 %RPO 0.346 RPO Limit Qual 20 1903326-03A See Qualifiers Page for a list of Qualifiers aud their explauation. QC Page: 1 of 1 Page 23 of25 HFNA-000002994 EPA Inspection Report - Page 1445 of 1969 10450 Stancliff Rd, Ste 210 Houston, TX 77099 T: +1 281 530 5656 F: +1 281 530 5887 www.alsglobal.com Subcontract Chain of Custody COC ID: 10878 SUBCONTRACT TO: ALS Group USA, Corp. 3352 - 128th Ave Phone: Holland, MI 494249263 +1 616 399 6070 INVOICE INFORMATION: CUSTOMER INFORMATION: Company: ALS Houston Company: ALS Houston Contact: Corey Grandits Contact:: Accounts Payable Address: 10450 Stancliff Rd, Ste 210 Address: 10450 Stancliff Rd, Ste 210 Phone: +1 281 530 5656 Phone: +1 281 530 5656 Email: Corey.Grandits@alsglobal.com Reference: HS19030263 TSR: Houston House Acct Alternate Contact: Email: Jumoke M. Lawal jumoke.lawal@alsglobal.com CLIENT SAMPLE ID LAB SAMPLE ID ANALYSIS REQUESTED 1. HS19030263-01 MATRIX Liquid S-1 (API HC) HS19030263-02 liquid S-3 {API Water) HS19030263-03 liquid S-5 (T-40) HS19030263-04 05 Mar 2019 10:13 13 Mar 2019 Sub Specific Gravity to ALS Holland 4. 05 Mar 2019 10:13 13 Mar 2019 Sub Specific Gravity to ALS Hofland 3. 05 Mar 2019 10:13 13 Mar 2019 Sub Specific Gravity to ALS Holland 2. COLLECT DATE DUE DATE Liquid S-6 (T-41) 05 Mar 2019 10:13 13 Mar 2019 Sub Specific Gravity to ALS Holland Comments: Please analyze for the analysis listed above. Send report to the emails shown above. QC Level: STD (Laboratory Standard QC: method blank and LCS required) Relinquished By: Date/Time: Received By: Date/Time: Cooler ID(s): Temperature{s): (50 Page 24 of25 HFNA-000002995 EPA Inspection Report - Page 1446 of 1969 ALS Group, USA Sample Receipt Checklist Client Name: ALS - HOUSTON Date/Time Received: Work Order: 1903326 Received by: _LlULK 4 times amount spiked P Dual Column results percent difference > 40% R RPO above laboratory control limit S Spike Recovery outside laboratory control limits U Analyzed but not detected above the MDL/SOL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Unit Reported Description mg/Kg Milligrams per Kilogram mg/L Milligrams per Liter Page 23 of28 HFNA-000003019 EPA Inspection Report - Page 1470 of 1969 ALS Houston, US Date: 14-Mar-19 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date Arkansas 88-0356 27-Mar-2019 Texas T10470231-18-21 30-Apr-2019 North Dakota R193 2018-2019 30-Apr-2019 Illinois 004438 29-Jun-2019 Louisiana 03087 30-Jun-2019 Dept of Defense ANAB L2231 20-Dec-2021 Kentucky 123043 - 2018 30-Apr-2019 Kansas E-10352 2018-2019 31-Jul-2019 Oklahoma 2018-156 31-Aug-2019 North Carolina 624-2019 31-Dec-2019 California 2919, 2018-2019 30-Apr-2019 Maryland 343, 2018-2019 30-Jun-2019 Page 24 of28 HFNA-000003020 EPA Inspection Report - Page 1471 of 1969 ALS Houston, US Date: Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS19030352 14-Mar-19 SAMPLE TRACKING Lab Sarnp ID Client Sample ID Action Date Person New Location HS19030352-01 S-1 (API HG) Login 3/7/2019 6:04:48 PM JRM VOA243 HS19030352-02 S-3 (API Water) Login 3/7/2019 6:04:48 PM JRM VOA243 HS19030352-03 S-5 (T-40) Login 3/7/2019 6:04:48 PM JRM VOA243 HS19030352-04 S-6 (T-41) Login 3/7/2019 6:04:48 PM JRM VOA243 HS19030352-05 Field Blank Login 3/7/2019 6:04:48 PM JRM VOA243 HS19030352-06 EQ Blank Port 1 Login 3/7/2019 6:04:48 PM JRM VOA243 HS19030352-07 EQ Blank Port 2 Login 3/7/2019 6:04:48 PM JRM VOA243 HS19030352-08 Duplicate Login 3/7/2019 6:04:48 PM JRM VOA243 HS19030352-09 Trip Blank Login 3/7/2019 6:04:48 PM JRM VOA243 Page 25 of28 HFNA-000003021 EPA Inspection Report - Page 1472 of 1969 ALS Houston, US Date: 14-Mar-19 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 06-Mar-2019 12:50 Work Order: HS19030352 Received by: JRM Checklist completed by: Matrices: Reviewed by: Jared R. Afakan 7-Mar-2019 -e,:-S,-ig_n_a,-tu-re-------...---=--,--Date Corey Grandits 8-Mar-2019 Date eSignature Water. Product FedEx Priority Overnight Carrier name: ~ No Shipping container/cooler in good condition? Yes Custody seals intact on shipping container/cooler? Yes Custody seals intact on sample bottles? D D Yes D No Yes No Chain of custody present? Yes No Chain of custody signed when relinquished and received? Yes Samplers name present on COG? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Container/Temp Blank temperature in compliance? Yes VOA/TX1005/TX1006 Solids in hermetically sealed vials? ~ ~ [£] ~ ~ ~ @ ~ @ Temperature(s)/Thermometer(s): 0.4c/0.4c UC/C Cooler( s)/Kit( s): ==oam Date/Time sample(s) sent to storage: 03/07/2019 18:20 No No No No No No No No No D D D D D D D D D D D D D Not Present Not Present Not Present Not Present D ~ ~ @ 1 Page(s) COC 1Ds:N/A ll1R11 Water - VOA vials have zero headspace? Yes~ No Water - pH acceptable upon receipt? Yes~ No pH adjusted? Yes D No D D ~ No VOA vials submitted N/A N/A D D D pH adjusted by: Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 26 of28 HFNA-000003022 EPA Inspection Report - Page 1473 of 1969 Chain of Custody Form Page _1_ of _L__ Cincinnati, OH D +15137335336 D Holland, Ml +16163996070 D Salt Lake City, UT +I 801 266 7700 D Everett, WA +I 425 356 2600 El Houston, TX +I 281 530 5656 D Spring City, PA D Fort Collins, CO +19704901511 D Middletown, PA +I 717 944 5541 D York, PA +I 717 505 5280 +I 610 948 4903 Enuiro nment al ···········••••• customer hiformaft()if •·••.. •.... ··· · .·. ·.·.· .-.-.·.· .. ·.·.·.· .. ·.·.·.·. ~oinpar.i{Na~e Navajo Refining Company LLC >: •• $~ii~ R~~ort:f:~ Tyler Turner, Gabi Combs ••• >. HS19030352 P.O. Box 159, Navajo Refining Company :cf :H: ......... BWON Monthly Sampling (EOL) I1111111111111111 H 111111 Pres: : i i3ouies< , :.:9 .•: Trip Blank /10: 03/05/19 10:13AM liquid 8 1 03/05/19 10:21AM Liquid 8, l 1 X 03/05/19 9:39AM Liquid 8 1 X 03/05/19 9:45AM Liquid 8 1 X 03/05/19 10:16AM Liquid 8,1 1 X 03/05/19 10:39AM Liquid B,1 1 X 03/05/19 10:39AM Liquid 8,1 1 X 03/05/19 XXX Liquid 8,1 1 X 03/05/19 XXX Liquid 8,1 2 X Temperature Blank Liquid X l Required Turnaround Time: Received by: 00ther _ _ __ D STD 10 Wk Days FedEx D 2 Wk Days D 24 Hour , - - - - - .. Received by (Laboratory): Level JI: Standard QC Level III: Std QC + Raw Data Level IV: SW846 CLP-Like TRRP-Checklist TRRP Level IV Other: Note: Any changes must be made in writing once samples and COC Form have been submitted to ALS Laboratory Group. Page 27 of28 Copyright 2009 by ALS laboratory Group Cyo,o HFNA-000003023 EPA Inspection Report - Page 1474 of 1969 Use of this system constitutes your agreement to the service conditions in the current FedEx Service Guide, available on fedex.com. FedEx will not be responsible for any claim m excess of $100 per package, whether the result of loss, damage, delay, non--deHvery, misde!ivery, or rTI!sinformation, unless you declare a higher value, pay an additional charge, document your actual loss and file a timely claim. Umitations found in the current FedEx Service Guide app!y. Your right to recover from FedEx for any loss, including intrinsic value of the package, loss of sales, income interest, profit, attorney's fees, costs, and other forms of damage whether direct, incidental, consequential, or special is limited to the greater of $100 or the authorized declared va[ue. Recovery cannot exceed actual documented loss. Maximum for ltems of extraordinary value ts $1,000, e.g. jewelry, precious metals, negotiable instruments and other items listed in our Service Guide. Written claims must be filed within strict time limits, see current Ped Ex Service Guide. After printing this label. CONSIGNEE COPY· PLEASE PLACE IN FRONT OF POUCH 1. Fold the pdnted page along the horizontal line. 2. Place- labe.l in shipping po~ch and affix il io your shipment Page 28 of28 HFNA-000003024 EPA Inspection Report - Page 1475 of 1969 10450 Stancliff Rd. Suite 210 Houston, TX 77099 T: +1 281 530 5656 F: +1 281 530 5887 February 14, 2019 Gabriela Combs Navajo Refining Company PO Box 1490 Artesia, NM 88211-1490 Work Order: HS19020432 Laboratory Results for: BWON Monthly Sampling (EOL) Dear Gabriela, ALS Environmental received 4 sample(s) on Feb 08, 2019 for the analysis presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Results are expressed as "as received" unless otherwise noted. QC sample results for this data met EPA or laboratory specifications except as noted in the Case Narrative or as noted with qualifiers in the QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained by ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. If you have any questions regarding this report, please feel free to call me. Sincerely, ~:::~:::::::~=·--z,. .· · · · t-{;-;...-,·· Generated By: JUMOKE.LAWAL Corey Grandits Project Manager Right Solutions · Right Partnu www.a!sg!obaLcom Pagel of24 HFNA-000003025 EPA Inspection Report - Page 1476 of 1969 ALS Houston, US Date: Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS19020432 14-Feb-19 SAMPLE SUMMARY lab Samp ID Client Sample ID Matrix HS19020432-01 S-1 (API HC) HS19020432-02 TagNo Collection Date Date Received Liquid 07-Feb-2019 09:08 08-Feb-2019 09:00 S-3 (API Water) Liquid 07-Feb-2019 09:25 08-Feb-2019 09:00 HS19020432-03 S-5 (T-40) Liquid 07-Feb-2019 08:46 08-Feb-2019 09:00 HS19020432-04 S-6 (T-41) Liquid 07-Feb-2019 08:51 08-Feb-2019 09:00 Hold D D D D Page 2 of24 HFNA-000003026 EPA Inspection Report - Page 1477 of 1969 ALS Houston, US Client: Project: Work Order: Date: Navajo Refining Company 14-Feb-19 CASE NARRATIVE BWON Monthly Sampling (EOL) HS19020432 Work Order Comments • The analyses for Specific Gravity was subcontracted to ALS Environmental in Holland, Ml. Final report attached. Page 3 of24 HFNA-000003027 EPA Inspection Report - Page 1478 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 14-Feb-19 RESULT QUAL SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY Subcontract Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-1 (API HC) 07-Feb-2019 09:08 MDL Work0rder:HS19020432 Lab ID:HS19020432-01 Matrix: Liquid REPORT LIMIT UNITS Method:NA See Attached 0 NA DILUTION FACTOR DATE ANALYZED Analyst: SUBHO 14-Feb-2019 09:30 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 4 of24 HFNA-000003028 EPA Inspection Report - Page 1479 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 14-Feb-19 RESULT QUAL SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY Subcontract Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-3 (API Water) 07-Feb-2019 09:25 MDL Work0rder:HS19020432 Lab ID:HS19020432-02 Matrix: Liquid REPORT LIMIT UNITS Method:NA See Attached 0 NA DILUTION FACTOR DATE ANALYZED Analyst: SUBHO 14-Feb-2019 09:30 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 5 of24 HFNA-000003029 EPA Inspection Report - Page 1480 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 14-Feb-19 RESULT QUAL SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY Subcontract Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-5 (T-40) 07-Feb-2019 08:46 MDL Work0rder:HS19020432 Lab ID:HS19020432-03 Matrix: Liquid REPORT LIMIT UNITS Method:NA See Attached 0 NA DILUTION FACTOR DATE ANALYZED Analyst: SUBHO 14-Feb-2019 09:30 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 6 of24 HFNA-000003030 EPA Inspection Report - Page 1481 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 14-Feb-19 RESULT QUAL SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY Subcontract Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-6 (T-41) 07-Feb-2019 08:51 MDL Work0rder:HS19020432 Lab ID:HS19020432-04 Matrix: Liquid REPORT LIMIT UNITS Method:NA See Attached 0 NA DILUTION FACTOR DATE ANALYZED Analyst: SUBHO 14-Feb-2019 09:30 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 7 of24 HFNA-000003031 EPA Inspection Report - Page 1482 of 1969 ALS Houston, US BWON Monthly Sampling (EOL) R332838 HS19020432-01 DA TES REPORT HS19020432 Client Samp ID Sample ID 14-Feb-19 Navajo Refining Company Client: Project: WorkOrder: Batch ID Date: Collection Date TCLP Date Test Name: SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY S-1 (API HC) 07 Feb 2019 09:08 Analysis Date Prep Date DF Matrix: Liquid 14 Feb 2019 09:30 HS19020432-02 S-3 (API Water) 07 Feb 2019 09:25 14 Feb 2019 09:30 HS19020432-03 S-5 (T-40) 07 Feb 2019 08:46 14 Feb 2019 09:30 HS19020432-04 S-6 (T-41) 07 Feb 2019 08:51 14 Feb 2019 09:30 Page 8 of24 HFNA-000003032 EPA Inspection Report - Page 1483 of 1969 ALS Houston, US Client: Project: WorkOrder: Qualifier Date: Navajo Refining Company BWON Monthly Sampling (EOL) 14-Feb-19 QUALIFIERS, ACRONYMS, UNITS HS19020432 Description Value exceeds Regulatory Limit a Not accredited B Analyte detected in the associated Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time J Analyte detected below quantitation limit M Manually integrated, see raw data for justification n Not offered for accreditation ND Not Detected at the Reporting Limit 0 Sample amount is> 4 times amount spiked p Dual Column results percent difference > 40% R RPO above laboratory control limit s u Spike Recovery outside laboratory control limits Analyzed but not detected above the MDL/SOL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Page 9 of24 HFNA-000003033 EPA Inspection Report - Page 1484 of 1969 ALS Houston, US Date: 14-Feb-19 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date Arkansas 88-0356 27-Mar-2019 Texas T10470231-18-21 30-Apr-2019 North Dakota R193 2018-2019 30-Apr-2019 Illinois 004438 29-Jun-2019 Louisiana 03087 30-Jun-2019 Dept of Defense ANAB L2231 20-Dec-2021 Kentucky 123043 - 2018 30-Apr-2019 Kansas E-10352 2018-2019 31-Jul-2019 Oklahoma 2018-156 31-Aug-2019 North Carolina 624-2019 31-Dec-2019 California 2919, 2018-2019 30-Apr-2019 Maryland 343, 2018-2019 30-Jun-2019 Page 10 of24 HFNA-000003034 EPA Inspection Report - Page 1485 of 1969 ALS Houston, US Date: Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS19020432 14-Feb-19 SAMPLE TRACKING Lab Sarnp ID Client Sample ID Action Date Person New Location HS19020432-01 S-1 (API HG) Login 2/8/2019 3:03:32 PM PMG Sub HS19020432-02 S-3 (API Water) Login 2/8/2019 3:03:32 PM PMG Sub HS19020432-03 S-5 (T-40) Login 2/8/2019 3:03:32 PM PMG Sub HS19020432-04 S-6 (T-41) Login 2/8/2019 3:03:32 PM PMG Sub Page 11 of24 HFNA-000003035 EPA Inspection Report - Page 1486 of 1969 ALS Houston, US Date: 14-Feb-19 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 08-Feb-2019 09:00 Work Order: HS19020432 Received by: NDR Checklist completed by: Pare sh M. Giga Reviewed by: 8-Feb-2019 Date eSignature Corey Grandits Matrices: Carrier name: Shipping container/cooler in good condition? Yes Custody seals intact on shipping container/cooler? Yes Custody seals intact on sample bottles? D D Yes D No Yes No Chain of custody present? Yes No Chain of custody signed when relinquished and received? Yes Samplers name present on COG? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Container/Temp Blank temperature in compliance? Yes VOA/TX1005/TX1006 Solids in hermetically sealed vials? ~ ~ ~ [£] ~ ~ ~ @ ~ @ Temperature(s)/Thermometer(s): 0.8c/1.1 c U/c Cooler( s)/Kit( s): Hazmatpac Date/Time sample(s) sent to storage: 2/8/19 15:35 D Yes D Yes D Water - VOA vials have zero headspace? Yes Water - pH acceptable upon receipt? pH adjusted? 13-Feb-2019 Date eSignature FedEx No No No No No No No No No No D D D D D D D D D D D D D Not Present Not Present Not Present Not Present D ~ ~ @ 1 Page(s) COC 1Ds:None ll1R25 No No No D D D No VOA vials submitted N/A N/A ~ ~ ~ pH adjusted by: Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 12 of24 HFNA-000003036 EPA Inspection Report - Page 1487 of 1969 HS19020432 Chain of Custody Form A Page _1~ of ~ ALS Project Manager: Erica Padl!.la : : pJ;.c:;~a~e Otd~r BVVON Monthly Samplin g (EOL) III I~ 11111111111111111111 Enu iran men tal UT ·oo Navajo Refining Company 03 IHI HI 80 1111111 <>Pt6Jecf Naiti~ BWON Monthly Samplin g (EOL) . ···-:-· ·--<<<<· >j;j: .... '' ........ ... . : <¢oinpan{Name Navajo Refining Company LLC Elili T:<>Corripaii~ Holly Frontier Navajo Refining LLC : C Tyler Turner Gabi Combs P.O. Box 159 501 East Maln \ \ \¢ityi~ta iel~ip Artesia, NM 88211-0159 : .. ·: <: /cityJS~telZii> Artesia, New Mexico 88210 >:: P66iie (575) 748-3311 <: : < •::: : > J".ait (575) 746-5451 . .. .. . .. . . Na.::::::•:• < :: . . . . . . . . . . . . :fa)! (575) 746-5451 :::•······ e~~allAd~~ss Suzanne.Aguilar@hollyfrontier.com :i >•: sam:i:m{oesiription\ 1.·. :>> · .... >> S-1 (AP! HC) >( r:i-iooe (575) 748-3311 S-3 (API Water) :>3< > S-5 (T-40) 02/07 /19 9:08 AM Liquid 8 02/07/19 9:25AM Liquid 8 X 02/07/19 8:46AM Liquid 8 X 02107/19 8:51 AM Liquid 8 X 1 X : 10:: Oother _ _ __ 02 Wk Days Relinquished by: . ... ., ·. Preservative .Key: .. . . D,i_\e: . · .. •. Time: 7aborato.1/ Received by ( N \0 .. D~t&r > ,... •. ··••• , •• •··· 'rilne: . .... • .• .••. ···· . ChecklidllY(labotatory); . ·. •··•• 6'-Na2s203 .. f- . ITRRP-C hecklist ITRRP Level IV Other: Copyright 2009 by ALS laborator y Group Page 13 of 24 HFNA-000003037 EPA Inspection Report - Page 1488 of 1969 Use ofthls system constitutes your agreement to the service conditions in the current FedEx Service Guide, available on fedex.com. FedEx vA!I not be responsible for any daim in excess of $100 per package, whether the result of loss1 damage, delay, nor-1-de!lvery, misde!ivery, or misinformation, unless you declare a higher value, pay an add!tiona! charge, document your actual loss and file a timely claim, Limitations found in the current FedEx Service Guide apply. Your right to recover from FedEx for any loss, including intrinsic value of the package, loss of sales, income mterest, profit, attorney's fees, costs, and other farms of damage whether direct, incidentaf, cor:isequential, or special is limited to the greater of $100 or the authorized declared value. Recovery cannot exceed actual documented loss. Maximum for items of extraordinary value is $1,000, e.g. jewelry 1 precious meta!s1 negotiable instruments and other items listed in our Service Guide. Written claims must be Wed wlthin strict time limits, see current Fed Ex Service Guide. After printing this !abel CONSIGNEE COPY• PLEASE PLACE lij FRONT OF POUCH 1. Fold !he printl?d page along the horizontal line 2. Place labe: in shipping pouch and affrx lt to your shipment. t l r~ i;i )> d~ OJ c.o ....i 0 U) (.,,) G) 0:, ~ 0 ....i U) .,:,. = 00 ::; "' <.a ~ ~ 0 1 ig_ 0 (i) '? -0 ,, ;:c 5 ;:c "Tl m c:o .~ ~ l 0 01 C: "' z 0.... G'5 ...::. C ;:c -..i _-..i :t::~ 2:! =i 0 -< 00 0 'TI < m m OJ .... X )>O 0 'TI 0 ::i::, 0 Q ::c -I )> Page 14 of 24 HFNA-000003038 EPA Inspection Report - Page 1489 of 1969 14-Feb-2019 Corey Grandits ALS Environmental 10450 Stancliff Rd Suite 210 Houston, TX 77099 Re: Work Order: HS19020432 1902589 Dear Corey, ALS Environmental received 4 samples on 12-Feb-2019 11 :30 AM for the analyses presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental - Holland and for only the analyses requested. Sample results are compliant with industry accepted practices and Quality Control results achieved laboratory specifications. Any exceptions are noted in the Case Narrative, or noted with qualifiers in the report or QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained from ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. The total number of pages in this report is 10. If you have any questions regarding this report, please feel free to contact me: ADDRESS: 3352 128th Avenue, Holland, Ml, USA PHONE: +1 (616) 399-6070 FAX: +1 (616) 399-6185 Sincerely, Electronically approved by: Chad Whelton Chad Whelton Project Manager Report of Laboratory Analysis Certificate No: MN 026-999-449 ~·:>.c:Bf}H'J %Ul.t.t'J~t:3P% ::·:·:::::·. :.:: ·:· .,.... Page 15 of24 HFNA-000003039 EPA Inspection Report - Page 1490 of 1969 ALS Group, USA Client: Project: Work Order: Date: 14-Feb-19 ALS Environmental HS 19020432 Work Order Sample Summary 1902589 Lab Samp ID Client Sample ID Matrix Tag Number Collection Date Date Received 1902589-0 l 1902589-02 1902589-03 1902589-04 Liquid Liquid Liquid Liquid S-1 S-3 S-5 S-6 2/7/2019 09:08 2/7/2019 09:25 2/7/2019 08:46 2/7/2019 08:51 2/12/2019 2/12/2019 2/12/2019 2/12/2019 HS l 9020432-0 l HS l 9020432-02 HS l 9020432-03 HS l 9020432-04 Page 16 of24 (API HC) (API Water) (T-40) (T-41) 11 :30 11:30 11 :30 11:30 Hold D Sample Summary Pagel of l HFNA-000003040 EPA Inspection Report - Page 1491 of 1969 Date: 14-Feb-19 ALS Group, USA Client: Project: WorkOrder: Qualifier ALS Environmental HS19020432 1902589 QUALIFIERS, ACRONYMS, UNITS Description Value exceeds Regulatory Limit ** Estimated Value a Analyte is non-accredited B Analyte detected in the associated Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time Hr BOD/CBOD - Sample was reset outside Hold Time, value should be considered estimated. J ND Analyte is present at an estimated concentration between the MDL and Report Limit Not Detected at the Reporting Limit 0 Sample amount is > 4 times amount spiked p Dual Column results percent difference > 40% R RPD above laboratory control limit s u Analyzed but not detected above the MDL X Acronym Spike Recovery outside laboratory control limits Analyte was detected in the Method Blank between the MDL and Reporting Limit, sample results may exhibit background or reagent contamination at the observed level. Description DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate LOD Limit of Detection (see MDL) LOQ Limit ofQuantitation (see PQL) MBLK MDL MS Method Blank Method Detection Limit Matrix Spike MSD Matrix Spike Duplicate PQL Practical Quantitation Limit RPD Relative Percent Difference TDL Target Detection Limit TNTC Too Numerous To Count A APHA Standard Methods D ASTM E EPA SW Units Reported SW-846 Update III Description none Page 17 of24 QFPage 1 of 1 HFNA-000003041 EPA Inspection Report - Page 1492 of 1969 Date: 14-Feb-19 ALS Group, USA Client: ALS Enviromnental Project: HS19020432 Sample ID: HS19020432-0l Work Order: 1902589 Lab ID: 1902589-01 Collection Date: 2/7/2019 09:08 AM Matrix: LIQUID Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 0.975 none Dilution Factor Date Analyzed Analyst: RZM 2/14/201912:14 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page l of 4 Page 18 of24 HFNA-000003042 EPA Inspection Report - Page 1493 of 1969 Date: 14-Feb-19 ALS Group, USA Client: ALS Enviromnental Project: HS19020432 Sample ID: HS19020432-02 Work Order: 1902589 Lab ID: 1902589-02 Collection Date: 2/7/2019 09:25 AM Matrix: LIQUID Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 1.00 none Dilution Factor Date Analyzed Analyst: RZM 2/14/201912:14 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 2 of 4 Page 19 of24 HFNA-000003043 EPA Inspection Report - Page 1494 of 1969 Date: 14-Feb-19 ALS Group, USA Client: ALS Enviromnental Project: HS19020432 Sample ID: HS19020432-03 Work Order: 1902589 Lab ID: 1902589-03 Collection Date: 2/7/2019 08:46 AM Matrix: LIQUID Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 1.14 none Dilution Factor Date Analyzed Analyst: RZM 2/14/201912:14 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 3 of 4 Page 20 of24 HFNA-000003044 EPA Inspection Report - Page 1495 of 1969 Date: 14-Feb-19 ALS Group, USA Client: ALS Enviromnental Project: HS19020432 Sample ID: HS19020432-04 Work Order: 1902589 Lab ID: 1902589-04 Collection Date: 2/7/2019 08:51 AM Matrix: LIQUID Result Analyses Qual Report Limit D5057-90 SPECIFIC GRAVITY Specific Gravity Note: Units 1.14 none Dilution Factor Date Analyzed Analyst: RZM 2/14/201912:14 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 4 of 4 Page 21 of24 HFNA-000003045 EPA Inspection Report - Page 1496 of 1969 Date: 14-Feb-19 ALS Group, USA Client: Work Order: Project: ALS Environmental 1902589 HS19020432 Batch ID: R254869 DUP QC BATCH REPORT Instrument ID WETCHEM Method: D5057-90 Sample ID: 1902589-02A DUP Client ID: HS19020432-02 Analyte Units: none Run ID: WETCHEM_190214D Result Specific Gravity The following samples were analyzed in this batch: PQL SPK Val 0 0 SeqNo: 5521226 SPK Ref Value 1902589-01 A Analysis Date: 2/14/2019 12:14 PM %REC 0 0 1902589-02A OF: 1 Prep Date: Control Limit 0-0 RPO Ref Value 1.002 %RPO 0.16 RPO Limit Qual 20 1902589-03A 1902589-04A Note: See Qualifiers Page for a list of Qualifiers aud their explauation. QC Page: 1 of 1 Page 22 of24 HFNA-000003046 EPA Inspection Report - Page 1497 of 1969 10450 Stancliff Rd, Ste 210 Houston, TX 77099 T: + 1 281 530 5656 · · F: +1 281 530 5887 www.alsglobal.com Subcontract Chain of Custody COC ID: 10716 SUBCONTRACT TO: ALS Environmental 3352 128th Ave Phone: Holland, MI 49424 INVOICE INFORMATION: CUSTOMER INFORMATION: Company: Contact: +1 616 399 6070 ALS Houston Company: ALS Houston Accounts Payable Corey Grandits Contact: Address: 10450 Stancliff Rd, Ste 210 Address: 10450 Stancliff Rd, Ste 210 Phone: + 1 281 530 5656 Phone: +l 281 530 5656 Email: Corey .Grand its@alsglobal.com Reference: HS19020432 TSR: Houston House Acct Alternate Contact: Email: .· MATRIX> · lASSAMPLEID··· CUENT SAMPLE ID . tfl-Ni\l'(Sl$• ~EQUESTED 1, HS19020432-01 OUEOATE· . >· S-1 (API HC) Liquid HS19020432-02 Liquid S-3 (API Water) Liquid HS19020432-03 HS19020432·04 07 Feb 2019 08:46 15 Feb 2019 Sub Specific Gravity to ALS Holland 4, 07 Feb 2019 09:25 15 Feb 2019 Sub Specific Gravity to ALS Holland 3. 07 Feb 2019 09:08 15 Feb 2019 Sub Specific Gravity to ALS Holland 2. c:pp~Ec:T DATE Liquid S-6 (T-41) 07 Feb 2019 08:51 15 Feb 2019 Sub Specific Gravity to ALS Holland Comments: Please analyze for the analysis listed above. Send report to the emails shown above. SDS Sheets attached QC Level: STD (Laboratory Stan d QC: method blank and LCS required) Relinquished By: Date/Time: Received By: Date/Time: Cooler ID(s): Temperature(s): Page 23 of24 HFNA-00000304 7 EPA Inspection Report - Page 1498 of 1969 ALS Group, USA Sample Receipt Checklist Client Name: ALS - HOUSTON Date/Time Received: Work Order: 1902589 Received by: _LlULK 4 times amount spiked p Dual Column results percent difference > 40% R RPO above laboratory control limit s u Spike Recovery outside laboratory control limits Analyzed but not detected above the MDL/SOL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Page 17 of 43 HFNA-000003066 EPA Inspection Report - Page 1517 of 1969 ALS Houston, US Date: 14-Dec-18 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date North Carolina 624-2018 31-Dec-2018 Arkansas 88-0356 27-Mar-2019 Texas T10470231-18-21 30-Apr-2019 North Dakota R193 2018-2019 30-Apr-2019 Illinois 004438 29-Jun-2019 Louisiana 03087 30-Jun-2019 Dept of Defense ANAB L2231 22-Dec-2018 Kentucky 123043 - 2018 30-Apr-2019 Kansas E-10352 2018-2019 31-Jul-2019 Oklahoma 2018-156 31-Aug-2019 Page 18 of 43 HFNA-000003067 EPA Inspection Report - Page 1518 of 1969 ALS Houston, US Date: Client: Navajo Refining Company Project: BWON Annual Sampling Work Order: HS18120496 14-Dec-18 SAMPLE TRACKING Lab Sarnp ID Client Sample ID Action Date Person New Location HS18120496-01 D-2101 Desalter Water Login 12/10/2018 4:03: 12 PM JRM Sub HS18120496-02 D-2101 Desalter HC Login 12/10/2018 4:03: 12 PM JRM Sub HS18120496-03 D-130 Desalter Water Login 12/10/2018 4:03: 12 PM JRM Sub HS18120496-04 D-130 Desalter HC Login 12/10/2018 4:03: 12 PM JRM Sub HS18120496-05 D-482 Water Login 12/10/2018 4:03: 12 PM JRM Sub HS18120496-06 P-185 Strainer Water Login 12/10/2018 4:03: 12 PM JRM Sub HS18120496-07 T-401 ISOM Login 12/10/2018 4:03: 12 PM JRM Sub HS18120496-09 T-401 Sump Water Login 12/10/2018 4:03: 12 PM JRM Sub HS18120496-11 D-180 Naptha Login 12/10/2018 4:03: 12 PM JRM Sub HS18120496-12 70-C-350 Naptha Login 12/10/2018 4:03: 12 PM JRM Sub Page 19 of 43 HFNA-000003068 EPA Inspection Report - Page 1519 of 1969 ALS Houston, US Date: 14-Dec-18 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 07-Dec-2018 10:00 Work Order: HS18120496 Received by: JRM Checklist completed by: Reviewed by: Jared R. Makan 1O-Dec-2018 -e,:-S,-ig_n_a,-tu-re-------...---,D=-a..,.t_e_ _ Corey Grandits eSignature Matrices: Carrier name: Shipping container/cooler in good condition? Yes Custody seals intact on shipping container/cooler? Yes ~ ALS Courier No D Yes D No Chain of custody present? Yes No Chain of custody signed when relinquished and received? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes TX1005 solids received in hermetically sealed vials? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Container/Temp Blank temperature in compliance? Yes Custody seals intact on sample bottles? Temperature(s)/Thermometer(s): ~ D ~ ~ ~ D ~ ~ ~ No No No No No No No No No D D D D Not Present D Not Present ~ Not Present ~ ~ D D D D N/A ~ D D D 1.3c/1.6c UC/C Cooler( s)/Kit( s): 12-Dec-2018 Date IR25 oam cooler Date/Time sample(s) sent to storage: 12/10/2018 16:00 Water - VOA vials have zero headspace? Yes 4 No Water - pH acceptable upon receipt? Yes D Yes D No pH adjusted? No No VOA vials submitted D D N/A ~ N/A ~ pH adjusted by: Login Notes: f:;oc 2 of 2 not relinquished. Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 20 of 43 HFNA-000003069 EPA Inspection Report - Page 1520 of 1969 Chain of Custody Form A Page _1_ Enuiranmenltal : : custoroor:informatfon <•• .....• : . . .... : w.bri< orci.~r:. . . .. : (;ompariy ~arne Navajo Refining Company LLC . ··········· .... : i-J( 1: : : A. BWON Annual Sampling Everett, WA +I 425 356 2600 D Houston, TX +1281 5305656 D Spring City, PA +16109484903 D Fort Collins, CO +I 970 490 1511 D D York, PA + I 71 7 505 52 80 Middletown, PA + 1 717 944 5541 •. · Specific Gravity •. !;\: .......... . $iii 'ti/¢cimpany Holly Frontier Navajo Refining LLC '.:.................. ........ <; ..... - lti: 501 East Main :: : ::: HS18120496 :F Artesia, New Mexico 88210 > qityJStateil{p > ....... ..... . - Navajo Refining Company :d ' <: f'i!X. BWON Annual Sampling Fax !575) 746-5451 IJ :•••••••• e~MaliAdd$s Suzanne.Aguilar@hollyfrontier.com ..... MatriX · . Pres:<. ,;~;1~/ :: .... l)ate ••••••·· ....... "J"iine • :<:: : • ··•·•· (575) 746-5451 > ••••• >< ~~~~I~ ~~~c;:i~ti~~ •.•.. : Liquid 10:59AM 12/06118 D-2101 DesalterWater 8 Ill IIII II 111111111111111 >I •E I) }= .••. •· G i>H < J1e (575) 748-3311 : ...•••... ••••••• >) >4 Salt Lake City, UT + I 801 266 7700 Susie Aguilar \ : }Clty1$tiai~l2:ip Artesia, NM 88211-0159 . :-1 . >2 D ····.· ••>•>>>> << rt:f:q I D Work Order#: <·~r,oj~ctinformatfon .. • > Cincinnati, OH +1 513 733 5336 :+'--'--'-'+-------------*.-;--'-c-'-'-:+'-~ -'--'-'-,-'--c-'--j---------------l-~1------ ---------------------1 > .. .. __2_ ALS Project Manager: : Projecf~aitie P.uri;tias.e Orde/ / of D T-401 Sump Gasoline Blend D Other _ _ _ __ Required Turnaround Time: ! D STD 10 Wk Days __ .,., · ed by: Reei».in .,,_..l Relinquished by: --- Logged by (Laboratory): Date: ,_ / • / {')--/ 7 //x Date: ' Time: Received by: Time: Received by (Laboratory): /(); D 2 Wk Days s Wk Days D 24 Hour Notes: ·. G)C) P:ackage: (CJ1ee:k E!o~:13~101119:/>:: . Cooler Temp. 1--......;.,;.;....;...;...;.......;......;...,...;.;,,..;.;.......;......;...,.....;,...;..;.,_........;..........;..;.....,.-« ITRRP-Checklist Level I!: Standard QC u;t.C... ·::::r .· rvv,::, .,,./, ";,., c·n Cheeked by {laboratory): Time: 0 ...!_ . Level Ill: Std QC + Raw Data Level IV: SW846 CLP-Like ITRRP Level IV .....s"'"c~~9..00-35....._ __._ _ _ _ _ _ _ _ _ _ _ __ ree ..... ...a"'"H~s"'"o"'"4~-1"'"-0t-h_e....r.........8-.4....d...eg _N'!"a""o""H-...S..,...,,.N-a2"'"s"'"2""0~3-..,.6...,N a.""'H""2""s""o""4........,.4... ............. 1-p-re""s_e_rv_a""t1-..,-1:1."'"K""e'"'y:-'"'t-"'H""c""t-·-2--~H""'N"'o'""s : .... ·. .· Note: Any changes must be made in writing once samples and COC Form have been submitted to ALS laboratory Group. Other: Copyright 2009 by ALS Laboratory Group Page 21 of 43 HFNA-000003070 EPA Inspection Report - Page 1521 of 1969 Chain of Custody Form A Page _2_ of _2_ Cincinnati, OH D +1 513 733 5336 D Holland, Ml +16163996070 D Salt Lake City, UT +1 801 266 7700 D Everett, WA +I 425 356 2600 D Houston, TX +I 2815305656 D Spring City, PA +I 610 948 4903 D Fort Collins, CO +1970490 1511 D Middletown, PA +I 717944 5541 D York, PA +I 717 505 5280 Enuiro nment al <: ........... •••Piir~~se otd~r .... • • ••> P:roje~i~afu.6 BWON Annual Sampling ' · · · · ·•·•· ···w~riio,ii•i< Coinparif ~arne Navajo Refining Company LLC ....... 1: •: /: E!ill A: Specific Gravity T~ (:{)~p~llY Holly Frontier Navajo Refining LLC • P.O. Box 159 C: Navajo Refining Company ))t:ifyl$tat~iZip Artesia, New Mexico 88210 ·.· ·.· . . . . ·.· . . . . . . •••• >> .·. P~o.ne (575) 748-3311 . ·. . . . . . . . . Pfioiie iH: >fax (575) 746-5451 •........ :<: ::•:•:::: :::::::::::··-: · ···j·:··::-: ··-:-.-·-:: Gabriela.Combs@hollyfrontier.com •:••• :•• :::ecM~li Address: Suzanne.Aouilar@hollyfront[ercom )( D-180 Naptha I: :~ •• 70-C-350 Naptha .~ BWON Annual Sampling (575) 143.3311 . ···<·:·: :-:·:· >:<•:::::::F~if (575) 746-5451 . · .: : e:,IVl~.1.J\ddress: !turner am@gmail.com - HS18120496 • 501 East Main - II I III I II 111111111111111 12/06118 11:30 AM Liquid 8 X 12/06118 8:50AM Liquid 8 X .... A•:• ·. ·. .· .. !Shipment Method: Required Turnaround Time: ! D STD 10 Wk Days FedEX Relinquished by: Date: Time: Received by: Relinquished by: Date: Time: Received by (Laboratory): Time: Check~d by (Laboratory): Logged by {Laboratory): ·· .. 3,,H2S04 5-Na2S203 . 5 Wk Days D0ther ____ D 2 Wk Days D 24Hour .·.·. ·.· . ·.· . Notes: CoolerTel'!Jp. {;IC .· .. . 6~aHS04 7-0ther .·· PreservativeKe y: •.•• 1-HCL ·. 2~HN03 0 Level ll: Standard QC ITRRP-Checklist Level Ill: Std QC + Raw Data ITRRP Level IV ......-+L""e-v-e""'!""IV,.,...:""s.,.w'"'s""4""6""C""'""L""P--L""i~k-e-+-..... ------1 ' Mdegrees C Note: Any changes must be made in writing once samples and COC Form have been submitted to ALS Laboratory Group. Pac~ge: (~he()k B~:x:!3~loif4.•••• 9-5035 Other: Copyright 2009 by ALS Laboratory Group Page 22 of 43 HFNA-000003071 EPA Inspection Report - Page 1522 of 1969 SHIPPER'S DECLARATION FOR DANGEROUS GOODS (Provide at least three copies to airline.) Shipper Air Waybm No. NAVAJO REFINING COMPANY C/0 AQUA MICROBICS 501 E MAIN ARTESIA 709308590718 Page 1 of 1 Page{s) ~:x Shipper's Reference Number NM88210 US (optional} Consignee Corey Grandits ALS 10450 Stancliff Suite 210 HOUSTON 18 Compliant Express CAFE3211 TX77099 US Two compfeted and signed copies of this Declaration must be handed to the operator WARNING TRANSPORT DETAILS Failure to comply with all respects with the applicable Dangerous Goods Regulations may be in breach of the applicable law ,subject to legal penalties. This shipment is within the limltatlons prescribed for: Airport of Departure ARTESIA {delete non applicable} ~ FT y Airport of Destination: HOUSTON Shioment tvce: ABSGRA (delete non anulidb41) NATURE AND QUANTITY OF DANGEROUS GOODS UN Number or ide11tification Number, proper shipping name1 Class or DiVision (subsidiary rfskj, packing group (if required}, and all other required information. UN 1267, Petroleum crude oil,3,1/1 80 ml//361 UN 1268, Petroleum distillates, n.o.s.,3,111/1 160 mil/366 UN 3082, Environmentally hazardous substance, liquid, n.o.s.(AMMONIA, ANHYDROUS, HYDROGEN SULFIDE),9,lllil 160 mll/964 All Packed in One FIBREBOARD BOX a ~0.1 . --------------------------------------------------------------------------------------------------------------------------------Additional Handling Information 24 Hour Emergency Response-- CHEt\t'ITREC 1800-424-9300 CCN 201319 I hereby declare that the contents of this consignment are fully and Name/Title of Signatory accurately described above by the proper shipping name, and are classified, packaged, marked and labelled/placarded, and are ln all Brady Hubbard/Envircnmenta! Coordinator respects in proper condition for transport according to applicable International and National Governmental Regulations. I declare that all of the applicable air transport requirements have been met. Place and Date Artesia NM i2,'(}6/2018 Signature (sae warning above; 18224249300 Emergency Telephone Num~r Br~~~~ FOR RADIOACTIVE MATER!AL SHIPMENT ACCEPTABLE FOR PASSENGER AIRCRAFT, THE SHIPMENT CONTAINS RADIOACTIVE MATERIAL INTENOEO FOR. USE IN OR INC!DENTTO Rl::SEARCH, MEDICAL DIAGNOSIS OR TREATMENT. ADR EUROPEAN TRANSPORT STATEMENT: CARRIAGE IN ACCORDANCE WITH 1.1.4.2.1 - LOGOS ~1b729511/12 Page 23 of 43 HFNA-000003072 EPA Inspection Report - Page 1523 of 1969 Use of this system constitutes your agreement to the service conditions ln the current FedEx Service Guide, available on fedex.com. FedEx will not be responsible for any claim in excess of $100 per package, whether the result of loss, damage, delay, non·delivery, misdeHvery, or mis.information, unless you declare a higher value, pay an additional charge, document your actual loss and file a timely daim. limitations found in the current FedEx Service Guide apply. Your right to recover from FedEx for any loss, including intrinsic"Va!ue of the package, loss of sales, income interest, profit, attorney's fees, costs, an'd other forms of damage whether direct1 incidental, consequential, or special is limited to the greater of $100 or the authorized declared value. Recovery cannot exceed actual documented loss. Maximum for items of extraordinary value is $1,000, e.g. jewelry, prec!ous metals, negotiable instruments and other items listed in our Service Guide. Written dalms must be filed within strict time limits, see current FedEx Service Guide. After printing this !abel: CONSIGNEE COPY· PLEASE PLACE IN FRONT OF POUCH 1. Fold the printed paga along the horizontal Hna. 2. Place label in shipping pouch and affix it to your shiprnenl -:::: -= "' )> i"" t::J:;J: :,: ,t ' ..... 0 DJ c,p u, w 0 C) 00 ~ ..... (J'I I; g, ->, "' 00 c:::> -~ •"'-,) = = ;:! 0 <'::: _ "' ..... ...... )>O :c~ ;):, 0 0 ""'"' 0 :z -.i 0 ,,:;;' U) ~ .,, ~CD '"'z ~;:: U)O Cl =i w 00 = U,Q "0- ~ i' en r I I '*! F ;;o m Q ~ ~ ""'"' )> m mro -< "'"" G) c:~ ~ :z ("") 0 ::i:: 0 =J-l ~ -I 0 0 < m m 0 ;:o .... z 0 i5 w -I z >< -.i 0 §',;~ )> ("") t9fJ3 ro en ;:o wl' -, "' "Tl m 0 ~~ ·o 0 5 (/) -I 0 ~ - I [ :;o ~Cl> "'-I ~ = j '"O t;; .... 2- ..... 0 :ag s """' """' ~ CD 0 f!J I"'-') fr -; -ozf-3 Ps~:C Cl) "'"'"' )>0:C ~~~ -.i-l~ ~~ri:i ~6g ooo ~rm mwo Ki~i» lffil1i JH1111~UUiw ::!Z 551C11FlFEl104C Page 24 of 43 HFNA-000003073 EPA Inspection Report - Page 1524 of 1969 14-Dec-2018 Corey Grandits ALS Environmental 10450 Stancliff Rd Suite 210 Houston, TX 77099 Re: Work Order: HS18120496 1812650 Dear Corey, ALS Environmental received 12 samples on 11-Dec-2018 10:00 AM for the analyses presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental - Holland and for only the analyses requested. Sample results are compliant with industry accepted practices and Quality Control results achieved laboratory specifications. Any exceptions are noted in the Case Narrative, or noted with qualifiers in the report or QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained from ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. The total number of pages in this report is 19. If you have any questions regarding this report, please feel free to contact me: ADDRESS: 3352 128th Avenue, Holland, Ml, USA PHONE: +1 (616) 399-6070 FAX: +1 (616) 399-6185 Sincerely, Electronically approved by: Chad Whelton Chad Whelton Project Manager Report of Laboratory Analysis Certificate No: MN 998501 ~·:>.c:Bf}H'J %Ul.t.t'J~t:3P% ::·:·:::::·. :.:: ·:· .,.... Page 25 of 43 HFNA-00000307 4 EPA Inspection Report - Page 1525 of 1969 ALS Group, USA Client: Project: Work Order: Date: 14-Dec-18 ALS Environmental HS18120496 1812650 Work Order Sample Summary Lab Samp ID Client Sample ID Matrix Tag Number Collection Date Date Received 1812650-01 HS18120496-0l Liquid 12/6/2018 10:59 12/11/2018 10:00 1812650-02 1812650-03 HS18120496-02 HS18120496-03 Liquid Liquid 12/6/2018 10:42 12/6/2018 09: 15 12/11/2018 10:00 C 12/11/2018 10:00 C 1812650-04 1812650-05 1812650-06 HS18120496-04 HS18120496-05 HS18120496-06 Liquid Liquid Liquid 12/6/2018 08:54 12/6/2018 09:29 12/6/2018 10:04 12/11/2018 10:00 12/11/2018 10:00 C 12/11/2018 10:00 C 1812650-07 1812650-08 1812650-09 ]8]2650-10 HS18120496-07 HS18120496-08 HS18120496-09 HS 18120496-10 Liquid Liquid Liquid Liquid 12/5/2018 12/5/2018 12/5/2018 12/5/20]8 12/11/2018 12/11/2018 12/11/2018 ]2/11/2018 1812650-11 1812650-12 HS18120496-ll HS18120496-12 Liquid Liquid D-210 l Desalter Water D-2101 DesalterHC D-130 Desalter Water D-130 Desalter HC D-482 Water P-185 Strainer Water T-401 ISOM T-401 Water T-401 Sump Water T-401 Sump Gasoline Blend D-180 Naptha 70-C-350 Naptha Page 26 of 43 15:09 15:04 ]5:]5 15:15 12/6/2018 11 :30 12/6/2018 08:50 Hold 10:00 10:00 C 10:00 C 10:00 C 12/11/2018 10:00 C 12/11/2018 10:00 C Sample Summary Pagel of l HFNA-000003075 EPA Inspection Report - Page 1526 of 1969 Date: 14-Dec-18 ALS Group, USA Client: Project: WorkOrder: Qualifier ALS Environmental HS18120496 1812650 QUALIFIERS, ACRONYl\1S, UNITS Description Value exceeds Regulatory Limit ** Estimated Value a Analyte is non-accredited B Analyle detected in the associakd Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time Hr BOD/CBOD - Sample was reset outside Hold Time, value should be considered estimated. J ND Anal)1e is present al an estimated concentration between the MDL and Report Limit Not Detected at the Reporting Limit 0 Sample amount is > 4 times amount spiked p Dual Column results percent difference > 40% R RPD above laboratory control limit s u Analyzed but not detected above the MDL X Acronym Spike Recovery outside laboratory control limits Analyte was detected in the Method Blank between the MDL and Reporting Limit, sample results may exhibit background or reagent contamination at the observed level. Description DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate LOD Limit of Detection (see MDL) LOQ Limit ofQuantitation (see PQL) MBLK MDL MS Method Blank Method Detection Limit Matrix Spike MSD Matrix Spike Duplicate PQL Practical Quantitation Limit RPD Relative Percent Difference TDL Target Detection Limit TNTC Too Numerous To Count A APHA Standard Methods D ASTM E EPA SW Units Reported SW-846 Update III Description none Page 27 of 43 QFPage 1 o/1 HFNA-000003076 EPA Inspection Report - Page 1527 of 1969 Date: 14-Dec-l 8 ALS Group, USA Client: ALS Enviromnental Project: HS18120496 Sample ID: HS18120496-0l Work Order: 1812650 Lab ID: 1812650-01 Collection Date: 12/6/2018 10:59 AM Matrix: LIQUID Result Analyses Qual Note: Units 0.999 Dilution Factor Date Analyzed Analyst: JSH D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit none 12/13/2018 03: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 1 of 12 Page 28 of 43 HFNA-000003077 EPA Inspection Report - Page 1528 of 1969 Date: 14-Dec-l 8 ALS Group, USA Client: ALS Enviromnental Project: HS18120496 Sample ID: HS18120496-02 Work Order: 1812650 Lab ID: 1812650-02 Matrix: LIQUID Collection Date: 12/6/2018 10:42 AM Result Analyses Qual Note: Units 0.770 Dilution Factor Date Analyzed Analyst: JSH D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit none 12/13/2018 03: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 2 of 12 Page 29 of 43 HFNA-000003078 EPA Inspection Report - Page 1529 of 1969 Date: 14-Dec-l 8 ALS Group, USA Client: ALS Enviromnental Project: HS18120496 Sample ID: HS18120496-03 Work Order: 1812650 Lab ID: 1812650-03 Collection Date: 12/6/2018 09:15 AM Matrix: LIQUID Result Analyses Qual Note: Units 1.00 Dilution Factor Date Analyzed Analyst: JSH D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit none 12/13/2018 03: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 3 of 12 Page 30 of 43 HFNA-000003079 EPA Inspection Report - Page 1530 of 1969 Date: 14-Dec-l 8 ALS Group, USA Client: ALS Enviromnental Project: HS18120496 Sample ID: HS18120496-04 Work Order: 1812650 Lab ID: 1812650-04 Collection Date: 12/6/2018 08:54 AM Matrix: LIQUID Result Analyses Qual Note: Units 0.789 Dilution Factor Date Analyzed Analyst: JSH D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit none 12/13/2018 03: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 4 of 12 Page 31 of 43 HFNA-000003080 EPA Inspection Report - Page 1531 of 1969 Date: 14-Dec-l 8 ALS Group, USA Client: ALS Enviromnental Project: HS18120496 Sample ID: HS18120496-05 Work Order: 1812650 Lab ID: 1812650-05 Collection Date: 12/6/2018 09:29 AM Matrix: LIQUID Result Analyses Qual Note: Units 0.995 Dilution Factor Date Analyzed Analyst: JSH D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit none 12/13/2018 03: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 5 of 12 Page 32 of 43 HFNA-000003081 EPA Inspection Report - Page 1532 of 1969 Date: 14-Dec-l 8 ALS Group, USA Client: ALS Enviromnental Project: HS18120496 Sample ID: HS18120496-06 Work Order: 1812650 Lab ID: 1812650-06 Collection Date: 12/6/2018 10:04 AM Matrix: LIQUID Result Analyses Qual Note: Units 1.00 Dilution Factor Date Analyzed Analyst: JSH D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit none 12/13/2018 03: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 6 of 12 Page 33 of 43 HFNA-000003082 EPA Inspection Report - Page 1533 of 1969 Date: 14-Dec-l 8 ALS Group, USA Client: ALS Enviromnental Project: HS18120496 Sample ID: HS18120496-07 Work Order: 1812650 Lab ID: 1812650-07 Collection Date: 12/5/2018 03 :09 PM Matrix: LIQUID Result Analyses Qual Note: Units 0.658 Dilution Factor Date Analyzed Analyst: JSH D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit none 12/13/2018 03: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 7 of 12 Page 34 of 43 HFNA-000003083 EPA Inspection Report - Page 1534 of 1969 Date: 14-Dec-l 8 ALS Group, USA Client: ALS Enviromnental Project: HS18120496 Sample ID: HS18120496-08 Work Order: 1812650 Lab ID: 1812650-08 Collection Date: 12/5/2018 03 :04 PM Matrix: LIQUID Result Analyses Qual Note: Units 0.671 Dilution Factor Date Analyzed Analyst: JSH D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit none 12/13/2018 03: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 8 of 12 Page 35 of 43 HFNA-000003084 EPA Inspection Report - Page 1535 of 1969 Date: 14-Dec-l 8 ALS Group, USA Client: ALS Enviromnental Project: HS18120496 Sample ID: HS18120496-09 Work Order: 1812650 Lab ID: 1812650-09 Collection Date: 12/5/2018 03:15 PM Matrix: LIQUID Result Analyses Qual Note: Units 0.716 Dilution Factor Date Analyzed Analyst: JSH D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit none 12/13/2018 03: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 9 of 12 Page 36 of 43 HFNA-000003085 EPA Inspection Report - Page 1536 of 1969 Date: 14-Dec-l 8 ALS Group, USA Client: ALS Enviromnental Project: HS18120496 Sample ID: HS18120496-10 Work Order: 1812650 Lab ID: 1812650-10 Collection Date: 12/5/2018 03:15 PM Matrix: LIQUID Result Analyses Qual Note: Units 0.726 Dilution Factor Date Analyzed Analyst: JSH D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit none 12/13/2018 03: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 10 of 12 Page 37 of 43 HFNA-000003086 EPA Inspection Report - Page 1537 of 1969 Date: 14-Dec-l 8 ALS Group, USA Client: ALS Enviromnental Project: HS18120496 Sample ID: HS18120496-ll Work Order: 1812650 Lab ID: 1812650-11 Matrix: LIQUID Collection Date: 12/6/2018 11:30 AM Result Analyses Qual Note: Units 0.700 Dilution Factor Date Analyzed Analyst: JSH D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit none 12/13/2018 03: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 11 of 12 Page 38 of 43 HFNA-000003087 EPA Inspection Report - Page 1538 of 1969 Date: 14-Dec-l 8 ALS Group, USA Client: ALS Enviromnental Project: HS18120496 Sample ID: HS18120496-12 Work Order: 1812650 Lab ID: 1812650-12 Collection Date: 12/6/2018 08:50 AM Matrix: LIQUID Result Analyses Qual Note: Units 0.777 Dilution Factor Date Analyzed Analyst: JSH D5057-90 SPECIFIC GRAVITY Specific Gravity Report Limit none 12/13/2018 03: 15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 12 of 12 Page 39 of 43 HFNA-000003088 EPA Inspection Report - Page 1539 of 1969 Date: 14-Dec-18 ALS Group, USA Client: Work Order: Project: ALS Environmental 1812650 HS18120496 Batch ID: R251336 DUP QC BATCH REPORT Instrument ID WETCHEM Method: D5057-90 Sample ID: 1812650-0SA DUP Client ID: HS18120496-05 Analyte Specific Gravity Units: none Run ID: WETCHEM_181213M Result PQL SPK Val 1.005 0 0 Analysis Date: 12/13/2018 03:15 PM SeqNo: 5436592 SPK Ref Value %REC 0 0 OF: 1 Prep Date: Control Limit 0-0 RPO Ref Value 0.9947 %RPO 1.03 RPO Limit Qual 20 ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------1 Sample ID: 1812650-09A DUP DUP Client ID: HS18120496-09 Units: none Run ID: WETCHEM_181213M Analyte Result PQL SPK Val Specific Gravity 0.7188 0 0 The following samples were analyzed in this batch: Note: SPK Ref Value 1812650-01A 1812650-04A 1812650-07A 1812650-1 OA Analysis Date: 12/13/2018 03:15 PM %REC 0 0 1812650-02A 1812650-05A 1812650-08A 1812650-11 A OF: 1 Prep Date: SeqNo: 5436597 Control Limit 0-0 RPO Ref Value 0.7157 %RPO 0.431 RPO Limit Qual 20 1812650-03A 1812650-06A 1812650-09A 1812650-12A See Qualifiers Page for a list of Qualifiers and their explanation. QC Page: 1 of 1 Page 40 of 43 HFNA-000003089 EPA Inspection Report - Page 1540 of 1969 10450 Standlff Rd, Ste 210 Houston, TX 77099 T: +1 281 530 5656 A ' s +1 281 530 5887 _ F: www.alsglobal.com Subcontract Chain of Custody COC ID: 10407 SUBCONTRACT TO: ALS laboratory Group 3352 128th Ave. Phone: Holland, MI 494249263 +1 616 399 6070 INVOICE INFORMATION: CUSTOMER INFORMATION: Company: ALS Houston Company: ALS Houston Contact: Corey Grandits Contact: Accounts Payable Address: 10450 Stancliff Rd, Ste 210 Address: 10450 Standiff Rd, Ste 210 Phone: + 1 281 530 5656 Phone: +1 281 530 5656 Email: Corey. Grandlts@alsglobal.com Reference: HS18120496 TSR: Houston House Acct Alternate Contact: Email: 1. Jumoke M. Lawal jumoke.lawal@alsglobal.com HS18120496-01 D-2101 Desalter Water Liquid 14 Dec 2018 Sub to ALS Holland 2. HS181l0496--02 D-2101 Desalter HC Uquld HS18120496-03 D-130 Desalter Water Uquld HS18120496-04 D-130 Desalter HC Liquid HS181l0496-05 Uquld D-482 Water HS:1.8120496•06 P-185 Strainer Water Liquid HS18120496-07 Uquld T-401 ISOM HS18120496-08 Liquid T-401 Water HS181l0496--09 OS Dec 2018 15:04 14 Dec 2018 Sub to ALS Holland !!ill. 05 Dec 2018 15:09 14 Dec 2018 Sub to ALS Holland 8. 06 Dec 2018 10:04 14 Dec 2018 Sub to ALS Holland 7. 06 Dec 2018 09:29 14 Dec 2018 Sub to ALS Holland 6. 06 Dec 2018 08:54 14 Dec 2018 Sub to ALS Holland 5. 06 Dec 2018 09: 15 14 Dec 2018 Sub to ALS Holland 4. 06 Dec 2018 10:42 14 Dec 2018 Sub to ALS Holland 3. 06 Dec 2018 10:59 T-401 Sump Water Uquld 05 Dec 2018 15:15 Page 41 of 43 HFNA-000003090 EPA Inspection Report - Page 1541 of 1969 Subcontract Chain of Custody COC ID: 14 Dec 2018 Sub to ALS Holland 10. HS18120496-10 Uquld T-401 Sump Gasoline Blend HS18120496·11 Uquld D-180 Naptha HS18120496-12 06 Dec 2018 11:30 14 Dec 2018 Sub to ALS Holland 12. 05 Dec 2018 15:15 14 Dec 2018 Sub to ALS Holland 11. 10407 Uquld 70-C:·350 Naptha 06 Dec 2018 08:50 14 Dec 2018 Sub to ALS Holland Comments: Please analyze for the analysis Hsted above. Send report to the emails shown above. QC Level: STD (Laboratory Standard QC: method blank and LCS required) Rellnqulshed By: Date/Time: Re<:eived By: Date{Time: Cooler ID(s): Temperature( s) : l D ,ooo Page 42 of 43 HFNA-000003091 EPA Inspection Report - Page 1542 of 1969 ALS Group, USA Sample Receipt Checklist Client Name: ALS - HOUSTON Date/Time Received: Work Order: 1812650 Received by: Checklist completed by _LlULK 4 times amount spiked P Dual Column results percent difference > 40% R RPO above laboratory control limit S Spike Recovery outside laboratory control limits U Analyzed but not detected above the MDL/SOL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Unit Reported Description mg/Kg Milligrams per Kilogram mg/L Milligrams per Liter Page 36 of 42 HFNA-000003128 EPA Inspection Report - Page 1579 of 1969 ALS Houston, US Date: 20-Dec-18 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date North Carolina 624-2018 31-Dec-2018 Arkansas 88-0356 27-Mar-2019 Texas T10470231-18-21 30-Apr-2019 North Dakota R193 2018-2019 30-Apr-2019 Illinois 004438 29-Jun-2019 Louisiana 03087 30-Jun-2019 Dept of Defense ANAB L2231 22-Dec-2018 Kentucky 123043 - 2018 30-Apr-2019 Kansas E-10352 2018-2019 31-Jul-2019 Oklahoma 2018-156 31-Aug-2019 Page 37 of 42 HFNA-000003129 EPA Inspection Report - Page 1580 of 1969 ALS Houston, US Date: Client: Navajo Refining Company Project: BWON Annual Sampling Work Order: HS18120510 20-Dec-18 SAMPLE TRACKING Lab Sarnp ID Client Sample ID Action Date Person New Location HS18120510-01 D-2101 Desalter Water Login 12/10/2018 5:58:35 PM JRM Sub HS18120510-02 D-2101 Desalter HC Login 12/10/2018 5:58:35 PM JRM Sub HS18120510-03 D-130 Desalter Water Login 12/10/2018 5:58:35 PM JRM Sub HS18120510-04 D-130 Desalter HC Login 12/10/2018 5:58:35 PM JRM Sub HS18120510-05 D-482 Water Login 12/10/2018 5:58:35 PM JRM Sub HS18120510-06 P-185 Strainer Water Login 12/10/2018 5:58:35 PM JRM Sub HS18120510-07 T-401 ISOM Login 12/10/2018 5:58:35 PM JRM Sub HS18120510-08 T-401 Water Login 12/10/2018 5:58:35 PM JRM Sub HS18120510-09 T-401 Sump Water Login 12/10/2018 5:58:35 PM JRM Sub HS18120510-10 T-401 Sump Gasoline Blend Login 12/10/2018 5:58:35 PM JRM Sub HS18120510-11 D-180 Naptha Login 12/10/2018 5:58:35 PM JRM Sub HS18120510-12 70-C-350 Naptha Login 12/10/2018 5:58:35 PM JRM Sub Page 38 of 42 HFNA-000003130 EPA Inspection Report - Page 1581 of 1969 ALS Houston, US Date: 20-Dec-18 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 07-Dec-2018 10:00 Work Order: HS18120510 Received by: JRM Checklist completed by: Reviewed by: Jared R. Makan 1O-Dec-2018 -e,:-S,-ig_n_a,-tu-re-------...---,D=-a..,.t_e_ _ Corey Grandits eSignature Matrices: Carrier name: Shipping container/cooler in good condition? Yes Custody seals intact on shipping container/cooler? Yes ~ ALS Courier No D Yes D No Chain of custody present? Yes No Chain of custody signed when relinquished and received? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes TX1005 solids received in hermetically sealed vials? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Container/Temp Blank temperature in compliance? Yes Custody seals intact on sample bottles? Temperature(s)/Thermometer(s): ~ D ~ ~ ~ D ~ ~ ~ No No No No No No No No No D D D D Not Present D Not Present ~ Not Present ~ ~ D D D D N/A ~ D D D 1.3c/1.6c UC/C Cooler( s)/Kit( s): 12-Dec-2018 Date IR25 oam cooler Date/Time sample(s) sent to storage: 12/10/2018 16:00 Water - VOA vials have zero headspace? Yes 4 No Water - pH acceptable upon receipt? Yes D Yes D No pH adjusted? No No VOA vials submitted D D N/A ~ N/A ~ pH adjusted by: Login Notes: f:;oc 2 of 2 not relinquished. Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 39 of 42 HFNA-000003131 EPA Inspection Report - Page 1582 of 1969 Chain of Custody Form A Page _1_ of ......-2......_ enua ranm ental D Cincinnati, OH 11 513 733 5336 D Holland, Ml +16163996 070 D Salt Lake City, UT +l 801 266 7100 D Everett, WA + I 425 356 2600 D Houston, TX +1 281530565 6 D Spring Cit¥, PA + 1 610 948 4903 D Fart Collins, CO +I 970490 15/1 D Middletown, PA +17179445 541 D ALS Project Manager: Work Order#: >): :{Ptoieii(~ajj:je BWON Annual Sampling >< ~ornpaiJY.N~nie Navajo Refining Company LLC 1: :.:~ : ::• 1.· > I :f : BiU)~C : : >{ F.~li (575) 145.5451 : fait , · :: ••·::·· D-2101 Desalter Water D-130 Desalter Water 4 < D-130 Desalter HC : :S : D-482 Water HS18120510 :F Navajo Refining Compan y :H: 1111111 IUII 1111111111ml 1111111 12/06118 10:59 AM Liquid 8 X 12/06/18 10:42AM Liquid 8 X 12/06/18 9:15AM Liquid 8 X 12/06118 8:54AM Liquid 8 X 12106118 9:29AM Liquid 1, 8 X 12106118 10:04 AM Liquid 8 ·:- T-401 Sump Water 12/05118 : HJ: T-401 Sump Gasoline Blend 3:15 PM Liquid 1,8 X 12/05118 3:15PM Liquid 8 X 1. ~/ 1 f : P-185 Strainer Water ··· ·. · ·. }Shipmen t Method: . Date: --- Relin9liished by: ·ti LJ. /3-/1/;f. /0 PreservativeKey: Date: • ,u-1c.1. Date! Time: ' Time: D STD 10 Wk Days Received by: /?· " Logged by (Laboratory): Time: Required Turnaroun d Time: FedEX . J:.H2S04 4,.NaOH 0 - Oother _ _ __ 5 Wk Days D 2 Wk Days D 24 Hour Notes: c----·-·- ··-····· Received by (Laboratory): ' (?C F>alikag~:(Checik Checked by (La~ratory): I $-Na2S203 6-NaHS04 1-0ther Elo~ Betoyq ::: : ·: .. Cooler.Temp. 1---'l'! "-"'!"" !'-~--:- ~~~--- ,,~~~~ ~~--t ,,-,,c:• Level II: Standard QC ITRRP-Checklist ·. 2;HN03 - BWON Annual Sampling ,. (575) 145.5451 •:ii;• ()jty/Sfat~iZip Artesia, New Mexico 88210 / j:< D-2101 Desalter HC 3: A_ VOLATILES (8260) Benzene .· ::.·> ~~~" :·.· :, > '-4-- ----~~~~ I·>/ York, PA +I 717 505 5280 8-4-degreesC Note: Any changes must be made in writing once samples and COC Form have been submitted to ALS Laboratory Group. 9-5035 Level Ill: Std QC+ Raw Data Level IV: SW846 CLP-Like ITRRP level IV Other: Copyright 2009 by ALS Laboratory Group Page 40 of 42 HFNA-000003132 EPA Inspection Report - Page 1583 of 1969 Chain of Custody Form A Page _2_ of _.L__ Enu iran men tal D Cincinnati, OH +I 513 733 5336 D Holland, Ml +1616399 6070 D Everett, WA + l 425 356 2600 D +I 28153056 56 D Fort Collins, CO +1970490 1511 D ALS Project Manager: •• • ••<:oin~an{Nanie Navajo Refining Company LLC < Bill:ti>~ri1J:1any Holly Frontier Navajo Refining P.0.Box 159 i{ .·.·.·.·.·.·.·.ttU1:.n~r.,sr:n@gma1l.com >) •< < i •:• 12/06/18 11:30AM Liquid 12/06/18 8:50AM Liquid f 8 1 Field Blank 12/06/18 9:27 AM <4: Liquid 1, 8 1 Trip Blank :~< 12/06118 XXX Liquid 1, 8 2 EQ Blank Port 1 12/06/18 1:30 PM Liquid 1, 8 ••~) EQ Blank Port 2 12/06118 1:30 PM Liquid 1,8 1 12/06118 1:30 PM Liquid 1, 8 1 Duplicate 12/05/18 JOO{f Liquid 8 Temperature Blank 12/06/18 XXX Liquid tF [/9< <10: ,.· •:· .·. ·.· ·. ,: ·., .... ~$.fg,f { } Relinquishe d by: <: :/. Relinquishe d by: Logged by (Laboratory): . . :<: > : : :: :: >: .·. ·.· <• ·. } <> :\,Shipm ent Method: : FedEx Date: Time: Received by: Date: Time: Received by (Laboratory): Date: Timi!: CMcked by (Labor11tory): .. ·4-NaOH 5-Na2S203 S::NaHS04 III I II 111111111111111 - 8 STD 10 Wk Days 0 5 Wk Days D Other _ _ _ __ D 2 Wk Days D 24 Hour Level m: Std QC + Raw Data Level IV: SW846 CLP-Like . 3·H2S04 - Notes: .. 2-HN03 Ill !Required Turnarou nd Time: ID - Navajo Refining Compa ny §.uzanne~e,gui!ar(dlhol!yfront,er com D-180 Naptha 1• York, PA +I 717 505 5280 HS18120510 [I . 70-C-350 Naptha , 1:< EQ Blank Port 3 D BWON Annual Sampling ··· >» •<Pr6J~i:ifName BWON Annual Sampling ............. Houston, TX D 7°0ther ·. ·• Note: Any changes must be made in writing once samples and COC Form have been submitted to ALS Laboratory Group. ITRRP Level IV 9-5035 Other: Copyright 2009 by ALS Laboratory Group Page 41 of 42 HFNA-000003133 EPA Inspection Report - Page 1584 of 1969 SHIPPER'S OE CLARA TION FOR DANGEROUS GOODS (Provide at least three copies to airline.) Shipper NAVAJO REFINING COMPANY CIO AQUA MICROBICS 501 E MAIN ARTESIA Air Waybill No. 709308590718 Page 1 of 1 Page(s) ~: x NM88210 US Shipper's Reference Number /optional) Consignee Corey Grandits ALS 10450 Stanciiff Suite 210 HOUSTON 18 Compliant Express TX77099 CAFE3211 US Two completed and signed copies of this f?eclaratjon must be handed to the operator TRANSPORT OETAILS This shipment is within the limitations prescribed for: {delete non applicable) Failure to comply with all respects with the applicable Dangerous Goods Regulations may be in breach of the applicable law ,subject to legal penalties. Airport of Departure ARTESIA ~ y WARNING r Airport of Destination: HOUSTON . Shioment tvne: •nw. ABSGRA {delete non applicable) NATURE AND QUANTITY OF DANGEROUS GOODS UN Number or identification Number, proper shipping name, Class or Division (subsidiary risk), packing group (if required)¥ and all other required lnfonnatfon. UN 1267, Petroleum crude oil.3,1/1 80 ml//361 UN 1268, Petroleum distillates, n.o.s.,3,ill// 160 ml/1366 UN 3082. Environmentally hazardous substance, liquid. n.o.s.{AMMONIA, ANHYDROUS , HYDROGEN SULFIOE),9,111// 160 ml//964 All Packed In One FIBREBOARD BOX Q =0.1 ----------a-----------------------------------------~-----------------------------------------------------------------..---------Additional Handling Information 24 Hour Emergency Response- CHEM.rREC 1800-424-9300 CCN 201319 I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged, marked and labelled/placarded, and are in all respects in proper condition for transport according to applicable International and Nation.al Governmental Regulations. I declare that all of the applicable air transport requirements have been met. Name/Title of Signatory Brady Hubbard/Environmental Coordinator Place and Date Artesia NM 12/0612018 Signature 18224249300 (See wamin9 abcv&} Em&rgem:y Telephone Number sj;;;__ :o_~ ,,,,. / FOR RADIOACTIVE MATERIAL SHlPMENT ACCEPTABLE FOR PASSENGER AIRCRAFT, THE SHIPMENT CONTAINS RADIOACTIVE MATE:RIAL INTENDED FOR use IN OR INCIDENT TO RESEARCH, MEDICAL OIAGNOSlS OR TREATMENT. AOR EUROPEAN TRANSPORT STATEMENT: CARRIAGE JN ACCOF;:OANCE WITH 1.1.4,2.1 LOGO~;J-1572S:5 1111? Page 42 of 42 HFNA-000003134 EPA Inspection Report - Page 1585 of 1969 ATTACHMENT 7 - Provided in Enclosed CD NSPS SUBPART Ja EXCESS EMISSIONS Period: July-December 2018 (Paragraph 18 Appendix E) HFNA-000003135 EPA Inspection Report - Page 1586 of 1969 HOLL'lFRONTI ER . January 30. 2019 Enforcement Manager Ne,v Mexico Environment Departmelll (\;_tificd Mail/Return -8,~;:,:tm 7015 0640 0006 6577 737 l 525 Camino de Los Marquez, Suite l Santa Fe, NM 87505 Re: NSPS Subpart Ja CMS Excess .Emissions and Summary Reports Reporting Period 07/01/2018 to 12/31/2018 IIoHyFn:m.tier Navajo Refining LLC - Artesia, NM Refinery Agency Interest No. 198 HoLlyFrontier Navajo Refining LLC (Navajo) is submitting this semi-annual report for the Artesia, NM Refinery pursuant to the requirements of 40 CFR 60.7 (c), in NSPS Subpart /L Per Nl'vlED request on 08/05/2016, the reports for applicable NSPS Db, J, and .fa affected sources are being submitted individually. This report covers the sources subject to NSPS Subpart Ja, and includes a Data Summary Report, a Monitoring System Dmvntirne Report, and an Excess Emissions Report. The monitored source(s) are identified as: - NSR Permit Source ID or Navajo Pollutant Equipment RuJe Name Monitored Number NSPS---··-•+•••••••••••••-·-----+-Ja . Boiler 9 NOx B-9 ---·--- - -.. Process Unit Number 38 TAG 38AI001.PV • • • • • • • • • • • • • • • • • • • • • • • • • · - - - - - + - - - - - - - - ! - - - · - - · - • • • • • • • • • • o H O O O _ _ __ _ , I, ~~~i8i ~a~e~t I Pressure i (H-2501) ___ .........J':'.!.(_)_x_ __,__~_l_··2_5_0_1____2_5__ .L:?.?.:~J0469C.DACAPV High i NSPS Ja 1 ,____N_S_P_S_J_a_-+-_~_\_:_~-·~--~~;;·········· .__._ _I_{;_,S_ _+---_[_J._.()_7_7_0·--t·······7 ............J........ 07 AlOO l.PV- · Lmv 1 Pressure Refinery I NSPS Ja 07.AI002.PV _!:'1:!.:?.1-.D.f.1_s _ _ _ H.cc_?.s_--j__o_··_-0_0.t?.. . . . . . . ?.____ SRU3 Tail I Gas 31 AJ426C .Di\CA.PV i ..........F.:!.?.!.:..~. }~-+--In_c_ir_H:_:ra_t_o_r_+-__.?.9). . . . . . . .!._S_R_l_J_3_-T_{_~r_I-+--3_1_-+_3__1Al425C.D ACA.PV ~ Hydrocrack -0 2 for I ! NSPS Ja 34 .34Al0242.DACA.PV _e_r_R_e_b_o_il_e1_·-+--···-_..li9.~. . . . . . . ·. . . . . . }~~3402 ---··············---------< Unit 64 I Hydrogen I i. . . . ._. ·-f- Plant I ···-···0.!.~f.§.._:_fa___R_e_"f_o_n_.n_t:1_·--+---······~.9.!............J__H_-<_J8_'5_1_--+-__o_·4_ _i_6_.4_ AYO l 06B.D ACA. PV 1 11 J. . . . . . .N.~J.:.?..J~···-·~-N-(_;_"f_~t_a_:::_"_·_t~--..!.i/?.. . . . . . . FL-400 55 I 55A1400AI .PV , J I HdlyFrnntier Navajo Refining LLC 501 F;:stMain • Artesh, NM 88210 (575) 748-33 l l • hr.tp:i iv,ww.hollvfrontier.com HFNA-000003136 EPA Inspection Report - Page 1587 of 1969 NSPS Subpart Ja I Rule NSR Permit Source ID or Navajo Equipment Number Pollutant lVfonitored Name January 30, 2019 i Process Unit Number TAG ---1------- 4---------1 -----+-----------' North Plant NSPS Ja --N~;~~f~~-lf-Ja--n-t-+--F--•l_,or_\'.{_,1s1_t_~,---· ~------FF.•l.L44{())(0)_____)_-5_ ~ NSPS Ja Flare South Plant NSPS Ja Flare · - - - - - - + - - - - -....................1 South Plant \ __,___.._~,:?J1.9_(!B_l_.P_\_1_--i . . , +----------............................ ., I .. 55 55FQI400A.PV ------+-------------- -··········----+------... +··-·-------;------ -~ ------; _.li§l'S Ja Sm:J~~anl ·.-.....J'.'1:~J~?...1-.0..... NSPS Ja Flare FCC Flare ,i,,,,,, FL-401 55 ·---··-··················,·············· ········--··- .• TRS F!.-40 l +-~'? , ,__ _ FL-401 ·+·--···-2~............J.............. 55FQI401A_.PY..............J .._:......JJg.,.y~ate J. __ 55Al401A1 .PV i ...................._ . ~ , }hS H,S I FL-402 i 55 I 55 AI401 BlYY,,, ,. ~ 55AI402ALPV ~....... NSP-~;~·-·····. ·····~-·~:~: ~1_<1.i:~.... ~;;;·············r. . . . . ~'L-~q.?_............1.............?..?..........r-·······~·~~~~~021}..:LYV · NSPS Ja i FCC Flare Flowrnte FLA02 ! 55 i 55FQI402A.PV !---·-·-···-·····················..···: -··+·····························-···· . ·t··············· . ·----···················· J I J NSPS Ja I Alkv Flare ···t··················"'. I Flowrate FL-403 ···---------------- ···············-······-- NSPS Ja GOH Flare H2S----+-----------------·-····· FL-404 -------------··············-+-- NSPS Ja GOH Flare TRS FLA04 GOH Flare Flowrate FL-404 55 .. 55FQ1403A.PV 55 55Al404A1 .PV ··············<············-·-··-~ ---·-················"····------< 55 ·················-------······· 55AJ404Bl.PV ------------------·-···--······ ·······-·------- -------------················· ·--+---------·--·····-····-·i ···············< NSPS Ja .......................--~---·--·············· ········..····· 55 55FQI404A.PV Please note that 60. l 03a(h) exempts startup, shutdown, malfunction, and process upset gases, along with relief valve leakage, from the requireinent to meet the l 62 ppm (J-I:,,S) limiL In this report we have induded infonnation on these events we believe are subject to this provision and exemption, and have identified them as such. An /\ltemative Monitoring Plan (AMP) pursuant 40 CFR §60, 13(i)(6) was submitted on November 24 1h, 2015 to the Envirnnrnental Protection Agency (EPA) requesting authorization to perform the required daily two-point CD validation and the two-point quarterly accuracy audits for the low measurement range of each SOLA II in order to validate the high measurement range perfonmrnce of the instrument as an alternative to the quality assurance procedures described in tj60. l 07a( e )(1 )(iii). An (AMP) pursuant to 40 CFR Part 60.13(i) for all New Source Performance Standards (NSPS) \Vas submitted on June 21, 2013 to the Environmental Protection A.gency (EPA) to cover the operation of Unit 34 Hydrocracker Reboiler I (H··3402), which primmily uses purchased naturnl gas. Navajo repmts instances of bumiug refinery fuel gas in the attached report sheets. The FCC Flare (FL-402) and the North Plant Flare (FL-400} were previously part of an interconnected network of fiare headers, although they did not operate as interconnected flares. The Flare Management Plan (FMP) subrnitted on November 11, 2015 established the combined flow baseline for FL-400 (North Plant) and FL-402 (FCC) flares as 1,077,961. As of July 2017, the physical connection be1ween the flares headers was removed, and separate flow baseh111.~s 1vere established for each flare. The July 2017 FMP update establishes a new flow baseline of 162,000 SCF in any 24-hour period for FL-402 (FCC), and a uev1 How baseline of 624,000 SCF in any 24-hour period for FL-400 (NP). Per 40 CFR ::i60,103a(c)(l)(ii), the tlm::shold fi:)r a Root HollyFrontie, Navajo Refining LLC .501 East Main• Artesia. NM 88210 (575) 748I / AllnlT I / 07/01/2018 Total Time in Reporting Period Total Source Downtime (hours) 4416 (hours) 0 Total Source Operating Time in Reporting Period (hours) 4416 CMS Performance Summary Number of Incidents 7 CMS downtime in reporting period due to: Monitoring Equipment Malfunctions Non-Monitoring Equipment Malfunctions (e.g., Computer, Data Recorder, Etc.) Quality Assurance/Quality Control Calibrations Other Known Causes Other Unknown Causes Totals ' ULCII \J .. ..., UUvvl ILII' I v c,.;::, Cl r "''""''IL UI I '"' --·= ULCII ...., Duration (Hours) 7.00 0 0.00 0 0 0 0.00 0.00 0.00 7 7.00 ''-'' I.,<, 0.16% ··-- Emission Data Summary (Exceeds 500,000 SCF over baseline in rolling 24 hours) Duration of excess emissions in reporting period due to: Startup Shutdown Control Equipment Problems Process Problems Other Known Causes Other Unknown Causes Totals Total Duration of Deviations as a Percent of Total Source Operating Time Number of Incidents 0 1 0 1 0 0 2 Duration (Hours) 0.00 12.00 0.00 55.00 0.00 0.00 67.00 1.52% HFNA-000003225 EPA Inspection Report - Page 1676 of 1969 HollyFrontier Navajo Refining LLC Artesia Refinery NSPS Subpart Ja Periodic Report Alky Flare (FL-0403) FL-403 Flowmeter Downtime CMS Downtime Affected Source Name Monitor Type Monitored HAP or Gas Downtime Start Date and Time Downtime End Date and Time Duration of Downtime (hours) Type of Downtime Period Type of Cause of Deviation FL-403 Flowmeter SCF 07/23/2017 05:00 07/23/2017 05:15 0.25 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician corrected the analyzer No changes were made in operation malfunction, and the analyzer was returned to service. of the emission control system. FL-403 Flowmeter SCF 08/07/2017 06:30 08/07/2017 09:30 3.00 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician corrected the analyzer No changes were made in operation malfunction, and the analyzer was returned to service. of the emission control system. FL-403 Flowmeter SCF 08/14/2017 07:00 08/14/2017 07:15 0.25 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician corrected the analyzer No changes were made in operation malfunction, and the analyzer was returned to service. of the emission control system. FL-403 Flowmeter SCF 09/21/2017 17:00 09/21/2017 17:15 0.25 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician corrected the analyzer No changes were made in operation malfunction, and the analyzer was returned to service. of the emission control system. FL-403 Flowmeter SCF 08/14/2018 17:00 08/14/2018 18:00 1.00 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician corrected the analyzer No changes were made in operation malfunction, and the analyzer was returned to service. of the emission control system. FL-403 Flowmeter SCF 08/27/2018 13:45 08/27/2018 14:00 0.25 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician corrected the analyzer No changes were made in operation malfunction, and the analyzer was returned to service. of the emission control system. FL-403 Flowmeter SCF 10/04/2018 09:00 10/04/2018 11 00 2.00 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician corrected the analyzer No changes were made in operation malfunction, and the analyzer was returned to service of the emission control system. Total 7.00 Brief Description of Cause of Downtime Corrective Action Taken Changes to Emission Control 60.108a(d)(6) HFNA-000003226 EPA Inspection Report - Page 1677 of 1969 HollyFrontier Navajo Refining LLC Artesia Refinery NSPS Subpart Ja Periodic Report Alky Flare (FL-0403) FL-403 500M SCF Deviations CMS Deviations iMonitored Excess Emissions HAP or Sta rt Date and Ti me Gas Duration of excess Brief Description of Nature and Cause of Excess emissions in Emission reporting period due to: Affected Source Name Monitor Type FL-403 Flowmeter SCF 08/11/2018 11 :00 08111/2018 23:00 1200 y Shutdown Depressured the Propane Treater (D-0629) for maintenance to replace media FL-403 Flowmeter SCF 09/18/201818:00 09121/2018 01 :00 55.00 N Process Problems W-79 began venting non-condensables to FL0403. Total 67.00 Excess Emissions End Date and Time Duration of Excess Emissions Deviation Occurred During (hours) Period of Corrective Action Taken or Preventative Measure Adopted Discharges Per 60.108a(d)(5) All standard operating procedures were followed See Attached Event Record: ''#15to minimize emissions from the flare during 2018-08-28 FL-0403 NSPS Ja Flow RCA" shutdown. See Attached Event Record: "/116completed venting non-condensables and 2018-10-05 FL-0403 NSPS Ja Flow flaring was minimized. RCA" W- HFNA-000003227 EPA Inspection Report - Page 1678 of 1969 Holly Frontier Navajo Refining LLC Artesia, Nl'v1 Refinery NSPS Subpart Ja Artesia GOH Flare, FL-404 §60.lOOa Applicability, designation of affected facility, and reconstruction. (b) For flares, the provisions of this subpart apply only to flares which commence construction, modification or reconstruction after June 24, 2008. §60.101a Definitions. Terms used in this subpart are defined in the Clean Air Act (CAA), in §60.2 and in this section. Emergency flare means a flare that combusts gas exclusively released as a result of malfunctions (and not startup, shutdown, routine operations or any other cause) on four or fewer occasions in a rolling 365-day period. For purposes of this rule, a flare cannot be categorized as an emergency flare unless it maintains a water seal. Non-emergency flare means any flare that is not an emergency flare as defined in this subpart. Flare FL-404 is a Non-emergency flare. Modification or reconstrnction occurred on Flare FL-404 after June 24, 2008. Therefore FL-4040 is subject to NSPS Subpart Ja. HFNA-000003228 EPA Inspection Report - Page 1679 of 1969 Holly Frontier Navajo Refining LLC Artesia, Nl'v1 Refinery NSPS Subpart Ja - 500 M SCF 24-hour rolling average Artesia GOH Flare, FL-404 §60.103a Design, equipment, work practice or operational standards (a) Except as provided in paragraph (g) of this section, each owner or operator that operates a flare that is subject to this subpart shall develop and implement a written flare management plan no later than the date specified in paragraph (b) of this section. The flare management plan must include the information described in paragraphs (a)(l) through (7) of this section. compressor staging and a justification for why the maximum time period cannot be further reduced. (4) An evaluation of the baseline flow to the flare. The baseline flow to the flare must be determined after implementing the minimization assessment in paragraph (a)(2) of this section. Baseline flows do not include pilot gas flow or purge gas flow (i.e., gas introduced after the flare's water seal) provided these gas flows remain reasonably constant (i.e., separate flow monitors for these streams are not required). Separate baseline flow rates may be established for different operating conditions provided that the management plan includes: (c) Except as provided in paragraphs (t) and (g) of this section, each owner or operator that operates a flare subject to this subpart shall conduct a root cause analysis and a corrective action analysis for each of the conditions specified in paragraphs (c)(l) of this section. (1) For a flare: (ii) Any discharge to the flare in excess of 14,160 standard cubic meters (m3) (500,000 standard cubic feet (set)) above the baseline, determined in paragraph (a)(4) of this section, in any 24-hour period. §60.107a Monitoring of emissions and operations for fuel gas combustion devices and flares. (t) Flow monitoring for flares. Except as provided in paragraphs (t)(2) and (h) of this section, the owner or operator of an affected flare subject to §60.103a(c) through (e) shall install, operate, calibrate and maintain, in accordance with the specifications in paragraph (t)(l) of this section, a CPMS to measure and record the flow rate of gas discharged to the flare. (1) The owner or operator shall install, calibrate, operate and maintain each flow monitor according to the manufacturer's procedures and specifications and the following requirements. (iv) At least quarterly, perform a visual inspection of all components of the monitor for physical and operational integrity and all electrical connections for oxidation and galvanic corrosion if the flow monitor is not equipped with a redundant flow sensor. (v) Recalibrate the flow monitor in accordance with the manufacturer's procedures and specifications biennially (every two years) or at the frequency specified by the manufacturer. Flare FL-404 is subject to the reporting threshold of 500 MSCF above the flow baseline in a 24-hour period. Navajo maintains a flow monitor for continuously measuring the flow to the flare. The Flare Management Plan submitted on November 1 L 2015 established the baseline flow for FL-404 to be 3,504,000 standard cubic feet per day (SCFD; where a day is any 24-hour period). Per 40 CFR §60. l03a(c)(l)(ii), the threshold for an RCA and corrective action plan is 4,004,000 SCF in any 24-hour period. The June 2017 Flare Management Plan update included an alternative flow baseline of 8,500,000 SCF in any 24-hour period for excess hydrogen flaring during outages of the hydrogen units (Unit 63 and 64), or hydrogen consumers. The threshold for a Root Cause Analysis and corrective action plan is 9,000,000 SCF in any 24-hour period. HFNA-000003229 EPA Inspection Report - Page 1680 of 1969 HollyFrontier Navajo Refining LLC Artesia Refinery NSPS Subpart Ja Periodic Report GOHT Flare (FL-0404) Affected Source Emission Limit Citation FL-404 500M SCF CEMS Summary FL-404 GOH Flare §60.103a(c)(1)(ii) 500,000 Emission Limitation (SCF over baseline in rolling 24 hours) Monitor Manufacturer and Model No. Monitor Serial Number Date of Latest CMS Certification or Audit General Electric - GF868-2-11 4382 10/18/2017 07/01/2018 12/31/2018 Reporting Period Beginning Date Reporting Period Ending Date Total Time in Reporting Period Total Source Downtime (hours) 4416 (hours) 0 Total Source Operating Time in Reporting Period (hours) 4416 CMS Performance Summary CMS downtime in reporting period due to: Monitoring Equipment Malfunctions Non-Monitoring Equipment Malfunctions (e.g., Computer, Data Recorder, Etc.) Quality Assurance/Quality Control Calibrations Other Known Causes Other Unknown Causes Totals Total CMS Downtime as a Percent of Total Source Operating Time Number of Incidents 13 Duration (Hours) 19.00 0 0.00 0 0 0 13 0.00 0.00 0.00 19.00 0.43% Emission Data Summary (Exceeds 500,000 SCF over baseline in rolling 24 hours) Number of Duration (Hours) Duration of excess emissions in reporting period due to: Incidents 3 60.00 Startup Shutdown 1 59.00 0 0.00 Control Equipment Problems Process Problems 1 19.00 5 232.00 Other Known Causes Other Unknown Causes 0 0.00 10 370.00 Totals Total Duration of Deviations as a Percent of Total Source 8.38% Operating Time HFNA-000003230 EPA Inspection Report - Page 1681 of 1969 HollyFrontier Navajo Refining LLC Artesia Refinery NSPS Subpart Ja FL-404 Flowmeter Downtime Periodic Report GOHT Flare (FL-0404) CMS Downtime Affected Source Name Monitor Type Monitored Duration of Downtime Downtime HAP or Downtime ! Start Date and Time End Date and Time (hours) Gas FL-404 Flowmeter SCF 07/30/2018 0930 07/30/20181200 2.50 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician performed maintenance to correct an analyzer malfunction, and the analyzer was returned to service No changes were made in operation of the emission control system. FL-404 Flowmeter SCF 08/14/2018 17 00 08/14/20181800 100 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician performed maintenance to correct an analyzer malfunction, and the analyzer was returned to service No changes were made in operation of the emission control system. FL-404 Flowmeter SCF 09/05/2018 09 15 09/05/2018 10 15 100 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction The l&E technician performed maintenance to correct an analyzer malfunction, and the analyzer was returned to service. No changes were made in operation of the emission control system. FL-404 Flowmeter SCF 09/11/2018 1415 09/11/2018 15 30 1.25 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician performed maintenance to correct an analyzer malfunction, and the analyzer was returned to service No changes were made in operation of the emission control system. FL-404 Flowmeter SCF 09/14/2018 0145 09/14/2018 0215 0.50 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction The l&E technician performed maintenance to correct an analyzer malfunction, and the analyzer was returned to service. No changes were made in operation of the emission control system. FL-404 Flowmeter SCF 09/17/20181230 09/17/2018 1315 0.75 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction The l&E technician performed maintenance to correct an analyzer malfunction, and the analyzer was returned to service. No changes were made in operation of the emission control system. FL-404 Flowmeter SCF 10/02/2018 08 00 10/02/2018 11 30 3.50 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician performed maintenance to correct an analyzer malfunction, and the analyzer was returned to service No changes were made in operation of the emission control system. FL-404 Flowmeter SCF 11/05/20181015 11/05/20181130 1.25 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician performed maintenance to correct an analyzer malfunction, and the analyzer was returned to service No changes were made in operation of the emission control system. FL-404 Flowmeter SCF 11/26/2018 0915 11/26/2018 1145 2.50 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician performed maintenance to correct an analyzer malfunction, and the analyzer was returned to service No changes were made in operation of the emission control system. FL-404 Flowmeter SCF 11/27/2018 1515 11/27/2018 15 30 0.25 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician performed maintenance to correct an analyzer malfunction, and the analyzer was returned to service No changes were made in operation of the emission control system. FL-404 Flowmeter SCF 11/28/2018 0900 11/28/2018 0915 0.25 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction The l&E technician performed maintenance to correct an analyzer malfunction, and the analyzer was returned to service. No changes were made in operation of the emission control system. Type of Downtime Period Type of Cause Brief Description of Cause of Downtime of Deviation Corrective Action Taken Changes to Emission Control 60.108a(d)(6) HFNA-000003231 EPA Inspection Report - Page 1682 of 1969 HollyFrontier Navajo Refining LLC Artesia Refinery NSPS Subpart Ja FL-404 Flowmeter Downtime Periodic Report GOHT Flare (FL-0404) Duration of Monitored Downtime Downtime HAP or Downtime i Start Date and Time End Date and Time (hours) Gas Affected Source Name Monitor Type FL-404 Flowmeter SCF 12/11/2018 0845 12/11/2018 0945 100 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician performed maintenance to correct an analyzer malfunction, and the analyzer was returned to service. No changes were made in operation of the emission control system. FL-404 Flowmeter SCF 12/27/2018 1000 12/27/2018 1315 3.25 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode due to an analyzer malfunction. The l&E technician performed maintenance to correct an analyzer malfunction, and the analyzer was returned to service. No changes were made in operation of the emission control system. Total 1900 Type of Downtime Period Type of Cause Brief Description of Cause of Downtime of Deviation Corrective Action Taken Changes to Emission Control 60.108a(d)(6) HFNA-000003232 EPA Inspection Report - Page 1683 of 1969 HollyFrontier Navajo Refining LLC Artesia Refinery NSPS Subpart Ja Periodic Report GOHT Flare (FL-0404) FL-404 500M SCF Deviations CMS Monitored Excess Emissions excess Affected Source Name Monitor Type Monitore Excess Emissions d HAP or Start Date and Time Gas Excess Emissions End Date and Time uura11on of Duration of Emissions excess Deviation OccurredfDSu;~g emissions in (hours) (Y/N) nerinrl due to: Brief Description of Nature and Cause of Excess Emission Corrective Action Taken or Preventative Measure Adopted Discharges Per 60.108a(d)(5) ~i1~ ~~ot;; y SCF 07/19/2018 16:00 07/20/2018 02:00 1000 Startup Hydrogen venting to the GOH Flare (FL-0404) during startup of the The startup of Unit 63 wa_s complete? and the produ_c~ion rate in the . :g:;/ttache~aE;~n~aRs:~i~~d;\;: :L-----+--------------1------------------------------+----------------------------+----------------1------------------------1---------------------IH,,dro_,aen Plant No.1 and increased rate in the CCR contribute to hydrogen Plant No.2 (Unit 64) was dialed back to minimum rate, reducing FLNSPS Ja Alt Baseline Flow 1201 0404 y Startup the the hydrogen flow vented to the flare. ! RCAH SCF 07/22/2018 05:00 07/23/2018 17:00 36.00 FL-404 !Flowmete, FL-404 iFlowmete, FL-404 iFlowmete1 FL-404 iFlowmete, SCF SCF 08/27/2018 16:00 09/23/2018 18:00 08/30/2018 03:00 09/25/2018 00:00 59.00 30.00 y Shutdown During the shutdown period of the Al~fation Unit for flare tip repairs, the production rates in the hydrotreater units was reduced, minimizing their hydrogen consumption. The hydrogen that was not consumed by these units during this period had to be vented to the GOH flare, contributing to the flare flow to increase above the reporting threshold. The repairs to the Alkylation Flare tip were completed and the Alkylation unit was restarted. The hydrotreaters' production and hydrogen consumption were increased to normal rates, reducing the hydrogen discharge to the flare. !see Attached Event Record: "#19-2018-10-25 FLJa Alt Baseline Flow RCA" !0404 N The electrical power supply from a third party substation to the Artesia Refinery was interrupted for approximately 3 hours, resulting in the Other Known shutdown of several process units, as well as several pumps, compressors Cause and other electric pieces of equipment within the refinery. The flaring associated with the units' shutdown contributed to discharge to the flare in excess of the flow baseline reporting threshold. The electrical supply was promptly shifted to four additional substations that provide the electrical power to other sections of the refinery, allowing !see Attached Event Record: "#20-2018-10-16 FLthe electrical power to be restored. The frequency of preventative Ja Alt Baseline Flow RCA" !0404 maintenance activities petionned by the third-party electrical substation was increased fonn semiannual to monthly basis. The electrical power supply from a third party substation to the Artesia Refinery was interrupted for approximately 3 hours, resulting in the Other Known shutdown of several process units, as well as several pumps, compressors Cause and other electric pieces of equipment within the refinery. The flaring associated with the units' shutdown contributed to discharge to the flare in excess of the flow baseline reporting threshold The electrical supply was promptly shifted to four additional substations that provide the electrical power to other sections of the refinery, allowing !See Attached Event Record: "#20-2018-10-16 FLthe electrical power to be restored. The frequency of preventative Ja Alt Baseline Flow RCA" !0404 maintenance activities performed by the third-party electrical substation was increased fonn semiannual to monthly basis. FL-404 iflowmete, SCF 09/25/2018 18:00 09/25/2018 23:00 5.00 N FL-404 jFlowmete, SCF 09/28/2018 13:00 09/29/2018 03:00 14.00 y Startup Process Problems FL-404 iFlowmete, SCF 10/2912018 05:00 10/3012018 00:00 19.00 N FL-404 iFlowmete, SCF 11/19/201816:00 11/25/2018 01:00 129.00 Other FL-404 !Flowmete, SCF 11/25/201815:00 11/27/2018 20:00 53.00 Other FL-404 iflowmete, SCF 11/29/2018 04:00 11/29/2018 19:00 15.00 Other Total 370.00 Startup of the Mild Hydrocracker Unit (MHC) following a planned shutdown The planned shutdown and startup procedures were followed. for MHC Guard Bed Reactor catalyst replacement. iSee Attached Event Record: "#21-2018-10-17 FLJa Alt Baseline Flow RCA" and "#22i0404 Ja RCA S02 FL-0404" i201 Unexpected shutdown of Diesel Hydrotreater (DHT, Unit 33) Recycle Compressor (C-0693) due to a seal malfunction in the oil level indicator. The hydrogen feed not consumed by the DHT during the shutdown period was vented to the flare, causing the flare flow to exceed the alternative baseline flow reporting threshold of 9 MMSCF in a 24-hour period. Presence of water in the conduit to the level indicator was identified as the cause of the seal malfunction that resulted in the unit shutdown. isee Attached Event Record: "#23-2018-11-06 FLJa Alt Baseline Flow RCA" i0404 1&3 technicians removed the water, restarted the compressor and the DHT, stopping the venting of excess hydrogen to the flare. Between 11/19/18 and 11/26/2018, the GOH Flare (FL-0404) flow baseline Other Known reporting threshold was exceeded. During this period, discharges to the Cause flare associated to the startup of the ROSE (Unit 25), the venting of Other Known hydrogen associated with an unexpected shutdown of the Diesel Hydrotreater (DHT, Unit 33) Recycle Hydrogen Compressor (C-0693), the Units were restarted; C-693 was repaired returned online. Cause planned shutdown of the Mild Hydrotreater (MHC) unit, and the unit startup Other Known of several process units after an unexpected interruption of electrical power to the refinery, contributed to increasing the flare flow above the reporting Cause threshold. !See Attached Event Record: "#24-2018-12-06 FLJa Baseline Flow RCA" !0404 HFNA-000003233 EPA Inspection Report - Page 1684 of 1969 Holly Frontier Navajo Refining LLC Artesia, Nl'v1 Refinery NSPS Subpart Ja - 162 ppmvd H 2S 3-hour rolling average Artesia GOH Flare, FL-404 §60.103a Design, equipment, work practice or operational standards (h) Each owner or operator shall not bum in any affected flare any fuel gas that contains H 2 S in excess of 162 ppmv determined hourly on a 3-hour rolling average basis. The combustion in a flare of process upset gases or fuel gas that is released to the flare as a result of relief valve leakage or other emergency malfunctions is exempt from this limit. §60.107a Monitoring of emissions and operations for fuel gas combustion devices and flares. (a) Fuel gas combustion devices subject to S0 2 or H2 S limit and flares subject to H 2 S concentration requirements. (2) The owner or operator of a fuel gas combustion device that elects to comply with the H 2 S concentration limits in §60.102a(g)(1)(ii) or a flare that is subject to the H 2S concentration requirement in §60.103a(h) shall install, operate, calibrate and maintain an instrument for continuously monitoring and recording the concentration by volume (dry basis) of H 2S in the fuel gases before being burned in any fuel gas combustion device or flare. (3) The owner or operator of a fuel gas combustion device or flare is not required to comply with paragraph (a)(l) or (2) of this section for fuel gas streams that are exempt under §§60.102a(g)(1)(iii) or 60.103a(h) or, for fuel gas streams combusted in a process heater, other fuel gas combustion device or flare that are inherently low in sulfur content. (e) Su(f'ur monitoring for assessing root cause analysis threshold for affected flares. (2) H 2S monitoring requirements. The owner or operator shall install, operate, calibrate, and maintain an instrument for continuously monitoring and recording the concentration of H 2 S in gas discharged to the flare according to the requirements in paragraphs (e)(2)(i) through (iii) of this section and shall collect and analyze samples of the gas and calculate total sulfur concentrations as specified in paragraphs (e)(2)(iv) through (ix) of this section. Flare FL-404 is subject to the 162 ppmv hydrogen sulfide (H 2 S) limit. Therefore, Navajo maintains an H 2 S CEMS on Flare FL-404 that records concentrations in parts per million by volume on a dry basis (ppmvd). Note: 60. l03a(h) exempts process upset gases and releases resulting from relief valve leakage or other emergency malfm1ctions from the requirement to meet the 162 ppm (H2S) limit. In this report we have included infonnation on these events subject to exemptions, and have identified them as such. HFNA-000003234 EPA Inspection Report - Page 1685 of 1969 HollyFrontier Navajo Refining LLC Artesia Refinery NSPS Subpart Ja Periodic Report for GOHT Flare (FL-0404) Affected Source Emission Limit Citation Emission Limitation (H 2 S ppmv on rolling 3-hours) Monitor Manufacturer and Model No. Monitor Serial Number Date of Latest CMS Certification or Audit FL-404 H2S CEMS Summary FL-404 GOH Flare §60.103a(h) §60.107a(e)(2) 162 Siemens - Maxum II 30049702230100 02/14/2018 07/01/2018 12/31/2018 Reporting Period Beginning Date Reporting Period Ending Date Total Time in Reporting Period Total Source Downtime (hours) 4416 (hours) 0 Total Source Operating Time in Reporting Period (hours) 4416 Number of Incidents 4 Duration (Hours) 745.00 0 0.00 184 10 0 0.00 78.00 0.00 198 823.00 CMS Performance Summary CMS downtime in reporting period due to: Monitoring Equipment Malfunctions Non-Monitoring Equipment Malfunctions (e.g., Computer, Data Recorder, Etc.) Quality Assurance/Quality Control Calibrations Other Known Causes Other Unknown Causes Totals Total CMS Downtime as a Percent of Total Source Operating Time 18.64% Emission Data Summary (Exceeds 162 H2 S ppmv on rolling 3-hours) Duration of excess emissions in reporting period due to: Startup Shutdown Control Equipment Problems Process Problems Other Known Causes Other Unknown Causes Totals Total Duration of Deviations as a Percent of Total Source Operating Time Number of Incidents 3 2 0 7 5 2 19 Duration (Hours) 30.00 9.00 0.00 78.00 25.00 3.00 145.00 3.28% HFNA-000003235 EPA Inspection Report - Page 1686 of 1969 HollyFrontier Navajo Refining LLC Artesia Refinery FL-404 H2 S CEMS Downtime NSPS Subpart Ja Periodic Report for GOHT Flare (FL-0404) GEMS Downtime DoV\111time End Date and Time Duration of DoV\111time (hours) Type of Downtime Period Type of Cause of Deviation 07/30/2018 08:55 07/30/2018 11 :50 3.00 Other Known Cause Other The analyzer vvas placed in maintenance mode to perform maintenance. The l&E technician changed the probe filter and returned the analyzer to service. No changes were made in operation of the emission control system. H 2S 08/22/2018 09:41 08/22/2018 11 :36 1.00 Other Known Cause Other The analyzer vvas placed in maintenance mode to perform a CGA The E&I technician performed the CGA and returned the analyzer to service. No changes were made in operation of the emission control system GEMS H 2S 09/05/2018 05:00 09/05/2018 10: 15 5.00 Monitor Equipment Malfunction Malfunction The analyzer vvas placed in maintenance mode due to low sample pressure. The l&E technician identified contamination in the sample pump as the cause of malfunction. The sample pump was cleaned and rebuilt, and the analyzer vvas returned to service. No changes were made in operation of the emission control system. FL-404 GEMS H 2S 09/11/20181330 09/11/2018 15:20 1.00 Other Known Cause Other The analyzer vvas placed in maintenance mode to perform maintenance. The l&E technician replaced the sample pump assembly in the SGS cabinet, and returned the analyzer to service. No changes were made in operation of the emission control system FL-404 GEMS H2S 09/13/2018 23:00 09/14/2018 02:00 3.00 Monitor Equipment Malfunction Malfunction The analyzer vvas placed in maintenance mode due to a sample pump failure. The l&E technician repaired the pump, replacing the diaphragm and valves, and returned the analyzer to service. No changes were made in operation of the emission control system. FL-404 GEMS H2S 09/17/2018 11 :45 09/17/201813:15 1.00 Other Known Cause Other The analyzer vvas placed in maintenance mode to perform routine maintenance. The l&E technician changed the probe filter, the water carry over filter, rebuilt sample pump, and returned the analyzer to service. No changes were made in operation of the emission control system. FL-404 GEMS H2S 10/24/2018 08:57 10/26/2018 14:39 53.00 Other Known Cause Other The analyzer vvas placed in maintenance mode to complete the installation of new equipment for the RSR upgrade Maintenance/project \/\/Ork was being performed for No changes were made in operation of the RSR upgrade, and the analyzer was returned to the emission control system. service when completed. FL-404 GEMS H2S 10/26/2018 14:39 11/01/2018 00:00 129.00 Monitor Equipment Malfunction Malfunction The monitor was placed in maintenance mode The technician repaired the analyzer and returned it No changes were made in operation of due to analyzer failures. to service the emission control system. FL-404 GEMS H 2S 11/01/2018 0000 11/26/2018 08:00 608.00 Monitor Equipment Malfunction Malfunction The monitor was placed in maintenance mode The technician repaired the analyzer and returned it No changes were made in operation of due to analyzer failures to service. the emission control system FL-404 GEMS H2S 11/26/2018 08:37 11/26/2018 11 :42 2.00 Other Known Cause Other The analyzer vvas placed in maintenance mode to complete project tie-in. The l&E technician proceeded with the RSR project No changes were made in operation of tie-ins and returned the analyzer to service. the emission control system FL-404 GEMS H2S 11/27/2018 09:00 11/27/2018 16:00 700 Other Known Cause Other The analyzer vvas placed in maintenance mode to complete project tie-in. The l&E technician proceeded with the RSR project No changes were made in operation of tie-ins and returned the analyzer to service. the emission control system. FL-404 GEMS H2S 11/28/2018 07:40 11/28/2018 12:00 4.00 Other Known Cause Other The analyzer vvas placed in maintenance mode to complete a linearity test. The l&E technician performed a linearity test and returned the analyzer to service. No changes were made in operation of the emission control system FL-404 GEMS H2S 12/06/2018 10:36 12/06/2018 12: 22 1.00 Other Known Cause Other The analyzer vvas placed in maintenance mode to perform a CGA The E&I technician performed the CGA and returned the analyzer to service. No changes were made in operation of the emission control system. Affected Source Name Monitor Type Monitored Downtime HAP or Start Date and Time Gas FL-404 GEMS H 2S FL-404 GEMS FL-404 Brief Description of Cause of Downtime Corrective Action Taken Changes to Emission Control 60.108a(d)(6) HFNA-000003236 EPA Inspection Report - Page 1687 of 1969 HollyFrontier Navajo Refining LLC Artesia Refinery Affected Source Name Monitor Type FL-404 CEMS Monitored Downtime HAP or Start Date and Time Gas H2S FL-404 H2 S CEMS Downtime NSPS Subpart Ja Periodic Report for GOHT Flare (FL-0404) 12/27/2018 08:05 Dovvntime End Date and Time Duration of Dovvntime (hours) Type of Downtime Period Type of Cause of Deviation 12/27/201813:15 5.00 Other Known Cause Other Total 823.00 Brief Description of Cause of Downtime The analyzer vvas placed in maintenance mode due to plugged probe and pump. Corrective Action Taken The l&E technician replaced the filter and rebuilt pump. The sample system would not heat up. Freed up pressure switch and the system heated, and the analyzer was returned to service Changes to Emission Control 60.108a(d)(6) No changes were made in operation of the emission control system. HFNA-000003237 EPA Inspection Report - Page 1688 of 1969 HollyFrontier Navajo Refining LLC Artesia Refinery FL-404 H2 S Excess Emissions NSPS Subpart Ja Periodic Report for GOHT Flare (FL-0404) CEMS Monitored Excess Emissions Excess Duration of Monitored Duration of Emissions Excess Emissions Excess Emissions excess emissions HAP or Deviation Occurred in reporting Sta rt Date and Ti me End Date and Time Gas (hours) i During Period period due to: of SSM (YIN) Affected Source Name Monitor Type FL-404 CEMS H2S 08/06/2018 15:00 08/06/2018 16: 00 1.00 N The GOH (FL-0404) flare header exceeded the NSPS Ja limit of 162 Operations immediately increased f-bS scavenger injection rate. The event Other Unknown ppm H2S, on a 3-hour rolling average basis. Operations conducted a ended before the actual cause of the event could be determined or Cause unit wide walk-through looking for potential equipment and relief valve corrective actions were implemented. leaks with no issues found. FL-404 CEMS H2S 08/26/2018 16:00 08/26/2018 18:00 2.00 N The GOH flare header exceeded the NSPS Ja limit of 162 ppm H2S, Operations immediately increased f-bS scavenger injection rate. The event Other Unknown on a 3-hour rolling average basis. Operations conducted a unit wide ended before the actual cause of the event could be determined or Cause walk-through looking for potential equipment and relief valve leaks wiU corrective actions were implemented. no issues found. FL-404 CEMS H2S 08/29/2018 06:00 08/29/2018 09: 00 3.00 y Shutdown FL-404 CEMS H2S 09/06/2018 18:00 09/07/2018 05:00 11.00 y Startup FL-404 CEMS H2S 09/22/2018 05 00 09/22/2018 08:00 3.00 N Brief Description of Nature and Cause of Excess Emission Corrective Action Ta ken or Preventative Measure Adopted The GOH flare header exceeded the NSPS Ja limit of 162 ppm H2S, on a 3-hour rolling average basis while depressuring the Asphaltene Separator (D-2502) for planned maintenance on Unit 25 A controlled venting to the flare was monitored to relieve the pressure in the drum. As soon as the pressure in the drum was reduced within normal operating values, the venting to flare was stopped. The gas was safely combusted and dispersed from a steam-assisted flare, which aides in dispersion During start up of Unit 25, drum D-2506 was vented to flare to maintain pressure and levels. The standard operating procedures were followed to minimize emissions from the flare during startup of the units Scavenger was injected to minimize S02 emissions. Process Problems Unexpected shutdown of Amine Unit Lean Amine Pump (P-0775). The Electricians were called as soon as the switchgear malfunctioned, spare Lean Amine Pump (P-0776) was started. While testing P-0775, determining that the bucket style breaker tripped. The breaker was reset. the spare pump (P-0776) was restarted. The Amine contactors were returned the switch rack breaker feeding the breaker rack shorted causing a loss of power to both amine pumps. The amine contactors could not on line, resuming normal operation. To minimize excess SQ emissions from operate, reducing the treating capacity of acid gas being sent to the the flare, operations promptly injected an H:,S scavenger agent upstream of fuel gas system This caused an exceedance of the NSPS Ja 162 the Flare Knockout drum in order to reduce the emissions of S02 from the ppm H2S 3-hour rolling average at the flare. flare. Planned shutdown of the Mild Hydrocracker (MHC) unit for catalyst replacement in the Guard Bed Reactor. The unit shutdown procedure was followed. During the shutdovvn and decontamination of the MHC, pressure normally builds up in the reactors and the fractionator, which has to be relieved to the flare. The unit shutdown procedure was followed. Additionally, f-bS scavenger was injected at maximum rate to reduce the concentration of this gas in the flare header. The minimum volume necessary to safely de-pressure the system was vented to the flare. The electrical power supply from a third party substation to the Artesia Refinery was interrupted for approximately 3 hours, resulting in the shutdown of several process units, as well as several pumps, compressors and other electric pieces of equipment within the refinery. Off-gas was continued to be produced some time after the power outage occurred and the process units shut dovvn. Without the electrical power to operate amine contactors and H:,S strippers, the H:::,S concentration in the FGS and Amine Unit increased. Because the FG is also used as vent gas in the flare system, the H2S concentration increase in the FGS was transferred to the North Plant, FCC, and GOH flare systems, resulting in excess of the NSPS Ja 162 ppm H2S 3-hour rolling average. The electrical supply was promptly shifted to four additional substations that provide the electrical power to other sections of the refinery, allovving the electrical power to be restored, and process units to be restarted. The frequency of preventative maintenance activities performed by the thirdparty electrical substation was increased form semiannual to monthly basis S1artup of the MHC after catalyst replacement in the Guard Bed Reactor. The unit startup procedure was followed FL-404 CEMS H2S 09/22/2018 21 :00 09/23/2018 03:00 6.00 y Shutdown FL-404 CEMS H2S 09/23/2018 07 00 09/23/2018 15:00 8.00 N Other Known Cause FL-404 CEMS H2S 09/23/2018 22:00 09/2412018 07:00 9.00 N Other Known Cause FL-404 CEMS H2S 09/24/2018 10:00 09/24/2018 13:00 3.00 N Other Known Cause FL-404 CEMS H2S 09/24/2018 19:00 09/24/2018 22:00 3.00 N Other Known Cause FL-404 CEMS H2S 09/25/2018 08:00 09/25/2018 10: 00 2.00 N Other Known Cause FL-404 CEMS H2S 09/28/2018 17 00 09/29/2018 11 :00 18.00 y Startup FL-404 CEMS H2S 09/29/2018 15:00 09/29/2018 16: 00 1.00 y Startup HFNA-000003238 EPA Inspection Report - Page 1689 of 1969 HollyFrontier Navajo Refining LLC Artesia Refinery NSPS Subpart Ja Periodic Report for GOHT Flare (FL-0404) FL-404 H 2 S Excess Emissions CEMS Monitored Excess Emissions Excess Duration of Duratron of Emissions Monitored excess emissions Excess Emissions Excess Em1ss1ons Occurred HAP or Dev1at1on Sta rt Date and Ti me End Date and Trme in reporting Gas (hours) i During Period period due to: of SSM (YIN) Affected Source Name Monitor Type FL-404 GEMS H2S 10101/201811:00 10/0312018 03:00 40.00 N Process Problems FL-404 GEMS H2S 10103/2018 05:00 1 0/0312018 22: 00 17.00 N Process Problems FL-404 GEMS H 2S 10/0412018 11 00 10104/2018 15:00 4.00 N Process Problems FL-404 GEMS H 2S 10104/201817:00 10104/2018 23:00 6.00 N Process Problems FL-404 GEMS H2S 10105/201810:00 1 0/0512018 12: 00 2.00 N Process Problems FL-404 GEMS H 2S 10105/20181600 1 0/0512018 22: 00 6.00 N Process Problems Total 145.00 Brief Description of Nature and Cause of Excess Emission Corrective Action Ta ken or Preventative Measure Adopted ! An increase of the FGS H 2S concentration was transferred to the flare There are three scavenger injection points to the flare system. Adjusting these injection points did not alleviate the issue. Investigation continued and operations found a plugged quill at one of the injection points. i be exceeded intermittently i header. causing the NSPS Ja 162 ppm H2S 3-hour rolling average to HFNA-000003239 EPA Inspection Report - Page 1690 of 1969 Holly Frontier Navajo Refining LLC Artesia, Nl'v1 Refinery NSPS Subpart Ja - 500 lb S02 24-hour rolling average Artesia GOH Flare, FL-404 §60.103a Design, equipment, work practice or operational standards (c) Except as provided in paragraphs (t) and (g) of this section, each owner or operator that operates a flare subject to this subpart shall conduct a root cause analysis and a corrective action analysis for each of the conditions specified in paragraphs (c)(l) of this section. (1) For a flare: (i) Any time the S02 emissions exceed 227 kilograms (kg) (500 lb) in any 24-hour period; or §60.107a Monitoring of emissions and operations for fuel gas combustion devices and flares. (a) Fuel gas combustion devices subject to S02 or II2 S limit and flares subject to II2 S concentration requirements. (2) The owner or operator of a fuel gas combustion device that elects to comply with the II 2 S concentration limits in §60.102a(g)(1)(ii) or a flare that is subject to the II2S concentration requirement in §60.103a(h) shall install, operate, calibrate and maintain an instrument for continuously monitoring and recording the concentration by volume (dry basis) of II 2S in the fuel gases before being burned in any fuel gas combustion device or flare. (3) The owner or operator of a fuel gas combustion device or flare is not required to comply with paragraph (a)(l) or (2) of this section for fuel gas streams that are exempt under §§60.102a(g)(1)(iii) or 60.103a(h) or, for fuel gas streams combusted in a process heater, other fuel gas combustion device or flare that are inherently low in sulfur content. (e) Su(f'ur monitoring for assessing root cause analysis threshold for affected flares. Except as described in paragraphs (e)(4) and (h) of this section, the owner or operator of an affected flare subject to §60.103a(c) through (e) shall determine the total reduced sulfur concentration for each gas line directed to the affected flare in accordance with either paragraph (e)(l), (e)(2) or (e)(3) of this section. (1) Total reduced sulfur monitoring requirements. The owner or operator shall install, operate, calibrate and maintain an instrument for continuously monitoring and recording the concentration of total reduced sulfur in gas discharged to the flare. Flare FL-404 is subject to the 500 lbs S02 threshold monitoring requirements. Navajo maintains a CEMS for continuously measuring the concentration of total reduced sulfur in gas discharged to the flare. HFNA-000003240 EPA Inspection Report - Page 1691 of 1969 HollyFrontier Navajo Refining LLC Artesia Refinery NSPS Subpart Ja Periodic Report GOHT Flare (FL-0404) Affected Source Emission Limit Citation Emission Limitation (lbs S0 2 in rolling 24 hours) FL-404 500 lb S0 2 CEMS Summary FL-404 GOH Flare §60.107a(e)(1) 500 Monitor Manufacturer and Model No. ThermoScientific - SOLA 11 SL-10030914 Monitor Serial Number 12/06/2018 Date of Latest CMS Certification or Audit 07/01/2018 12/31/2018 Reporting Period Beginning Date Reporting Period Ending Date Total Time in Reporting Period Total Source Downtime (hours) 4416 (hours) 0 Total Source Operating Time in Reporting Period (hours) 4416 Number of Incidents 4 Duration (Hours) 39.00 0 0.00 185 9 0 1.00 25.00 0.00 198 65.00 CMS Performance Summary CMS downtime in reporting period due to: Monitoring Equipment Malfunctions Non-Monitoring Equipment Malfunctions (e.g., Computer, Data Recorder, Etc.) Quality Assurance/Quality Control Calibrations Other Known Causes Other Unknown Causes Totals Total CMS Downtime as a Percent of Total Source Operating Time Emission Data Summary Duration of excess emissions in reporting period due to: Startup Shutdown Control Equipment Problems Process Problems Other Known Causes Other Unknown Causes Totals Total Duration of Deviations as a Percent of Total Source Operating Time 1.47% Number of Incidents 1 0 0 0 1 0 2 Duration (Hours) 24.00 0.00 0.00 0.00 10.00 0.00 34.00 0.77% HFNA-000003241 EPA Inspection Report - Page 1692 of 1969 HollyFrontier Navajo Refining LLC Artesia, NM Refinery NSPS Subpart JA Periodic Report GOHT Flare (FL-0404) FL-404 500 lb S0 2 GEMS Downtime CEMS Downtime Affected Monitor Monitored Downtime Source Name Type HAP or Gas Start Date and Time Downtime End Date and Time Duration of Downtime (hours) Type of Downtime Period Type of Cause of Deviation Brief Description of Cause of Downtime Corrective Action Taken Changes to Emission Control 60.108a(d)(6) FL-404 CEMS so, 07/21/2018 08:42 07/21/2018 09:50 1.00 Quality Assurance Calibration other The analyzer was placed in calibration mode to The E&I technician ran calibration gases to the probe to check verify calibration values the analyzer and returned the analyzer to service. No changes were made in operation of the emission control system. FL-404 CEMS so, 07/30/2018 08:55 07/30/201811:50 3.00 Other Known Cause Other The analyzer was placed in maintenance mode The l&E technician changed the probe filter and returned the to perform maintenance analyzer to service. No changes were made in operation of the emission control system. FL-404 CEMS so, 08/22/2018 13:20 08/22/2018 15:15 1.00 Other Known Cause Other The analyzer was placed in maintenance mode The l&E Technician performed a CGA and returned the analyzer No changes were made in operation of the to perfonn a CGA. to service. emission control system. FL-404 CEMS so, 09/05/2018 05:00 09/05/2018 10:15 5.00 Monitor Equipment Malfunction Malfunction FL-404 CEMS so, 09/11/2018 13:30 09/11/201815:20 1.00 Other Known Cause FL-404 CEMS SO- 09/13/2018 23:00 09/14/2018 02:00 3.00 FL-404 CEMS so, 10/19/2018 04:30 10/20/2018 1000 FL-404 CEMS so, 11/05/2018 09:36 FL-404 CEMS SO- FL-404 CEMS FL-404 The l&E technician determined that the low pressure was The analyzer was placed in maintenance mode caused by sample pump contamination. The sample pump due to low sample pressure. head was cleaned, the pump rebuilt. and the analyzer was returned to service. No changes were made in operation of the emission control system. Other The analyzer was placed in maintenance mode The l&E technician replaced the sample pump assembly on the to perform maintenance SCS cabinet, and returned the analyzer to service. No changes were made in operation of the emission control system. Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode The l&E technician repaired the pump, replacing the diaphragm due to a sample pump failure. and valves, and returned the analyzer to service No changes were made in operation of the emission control system. 30.00 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode The l&E Technician recalibrated and returned the analyzer to due to a failed calibration. service. No changes were made in operation of the emission control system. 11/05/201811:34 1.00 Monitor Equipment Malfunction Malfunction The analyzer was placed in maintenance mode The l&E technician rebuilt the sample pump, and returned the due to a sample pump failure analyzer to service. No changes were made in operation of the emission control system. 11/16/2018 09:20 11/16/201811:30 1.00 Other Known Cause Other The analyzer was placed in maintenance mode The l&E technician performed a CGA and returned the analyzer No changes were made in operation of the to perfonm a CGA. to service emission control system. so, 11/26/2018 08:37 11/26/2018 11 :42 2.00 Other Known Cause Other The analyzer was placed in maintenance mode The l&E technician proceeded with the RSR project tie-ins and to complete project tie-ins. returned the analyzer to service. No changes were made in operation of the emission control system. CEMS so, 11/27/2018 09:00 11/27/201816:00 7.00 Other Known Cause Other The analyzer was placed in maintenance mode The l&E technician proceeded with the RSR project tie-ins and to complete project tie-ins. returned the analyzer to service No changes were made in operation of the emission control system. FL-404 CEMS so, 11/28/2018 07:40 11/28/201812:00 4.00 Other Known Cause Other The analyzer was placed in maintenance mode The l&E technician performed a linearity test and returned the to perform a linearity test. analyzer to service. No changes were made in operation of the emission control system. FL-404 CEMS so, 12/06/2018 10:36 12/06/2018 1222 1.00 Other Known Cause Other The analyzer was placed in maintenance mode The l&E technician performed a CGA and returned the analyzer No changes were made in operation of the to perfonm a CGA. to service. emission control system. FL-404 CEMS so, 12127/2018 08:05 12/27/2018 13:15 5.00 Other Known Cause other The l&E technician replaced the filter and rebuilt the pump The The analyzer was placed in maintenance mode sample system would not heat up. The pressure switch was No changes were made in operation of the due to plugged probe and pump reset and the system began to heat up, and the analyzer was emission control system. returned to service. Total 65.00 HFNA-000003242 EPA Inspection Report - Page 1693 of 1969 HollyFrontier Navajo Refining LLC Artesia, NM Refinery FL-404 500 lb S0 2 Excess Ernissi NSPS Subpart Ja Periodic Report GOHT Flare (FL-0404) GEMS Monitored Excess Emissions Affected Source Name Excess Emissions Monitor M~;i~o~~d Type Gas Start Date and Time FL-404 CEMS FL-404 CEMS so, Excess Emissions End Date and Time Excess Duration of excess Duration of Emissions emissions in Deviation Occurred reporting period (hours) During Period due to: ofSSM(Y/N) Brief Description of Nature and Cause of Excess Emission 09/24/2018 01 :DO 09/24/201811:00 1000 N Other Known Cause The electrical power supply from a third party substation to the Artesia Refinery ,,vas interrupted for approximately 3 hours, resulting in the shutdown of several process units, as well as several pumps, compressors and other electric pieces of equipment v.ithin the refinery. Off-gas was continued to be produced some time after the power outage occurred and the process units shut down. Without the electrical power to operate amine contactors and H 2S strippers, the H 2 S concentration in the FGS and Amine Unit increased. The flaring associated with the units' shutdown and subsequent startup resulted in emissions from the GOH Flare to exceed 500 lbs. S0 2 in a 24-hour period. 09/28/2018 23:00 09/29/2018 23:00 24.00 y Startup Planned shutdown of the Mild Hydrocracker (MHC) unit for catalyst replacement in the Guard Bed Reactor. The unit shutdown procedure was followed. During the shutdown and decontamination of the MHC. pressure normally builds up in the reactors and the fractionator, v,thich has to be relieved to the flare. Total 34.00 Corrective Action Taken or Preventative Measure Adopted Discharges Per 60.108a(d)(5) The electrical supply was promptly shifted to four additional substations that provi~e the electrical power to other sections of the refiner~, allowing See Attached Event Record: "#258201 the_electncal PO\~~~ to be restored. The fre_quency of pre\entat1ve . _ NSPS Ja RCA FL., 802 10 08 0404 maintenance act1V1t1es performed by the third-party electrical substation was increased from semiannual to monthly basis. The unit shutdown procedure was followed See Attached Event Record: "#26-201810-25 NSPS Ja RCA S02 FL-0404" HFNA-000003243 EPA Inspection Report - Page 1694 of 1969 NSPS SUBPART Ja ROOT CAUSE ANALYSYS Reporting Period:July-December 2018 HFNA-000003244 EPA Inspection Report - Page 1695 of 1969 #1-2018-08-28 FL-0400 NSPS JaFlow RCA Pagel of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: August 28, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from the North Flare (FL-0400) per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 06/16/2018, the North Flare (FL-0400) began exceeding its baseline threshold by >500,000 scfd while flaring. The excess flaring was caused by the SRU (Unit 31) thermal reactor (D-3100) being taken out of service to repair a crack near the acid gas inlet nozzle to the rear chamber. Rates were decreased through the area to move the acid and sour water gas to the other SRU (Unit 30). At approximately 15:00 on 07/12/2018 FL-0400 began exceeding its baseline threshold until approximately 18:00 on 07/13/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 07/12/2018 15 :00 Event Duration: 07/12/2018 15:00 -07/13/2018 18:00; 28 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) North Flare (FL-0400) 1,575,530 24-Hour Period 07/12/2018 15:00 - 07/12/2018 23:59 07/13/2018 00:00 - 07/13/2018 18:59 Quantity of Gas Discharged in 24-Hour Period (dsc:I) 735,530 840,000 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(]) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. HFNA-000003245 EPA Inspection Report - Page 1696 of 1969 #1-2018-08-28 FL-0400 NSPS JaFlow RCA Page 2 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S02 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess e1nissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Unit feed rates were reduced to mini1nize excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d). including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): North Flare (FL-0400) Date of Discharge: 07/12/2018 DurationofDischarge: 28 hours ROOT CAUSE ANALYSIS Unexpected shutdown of the SRU 2 (Unit 31) caused excess flaring to the North Plant Flare (FL-0400). CORRECTIVE ACTION ANALYSIS Unit feed rates were reduced so that excess flaring was minimized. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e). a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action Unit feed rates reduced Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003246 EPA Inspection Report - Page 1697 of 1969 #2-2018-08-28 FL-0400 NSPS JaFlow RCA Pagel of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: August 28, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from the North Flare (FL-0400) per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 07/16/2018, the North Flare (FL-0400) began exceeding its baseline threshold by >500,000 scfd while flaring. The excess flaring was caused by the fuel balance drum (D-19) receiving excess sweet gas from various units throughout the facility. At approximately 18:00 on 07/16/2018 FL-0400 began exceeding its baseline threshold until approximately 17:00 on 07/17/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 07/16/2018 18:00 Event Duration: 07/16/2018 18:00 -07/17/2018 17:00; 24 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) North Flare (FL-0400) 1,133,110 24-Hour Period 07/16/2018 18:00 - 07/16/2018 23:59 07/17/2018 00:00-17/17/2018 17:59 Quantity of Gas Discharged in 24-Hour Period (dscf) 342,780 790,330 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(]) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. HFNA-00000324 7 EPA Inspection Report - Page 1698 of 1969 #2-2018-08-28 FL-0400 NSPS JaFlow RCA Page 2 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S02 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess e1nissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Unit feed rates were reduced to mini1nize excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d). including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): North Flare (FL-0400) Date of Discharge: 07/16/2018 DurationofDischarge: 24 hours ROOT CAUSE ANALYSIS The fuel balance drum (D-19) reduced venting from the vessel to the flare. CORRECTIVE ACTION ANALYSIS Unit feed rates were reduced so that excess flaring was minimized. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e). a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action D-19 reduced venting Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003248 EPA Inspection Report - Page 1699 of 1969 #3-2018-10-05 FL-0400 NSPS JaFlow RCA Pagel of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: October 8, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from the North Flare (FL-0400) per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 09/24/2018, the North Flare (FL-0400) began exceeding its baseline threshold by >500,000 scfd while flaring. The Naphtha Hydrodesulfurization Unit (Unit 13) experienced a flange leak causing the Splitter Distillate Drum (D-44) and the Product Separator Drum (D-58) to empty to the flare so that repairs could be made. The unit was brought back online with additional malfunctions (EIV 13HIS181) and was shut-down again to repair EIV. The unit was brought back into service on 09/26/2018 with no additional issues. Steps were taken to prevent excess emissions during startup/shutdown/startup. Scavenger was injected to reduce H 2S in the flare. At approximately 03:00 on 09/24/2018 FL-0400 began exceeding its baseline threshold until approximately 18:00 on 09/27/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 09/24/2018 03 :00 Event Duration: 09/24/2018 03 :00 - 09/27/2018 18:00; 88 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) North Flare (FL-0400) 5,210,970 24-Hour Period 09/24/2018 09/25/2018 09/26/2018 09/27/2018 03:00 00:00 00:00 00:00 Quantity of Gas Discharged in 24-Hour Period (dsc:I) - 09/24/2018 09/25/2018 09/26/2018 09/27/2018 23:59 23:59 23:59 18:00 1,712,370 1,321,350 1,326,530 850,720 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60 I02a(g)(I) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. HFNA-000003249 EPA Inspection Report - Page 1700 of 1969 #3-2018-10-05 FL-0400 NSPS JaFlow RCA Page 2 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 60.108a(c)(6) (vi) For each discharge greater than 5001bs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. 60.108a(c)(6) (vii) For each discharge greater than 5001bs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Unit feed rates were reduced to minimize excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d), including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause( s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): North Flare (FL-0400) Date of Discharge: 09/24/2018 Duration of Discharge: 88 hours ROOT CAUSE ANALYSIS The Naphtha Hydrodesulfurization Unit (Unit 13) e;,.,.1)erienced a flange leak causing the Splitter Distillate Drum (D-44) and the Product Separator Drum (D-58) to empty to the flare so that repairs could be made. The unit was brought back online with additional malfm1ctions (EIV 13HIS181) and was shutdown again to repair EIV. The unit was brought back into service on 09/26/2018 with no additional issues. CORRECTIVE ACTION ANALYSIS Steps were taken to repair the flange and then the EIV. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60. l03a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action Repairs made Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planued startup or shutdown of a refinery process unit or ancillary equipment conuected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003250 EPA Inspection Report - Page 1701 of 1969 4 F: #4-2018-10-08 NSPS JaRCA S02 FL-0400 Page 1 of2 ................................................................................................................HollyFrontier Navajo Refining LLC HOLLYFRONTIER 501 E. Main Artesia, NM 88201 (575) 748-3311 DATE: October 8, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for S0 2 from Flares per 60. l03a(c)(l) I 60.l08a(c)(6)(i) A description of the discharge. Unexpected shutdown of the Naphtha Hydrotreating Unit (Unit 13) due to a flange leak. This caused the Naphtha Separator (D-0058) and Splitter Distillate (D-0044) to vent to the North Flare (FL-0400), resulting in emissions above the reporting threshold. I 60.l08a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 09/24/2018 07:00 Event Duration: 09/24/2018 07:00 - 09/27/2018 18:00; 69 hours 60. l08a( c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.l07a(g). Affected Facility(s) 24-hour Period North Flare FL-0400 09/24/2018 09/25/2018 09/26/2018 09/27/2018 07:00 14:00 00:00 00:00 - 09/24/2018 09/25/2018 09/26/2018 09/27/2018 22:59 23:59 23:59 18:59 Quantity of Gas Discharged over Event Duration (dscf) L026,840 633,000 L326,530 850,720 60.l08a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Date 09/24/2018 09/25/2018 09/26/2018 09/27/2018 Number of hours 07:00 14:00 00:00 00:00 - 09/24/2018 09/25/2018 09/26/2018 09/27/2018 22:59 23:59 23:59 18:59 16 10 24 19 Hourly Average Measured Total Sulfur Concentration During Event (ppm) {60.l08a(c)(6)(iv)} 1,193 23,781 6,175 248 60.l08a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(l) from a fuel gas combustion device, either the measured concentration ofH 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60. l07a(e)( 4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. HFNA-000003251 EPA Inspection Report - Page 1702 of 1969 #4-2018-10-08 NSPS JaRCA S02 FL-0400 Page 2 of2 .....................................................................................................................................................................................HollyFrontier ..Navajo...RefiningLLC 501 E. Main Artesia, NM 88201 (575) 748-3311 Not applicable to this event. 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Affected Facility North Flare (FL-0400) Cumulative Quantity ofH 2S Released (pounds) 27 Cumulative Quantity of S02 Released (pounds) 5,055 I 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. The flange was repaired. The gas was safely combusted in a steam-assisted flare and scavenger was i1tjected into the system. Maintenance worked quickly to detennine what steps needed to be taken to reduce excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d), including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause( s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): North Flare (FL-0400) Date of Discharge: 09/24/2018 Duration of Discharge: 69 hours ROOT CAUSE ANALYSIS Unexpected shutdown of the Naphtha Hydrotreating Unit (Unit 13) due to a flange leak. This caused the Naphtha Separator (D-0058) and Splitter Distillate (D-0044) to vent to the North Flare (FL-0400). resulting in emissions above the reporting threshold. CORRECTIVE ACTION ANALYSIS The leak was repaired. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action The leak was repaired Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003252 EPA Inspection Report - Page 1703 of 1969 4 F: #5-2018-11-26 FL-0400 NSPS Ja S02 RCA Page 1 of2 Hollyfrnnti~r N~v~jq R~fining lJ,C HOLLYFRONTIER 501 E. Main Artesia, NM 88201 (5 75) 748-3311 DATE: November 26, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for S0 2 from Flares per 60.103a(c)(]) I 60 .108a(c)(6)(i) Adescription of the discharge. Process imbalance in the NHU debutanizer system, which included a pressure increase in the splitter overhead system, and resulted in venting ofoverhead gases with high sulfur (S) content from the Splitter Distillate Drum (D-0044). The associated flare emissions exceeded 500pounds of sulfur dioxide (S0 2) on a 24-hour basis. I 60 .108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 11/08/2018 18:00 Event Duration: l l/08/201818:00-1l/09/201817:00: 24 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). 24-hour Period Affected Facility(s) North Flare FL-0400 11/08/201818:00- l l/09/2018 17:00 Quantity of Gas Discharged over Event Duration(dscf) 1,036,940 60.] 08a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2 S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Date 11/08/2018 18:00- 11/09/2018 17:00 Number of hours 24 Hourly Average Measured Total Sulfur Concentration During Event (ppm) {60.108a(c)(6)(iv)} 3,439.8 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60 l 02a(g)(l) from a fuel gas combustion de"ice, either the measured concentration ofH 2 S in the fuel gas or the measured concentration of S02 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion de-vices, but cannot be used to make these estimates for flares, except as provided in I §60.107a(e)(4). Not applicable to this event. 60 .108a(c)(6) (-vi) For each discharge greater than 5 OOlbs S02 in excess of the allowable limits from a sulfur recovery pl ant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. 60 .108a(c)(6) (-vii) For each discharge greater than 5 OOlbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the HFNA-000003253 EPA Inspection Report - Page 1704 of 1969 #4-2018-10-08 NSPS Ja RCA S02 FL-0400 Page 2 of2 H<::>IIYfr9nJiE:lL Nc:1vc:1j9 RE:ifining J,,1.,,G 501 E. Main Artesia, NM 88201 (5 75) 748-3311 cumulative quantity ofH 2 S and S02 released into the atmosphere. For releases controlled by flares. asslUne 99-percent conversion of reduced sulfur or total sulfur to S02 For fuel gas combustion devices, assllllle 99-percent conversion ofH 2 S to S02 . Affected Facility North Flare (FL-0400) ClUllulative Quantity ofH 2 S Released (pounds) 27 ClUllulative Quantity of S02 Released (pounds) 5,055 I 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas was safely combusted in a steam-assisted flare and scavenger was injected into the system. Maintenance worked quickly to determine what steps needed to be taken to reduce excess flaring. 60 .108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in § 60. l 03a(d), including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60. l 03a(e). AffectedFacility(s): North Flare (FL-0400) Date ofDischarge: 11/08/2018 Duration of Discharge: 24 hours ROOT CAUSE ANALYSIS Process imbalance in the NHU debutanizer system, which included a pressure increase in the splitter overhead system, and resulted in venting of overhead gases with high sulfur (S) content from the Splitter Distillate Drlllll (D-0044). TI1e associated flare emissions exceeded 500 pounds of sulfur dioxide (S02) on a 24-hour basis. CORRECTIVE ACTION ANALYSIS After the unit shutdown, the flat cap in X-0341 was tightened, thereby eliminating the leak. The Naphtha Hydrotreating Unit (NHU, Unit 13) started up and was returned to normal operation as expeditiously as possible. Additional corrective actions may be implemented pending the outcome of the above-described further root cause analysis for the Feed Pre heater (X-0342), and an update will be submitted within thirty days after completion of the implementation of any such additional corrective actions. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action The flat cap in X-03 41 . Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a plmmed startup or shutdo"11 of a refinery process unit or m1cillary equipment connected to the affected flare. a statement that a root cause analysis m1d corrective action analysis are not necessary because the oy,,ner or operator followed the flare management plan. Not applicable to this event. HFNA-000003254 EPA Inspection Report - Page 1705 of 1969 4 F: #6-2018-12-27 NSPS JaRCA S02 FL-0400 Page 1 of2 ...............................................................................................................HollyFrontier Navajo RefiningLLC HOLLYFRONTIER 501 E. Main Artesia, NM 88201 (575) 748-3311 DATE: December 27, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for S0 2 from Flares per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. Process imbalance in the NHU debutanizer system, which included a pressure increase in the splitter overhead system, and resulted in venting of overhead gases with high sulfur (S) content from the Splitter Distillate Drum (D-0044). The associated flare emissions exceeded 500 pounds of sulfur dioxide (S0 2) on a 24-hour basis. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 12/07/2018 22:00 Event Duration: 12/07/2018 22 :00 - 12/09/2018 09:00; 36 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) North Flare (FL-0400) 24-hour Period 12/07/2018 22:00 -12/07/2018 23:59 12/08/2018 00:00 - 12/08/2018 23 :59 12/09/2018 00:00 - 12/09/2018 09:59 Quantity of Gas Discharged over Event Duration (dscf) 83,470 884,020 352,770 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2 S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Date 12/07/2018 22:00 - 12/07/2018 23:59 12/08/2018 00:00 - 12/08/2018 23 :59 12/09/2018 00:00 - 12/09/2018 09:59 Number of hours 2 24 10 Hourly Average Measured Total Sulfur Concentration During Event (ppm) {60.108a(c)(6)(iv)} 36289 3,114 790 60.108a(c)(6)(v) For each discharge ,greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(l) from a fuel gas combustion device, either the measured concentration ofH 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. HFNA-000003255 EPA Inspection Report - Page 1706 of 1969 #6-2018-12-27 NSPS JaRCA S02 FL-0400 Page 2 of2 .....................................................................................................................................................................................HollyFrontier ..Navajo...RefiningLLC 501 E. Main Artesia, NM 88201 (575) 748-3311 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2S to S02. Affected Facility North Flare (FL-0400) Cumulative Quantity ofH 2S Released (pounds) 6.06 Cumulative Quantity of S02 Released (pounds) 1,130 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess e1nissions on ambient air quality. The gas was safely combusted in a steam-assisted flare and scavenger was injected into the system. Maintenance worked quickly to detennine what steps needed to be taken to reduce excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d), including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): North Flare (FL-0400) Date of Discharge: 12107/2018 Duration of Discharge: 36 hours ROOT CAUSE ANALYSIS Process imbalance in the NHU debutanizer system, which included a pressure increase in the splitter overhead system, and resulted in venting of overhead gases with high sulfur (S) content from the Splitter Distillate Drum (D-0044 ). The associated flare emissions exceeded 500 pounds of sulfur dioxide (S0 2) on a 24-hour basis. CORRECTIVE ACTION ANALYSIS The standard procedure for unit shutdown was followed. After the unit shutdown was completed, Feed Preheater (X0342) was by-passed for inspection and cleaning, as needed. After the exchanges was isolated and by-passed, the Naphtha Hydrotreating Unit (NHU, Unit 13) was started up and was returned to normal operation as expeditiously as possible. Additional corrective actions may be implemented pending the outcome of the above-described further root cause analysis for the Feed Preheater (X-0342), and an update will be submitted within thirty days after completion of the implementation of any such additional corrective actions. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed conunencement and completion dates. Corrective Action Repairs were made. Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003256 EPA Inspection Report - Page 1707 of 1969 #7-2018-08-28 FL-0402 NSPS JaFlow RCA Pagel of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: August 29, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from the FCCU Flare (FL-0402) per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 07/21/2018, the Fluid Catalytic Cracking Unit (FCC, Unit 10) had a loss of compressor (C-0945) for the Lift Air Blower. This caused a shut-down of the FCC unit. Losing the compressor causes swing in the unit due to an air imbalance. Emergency steam kicks in to prevent plugging and causes back pressure in the Main Air Blower. Safeguards that are in place cause a shut-down of the unit automatically to prevent a more significant event. Instrument techs, electricians and maintenance were called out to check systems and found no known causes. A malfunction of the Bently Nevada Vibration Relay is believed to be the cause of the flaring event but further investigations are pending. At approximately 18:00 on 07/22/2018 FL-0402 began exceeding its baseline limit until approximately 17 :00 on 07/23/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 07/22/2018 18:00 Event Duration: 07/22/2018 18:00 -07/23/2018 17:00; 24 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) FCCU Flare (FL-0402) 697,930 24-Hour Period 07/22/2018 18:00 - 07/22/2018 23:59 07/23/2018 00:00 - 07/23/2018 17:00 Quantity of Gas Discharged in 24-Hour Period (dsc:I) 526,320 171,610 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or botl1 the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(]) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S02 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of tl1e allowable li1nits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. HFNA-000003257 EPA Inspection Report - Page 1708 of 1969 #7-2018-08-28 FL-0402 NSPS Ja Flow RCAPa Page 2 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 Not applicable to this event. 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Repairs were made to C-0952 to minimize excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d), including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause( s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60. l03a(e). Affected Facility(s): FCCU Flare (FL-0402) Date of Discharge: 07/2212018 Duration of Discharge: 24 hours ROOT CAUSE ANALYSIS On 07/21/2018, the Fluid Catalytic Cracking Unit (FCC, Unit 10) had a loss of compressor (C-0945) compressor for the Lift Air Blower. This caused a shutdown of the FCC unit. Losing the compressor causes swing in the unit due to an air imbalance. Emergency steam kicks in to prevent plugging and causes back pressure in the Main Air Blower. Safeguards that are in place cause a shut-down of the unit automatically to prevent a more significant event. CORRECTIVE ACTION ANALYSIS The root cause analysis indicates that vibration of the C-0945 Lift Air Blower caused the Bently Nevada Vibration relay to lose electrical contact, which in tum caused the loss of the Lift Air Blower. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60. l03a(e), a description oftl1e corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action Electricians reset the tripped relay after the Lift Air Blower tripped. Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003258 EPA Inspection Report - Page 1709 of 1969 #8-2018-09-05 FL-0402 NSPS JaFlow RCA Pagel of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: September 5, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from the FCCU Flare (FL-0402) per 60. l03a(c)(l) I 60.l08a(c)(6)(i) A description of the discharge. On 08/27/2018, the Fluid Catalytic Cracking Unit (FCC, Unit 10) began exceeding its baseline limit. This was due to scheduled maintenance for repairs of the Alky Flare (FL-0403). Charges were reduced to reduce excess flow flaring until the exceedance could be minimized. At approximately 03 :00 on 08/27/2018 FL-0402 began exceeding its baseline limit until approximately 00:00 on 09/03/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 08/27/2018 Event Duration: 08/27/2018 03 :00 - 09/03/2018 00:00; 166 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) FCCU Flare (FL-0402) 38,526,300 24-Hour Period 08/27/2018 03:00 - 08/27/2018 23:59 08/28/2018 00:00 - 08/28/2018 23:59 08/29/2018 00:00 - 08/29/2018 23:59 08/30/2018 00:00 - 08/30/2018 23:59 08/31/2018 00:00 - 08/31/2018 23:59 09/01/2018 00:00 - 09/01/2018 23:59 09/02/2018 00:00 - 09/02/2018 23:59 09/03/2018 00:00 - 09/03/2018 00:59 Quantity of Gas Discharged in 24-Hour Period (dsc:I) 6,109,150 5,526,610 6,529,930 6,520,590 6,528,810 6,275,250 1,025,760 10,200 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(]) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. HFNA-000003259 EPA Inspection Report - Page 1710 of 1969 #8-2018-09-05 FL-0402 NSPS JaFlow RCA Page 2 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 60.108a(c)(6) (vi) For each discharge greater than 5001bs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. 60.108a(c)(6) (vii) For each discharge greater than 5001bs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S02 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess e1nissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d). including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): FCCU Flare (FL-0402) Date of Discharge: 08/27/2018 Duration of Discharge: 166 hours ROOT CAUSE ANALYSIS On 0812712018, the Fluid Catalytic Cracking Unit (FCC, Unit 10) began exceeding its baseline limit. This was due to scheduled 1naintenance for repairs of the Alky Flare (FL-0403). CORRECTIVE ACTION ANALYSIS Charges were reduced to drop excess flow flaring until the exceedance could be minimized. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60. l03a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed conunencement and completion dates. Corrective Action Reduced charges Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planued startup or shutdown of a refinery process unit or ancillary equipment conuected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003260 EPA Inspection Report - Page 1711 of 1969 #9-2018-10-08 FL-0402 NSPS Ja Flow RCA Page 1 of2 HollyFrontier Navajo Refining LLC ·H.OLLYF.RONTIER ··········································································································································································· ······················.P.O.··Bex 1fill Artesia, NM 88211 (575) 365-8365 DATE: October 8, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfdfrom the FCCUFlare (FL-0402) per 60.l 03a(c)(l) I 60 .108a(c)(6)(i) Adescription of the discharge. On 09/05/2018, the Fluid Catalytic Cracking Unit (FCC, Unit l 0) Flare began exceeding its baseline threshhold. Tiris was due to the loss of a compressor (C-0945) for the Lift Air Blower. This caused a shutdo"'n of the FCC Unit. Losing C-0945 causes a rning in the Unit due to an air imbalance. Emergency stean1 kicked in to prevent plugging and caused back pressure in the Main Air Blower. Safeguards in place caused a shut-do"'n of the unit automatically to prevent a more significant event. Instrument technicians, electricians, and maintenance checked systems and found that C-0945 had unexpectedly tripped. At approximately 04:00 on 09/05/2018FL-0402 began exceeding its baseline threshhold tmtil approximately 04:00 on 09/06/2018. I 60 .108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date& Time: 09/05/2018 Event Duration: 09/05/2018 04:00- 09/06/2018 04:00; 25 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) FCCU Flare (FL-0402) 1,095,600 24-Hour Period Quantity of Gas Discharged in 24-Hour Period (dscf) 09/05/2018 04:00- 09/05/2018 23 :59 09/06/2018 00:00- 09/06/2018 04:59 1,047,600 48,000 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hourperiod from a flare, the measured total sulfur concentration or both the measured H 2 S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.I08a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60 l 02a(g)(l) from a fuel gas combustion de"ice, either the measured concentration ofH 2 S in the fuel gas or the measured concentration of S02 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion de-vices, but cannot be used to make these estimates for flares, except as provided in §60.I07a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery pl ant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. HFNA-000003261 EPA Inspection Report - Page 1712 of 1969 #9-2018-10-08 FL-0402 NSPS Ja Flow RCA Page 2 of2 HollyFrontier Navajo Refining LLC ··········································································································································································· ······················.P.O.··Bex 1fill Artesia, NM 88211 (575) 365-8365 Not applicable to this event. 60 .108a(c)(6) (vii) For each discharge greater than 5 OOlbs S02 in any 24-hour period from any affected flare or discharge greater than 5 OOlbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity ofH 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02 . Not applicable to this event. I 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas \\as safely combusted in a steam-assisted flare. Repairs were made to C-0952 to minimize excess flaring. 60 .108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in § 60.1 03a(d), including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). AffectedFacility(s): FCCUFlare (FL-0402) Date of Discharge: 0910512018 DurationofDischarge: 25 hours ROOT CAUSE ANALYSIS On 09105/2018, the Fluid Catalytic Cracking Unit (FCC, Unit 10) Flare began exceeding its baseline limit. This was due to an unexpected trip ofC-0945. A nuisance trip of the GE Multilins 369 motor protection relay, a component of the C0945 Lift Air Blower (see below) caused the loss of the Lift Air Blower. The loss ofC-0945 Lift Air Blower caused a shutdown of the FCC Unit. CORRECTIVE ACTION ANALYSIS Electricians replaced the GE Multilins 369 motor protection relay. A Preventative Maintenance work order has been generated so this relay will be inspected annually. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action Electricians replaced the GE Multilins 369 motor protection relay. A Preventative Maintenance work order has been generated so this relay will be inspected annually. Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60. l 08a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003262 EPA Inspection Report - Page 1713 of 1969 #10-2018-10-25 FL-0402 NSPS JaBaseline Flow RCA Pagel of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: October 25, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from the FCC Flare (FL-0402) baseline per 60.103a(c)(l) I 60.108a(c)(6)(i) A descriptionofthe discharge. On 09/25/2018, the FCC Flare (FL-0402) began exceeding its baseline threshold. This was due to a power outage that affected Units 33 (Diesel Hydrotreater), 44 (Distillate Hydrodesulfurization), 45 (GOH), 70 (CCR), 10 (FCC), and the North Plant. The affected units ended up causing excess flaring to the FCC Flare. The outage lasted approximately 2-3 hours. At approximately 14:00 on 09/25/2018 FL-0402 began exceeding its alternative baseline threshold until approximately 12 :00 on 09/26/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 09/25/2018 14 :00 Event Duration: 09/25/2018 14:00 - 09/26/2018 12:00; 23 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) FCC Flare (FL-0402) 642,000 24-Hour Period 09/25/2018 13:00 - 09/25/2018 23:59 09/26/2018 00:00 - 09/26/2018 12:59 Quantity of Gas Discharged in 24-Hour Period (dscf) 496,340 145,660 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(]) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable li1nits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. HFNA-000003263 EPA Inspection Report - Page 1714 of 1969 #10-2018-10-25 FL-0402 NSPS JaBaseline Flow RCA Page 2 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60.108a(c)(6) (viii) The steps that the owner or operator took to linlit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Unit feed rates were reduced to mini1nize excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d), including an identification of the affected facility, the date and duration of the discharge. a statement noting whether the discharge resulted from the same root cause( s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60. l03a(e). Affected Facility(s): FCC Flare (FL-0402) Date of Discharge: 09/25/2018 Duration of Discharge: 23 hours ROOT CAUSE ANALYSIS A power outage led to an excess of flaring. CORRECTIVE ACTION ANALYSIS Power was restored for the Plant. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation. including proposed commencement and completion dates. Corrective Action Power was restored for the plant Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003264 EPA Inspection Report - Page 1715 of 1969 4 F: #11-2018-08-28 FL-402 NSPS Ja RCA S02 Pagel of3 ...............................................................................................................HollyFrontier Navajo RefiningLLC HOLLYFRONTIER 501 E. Main Artesia, NM 88201 (575) 748-3311 DATE: June 18, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for S0 2 from Flares per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 07/21/2018, the Fluid Catalytic Cracking Unit (FCC, Unit 10) had a loss of compressor (C-0945) compressor for the Lift Air Blower. This caused a shutdown of the FCC unit. Losing the compressor causes swing in the unit due to an air imbalance. Emergency steam kicked in to prevent plugging and causes back pressure in the Main Air Blower. Safeguards in place caused a shut-down of the unit aut01uatically to prevent a more significant event. Instrument techs, electricians and maintenance were called out to check systems and found no known causes. A malfunction of the Bently Nevada Vibration Relay is believed to be the cause of the flaring event but further investigations are pending. At approximately 03 :00 on 07/22/2018 FL-0402 began exceeding its baseline limit until approximately 18:00 on 07/23/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 07/22/2018 03 :00 Event Duration: 07/22/2018 03 :00 - 07/23/2018 18:00; 40 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) FCC Flare FL-0402 24-hour Period 07/22/2018 03:00 - 07/22/2018 23:59 07/23/2018 00:00 - 07/23/2018 18:00 Quantity of Gas Discharged over Event Duration (dscf) 997,220 181,090 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Date 07/22/2018 03:00 - 07/22/2018 23:59 07/23/2018 00:00 - 07/23/2018 18:00 Number of hours 21 19 Hourly Average Measured Total Sulfur Concentration During Event (ppm) {60.108a(c)(6)(iv)} 23,387.80 194.92 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(1) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. HFNA-000003265 EPA Inspection Report - Page 1716 of 1969 #11-2018-08-28 FL-402 NSPS Ja RCA S02 Page 2 of3 .....................................................................................................................................................................................HollyFrontier ..Navajo...RefiningLLC 501 E. Main Artesia, NM 88201 (575) 748-3311 60.108a(c)(6) (vi) For each discharge greater than 5001bs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S02 discharged to the atmosphere. Not applicable to this event. 60.108a(c)(6) (vii) For each discharge greater than 5001bs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant. the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Affected Facility FCC (FL-0402) Cumulative Quantity ofH 2S Released (pounds) 16.50 Cumulative Quantity of S02 Released (pounds) 3,074.95 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Maintenance worked quickly to determine what steps needed to be taken to reduce excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d), including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause( s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): FCC Flare (FL-0402) Date of Discharge: 07/2212018 - 07/23/2018 Duration of Discharge: 40 hours ROOT CAUSE ANALYSIS On 07/21/2018, the Fluid Catalytic Cracking Unit (FCC, Unit 10) had a loss of compressor (C-0945) compressor for the Lift Air Blower. This caused a shutdown of the FCC unit. Losing the compressor causes swing in the unit due to an air imbalance. Emergency steam kicks in to prevent plugging and causes back pressure in the Main Air Blower. Safeguards that are in place cause a shut-down of the unit automatically to prevent a more significant event. CORRECTIVE ACTION ANALYSIS Weekly monitoring data indicated a change in the vibration noise of the C-0949 gearbox. Based on our inspection, the gear teeth were damaged due to unknown causes. Our review shows that the gear box has nm for approximately 20 years and had a preventative maintenance schedule for inspection during every tum-around. The last complete inspection was done 02/2017 during our last major tum-around. The oil filters were change the week of 05107/2018. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed conunencement and completion dates. Corrective Action Repairs to C-0949 gear box Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA HFNA-000003266 EPA Inspection Report - Page 1717 of 1969 #11-2018-08-28 FL-402 NSPS Ja RCA S02 Page 3 of3 .....................................................................................................................................................................................HollyFrontier ..Navajo...RefiningLLC 501 E. Main Artesia, NM 88201 (575) 748-3311 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003267 EPA Inspection Report - Page 1718 of 1969 4 F: #12-2018-09-04 NSPS JaRCA S02 FL-0402 Page 1 of3 ...............................................................................................................HollyFrontier Navajo RefiningLLC HOLLYFRONTIER 501 E. Main Artesia, NM 88201 (575) 748-3311 DATE: September 4, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for S0 2 from Flares per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 08/27/2018, the Fluid Catalytic Cracking Unit (FCC, Unit 10) began exceeding its S0 2 limit. This was due to scheduled maintenance for repairs of the Alky Flare (FL-0403). Charges were reduced to reduce S02 flaring until the exceedance could be minimized. At approximately 09:00 on 08/27/2018 FL-0402 began exceeding its S02 limit until approximately 09:00 on 08/31/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 08/27/2018 09:00 Event Duration: 08/27/2018 09:00 - 08/31/2018 09:00; 97 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) 24-hour Period FCC Flare FL-0402 08/27/2018 08/28/2018 08/29/2018 08/30/2018 08/31/2018 09:00 00:00 00:00 00:00 00:00 - 08/27/2018 08/28/2018 08/29/2018 08/30/2018 08/31/2018 23:59 23:59 23:59 23:59 09:59 Quantity of Gas Discharged over Event Duration (dscf) 4,703,060 5,526,610 6,529,930 6,520,590 2,723,710 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Date 08/27/2018 08/28/2018 08/29/2018 08/30/2018 08/31/2018 Number of hours 09:00 00:00 00:00 00:00 00:00 - 08/27/2018 08/28/2018 08/29/2018 08/30/2018 08/31/2018 23:59 23:59 23:59 23:59 09:59 15 24 24 24 10 Hourly Average Measured Total Sulfur Concentration During Event (ppm) {60.108a(c)(6)(iv)} 1,387 1,193 2,382 1,419 227 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(]) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). HFNA-000003268 EPA Inspection Report - Page 1719 of 1969 #12-2018-09-04 NSPS JaRCA S02 FL-0402 Page 2 of3 .....................................................................................................................................................................................HollyFrontier ..Navajo...RefiningLLC 501 E. Main Artesia, NM 88201 (575) 748-3311 Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Affected Facility FCC (FL-0402) Cumulative Quantity ofH 2S Released (pounds) 34.0 Cumulative Quantity of S02 Released (pounds) 6,346.5 I 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Maintenance worked quickly to determine what steps needed to be taken to reduce excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d). including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): FCC Flare (FL-0402) Date of Discharge: 08/27/2018 Duration of Discharge: 97 hours ROOT CAUSE ANALYSIS On 0812712018, the Fluid Catalytic Cracking Unit (FCC, Unit 10) began exceeding its S0 2 limit. This was due to scheduled maintenance for repairs of the Alky Flare (FL-0403). CORRECTIVE ACTION ANALYSIS Charges were reduced to drop S02 flaring until the exceedance could be minimized. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60. l03a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed conunencement and completion dates. Corrective Action Charges were reduced Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA HFNA-000003269 EPA Inspection Report - Page 1720 of 1969 #12-2018-09-04 NSPS JaRCA S02 FL-0402 Page 3 of3 .....................................................................................................................................................................................HollyFrontier ..Navajo...RefiningLLC 501 E. Main Artesia, NM 88201 (575) 748-3311 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003270 EPA Inspection Report - Page 1721 of 1969 4 F: #13-2018-10-08 NSPS Ja RCA S02 FL-0402 Page 1 of3 H<::>IIYfr9nJiE:lL Nc:1vc:1j9 RE:ifining J,,1.,,G HOLLYFRONTIER 501 E. Main Artesia, NM 88201 (5 75) 748-3311 DATE: October 8, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for S0 2 from Flares per 60.103a(c)(]) I 60 .108a(c)(6)(i) Adescription of the discharge. On 09/04/2018, the Fluid Catalytic Cracking Unit (FCC, Unit 10) began exceeding its S02 limit. This was due to the loss of a compressor (C-0945) for the Lift Air Blower. This caused a shutdown of the FCC Unit. Losing C-0945 caused a swing in the Unit due to an air imbalance. Emergency steam kicked in to prevent plugging and caused back pressure in the Main Air Blower. Safe guards in place caused a shut-do~n of the unit automatically to prevent a more significant event. Instrument technicians, electricians, and maintenance checked systems and found that C-0945 had unexpectedly tripped. At approximately 16:00 on 09/04/2018FL-0402 began exceeding its S02 limit until approximately 05:00 on 09/06/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 09/04/2018 16:00 Event Duration: 09/04/201816:00-09/06/2018 05:00; 38 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). 24-hour Period Affected Facility(s) FCC Flare FL-0402 09/04/201816:00- 09/04/2018 23:59 09/05/2018 00:00- 09/05/20! 8 23:59 09/06/2018 00:00- 09/06/20!8 05:59 Quantity of Gas Discharged over Event Duration(dscf) 173,250 1,110,860 58,850 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2 S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Date 09/04/2018 16:00- 09/04/2018 23:59 09/05/2018 00:00- 09/05/2018 23:59 09/06/2018 00:00- 09/06/2018 05:59 Number of hours 8 24 6 Hourly Average Measured Total Sulfur Concentration During Event (ppm) {60.108a(c)(6)(iv)} 28,909 5,372 776 60 .108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60 l 02a(g)(l) from a fuel gas combustion de"ice, either the measured concentration ofH 2 S in the fuel gas or the measured concentration of S02 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. HFNA-000003271 EPA Inspection Report - Page 1722 of 1969 #13-2018-10-08 NSPS Ja RCA S02 FL-0402 Page 2 of3 H<::>IIYfr9nJiE:lL Nc:1vc:1j9 RE:ifining J,,1.,,G 501 E. Main Artesia, NM 88201 (5 75) 748-3311 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery pl ant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. 60 .108a(c)(6) (vii) For each discharge greater than 5 OOlbs S02 in any 24-hour period from any affected flare or discharge greater than 5 OOlbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity ofH 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S02 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02 . Affected Facility FCC (FL-0402) Cmnulative Quantity ofH 2 S Re leased (potmds) 12.5 Cumulative Quantity of S02 Released (pounds) 2,337 I 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas \\as safely combusted in a steam-assisted flare and scavenger was injected into the system. Maintenance worked quickly to determine what steps needed to be taken to reduce excess flaring. 60 .108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in § 60.1 03a(d), including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). AffectedFacility(s): FCC Flare (FL-0402) Date of Discharge: 0910412018 DurationofDischarge: 38 hours ROOT CAUSE ANALYSIS On 09104/2018, the Fluid Catalytic Cracking Unit (FCC, Unit 10) began exceeding its S02 limit. This \\as due to the loss of a compressor (C-0945) for the Lift Air Blower. A root cause analysis \\as conducted which determined that the probable cause of the loss of the blower was a nuisance trip of the GE Multilins 369 motor protection relay, a component of the C-0945 Lift Air Blower that \\as in use beyond its recommended life. The root cause of the trip is mechanical fatigue. CORRECTIVE ACTION ANALYSIS Electricians replaced the GE Multilins 369 motor protection relay. A Preventative Maintenance work order has been generated so this relay will be inspected annually. 60. l 08a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60. l03a( e). a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action C-0945 \\as restarted Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA HFNA-000003272 EPA Inspection Report - Page 1723 of 1969 #13-2018-10-08 NSPS Ja RCA S02 FL-0402 Page 3 of3 Hollyfrnnti~r N~v~jq R~fining lJ,C 501 E. Main Artesia, NM 88201 (5 75) 748-3311 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003273 EPA Inspection Report - Page 1724 of 1969 4 F: #14-2018-10-25 NSPS JaRCA S02 FL-0402 Page 1 of2 ...............................................................................................................HollyFrontier Navajo RefiningLLC HOLLYFRONTIER 501 E. Main Artesia, NM 88201 (575) 748-3311 DATE: October 25, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for S0 2 from Flares per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 09/24/2018, the FCC Flare (FL-0402) began exceeding its S02 threshold. This was due to a power outage that affected Units 33 (Diesel Hydrotreater), 44 (Distillate Hydrodesulfurization), 45 (GOH), 70 (CCR), 10 (FCC), and the North Plant. The flaring associated with the units's shutdown and subsequent startup resulted in emissions from the FCC Flare (FL-0402) to exceed 500 lbs S0 2 in a 24-hour period. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 09/25/2018 14:00 Event Duration: 09/25/2018 14:00 - 09/26/2018 14:00; 25 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) FCC Flare FL-0402 24-hour Period 09/25/2018 14:00 - 09/26/2018 14:59 Quantity of Gas Discharged over Event Duration (dscf) 664,520 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2 S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Date 09/25/2018 14:00 - 09/25/2018 23:59 09/26/2018 00:00 - 09/26/2018 14:59 Number of hours 10 15 Hourly Average Measured Total Sulfur Concentration During Event (ppm) {60.108a(c)(6)(iv)} 75,105 3,014 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(l) from a fuel gas combustion device, either the measured concentration ofH 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. HFNA-00000327 4 EPA Inspection Report - Page 1725 of 1969 #14-2018-10-25 NSPS JaRCA S02 FL-0402 Page 2 of2 .....................................................................................................................................................................................HollyFrontier ..Navajo...RefiningLLC 501 E. Main Artesia, NM 88201 (575) 748-3311 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant. the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2S to S02. Affected Facility FCC Flare (FL-0402) Cumulative Quantity ofH 2S Released (pounds) 7.0 Cumulative Quantity of S02 Released (pounds) 1,297 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas was safely combusted in a steam-assisted flare and scavenger was injected into the system. Maintenance worked quickly to determine what steps needed to be taken to reduce excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d), including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause( s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): FCC Flare (FL-0402) Date of Discharge: 09/25/2018 DurationofDischarge: 25 hours ROOT CAUSE ANALYSIS An unexpected power outage affected Units 33 (Diesel Hydrotreater), 44 (Distillate Hydrodesulfurization), 45 (GOH), 70 (CCR), 10 (FCC), and the North Plant. The affected units ended up causing excess S02 flaring to the FCC Flare. The outage lasted approximately 2-3 hours. CORRECTIVE ACTION ANALYSIS The electrical supply was promptly shifted to four additional substations that provide the electrical power to other sections of the refinery, allowing the electrical power to be restored. The frequency of preventative maintenance activities performed by the third-party electrical substation was increased fonn semiannual to monthly basis. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed connnencement and completion dates. Corrective Action Power was restored and units restarted. Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003275 EPA Inspection Report - Page 1726 of 1969 #15-2018-08-28 FL-0403 NSPS JaFlow RCA Page 1 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: August 28, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from the Alky Flare (FL-0403) per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 08/22/2018, the Alky Flare (FL-0403) began exceeding its baseline threshold by >500,000 scfd while flaring. The excess flaring was caused by the Propane Treater (D-0629) being depressurized to the flare for scheduled maintenance. D-629 requires replacement of media so that the propane can be neutralized prior to being sent to storage. Flaring continued until D-629 reached no pressure and maintenance could work on the vessel. At approximately 11 :00 on 08/22/2018 FL-0403 began exceeding its baseline threshold until approximately 22 :00 on 08/22/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 08/11/2018 11:00 Event Duration: 08/11/2018 11:00 -08/11/2018 23:00; 13 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) Alky Flare (FL-0403) 270,230 24-Hour Period 08/11/2018 11:00 -08/11/2018 22:59 Quantity of Gas Discharged in 24-Hour Period (dscf) 270,230 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(]) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. HFNA-000003276 EPA Inspection Report - Page 1727 of 1969 #15-2018-08-28 FL-0403 NSPS JaFlow RCA Page 2 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Unit feed rates were reduced to mini1nize excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d), including an identification of the affected facility, the date and duration of the discharge. a statement noting whether the discharge resulted from the same root cause( s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60. l03a(e). Affected Facility(s): Alky Flare (FL-0403) Date of Discharge: 08/11/2018 Duration of Discharge: 12 hours ROOT CAUSE ANALYSIS Scheduled maintenance on the propane treater (D-0629) resulted in excess flaring during depressurization of the vessel. CORRECTIVE ACTION ANALYSIS Maintenance finished de pressurization of the vessel and excess flaring was reduced. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60. l03a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action Depressurization finished Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003277 EPA Inspection Report - Page 1728 of 1969 #16-2018-10-05 FL-0403 NSPS JaFlow RCA Page 1 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: October 5, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from the Alky Flare (FL-0403) per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 09/18/2018, the Alky Flare (FL-0403) began exceeding its baseline threshold by >500,000 scfd while flaring. The excess flaring was caused by non-condensables from the depropanizer (W-0079) being vented to the flare. Flaring continued until W-79 no longer had condensables in the system. At approximately 18:00 on 09/18/2018 FL-0403 began exceeding its baseline threshold until approximately 00:00 on 09/21/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 09/18/2018 18:00 Event Duration: 09/18/2018 18:00 - 09/21/2018 00:00; 55 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) Alky Flare (FL-0403) 1,383,800 24-Hour Period 09/18/2018 09/19/2018 09/20/2018 09/21/2018 18:00 00:00 00:00 00:00 - Quantity of Gas Discharged in 24-Hour Period (dscf) 09/18/2018 09/19/2018 09/20/2018 09/21/2018 23:59 23:59 23:59 00:59 177,090 594,430 589,590 22,690 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(]) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. HFNA-000003278 EPA Inspection Report - Page 1729 of 1969 #16-2018-10-05 FL-0403 NSPS JaFlow RCA Page 2 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 Not applicable to this event. 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60 .108a(c)(6) (viii) The steps thatthe owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Unit feed rates were reduced to mini1nize excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d), including an identification of the affected facility, the date and duration of the discharge. a statement noting whether the discharge resulted from the same root cause( s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60. l03a(e). Affected Facility(s): Alky Flare (FL-0403) Date of Discharge: 09/18/2018 DurationofDischarge: 55 hours ROOT CAUSE ANALYSIS W-79 began venting non-condensables to FL-0403. CORRECTIVE ACTION ANALYSIS W-79 completed venting non-condensables and flaring was minimized. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60. l03a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and. for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action W-79 completed venting non-condensables and flaring stopped. Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003279 EPA Inspection Report - Page 1730 of 1969 #17-2018-08-25 FL-0404 NSPS Ja Alt Baseline Flow RCA Pagel of2 ........................................................................................................HollyFrontier ..NavaioRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: August 25, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from GOHT Flare (FL-0404) alternative baseline per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. Hydrogen venting to the GOH Flare (FL-0404) during startup of the Hydrogen Plant No.l (Unit 63 ), and increased rate in the CCR contributed to the increase of hydrogen flow directed to the flare. At approximately 16:00 on 07/19/2018 FL-0404 began exceeding its alternative baseline threshold until approximately 02 :00 on 07/20/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 07/19/2018 16:00 Event Duration: 07/19/2018 16:00 -07/20/2018 02:00; 10 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) GOH Flare (FL-0404) Alternative Baseline 3,840,640 24-Hour Period 07/19/2018 16:00 - 07/20/2018 02:00 Quantity of Gas Discharged in 24-Hour Period (dsc:I) 3,840,640 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60 I02a(g)(I) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S02 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. HFNA-000003280 EPA Inspection Report - Page 1731 of 1969 #17-2018-08-25 FL-0404 NSPS Ja Alt Baseline Flow RCA Page 2 of2 ........................................................................................................HollyFrontier ..NavaioRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Unit feed rates were reduced to mini1nize excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d), including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause( s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60. l03a(e). Affected Facility(s): GOH Flare (FL-0404) Date of Discharge: 07/19/2018 DurationofDischarge: 10 hours ROOT CAUSE ANALYSIS Hydrogen venting to the GOH Flare (FL-0404) during startup of the Hydrogen Plant No.l (Unit 63), and increased rate in the CCR contribute to the increase of hydrogen flow directed to the flare. CORRECTIVE ACTION ANALYSIS The startup of Unit 63 was completed and the production rate in the hydrogen Plant No.2 (Unit 64) was dialed back to minimum rate, reducing the hydrogen flow vented to the flare. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action Unit 63 startup was completed. Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003281 EPA Inspection Report - Page 1732 of 1969 #18-2018-10-25 FL-0404 NSPS Ja Alt Baseline Flow RCA Page 1 of2 ........................................................................................................HollyFrontier ..NavaioRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: October 25, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from GOHT Flare (FL-0404) alternative baseline per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 07/23/2018, the GOH Flare (FL-0404) began exceeding its alternative baseline threshold. This was due to Unit 70, the Continuous Catalytic Reformer (CCR) being nm at full rates and Unit 33, the Diesel Hydrotreater (DHT) nmning at reduced rates. The CCR produces additional hydrogen that, under nonnal operating conditions, the DHT is able to use. Due to the reduced rates the excess hydrogen was flared. At approximately 02 :00 on 07/23/2018 FL-0404 began exceeding its alternative baseline threshold until approximately 19:00 on07/23/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 07/23/2018 02 :00 Event Duration: 07/23/2018 02:00 -07/23/2018 19:00; 18 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) GOH Flare (FL-0404) Alternative Baseline 5,888,970 24-Hour Period 07/23/2018 02:00 - 07/23/2018 19:59 Quantity of Gas Discharged in 24-Hour Period (dsc:I) 5,888,970 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(]) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S02 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. HFNA-000003282 EPA Inspection Report - Page 1733 of 1969 #18-2018-10-25 FL-0404 NSPS Ja Alt Baseline Flow RCA Page 2 of2 ........................................................................................................HollyFrontier ..NavaioRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Unit feed rates were reduced to mini1nize excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d), including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause( s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60. l03a(e). Affected Facility(s): GOH Flare (FL-0404) Date of Discharge: 07/23/2018 DurationofDischarge: 18 hours ROOT CAUSE ANALYSIS Unit 70 was mnning at full capacity and Unit 33 was mmring at reduced rates. Excess hydrogen from Unit 70 wasn't able to be used in Unit 33 due to the reduced rates and had to be directed to the flare. CORRECTIVE ACTION ANALYSIS Unit 33 was able to process more hydrogen. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action Unit 33 was able to process more hydrogen. Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003283 EPA Inspection Report - Page 1734 of 1969 #19-2018-10-25 FL-0404 NSPS Ja Alt Baseline Flow RCA Page 1 of2 ........................................................................................................HollyFrontier ..NavaioRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: October 25, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from GOHT Flare (FL-0404) alternative baseline per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 07/23/2018, the GOH Flare (FL-0404) began exceeding its alternative baseline threshold. This was due to Unit 9, the Alkylation Unit being down for repairs. Because Unit 9 was down and there were decreased rates throughout the facility excess hydrogen was sent to the GOH Flare. At approximately 18:00 on 08/27/2018 FL-0404 began exceeding its alternative baseline threshold until approximately 05 :00 on 08/30/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 08/27/2018 18:00 Event Duration: 08/27/2018 18:00 - 08/30/2018 05 :00; 60 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) GOH Flare (FL-0404) Alternative Baseline 23,764,370 24-Hour Period 08/27/2018 08/28/2018 08/29/2018 08/30/2018 18:00 00:00 00:00 00:00 - Quantity of Gas Discharged in 24-Hour Period (dsc:I) 08/27/2018 08/28/2018 08/29/2018 08/30/2018 23:59 23:59 23:59 05:59 2,493,880 9,740,000 9,445,270 2,085,220 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(]) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. HFNA-000003284 EPA Inspection Report - Page 1735 of 1969 #19-2018-10-25 FL-0404 NSPS Ja Alt Baseline Flow RCA Page 2 of2 ........................................................................................................HollyFrontier ..NavaioRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S02 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess e1nissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Unit feed rates were reduced to mini1nize excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d). including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): GOH Flare (FL-0404) Date of Discharge: 08/27/2018 DurationofDischarge: 60 hours ROOT CAUSE ANALYSIS The GOH Flare exceeded its alternative baseline threshold due to Unit 9 being down for repairs. This led to excess hydrogen being routed to the GOH Flare. CORRECTIVE ACTION ANALYSIS Unit 9 repairs were finished and the unit was brought back online. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60. l03a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action Unit 9 was brought back into service. Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003285 EPA Inspection Report - Page 1736 of 1969 #20-2018-10-16 FL-0404 NSPS Ja Alt Baseline Flow RCA Page 1 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: October 16, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from GOHT Flare (FL-0404) alternative baseline per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 09/23/2018, the GOH Flare (FL-0404) began exceeding its alternative baseline threshhold. This was due to a power outage that affected Units 33 (Diesel Hydrotreater), 44 (Distillate Hydrodesulfurization), 45 (GOH), 70 (CCR), 10 (FCC), and the North Plant. The affected units ended up causing excess flaring to the GOH Flare. The outage lasted approximately 2-3 hours. While this was occurring, Unit 34 (Mild Hydrocracker) was shut down for a scheduled catalyst change. Unit 34 uses hydrogen in its process and when the unit is down Units 63 and 64 (Hydrogen Plants 1 and 2) are able to reduce their rates but not fully shut off for safety concerns. Because of this excess hydrogen was flared to FL0404 leading to an exceedance of FL-0404 's alternative baseline. Due to the nature of a catalyst change in Unit 34 the duration of the startup event and the quantity of excess hydrogen flared was ,greater than a typical startup event. At approximately 20:00 on 09/23/2018 FL-0404 began exceeding its alternative baseline threshhold until approximately 02:00 01109/25/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 09/23/2018 20 :00 Event Duration: 09/23/2018 20:00 -09/25/2018 02:00; 31 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) GOH Flare (FL-0404) Alternative Baseline 13,448,870 24-Hour Period 09/23/2018 20:00 - 09/23/2018 23:59 09/24/2018 00:00 - 09/24/3018 23:59 09/25/2018 00:00 - 09/25/2018 02:59 Quantity of Gas Discharged in 24-Hour Period (dscf) 2,385,850 9,937,950 1,125,070 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60 I02a(g)(I) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. HFNA-000003286 EPA Inspection Report - Page 1737 of 1969 #20-2018-10-16 FL-0404 NSPS Ja Alt Baseline Flow RCA Page 2 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess e1nissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Unit feed rates were reduced to mini1nize excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d), including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): GOH Flare (FL-0404) Date of Discharge: 09125/2018 DurationofDischarge: 31 hours ROOT CAUSE ANALYSIS A power outage along with a planned shutdown of Unit 34 led to an excess of flaring. CORRECTIVE ACTION ANALYSIS Power was restored for the Plant. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action Power was restored for the plant Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003287 EPA Inspection Report - Page 1738 of 1969 #21-2018-10-17 FL-0404 NSPS Ja Alt Baseline Flow RCA Page 1 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: October 17, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from GOHT Flare (FL-0404) alternative baseline per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 09/28/2018, the GOH Flare (FL-0404) began exceeding its alternative baseline threshold. This was due to Unit 34 being brought back in line following the planned catalyst change. Unit 34 uses hydrogen in its process and when the unit is down Units 63 and 64 (Hydrogen Plants l and 2) are able to reduce their rates but not fully shut off for safety concerns. Because of this excess hydrogen was flared to FL-0404 leading to an exceedance of FL-0404 's alternative baseline. Due to the nature of a catalyst change in Unit 34 the duration of the startup event and the quantity of excess hydrogen flared was greater than a typical startup event. At approximately 15 :00 on 09/28/2018 FL-0404 began exceeding its alternative baseline threshold until approximately 05:00 01109/29/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 09/28/2018 15 :00 Event Duration: 09/28/2018 15:00 -09/29/2018 05:00; 15 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) GOH Flare (FL-0404) Alternative Baseline 5,107,160 24-Hour Period 09/28/2018 15:00 - 09/28/2018 23:59 09/29/2018 00:00 - 09/29/2018 05:59 Quantity of Gas Discharged in 24-Hour Period (dscf) 3,581,570 1,525,590 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60 I02a(g)(I) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S02 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. HFNA-000003288 EPA Inspection Report - Page 1739 of 1969 #21-2018-10-17 FL-0404 NSPS Ja Alt Baseline Flow RCA Page 2 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 Not applicable to this event. 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Unit feed rates were reduced to mini1nize excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d), including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause( s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60. l03a(e). Affected Facility(s): GOH Flare (FL-0404) Date of Discharge: 09128/2018 DurationofDischarge: 15 hours ROOT CAUSE ANALYSIS The startup of Unit 34 led to an excess of flaring. CORRECTIVE ACTION ANALYSIS Startup continued as planned and flaring was minimized as Unit 34 was brought back online. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action Unit 34 was brought back online. Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003289 EPA Inspection Report - Page 1740 of 1969 4 F: #22-2018-10-25 NSPS JaRCA S02 FL-0404 Page 1 of3 ...............................................................................................................HollyFrontier Navajo RefiningLLC HOLLYFRONTIER 501 E. Main Artesia, NM 88201 (575) 748-3311 DATE: October 28, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for S0 2 from Flares per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 09/28/2018, the GOH Flare (FL-0404) began exceeding its S02 threshold. At approximately 03:00 on 09/28/2018, operations began a planned startup of the Mild Hydrocracker Unit (Unit 34) following a planned shutdown to replace the catalyst in the Guard Bed Reactor (D-3401). Due to low temperature and no steam in the Stripper (W-3401) all pressure built up in the Fractionator (W-3402) has nowhere to go except to be vented to the GOHT Flare (FL-0404). At approximately 10:00 on 09/28/2018, operations fired the Reactor Charge Heater (H-3403) to begin heating up the process to nonnal operating temperature. Once H-3403 is running, it heats the temperature through the Reactors (D3400/01/02), the Hot Oil Separator (D-3404), the Stripper (W-3401), and the Fractionator (W-3402). At approximately 20:42 on 09/28/2018, the temperature in W-340 l was hot enough for steam to remain in vapor state and operations began adding stripping steam to W -340 l. When stripping steam is added, the steam pushes the diesel light ends (naphtha) to the Stripper Overhead Accumulator (D-3411) and operations can send the process downstream to North Division units instead of flaring. Othenvise, the process is pushed to W-3402 and flaring begins. The flaring is caused by low temperature and no steam in (W-340 l ). Until temperature is hot enough for stripping steam to be added, all built up pressure in (W-3402) is vented to FL-0404. At approximately 23 :00 on 09/28/2018 FL-0404 began exceeding its S02 threshold until approximately 22 :00 on 09/29/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 09/28/2018 23 :00 Event Duration: 09/28/2018 23:00 - 09/29/2018 22:00; 24 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) GOH Flare FL-0404 24-hour Period 09/28/2018 23:00 - 09/29/2019 22:59 Quantity of Gas Discharged over Event Duration (dscf) 4,827,960 60.108a(c)(6 )(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Date 09/28/2018 23:00 - 09/28/2018 23:59 09/29/2018 00:00 - 09/29/2018 22:59 Number of hours l 23 Hourly Average Measured Total Sulfur Concentration During Event (ppm) {60.108a(c)(6)(iv)} 4,130 437 HFNA-000003290 EPA Inspection Report - Page 1741 of 1969 #22-2018-10-25 NSPS JaRCA S02 FL-0404 Page 2 of3 .....................................................................................................................................................................................HollyFrontier ..Navajo...RefiningLLC 501 E. Main Artesia, NM 88201 (575) 748-3311 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-tenn emissions limit in §60102a(g)(l) from a fuel gas combustion device, either the measured concentration ofH 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares. except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Affected Facility GORT Flare (FL-0404) Cumulative Quantity ofH 2S Released (pounds) 3.1 Cumulative Quantity of S02 Released (pounds) 572 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas was safely combusted in a steam-assisted flare and scavenger was injected into the system. Maintenance worked quickly to detennine what steps needed to be taken to reduce excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d). including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): GOH Flare (FL-0404) Date of Discharge: 09/28/2018 Duration of Discharge: 24 hours ROOT CAUSE ANALYSIS The flaring is caused by low temperature and no steam in (W-3401). Until temperature is hot enough for stripping steam to be added, all built up pressure in (W-3402) is vented to FL-0404. CORRECTIVE ACTION ANALYSIS No corrective actions are planned. Operations continues to investigate alternatives to startup procedures for the purpose of identifying potential methods to reduce or eliminate the need to flare during unit startup. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action Actions Completed within 45 days Proposed Start Date Completion Date HFNA-000003291 EPA Inspection Report - Page 1742 of 1969 #22-2018-10-25 NSPS JaRCA S02 FL-0404 Page 3 of3 .....................................................................................................................................................................................HollyFrontier ..Navajo...RefiningLLC 501 E. Main Artesia, NM 88201 (575) 748-3311 I Temperature was hot enough for W-3401 I Yes IN/A IN/A I 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003292 EPA Inspection Report - Page 1743 of 1969 #23-2018-11-06 FL-0404 NSPS Ja Alt Baseline Flow RCA Page 1 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: November 6, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from GOHT Flare (FL-0404) alternative baseline per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 10/29/2018, the GOH Flare (FL-0404) began exceeding its alternative baseline threshhold. This was due to the Recycle Hydrogen Compressor (C-693) unexpectedly shutting down. Because of this shutdown excess hydrogen was sent to the flare. Water was found in the conduit for the seal oil level indication causing an issue with the electrical connections for the level transmitter of the seal oil tank. The seal was replaced for the conduit and the electrical wiring was tenninated for the seal oil tank level. At approximately 07:00 on 10/29/2018 FL-0404 began exceeding its alternative baseline threshhold until approximately 02:00 on 10/30/2018. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 10/29/2018 07 :00 Event Duration: 10/29/2018 07:00 -10/30/2018 02:00; 20 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) GOH Flare (FL-0404) Alternative Baseline 6,643,130 24-Hour Period 10/29/2018 06:00 - 10/29/2018 23:59 10/30/2018 00:00 -10/30/2018 02:59 Quantity of Gas Discharged in 24-Hour Period (dscf) 6,279,630 363,500 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60 I02a(g)(I) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. HFNA-000003293 EPA Inspection Report - Page 1744 of 1969 #23-2018-11-06 FL-0404 NSPS Ja Alt Baseline Flow RCA Page 2 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 Not applicable to this event. 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S02 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess e1nissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Unit feed rates were reduced to mini1nize excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d). including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): GOH Flare (FL-0404) Date of Discharge: 10/29/2018 Duration of Discharge: 20 hours ROOT CAUSE ANALYSIS The unexpected shutdown of C-693 led to an excess of flaring. CORRECTIVE ACTION ANALYSIS C-693 was repaired and brought back online. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in § 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action C-693 was repaired. Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planued startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003294 EPA Inspection Report - Page 1745 of 1969 #24-2018-12-06 FL-0404 NSPS Ja Baseline Flow RCA Pagel of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 ·H.OLLYF.RONTIER (575) 365-8365 DATE: December 6, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for flow >500,000 scfd from GOHT Flare (FL-0404) alternative baseline per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. Between 11/19/18 and 11/26/2018, the GOH Flare (FL-0404) flow baseline reporting threshold was exceeded. During this period, discharges to the flare associated to the startup of the ROSE (Unit 25), the venting of hydrogen associated with an unexpected shutdown of the Diesel Hydrotreater (DHT, Unit 33) Recycle Hydrogen Compressor (C-0693 ), the plam1ed shutdown of the Mild Hydrotreater (MHC) unit, and the unit startup of several process units after an unexpected interruption of electrical power to the refinery, contributed to increasing the flare flow above the reporting threshold. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 11/19/2018 16:00 Event Duration: 11/19/2018 16:00 -11/26/2018 19; 370 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) Measured Quantity of Gas Discharged over Event Duration (dscf) GOH Flare (FL-0404) Alternative Baseline 27,060,572 24-Hour Period 11/19/2018 11/20/2018 11/21/2018 11/22/2018 11/23/2018 11/24/2018 11/25/2018 11/26/2018 16:0016:0016:0016:0016:0016:0016:0016:00- Quantity of Gas Discharged in 24-Hour Period (dsc:I) 11/20/2018 11/21/2018 11/22/2018 11/23/2018 11/24/2018 11/25/2018 11/26/2018 11/26/2018 15:00 15:00 15:00 15:00 15:00 15:00 15:00 19:00 1,716,595 1,395,740 1,624,797 1,425,801 1,006,709 9,005,060 9,355,030 1,530,840 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Not applicable to this event. 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(]) from a fuel gas combustion device, either the measured concentration of H 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. HFNA-000003295 EPA Inspection Report - Page 1746 of 1969 #24-2018-12-06 FL-0404 NSPS Ja Baseline Flow RCA Page 2 of2 ........................................................................................................HollyFrontier ..NavajoRefiningLLC. P.O. Box 159 Artesia, NM 88211 (575) 365-8365 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S02 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Not applicable to this event. 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess e1nissions on ambient air quality. The gas was safely combusted in a steam-assisted flare. Unit feed rates were reduced to mini1nize excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d). including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): GOH Flare (FL-0404) Date of Discharge: 10/29/2018 Duration of Discharge: 20 hours ROOT CAUSE ANALYSIS Between 11/19118 and 1112612018, the GOH Flare (FL-0404) flow baseline reporting threshold was exceeded. During this period, discharges to the flare associated to the startup of the ROSE (Unit 25), the venting of hydrogen associated with an unexpected shutdown of the Diesel Hydrotreater (DHT, Unit 33) Recycle Hydrogen Compressor (C-0693), the planned shutdown of the Mild Hydrotreater (iv1HC) unit, and the unit startup of several process units after an unexpected interruption of electrical power to the refinery, contributed to increasing the flare flow above the reporting threshold. CORRECTIVE ACTION ANALYSIS Units were restarted, C-693 was repaired returned online. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in § 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action Units were restarted, C-693 was repaired returned online. Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003296 EPA Inspection Report - Page 1747 of 1969 4 F: #25-2018-10-08 NSPS JaRCA S02 FL-0404 Pagel of2 ...............................................................................................................HollyFrontier Navajo RefiningLLC HOLLYFRONTIER 501 E. Main Artesia, NM 88201 (575) 748-3311 DATE: October 8, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for S0 2 from Flares per 60.103a(c)(l) I 60.108a(c)(6)(i) A description of the discharge. On 09/24/2018, the FCC Flare (FL-0402) began exceeding its S02 threshold. This was due to a power outage that affected Units 33 (Diesel Hydrotreater), 44 (Distillate Hydrodesulfurization), 45 (GOH), 70 (CCR), 10 (FCC), and the North Plant. The flaring associated witht he units's shutdown and subsequent startup resulted in emissions from the GOH Flare (FL-0404) to exceed 500 lbs S0 2 in a 24-hour period. I 60.108a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 09/24/201801:00 Event Duration: 09/24/2018 01:00 - 09/24/2018 10:00; 10 hours 60 .108a(c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.107a(g). Affected Facility(s) GOH Flare FL-0404 24-hour Period 09/24/2018 01:00 - 09/24/2018 10:59 Quantity of Gas Discharged over Event Duration (dscf) 5,037,970 60.108a(c)(6)(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2 S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Date 09/24/2018 01:00 - 09/24/2018 10:59 Number of hours 10 Hourly Average Measured Total Sulfur Concentration During Event (ppm) {60.108a(c)(6)(iv)} 244 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-term emissions limit in §60102a(g)(l) from a fuel gas combustion device, either the measured concentration ofH 2S in the fuel gas or the measured concentration of S02 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares, except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the HFNA-000003297 EPA Inspection Report - Page 1748 of 1969 #25-2018-10-08 NSPS JaRCA S02 FL-0404 Page 2 of2 .....................................................................................................................................................................................HollyFrontier ..Navajo...RefiningLLC 501 E. Main Artesia, NM 88201 (575) 748-3311 cumulative quantity of H 2S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2S to S02. Affected Facility GOH Flare (FL-0404) Cumulative Quantity ofH 2S Released (pounds) 1.13 Cumulative Quantity of S02 Released (pounds) 210.72 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess e1nissions on ambient air quality. The gas was safely combusted in a steam-assisted flare and scavenger was injected into the system. Maintenance worked quickly to determine what steps needed to be taken to reduce excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d), including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause( s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): GOH Flare (FL-0404) Date of Discharge: 09/24/2018 Duration of Discharge: 10 hours ROOT CAUSE ANALYSIS An unexpected power outage affected Units 33 (Diesel Hydrotreater), 44 (Distillate Hydrodesulfurization), 45 (GOH), 70 (CCR), 10 (FCC), and the North Plant. The affected units ended up causing excess S02 flaring to the GOH Flare. The outage lasted approximately 2-3 hours. CORRECTIVE ACTION ANALYSIS The electrical supply was promptly shifted to four additional substations that provide the electrical power to other sections of the refinery, allowing the electrical power to be restored. The frequency of preventative maintenance activities performed by the third-party electrical substation was increased fonn semiannual to monthly basis. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action Power was restored. Actions Completed within 45 days Yes Proposed Start Date Completion Date NIA NIA 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003298 EPA Inspection Report - Page 1749 of 1969 4 F: #26-2018-10-25 NSPS JaRCA S02 FL-0404 Pagel of3 ...............................................................................................................HollyFrontier Navajo RefiningLLC HOLLYFRONTIER 501 E. Main Artesia, NM 88201 (575) 748-3311 DATE: October 28, 2018 RE: 40 CFR Part 60 Subpart Ja: Investigation for S0 2 from Flares per 60.103a(c)(l) I 60.I08a(c)(6)(i) A description of the discharge. On 09/28/2018, the GOH Flare (FL-0404) began exceeding its S02 threshold. At approximately 03:00 on 09/28/2018, operations began a planned startup of the Mild Hydrocracker Unit (Unit 34) following a planned shutdown to replace the catalyst in the Guard Bed Reactor (D-3401). Due to low temperature and no steam in the Stripper (W-3401) all pressure built up in the Fractionator (W-3402) has nowhere to go except to be vented to the GOHT Flare (FL-0404). At approximately 10:00 on 09/28/2018, operations fired the Reactor Charge Heater (H-3403) to begin heating up the process to nonnal operating temperature. Once H-3403 is running, it heats the temperature through the Reactors (D3400/01/02), the Hot Oil Separator (D-3404), the Stripper (W-3401), and the Fractionator (W-3402). At approximately 20:42 on 09/28/2018, the temperature in W-340 l was hot enough for steam to remain in vapor state and operations began adding stripping steam to W -3401. When stripping steam is added, the steam pushes the diesel light ends (naphtha) to the Stripper Overhead Accumulator (D-3411) and operations can send the process downstream to North Division units instead of flaring. Othenvise, the process is pushed to W-3402 and flaring begins. The flaring is caused by low temperature and no steam in (W-340 l ). Until temperature is hot enough for stripping steam to be added, all built up pressure in (W-3402) is vented to FL-0404. At approximately 23 :00 on 09/28/2018 FL-0404 began exceeding its S02 threshold until approximately 22 :00 on 09/29/2018. I 60.I08a(c)(6)(ii) The date and time the discharge was first identified and the duration of the discharge. Event Start Date & Time: 09/28/2018 23 :00 Event Duration: 09/28/2018 23:00 - 09/29/2018 22:00; 24 hours 60. l08a( c)(6)(iii) The measured or calculated cumulative quantity of gas discharged over the discharge duration. If the discharge duration exceeds 24 hours, record the discharge quantity for each 24-hour period. For a flare, record the measured or calculated cumulative quantity of gas discharged to the flare over the discharge duration. If the discharge exceeds 24 hours, record the quantity of gas discharged to the flare for each 24-hour period. Engineering calculations are allowed for fuel gas combustion devices, but are not allowed for flares, except for those complying with the alternative monitoring requirements in §60.I07a(g). Affected Facility(s) GOH Flare FL-0404 24-hour Period 09/28/2018 23:00 - 09/29/2019 22:59 Quantity of Gas Discharged over Event Duration (dscf) 4,827,960 60. l08a( c)(6 )(iv) For each discharge greater than 500lbs S02 in any 24-hour period from a flare, the measured total sulfur concentration or both the measured H 2S concentration and the estimated total sulfur concentration in the fuel gas at a representative location in the flare inlet. Date 09/28/2018 23:00 - 09/28/2018 23:59 09/29/2018 00:00 - 09/29/2018 22:59 Number of hours 1 23 Hourly Average Measured Total Sulfur Concentration During Event (ppm) {60.I08a(c)(6)(iv)} 4,130 437 HFNA-000003299 EPA Inspection Report - Page 1750 of 1969 #26-2018-10-25 NSPS JaRCA S02 FL-0404 Page 2 of3 .....................................................................................................................................................................................HollyFrontier ..Navajo...RefiningLLC 501 E. Main Artesia, NM 88201 (575) 748-3311 60.108a(c)(6)(v) For each discharge greater than 500lbs S02 in excess of the applicable short-tenn emissions limit in §60102a(g)(l) from a fuel gas combustion device, either the measured concentration ofH 2S in the fuel gas or the measured concentration of S0 2 in the stream discharged to the atmosphere. Process knowledge can be used to make these estimates for fuel gas combustion devices, but cannot be used to make these estimates for flares. except as provided in §60.107a(e)(4). Not applicable to this event. 60.108a(c)(6) (vi) For each discharge greater than 500lbs S02 in excess of the allowable limits from a sulfur recovery plant, either the measured concentration of reduced sulfur or S0 2 discharged to the atmosphere. Not applicable to this event. 60.108a(c)(6) (vii) For each discharge greater than 500lbs S02 in any 24-hour period from any affected flare or discharge greater than 500lbs S02 in excess of the allowable limits from a fuel gas combustion device or sulfur recovery plant, the cumulative quantity of H 2 S and S02 released into the atmosphere. For releases controlled by flares, assume 99-percent conversion of reduced sulfur or total sulfur to S0 2 For fuel gas combustion devices, assume 99-percent conversion of H 2 S to S02. Affected Facility GORT Flare (FL-0404) Cumulative Quantity ofH 2S Released (pounds) 3.1 Cumulative Quantity of S02 Released (pounds) 572 60.108a(c)(6) (viii) The steps that the owner or operator took to limit the emissions during the discharge. Operations followed procedures to minimize the impact of the excess emissions on ambient air quality. The gas was safely combusted in a steam-assisted flare and scavenger was injected into the system. Maintenance worked quickly to detennine what steps needed to be taken to reduce excess flaring. 60.108a(c)(6) (ix) The root cause analysis and corrective action analysis conducted as required in§ 60.103a(d). including an identification of the affected facility, the date and duration of the discharge, a statement noting whether the discharge resulted from the same root cause(s) identified in a previous analysis and either a description of the recommended corrective action(s) or an explanation of why corrective action is not necessary under§ 60.103a(e). Affected Facility(s): GOH Flare (FL-0404) Date of Discharge: 09/28/2018 Duration of Discharge: 24 hours ROOT CAUSE ANALYSIS The flaring is caused by low temperature and no steam in (W-3401). Until temperature is hot enough for stripping steam to be added, all built up pressure in (W-3402) is vented to FL-0404. CORRECTIVE ACTION ANALYSIS No corrective actions are planned. Operations continues to investigate alternatives to startup procedures for the purpose of identifying potential methods to reduce or eliminate the need to flare during unit startup. 60.108a(c)(6) (x) For any corrective action analysis for which corrective actions are required in§ 60.103a(e), a description of the corrective action(s) completed within the first 45 days following the discharge and, for action(s) not already completed, a schedule for implementation, including proposed commencement and completion dates. Corrective Action Actions Completed within 45 days Proposed Start Date Completion Date HFNA-000003300 EPA Inspection Report - Page 1751 of 1969 #26-2018-10-25 NSPS JaRCA S02 FL-0404 Page 3 of3 .....................................................................................................................................................................................HollyFrontier ..Navajo...RefiningLLC 501 E. Main Artesia, NM 88201 (575) 748-3311 I Temperature was hot enough for W-3401 I Yes IN/A IN/A I 60.108a(c)(6) (xi) For each discharge from any affected flare that is the result of a planned startup or shutdown of a refinery process unit or ancillary equipment connected to the affected flare, a statement that a root cause analysis and corrective action analysis are not necessary because the owner or operator followed the flare management plan. Not applicable to this event. HFNA-000003301 EPA Inspection Report - Page 1752 of 1969 New l\'lexko En\'ironment Department Ai:r Quality Bureau Compliance and Enforcement Section 525 Camino de fos Marquez, Suite 1 Santa Fe, NM 87505 Phone (505) 476-4300 Fax (505) 476-4375 Version 05.02.13 l NMED USE ONLY ' ~--=-~--:~~-----1------------------·----J REPORTING SUBMITTAL FORM NMEQJ.JSE ONLY -------1 Staff Admin ...................-.. - - - ~ · L PLEASE NOTE:® - Indicates reauired field SECTION I GENERAL COMPANY AND FACILITY INFORMATION w A ® Company Name: D. ® Facility Name: HollyFrontier Navajo Refining LLC E.1 ® Facility Address: 501 E.Main St. HollyFrontier Navajo Refining LLC B.1 ® Company Address: · PO Box 159 ... ················································· ...-......., ......., B.2®City: .. \ Artesia C.1 ® Company Environmental Contact: Scott M. Denton ! ~~ ® State: j Ba:2~1~~:~~------------------- C.2 ® Title: Environmental Manager ~~e~:ity: ___ F.2 ® Title: I Environmental Manager I ~7~~: ;_~,ie~;;: ~?:-~~~; _l__~A® State: I~8~~~i:: i F.1 ® Facility Contact: Scott M. Denton -;;;_~ :~ ~~~ Number: ~~mber: : Number: ~~ ~,:,-~-m""b-e-r:----~ 4 5 4 7 6 4 C.5 ® E=m-ai_l_A-d-d-re_s_s-:----~------------+-F~.-5~®~E~m-ai-l~Address: ........................................, .............--..--------------------------..-~.. 1 Scott.Denton@hollyfrontier.com Scott.Denton@hollyfrontier.com ,====··=······•••••••••••••••••••••••••N•;..\.-..:=:.::=::===• · J. Fax Number: H. Title: !. Phone Number: Vice President & Refinery 575-748-3311 575-746-5451 Manacer ! l. Title V Permit Number: ~ M. Title V Permit ls~ue Date~ •N. NSR Permit Number: 0. NSR Permit Issue Date: P051-R2 05/06/2015 PSD-NM-0195-M37 • 08/12/2016 -.--------------------------------------------'---------------···························;-1................. ,1. G. Resoonsible Official: mue VonM: Parrish R. Miller K. ® Al Number: 198 TReporting Period: From: 01/01/2019 To: 03/31/2019 SECTION II -TYPE Of SUBMITTAi.. (check one that applies) j Title V Annual Compliance Permit Condition(s): A D ~~~oo i s.o I' Title V Semi-annual Monitoring Report C. D NSPS Requirement (40CFR60} MACT Requirement (40CFR63} E.D NMAC Requirement (20.2.xx) or NESHAP Requirement (40CFR61) F.D Permit or Notice of Intent (NOi} Requirement G.[gj Requirement of an Enforcement Action !Description: . Permit Condition(s): j Descriotion: Reaulation: Section{sl: Description: Reaulation: Section(sl: Description: Reaulation: Section{si: Descri otion: Permit No.D: or NOi No.D: Condition(s): Description: NOVNo. 0: orSFO No. 0: Section(s): Description: Paragraphs 37 and 23.0 EPA Consent Decree Quarterly Report for HollyFrontier Navajo Refining (Artesia and Lovington) or CD No. [gj: or Other D: CIV-01 1422LH SECTION IV -CERTIFICATION .................--.-....- ..- .........---------------------------·------ - ..............................................................., ..., ..... w ----------------------------···---·····--- ....... After reasonable inquiry, I Parrish R. Miller ...................... certify that the information in this submittal is true, accurate and complete. {name of reporting official) ® Title: " ® Date ® Responsible Official for Title V? Vice President & Refinery I Manager Reviewed By: 0413012019 [gJ Yes Date Reviewed: HFNA-000003302 EPA Inspection Report - Page 1753 of 1969 New Mexico Environment Department Air Quality Bureau Compliance and Enforcement Section 525 Camino de fos :J\,farquez, Suite 1 Santa Fe, Nl\1 87505 Phone (505) 476-4300 Fax (505) 476-4375 Version 05.0:!.13 L._"'" t:JMED USE;,QNbX l............................. NMED USE ONLY __________ ::,. REPORTING SUBMITTAL FORM • TEMPO ----------~\ Staff Adm in :::::::::::::::::::::::: :::::::::: ::: ] PLEASE NOTE:® • indicates required field SECTION I GENER.Al COMPANY AND FACILITY INFORMATION w A. ® Company Name: D. ® Facmtv Name: HollyFrontier Navajo Refining LLC HollyFrontier Navajo Refining LLC B.1 ® Company Address: ...................................................·-·------···············I···,E,··.···1··,····'@"'·--~Faciiity Address: PO Box 159 7406 South Main i~J . !J~~~C.ity: · · · · · · · · · · · · · · ® State: • ~:2~ "" E~~i~g~~~yi 1"=~:59-1 ................ ···········l~·~ ®State: l 1 F.2 ® Title: C.1 ® Company Environmental Contact: C.2 ® Title: · ------~-F-.1-®_F_a_c_m_ty_C_o_n_t_a-ct-:- - Scott M. Denton Environmental Manager Scott M. Denton ·c::f®Phone Number: ······························r····cA..ii!i"°Fa,di.i"i:imber:················· hone Number: i 575-746-5487 .. ..... C.5 ® Email Address: ScottDenton hol! rontier.com G. Resoonsible Official: ITitle V onM: J 575-746-5451 ~~1:c;zi'ii:····················-··••o ! Environmental Manager iF.4®FaxNumber:· ...... .................. 575-746-5487 · F.5 ® Email Address: Scott.Denton@hollyfrontier.com • I. Phone Number: 575-748-3311 575-746-5451···················································· I M. Title V Permit Issue Date: 07/13/2015 ··P. Reporting Period: From: 01/01/2019 To: 03/31/2019 SECTION II -TYPE OF SUBMITTAL {check one that applies} D i Title V Annual Compliance 'Permit Condition{s): ! A. Certification B. D Title V Semi-annual Monitoring Report C. D NSPS Requirement (40CFRS0) D. D MACT Requirement (40CFR63} D NMAC Requirement (20.2.xx) or NESHAP Requirement (40CFR61) E. F.O Permit or Notice of Intent (NOi) Requirement G.IXJ Requirement of an Enforcement Action . • ;Description: • •Permit Condition(s): J>escription: Reau lat ion: •Section!sl: !Description: · . Reaulation: • Sectionisl: IDescription: Rem.alation: Section{sl: I!Description: ! Permit No.D: or NOi No.D .• Condition(s): 'Description: NOV No. D: or SFO No. D: •. Section(s): Description: or CD No. 181: or Other D: CIV-01 1422LH SECTION IV CERTIFICATION M =·············································~~~~-~---···---- After reasonable inquiry, I Reviewed By: _ _ _ _ _ __ Parrish R. Miller • Paragraphs 37 and 23.0 EPA Consent Decree Quarterly Report for HollyFrontier Navajo Refining (Artesia and Lovington) --------------------·-······-----·····------------------- ----·········--~~~~~~~~~~=~~~~~~~~~~~~~~~~~~------------- ®S;gnar~:~;~r ,. -,, . ,. , , ""'"' ~ """""···························--·----·········---- certify that the information in this submittal is true, accurate and complete. ®Title: Vice President & Refinery I Manager ®Date 04/3012019 •® Responsible Official for Tltle V? IXJ Yes Date Reviewed: HFNA-000003303 EPA Inspection Report - Page 1754 of 1969 :HOLLY"FRONTIER~ July 30, 2019 U.S. Environmental Protection Agency Director, Air Enforcement Division Ariel Rios Building 1200 Pennsylvania Avenue, N.W. Mail Code 2242-A Washington, DC 20460 Re: Certified Mail/Retum_Receipt 7018 0360 0001 7923 5828 Quarterly Implementation Progress Report Pursuant to the Consent Decree entered March 5, 2002 by the U.S. District Court for the District of New Mexico in United States of America et al. v. Navajo Refining Company, LLC et at Dear Director: Pursuant to Paragraphs 37 and 23.0 of the subject consent decree, this submittal provides the status of implementation of consent decree requirements through the calendar quarter ending June 30, 2019 for HollyFrontierNavajo Refining LLC (formerly Navajo Refining Company, L.L.C), (Navajo's) Artesia and Lovington, N'"M refineries. As specified by Paragraph 37, a statement of certification is provided on the following page. In accordance with the notice provisions of Paragraph 91, copies of this report are being mailed to EPA Region 6 (i.e., the Applicable EPA Region) and to both addresses listed for the State of New Mexico. Navajo is also providing an additional hardcopy to EPA's contractor and an electronicmail copy to the address provided in the email from EPA Region 6 dated January 31, 2019. If you have any questions regarding this submittal, please contact me at 575-746-5487 or Ray Smalts at 575-746-5490. Sincerely, Scott M. Denton Environmental Manager HollyFrontier Navajo Refining LLC P.O. Box 159 Artesia, New Mexico 88211-0159 Phone: (575) 746-5487 E-mail: HollyFrontier Navajo Refining LLC 501 East Main• Artesia, NM 88210 {575) 748-3311 • nrn1:/!w:w:w.,pg.1):yfr1;mtjey,9:).m HFNA-000003304 EPA Inspection Report - Page 1755 of 1969 By signature below, the undersigned hereby certifies to the following: Statement. of Certification I certify 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 person(s) who manage the system, or the person(s) directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. Enclosure cc (w/enc.): Bureau Chief Air Quality Bureau New Mexico Environment Department 525 Camino de los Marquez, Suite 1 Santa Fe, NM 87507 General Counsel Office of General Counsel New Mexico Environment Department P.O. Box 26110 Santa Fe, NM 87502-61 lO U.S. Environmental Protection Agency c/o Matrix Environmental & Geotechnical Services Matrix New World Engineering, Inc. 26 Columbia Turnpike Florham Park, NJ 07932 Electronic cc (w!enc.): (6{.:/\.:\(.:::,:>,J;•..,:;::,::i:\;•:e.c.;:·••,":•· Electronic cc (w/enc.): HollyFrontier: P. Miller, B. Romine, K Srnalts Environmental File: J. Stump, T. Jones, T. \Vheeler, S. Gokhale; R. Bagherian 5.2.3 .1 Consent Decree\Subm-Resp\Quarterly Reports\2019\2019-07-30 2QT Report\2019-07-30 2QT Consent Decree Report.pdf HollyFrontier Navajo R.etming LLC 501 East Main• Artesia, Ni\188210 (575) 748-3311 • l;mp;//'-\'W\"!,hollyfri.:mtier,com HFNA-000003305 EPA Inspection Report - Page 1756 of 1969 New lVIexico Environment Department Air Qualify Bureau Compliance and Enforcement Section 525 Camino de los Marquez, Suite 1 Santa Fe, Nl\1 87505 Phone (505) 476-4300 Fax (505) 476-4375 Version 05.02.13 NMED USE ONLY . St~;ED ~USE. .ONl Y.·.·.·.·.····.··.·.·.·.·.·.·.·.·.····· .TEMPo.L___J REPORTING SUBMITTAL FORM - Adm;n ~1 PLEASE NOTE:® • indicates required field SECTION i GENERAL COMPANY AND FACILITY INFORMATION M A. ® Company Name: HollyFrontier Navajo Refining LLC 8.1 ® Company Address: PO Box 159 . 8.2®City: Artesia C.1 ® Company Environmental Contact: Scott M. Denton C.3 ® Phone Number: D. ® Facmtv Name: HollvFrontier Navajo Refining LLC E. 1 ® Facility Address: ........ 501 E.Main St. i~~: ::::: . ~~ ®/~p:1 - O 1 5 9 i Environmental Manager . . . . . . . . . . . . .J. ;+:-~~~~ 575-746-5487 4~~mber: C.5 ® Email Address: Scott.Denton@hollyfrontier.com G. Resoonsible Official: ffitle V onM: D Environmental Manager :?~-~:S~;;: ~ 575-748-3311 Description: Reaulation: Section(sl: Description: Reaulation: Sectionlsi: Description: Reaulation: Section(sl: Descriotion: D NSPS Requirement {40CFR60) D. D MACT Requirement {40CFR63) E. D NMAC Requirement (20.2.xx) or NESHAP Requirement (40CFR61) Permit or Notice of Intent {NOi) Requirement G. l'8J 0: or SFO No. 0: or CD No. t8l: or Other O: I CIV-01 w -®S;gn,tu:t,::_ /~ Section(s): Description; Paragraphs 37 and 23.0 EPA Consent Decree Quarterly Report for HollyFrontier Navajo Refining (Artesia and Lovington) 1422LH y,4Z__ Reviewed By: • ~~~~~~~~~~ Description: SECTION IV CERTIFICATION After reasonable j.tt~lry, ! J. Fax N'umber: i Permit No.D: or NOi No.O Com::lition{s): ! NOV No. Requirement of an Enforcement Action , ···································~~ ...... Permit Condltion{sl: C. F.D ····························~ Description: Title V Semi-annual Monitoring Report 7~~%6~~~~1 _:~:~:· · · · · · · · · · · · · · · · · · •. 575-746-5451 Title V Annual Compliance Permit Condition(s): Certification a. D ~~~~Zip:............................. Scott M. Denton SECTION II-TYPE OF SUBMITTAL (check one that applies) ................... (-'-»»»»---------------------------···----------------------------------~-------------------------------------------------------------············· ..................... A. i·~ ·: : ~ ~:::::ty Contact; ................................. 7 Number: F.5 ® Email Address: Scott.Denton@hoHyfrontier.com I. Phone Number: H. Title: Vice President & Refinery Manager, HollyFrontier Navajo Refinina LLC Parrish R. Miller :.f """"""'" Parrish R. Miller 1,-.,f Npo ...... offidol] ··-c-cc ......................................................."'"""""""'" certify that the information in this submittal is true, accurate and complete. cc CCC ® Title: Vice President & Refinery Manager, HollyFrontier Navajo Refininu LLC ®Date 07/30/2019 ® Responsible Official for Title II? r;gj Yes 0No Date Reviewed: HFNA-000003306 EPA Inspection Report - Page 1757 of 1969 New Mexico En'\'ironment Department Ai:r Quality Bureau Compliance and Enforcement Section 525 Camino de fos Marquez, Suite 1 Santa Fe, NM 87505 Phone (505) 476-4300 Fax (505) 476-4375 Version 05.02.13 I TEMP:~EDUSEONLY REPORTING SUBMITTAL FORM ' St~~ED USE. ON~)' I .............................) Admin PLEASE NOTE:®. Indicates required field SECTION I GENERAL COMPANY AND FACILITY INFORMATION w A. ® Company Name: HollyFrontier Navajo Refining LLC 13.1 ® Company Address: PO Box 159 --0:2 ® City: D. ® Facmtv Name: HollyFrontier Navajo Refining LLC E.1 ® Facility Address: 7406 South Main ! 13.3 ® State: i EU® Zip: Artesia C.1 ® Company Environmental Contact: Scott M. Denton C.3 ® Phone Number: 575-746-5487 • C.5 ® Email Address: Scott.Denton@hollyfrontler.com G. Resoonsib!e Official: /Title V onlvl: Parrish R. Miller ""'"""""""""""""""""""""""'""'""'.... E.2 ® City: ·• NM • 8 8 2 1 1 - 0 1 5 9 Lovington • C.2 ® Title: · ----~-F-.-1-®-F-a-c-il...i..t..y....·c········o·ntact: Environmental Manager Scott M. Denton C.4 ® Fax Number: F.3 ® Phone Number: 575-746-5451 575-746-5487 F.5 ® Email Address: Scott.Denton@hollyfrontier.com -======~'=1.' Phone 't'.i;'.;mber: • H. Title: • Vice President & Refinery • Manager, HollyFrontier Navajo I 575-748-3311 ! • Refinino UC I I I • E.3 ® State: • E.4 ® Zip: 88260 I• NM F.2 ®Title: •........................................................ . • Environmental Manager F.4 ® Fax Number: 575-746-5451 J. Fax Number: 575-746-5451 r. . . ~ f. .o...~... .J22® A!Number:00000000000 ] LPri~~~R~~~rmit. Number= ......... ~iJl~.~~;J°1';frmr···i·t···'··s···s···u····e····D····i!!··t···e··:···············''..N···6····:····l'···3··~····M····~····~···r··r .....i-t~N~u-m-b-e...r. ,.=....······························,,....... 1. .·.1. .. . . :. . . .1. . P. Reporting Period: From: 04/01/2019 To: 06/30/2019 SECTION II-TYPE OF SUBMITTAL {check one that apelies) ___ .. D •Title V Annual Compliance .Permit Condition(s): A. Title V Semi-annual Monitoring Report C. D NSPS Requirement (40CFR60) D. D MACT Requirement {40CFR63) D NMAC Requirement (20.2.xx} or NESHAP Requirement (40CFR61} E. ....................., ..................................................................._,,""""""""'"" Description: Certification • B.O. 6·e·····r··m·····i·t·····l·s···s···;:;····e·····D····a····t··;···:······i F.0 Permit or Notice of Intent {NOi) Requirement G.[gj Requirement of an Enforcement Action Descriotion: • Reiwlation: Section{s): Descriotion: Reaulation: Section(s): Descriotion: IRecmlation: Section(s): Descriotlon: " I Permit No.O: or NOi No.O: Condition{s}: NOV No. 0: or SFO No. 0: tEl: or Other D: Description: Section(s): Description: Paragraphs 37 and 23.0 EPA Consent Decree Quarterly Report for HollyFrontler Navajo Refining {Artesia and Lovington) or CD No. CIV-01 1422LH Reviewed By: " \ Permit Condition(s}: Date Reviewed: HFNA-000003307 EPA Inspection Report - Page 1758 of 1969 CALENDAR QUARTERLY REPORT SUBMITTED PURSUANT TO SECTION IX OF THE CONSENT DECREE ENTERED IN UNITED STATES OF AMERICA ET Al. V. NAVA.JO REFINING COMPANY, l.P., AND MONTANA REFINING COMPANY (ENTERED MARCH 5, 2002) Cumulative from Lodging (December 20, 2001) Through June 30, 2019 HollyFrontier Navajo Refining LLC (formerly Navajo Refining Company, l.LC.) Artesia and Lovington, NM Refineries P.O. Box 159 Artesia, NM 88211-0159 HFNA-000003308 EPA Inspection Report - Page 1759 of 1969 £al~ndar Quarterly Report - 2nd Quarter 2019 Ho!lyFrontier Navajo Refining LLC, Artesia and Lovington Refineries TABLE OF CONTENTS 1.0 INTRODUCTION ............................................................................................................:1:~- 2.0 PROGRESS REPORT ON IMPLEMENTATION OF SECTION V OF THE CONSENT DECREE .....................................................................................................................................2 3.0 SUMMARY OF ACTUAL OR ANTICIPATED PROBLEMS IN IMPLEMENTING THE REQUIREMENTS OF SECTION V ...........................................................................................24 4.0 SUMMARY Of EMISSIONS DATA ..............................................................................24 5.0 IMPLEMENTATION OF ENVIRONMENTALLY BENEFICIAL PROJECTS .................. 28 6.0 OTHER MATTERS .......................................................................................................33 ATTACHMENTS ATTACHMENT 1 -APPENDIX G SUMMARY REPORT ATTACHMENT 2 - APPENDIX H SUMMARY REPORT ATTACHMENT 3 - QUARTERLY EOL SUMMARY ATTACHMENT 4 - 2QT 2019 EOL ANALYTICAL REPORTS ii HFNA-000003309 EPA Inspection Report - Page 1760 of 1969 Calendar Quarterlv Report - 2nd Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries CALENDAR QUARTERLY REPORT Cumulative from Lodging (DECEMBER 20, 2001) Through June 30, 2019 HollyFrontier Navajo Refining LLC (Navajo) Artesia and Lovington, NM Refineries 1.0 INTRODUCTION In accordance with the requirements of Section !X of the Consent Decree entered in UNITED STA TES OF AMERICA ET Al., D. V.M NAVAJO REFINING COMPANY, L.P., AND MONTANA REFINING COMPANY (entered March 5, 2002), Navajo submits the following "calendar quarterly report" for the Artesia and Lovington, NM refineries. Section IX requires that the quarterly report be submitted within 30 days following the calendar quarter. Today's report covers actions through the second quarter 2019. For completeness, this report addresses relevant actions or activities not just within the current quarter but anytime after the December 20, 2001 Date of Lodging. The contents of this report include: 1. 2. 3. 4. 5. A progress report on the implementation of the requirements of Section V (Section 2.0) A description of any problems anticipated with respect to meeting the requirements of Section V (Section 3.0) A summary of the emissions data as required by Section V (Section 4.0); A description of environmentally beneficial projects and SEP implementation activity during this reporting period (Section 5.0); and Such other matters as Navajo believes should be brought to the attention of EPA (Section 6.0). Summaries showing the progress on Consent Decree Appendices G and H are provided as Attachments 1 and 2, respectively, 1 HFNA-000003310 EPA Inspection Report - Page 1761 of 1969 Calendar Quarterly Report - 2nd Quarter 2019 Hol!yFrontier Navajo Refining LLC, Artesia and Lovington Refineries 2.0 PROGRESS REPORT ON IMPLEMENTATION OF SECTION V OF THE CONSENT DECREE A. Section V, Paragraphs 11 and 14: NOx and CO Emission Rech.1ctions from FCCUs Paragraph 12: S02 Emission Reductions from fCCUs Paragraph 13: PM Emission Reductions from FCCUs ; . · · -Artesia - · - -FCCU · · · ·(No · · ·FCCU · - - at ~Lovin ~ ~ton .......... ,,1:.............................................................................................................._ .. Requirement CD Status/Comment Para ra h ..........................-·---+------------~~--------.......................................................................................................--..,,..; i Begin baseline period, 11.B Requirement completed. The optimization period 1 · perform notices of Low- NOx was completed and the optimized addition rate to be promoter and optimization used during the demonstration period was study. Baseline period data submitted to EPA with supporting documentation on collection from 1/1/04 2/24/05. 6/30/04. Optimization period , to commence no later than I June 30, 2004. ........................................... ...................................................----------------............................................................ [ Commencement of NOx 11.D i As agreed between Navajo and EPA, the i Additive Demonstration ' i Demonstration Period ended 05/31/2006. Navajo li_::;;;3~ L i ~~bo~'.~~1ii~r:~:o_n_c-e_n_tr-at-io_n_-_ba_s_e_d_N_O_x-lim-its 2 HFNA-000003311 EPA Inspection Report - Page 1762 of 1969 Requirement Status/Comment ............... ·················co········ """"""·------···, ~-----------P_aragr~ph........................................................................................ ········································-···· Install/certify CEMS to 11.F CEMS installed and certification RATA performed monitor FCCU NOx and 02 11/13/03. Report showing initial certification by 12/31/03. submitted to NMED on 1/7/04. Pursuant to 40 CFR 60 App F, annual RATA performed 02/14 and 02/15/06. Report showing certification submitted to NMED on 03/15/06. Pursuant to 40 CFR 60 App F, annual RATA performed 01/24/07. Report showing certification submitted to NMED on 02/22/07. Pursuant to 40 CFR 60 App F, annual RATA performed 01/22/08. Report showing certification submitted to NMED on 02/18/08. Pursuant to 40 CFR 60 App F, annual RATA performed 03/03/09. Report showing certification submitted to NMED on 03/30/09. Pursuant to 40 CFR 60 App F, annual RATA performed 03/02/2010 and 03/03/2010. Report showing certification submitted to NMED on 04/05/2010. Pursuant to 40 CFR 60 App F, annual RATA performed 03/01/2011. Report showing certification submitted to NMED on 03/28/2011. Pursuant to 40 CFR 60 App F, annual RATA performed 01/17/2012. Report showing certification submitted to NMED on 02/17/2012. Pursuant to 40 CFR 60 App F, annual RATA performed 01/08/2013. Report showing certification submitted to NMED on 02/07/2013. Pursuant to 40 CFR 60 App F, annual RATA performed 01/08/2014. Report showing certification submitted to NMED on 02/04/2014. Annual RATA performed 01/06/2015. Report submitted to NMED on 02/05/2015. Annual RATA performed 01/05/2016. Report submitted to NMED on 02/04/2016. Annual RATA performed 01/03/2017. Report submitted to NMED on 02/04/2017. Annual RATA performed 01/09/2018. Report submitted to NMED on 02/09/2018. Annual RATA performed 02/13/2019. Report submitted to NMED on 03/23/2019. A review of documentation of QC procedures under 40 CFR 60 App. F was recently undertaken. Documentation of all QC procedures in accordance with 40 CFR 60 App. F was completed as of 12/31/2017, 3 HFNA-000003312 EPA Inspection Report - Page 1763 of 1969 , .......... ............................................................ Requirement .......... rtesia and Lovington Re ineries ··------··-----·-- ,- ••••••••••••••••••ssssssssssssssssssssssssssssssss,,, CD ..........,,-. ····························--·----------- Status/Comment Par~g(~P~ .......................... ••••••••••••••••··••••••••••ssssssssssssssssssssss Submit plan to minimize NOx from FCCU during GOHT outages within 180 days of lodging Date. 11.G Plan Submitted on 6/18/02. EPA's response letter dated 12/9/04 enumerated the requ irements for Navajo to have relief from the short term NOx emission limit. Install and operate wet gas scrubber on FCCU to meet 25 ppmv (annual avg) and 50 ppmv (7-day) S02 by 12/31/03. 12.B Wet gas scrubber installed and ope rational during 4th Quarter 2003. S02 performance testing completed on 10/16/03; report sub mitted 1/7/04. ····································••••••••••••••••••••• ........ . 4 HFNA-000003313 EPA Inspection Report - Page 1764 of 1969 Calendar Quarterly Report - 2nd Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries I ~:~~~~::.e~~ : :: } Install and calibrate S02 CEMS in accordance with 40 CFR 60.11, 60. 13 and Part 60 App. F Par~:aph ::::::::: 12.D .. ........... -~~:~~~'~_o_m_m_e_nt_ _ _·_· · ·_· · ·_· · · · · · · · · · CEMS installed and certification RATA performed 11 /13/03. Report showing initial certification submitted to NMED on 1/7 /04. Pursuant to 40 CFR 60 App F, annual RATA performed 02/14 and 02/15/06. Report showing certification submitted to NMED on 03/15/06. Pursuant to 40 CFR 60 App F, annual RATA performed 01/24/07. Report showing certification submitted to NMED on 02/22/07. Pursuant to 40 CFR 60 App F, annual RATA performed 01/22/08. Report showing certification submitted to NMED on 02/18/08. Pursuant to 40 CFR 60 App F, annual RATA performed 03/03/09. Report showing certification submitted to NMED on 03/30/09. Pursuant to 40 CFR 60 App F, annual RATA performed 03/02/2010 and 03/03/2010. Report showing certification submitted to NMED on 04/05/2010. Pursuant to 40 CFR 60 App F, annual RATA performed 03/01/2011. Report showing certification submitted to NMED on 03/28/2011. Pursuant to 40 CFR 60 App F, annual RATA performed 01/17/2012. Report showing certification submitted to NMED on 02/17/2012. Pursuant to 40 CFR 60 App F, annual RATA performed 01/08/2013. Report showing certification submitted to NMED on 02/07/2013. Pursuant to 40 CFR 60 App F, annual RATA performed 01/08/2014. Report showing certification submitted to NMED on 02/04/2014. Annual RATA performed 01/06/2015. Report submitted to NMED on 02/05/2015. Annual RATA performed 01/05/2016. Report submitted to NMED on 02/04/2016. Annual RATA performed 01/03/2017. Report submitted to NMED on 02/04/2017. Annual RATA performed 01/09/2018. Report submitted to NMED on 02/09/2018. Annual RATA performed 02/13/2019. Report submitted to NMED on 03/23/2019. See entry for Paragraph 11.F. regarding 40 CFR 60 ........ ""~Rf?.: F QC procedures. ................................. 5 HFNA-000003314 EPA Inspection Report - Page 1765 of 1969 Calendar Quarterly Report- 2nd Quarter 2019 HollyFrontier Navajo Refining llC, Artesia. and Lovington Refineries I Requirement "f""""" CD • I " Status/Commin"i"""-"""" I 1·wGSshaH achieve 1 lb p.i\if·········rE~rr~~P..~Twet gas scrubber installedandope.raiionaTciuring""""""; • per 1000 lb coke bum on 3-hr l 4th Quarter 2003. basis by 12/31/03. I PM testing completed 11/13/03 and report submitted 1/7/04. Results of 0.5-0.6 lb PM per 1,000 lb coke burn compared to <1.0 lb PM per 1,000 lb coke bum standard. Additional testing was performed 3/3/04 following repairs to the scrubber. These test results indicate <0.25 lb PM per 1,000 lb coke bum (i.e., 25% of standard). --------- _I 1.................. 6 HFNA-000003315 EPA Inspection Report - Page 1766 of 1969 Calendar Quarterly Reoort - 2nd Quarter 2019 HollyFrontier Navajo Refining llC, Artesia and Lovington Refineries ~----················································· ·······.,........... Requirement """"',""'"""""'""""'""""""""···· CD I ! Paragraph I • ----- .............................................. Status/Comment • I ~:s~! ;~~ ~~~~~~vo~n 1-hr ..r. . . 1. 4~~Ina. . . L~~:i·~~o~~~~~:s~~~~~~~du~tt/~.~~~~-6/~;p~~MS "1 annual avg. by 12/31/03. Install/Certify CEMS for FCCU CO and 02 by 12/31/03. showing certification submitted to NMED on 1/7/04. Pursuant to 40 CFR 60 App F, annual RATA performed 02/14 and 02/15/06. Report showing certification submitted to NMED on 03/15/06. Pursuant to 40 CFR 60 App F, annual RATA performed 01/24/07. Report showing certification submitted to NMED on 02/22/07. Pursuant to 40 CFR 60 App F, annual RATA performed 01/22/08. Report showing certification submitted to NMED on 02/18/08. Pursuant to 40 CFR 60 App F, annual RATA performed 03/03/09. Report showing certification submitted to NMED on 03/30/09. Pursuant to 40 CFR 60 App F, annual RATA performed 03/02/2010 and 03/03/2010. Report showing certification submitted to NMED on 04/05/2010. Pursuant to 40 CFR 60 App F, annual RATA performed 03/01/2011. Report showing certification submitted to NMED on 03/28/2011. Pursuant to 40 CFR 60 App F, annual RATA performed 01/17/2012. Report showing certification submitted to NMED on 02/17/2012. Pursuant to 40 CFR 60 App F, annual RATA performed 01/08/2013. Report showing certification submitted to NMED on 02/07/2013. Pursuant to 40 CFR 60 App F, annual RATA performed 01/08/2014. Report showing certification submitted to NMED on 02/04/2014. Annual RATA performed 01/06/2015. Report submitted to NMED on 02/05/2015. Annual RATA performed 01/05/2016. Report submitted to NMED on 02/04/2016. Annual RATA performed 01/03/2017. Report submitted to NMED on 02/03/2017. Annual RATA performed 01/09/2018. Report submitted to NMED on 02/09/2018. Annual RATA performed 02/13/2019. Report submitted to NMED on 03/23/2019. See entry for Paragraph 11.F. regarding 40 CFR 60 App. F QC procedures. 7 HFNA-000003316 EPA Inspection Report - Page 1767 of 1969 Calendar Quarterl:t: Report- 2nd Quarter 2019 HollyFronUer Navajo Refining LLC, Artesia and Lovington Refineries B. Section V, Paragraph 15: NSPS Applicability of FCCUs 1==~~~~~i~~~o.FC:r~~J:~: L. . . . . . . . . Slalus/Coni===-=--J , NSPS becomes applicable to ! FCCU for S02, PM, CO and opacity on 12/31/03. I I 15 I Wet gas scrubber installed and operational during I 4th Quarter 2003. PM performance testing, initial I I • GEMS certification RATA for S02 and CO completed 11/13/03 and report submitted 117/04. AMP for opacity submitted 12/31/03; pending written approval. Method 9 readings indicate O 5% opacity. Annual PM testing per AMP was performed 2/8/05 indicating 0.11 lb PM/1000 lb coke. Annual PM testing per AMP was performed 2/15/06 indicating 0.19 lb PM/1000 lb coke. Annual PM testing per AMP was performed 1/24/07 indicating 0.34 lb PM/1000 !b coke. Annual PM testing per AMP was performed 1/22/08 indicating 0.13 lb PM/1000 lb coke. Annual PM testing per AMP was performed 3/3/09 indicating 0.47 lb PM/1000 lb coke burned. Annual PM testing per AMP was performed 03/02/2010 and 03/03/2010.indicating 0.54 lb PM/1000 lb coke burned. Annual PM testing per AMP was performed 03/01/2011 indicating 0.23 lb PM/1000 lb coke burned. Annual PM testing per AMP was performed 01/17/2012 indicating 0.39 lb PM/1000 lb coke burned. Annual PM testing per AMP was performed 01/08/2013, which did not show compliance, and again on 3/04/2013 indicating 0.204 lb PM/1000 lb coke burned. Annual PM testing per AMP performed 01/08/2014 indicating 0. 71 lb PM/1000 !b coke burned. Report showing certification submitted to NMED on 02/04/2014. Annual PM testing per AMP performed 01/06/2015 indicating 0.11 lb PM/1000 lb coke burned. Report submitted to NMED on 02/05/2015. Annual PM testing per AMP performed 01/05/2016 indicating 0.35 !b PM/1000 lb coke burned. Report submitted to NMED on 02/04/2016. Annual PM testing per AMP performed 01/03/2017 indicating 0.03 lb PM/1000 lb coke burned. Report submitted to NMED on 02/03/2017. Annual PM testing per AMP performed 01/09/2018 indicating 0.50 lb PM/1000 lb coke burned. Report submitted to NMED on 02/09/2018. Annual PM testing per AMP performed 02/13/2019 indicating 0.10 lb PM/1000 lb coke burned. Report submitted to NMED on 8 HFNA-000003317 EPA Inspection Report - Page 1768 of 1969 Calendar Quarterly Report- 2nd Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries , .... c. Section.v, .. Para9r~phJ6: __NOx Emissions Reductionsfrom...Heaters an~Boilers ..... Requirements I CD I Status/Comment L" "· """" ..... L.Paragraph J ............................................. ·········------------···················· • Install NOx control on B-7 by I 16.B.ii. and 1 FGR started up on 12/17/2002. CEMS installed 12/31/02 to meet 0.06 16.C.i. and was successfully certified by a RATA lb/MMBtu and operate CEMS • performed 12/18/2002. Test results and CEMS on B-7 for NOx and 02. • indicate B-7 meets NOx control requirement. 1 Pursuant to 40 CFR 60 App F, annual RATA performed 09/26/2006, 09/13/2007, 09/09/2008, 09/17/2009, 08/24/2010, 08/16/2011, 08/15/2012, 08/07/2013. RATA performed 07/30/2014. Certification report submitted to NMED on 09/11/2014. RATA performed 07/23/2015. Certification report submitted to NMED on 08/20/2015. RATA performed 07/13/2016. Certification report ' submitted to NMED on 08/05/2016. RATA performed 06/21/2017. Certification report submitted to NMED on 07/20/2017. RATA performed 03/06/2018. Certification report submitted to NMED on 03/29/2018. RATA performed 03/19/2019. Certification report submitted to NMED on 04/18/2019. .......................................... ···1ifrfii. and I acfi:iaffriTffai startlip_a_n_d_s_h_a-ke-d-own Install NOx control on B-8 by 12/31/03 to meet 0.06 16.C.i. [ period on 7/23/03. NOx controls and CEMS lb/MMBtu and operate CEMS ' operational. CEMS RATA and B-8 performance on B-8 for NOx and 02. testing done 10/29/03. Test report submitted 12/8/03. Pursuant to 40 CFR 60 App F, annual RATA performed 09/26/2006, 09/13/2007, 09/09/2008, 09/17/2009, 08/24/2010 08/16/2011, 08/15/2012, 08/06/2013, 07/30/2014. : RATA was performed 07/29/2014. Certification I report submitted to NMED on 09/11/2014. : RATA was performed 07/22/2015. Certification • report submitted to NMED on 08/20/2015. ;i RATA was performed 07/13/2016. Certification I report submitted to NMED on 08/05/2016. RATA performed 06/21/2017. Certification report : submitted to NMED on 07/20/2017. j RATA performed 03/07/2018. Certification report ! submitted to NMED on 03/29/2018. RATA performed 03/19/2019. Certification report ............ !. . submitted to NMED on 04/18/2019. .......... .................."""'""-· 1 I s=s'5eiian 1 I g HFNA-000003318 EPA Inspection Report - Page 1769 of 1969 Calendar Quarterly Regort - 2na Quarter 2019 Hol!yFrontier Navajo Refining LLC, Artesia and Lovington Refineries j. ••••••••••••••••••••••••••.-~--~~q~u~ir~e~m~e~n~t_s________~ I Install next-generation ultra- , low NOx control on H-20 and PHe-~o1rma: Ancrteesteia treHf~n e ~.nd 5 11 "' - 2 0 Cl! H-601. Establish compliance indicators by an initial performance test !.·.. 4 [. j i I 1 J. . . . . . . . - ~~~~~~~--····~~:-~~~~~~.::::~ . . . . . Par;fJ~aph .. --~--1 16.B.i., I H-601 burners installed. Testing conducted on 16.C.iii., and 3/2/04. Report including proposed compliance Appendix C / indicators and permit limits was submitted 5/14/04. i H-20 burners installed prior to 12/31/05 deadline I and heater resumed operation 12/29/05. :I H-20 performance test conducted on 02/16/06. . Report submitted to NMED on 03/23/06. Permit I limit proposed in air permit application submitted to i NMED on 4/27/06. NMED issued permit 6/23/06. I •••••••••••••••••••••••••••••••••ccccc•••cc•cc=cc _ _ _ _ _ """"W«••••••••••••••••••••• 10 HFNA-000003319 EPA Inspection Report - Page 1770 of 1969 Calendar Quarterly Reno rt - 2nd Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries •••••••••••••••••••••••••••••••••••••••••••••••••••••••·~~------------ ••••••••••••••••••••••••••••••••••• ••••••••••ss,-·.•.•n. Requirements CD Status/Comment ··················"<««··«······Pa_r_ag-r_a~p_h-_ _ _ _ _ __ Install next-generation ultra16.B.i., Heater H-101 was removed from service low NOx control on H-101 at 16.C.ii., and November 2003. Lovington refinery. Operate Appendix C Navajo installed NGULNBs in the new Crude Oi! CEMS or PEMS on H-101 by Charge Heater (H-103) that replaced H-101. 12/31/05. Installation of H-103 was completed during December 2003 turnaround and began operation after 4th Quarter turnaround. As-installed duty of NGULNBs was < 150 MM Btu/hr, but > 100 MM Btu/hr. H-103 initial testing done 03/04/04. Test report, including proposed parametric monitoring plan and permit limits, was submitted 05/14/04. The permit with new limits was approved on 02/21/2006. In 02/2009, Navajo installed eight additional NGULNBs in the Crude Oil Charge Heater (H-103) that replaced H-101. As-installed duty of NGULNBs was > 150 MM Btu/hr, so a NOx CEMS was installed. An initial performance test and the NO:x: CEMS RATA were conducted 05/21/2009. Pursuant to 40 CFR 60 App F, annual RATA performed 05/20/2010, 08/16/2011, 05/24/2012. RATA was performed 05/14/2013. Certification report submitted to NMED on 06/10/2013. RATA was performed 05/13/2014. Certification report submitted to NMED on 06/12/2014. RATA was performed 05/06/2015. Certification report submitted to NMED on 06/04/2015. RATA was performed 05/04/2016. Certification report submitted to NMED on 06/03/2016. RATA was performed 04/25/2017. Certification report submitted to NMED on 05/16/2017. RATA was performed 02/14/2018. Certification report submitted to NMED on 03/14/2018. RATA was performed 03/05/2019. Certification report submitted to NMED on 04/08/2019. Based on a review, not all QC procedures for heaters and boilers with CEMS may be documented in accordance with 40 CFR 60 App. F. The 4th quarter 2017 Consent Decree progress report inadvertently cross-referenced the entry for Paragraph 11.F. (pertaining to the FCCU) and did not explain that QC procedures for heaters and boilers with CEMS may not have been fully documented. A review of documentation of QC procedures under 40 CFR 60 App F was undertaken. A QA/QC manual was finalized in January 2019. 11 HFNA-000003320 EPA Inspection Report - Page 1771 of 1969 Calendar Quarterly Report- 2nd Quarter 2019 Hol!yFrontier Navajo Refining lLC, Artesia and Lovington Refineries !_____ Requ~:~~:: :~~~:: : :::::···::::::::::::,.:::::;~!~g~~P.h."'.L Install next-generation ultralow NO:x: control on H-600 and 70-H1/H2/H3 at Artesia refinery. Performance test H600, and 70-H1/H2/H3. Establish compliance indicators by 12/31/09. low NOx control on B-SG1101 A and B-SG-1101Bat Lovington refinery by 12/31 /09. Conduct performance test 8-SG1101 A and B-SG-1101Band establish compliance indicators. Status/Comme~~:::::::::::::::::::::::. .: : : : : : : : : : :· · · "'"'"' 16.B.i., 1 H-600: Air permit 0195-M25-R3 authorizing the I 16.C.iii., and burner retrofit was issued by NMED on 05/14/08. Appendix C The retrofit was completed in 02/2009. The performance test was conducted 03/04/09 and the test report submitted 03/30/09. Administrative permit revision 0195-M26-R1 effective 04/14/2009. 70-H1/H2/H3: NGULNBs were installed in CCR Heaters 70-H 1/H2/H3 in May 2006 and heaters resumed operation on 6/2/06. Performance test conducted 7/11/06 and test report submitted 8/15/06. An application for a proposed permit limit was submitted to NMED 9/28/06. NMED issued PSD-NM-0195-M25 on 12/14/2007. An air permit application proposing installation 16.C.iii., and of NGUlNBs in SG-1101A and SG-11018 was Appendix C submitted to NMED on 12/21/2007. Permit 0273M? authorizing the retrofit with NGULN8s was issued by NMED on 05/06/2008. Navajo subsequently decided to replace the existing i boilers with new boilers using NGUlNBs. Permit 0273-M7-R1 authorizing the replacement boilers was issued by NMED on 10/14/2009. Boiler SG11 OB was permanently shut down on 12/05/2009. Its replacement, B0-1104, began operation on 12/17/2009. Initial performance testing was conducted 01/28/2010 on 80-1104 and the report submitted to NMED on 02/24/2010. Because of initial operating problems with 80-1104, the second boiler, SG-1101A was not permanently shut down until 01/04/2010. Its replacement, B01105, began operation on 01/15/2010. Initial performance testing was conducted 01/26/2010 on B0-1105 and the report submitted to NMED on 2/24/2010. The B0-1105 initial performance test was conducted on 1/26/2010, and the report submitted to the AQB on 02/24/2010. The B01104 initial performance test was conducted on 01/28/2010, and the report submitted to the AQB on 02/24/2010. The burners installed with B01105 and B0-1104, were subsequently found to not meet the NGULN8 performance specification in the Consent Decree. The installation of NGULN8 in 80-1105 was completed 06/20/2013. The installation of B0-1104 NGULNB was completed 07/29/2013. B0-1105 NOx Performance Test was completed 07/12/2013 and the results were submitted to NMED on 08/06/2013. 80-1104 NOx Performance Test was completed 09/04/2013 and the results were submitted to NMED on 12/05/2013. 12 HFNA-000003321 EPA Inspection Report - Page 1772 of 1969 Calendar Quarterly Report - 2nd Quarter 2019 Ho!lyFrontier Navajo Refining lLC, Artesia and Lovington Refineries ;.----R_e_q_u_ir_e_m_e_n_ts--~ Submit proposed NOx permit limits within 120 days of NOx control technology installation. J. . II. . . . . . . : : : : : : : :~: . Par~;aph ..... 16.D Status/C::::.nt Requirement completed. ·······························•• ~ ., B -7 : Pro.posed B-7 NOx limit submitted to NMED 0 113 110 3 B-8: Proposed B-8 NOx limit submitted to NMED 12/8/03. H-601: Proposed H-601 NOx limit submitted 5/14/04 in stack test report and permitted in 195M 17 as issued 12/15/04. H*103 (Lovington Refinery): Proposed H-103 NOx limit submitted 5/14/04 in stack test report; on 2/21/06 NMED issued 0273-M4 to add the NO.x ·• limit After installing additional NGUlNBs in • 02/2009, the limits were confirmed in the • 05/21/2009 test and included in Permit 0273-M7R1 issued by NMED on 10/14/2009. H-20: Proposed H-20 NOx limit submitted to NMED in air permit application on 04/27/06; permit 0195-M24 issued 06/23/06. 70-H1/H2/H3: Proposed 70-H1/H2/H3 NOx limit submitted to NMED in air permit application on 09/28/06; permit PSD-NM-0195-M25 issued 12/14/2007. H-600: Proposed H-600 NO.x limit authorized by NMED air permit administrative revision effective on 04/14/09. B0-1104 and B0-1105: (replacement boilers for 8-SG-110A and B-SG-1101 B). Proposed 80-1104 and B0-1105 NOx limits submitted to NMED in air permit application on 04/13/201 O; permit 0273-MB issued 07/19/2010. ! 13 HFNA-000003322 EPA Inspection Report - Page 1773 of 1969 meries I Submit annual progress 16.E • report on NOx control technology 1 First report was submitted 12/19/02. The report for 2003 was submitted 12/29/03 with supplemental information provided 1/8/04. 2004 report submitted 12/31/2004. 2005 report submitted 12/31/2005. 2006 report submitted 12/11/2006. 2007 report submitted 12/20/2007. 2008 report submitted 12/19/2008. 2009 report submitted 12/28/2009. 2010 report submitted 12/15/2010. 2011 report submitted 12/31/2011. 2012 report submitted 12/11/2012. 2013 report submitted 12/18/2013. 2014 report submitted 12/19/2014. 2015 report submitted 12/31/2015. 2016 report submitted 12/30/2016 2017 report submitted 12/28/2017. 2018 report submitted 12/27/2018. D. Section V, Paragraph 17: S02 Emissions Reductions from Heaters and Boilers and ...................... f\l.SPS_Applicabilit '"""""" ............................. ············--····· · · · · · · --·· · · · · · · · · · Requirements CD Status!Comment Para ra h NSPS Subparts A and J 17.B i Commenced 12/20/01 become applicable to Heaters • See entry for Paragraph 16.B.i., 16.C.ii., and and Boilers by Date of • Appendix C on p. 12 of this report regarding 40 lodging. • CFR 60 App. F QC procedures. ••••••••••••••••••••••••••••••••••••••••••••••••ssssssssss--- ······································-··-------"-----~- E. Section V, Pc1rc19_r~e!i!; :1.~ andCD J~~ N~F~APP.li~~l:>ili~yff?.r.§.~.E ~~I:!~ Flaring Devices. Status/Comment Requirements ......... ··········.·· I SRP shall comply with NSPS I J limit and monitor tail gas I emissions by Date of ...•..Paragraph 18.C.i. and • Com me need 12/20/01. 18.C.ii. I See entry for Paragraph 11.F. regarding 40 CFR • 60 App. F QC procedures. ••••••••••••••••••••••ccccccccccccc--------- L_Lodging. 14 HFNA-000003323 EPA Inspection Report - Page 1774 of 1969 Calendar Quarterly Regort - 2nd Quarter 2019 "' Ho!lyFrontier Navajo Refining LLC, Artesia and Lovington Refineries --------"'Requirements________ I J_ _ Parag-r_a~p_h-_ _ _ __ NSPS Subparts A and J become applicable to Flares by Date of Lodging. Appendix E 't 1mit AMP plan for Flares FL-400, Fl-401, FL-402 and FL-403 within 90 days of Lodging Date. ___________ _________________________ "' CD Appendix E Status/Comment Commenced 12/20/01. The recent implementation of flare monitoring requirements under NSPS Ja resulted in the identification and repair of several relief valves that were leaking to the flare. In addition, three flare gas streams with higher sulfur levels were identified as routed to the Lovington flare. These I three streams were rerouted to the fuel gas system. As of November 11, 2015, all gas streams currently routed to the flares are monitored for compliance with the NSPS Ja requirements. Excess emission information for the flares at Artesia and Lovington for the semiannual period: January-June 2016 was included in Attachment 4 to the 3rd quarter 2016 Consent Decree Progress Report The excess emission information for events occurring during the semiannual period: July-December 2016 was included in the semiannual NSPS monitoring report submitted on January 30, 2017, and was attached to the 1st quarter 2017 Consent Decree Progress Report. Excess emission information for events occurring during the semiannual period: January-June 2017 was included in the semiannual NSPS Ja monitoring report submitted on July 28, 2017, and was attached to the 3rd quarter Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: July-December 2017 was included in the semiannual NSPS monitoring report submitted on January 30, 2018, and was attached to the 1st quarter 2018 Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: JanuaryJune 2018 was included in the semiannual NSPS monitoring report submitted on July 30, 2018, and was attached to the 3rd quarter 2018 Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: JulyDecember 2018 was included in the NSPS monitoring report submitted on January 30, 2019, and was attached to the 1st quarter Consent Decree Progress Report. t Submitted 3/19/02. 15 HFNA-000003324 EPA Inspection Report - Page 1775 of 1969 Calendar Quarterly Regort - 2nd Quarter 2019 Ho!lyFrontier Navajo Refining LLC, Artesia and Lovington Refineries ------------------------------------------·----·----- Requirements - · · · · ---~~:~~-:-~~cnn:: :~:_ : : :· : :"·"- - -· ] CD Para.graph • NSPS Subparts A and J ! become applicable to Flare FL-1001 at Lovington refinery on 12/31/06. Appendix E Submit AMP plan for Flare FL-1001 at Lovington refinery Appendix E Off-Gas Scrubber system for sweetening sour LPG before combusting in flare completed by 12/31/06. ............................................ --········--·--·""""""""""" by_ 7/30/07. ... ···-------------, : Submit enhanced Maintenance and Operation plan for SRP (PMO plan) within 270 days of Date of ································--·--····· ---------------········· ······················------i An approvable AMP was submitted 02/14/07. AMP is pending EPA approval. ...................................... 18.D I ---------------~ ,,,................ ................ --------------~ Plan submitted on 9/16/02 and updated on 03/24/05. The !ast revision was completed on ! i i 09/2017 [Lodging._____ ···········-----------------------------······---~----~18.E ! Study commenced by 1/1/04 deadline. I SRP by 1/1/04. -~--·················.,,.,.... i------j Complete optimization study 18.E i Navajo retained a third party to coordinate • on SRP and report results by • performance testing for the optimization study and • i 12/31/04. prepare a report which was submitted to EPA on • 12/31/04. • Commenced 12/20/01. ---------------------································-! 19.E ! Begin optimization study on ! , i i:-~~~::u~~~~e'~~~~~: 1 i • shutdowns affecting ! Lovington refinery by Date of • lodging. '""" ··················································· -------------·····----------------- c.,,,,. ····················.,,,,,,...... . ······························---------- F. Section V, Paragraphs 20 and 21: Control of Acid Gas Flaring, Tail Gas Incidents and Hydrocarbon Flaring ------------------------------------------------------ Requirements -----------------'---------········---··················--············---- CD Paragraph Status/Comment ···················(···-------- .;------ Perform root cause analyses for acid gas and tail gas incidents beginning on -~edging Date. Perform root cause analyses for hydrocarbon flaring incidents beginning on Lodging Date. 20 Commenced 12/20/01, ... ····:ir·················-~ '"com"menced 12126R51:··· ·······------±- ·························--------------------···-------------< -----------------~------------···········-,--............, ......... . G. Section V, Paragraph 22: Benzene Waste NESHAP t Status/Comment Requirements ------···---······r····-~:·;~~=·····-~·-···· --------------------------------- ----~.--9_...JJ__________ _ -------------- I 16 HFNA-000003325 EPA Inspection Report - Page 1776 of 1969 Calendar Quarter!·, R HollyFrontier Navajo rt - 2 110 Quarter 2019 ing LLC, Artesia and Lovington Refineries ..................................................................................................................." " " " ' · ~ - - - - ~ Requirements Status/Comment CD Pa Phase Oneofthe·----"" !!.Complete review and verification of the h 22.CJ. Completed 09/11/02. 1 i TAB by 9/16/02. !,-,·- - - - - - - ~ - - - - - - - - + - - - - - - - - - - - .......................................................................i 22.CJ. Report of results submitted on 10/09/02. I Compliance Review and I Submit BWN Phase One Verification report for EPA approval by 10/16/02. • Submit amended TAB report if BWN Compliance Review shows reporting applied. Establish annual review program ·····1 , 22.D.i. Amended TAB report waS included in the 10/09/02 . submittal. !,,,,,. 22.E [ Completed as part of Phase One review and is • now ongoing. 1 · ~·-···········································································································) ...............................................· .......................................... Train employees who conduct ' 22.G and sampling. 22, M.iLa( 1) Submit schematics of • Waste/Slop/Off-Spec Oil ! Management by 03/20/02. ! Conduct annual sampling of waste streams which the BWN Compliance Review and Verification Report showed to be 0.05 Mg/yr or greater. 22.H.L A training plan was developecFon 12/06/62 for the Artesia Refinery (Le., since its TAB is greater than 1.0 Mg/yr). The first training session was held 01/07/03 at both the Artesia and Lovington refineries. The second training session for the two refineries was held 1/27/04 and 01/28/04. Annual refresher training for the two refineries was performed the weeks of 02/08/05, 03/27/06, · 03/05/07, 02/25/08 (lov), 11/07/08 (Art), 12/18/09, 12/17/1 O and 12/20/2011. BWON TAB training was conducted on at the Artesia and Lovington refineries on 11/08/2012 01/14/2013 and 04/18/2013, 11 /12 to 11/14/2013, 05/24/2014, 06/22/2014, 12/12/2014, 3/16/2015, 4/1/2015, 5/15/2015, 2/29/2016, 3/8/2016, 3/17/2016, 09/25/2017, 11/08/2018, and 11/12/2018. ! Submitted on 03/19/02. Revised schematics reflecting NSPS QQQ were submitted 04/29/04. Schematics are awaiting approval by EPA. The annual sampling was performed in February 2005. The results were in Attachment 4 to the first quarter 2005 report. Annual sampling performed in February 2006. The results were in Attachment 4 of the first quarter 2006 report. Annual sampling was performed in September and December 2007. The results were submitted in attachment 4 of the first quarter 2008 report as I required by ~22.M.ii.a(2). • Annual sampling was performed in December • 2008. The results were in attachment 4 of the first i quarter 2009 report as required by 'If22.M.!La(2). Annual sampling was performed in December 2009. The results were submitted in attachment 4 ........................ ........... ......of. thefirstquarter.. 2010 report. as .. require_d_b'"""y_ ____, 22.J.i. and 22.MJi.a(2) 17 HFNA-000003326 EPA Inspection Report - Page 1777 of 1969 Calendar Quarterly Reeort- 2nd Quarter 2019 HollyFrontier Navajo Refining lLC, Artesia and Lovington Refineries Requirements ·····"""""""""1. .Par~g~aph.....1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .St~~~~.~~::~:~: ·- · · · : : : : : : : : : : ·:I ,I22.M.ii.a(2). Annual sampling was performed in December 2010. The results were in attachment 4 of the first quarter 2011 report as required by ,I22.M.ii.a(2). Annual sampling was performed in December 2011. The results are ln Attachment 4 of the first quarter 2012 report as required by ,I22.M.ii.a(2). Annual sampling was performed in December 2012. The results were submitted in Attachment 4 of the first quarter 2013 report as required by 1f22.M.ii.a(2). Annual sampling was performed in December 2013. The results were submitted in Attachment 4 of the first quarter 2014 report as required by 1f22.M.ii.a(2). Annual sampling was performed in December 2014. The results were submitted in Attachment 4 of the 1st quarter 2015 report as required by ,T22.M.ii.a(2). Annual sampling was performed in December 2015. The results were included in Attachment 4 of the 1st quarter 2016 report as required by ,T22.M.ii.a(2). Annual sampling was performed in October 2016. The results were included in Attachment 4 of the 1st quarter 2017 report as required by 1f22.M.ii.a(2). Annual sampling was performed in December 2017. The results were included in Attachment 4 and 7 of the 1st quarter 2018 report as required by ,r22.M.ii.a(2). Annual sampling was performed in December 2018. The results were included in the 1st quarter J '· : Meet with NMEo···ancr·EPA at the refinery and submit an annual end of line (EOl) sampling plan - applicable to Artesia Refinery (i.e., TAB is equal to or greater than 1 Mg/yr but less than 10 Mg/yr). . . . . """""""""""""""""'""'':?g_:t9 report as required,J?yj}g?.:.M:Ji.:..:1.f.?1........ 22.J.ii ' Navajo was notified by NMED and EPA via email dated 12/9/02 that the ,I22.J.li visit by the agencies would not occur. Navajo met the deadline by submitting the EOl sampling plan on 2/6/03. Conditional approval of the plan was received from EPA by letter dated 1/23/04. Navajo responded by submitting a revised EOL sampling plan by letter dated 3/31 /04. ••••••••••·~~~---··-------~---------------~'""••••••••••••••••••••••••••••••••••••• •••••••••••••ssssssss""'~ 18 HFNA-000003327 EPA Inspection Report - Page 1778 of 1969 Calendar Quarterl;t; f.85% was developed · and these pumps are using the 2,000 ppm leak definition for all monitoring subsequent to 12/20/03. All pump monitoring using internal leak definition of 2,000 ppm after 4/20/05. This was completed upon CD lodging. Crude Vent Compressor (C-150A/B) is now included in the LOAR monitoring program. l•_ _lodg ing .___ -------------------------------ssssss-.---""""""""'"I,""""""'" First attempt at repairs on 23.G Commenced with January 2002 quarterly monitoring. • valves that have voe reading I > 200 ppm within 90 days of •.._lodging _ Date. __________________________________________________________ .____________________________________ _ Quarterly monitoring of valves Completed by 12/20/01. 23.H.ii. - no Skip Period by Date of lodgin~;. ____ Commenced with May 2002 monitoring. 23.1.i. LDAR database to include date, time, operator, and • instrument within 6 months of I __ Date__ of__Lodging.. __ -------------------------------------..--.1 . .- - - - ~ - - - •••••••••••••••••••••••••••••••••••••••••••••ccccccccccc------- WWW __ l • """""""""""""""""'"""""""""---'················''"····· 21 HFNA-000003330 EPA Inspection Report - Page 1781 of 1969 Calendar Quarterly Re2ort - 2nd Quarter 2019 Hoi!yFrontier Navajo Refining lLC, Artesia and Lovington Refineries Requirements Pa;;g';..ph I- ~/Comment Submit operational 23.1.ii., and Submitted 6/19/02. specifications designed to 23.0.i.b. m!n!mize non-electronic data collection and transfer within 6 months of Date of _Lodgin;g Develop/ implement 23:J Procedure developed on 3119102 and includec:fa~ i procedure for LOAR data an appendix in the written LOAR program. J QA/QC within 90 days of LLodging,_Date .....................- ....- .........._ _,,__ _ _ _- + - - - - - - - - - - - -........................................................................ I E~~;~~ ::_I__:~ i Completed by 12120101. 1a~;a~~~:e l~~S'.~~§l3.L [ Conduct calibration/drift I -~~~~~~02ana··1s · 23.M 1..... 23.N:iL l Commenced on 12/20/01. I assessments of monitoring i instruments at the end of ! each shift by the Date of 1 I~o~;i';~~ingeni'defay..of're.pafr .. 0 i requirements including drill i and tap for valves reading >10,000 ppm by Date of : lodging. 1Commenced on 12)26701. II. I 1 <-----------,,i,,~, ! Submit written facility-wide l. ~~~~~~~-~.li~nce progra: i Submit LDAR report with MACT Periodic reports. ! ••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• L 23.0.i.a. 23. O.ii.c. I Submitted 05/13/2002. ••••••••••••••••••ss"" _ __ The monitoring results were incorporated into the periodic reports submitted pursuant to 40 CFR 63.654 on: 3/15/02, 9/13/02, 3/15/03, 9/15/03, 3/15/04, 9/15/04, 3/14/05 (3/15/05 for Lovington), 9/13/05 (9/15/05 for Lovington), 3/17/06, 9/13/06 (9/06/06 for Lovington), 3/16/07, 09/14/07, 3/17/08, 9/12/08, 03/16/09, 08/27/09, 03/16/2010, 09/13/2010, 03/16/2011, 03/09/2012 and 09/06/2012 (09/06/2012 for Lovington), 03/15/2013, 09/16/2013, 02/25/2014 (Artesia), 08/26/2014 (Lovington), 02/26/2015 (Artesia and Lovington), 08/27/2015 (Artesia and Lovington), 02/18/2016 (Artesia and Lovington), 08/29/2016 (Artesia and Lovington), 02/28/2017 (Artesia and Lovington), 08/29/2017 (Artesia and Lovington), 08/30/2018 (Artesia and Lovington), and 02/28/2019 (Artesia and Lovington) . .......................................................................................................... , .., - - 22 HFNA-000003331 EPA Inspection Report - Page 1782 of 1969 Calendar Quarterly Report - 2n° Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries I. S~~:~~:~::;:graph 24:Jnc~gorate[CD __ Requiremen~t~~~~/~~:~:~~le"Permits ,:- -Within - - - - - - - - - - -180 - - - - - - -days - - - - - - - - -of- - - -Date - - - - - - - -of- - -· · · · · · · · ·I··"'· · ·Paragraph · · · · · ·24.A --I Applications - - - - - - - - - - - - - - - - to- - - - -revise - - - - - - - - -" "·the - -"- - - - -NSR - - "· - - - · · ·permits · · · · · · · · · - - - - - -for - - - - - the - - - -" " " . . . . . __• 1 I Lodging, submit an I Artesia and Lovington refineries were submitted i 5/28/02. j application for Federally : enforceable NSR permit to incorporate of limits, standards, or schedules I effective on the Date of !...Lodging ..... I Submit applications within 30 •· days of the effective date or I establishment of limits, I standards, or schedules .pursuant to the CD. "· "". . . . Permit revision issued for Lovington on 10/15/03. Permit revision for Artesia issued 12/15/04. I I Section V, Paragraph 25: 5::~:;;::b~· ••••••••••••••··--------------------·ssssssss~nnnnn-- UtiUze construction permits to implement control projects required by the CD. ---~-----------··--~----------·----------------------------··--------------------< 24.B : Navajo's understanding is that ,I16 NOx limits for .• boilers and heaters, which require permit I application filing within 120 days after start-up I : under ,I16.D, are not subject to 1[24.B. No other • • limits under Section V have occurred __ to.date. _____ I 1• J Obtaining Construction Permits ···········································~ ~h ~ RequirementC;~:::~mmem •I The 5/28/02 NSR permit revision application for the • :~~s~a~=~i~~z ;~;'~~~=~ted the installation of the • Navajo submitted an application to NMED on ! 4/9/03 to install a new crude heater (H-103) at the • Lovington refinery. The permit was issued I 10/15/03. H-103 began operation in 12/03. Since • heater H-103 replaced H-101 (i.e., the existing • crude heater which requires burner retrofit by 12/05 I under the CD) and uses NGULNBs, this effectively II achieves early implementation of the NOx emission • reductions sought by the CD . • In order to retrofit heater H-20 with NGULNB by • 12/31 /05, Navajo submitted a significant revision • air permit application to NMED on 04/12/05. Since NMED had not completed the application review, a • waiver allowing limited construction activities to • begin was granted on 10/11/05. Permit Oi95-M21, • authorizing NGUlNB for H-20, was issued by • NMEDon 11/18/05. II An air permit application proposing the installation . . . . . . . . . . . . .1..9.LN.G.l:J.b.N~!:;JIJ ~9~J1Q§_m:>rmerly SG-11 O1A) am:l 11 23 HFNA-000003332 EPA Inspection Report - Page 1783 of 1969 rt - 2nd Quarter 2019 g LlC, Artesia and Lovington Refineries ·····································'''''"'····· ' R · t \ CD ,. . . . . . . . . . .::.~.1.~:.::."-s--.. . . . . J.....~.~~~graph I I Status/Comment B0-1104 (formerly SG-1101 B) was submitted to NMED on 12/21/2007. Permit 0273-M? authorizing the NGULNBs in SG-1101A and SG-1101 B was issued by NMED on 05/06/2008. Navajo subsequently decided to replace the existing boilers with new boilers using NGUlNBs. Permit 0273-M7-R1 authorizing the replacement boilers was issued by NMED on 10/14/2009. The installation of NGULNB in B0-1105 was completed 06/20/2013. The installation of B0-1104 NGULNB was completed 07/29/2013. H-600: Air permit 0195-M25-R3 authorizing the burner retrofit was issued by NMED on 05/14/08. in 02/2009. The retrofit was 3.0 SUMMARY OF ANTICIPATED PROBLEMS IN IMPLEMENTING THE REQUIREMENTS OF SECTION V. None at this time. 4.0 SUMMARY Of EMISSIONS DATA • • • • • • • • • • • The Boiler B-7 initial performance stack test and CEMS RATA was conducted on 12/18/2002 and the results submitted to the NMED on 01/31/2003. The Boiler B-8 initial performance stack test and CEMS RATA was conducted on 10/29/2003 and the results submitted to the NMED on 12/08/2003. The Heater H-601 initial performance stack test was conducted on 03/02/2004 and the results were submitted to the NMED on 05/14/2004. The Heater H-103 (replacement for H-101) initial performance stack test was conducted on 03/04/2004 and the results were submitted to the NMED on 05/14/2004. Data was collected for reporting pursuant to Paragraph 11 (e.g., FCCU NOx optimization and demonstration period data.) NOx Additive Demonstration Period report with proposed NOx concentration-based limits submitted 07/27/2006. The FCCU Regenerator Scrubber_CEMS RATA was conducted on February 14 and 15, 2006 and the results were submitted to the NMED on 03/15/2006. The FCCU Regenerator Scrubber annual PM test was conducted on 02/15/2006 and the results were submitted to the NMED on 03/15/2006. Heater H-20 was retrofit with NGULNBs in December 2005. A performance stack test was conducted on 02/16/2006 and the results were submitted to the NMED on 03/23/2006. Heaters H-352, H-353, and H-354 (formerly identified as 70-H1/H2/H3) were retrofit with NGULNBs in June 2006. A performance stack test was conducted on 07/11/2006 and the results were submitted to the NMED on 08/15/2006. The Boiler B-7and Boller B-8 annual CEMS RATAs were conducted on 09/26/2006 and the results submitted to the NMED on 10/17/2006. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/24/2007 and the results were submitted to the NMED on 02/22/2007, 24 HFNA-000003333 EPA Inspection Report - Page 1784 of 1969 Calendar Quarterlz' Re2ort - 2nd Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries • • • • • • • • • • • • • • • • • • • • • • • The FCCU Regenerator Scrubber annual PM test was conducted on 01/24/2007 and the results were submitted to the NMED on 02/22/2007. The Heater H-20 annual performance stack test was conducted on 01/25/2007 and the results were submitted to the NMED on 02/22/2007. The Boiler B-7and Boiler B-8 annual CEMS RATAs were conducted on 09/13/2007 and 09/12/2007 respectively, and the results submitted to the NMED on 10/11/2007. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/22/2008 and the results were submitted to the NMED on 02/18/2008. The FCCU Regenerator Scrubber annual PM test was conducted on 01/22/2008 and the results were submitted to the NMED on 02/18/2008. The Heater H-20 annual performance stack test was conducted on 01/23/2008 and the results were submitted to the NMED on 02/18/2008. The Boiler B-7and Boiler B-8 annual GEMS RATAs were conducted on 09/09/2008 and the results submitted to the NMED on 10/09/2008. The FCCU Regenerator Scrubber GEMS RATA was conducted on 03/03/2009 and the results were submitted to the NMED on 03/30/2009. The FCCU Regenerator Scrubber annual PM test was conducted on 03/03/2009 and the results were submitted to the NMED on 03/30/2009. Heater H-600 was retrofit with NGULNBs in 02/2009. The Heater H-600 initial performance stack test was conducted on 03/04/2009 and the results were submitted to the NMED on 03/30/2009. The Heater H-20 annual performance stack test was conducted on 03/05/2009 and the results were submitted to the NMED on 03/30/2009. After adding additional burners, the Heater H-103 (replacement for H-101) performance stack test and NOx GEMS RATA was conducted on 05/21/2009 and the results were submitted to the NMED on 06/22/2009. The Boiler B-7and Boiler B-8 annual CEMS RATAs were conducted on 09/17/2009 and the results submitted to the NMED on 10/14/2009. The B0-1105 (replacement boiler for Lovington boiler 8SG-1101A) initial performance testing was conducted 01/26/2010 and the report submitted to NMED on 02/24/2010. The B0-1104 (replacement boiler for Lovington boiler BSG-1101 B) initial performance testing was conducted 01/28/2010 and the report submitted to NMED on 02/24/2010. The FCCU Regenerator Scrubber GEMS RATA was conducted on 03/02 and 03/2010 and the results were submitted to the NMED on 04/05/2010. The FCCU Regenerator Scrubber annual PM test was conducted on 03/02 and 03/2010 and the results were submitted to the NMED on 04/05/2010. The Heater H-20 annual performance stack test was conducted on 03/04/2010 and the results were submitted to the NMED on 04/05/2010. The Heater H-103 {replacement for H-101) NOx GEMS RATA was conducted on 05/19/2010 and 05/20/2010, and the results were submitted to the NMED on 06/16/2010. The Boiler B-7and Boiler B-8 annual GEMS RATAs were conducted on 08/24/2010 and the results submitted to the NMED on 09/14/2010. The FCCU Regenerator Scrubber CEMS RATA was conducted on 03/01/2011 and the results were submitted to the NMED on 03/28/2011. The FCCU Regenerator Scrubber annual PM test was conducted on 03/01/2011 and the results were submitted to the NMED on 03/28/2011. The Heater H-20 annual performance stack test was conducted on 03/02/2011 and the results were submitted to the NMED on 03/28/2011. 25 HFNA-000003334 EPA Inspection Report - Page 1785 of 1969 Calendar Quarterly Report - 2nd Quarter 2019 Hol!yFrontier Navajo Refining llC, Artesia and Lovington Refineries • • • • • • • • • • • • • • • • • • • • • • • • The Boiler B-7and Boiler B-8 annual GEMS RATA's were conducted on 08/16/2011 and the results submitted to the NMED on 09/16/2011. The Heater H-103 (replacement for H-101) NOx GEMS RATA was conducted on 05/3/2011 and the results were submitted to the NMED on 05/31/2011. The Heater H-20 annual performance stack test was conducted on 01/19/2012 and the results were submitted to the NMED on 02/27/2012. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/17/2012. Report showing certification submitted to NMED on 02/17/2012. The FCCU Regenerator Scrubber annual PM test was conducted on 01/17/2012. Report showing certification submitted to NMED on 02/17/2012. The Heater H-103 (replacement for H-101) NOx CEMS RATA was conducted on 05/24/2012, and the results were submitted to the NMED on 06/20/2012. The Boiler B-7and Boiler B-8 annual CEMS RATA's were conducted on 08/15/2012 and the results submitted to the NMED on 09/13/2012. The Heater H-20 annual performance stack test was conducted on 01/09/2013 and the results were submitted to the NMED on 02/07/2013. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/08/2013. Report showing certification submitted to NMED on 02/07/2013. The FCCU Regenerator Scrubber annual PM test was conducted on 01/08/2013. Report showing certification submitted to NMED on 02/07/2013. The Heater H-103 (replacement for H-101) NOx and CO GEMS RATA was conducted on 05/14/2013, and the results were submitted to the NMED on 06/10/2013. The FCCU Regenerator Scrubber annual PM was retested on 03/05/2013. Report showing certification submitted to NMED on 04/01/2013. The Boiler B-7 annual CEMS RATA's was conducted on 08/07/2013 and the results submitted to the NMED on 09/17/2013. The Boiler B-8 annual GEMS RATA's was conducted on 08/06/2013 and the results submitted to the NMED on 09/17/2013. The Heater H-20 annual performance stack test was conducted on 01/09/2014 and the results were submitted to the NMED on 02/04/2014. The FCCU Regenerator Scrubber annual PM was tested on 01/08/2014. Report showing certification submitted to NMED on 02/04/2014. The FCGU Regenerator Scrubber CEMS RATA was conducted on 01/08/2014. Report showing certification submitted to NMED on 02/04/2014. After the installation of NGULNB was completed, the B0-1105 (replacement boiler for Lovington boiler BSG-1101A) initial performance testing was conducted 07/12/2013 and the report submitted to NMED on 08/06/2013. After the installation of NGULNB was completed, the 80-1104 (replacement boiler for Lovington boiler BSG-1101 B) initial performance testing was conducted 09/04/2013 and the report submitted to NMED on 12/05/2013. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATAwas conducted on 05/13/2014, and the results were submitted to the NMED on 06/12/2014. The Boiler B-7annual CEMS RATA's was conducted on 07/30/2014 and the results submitted to the NMED on 09/11/2014. The Boiler B-8 annual CEMS RATA's was conducted on 07/29/2014 and the results submitted to the NMED on 09/11/2014. The Heater H-20 annual performance stack test was conducted on 02/17/2015 and the results were submitted to the NMED on 03/09/2015. The FCCU Regenerator Scrubber annual PM was tested on 01/06/2015. Report showing certification submitted to NMED on 02/05/2015. 26 HFNA-000003335 EPA Inspection Report - Page 1786 of 1969 Calendar Quarter!J: Re.gprt - 2nd Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries • • • • • • • • • • • • • • • • • • • • • • • • • The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/06/2015. Report showing certification submitted to NMED on 02/05/2015. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATA was conducted on 05/06/2015, and the results were submitted to the NMED on 06/04/2015. The Boiler B-7 annual CEMS RATA's was conducted on 07/23/2015 and the results submitted to the NMED on 08/20/2015. The Boiler B-8 annual CEMS RATA's was conducted on 07/22/2015 and the results submitted to the NMED on 08/20/2015. The Heater H-20 annual performance stack test was conducted on 01/07/2016 and the results were submitted to the NMED on 02/05/2016. The FCCU Regenerator Scrubber annual PM was tested on 01/05/2016. Report showing certification submitted to NMED on 02/04/2016. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/05/2016. Report showing certification submitted to NMED on 02/04/2016. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATAwas conducted on 05/04/2016, and the results were submitted to the NMED on 06/03/2016. The Boiler B-7 annual CEMS RATA's was conducted on 07/13/2016 and the results submitted to the NMED on 08/05/2016. The Boiler B-8 annual CEMS RATA's was conducted on 07/13/2016 and the results submitted to the NMED on 08/05/2016. The Heater H-20 annual performance stack test was conducted on 01/05/2017 and the results were submitted to the NMED on 02/03/2017. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/03/2017. Report showing certification submitted to NMED on 02/03/2017. The FCCU Regenerator Scrubber annual PM was conducted on 01/03/2017. Report showing certification submitted to NMED on 02/04/2017. The Boiler B-7 annual CEMS RATA's was conducted on 06/21/2017 and the results submitted to the NMED on 06/20/2017. The Boiler B-8 annual CEMS RATA's was conducted on 06/21/2017 and the results submitted to the NMED on 06/20/2017. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATA was conducted on 04/25/2017, and the results were submitted to the NMED on 05/16/2017. The Heater H-20 annual performance stack test was conducted on 01/11/2018 and the results were submitted to the NMED on 02/09/2018. The FCCU Regenerator Scrubber CEMS RATA was conducted on 01/09/2018. Report showing certification submitted to NMED on 02/09/2018. The FCCU Regenerator Scrubber annual PM stack test was conducted on 01/09/2018. Report showing certification submitted to NMED on 02/09/2018. The Boiler B-7 annual CEMS RATA's was conducted on 03/06/2018 and the results submitted to the NMED on 03/29/2018. The Boiler B-8 annual CEMS RATA's was conducted on 03/07/2018 and the results submitted to the NMED on 03/29/2018. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATA was conducted on 02/14/2018, and the results were submitted to the NMED on 03/14/2018.The Heater H-20 annual performance stack test was conducted on 02/20/2019 and the results were submitted to the NMED on 03/21/2019.• The FCCU Regenerator Scrubber CEMS RATA was conducted on 02/13/2019. Report showing certification submitted to NMED on 03/23/2019. The FCCU Regenerator Scrubber annual PM stack test was conducted on 02/13/2019. Report showing certification submitted to NMED on 03/23/2019. 27 HFNA-000003336 EPA Inspection Report - Page 1787 of 1969 Calendar Quarterlv Report - 2nd~ Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries • • • The Boiler B-7 annual CEMS RATA's was conducted on 03/19/2019 and the results were submitted to the NMED on 04/18/2019. The Boiler B-8 annual CEMS RATA's was conducted on 03/19/2019 and the results were submitted to the NMED on 04/18/2019. The Heater H-103 (replacement for H-101) NOx and CO CEMS RATA was conducted on 03/05/2019, and the results were submitted to the NMED on 04/08/2019. Consistent with past reports, any emissions excursions from Consent Decree limits have generally been reported to NMED pursuant to the NSPS, MACT and/or Title V programs semiannually (as well as pursuant to NMED's excess emissions reporting program). We are in this report identifying emissions excursions that occurred in the 2nd quarter 2019 for the emission limits and units below. For the flares at Artesia and Lovington, excess emission information for events occurring during the semiannual period: January-June 2019 will be reported in the semiannual NSPS Ja monitoring report due on July 30, 2019, and will be attached to the 3ra quarter 2019 Consent Decree Progress Report. Consent Decree Condition V.18.B: SRU S02 Emission limits SRU-2 [ S02 250 ppm 12-hr average •••••••••••••••••••••••••••ss•••ss,~nn~nn,n=n-nf•••• Start Time Excess Emissions per Event End Time ········---------------------------------------------.----- 2019-04-03 10:00 2QJ§l~94J.>~ ?Q:qq • {IIJ.ts.2 ......................- - . 10.95 •••••••••••cc•••ccccccccccccc•------J 2019-06-14 22:00 2019-06-15 23:00 25.27 2019-06-17 21:00 2019-06-18 09:00 12.16 5. Implementation of ENVIRONMENTAllY beneficial Projects [Changes from Prior Quarter Italicized] Paragraph 35 requires certain information to be submitted for each project which has been completed. The projects for Paragraphs 30 and 32 have been completed. The following summarizes the status of the completed and ongoing projects, and highlights actions taken thus far: 28 HFNA-000003337 EPA Inspection Report - Page 1788 of 1969 Calendar Quarterly Report - 2nd Quarter 2019 HollyFrontier Navajo Refining llC, Artesia and Lovington Refineries Environmentally Beneficial t~:fSPS aa6~~c:~es applicable to Artesia and Lovington individual drain systems, oil-water separators, and aggregate facilities by 12/31/03 ·1 ---------------------··············································~~~~~~~~~~~~~~~----~ CD Status/Comment t . . Par;:~ph__ _ : Prior to 12/31 /03, Navajo began operation ofthe new covered wastewater sepa(ator, completed the bypass of the South Plant API, installed covers on junction boxes and initiated drain inspections for the Artesia refinery. Junction boxes at the Lovington refinery were also covered and the routine inspection of drains (to assure proper water seal) was begun. Navajo otherwise ceased the use of an open culvert for draining oily process wastewater into the sewer. , In early September 2010, it was discovered that the storm water catch basin of the A!kyiation Unit ' Tar Pit could still receive some oily-water and therefore could be considered as a junction box. A cover for the storm water basin was designed, constructed, and installed by 11/12/2010. In July 2014, it was discovered that visual inspections were not conducted initially and semiannually as required by 40CFR 60.692-2 (07/11/2014 self-disclosure letter to NMED. Certified Receipt Number: 70073020000030288246). Navajo Started semiannual inspections on 07/01/2015. A third party review of the QQQ program indicated that there may be a potential issue regarding certain aspects of the drain systems at the Artesia and Lovington refineries, in particular, the status of catch basins in these drain systems. Subpart QQQ exempts drain systems that have catch basins in their existing configuration prior to the rule's applicability date. Navajo is nevertheless evaluating the proactive retrofit of these catch basins with covers (inserts), and has initiated a capital project to address this. Retrofit work is in progress and is expected to be completed by the end of calendar year 2020. I 29 HFNA-000003338 EPA Inspection Report - Page 1789 of 1969 Calendar Quarterly Report - 2nd Quarter 2019 Hol!yFrontier Navajo Refining LLC, Artesia and Lovington Refineries B. Section V, Paragraph 30: Operation of the 40 l TPD SRU {SRU1} on Standby Artesia SRP (No SRU at Lovington): :. Environmentally Beneficial · i~~~~~~n I Complete of : equipment on SRU 1 to allow • operation in standby service : by 12/31/03 --~----------- CD .. Para3g0aph I ··········································· Status/Comment ................ ...... ., • rs·FfU1 was started up again on 5/10/03 ·operaffn·g···a1·1 I a reduced rate in backup service. ' i A new 100 long ton per day sulfur recovery unit I (SRU3) began operating 05/11/2009. The I combined capacity of SRU2 and SRU3 provides • excess sulfur recovery capacity. Therefore, as an • energy and emissions conservation measure, • SRU1 is no longer operated in standby service. ............. .............................. [······························································································ Complete study plan on how to limit excess TGU emissions and Acid Gas Flaring by 2/28/04 30 · . . . . . . . . . . . . . . . . . . . . .! Acid Gas Flaring and TGU Excess Emissions Study Plan submitted 2/27/04. Pursuant to the plan, Navajo completed the study and submitted a 3/24/05 summary of the study including actions taken and recommendations. The study results were used to update the PMO plan with the modified PMO plan included with the 3/24/05 submittal. ............................................................1...................................................................- - - - - - - C. Section V, Paragraph 31: Installation of Spare FCCU Wet Gas Compressor Artesia FCCU (No FCCUat Lovington}: ···················----····· ...... .................................................................. Environmentally Beneficial I CD Status/Comment • Project Paragraph . tt:omp!ete installation of spare : wet gas compressor by I 12/31/03. Operate so as to i minimize the duration of AG or HC flaring incidents during outages of the original compressor, 31 A spare wet gas compressor was installed during J the 4th Quarter of 2003 FCCU turnaround. On 01/07/2011, Navajo's outside legal counsel submitted a request to modify or remove this paragraph. Operating procedures to minimize the duration of AG flaring were updated 04/30/2015. A preventive maintenance plan for the spare compressor C-0950 was completed on 05/11/2015. 30 HFNA-000003339 EPA Inspection Report - Page 1790 of 1969 Hol!yFrontier Navajo Refining lLC, Artesia and Lovington Refineries D. Section V, Paragraph 32: Supplemental Environmental Project (SEP) Benefiting the ........................ Artesia..Community _____ ------~-------·········································· : Environmentally Beneficial CD Status/Comment I Project Paragraph I Complete implementation of Navajo completed the community SEP prior to the ···--1 revised 9/29/03 deadline and submitted cost certification data on 9/23/03 pursuant to Paragraph 32 ! SEP to benefit the Artesia community by June 30, 2003 91. The SEP installed mechanical mixers to replace air mixers on nine asphalt storage tanks to reduce odors. The tanks were T-0110, T-0404, T-0405, T0406, T-0409, T-0410, T-0428, T-0431, and T• 0432. T-0404, T-0405, T-0406, and T-0409, and T-0428 ..................................... .., ... have .. been.permanently. removed from service. I E. Sectior,V,Paragraph __33: _ EMS ..Baseline.Assessment.for.Artesia.. Refinery Environmentally Beneficial CD Status/Comment Project Paragraph ••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••--·••---------------------------------------------,ssssss•---· 1 ~~~~~~~~tDC~~~;~;t~ /~ • • perform the baseline • assessment r Execute contract with 33.C ·····+···············3::f o' t... lndependent ..Contractor ............... Completed via letter from NMED dated 4/19/02. Completed as of 4/15/02 t........................ .... . . . . . . . . . . . . . . . . . . . . . . . ________________, Baseline Assessment Report 33. E Navajo received the baseline assessment report on to be received by Navajo 7/17/02. within 210 days of Date of Lodgin"' ~-~~-------------4""--------------••••••••••••••••••••••••••••••••••••••••••••••··••••••··••• Navajo has accepted the recommendations and Navajo to implement 33.F schedule deadlines provided in the baseline report recommendations in (the 8 recommendations are numbered in accordance with the baseline parenthesis in the discussion below). For the two report schedule (i.e., 1A and 5) recommendations with 10/1/02 deadlines, Navajo implemented both on time {i.e., prior to the deadline). The report to file required by CD ,T33.F.ii was completed 12/27/02. •••••••••••ssssssss~' ;-------------------4""--------------~················································---···--- Navajo to implement recommendations in accordance with the baseline report schedule -Cont'd 33.F Navajo did the roll-out of the refinery environmental policy (1 B) and put environmental responsibilities (3) into a new specifically developed operator's manual prior to the baseline report recommendation deadline (Le., 2/1/03 and 3/1/03, respectively). 31 HFNA-000003340 EPA Inspection Report - Page 1791 of 1969 Calendar guarterlv Reeort - 2nd Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries ( Environmenta1iy Beneficial r. . . . . . . cif. . . . ·················---···········""""""""""""" Status/Comment • Project ....- ................................1.....Parag.....r...a .......P.....h........,...................................................... - - -.. . . . . . . . . . . . . . . . . ... · 33.F The position descriptions (6) which were recommendations in recommended for Navajo's Environmental Affairs • accordance with the baseline Department staff were prepared and distributed • report schedule prior to the 7/1/03 deadline. An independent · - Cont'd consultant performed an on-site evaluation of Navajo's implementation of the recommendations and prepared a 6/23/03 evaluation report prior to : the 6/30/03 deadline. I ----.......- -..- - - - - - - - - - - - - - - + Navajo to implement 33.F [ Per the independent consultant's June 2003 recommendations in : evaluation report, the 9/1/03 original deadline for accordance with the baseline · the recommended CBT training module (2) was report schedule revised to 3/1 /04. . .............J -Cont'd Navajo to implement 33.F 1 Work commenced in November 2003 on recommendations in developing the CBT training module (2). The CBT accordance with the baseline I module was completed and rolled out on 2/27/04, report schedule thus meeting the 3/1/04 deadline. The decision was made to implement (7) via the electronic - Cont'd I option (6/1/04 deadline). Recommendation No. 8A, "Develop Environmental Records Retention Policy • and Document Control Procedures" was •:: implemented prior to the 12/1/03 deadline. Navajo to implement 33.F • Completed the evaluation of the LOAR program, recommendations in • process and procedures (4) on 6/3/04 and accordance with the baseline • determined that the program is working as report schedule • intended. Integrated compliance requirements -Cont'd • calendar (7) was implemented prior to the 6/1/04 • deadline. Completed work to implement the • environmental records management system (8B) • during May 2004 with the aid of an outside • consultant The records management system is in • place and working. An independent consultant • conducted the implementation evaluation • presented in a June 30, 2004 report, thus meeting • the deadline. A final closure letter on the EMS improvement recommendations was issued September 30, 2004 by the consultant concluding I no remaining EMS improvement actions for Navajo . I Navajo to implement I I I I ! ••••••···••••••••••••••••••ccccccccccc•••••••'CC• •••••••••••••ccccccccccccccccccccccccccccccccccc~•••-----i--------------- ....................................... , I I I ......................... S..... .. .................................................................................." ..- .............. ___ 32 HFNA-000003341 EPA Inspection Report - Page 1792 of 1969 Calendar Quarter! HollyFrontier Navajo 6.0 - 2nd Quarter 2019 ng LLC, Artesia and Lovington Refineries OTHER MATTERS The recent implementation of flare monitoring requirements under NSPS Ja resulted in the identification and repair of several relief valves that were leaking to the flare. In addition, three flare gas streams with higher sulfur levels were identified as routed to the Lovington flare. These three streams were rerouted to the fuel gas system. As of November 11, 2015, all gas streams currently routed to the flares are being monitored for compliance with the NSPS Ja requirements. Excess emission information for the flares at Artesia and Lovington for the semiannual period: January-June 2016 was included in Attachment 4 to the 3rd quarter 2016 Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: July-December 2016 was included in the semiannual NSPS monitoring report submitted on January 30, 2017, and was attached to the 1st quarter 2017 Consent Decree Progress Report. Excess emission information for events occurring during the semiannual period: January-June 2017 was included in the semiannual NSPS Ja monitoring report submitted on July 28, 2017, and was attached to the 3rd quarter Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: January-June 2018 was included in the semiannual NSPS Ja monitoring report submitted on July 30, 2018, and was attached to the 3rd quarter 2018 Consent Decree Progress Report. The excess emission information for events occurring during the semiannual period: July-December 2018 was included in the semiannual NSPS Ja monitoring report submitted on January 30, 2019. The excess emission information for events occurring during the semiannual period: January-June 2019 will be reported in the semiannual NSPS Ja monitoring report due on July 30, 2019, and will be attached to the 3rd quarter 2019 Consent Decree Progress Report. 33 HFNA-000003342 EPA Inspection Report - Page 1793 of 1969 Calendar Quarterly Report - 2nd Quarter 2019 HollyFrontier Navajo Refining LLC, Artesia and Lovington Refineries HFNA-000003343 EPA Inspection Report - Page 1794 of 1969 .ATTACHMENT 1 APPENDIX G SUMMARY REPORTS HFNA-000003344 EPA Inspection Report - Page 1795 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 2nd QUARTER 2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT REPORTS, PLANS AND CERTIFICATIONS UNDER THE BENZENE WASTE NESHAP ENHANCED PROGRAM PROVISIONS OF PARAGRAPI-I 22 OJT THE CONSENT DECREE IN UNITED STATES ET AL. V. NAVAJO REFINING CO. ET AL. IName or Summary of the l R~P9rt,fi~µ:i,,gr l r ..Certification -.-.-.-.-.-.-.-.-.-.- - - - - - - - - - - - - - - - - - - - - - - - - - CD SubPara No. i Rqd. ("R") v. Contingent ("C") One-Time ("l ") v. Quarterly orw/ §63.654 Reports (''> 1") Due Date Status -----···········;;;;;;;;-;-;-;-:-.:-:-:-,= BWN Compliance Review and Verification Report R C.L 1 270 days after Lodging Review completed 09/11/2002. Report submitted 10/09/2002 uuuuu,u. Amended BWN Compliance Review and Verification Report uu•••• ••••••••••••••••• -~~~•••••~~~•••••~~~ ·••••••••••~~~••~~~ ·•••••••.-; C.ii. ...-~~-.-.-= ~~=~~~.- --------··;;/ .-.-.-.-.-.·-·-·-·-=~ C 1 90 days after completing additional sampling requested by EPA Not Yet Applicable. EPA has not requested additional sampling. ~ Amended TAB Report D.i C 1 60 days after completing BWN Compliance Review and Verification Report An Amended Report for the Artesia Refinery (>1 Mg, <10 Mg) was Submitted 10/09/2002 with the Verification Report Plan to comply w/ 6 BQ if TAB equals or is greater than 10 D.H; J.vi. C 1 180 days after completing BWN Compliance Review and Verification Report Not Applicable unless the Al1esia or Lovington Refinery exceeds 10 Mg/yr in the annual TAB report uu~.-.-.-.-.-.-.-. I ,,,, uuuuuuuu~~- "Tl z :r0 0 0 0 0 (,) (,) .i:,,. 01 ········~~~~~~~~~~~~~~~~~~~-~~ Pagel of 12 ••••••••••••••••••nu~ EPA Inspection Report - Page 1796 of 1969 HoI1yFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 2nc1 QUARTER 2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT -.-.---.-.-.-.-.- 1 CD i Rq d . I0 ne-T.1me Sub- I("R") I("1 ") V. Para Iv. Corrt- Quarterly ingent orw/ No. (''C") §63.654 Reports ("> l "} Compliance Certification D.iv C 1 30 days after completing all actions necessary to come into compliance Not Applicable unless the Artesia or Lovington Refinery exceeds 10 Mg/yr in the annual TAB report. Waste/Slop/Off-Spec Oil Schematics H.i. R 1 90 days after Lodging Submitted on 03/19/2002. Revised plan reflecting plant modifications submitted 04/29/2004. Schematics are. ~w~!!~O,/i ~rf!!;en. ae2roval by EPA. Submit revised Waste/Slop/Off-Spec Oil Schematics reflecting agreement with EPA on comments. H.i. C 1 Mutually-agreed upon time between Navajo and/or Montana Refining and EPA Not Applicable until EPA confers with Navajo on the Waste/Slop/Off-Spec Oil Schematics. , Schedule to complete installation of controls on waste management units I handling organic benzene waste H.ii. Mutually-agreed upon time between Navajo and/or Montana Refining and EPA, not to exceed 2 years Not Applicable unless the Artesia or Lovington Refinery exceeds 10 Mg/yr in the annual TAB report DueDat~ ~~~~~~uuu~~~~~~~uuuuuu-~u-····••••••••••ccc·· Status ---------··;;;- .;.;.;.;.;.;.;.;.;.;.;.;.;....~-;-;.uuuuuuu~ '""" i r t C l I Plan to quantify uncontrolled waste/slop/off-spec oil movements I "Tl ----------------~~~~~~----~~~------~~~~~~~~~~~~~-,,, ......................................... ..........................-.-.-.-.-.-...-...-...---.---~ H.iv. R l 'I u u u u u u u ...... ""........................-.-.-.--------- --------------------------------------------~~ 90 days after EPA has approved schematics (,) (,) 0) . .................••••••• ·~~~~~~~~ Not Applicable until EPA provides written approval of the Waste/Slop/OffSpec Oil Schematics. Although EPA has not commented on or approved the schematics submitted under paragraph 22.H.i, Navajo has quantified the tmcontrolled waste/slop/off-spec oil movements in the annual NESHAP Subpart FF Total Annual Benzene (TAB) repm1. ........................................................- - . z .i:,,. .-.------------------------------------ ~~~~~~~ :r0 0 0 0 0 .-•••••,;-:-:-:-:----;,.z..;,.;,.;,.;,.;,.;,.;,,· 1 Name or Summary of the Re.port.,.. Plan, or Certification, Page 2 of 12 EPA Inspection Report - Page 1797 of 1969 HollyFrontier Navajo Refming LLC Artesia and Lovington Refineries Al'TACHMENT 1 TO 2nd QUARTER 2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT =~~=~~=~=~=~~-~~,~=-=-;.,..,.-.~~-:-:-;-;-;-;-;-;...~~--~-=-=-;...~~- Name or Summary ofthe R~port, . :PJ<1:n,.or Certification -------------------·---------------········-: CD SubPara No. Rqd. ("R") v. Contingent ("C"} -.-.·.·.·.-.-.-.-.-.-.-.-.-.-.-uuuu.-,~ ""'"-"' One-Time ("1 ") V. Qumter1y orw/ §63.654 Reports (">_I_") " - " - - " ~ ' "'""""""""""""""·---.-.-.-.-. •••••••••••••••••••••••••••••••••••••·-~~~~~·nu,~,~ Due Date Stat~ """""""""" EO L Sampling Plan U; C 1 2 months after the 22.D.iii Certification (if TAB is 10 mg/yr or greater); 90 days after submitting fmal BWN Compliance Review and Verification Report (if TAB is 1 Mg/yr or more but less than 10) EOL Sampling Plan submitted on 02/06/2003. C As needed If and when Navajo and/or Montana Refm:ing become aware of factors indicating original plan no longer accurately reflects EOL benzene quantity Revised EOL Sampling Plan submitted 03/31/2004. C As needed J.ii EOL Revised Sampling Plan I.ii; J.ii. Applicable after refinery TAB exceeds ] 0 Mg/yr Plan to ensure that uncontrolled benzene does not equal or exceed, 6 Mg/yr or that it is minimized I.vii; --------------------------------------------~~------------~~--~~~~~~~~~~ ----.-.-~ ----.-.-.-----------------.-.-.-.-.-------.-. I "Tl z :r0 0 0 0 0 (,) (,) .i:,,. -..,J 30 days after the end of the quarter in which the projected calendar year benzene quantity is equal to or greater than6Mg. Not Applicable unless the Artesia or Lovington Refme1y exceeds l OMg/yr in the annual TAB report. u u u u u u u• Page 3 of 12 . . . . . . . . . . . . . . • • • • • • .- ••••••~~···~ EPA Inspection Report - Page 1798 of 1969 HoHyFro.mier Navajo Refining LLC 1\rtesia and Lovington Refineries AT'fACIIiV[EN'f 1 TO 2nct QUARTER 2019 STATUS REPORT APPENDIX G STATUS SUNlM.ARY REPORT u- Name or Summary of the ReporkPlan, or Certification CD Rqd, ("R") v, Contingent ("C") SubPara No. One-Time (" l '1) V. Quarterly orw/ Qu~I?.11te - - - - · · · · · · · · - - - - - - - ; ; •• ;-;-;-;-;-;-;-· Statyil §63,654 Reports (''> 1") J,ivApplicable if refinery J,v TAB is > 1 but < l 0 Mg/yr - Plan to ensure that uncontrolled benzene does not equa1 or exceed, as applicable, 10 Mg/yr or that it is minimized C '. I I "Tl z :r0 0 0 0 0 (,) (,) .i:,,. OJ As needed i j The 2007 4t1t quarter EOL benzene quantity;~;ee 2-5 Mg and the projected tab was > l OMg/yT, The required plan was included as a supplement to the 2"6 quarter report. Navajo specifically sought EPA\; concurrence with this plan but no response has been received, The EOL BQ for the 3n1 quarter of 2008 was> 2.5 Mg and the pn~jected tab vms > 10 Mg/yr (sec Attachment 3), The required plan was included as a supplement to the ya quarter report As required by 9l 2Ll\tiLa(3), Navajo specifically sought EPA 's concurrence with this plan but no response has been received. The TIOL BQ for the 4th quarter of 2008 was <2-5 Mg and the projected 2008 TAB was < l OMg/yr so no plan was required, The EOL BQs for the 1st, 2nd, ya a:nd 4th quarters of 2009 were <2.5 Mg and the projected 2009 TAB ;,vas < 10 Mg/yT so no plan was required, The EOL BQ frx the 1st, 2"d, 3\ and 4th quarters of 2010 was <25 Mg and the projected 2010 TAB was < 10 Mg/yr so no plan was required. The EOL BQ for the 1st, 2"0, J>d and 4th quarters of 2011 was <2,5 Mg and the projected 2010 TAB was < 10 Mg/yr so no plan is required. The EOL BQ for the l •1, 211d, 3ra and 4th quarters of 2012 ;,vas <2-5 Mg and the projected 2010 TAB was< 10 Mg/yr so no plan is required, ~ ,,,,,, ..I.!3E..t2.-b..~QJ?t_t,t_~;~t, 2"a, Jfd and 4th quarters of 2013 were each <2.5 M 30 days ailcr the end Page 4 of 12 EPA Inspection Report - Page 1799 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACIL"\'lENT 1 TO 2nd .QUARTER 2019 STA'IUS REPORT APPENDIX G STATUS SUJVIMARY REPORT uu,u.-.-.-.-.- Name or Summary of the Report Plan. or Certification ,_ ········~-······ -~~~~~~· ······ -.-.-.-.-.-u CD Sub~ Para No. Rqd, ("R") v, Contingent ("C") One-Time (" l ") V, Quarterly orw/ §63.654 Reports ("> 1") UUUUUUUU•• • • • • • • • •. ••••••• ; I z :r0 (,) (,) .i:,,. (!) Status ·uuuu=uu, "Tl 0 0 0 0 Due Date ' ·~~~~~~~~~~~~~~~~~~~~~~~ -~~~ and the projected 2012 TAB \Vas< 10 Mg/yr so no plan was required. The EOL BQ for the 1"' and 2nd quarters of 2014 was <2.5 Mg and the projected 2014 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the 1'', 2"'1, 3"\ and 4 1h quarters of 2014 ;,vere <2.5 Mg and the projected 2014 TA..B was< 10 Mg/yr so no plan was required, The EOL BQ fcir the 1"'quarter of 2015 was <2.5 Mg and the projected 2015 Ti\B was< 10 Mg/yT so no plan was required. The EOL BQ for the 2nd quarter of 2015 was <2,5 Mg and the projected 2015 TAB was < IO Mg/yr so no plan was required. The EOL BQ for the 2nd quarter of 2015 was <2.5 Mg and the projected 2015 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the 3rd quarter of2015 was <2.5 Mg and the projected 2015 TAB was < 10 Mg/yr so no plan was required. The EOL BQ for the 4th quarter of 2015 was <2.5 Mg and the projected 2015 TAB was < 10 Mg/yr so no plan was required. The EOL BQ for the 1st quarter of2016 was <2,5 Mg and the projected 2016 TAB was < 10 Mgiyr so no plan was required. The EOL BQ for the 2nd quarter of 2016 was <2.5 Mg and the projected 2016 TAB was < 10 Mg/yr so no plan was required. The EOL BQ for the 3rd quarter of 2016 exceeded 2,5 :tvlg but the calendar year 2016 TAB did NOT exceed 10 ]\:lg, As the first two quarters of2016 indicated significantly lower concentrations of benzene in the wastewater, the projected TAB remained below 10 Mg for the calendar year, and as such no specific actions need to be taken to ensure the TAB docs not exceed 1OMg. Regardless of that, however, Navajo developed a plan of targeted monitoring to help identify and address the benzene contributions during the third quarter. The plan was implemented by November 4, 2016 (attachment 4). Page 5 of 12 EPA Inspection Report - Page 1800 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 2nd QUARTER 2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT Name or Summary of the R~_;1ort, Plan. or Certification I I CD Rqd. One-Time Sub- I ("R") I(" l ") v. Para l v. Cont-I Quarterly No. ingent or w/ I("C") I§63.654 Reports !l ("> l ") It I I Due_Date Status I I .-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-~. ··························································································-.-.-~- ...................................................................................... .-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-~.-.-~~ The EOL BQ for the 4th quarter of 2016 was <2.5 Mg and the projected TAB for 2016 was <10 Mg/yr. The EOL BQ for the 1st quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. The EOL BQ for the 2nd quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. The EOL BQ for the 3rd quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. The EOL BQ for the 4th quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was 1") :QµeD,;ite: Last day of 4 111 Quarter as set forth in, I.viii. (if TAB is 10 mg/yr or greater); As agreed by EPA and Navajo and/or Montana Refining (i:fTAB isl Mg/yr or more but less than 10) 1 -----------------u u----•••-----~u----------uuuuu•U Status Not Applicable unless refinery cannot take actions to keep TAB below 10 Mg/yr. • u-u-uu•=uu•-,------------u•----------••----------- ------------------------···---------------------·n~~=~ Third-Party TAB Study and Compliance Review Iviii; J.vi C 1 30 days after receipt of Not Applicable unless refinery cannot take actions to keep TAB below 10 the Third-Party Study Mg/yr. and Compliance Review Plan to implement the results of the Third-Party TAB Study and Compliance Review J.vi; C l 120 days after receipt of the Third-Party TAB Study and Compliance Review Not Applicable unless refinery carmot take actions to keep TAB below 10 Mg/yr. I "Tl z :r0 0 0 0 0 (,) (,) 01 ...... ••••••••••••••••••••••••••••••••••••·-~~~·nnnn~~ Page 7 of 12 EPA Inspection Report - Page 1802 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 2nd OUARTER 2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT '"""·«-«««••-«•«-«-«•«-------,-----r-----,-------,---------------,----------------------------------------------s R~nort:,. Plmt . 9r CertWc@tiQJ+ CD SubPara No. Rqd. ("R") v. Contingent ("C") One-Time (" l ") V. Quarterly orw/ §63.654 Reports ("> l ") Report on training done in that Quarter G.iiii.; C Q Each Quarterly Report due under the Consent Decree ----------------------------------$ ------------------------------------................................. Name or Summary of the Miia(]) ~ - - - - - - - - - - - - - - - , . , __ _ _.,,,, ~ >>>>>>>>>>>" •••••••••••• ~ DueDate Status A training plan was developed 12/6/02 for the Artesia Refinery (i.e., since its TAB is greater than LO Mg/yr). The first training session was held 1/7/03 at both the Artesia and Lovington refineries. The second training session for the two refineries was held 1/27/04 and 1/28/04. Annual refresher training performed the weeks of2/8/05, 3/27/06, 3/5/07, 2/25/08 (Lov), 11/07/08 (Art), 12/18/09, 12/17/2010 and 12/20/2011, 11/08/2012, 01/14/2013, 04/18/2013 11/12 to 11/14/2013, 05/24/2014, 06/19/2014, 06/20/2014, 12/02/2014, 3/16/2015, 4/1/2015, 5/15/2015, 2/29/2016, 3/8/2016, 3/17/2016 (Art. and Lov), 02/28/2017 (Artesia and Lovington), 08/29/2017 (Artesia and Lovington), 09/30/2018 (Artesia and Lovington) and 02/28/2019 (Artesia and Lovington). ....J.-~.............................., -............... -........................................-.-.-...-.-.-.-.-.-.-.-.-.-. I "Tl z :r0 0 0 0 0 (,) (,) 01 N Page 8 of 12 .-.----------------------------------- ••••~~~~~~~~~~~~~~~~~~~~~~~~~NN~~~-----"' EPA Inspection Report - Page 1803 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 2nd QUARTER 2019 STATUS REPORT APPENDIX G STATUS SUl\1MARY REPORT u~UU~u~U~uuuuucccc~cc---•• Results of annual sampling of>0.05 Mg/yr benzene streams J.i; Mii- Jc , a(2) : In the first Quarterly Rep011 for the first calendar quarter of each year Q i j : I j l I "Tl z :r0 0 0 0 0 (,) (,) 01 (,) ----- •• ••• """"""""""""""" -------- '--•=~~~~ The annual sampling was perfonned. in February 2005. The result1 were presented with the first quarter 2005 report. Annual sampling was performed in February 2006. The results w1: ,·e presented in Attachment 4 with the first quarter 2006 report. Annual sampling was pe1formed in September and December 200'. . The results were submitted in attachment 4 of the first quarter 2008 rep 011 as required by iJ22.M.ii.a(2). Annual sampling was performed in December 2008. The results Vi ere submitted in attachment 4 of the first quarter 2009 report as require dby ,22.M.ii.a(2). Annual sampling was perfonned in December 2009. The results v. ere submitted in Attachment 4 of the first quarter 2010 report as requi1 ·edby iJ22.M.ii.a(2). Annual sampling was performed in December 2010. The results Vi ere submitted in Attachment 4 of the first quarter 2011 report as requit edby iJ22.M.ii.a(2). Annual sampling was performed in December 2011. 'foe results Vi ere submitted in Attachment 4 of the fust quarter 2012 report as requi1 edby ,22.M.ii.a(2). Annual sampling was performed in December 2012. The results Vi ere submitted in Attachment 4 of the first quarter 2013 report as requil edby ,22.M.ii.a(2). Annual sampling was performed in December 2013. The results Vi ere submitted in Attachment 4 of the first quarter 2014 repmt as requil edby iJ22.M.ii.a(2). Annual sampling was performed in December 2014. The results VI ere submitted in Attachment 4 of the 1stqua11er 2015 report as required by 122.M.ii.a(2). Page 9 of 12 EPA Inspection Report - Page 1804 of 1969 HollyFronticr Navajo Refining LLC Artesia and Lovington Refineries ATTACHJVIENT 1 TO zmi QUARTER 2{H9 STATUS REPORT APPENDIX G STATUS SUlVflViARY REPORf Results of annual sampling of>0,05 Mg/yr benzene streams Results of Quarterly EOL Sampling Jj; C In the first Quarterly Q Report for the first calendar quarter of each year J\foa(2) J.iii; M.ii. a(3); M.iib(2) C Q Each Quarterly Report due under the Consent Decree {after written EPA approval of EOL i,.1:1mpUnKPl.0en) I "Tl z :r0 0 0 0 0 (,) (,) 01 .i:,,. ; ! Annual sampling was performed in December 2015. The results were included in Attachment 4 of the 1'tquarter 2016 report as required by 922.1vu1.ac2,. ' Annual sampling was performed in October 2016. The results were included. in Attachment 4 of the l st quarter 2017 report as required by 922.M,ii.a(2). Annual sampling was performed in December 2017. The results were included in Attachment 4 of the 1st qurui:er 2018 report as required by ijf'F) ;i.<:.,;...;M" .11.ai_'2).. Annual srunpling was performed in December 2018. The results are included in the 1st quarter 2019 report as required by 4!22JvULa(2). I I 2004: Under the assumption that the sampling plan was accepted by EPA upon the 03/31/2004 submittal of the revised EOL Sampling Plan, Navajo conducted its first EOL sampling during the week of 3/22/04. The annual TAB, submitted 4/05 was 4.9 Mg fix Artesia and L5 Mg for Lovington, 2005: The EOL benzene quantity (BQ) for the 1", 2nct, 3rd, and 4th quarter of 2005 were each <2,5 Mg, 2006: The EOL BQ fbr the 1' 1, 2"d, 3"\ and 41h quarters of 2006 were each <2,5 Mg, 2007: The 1'\ 2"' 1, and 3, 2.5 Mg and the projected tab was> 10 ?vig/yr. The EOL BQ for the Td quarter of 2008 was> 2.5 Mg and. the projected tab was> 10 Mg/yT. The EOL BQ for the 4'1' quarter of 2008 was <2.5 Mg and the projected 2008 TAB was< 10 Mg/yT. 2009: The EOL BQ for the J5\ 2rn:1, 3'"0 a:nd 4th quarters of 2009 were <2.5 Mg and the projected 2009 TAB was< 10 Mg/yr so no plan was required, 2010: The EOL BQ for the 1~t, 2"d, ]', and 4,h qurui:ers of 20 l Owas <2,5 Mg and the projected 2010 TAB was< 10 Mg/yr so no plan was required. 2011: The EOL BQ for the l st, 2nd, 3ni and 4th quarters of 2011 was <2.5 Mg and the pn~iected 20Hl TAB was< lO Mg/yr so no plan isJegµ}reg. ___ Page 10 of 12 EPA Inspection Report - Page 1805 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 2nd QUARTER 2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT 2012: The EOL BQ for the l st, 2nct, yct and 4th q~arte;;··~:r°::2012 was <2.5 Mg and the projected 2012 TAB was< 10 Mg/yr so no plan is required. 2013: The EOL BQ for the P\ 2ml, 3rd and 4th quarters of 2013 was <2.5 Mg and the projected 2012 TAB was< 10 Mg/yr so no plan is required. 2014: The EOL BQ for the 1st, 2nd, 3rd and 4th quarters of 2014 were <2.5 Mg and the projected 2014 TAB was < 10 Mg/yr so no plan was required. 2015: The EOL BQ for the 1st quarter of 2015 was <2.5 Mg and the projected 2015 TAB was< IO Mg/yr so no plan was required. The EOL BQ for the 2nd quarter of 2015 was <2.5 Mg and the projected 2015 TAB was < 10 Mg/yr so no plan was required. The EOL BQ for the 3rd quarter of2015 was <2.5 Mg and the projected 2015 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the 41h quarter of 2015 was <2.5 Mg and the projected 2015 TAB was < l O Mg/yr so no plan was required. 2016: The EOL BQ for the 1st quarter of 2016 was <2.5 Mg and the projected 2016 TAB was< 10 Mg/yr so no plan was required. The EOL BQ for the 211dquarter of 2016 was <2.5 Mg and the projected 2016 TAB was < 10 Mg/yr so no plan was required. The EOL BQ for the 3ro quarter of 2016 exceeded 2.5 Mg. As required by paragraph 22.J.iv, Navajo submits the following plan that identifies the specific actions that will be taken, and the schedule for such actions, to ensure the TAB does not exceed 1OMg in the calendar year. As the first two quarters of 2016 indicated significantly lower concentrations of benzene in the wastewater, the projected TAB remained below 10 Mg for the calendar year, and as such no specific actions need to be taken to ensure the TAB does not exceed lOMg. Regardless of that, however, Navajo developed a plan of i targeted monitoring to help identify and address the benzene contributions l during the third quarter. The plan was implemented by November 4, 2016 l (attachment 4). The EOL BQ for the 4th quarter of 2016 was <2.5 Mg and the projected TAB for 2016 was <10 Mg/yr. 2017: The EOL BQ for the 1st quarter of 2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. I I I I "Tl z :r0 0 0 0 0 (,) (,) 01 01 , J ~?f:!?-~~O ' - - - - - - - - - - - ' - - - - ' - - - - - - ' - - - - ' - - - - - - - - - . . .. ~~e2 Page 11 of 12 ~£;;_quarter of 2017 was <2.5 Mg and the projected TAB EPA Inspection Report - Page 1806 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 1 TO 2nd QUARTER 2019 STATUS REPORT APPENDIX G STATUS SUMMARY REPORT The EOL BQ for the 3ro quarter of2017 was <2.5 Mg an.d th~projected. TAB for 2017 was <10 Mg/yr. The EOL BQ for the 4th quarter of2017 was <2.5 Mg and the projected TAB for 2017 was <10 Mg/yr. 2018: The EOL BQ for the 1st qumter of 2018 was <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr. The EOL BQ for the 2nd quarter of 20] 8 was <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr. The EOL BQ for the 3rd quarter of 2018 was <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr. The EOL BQ for the 4th quarter of 2018 was <2.5 Mg and the projected TAB for 2018 was <10 Mg/yr. 2019: The EOL BQ for the 1st quarter of 2019 was <2.5 Mg and the projected TAB for 2019 was <10 Mg/yr. The EOL BQ for the 2nd quarter of 2019 was <2.5 Mg and the projected TAB for 2019 was <10 Mg/yr. I "Tl z :r0 0 0 0 0 (,) (,) 01 0) Page 12 of 12 EPA Inspection Report - Page 1807 of 1969 t\TTACJ::IM~~ APPENDIX H SUMMARY REPORTS HFNA-000003357 EPA Inspection Report - Page 1808 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHl\tIENT 2 TO znd QUARTER2019 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT REPORTS, PLANS AND CERTIFICATIONS UNDERTHELDARENHANCEDPROGRAM PROVIS.IONS OF PARAGRAPH 23 OF THE CONSENT DECREE .IN UNITED STATES, ET AL. V. NAVAJO REF.IN.ING CO., ET AL. Name or Summary CD of the Report, Sub-1[ Plan, or Nos. Certification ....................................... Written RefineryWideLDAR Program A- ' One-Time ("l ") v. Quarterly orw/ §63.654 Reports ("> l") R l O.i.a A 1 DueDate Status 1150D I after Lodging Prepared by 4/19/02 and Submitted 5/13/02 As needed LDA.R plan updated 11/19/2009, 01/05/2011, 04/28/2014 (approved 7/22/2014). I I _,,,..,..,..,..,.., Updated RefineryWideLDAR Program Rqd. ("R") v. Contingent ("C"} .................................. C 1 ~~~~~~~~· Pagel of9 HFNA-000003358 EPA Inspection Report - Page 1809 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACH1\1ENT 2 TO 2nd QUARTER 2019 STATUS REPORT APPENDIX H STATUS SUI\/IMARY REPORT w Name or Summary CD of the Report, Sub-if Plan, or Nos. Certification Rqd. ("R") v. Contingent {"C") One-Time ("l ") v. Quarterly orw/ §63.654 Reports f"> l "} Report on training fornewLDAR personnel R >1 B.i; ...................................................................... DueDate In each Section 63.654 Report O.iic(l) ••••••••••••••••••••••••••••••••••••••• ••••••••••••••••••••••••••••••••••• ..................................................... ~~~~~~~~~ Status Training addressed in 63.654 Report submitted 9/13/02, 3/15/03, 9/15/03, 3/15/04, 9i15/04, 3/14/05 (3/15/05 for Lovington), 9/13/05 (9/15/05 for Lovington), 3/17/06, 9/13/06 (9/6/06 for Lovington), 3/16/07, 09/14/07, 03/17/08, 09/12/08, 03/16/09, 08/27/09, 03/16/2010, 09/13/2010, 03/16/2011 06/08/2011, 07/l 0/2012, 09/10/12, 11/06/2012, 12/11/2012, 01/13/2013, 05/02/2013, 05/08/2013, 05/15/2013, 02/08/2013 03/09/2013 and 09/16/2014 (for Artesia and Lovington). New hire training was conducted 06/08/2011, 07/10/2012, 09/10/12, 11/06/2012, 12il 1/2012, 01/13/2013, 05/02/2013, 05/08/2013, 05/15/2013, 02/08/2013, 12/9/2013, 03/22/2014, 03/31/2014, 04/01/2014, 06/18/14, 06/19/14, and 06/20/2014. Annual LDAR Computer Based Training (CBT) implemented during the fourth quarter 2014. First training completed before 12/31/2014. Annual CBT for new personnel completed during 2015. Annual CBT completed in 2016; additional training on 4/28/2016, 05/11/2016. Annual CBT completed in 2017; additional training on 04/13/2017, 04/25/2017, 05/20/2017, 12/01/2017. Annual CBT completed during 2018, additional training on 01/2018, 02/2018, and 03/2018. 2019 training on 01/08/2019, 01/11/2019, 02/20/2019, 03/05/2019, and 03/22/2019. ••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••ccccccccccccc Page 2 of9 HFNA-000003359 EPA Inspection Report - Page 1810 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO zn<1 QUARTER 2019 STATUS REPORT APPENDIX H STATUS SUM1VIARY REPORT .............. Name or Summary CD of the Report, Sub-,T Plan, or Nos. Certification Rqd. ("R") v. Contingent ("C") One-Time ("l'')v. Quarterly orw/ §63.654 Reports C'>l"} Report on annual training for LDAR personnel R >1 I B.ii; Due__Date In each Section 63.654 Report O.iic(l) ~~~~~~~~~~~~~~~~~~ Status Training addressed in 63.654 Report submitted 9/13/02, 3/15/03, 9/15/03, 3/15/04, 9/15/04, 3/14/05 (3/15/05 for Lovington), 9/13/05 (9/15/05 for Lovington), 3/17/06, 9/13/06 (9/6/06 for Lovington), 3/16/07, 09/14/07, 03/17/08, 09/12/08, 03/16/09, 08/27/09, 03/16/2010, 09/13/2010, (for Artesia and Lovington).Annual training was conducted on the following dates by the on-site LDAR contractor: 06/29/2011, 06/14/2012, 06/24/2013, 06/26/2013, 11/12 tol 1/14/20143, 01/12/2014, 01/16/2014, 01/20/2014, 01/21/2014, 02/08/2014, 02/10/2014, 6/18/2014, 6/19/2014, and 06/20/2014. Annual LDAR Computer Based Training (CBT) implemented during the fourth quarter 2014 for all refinery and contractor personnel. Annual CBT conducted during 2015. · l\.nnual CBT in 2016; additional 2016 training on 1/3/2016, 1/6/2016, 1/14/2016, and 1/19/2016, 1/31/2016, 04/28/2016, 05/11/2016, 09/2016, 10/2016, 11/2016, and ! 12/2016. Annual CBT in 2017; j additional training on 04/13/2017, 0412512011, 0512012011, 12m112011. Annual CBT in 2018; additional j training on 01/2018, 02/2018, j 03/2018, 4/2019. I I .................... ........................................... ~ ................... : _ , I ~ Page 3 of9 HFNA-000003360 EPA Inspection Report - Page 1811 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO 2"0 Q~RTER 2019 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT -~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Name or Summary CD of the Report, Sub-f Plan, or Nos. hertificatimi Rqd. ("R") v. Contingent ("C") One-Time ("1") v. Quarterly orw/ §63.654 Reports ("> 1"} Report on LDAR training for refinery and operations personnel who hold positions relevant to LDAR R >l Due Date Status ....................................: B.iii; O.iic(l) In each Section 63.654 Report Initial training program implemented. Training addressed in 63.654 Report submitted 9/13/02, 3/15/03, 9/15/03, 3/15/04, 9/15/04, 3/14/05 (3/15/05 for Lovington), I 9/13/05 (9/15/05 for Lovington), 3117/06, 9/13/06 (9/6/06 for j Lovington), 3/16/07, 09/14/07, i 03/17/08, 09/12/08, 03/16/09, j 08/27/09, 03il6/2010, 09/13/2010, 03/16/2011, 03/14/2012 and I 09/16/2013. Training was conducted i on the following dates for refinery j environmental personnel: 11/06/2012, 08/13 - 08/15/2013, 05119 - 512112014, s12112014, l 10/02/2014. Annual LDAR Computer Based Training (CBT) implemented during the fourth I l I I I I Il ~::::~t!~~~;~i~~;,e1:n;a~iBT in 2015. Annual CBT in 2016; additional training on 1/3/2016, 1 1/6/2016, 1/14/2016, and 1/19/2016, 1131/2016, 04/28/2016, and ! 05/11/2016. Annual CBT in 2017; additional training on 04/13/2017, 1 0412512011, 0512012011, 1210112011. i Annual CBT in 2018; additional training on O1/2018, 02/2018, and 0312018. I I I I I .......................... ··~~~~~~·····~~~--~~~~~~~~~ ' ~~~~~~~~~~~~~~~ Page 4 of9 HFNA-000003361 EPA Inspection Report - Page 1812 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO 2m1 QUARTE~9 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT I :t:::!,":,mary 1cn Plan, or Certification ! Sub-,T iI Nos. D·, LDARaudit reports and records O.ii-b. of corrective actions. Audits are required every two years. Rqd. ("R") v. Contingent ("C") One-Time ("1 ") v. Quarterly orw/ §63.654 Reports (''>1'] R >l Due Date I1n the Quarterly Report for the 1st calendar Quarter of each year I Status Included in the 1st Qtr 2003 report (submitted 04/17/2003) as Attachment 3. 3rd party audits for Artesia and Lovington were performed during December 2004, January 2007, January 2009, and January 2011. Included in the 1st Qtr 2012 report, a copy of the 01/201 I Audit Report and the corrective actions taken were included with the pt Quarter 2012 report as Attachment 5. The 2013 3rd party audit was conducted from 09/16 to 09/20/2013, after major refinery turnaround, and a complete quarter worth of normal operation data has been collected for comparative monitoring. A copy of the audit report and resolutions were presented in the 1st Quarter 2014 report. 3rd party audits for Artesia and Lovington were performed during the week of October 5th to 9th, 2015. A copy of the 2015 LDAR 3rd party audit report and resolutions are included in Attachment 5 of the 1st Quarter 2016 report. The 2017 LDAR 3rd party audit was conducted from 05/17 to 05/18/2017. A copy of the audit report was attached to the 3rd Quarter Consent Decree Progress Report. The audit resolutions were included as Attachment 5 to the 1st Quarter 2018 report. The 2019 LDAR 3rd party audit was conducted from 04/29 to 05/03/2019........ . Page 5 of9 HFNA-000003362 EPA Inspection Report - Page 1813 of 1969 HoHyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTAC!!lVIENT 2 TO 2nd QUARTER 2019 S'I,ATUS REPORT APPENDIX H STATUS SUIVIMARY REPORT Name or Summary CD of the Report, Sub-,I Plan, or Nos. Certification Rqd. ("R") v. Contingent ("C") One-Time i (" 1") v. I DueDate Quarterly orwi §63.654 Reports ("> 1") .............. Certification of implementation of the first attempt at repair program G·, Operational specifications for electronic LDA.R data collection and transfer I.ii.; Certification of implementation of QA/QC procedures for review of data generated by LDAR monitoring technicians J· ~~~~~···~~~~~~~ l In the Provided with Initial Quarterly first Qtrly Status Report submitted for 2nd report Quarter 2002 on July 30, 2002 due under the CD or the first Qtrly report in which the rqmt. becomes due R 1 6mos. after Lodging for Navajo; 1 yr. after Lodging for Montana Refining R 1 In the Provided with Initial Quarterly first Qtrly Status Report submitted for 2nd report Quarter 2002 on July 30, 2002. due under the CD or the first Qtrly report in which the rqmt. becomes due. O.i-b O.iia(2) . !R ' O.iia(l) ' I Status ,.,..,..,..,..,..,..,..,..,.., Submitted 06/19/2002 . ............ ....................... ~ ~~~~~ Page 6 of9 HFNA-000003363 EPA Inspection Report - Page 1814 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refmeries ATTACH1\1ENT 2 TO 2nd QUARTER 2019 S,IATUS REPORT APPENDIX H STATUS SUMMARY REPORT ~· . ........................... ~~~~~--------~~~~ Name or Summary CD of the Report, Sub-,T Plan, or Nos. Certificatio:11 Rqd. ("R") v. Contingent ("C") One-Time ("l")v. Quarterly orw/ §63.654 Reports ("> 1") R 1 R l Due Date ,.,..,_.,..,..,_..,..,..,.., Status ........................... ~~·····~~~~~ Identification of each Refinery's LDAR "point" person K', Certification of the development of a tracking program for new valves and pumps L" O.iia(3) ' O.iia(4) Provided with Initial Quarterly \ In the first Qtrly Status Report submitted for 2nd report Quarter 2002 on July 30, 2002 due under the CD or the first Qtrly report in which the rqmt. becomes due I I In the Provided with Initial Quarterly first Qtrly Status Report submitted for 2nd report Quarter 2002 on July 30, 2002 due under the CD or the frrst Qtrly report in which the rqmt. becomes due Page 7 of9 HFNA-000003364 EPA Inspection Report - Page 1815 of 1969 HollyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT t!9 2nd QUARTER 2019 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT 1 . Name or Summary CD of the Report, Sub-,T Plan, or Nos. Certification Rqd. ("R") v. Contingent ("C") I Certification of !M; implementation of O.iicalibration drift a(5) assessment . procedures One-Time ("l ") v. Quarterly orw/ §63.654 Reports ("> 1") ~~~~~~~~~ IR 1 Provided with Initial Quarterly In the first Qtrly Status Report submitted for 2nd report Quarter 2002 on July 30, 2002 due under the CD or the first Qtrly report in which the requirem ent becomes due . ~·· ~· ~·" N·, O.iia(6) Status ....................................... ' ...................... Certification of implementation of the "delay of repair" procedures Due.Date R l ....................................................................... ~ . .................... ~~~~~~~~~~~~~~~~ Provided with Initial Quarterly In the first Qtrly Status Report submitted for 2nd report Quarter 2002 on July 30, 2002 due under the CD or the frrst Qtrly report in which the requirem ent becomes due ....... ,._.._.._ ~~~~~ Page 8 of9 HFNA-000003365 EPA Inspection Report - Page 1816 of 1969 HoHyFrontier Navajo Refining LLC Artesia and Lovington Refineries ATTACHMENT 2 TO 2nd QUARTER 2019 STATUS REPORT APPENDIX H STATUS SUMMARY REPORT Name or Summary CD of the Report, Sub-'ff Plan, or Nos. ~ertification Rqd. ("R") v. Contingent ("C") One-Time ("l ") V. Quarterly orw/ §63.654 Reports ("'> 1") ........................................................................" LDAR monitoring report submitted withMACT periodic reports O· ' >l R O.iic(2) Due_Date Status ~~··········~~~~~~~~~~~~~~~~~~~ In each Section 63.654 Report I I I I Provided in MACT 63.654 Reports submitted: 3/15/02, 9/13/02, 3/15/03, 9/15/03, 3/15/04, 9/15/04, 3/14/05 (3/15/05 for Lovington 9/13/05 (9/15/05 for Lovington), 3/17/06, 9/13/06 (9/6/06 for Lovington), 3/16/07, 09/14/07, 03/17/08, 09/12/08, 03/16/09, 08/27/09, 03/16/2010, 09/13/2010, 03/16/2011, 09/15/2011, 03/09/2012, 0/06/2012 (09/06/2012 for Lovington), and 03/15/2013, 09/16/2013, {Lovington and Artesia) 02/25/2014 (Artesia), 08/26/2014 (Lovington), and 02/26/2015 (Artesia and Lovington), 08/27/2015, 2/18/2016 (Artesia and Lovington), 08/29/2016 (Artesia and Lovington), 02/28/2017 (Artesia and Lovington), 08/29/2017 (Artesia and Lovington), 08/30/2018 (Artesia and Lovington), and 02/28/2019 (Artesia and Lovington) ............. ~~~~ Page 9 of9 HFNA-000003366 EPA Inspection Report - Page 1817 of 1969 10450 Stancliff Rd. Suite 210 Houston, TX 77099 T: +1 281 530 5656 F: +1 281 530 5887 April 17, 2019 Gabriela Combs Navajo Refining Company PO Box 1490 Artesia, NM 88211-1490 Work Order: HS19040619 Laboratory Results for: BWON Monthly Sampling {EOL) Dear Gabriela, ALS Environmental received 9 sample(s) on Apr 09, 2019 for the analysis presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Results are expressed as "as received" unless otherwise noted. QC sample results for this data met EPA or laboratory specifications except as noted in the Case Narrative or as noted with qualifiers in the QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained by ALS Environmental. Samples will be disposed In 30 days unless storage arrangements are made. If you have any questions regarding this report, please feel free to call me. Sincerely, Generated By: JUMOKE.LAWAL Corey Grandits Project Manager Right Solutions · Right Partner www.a!sg!obaL::om Page 1 of29 HFNA-000003367 EPA Inspection Report - Page 1818 of 1969 A.LS Houston, US Date: Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS19040619 17-Apr-19 SAMPLE SUMMARY Lab Samp ID Client Sample ID Matrix HS19040619-01 S-1 {API HC) HS 19040619-02 TagNo Collection Date Date Received Liquid 08-Apr-2019 09:04 09-Apr-2019 12:54 S-3 (AP! Water) Liquid 08-Apr-2019 09:15 09-Apr-2019 12:54 HS19040619-03 S-5 (T-40) Liquid 08-Apr-2019 08:42 09-Apr-2019 12:54 HS19040619-04 S-6 (T-41) Liquid 08-Apr-2019 08:47 09-Apr-2019 12:54 L.. . . ...J. HS19040619-05 Field Blank Water 08-Apr-2019 09:09 09-Apr-2019 12:54 L. . .J HS 19040619-06 EQ Blank Port 1 Water 08-Apr-2019 09:45 09-Apr-2019 12:54 L. . J HS19D40619-07 EQ Blank Port 2 Water 08-Apr-2DHJ 09:45 09-Apr-2019 12:54 D HS19040619-08 Duplicate Liquid 08-Apr-2019 00:00 09-Apr-2019 12:54 HS 19040619-09 Trip Blank Water 08-Apr-2019 00:00 09-Apr-2019 12:54 Hold :::................"::: ~ ~ ~ ::: :::.................::: ::: ::_.-..-........... ~ ::: ».~ . . . . . . . .:::: : ::_.-..-..-..-..-..::; ::: ::: ::: ~ ;::;..................::: ......:::, ,:.·., ~ f""1 l . . . . . ....% [~~] Page 2 of29 HFNA-000003368 EPA Inspection Report - Page 1819 of 1969 AlS Houston, US Client: Project: Navajo Refining Company BWON Monthly Sampling (EOl) Work Order: HS19040619 Date: 17-Apr-19 CASE NARRATIVE GCMS Volatiles by Method SWl3260 Batch ID: R.336593 Sample ID: S-6 (T-41) (HS19040619-04} • Surrogate failure for HS19040619-04 due to sample matrix. Batch IIJ: R.336576 • The test results meet requirements of the current NELAP standards, state requirements or programs where applicable. Batch ID: R.336631 • The test results meet requirements of the current NE LAP standards, state requirements or programs where applicable. Batch ID: R336662 Sample ID: HS19040747-02MS • MS and MSD are for an unrelated sample. Page 3 of29 HFNA-000003369 EPA Inspection Report - Page 1820 of 1969 A.LS Houston, US Date: 17-Apr-19 Client: Project: Sample ID: Navajo Refining Company BWON Monthly Sampling (EOL) S-1 (API HC) Collection Date: 08-Apr-2019 09:04 ANALYSES RESULT QUAL MDL ANALYTICAL REPORT Work0rder:HS19040619 Lab lD:HS19040619-01 Matrix:Uquid DILUTION FACTOR UNITS 5.0 mg/Kg 1000 16-Apr-2019 15:46 %REC %REC %REC %REC 1000 16-Apr-2019 15:46 1000 16-Apr-2019 15:46 1000 16-Apr-2019 15:46 1000 16-Apr-2019 15:46 Method:SWS2M 35 Benzene 0.50 Analyst WLR Surr: 1, 2-Dichloroethane-d4 103 70-126 Surr: 4-Bromofluorobenzene 98.6 70-130 Surr: Dibromof/uoromethane 95.2 70-130 101 70-130 Surr: Toluene-dB DATE ANALYZED REPORT LIMIT Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 4 of29 HFNA-000003370 EPA Inspection Report - Page 1821 of 1969 AlS Houston, US Date: 17-Apr-19 ANAL YTICAl REPORT Client: Navajo Refining Company Project BWON Monthly Sampling (EOL) WorkOrder:HS 19040619 Sample ID: S-3 {API Water) Lab ID:HS19040619-02 Collection Date: 08-Apr-2019 09:15 Matrix:Liquid ANALYSES RESULT QUAl \l'OlATIU::'.S • SWS260C MDL REPORT I.IMIT UNITS DILUTION FACTOR Ahalyst: AK? Method:SW8260 2.0 Benzene DATE ANALYZED 0.030 0.25 mg/L 50 15-Apr-2019 23:37 Surr: 1,2-Dichloroethane-d4 86.1 70-126 %REC 50 15-Apr-2019 23:37 Surr: 4-Bromofluorobenzene 96.4 82-124 %REC 50 15-Apr-2019 23:37 Surr: Dibromof/uoromethane 90.1 77-123 %REC 50 15-Apr-2019 23:37 100 82-127 %REC 50 15-Apr-2019 23:37 Surr: Toluene-dB Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 5 of29 HFNA-000003371 EPA Inspection Report - Page 1822 of 1969 A.LS Houston, US Date: 17-Apr-19 ANALYTICAL REPORT Project: Navajo Refining Company BWON Monthly Sampling (EOl) Sample ID: S-5 (T-40) lab ID:HS19040619-03 Collection Date: 08-Apr-2019 08:42 Matrix:Uquid Client ANALYSES .. ,~~ ~ ~ " " " " " " " " ' " " " " " " " " " " " " " " " " " " RESULT QUAL MDL WorkOrder:HS 19040619 REPORT LIMIT ··········································------------- UNITS DILUTION FACTOR DATE ANALYZED .......................,,......, , - - ..........................,,,,,,,,,,,,,,,, Analyst: WLR Benzene 0.30 0.024 0.24 mg/Kg 50 Surr: 1,2-Dichloroethane-d4 107 70-126 50 15-Apr-2019 19:59 Surr: 4-Bromofluorobenzene 99.9 70-130 50 15-Apr-2019 19:59 Surr: Dibromofluoromethane 71.9 70-130 50 15-Apr-2019 19:59 106 70-130 %REC %REC %REC %REC 50 15-Apr-2019 19:59 Surr: Toluene-dB 15-Apr-2019 19:59 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 6 of29 HFNA-000003372 EPA Inspection Report - Page 1823 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 17-Apr-19 ANALYilCAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) WorkOrder: HS 19040619 S-6 (T-41) 08-Apr-2019 08:47 RESULT QUAL Lab ID:HS19040619-04 Matrix: Liquid MDL REPORT LIMIT UNITS DILUTION FACTOR DATE ANALVZED - - - - - - - - - - - - - - - - - - - - " " " " " " " " " " " " " " " " " " • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • , • , s s • • , • S s , - . - . • .................- - - - - :VOi.ATILES BY SW8260C Benzene Analyst 0.36 0.024 0.24 mg/Kg 50 WLR 15-Apr-2019 20:24 Surr: 1,2-Dichloroethane-d4 104 70-126 %REC 50 15-Apr-2019 20:24 Surr: 4-Bromofluorobenzene 96.6 70-130 %REC 50 15-Apr-2019 20:24 Surr: Dibromoffuoromethane 68.2 70-130 %REC 50 15-Apr-2019 20:24 70-130 %REC 50 15-Apr-2019 20:24 Surr: Toluene-dB s 102 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 7 of29 HFNA-000003373 EPA Inspection Report - Page 1824 of 1969 ALS Houston, US Client Project Sample ID: Collection Date: ANALYSES Date: 17-Apr-19 WorkOrder:HS 19040619 Field Blank 08-Apr-2019 09:09 RESULT QUAL iVOLATILES • SWS260C Benzene ANALYTICAL REPORT Navajo Refining Company BWON Monthly SampHng (EOL) < 0.00060 Lab ID:HS19040619-05 Matrix:Water MDL Method:SWS260 0.00060 REPORT LIMIT UNITS DIUJT!ON FACTOR DATE ANALYZED Analyst: AKP 0.0050 mg/L 13-Apr-2019 17:28 Surr: 1,2-Dichloroethane-d4 88.3 70-126 %REC 1 13-Apr-2019 17:28 Surr: 4-Bromofluorobenzene 95.9 82-124 %REC 1 13-Apr-2019 17:28 Surr: Dibromof/uoromethane 93.1 77-123 %REC 13-Apr-2019 17:28 Surr: Toluene-dB 97.1 82-127 %REC 13-Apr-2019 17:28 Note: See Qualifiers Page for a !ist of qualifiers and their explanation. Page 8 of29 HFNA-00000337 4 EPA Inspection Report - Page 1825 of 1969 ALS Houston, US Date: 17-Apr-19 ANALYTICAL REPORT Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) WorkOrder:HS 19040619 Sample ID: EQ Blank Port 1 Lab !D:HS19040619-06 Collection Date: 08-Apr-2019 09:45 Matrix:Water ANALYSES RESULT QUAL rlfOLATILES • SW8260C Benzene MDL REPORT UMIT UNITS DILUTION FACTOR Method:SW8260 < 0.00060 0.00060 DATE ANALYZED Analyst AKP 0.0050 mg/L 1 13-Apr-2019 17:53 Surr: 1, 2-Dich/oroethane-d4 89.0 70-126 %REC 1 13-Apr-2019 17:53 Surr: 4-Bromofluorobenzene 95.0 82-124 %REC 1 13-Apr-2019 17:53 Surr: Dibromofluoromethane 91A 77-123 %REC 1 13-Apr-2019 17:53 Surr: Tofuene..cJ8 97.8 82-127 %REC 1 13-Apr-2019 17:53 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 9 of29 HFNA-000003375 EPA Inspection Report - Page 1826 of 1969 AlS Houston, US Client: Project Sample ID: CoHection Date: ANALYSES Date: 17-Apr-19 ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) EQ Blank Port 2 08-Apr-2019 09:45 RESULT QUAL MDL WorkOrder:HS 19040619 Lab ID:HS19040619-07 Matrix:Water REPORT UMIT UNITS DH.UTION DATE FACTOR ANALYZED ------------------"~"'""~"""""""""""""""""""""""'"""""""'""'" ""'···································"·---------=····················· ········· VOLATILES • SWS2.SOC Benzene Analyst: AKP < 0.00060 0.00060 0.0050 mg/L %REC %REC %REC %REC Surr: 1,2-Dichloroethane-d4 87.1 70-126 Surr: 4-Bromofluorobenzene 96.7 82-124 Surr: Dibromof/uoromethane 91.3 77-123 Surr: Toluene-dB 98.5 82-127 13-Apr-2019 18:18 1 13-Apr-2019 18:18 1 13-Apr-2019 18:18 1 13-Apr-2019 18:18 1 13-Apr-2019 18:18 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 10 of29 HFNA-000003376 EPA Inspection Report - Page 1827 of 1969 ALS Houston, US Date: 17-Apr-19 Project: Sample ID: Navajo Refining Company BWON Monthly Sampling (EOL) Duplicate Collection Date: 08-Apr-2019 00:00 Client: ANALYSES RESULT QUAL ANALYTICAL REPORT Work0rder:HS19040619 lab !D:HS19040619-0B Matrix:Uquid MDL REPORT LIMIT UNITS DILUTION FACTOR Method:SW82~0 •SW8200C 1.7 Benzene 0.030 DATE ANALYZED Analyst AKP 0.25 mg/L 50 16-Apr-2019 00:02 Surr: 1, 2-Dichloroethane-d4 86.3 70-126 %REC 50 18-Apr-2019 00:02 Surr: 4-Bromofluorobenzene 96.0 82-124 %REC 50 16-Apr-2019 00:02 Surr: Dibromoffuoromethane 90.7 77-123 %REC 50 16-Apr-2019 00:02 Surr: Toluene-dB 99.4 82-127 %REC 50 16-Apr-2019 00:02 Note: See Qualifiers Page for a list of qualifiers and !heir explanation. Page 11 of29 HFNA-000003377 EPA Inspection Report - Page 1828 of 1969 A.LS Hcn.1ston, US Client: Project Sample ID: Collection Date: ANALYSES ........................................................................... VOLAT!!..E$ • SW8260C Date: 17-Apr-19 ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) WorkOrder:HS 19040619 Trip Blank Lab ID:HS19040619-09 08-Apr-2019 00:00 Matrix:Water RESULT QUAL ... ., ..................................... < 0.00060 MDL REPORT LIMIT _____________ Method:SWS260 0.00060 UNITS DILUTION FACTOR DATE ANALYZED ................,,,•·······= ·························.,,,,,,,,,,,,,..,,,,,,,,,,,__ Analyst: AKP 0.0050 mg/L 1 Surr: 1, 2-Dichloroethane-d4 88.0 70-126 %REC 1 13-Apr-2019 18:43 Surr: 4-Bromofluorobenzene 95.8 82-124 %REC 1 13-Apr-2019 18:43 Surr: Dibromofluoromethane 93.0 77-123 %REC 1 13-Apr-2019 18:43 Surr: Toluene-dB 98.8 82-127 %REC 1 13-Apr-2019 18:43 Benzene 13-Apr-2019 18:43 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 12 of 29 HFNA-000003378 EPA Inspection Report - Page 1829 of 1969 ALS Houston, US Date: 17-Apr-19 WEIGHT LOG Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) WorkOrder: HS19040619 Batch ID: 3015 SamplD HS19040619-01 HS19040619-03 HS 19040619-04 Method: Container VOLATILES BY SW8260C Sample WtNol Final Volume Weight Factor 5.033 (g) 5.171 (g) 5.123 (g) 5 (ml} 5 (ml} 0.99 0.97 0.98 5(mL) Container Type Bulk (5030B) Bulk (5030B) Bulk (5030B) Page 13 of29 HFNA-000003379 EPA Inspection Report - Page 1830 of 1969 ALS Houston, US Date: Navajo Refining Company BWON Monthly Sampling (EOL) Client: Project: WorkOrder: DATES REPORT HS19040619 Client Samp ID Sample ID 17-Apr-19 Collection Date TCLP Date Analysis Date Prep Date DF Matrix: Water HS19040619-05 08 Apr 2019 09:09 Field Blank 13 Apr 2019 17:28 HS 19040619-06 EQ Blank Port 1 08 Apr 2019 09:45 13 Apr 2019 17:53 HS19040619-07 EQ Blank Port 2 08 Apr 2019 09:45 13 Apr 2019 18:18 HS 19040619-09 Trip Blank 08 Apr 2019 00:00 13 Apr 2019 18:43 Batch ID R336593 Test Name: VOLATILES BY SW8260C Matrix: Liquid HS19040619-03 S-5 {T-40) 08 Apr 2019 08:42 15 Apr 2019 19:59 50 HS 19040619-04 S-6 (T-41 ) 08 Apr 2019 08:47 15 Apr 2019 20:24 50 .Satch ID R336631 HS19040619-01 Batch IO Test Name: VOLATILES BY SW8260C S-1 (API HC) R336662 08 Apr 2019 09:04 Test Name: VOLATILES - SW8260C Matrix: Liquid 16 Apr 2019 15:46 1000 Matrix: Liquid HS19040619-02 S-3 {API Water) 08Apr2019 09:15 15 Apr 2019 23:37 50 HS190406i9-08 Duplicate 08 Apr 2019 00:00 16 Apr 2019 00:02 50 Page 14 of29 HFNA-000003380 EPA Inspection Report - Page 1831 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 17-Apr-19 Navajo Refining Company BWON Monthly Sampling (EOL} HS19040619 R.336576 ( 0} MBLK QC BATCH REPORT NEW Sample ID: lnstnunent: Method: Units: ug/L VBLKW-041219 Run ID: Client ID: Analyte VOA9 VOA.9_336576 PQL Result Analysis Date: 13-Apr-2019 14:09 SeqNo: 5035184 SPKVal VOLATILES •SW8260C SPK Ref Value %REC PrepOate: Control Limit OF: 1 RPD Ref RPD Value %RPD Limit Qual .............................................................. ~~~~ Benzene 1, 2-Dich/oroethane-d4 Surr: 4-Bromofluorobenzene ···sur,.:·01b,omoiluoromeiiiane··· Surr: Toluene-dB lCS Sample ID: 44.32 48.5 0 50 0 97.0 82 • 115 45.96 0 50 0 91.9 73- 126 49.83 0 50 0 99.7 81 - 120 VLCSWi-190413 Client ID: Run ID: Analyte Result 20.08 Benzene Units: ug/L VOA9_336576 Analysis Date: 13-Apr-2019 13:19 SeqNo: 5035183 PQL SPKVal SPK Ref Value 5.0 20 0 Prep Date: %REC Control Limit 100 74 - 120 Surr: 1, 2-Dich/oroethane-d4 44.3 0 50 0 88.6 70- 130 Surr: 4-Bromofluorobenzene 49.82 0 50 0 99.6 82- 115 Surr: Dibromofluoromethane 48.17 0 50 Surr: Toluene-dB 49.48 0 50 MS Sample ID: Run ID: Benzene Surr: 4-Bromofluorobenzene ---,~"" Surr: Dibromof/uoromethane Surr: Toluene-dB Result 17.94 ·················o··· 0 Units: ug/l HS19040376-01 MS Client ID: Analyte - 5.0 < 0.60 96.3 73- 126 99.0 81- 120 Analysis Date: 13-Apr-2019 20:22 SeqNo: 5035199 VOA9_336576 OF: 1 RPD Ref RPD Value %RPO Limit Qual PQL SPKVal SPK Ref Value 5.0 20 0 PrepDate: %REC Control Limit 89.7 70 -127 49.48 0 50 0 99.0 82- 124 47.55 0 50 0 95.1 77 - 123 49.63 0 50 0 99.3 82- 127 DF: 1 RPO Ref RPD Value %RPO Limit Qual Page 15 of 29 HFNA-000003381 EPA Inspection Report - Page 1832 of 1969 A.LS Houston, US Client: Project: Work:Order: Batch ID: Date: 17-Apr-19 Navajo Refining Company BWON Monthly Sampling (EOL) HS19040619 QC BATCH REPORT NEW R.336576 ( 0) MSO Sample ID: HS19040376·01MSD Client ID: Analyte Benzene Units: ug/L Run ID: Result 17.05 VOA9_336576 Analysis Date: 13-Apr-2019 20:47 SeqNo: 5035200 PQL SPKVal SPK Ref Value 5.0 20 0 PrepDate: DF: 1 Control RPO Ref %REC Limit Value 85.2 70 - 127 RPD %RPD Limit Qual 17.94 5.12 20 '''"'··--------~"~"~" Surr: 1, 2-Dichforoethane-d4 44.03 0 50 0 88. 1 70-126 43.48 1.28 20 Surr: 4-Bromofluorobenzene 49.47 0 50 0 98.9 82- 124 49.48 0.0222 20 Surr: Dibromof/uoromethane 48.12 0 50 0 96.2 77 - 123 Surr: Toluene-d8 49.37 0 50 0 98.7 82 - 127 49.63 0.538 20 The follol~ing samples were analyzed in this batch: )HS19040619-05 HS19040619-06 .. HS19040619-07 .............. 47':55··· 1. 18 20 .············· ""'' ' '] ~--···················" Page 16 of 29 HFNA-000003382 EPA Inspection Report - Page 1833 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Dale: 17-Apr-19 Navajo Refining Company BWON Monthly Sampling (EOL) HS19040619 R.336593 ( 0) MBLK Sample ID: Instrument: Method: MBLKW1-041519 Units: ug/Kg Run ID: Client ID: Analyte QC BATCH REPORT NEW Result PQL Analysis Date: 15-Apr-201914:09 SeqNo: 5035772 VOA.8_336593 VOL.ATILES BY SW8260C SPK Val SPK Ref Value %REC PrepDate: Control Limit Benzene < 25 250 Surr: 1, 2-Dichloroethane-d4 2348 0 2500 0 93.9 76- 125 Surr: 4-Bromofluorobenzene 2298 0 2500 0 91.9 80- 120 Surr: Dibromof/uoromethane 2340 0 2500 0 93.6 80 - 119 Surr: To/uene-d8 2427 0 2500 0 97.1 81 - 118 LCS Sample ID: VLCSW1-041519 Client ID: Analyte VOA.8_336593 SeqNo: 5035771 PQL SPKVal 45.48 5.0 50 0 91.0 75 - 124 52.57 0 50 0 105 80-120 %REC Control Limit Surr: 1, 2-Dichforoethane-d4 Surr: 4-Bromofluorobenzene PrepDate: SPK Ref Value Result Benzene Analysis Date: 15-Apr-2019 13:19 Units: ug/Kg Run ID: Surr: Dibromofluoromethane 50.84 o 50 0 102 80-119 50.53 0 50 0 101 81 - 118 Sample ID: HS19040330-01 MS Client ID: Analyte DF: "I RPD Ref RPD Value %RPO Limit Qual 76 - 125 Surr: Toluene-dB MS DF: 50 RPD Ref RPO Value %RPD Limit Qual Units: ug/Kg Run ID: Result VOA.8_336593 Analysis Date: 15-Apr-2019 16:14 SeqNo: 5036542 PQL SPK Val SPK Ref Value PrepDale: %REC Control Limit Benzene 1845000 240000 2.425e+006 0 76.1 70 - 130 Surr: 1, 2-Dichloroethane-d4 2569000 0 2.425e+006 0 106 70- 126 0 93.9 70- 130 103 70-130 98.9 70-130 Surr: 4-Bromofluorobenzene 2277000 0 2.425e+006 Surr: Dibromof/uoromethane 2509000 0 2.425e+006 Surr: Toluene-dB 2399000 0 2.425e+006 ····························15·· 0 OF: 50000 RPD Ref RPD Value %RPO Limit Qua! Page 17 of29 HFNA-000003383 EPA Inspection Report - Page 1834 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 17-Apr-19 Navajo Refining Company HS19040619 R336593 { 0 ) MSD QC BATCH REPORT NEW BWON Monthly Sampling (EOL) Sample ID: Instrument: VOA$ HS19040330-01MSD Client ID: Method: Units: ug/Kg Run ID: VOA8_336593 VOL.ATILES BY SWS260C Analysis Date: 15-Apr-2019 16:39 SeqNo: 5036543 SPK Ref Analyte Result PQL SPKVal Value %REC PrepDate: Control Limit DF: 50000 RPO Ref RPD Value %RPO Limit Qual ................................................................. ~~~~~~~ 2.425e+006 0 89.5 70-130 1845000 16.2 30 O 2.425e+006 0 105 70- 126 2569000 1.17 30 2.425e+006 0 99.4 70 - 130 2277000 5.7 30 O 2.425e+006 0 105 70-130 2509000 1.01 30 0 97.4 70- 130 2399000 1.51 30 Benzene 21710()0 Surr: 1, 2-Dichloroethane-d4 2539000 Surr: 4-Bromof/uorobenwne 2410000 0 Surr: Dibromofluoromethane 2534000 Surr: Toluene-dB 2363000 0 240000 2.425e+006 The following samples were analyzed in this batch: ~iST9040619~03 ···················HsT§o,foKf9=l)4....................................... _j ··············-----····--··--· · · · · · · · · · · · · · · --·--·· · · · ~-----------------------·························································' Page 18 of29 HFNA-000003384 EPA Inspection Report - Page 1835 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch 10: Date: 17-Apr-19 Navajo Refining Company BWON Monthly Sampling (EOL) HS19040619 R.336631 ( O) MBLK QC BATCH REPORT NEW Sample ID: Instrument: MBLK.W1-041619 Run ID: Client ID: Analyte Result Method: VOi.ATILES BY SW8280C VOA8 Units: ug/Kg VOA.8_336631 PQL Analysis Date: 16-Apr-2019 09:31 SeqNo: 5036467 SPK Val SPK Ref Value %REC PrepDate: Control limit Benzene <25 250 Surr: 1, 2-Dich/oroethane-d4 2461 0 2500 0 98A 76- 125 Surr: 4-Bromofluorobenzene 2378 0 2500 0 95.1 80- 120 Surr: Dibromofluoromethane 2338 0 2500 0 93.5 80 - 119 Surr: Toluene-dB 2511 0 2500 0 100 81 - 118 LCS Sample ID: VLCSW1-041619 Client ID: Run ID: Analyte Result Benzene Analysis Date: 16-Apr-2019 08:41 Units: ug/Kg SeqNo: 5036466 VOA.8_336631 PQL SPKVal PrepDate: SPK Ref Value %REC Control Limit 75 - 124 43.8 5.0 50 0 87.6 Surr: 1, 2-Dichloroethane-d4 51,57 0 50 0 103 76 - 125 Surr: 4-Bromofluorobenzene 49.59 0 50 0 99.2 B0-120 Surr: Dibromofluoromethane 50.04 0 50 0 100 80-119 Surr: Toluene-dB 50.39 0 50 0 101 81 - 118 MS Sample ID: HS19040609-01MS Run ID: Client ID: Analyte Result SeqNo: 5038071 PQL SPKVal SPK Ref Value PrepDate: %REC Control Limit Benzene 2017 250 2525 0 79.9 70 - 130 Surr: 1, 2-Dich!oroethane-d4 2565 0 2525 0 102 70- 126 0 96.2 70 - 130 101 70-130 99.2 70-130 Surr: 4-Bromofluorobenzene 2428 0 2525 Surr: Dibromofluoromethane 2540 0 2525 Surr: Toluene-dB 2506 0 2525 OF: 1 RPO Ref RPD Value %RPO Limit Qual Analysis Date: 16-Apr-201916:11 Units: ug/Kg VOA.8_336631 DF: 50 RPD Ref RPD Value %RPO Limit Qual ·········································rr 0 DF: 50 RPD Ref RPO Value %RPD Limit Qual Page 19 of29 HFNA-000003385 EPA Inspection Report - Page 1836 of 1969 AlS Houston, US Client: Project: WorkOrder: Batch ID: Date: 17-Apr-19 Navajo Refining Company BWON Monthly Sampling {EOL) HS19040619 Instrument: R336631 ( 0) MSC! QC BATCH REPORT NEW Sample ID: HS19040609-01MSD Analyte Units: ug/Kg Run ID: Client ID: Result Method: VOi.ATiLES BY SW8260C VOAS VOA.8_336631 SeqNo: 5038072 PQL SPK Val . ................................................................................... ........ Analysis Date: 16-Apr-201916:36 PrepDate: SPK Ref Value %REC Control Limit 80.7 70 - 130 OF: 50 RPD Ref RPD Value %RPD limit Qual ~~~~~~~~~~ Benzene 2038 250 2525 0 Surr: 1, 2-Dich!oroethane-d4 2522 0 2525 0 99.9 70- 126 2565 1.66 30 Surr: 4-Bromofluorobenzene 2370 0 2525 0 93.8 70 - 130 2428 2A3 30 Surr: Dibromof/uoromethane 2536 0 2525 0 100 70- 130 Surr: Toluene-dB 2428 0 2525 0 96.2 70 - 130 2017 1.03 30 ''''''''''''''''''''''''''''''''''''''''"""~" ···················254()··· 2506 0.166 30 3.15 30 --------"~"" The follov.ing samples were analyzed in this batch: Page 20 of29 HFNA-000003386 EPA Inspection Report - Page 1837 of 1969 ALS Houston, US Client: Project: WorkOrder: Batch ID: Date: 17-Apr-19 Navajo Refining Company HS19040619 R336662 ( 0) MBLK QC BATCH REPORT NEW BWON Monthly Sampling (EOL) Sample ID: VBLKW-190415 Units: ug/L Run ID: Client ID: Analyte VOA9 Instrument: Result VOA.9_336662 PQL Analysis Date: 15-Apr-201919:27 SeqNo: 5036958 PrepDate: SPKVal SPK Ref Value %REC Control Limit 0 87.8 70- 130 < 0.60 5.0 Surr: 1, 2-Dichloroethane-d4 43.89 0 50 Surr: 4-Bromofluorobenzene 48.12 0 50 0 96.2 82 - 115 Surr: Dibromof/uoromethane 46.65 0 50 0 93.3 73- 126 Surr: Toluene-dB 49.09 0 50 0 98.2 81 - 120 Benzene LCS Sample ID: Units: ug/L VLCSW-190415 Run ID: Client ID: Analyte Result 17.87 Benzene Surr: 1, 2-Dichloroethane-d4 42.9 Surr: 4-Bromofluorobenzene 49.22 VOA.9_336662 SeqNo:5036957 PrepDate: PQL SPKVal SPK Ref Value %REC Control Limit 5.0 20 0 89.3 74 - 120 0 50 0 98.4 82- 115 47.12 0 50 0 94.2 73-126 4R12 0 50 0 98.2 81 - 120 Sample ID: Analyte DF: 1 RPD Ref RPD Value %RPD Limit Qual 70 - 130 Surr: Toluene-dB Units: ug/L HS19040747-02MS Run ID: Client ID: RPD Ref RPD Value %RPD Limit Qual Analysis Date: 15-Apr-2019 18:38 Surr: Dibromofluoromethane MS DF: 1 VOA.9_336662 Analysis Date: 15-Apr-2019 22:23 SeqNo:5036965 Result PQL SPKVal Benzene 3331 5.0 20 Surr: 1, 2-Dich/oroethane-d4 38.82 Surr: 4-Bromof!uorobenzene 47.38 0 Surr: Dibromof/uoromethane 46.92 0 Surr: Toluene-dB 45.78 0 50 SPK Ref Value %REC 2501 4150 ----- PrepDate: Control Limit 70 - 127 -- RPD Ref RPD Value %RPO Limit Qual SEO "~"---"~"-- 0 77.6 70- 126 50 0 94.8 82- 124 50 0 93.8 77 -123 0 91.6 82- 127 50 DF: 1 Page 21 of29 HFNA-000003387 EPA Inspection Report - Page 1838 of 1969 AlS Houston, US Client Project: WorkOrder: Dale: 17-Apr-19 Navajo Refining Company BWON Monthly Sampling (EOL) HS19040619 Batch ID: R336!l62 ( 0 ) MSD Sample ID: Instrument: Benzene , Method: VOLATILES - SW8260C HS19040747-02MSD Client ID: Analyte QC BATCH REPORT NEW Run ID: Result 2489 Units: ug/l VOA9_336662 Analysis Date: 15-Apr-2019 22:48 SeqNo: 5036966 PQL SPKVal SPK Ref Value 5.0 20 2501 %REC -62.6 PrepDate: Control limit 70 -127 DF: 1 RPD Ref RPD Value %RPO Limit Qual 3331 28.9 20 SREO Surr: 1,2-Dichloroethane-d4 44.95 0 50 0 89.9 70 • 126 38.82 14.6 20 Surr: 4-Bromofluorobenzene .................. ,,,,,,,,,,,,,,,, ............. ~"~" Surr: Dibromofluoromethane 42.38 0 50 0 84.8 82 - 124 47.38 11. 1 20 4921 0 50 0 98.4 77 - 123 46.92 4.77 20 49.48 0 50 0 98.9 82- 127 45.78 7.72 20 Surr: Toluene-dB The following samples were analyzed in this batch: rlS19040619-02 HS 19040619-08 ,,,,,,,,,, ••••••••••••••••ccccccccccccccc-~l Page 22 of29 HFNA-000003388 EPA Inspection Report - Page 1839 of 1969 ALS Houston, US Client Project: WorkOrder: Qualifier Date: Navajo Refining Company BWON Monthly Sampling (EOl) 17-Apr-19 QUALIFIERS, ACRONYMS, UNITS HS19040619 ..................Description .. Value exceeds Regulatory Limit a Not accredited B Analyte detected in the associated Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time J Analyte detected below quantitation limit M Manually integrated, see raw data for justification n Not offered for accreditation ND Not Detected at the Reporting Limit 0 Sample amount is > 4 times amount spiked p Dual Column results percent difference > 40% R RPD above laboratory control limit s u Spike Recovery outside laboratory control limits Analyzed but not detected above the MDUSDL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SDL Sample Detection Limit TRRP Texas Risk Reduction Program UnitReported ... P~~cription mg/Kg Milligrams per Kilogram mg/L Milligrams per Liter Page 23 of29 HFNA-000003389 EPA Inspection Report - Page 1840 of 1969 ALS Houston, US Date: H-Apr-19 CERTIFICATIONS,ACCREDITATIONS & LICENSES Number T10470231-18-21 R193 2018-2019 004438 03087 L2231 123043 - 2018 30-Apr-2019 E-10352 2018-2019 31-Jul-2019 Oklahoma 2018-156 31-Aug-2019 North Carolina 624-2019 31-Dec-2019 California 2919, 2018-2019 30-Apr-2019 Maryland 343, 2018-2019 30-Jun-2019 •••••••• .... • • • • • • • • • • • • • • • • • • • • • • • • • • • • c c c c c c c c c c c c c c c - - - - - - - - - ~ - - - - - - - - - Arkansas - - - - - ~19-028-0 --------~ ..................................................................................... Page 24 of29 HFNA-000003390 EPA Inspection Report - Page 1841 of 1969 A.LS Houston, US 17-Apr-19 Date: Client: Navajo Refining Company Project: BWON Monthly Sampling {EOL) Work Order: HS19040619 SAMPLE TRACKING Lab Samp ID Client Sample ID Action Date HS19040619-01 S-1 (API HC) Login 4/10/2019 8:10:13 PM PMG VOA160 HS19040619-02 S-3 (API Water) Login 4/10/2019 8:10:13 PM PMG VOA160 HS19040619-03 S-5 (T-40} Login 4/10/2019 8:10:13 PM PMG VOA160 Person New location HS 19040619-04 S-6 {T-41) Login 4/10/2019 8:10:13 PM PMG VOA"l60 HS 19040619-05 Field Blank Login 4/10/2019 8:10:13 PM PMG VOA160 HS 19040619-06 EQ Blank Port 1 Login 4/10/2019 8:10:13 PM PMG VOA160 HS19040619-07 EQ Blank Port 2 Login 4/10/2019 8:10:13 PM PMG VOA160 HS 19040619-08 Duplicate Login 4/10/2019 8:10:13 PM PMG VOA160 HS 19040619-09 Trip Blank Login 4/10/2019 8:10:13 PM PMG VOA160 Page 25 of29 HFNA-000003391 EPA Inspection Report - Page 1842 of 1969 AlS Houston, US Date: 17-Apr-19 Sample Receipt Checklist Client Name: Navajo Refining Datemme Received: 09-AJ;,r-2019 12:54 Work Order: HS19040619 Received by: PMG Checklist completed by: Paresh M. Giga Reviewed by: 10-Apr-2019 Date eSignature Co rev, Grandits---,---T-12-Apr-2019 '" i eSignature Matrices: Carrier name: Shipping container/cooler in good condition? Yes No Custody seals intact on shipping container/cooler? Yes No Not Present Not Present Custody seals intact on sample bottles? Yes No VOA/TX1005ITXi006 Solids in hermetically sealed vials? Yes No Not Present Not Present Chain of custody present? Yes No 1 Page{s} Chain of custody signed when relinquished and received? Yes No COG 1Ds:None Samplers name present on COC? Yes No Chain of custody agrees with sample labels? Yes No Samples in proper container/bottle? Yes No Sample containers intact? Yes No Sufficient sample volume for indicated test? Yes No All samples received within holding time? Yes No Containerrremp Blank temperature in compliance? Yes No Temperature(s )IThermometer(s ): Date .?cl U/C !:IR11 ..............::,....... Foam ........................................................................................""""""'···"········ ······--····---.' ···· Cooler(s)/Kit(s): Datemme sample(s) sent to storage: ~ /9/19 20:00 ·ves@ Water - VOA vials have zero headspace? No No VOA vials submitted Water - pH acceptable upon receipt? Yes No N/A pH adjusted? Yes No NIA pH adjusted by: Login Notes: Client Contacted: Contacted By: Date Contacted: Person Contacted: Regarding: Comments: Corrective Action: Page 26 of29 HFNA-000003392 EPA Inspection Report - Page 1843 of 1969 Chain of Custody Form ~..........?.!...... _ . 1 _ ..J D D Page ... ):::y:::)~~:~r:~:Rt:~~r! , . ,,,,.. , ....., , , , , , . . . . . . . . - . .- .·.·.·.·.-.·.·.·. ·.·.·.·.·.·.·.·.·.· ~ . . . _. ___ t itlri~:. - - ".,. ""'""":•~~•,, ~ ::::>tairip~i:i:v:Noon,iNavajo Refining Company LLC J I' +I 513 7.'l:J 5336 D Hol/ar,d,MI +I 616 399 6070 D Salt lake City, UT + 1 801 266 7700 !~e~~f ;! 2600 0 Houston, TX D Spring City, l'A +16109484903 Fort Col/Ins, CO +19704901511 D /11/iddlerowr,, PA +I 717944 5541 D York,PA +1717505 5280 Cincinnati, OH 1 I +I 2815305656 HS19040619 Al Navajo Refining Company BWON Monthly Sampling (EOL) 00;! Ea!f! Ma!n . ~- ;?" .• 1111 II ml 11111111111 .·.. ,. .· .}~i~i~#i~~iif Artesia, NM 88211-0159 }:/:\\:/:/:~# (575) 748-3311 D ·-----+'-.,_,_.,....;,s;..,,,...,,;,,.,...-,-;"'-+-------------1 [::~~;:1:::::\:i f:;:;:~~~~;:~:(:::i1.~:::::f;~:::;::::~#~#~~:~itriplklit···· i: :;,;:~~~i~~,w.-m 1 \\JS~1 {AP! HC} }i/lS-3 (API Water) ::>~:Js-s (T-40) \{JS-6 (T-41) /~\I Field Blank ______________ .... _,-._,,,.,,. __ 04108/1 t·•••••••Cq.•kY1C "'t""""'"1·•f'""""' !-L 1,••,.······t 1 OO!ller _ _ __ d Turfu1.round Ttroe:.: D STD 10 Wk Days fl) 5 W¥Days 0 2 Wk Days D 24 Hour I "Tl z :r0 0 0 0 0 (,) (,) (!) (,) Note: Any changes must be made In writing once 1111mples and COC: Form have been submitted to Al$ Laboratory Group. i'. . l 0..,1,J Cti-u\M'"'I{ {;;) t.:)' ,~ ~(~Y~ ...../ Page 27 of29 ' "*' Cl po. o "0 ~ ·.J;;9,PYri!I.ht 2009 by ALS Laboratory Group J- , ;·········! t EPA Inspection Report - Page 1844 of 1969 ~ ~. ~ -: : Us;e ofthlsi ltYstem eoi"l~itute! your sgreemerit to the service rondltkin:s lri the current ~dEl Ss!lrvltie Gu!d~f a\l'ail~ble on f~d~.tom. FedEx wlll not be res:pons;H,iefcr any da.im in el(.CeiE:i. of $100 pm pachge9 whi!thetthes re!S~dt of !os.s~ demsi:~. . O 4'\ - I z :r0 0 0 0 0 (,) (,) (!) .i:,,. ~~ ~ ~~ ~ After jiirln~;ia th!~ ffi.b!J!!I: CONSICN!t COPY PLEASE PL/ICE IN FRONT 01' POUCH 1, !='dd th* ~n1'9cl psge l!l:kms the h.t1rlzcrn:&e !lru:!. 2. Pio<• i.ool in •~!pplo; po•,h •n m ir~~:r c ~ Bj irn ~I· i;OS:t;,oo;:o ~ ~1 I ~ w 0 =r lli!ii I i u,·~---··<,,L..~ !~ UI 1 If i§ w ; I' :i ....;. ~~ m 'Tl ! "ti ;:a ;:a z ... :i,,, - 0 G'l i.:, 8 =i ~ ~- I ~-,~ w.:;Qs ll'i~nSl~ mu Page 28 of29 ~0 - z~ ~· . OO~j\i: .r- ·. ;~r' ;gm ~ -a >~ :c:~ = >llfg ·. »;i;: ~! ::a ' lij -0 X pz ::::1::;; ::t iJJ; iii!;! -I ~ 0 C: w m.l ?.:;,i::: -<.m).ll l>; .... [ c:::, 0 00 -l ;;;;;.. $! ii ~ ~ l;:c::: -1 m®m iiiil·==~ ;::~-:-·i1s~ ] ~ C) -~ "" -,, o i <.:JS .! .., i O ii[ - ;:::g'c ~ _ ::jc:<;;j ~$1 ~···· - ;1!1~z - - EPA Inspection Report - Page 1845 of 1969 SHIPPER'S llECLARATION FOR DANGEROUS GOODS t t (Provide at least thffle eopll!S to nlrllne.) I Sll!pp .. AlrW.ybnl No. 709306590762 NAVAJO REFINING COMPANY C/0 AQUA MICROBICS 501 E MAIN I ARTESIA 1.Shlpl"'f'• R-"°" lil""'bo' Pogo 1 cf 1 Pago(•! j NM88210 US /opl1"m!IJ Ct'l~Blgnee FX 18 Compliant Corey Gramiits ALS 10450 Stancliff Sui!e210 HOUSTON ~ ~ ® Express CAFE3211 TX 77099 US WARNING r"" f Failure to comply with all respects with the applicable Dangerous Goods Regulations may lie in breach of the appl!eable law ,subject to legal penalties. HW./:WORT DETAILS Thi• oh!pmont Is wlttllo Ills !Imitations pmtcribe!.1 ftlr. {dmb> mm opp!lcoblo} Al!J)Oriof°""",m"' ARTESIA ! -·,o-,,~-r·· "'W"I ~ O..Un.Uoo: HOUSTON ~ -t ==4 NATURE AND QUANTITY OF DANGEROUS GOODS UN Humbof or 1m1mcouoo Numoor, P"'fJ'll "111pp/ng n..,o. a,.. or llMsl<>n (8"bs/illolydsli;I, l'J"e/••I OOYom.,,.oml Raguiotlooo. I d..1... 11111t ! Neme/TiUe of Sfgnato1Y Brady Hubl>erolEmlronmenlal coom1M1or Plaoo and Paw Art~~.lJl, NM Mffl812tma au oftha 8ppUubie air tmnap(lrt r&quirmminl& hav1111 bem mat. Signature Brady Hullbon:I 16004249300 em.,v...yn,-N..,.... jlo,._,,lo;I ...~ (J ------------~------~~••-'•-HNN-~••-'---~•-"•"" r~ ~};n?::3A.C1'NE MAllE:RJAL ISHlABE~T .A.CCEPTABUS FOR fASSE11:1G£R SURCIIUFr, TH! !Ul!PME!ffCOlfrAIHS RM!O.\Ctf~ MA.ru.f4 !HnNDED FOR USE !HOR INCi!JEl!T Ta RESl!!.ARCH, MmaCAL Cl.AG.MOW! OR TRE'1.nlreH'r. ADR ll!UROPEAN mA.N9PORT BTATEMEPO': CARRIAGE IN ACCORDANCE mffl 1.1' ..U.1 !.O\l(lS.~HYl!ilS:VifH Page 29 of29 -~ -~ ~ EPA Inspection Report - Page 1846 of 1969 10450 StancHff Rd. Suite 210 Houston, TX 77099 T: +1 281 530 5656 F: +1 281 530 5887 April 17, 2019 Gabriela Combs Navajo Refining Company PO Box 1490 Artesia, NM 88211-1490 Work Order: HS19040623 Laboratory Results for: BWON Monthly Sampling {EOL} Dear Gabriela, ALS Environmental received 4 sample(s) on Apr 09, 2019 for the analysis presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Results are expressed as "as received" unless otherwise noted. QC sample results for this data met EPA or laboratory specifications except as noted in the Case Narrative or as noted with qualifiers in the QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained by ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. If you have any questions regarding this report, please feel free to call me. Sincerely, Generated Sy: JUMOKE.LAWAL Corey Grandits Project Manager Ri9ht Solutions Right Partner www,a!sgbbaLcom Page 1 of22 HFNA-000003396 EPA Inspection Report - Page 1847 of 1969 ALS Hcmston, US 17-Apr-19 Date: Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Work Order: HS19040623 SAMPLE SUMMARY Lab Samp ID Client Sample ID Matrix HS19040623-01 S-1 (API HC} HS19040623-02 TagNo Collection Date Date Received Liquid 08-Apr-2019 09:04 09-Apr-2019 12:54 :?..............~ ::: ~ ::: ~ S-3 (API Water) Liquid 08-Apr-2019 09:15 09-Apr-2019 12:54 :::...............::: ::: ::: ::: ::: :::.................~ HS19040623-03 S-5 (T-40) Liquid 08-Apr-2019 08:42 09-Apr-2019 12:54 L. . . . . . J HS19040S23-04 S-6 (T-41) Liquid 08-Apr-2019 08:47 09-Apr-2019 12:54 L.. . . ...J. Hold :::.................~ :::--.............::: ::: ::: ...............'x ~ ::: ::: Page 2 of22 HFNA-000003397 EPA Inspection Report - Page 1848 of 1969 ALS Houston, US Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Work Order: HS19040623 Date: 17-Apr-19 CASE NARR.ATIVE Work: Order Comments • The analysis for Specific Gravity was subcontracted to ALS Environmental in Holland, Ml. Final report attached. Page 3 of22 HFNA-000003398 EPA Inspection Report - Page 1849 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 17-Apr-19 WorkOrder:HS 19040623 S-1 {AP! HC) 08-Apr-2019 09:04 RESULT QUAL SUBCONTRACTED ANALYSIS SPECIFIC - ~~yrry Subcontract Analysis AN.AlYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) Lab ID:HS19040623-01 Matrix:Liquid MDL REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED -----------------------------------------------------------------------------------«~««---------------- Method:NA Analyst: ~UB!iQ See Attached 0 NA 17-Apr-2019 10:14 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 4 of22 HFNA-000003399 EPA Inspection Report - Page 1850 of 1969 ALS Houston, !JS Date: 17-Apr-19 ANALYTICAL REPORT Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Sample ID: S-3 (AP! Water) Collection Date: 08-Apr-2019 09:15 ANALYSES RESULT QI.JAL ~UBCONTAACTED ANALYSIS SPECIFIC GRAVITY Subcontract Analysis WorkOrder: HS 19040623 Lab !D:HS19040623-02 Matrix:Uquid MDL REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED Analyst Method:NA f3UB1-i0 See Attached 0 NA 17-Apr-2019 10:14 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 5 of22 HFNA-000003400 EPA Inspection Report - Page 1851 of 1969 ALS Houston, US Client: Date: 17-Apr-19 ANALYTICAL REPORT Navajo Refining Company WorkOrder:HS 19040623 Project: BWON Monthly Sampling (EOL) Sample ID: S-5 (T-40) Lab 1D:HS19040623-03 Collection Date: 08-Apr-2019 08:42 Matrix: Liquid ANALYSES RESULT QUAL $UBCONTRACTEl'J ANALYSIS SPECIFIC '.GRAVITY Subcontract Analysis MDL REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED Analyst: SU~HQ Method:NA See Attached 0 NA 17-Apr-2019 10:14 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 6 of22 HFNA-000003401 EPA Inspection Report - Page 1852 of 1969 ALS Houston, US Client: Project Sample ID: Collection Date: ANALYSES Subcontract Analysis Date: 17-Apr-19 ANALYilCAI.. REPORT Navajo Refining Company BWON Monthly Sampling {EOL) Work Order: HS 19040623 S-6 (T-41) 08-Apr-2019 08:47 RESULT QUAL Lab 1D:HS19040623-04 Matrix:Uquid MDL See Attached 0 REPORT LIMIT UNITS NA DILUTION FACTOR DATE ANALYZED Analyst SUBHO 17-Apr-2019 10:14 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 7 of22 HFNA-000003402 EPA Inspection Report - Page 1853 of 1969 ALS Houston, US Date: Navajo Refining Company BWON Monthly Sampling (EOL) Client: Project: Work.Order: DATES REPORT HS19040623 Client Samp ID Sample ID 17-Apr-19 Collection Date TCLP Date Analysis Date Prep Date OF --------------------------------------------------- )::latch ID R.336733 HS 19040623-01 Test Name: SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY S-1 (API HC) 08 Apr 2019 09:04 Matrix: Liquid 17 Apr 2019 10:14 HS 19040623-02 S-3 (API Water) 08 Apr 2019 09:15 17 Apr 2019 10:14 HS 19040623-03 S-5 (T-40) 08 Apr 2019 08:42 17 Apr 2019 10:14 HS 19040623-04 S-6 (T-41) 08 Apr 2019 08:47 17 Apr 2019 10:14 Page 8 of22 HFNA-000003403 EPA Inspection Report - Page 1854 of 1969 ALS Houston, US Client: Project: Work:Order: Qualifier Date: Navajo Refining Company BWON Monthly Sampling (EOl) 17-Apr-19 QUALIFIERS, ACRONYMS, UNITS HS19040623 Description Value exceeds Regulatory Limit a Not accredited B Analyte detected in the associated Method Blank above the Reporting limit E Value above quantitation range H Analyzed outside of Holding Time J Analyte detected below quantitation limit M Manually integrated, see raw data for justification n Not offered for accreditation ND Not Detected at the Reporting Limit 0 Sample amount is > 4 times amount spiked p Dual Column results percent difference > 40% R RPO above laboratory control limit s u Spike Recovery outside laboratory control limits Analyzed but not detected above the MDUSDL ~.C:.~?~Yl'!.I ...................... Description.. DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection limit MQL Method Quantitation limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SDL Sample Detection limit TRRP Texas Risk Reduction Program Page 9 of22 HFNA-000003404 EPA Inspection Report - Page 1855 of 1969 A.LS Houston, US Date: 17-Apr-19 CERTIFICA.TIONS,A.CCREIJITA TIONS & LICENSES Agency Expire Date 30-Apr-2019 30-Apr-2019 004438 Louisiana 03087 Dept of Defense ANAB L2231 Kentucky 123043- 2018 Kansas 29-Jun-2019 0352 2018-2019 Oklahoma 2018-156 North Carolina 624-2019 31-Dec-2019 California 2919, 2018-2019 30-Apr-2019 Maryland 343, 2018-2019 30-Jun-2019 Arkansas 19-028-0 27-Mar-2020 Page 10 of22 HFNA-000003405 EPA Inspection Report - Page 1856 of 1969 ALS Houston, US Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Work Order: HS 19040623 LabSamp ID 17-Apr-19 Date: Client Sample ID SAMPLE TRACKING Action Date Person PMG PMG PMG PMG HS19040623-01 S-1 (AP! HC) Login 4/10/2019 8:43:16 PM HS 19040623-02 S-3 (API Water) Login 4/10/2019 8:43:16 PM HS 19040623-03 S-5 (T-40} Login 4/10/2019 8:43:16 PM HS 19040623-04 S-6 (T-41) Login 4/10/2019 8:43:16 PM New Location Sub Sub Sub Sub Page 11 of22 HFNA-000003406 EPA Inspection Report - Page 1857 of 1969 ALS Houston, IJS Date: 17-Apr-19 Sample Receipt Checklist Client Name: Navajo Refining Dateffime Received: 09-Mr-~1~ 12~fi4 Work Order: HS19040623 Received by: PMG Checklist completed by: Paresh M Gi,.,a eSignature · ;~~:t~:tl!l~i~~ Reviewed by: 10-Apr-2019 Date ·" """""""I ·12-A68~;019 FedEx Matrices: Carrier name: Shipping container/cooler in good condition? Yes Not Present Custody seals intact on shipping containerlcooler? Yes Not Present Custody seals intact on sample bottles? Yes Not Present VOAffX1005ffX1006 Solids in hermetically sealed vials? Yes Not Present Chain of custody present? Yes 1 Page{s} Chain of custody signed when relinquished and received? Yes COG 1Ds:None Samplers name present on COC? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Yes~ Containerffemp Blank temperature in compliance? 1(2.,7c/2.7c U/C Temperature(s)ffhermometer(s): Cooler(s)/Kit(s): Date/Time sample(s) sent to storage: LJ •••••••••••••••••··-·••••••••••••••••• Waler - VOA vials have zero headspace? Yes Water - pH acceptable upon receipt? Yes pH adjusted? Yes D L. .J D ••••••••••••••••••••••ss••••••••sssssssss"---- No No No r:1 L. .J No VOA vials submitted NIA N/A pH adjusted by: login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 12 of22 HFNA-000003407 EPA Inspection Report - Page 1858 of 1969 17-Apr-2019 Corey Grandits ALS Environmental 10450 Stancliff Rd Suite 210 Houston, TX 77099 Re: Work Order: 1904851 HS19040623 Dear Corey, ALS Environmental received 4 samples on 12-Apr-2019 09:30 AM for the analyses presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental - Holland and for only the analyses requested. Sample results are compliant with industry accepted practices and Quality Control results achieved laboratory specifications. Any exceptions are noted in the Case Narrative, or noted with qualifiers in the report or QC batch Information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained from ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. The total number of pages in this report is 10. If you have any questions regarding this report, please feel free to contact me: ADDRESS: 3352128th Avenue, Holland, Ml, USA PHONE: +1 (616) 399-6070 FAX: +1 (616) 399-6185 Sincerely, Chad Whelton Project Manager Report of Laboratory Analysis Certificate No: MN 026-999-449 HFNA-000003408 EPA Inspection Report - Page 1859 of 1969 ALS Group, USA Client: Project: Work Order: Date: 17-Apr-19 ALS Environmental HS19040623 1904851 !,ah Samp m Client Sample ID 1904851-01 HS19040623-0l l 904851-02 HS l 9040623-02 l 904851-03 HS 19040623-03 1904851-04 HS 19040623-04 Work Order Sample Summary Matrix Liquid Liquid Liquid Liquid Tag Number S-1 (API HC) S-3 (API Water) S-5 (T-40) S-6 (T-41) Page 14 of22 Collection Date Date Receiveq 4/8/2019 09:04 4/8/2019 09: 15 4/8/2019 08:42 4/8/2019 08:47 4/12/2019 09:30 4/12/2019 09:30 4/12/2019 09:30 4/12/2019 09:30 Hold r:J Sample Summary Page 1 of l HFNA-000003409 EPA Inspection Report - Page 1860 of 1969 Date: l 7-Apr-19 ALS Group, USA Client: Project: WorkOrder: Qualifier ALS Environmental HS19040623 QUALIFIERS, ACRONYMS, UNITS 1904851 Description Value exceeds Regulatory Limit Estimated Value a Analyte is non-accredited B Analyte detected in the associated Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time Hr BOD/CBOD • Sample was reset outside Hold Time, value should be considered estimated. J ND 0 p Analyte is present at an estimated concentration between the MDL and Report Limi! Not Detected at tbe Reporting Limit Sample amount is > 4 times amount spiked Dual Column results percent difference> 40% R RPD above laboratory control limit s Spike Recovery outside laboratory control limits u Analyzed but not detected above the MDL X Analyte was detected in the Method Blank bet,veen the MDL and Reporting Limit, sample results may exhibit background or reagem contamination at the observed level. Acrom,'m Description DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Comrol Sample Duplicate LOD Limit of Detection (see IvIDL) LOQ Limit ofQuantitation (see PQL) :tvIBLK MDL MS Method Blank Method Detection Limit Matrix Spike MSD Matrix Spike Duplicate PQL Practical Quantitation Limit RPD Relative Percent Difference TDL Target Detection Limit TNTC Too Numerous To Count A APHA Standard Methods D ASTM E EPA SW Units ReQorted SW-846 Update III Description none Page 15 of22 QFPage 1 ofl HFNA-000003410 EPA Inspection Report - Page 1861 of 1969 Date: 17-Apr-19 ALS Group, USA Client: ALS Environmental Project: HS19040623 Sample ID: HS 19040623-01 Work Order: 1904851 Lab ID: 1904851-01 Collection Date: 4/8/2019 09:04 AM Matrix: LIQUID Result Analyses Qual Report Limit SPECIFIC GRAVITY Specific Gravity Note: Units Date Analyzed Analyst: RZM D5057-90 0.944 Dilution Factor none 4/16/2019 04:10 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page l of 4 Page 16 of22 HFNA-000003411 EPA Inspection Report - Page 1862 of 1969 Date: 17-Apr-l 9 ALS G:roup, USA Client: Project: ALS Environmental Sample ID: HS 19040623-02 HS19040623 Work Order: 1904851 Lab ID: 1904851-02 Collection Date: 4/8/2019 09:15 AM Analyses Matrix: LIQUID Result Qua] SPECIFIC GRAVITY Specific Gravity Note: Report Limit Units Date Analyzed Analyst: RZM D5057-90 none 0.998 Dilution Factor 4/16/2019 04:10 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 2 of 4 Page 17 of22 HFNA-000003412 EPA Inspection Report - Page 1863 of 1969 Date: J 7-Apr-19 ALS Group, USA ALS Environmental CJient: Project: HS 19040623 Sample ID: HS19040623-03 Work Order: 1904851 Lab ID: 1904851-03 Collection Date: 4/8i2019 08:42 AM Analyses Matrix: LIQUID Result QuaJ Report Limit SPECIFIC GRAVITY Specific Gravity Note: Units Date Analyzed Analyst RZM D5057-90 1.13 Dilution Factor none 4i16/2019 04:10 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 3 of 4 Page 18 of22 HFNA-000003413 EPA Inspection Report - Page 1864 of 1969 Date: 17-Apr-19 ALS G:roup, USA Client: ALS Environmental Project: Sample ID: HS19040623 Work Order: 1904851 Lab ID: 1904851-04 HS l 9040623-04 Collection Date: 4/8/2019 08:47 AM Analyses Matrix: LIQUID Result Qual Report Limit Units SPECIFIC GRAVITY Specific Gravity Note: 1.14 none Dilution Factor Date Analyzed Analyst: RZl\/1 4/16/2019 04:10 PM See Qualifiers page for a list of qualifiers and !heir definitions. Analytical Results Page 4 of 4 Page 19 of22 HFNA-000003414 EPA Inspection Report - Page 1865 of 1969 Date: 17-Apr-19 ALS Group, USA Client: Work Order: Project: ALS Environmental 1904851 HS19040623 Instrument ID WETCHEM Batch ID: R25S5S4 DUP QC BATCH REPORT Method: 05057'-90 Sample ID: 1904851-02A DUP Client ID: HS19040623.02 Units: none Run ID: WETCHEM_190416H Analyte Result POL SPK Val Specific Gravity 0.9998 0 0 The following samples were analyzed in this batch: Note: SeqNo: 5609851 SPKRef Value i904851-01A 1904851-04A Analysis Date: 411612019 04:10 PM %REC 0 0 1904851-02A DF: 1 Prep Date: Control Limit 0-0 RPD Ref Value 0.9978 %RPD 0.2 RPD Limit Qual 20 1904851-03A See Qualifiers Page for a list of Qualifiers and their explanation. QC Page: 1 of 1 Page 20 of22 HFNA-000003415 EPA Inspection Report - Page 1866 of 1969 10450 Stancilff Rd, Ste 210 Houston, rx 77099 T: +l 281 530 56S6 IF; +1 281 530 5887 www.alsglobal.com Subcontract Chain of Custody COC ID: :U.109 ALS Group USA, Corp. 3352 ~ 128th Ave Phone: Hollancl, MI 494249263 +1 i:i16 399 6070 INVOICE CUSTOMER INFORMATION; INIFOR.MATI:ON: Comp.tny: ALS Houston Corey Gram:ilts COmp.tny: contact: ALS Houston Contact: Address: 10450 Stancliff Rd, Ste 210 Address: 10450 Stancliff Rd, Ste 210 Phone: Email: +1 281 530 5656 Phone: +1 281 530 S656 Coray.Grand!ts@alsglobal.com Reference: HS:19040523 TSR: Houston House Acct Alternate Accounts Payable Contact: Email! 1, HS19040623..01 Liquid S-1 (AP! HC) Sub Specific Gravity to ALS Holliii!nd 2, HS:19040623..02 3, HS1!HJ40li23..0:3 Liquid S-3 (API Wa~r) Sub Spedflc Gravity HS:1.9040623~04 08 Apr 2019 O!h 15 16 Apr 2019 to ALS Holland Liquid i!iHS f'f-40) 08 Apr 2019 08:42 15 Apr 2019 Sub Spec!flc Gravity to ALS Holland 4. OB Apr 2019 09:04 16 Apr 2019 Uquld S-6 (T••,4:1.) 08 Apr 2019 08:47 16 Apr 2019 Sub Specific: Gravity to ALS Holland comments: Please analyze for the analysis listed above. Send report to the emails shown above. QC Leveb STO (Laboratory Standard QC: method blank and LC$ required) Relinquished By; Date/Tlme; Received Sy: Date/Tlme; Coo!er ID(s): Temperature{s); Page 21 of 22 HFNA-000003416 EPA Inspection Report - Page 1867 of 1969 ALS Group, USA Sample Receipt Checklist Client Name: A.LS • HOUSTON Date/Time Received: 12-Apr-1!Hl9:30 Work Order: 1904851 Received by: DS Checklist completed by .Jt,__ '--C,£,,_, Reviewed by: 12-Apr-19 eSignature c~.e )ckWt:.... 12-Apr-19 eSignature Date Date Matrices: Carrier name: Shipping container/cooler in good condition? Yes l~] No Not Present Custody seals intact on shipping container/cooler1 Yes l~] No Not Present Custody seals intact on sample bottles? Yes No Not Present Chain of custody present? Yes iv'! No Chain of custody signed when relinquished and received? Yes iv'! No Chain of custody agrees with sample labels? Yes !y'i No Samples in proper container/bottle? Yes vi No Sample containers intact? Yes ~ No Sufficient sample volume for indicated test? Yes ~ No All samples received within holding time? Yes ~ No Container/Temp Blank temperature in compliance? Yes ~ No Yes ~ No Sample(s) received on ice? Temperature(s )ffhermometer{s ): ~ SR2 i3.6/3.6 C Cooler{s)/Kit(s}: Date/Time sample(s) sent to storage: 4/12/2019 12:04:54 PM Water - VOA vials have zero headspace? Yes No No VOA vials submitted Water - pH acceptable upon receipt? Yes No NIA ~ pH adjusted? pH adjusted by: Yes No NIA ~ [~J Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: CorrectiveAction: Page12of22 SRC Page 1 of 1 HFNA-000003417 EPA Inspection Report - Page 1868 of 1969 10450 Stancliff Rd. Suite 210 Houston, TX 77099 T: +1 281 530 5656 F: +1 281 530 5887 May 17, 2019 Gabriela Combs Navajo Refining Company PO Box 1490 Artesia, NM 88211-1490 Work Order: HS190506134 laboratory Results for: BWON Monthly Sampling {EOL} Dear Gabriela, ALS Environmental received 4 sample(s) on May 10, 2019 for the analysis presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Results are expressed as "as received" unless otherwise noted. QC sample results for this data met EPA or laboratory specifications except as noted in the Case Narrative or as noted with qualifiers in the QC batch information. Should this laboratory report need to be reproduced, It should be reproduced in full unless written approval has been obtained by ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. If you have any questions regarding this report, please feel free to cal! me. Sincerely, Generated Sy: COREY.GRANDITS Corey Grandits Project Manager Ri9ht Solutions Ri9ht Partner www,ahgbhaLcnm Page 1 of23 HFNA-000003418 EPA Inspection Report - Page 1869 of 1969 A.LS Houston, US Date: Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Work Order: HS19050684 17-May-19 SAMPLE SUMMARY Lab Samp ID Client Sample ID Matrix HS19050684-01 S-1 (API HC) HS19050684-02 Collection Date Date Received Liquid 09-May-2019 09:28 10-May-2019 09:15 S-3 (API Water) Liquid 09-May-2019 09:39 10-May-2019 09:15 L. . . .J. HS19050684-03 S-5 (T-40) Liquid 09-May-2019 09:06 10-May-2019 09:15 L.w.1 HS19050684-04 S-6 (T-41) Liquid 09-May-2019 09:12 10-May-2019 09:15 TagNo Hold ,:.....,.....::; ~ ~ t. . . . . J ,::-.,,,... ~ ~ ~ ,:.-..-..-..-..-..-:;: ~ ~ t. . . . . . . .l 1... . . . . ..1 Page 2 of23 HFNA-000003419 EPA Inspection Report - Page 1870 of 1969 AlS Houston, US Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Work Order: HS19050684 Date: 17-May-19 CASE NARRATIVE Work Order Comments • The analysis for Specific Gravity was subcontracted lo ALS Environmental in Holland, Ml. Final report attached" Sample S-1 (API HC) had limited volume, ALS Holland was unable to perform analysis" Page 3 of23 HFNA-000003420 EPA Inspection Report - Page 1871 of 1969 AlS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 17-May-19 RESULT QUAL $0BCOlm:tACTED ANALYSIS SPECIFIC ~RA,V!TV Subcontract Analysis ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-3 (API Water) 09-May-2019 09:39 MDL Work0rder:HS19050684 lab ID:HS19050684-02 Matrix:liquid REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED Analyst Methcd:NA See Attached 0 NA SUBHO 17-May-2019 13:07 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 4 of23 HFNA-000003421 EPA Inspection Report - Page 1872 of 1969 ALS Houston, US Client Project: Sample ID: Collection Date: Date: 17-May-19 Navajo Refining Company BWON Monthly Sampling (EOL) S-5 (T-40) 09-May-2019 09:06 ANALYTICAL REPORT WorkOrder:HS 19050684 lab ID:HS19050684-03 Matrix:Uquid DILUTION DATE REPORT UNITS FACTOR ANALYZED LIMIT U""a""c""o=N=r=AA~C=re=o~A=NA""L~Y""'S"'"!S"'"S~P""'E"°'C""!F""IC=---M-et-h-od_:_N_A--------------·····························ss,ss·····-"----AF"n"'ai""ys"C"t:ANALYSES RESULT QUAL MDL s=· ~~VffY Subcontract Analysis SL1,£3tiQ See Attached 0 NA 17-May-2019 13:07 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 5 of23 RIGHT SOUJTIONS j RIGHT PARTNER HFNA-000003422 EPA Inspection Report - Page 1873 of 1969 ALS Houston, US Date: 17-May-19 ANALYTICAL REPORT Project: Navajo Refining Company BWON Monthly Sampling (EOL) Sample ID: S-6 {T-41) Lab lD:HS19050684-04 Collection Date: 09-May-2019 09:12 Matrix:Uquid Client ANALYSES Subcontract Analysis RESULT QUAL MDL See Attached 0 WorkOrder: HS 19050684 REPORT LIMIT UNITS NA DILUTION FACTOR DATE ANALYZED Analyst: SUBHO 17-May-2019 13:07 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 6 of23 HFNA-000003423 EPA Inspection Report - Page 1874 of 1969 ALS Houston, US Navajo Refining Company BWON Monthly Sampling (EOL) Client: Project: WorkOrder: DATES REPORT HS19050684 Client Samp ID Sample ID Batch lD Date: 17-May-19 R338645 Collection Date TCLP Date Analysis Date Prep Date Test Name : SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY DF Matrix: liquid HS19050684-02 S-3 (API Water} 09 May 2019 09:39 17 May 2019 13:07 HS19050684-03 S-5 (T-40) 09 May 2019 09:06 17 May 2019 13:07 HS19050684-04 S-6 (T-41) 09 May 2019 09:12 17 May 2019 13:07 Page 7 of23 HFNA-000003424 EPA Inspection Report - Page 1875 of 1969 ALS Houston, US Date: 17-May-19 Navajo Refining Company BWON Monthly Sampling (EOL) Client: Project: Work:Order: HS19050684 Qualifier Descri~ QUALIFIERS, ACRONYMS, UNITS Value exceeds Regulatory limit a Not accredited B Analy!e detected in the associated Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time J Analyte detected below quantitation limit M Manually integrated, see raw data for justification n Not offered for accreditation ND Not Detected at the Reporting Limit 0 p Dual Column results percent difference > 40% Sample amount is > 4 times amount spiked R RPO above laboratory control limit s Spike Recovery outside laboratory control limits u Analyzed but not detected above the MDUSDL DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SDL Sample Detection Limit TRRP Texas Risk Reduction Program Page 8 of23 HFNA-000003425 EPA Inspection Report - Page 1876 of 1969 A.LS Houston, US Date: 17-May-19 CERTIFICATIONS,ACCREDITATIONS & LICENSES Number Agency Expire Date Illinois Louisiana 30-Jun-2019 Dept of Defense Kansas 20-Dec-2021 E-10352 2018-2019 31-Jul-2019 Oklahoma 2018-156 31-Aug-2019 North Carolina 624-2019 31-Dec-2019 343, 2018-2019 30-Jun-2019 19-028-0 27-Mar-2020 ............................................................. ·······························································l····················-···--····-··-··---~---···········································-''-- '····························; TX104704231-19-23 30-Apr-2020 Page 9 of23 HFNA-000003426 EPA Inspection Report - Page 1877 of 1969 ALS Houston, I.JS Dale: 17-May-19 Sample Receipt Checklist Client Name: Navajo Refining Daterrime Received: .~J90~:15 Work Order: HS19050884 Received by: .I.BM Checklist completed by: Raegen Giga Matrices: Reviewed by: 19~M§Y~?919 eSignature Corey Grandits Date eSignature water1on Carrier name: Shipping container/cooler in good condition? Not Present Custody seals intact on shipping container/cooler? Not Present Custody seals intact on sample bottles? Not Present VONTX1005rrX1006 Solids in hermetically sealed vials? Not Present Chain of custody present? Chain of custody signed when relinquished and received? Samplers name present on COG? Chain of custody agrees with sample labels? Samples in proper container/bottle? Sample containers intact? Sufficient sample volume for indicated test? All samples received within holding time? Containerrremp Blank temperature in compliance? Temperature( s )i"Thermometer(s ): ········[!IR1f [1.2c ········································««««<«-------JJ----- Cooler(s)iKit(s): Foam Date/Time sample(s) sent to storage: 05/10/2019 ..1°9:30 Ltd Yes LJ Water - VOA vials have zero headspace? Yes Water - pH acceptable upon receipt? pH adjusted? Yes No VOA vials submitted I "'""' NA[?] NIA pH adjusted by: Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 10 of23 HFNA-000003427 EPA Inspection Report - Page 1878 of 1969 Chain of Custody Form ~e _j_ of __j__ -u--·····::--:;;;;----z---~ D D J D +I 513 733 5336 D Holland.Ml +I 616 399 6070 D EYerett, WA 0 Houston, TX +I 281 530 5656 D Spring Cl!V, PA +I 610 948 4903 D Middletown, PA ;.I 717 944 5541 D York.PA +I 717 505 5280 Ci11ci1111ati, OH +l 425 3S6 2600 fort Collins, CO +1970490 1SII Salt Lake City, UT + I 80! 266 7700 Enulranmen t:al :•?::::::::\:::::::::::::Cui:rto1Mt.fo'f0r.mi;foit:•·••- > ..·. :::. :;:::/::::/:::::\::::::: HS19050684 Navajo Refining Company BWON Monthly Sampling (EOL) P.O.Box 159 ~-~ '"" """ 1?:C:}?:~r!~~!~!JArtesia, 1111111111 New Mexico inmo 7411-3311 ;:;~;;;;;~)Lij:::~:~:~:tMjm!~ Coo•lg,,.. FX 18 Compliant Cor,ayGrandils /\LS 10450 Stanciiff Sui1e210 HOUSTON Express e CAFE3211 TX 77099 US n.o ocmpl«,,!land•1flne•II fo,: (oololo ooo appllo•b!o) -~ ~ ~~ ~ ~ All Woyi>ill No. Page 1 Ol 1 Page{s) 501 EM/\IN ARTESIA applicable Dangerous Goods Regulations may be in Alrp<>fl of l:!oportti"' AITTESIJ\ bmach of the applicable law ,subject to legal penaltil!9. 1 ABSGRA ,s;:.,.1;3: · N (!) I ~d-mm,pcl<:""11!) -~~-.-.-.~~-.-.-.-----------~~•••.v------------ ·•--c-c•ccc cccc~•ii 1 NATURE AND QUANTITY OF DANGEROUS GOODS I.IN n • .,..,. orldel!em..t1"" Number, pmpkohlpplog ""'"' Cl•.. or OMolon (s-/a,y Bfs,l\i, ~ g (JtOl)p !If ""l•ltoo'J, asda/1 olll' ·'·,«db...,,.. ··················• , > . / " · I horol>y doeloro lhal Ille ooiili!OIS ol lillo ••••ia,,m..t ""' rully and Name/Tillo OI Si90111i:l,y ' .s.e-cumt&ly described abl.we Dj" the proper shtpplng n.ame, and nm Brady Hubbam/Envlronmeni.31 Coordinator cl...liiGd, pacloi9ed, mollood ••d lollelln•I G""•mm•111111 Rf1l•lo!l<>oo. I doclom !Mt Me,la, NM DMl!il!llO oil ol ll!e opp!l .. blo olr !ron•pofl "'qol..,..o!l!s havo l>o&o mot. Brody Hubbord Slgna!um !,,,---------------------<, .....__ 18004249300 Em~1WyT1111'pJt1:1MN.itmW i~~ FOR RA!llOMllVE MA'fEl'llAI.SHll'MElrl' ACCEPTABLE R>R P"8l!E•G&UIRCRAFT; '!liE 8HIPMENTOONTMl!ll "'"31o=E MA,...,,.._IOTalDEO !'CM< OSE IM !311 IHC:H'J.l:HT ro RESEARCH, MEDICAL D~SIS OR nl:EA'JMENT. AOR. 16:IJROP!SAft mAtaSSPORTITTA'ii:MISNT: CMie!AGS ffi ACCORDAllllCEwrrtt 11.'JA.2.1 1..IX.DS!1'1S.'!l'.I!; 11112 Page 12 of 23 (,) .i:,,. ~ ~ ~ ~ (Provide at least three coplee m airline.) Slllppor NAVAJO REFINING COMPANY CIO AQUA MICROBICS ·ART~ Ii '1 . ~ ~ ~~ ~ -~ ~ ~ ~ - EPA Inspection Report - Page 1880 of 1969 t ~ : ~ ~ -~ t : ! ~ : I "Tl z :r0 0 0 0 0 (,) .i:,,. (,) 0 ~ - SMIPPER'S DECLARATION FOR DANGEROUS GOODS Air!llayblll No. f NAVAJO REFINING COMPANY ! C/0 AQUA MICROBICS i 501 EMAIN I I ARTESIA i ; NM 88210 t (Pmvlde at laait lhma copias lo airline.) rshlppor 709308590773 i'ag• 1 of 1 Pago{•! Nu'"""' /op!/onal) us Slllpper• Rofere11<• Cone!gnee FX 18 Compliant Coray Grandi!s ALS 1111 Express 10450 Slancliff Sutte210 CAFE3211 TX 77099 US r... """'f>leled Md olg,,od copi.,, of Ibis Oi!darallon muot Ile WARNING hooded lo 11"3 operator l'allura to comply with all respects with the applicable Dangerous Goods Regulations may be in AlrpOtl of o.p,rturo breach of the applicable law ,subject to legal ARTESIA penalties. CARGO AIRCRAFT ~~y_ s~:;,~::&n•• ABSGRA ~mO..U"m!om HOUSTON 1 ,d.,..,,...,.,•1'¢1coblo/ NATURE AND QUANTITY OF DANGEROUS GOODS !IN Numlleror- l'luml!m; prr,por s/Jlppm11- Classw DMskm (••~mlr!, ;,ocltlng gmup (If ""Ifllted), ••d ail olhor n,q,,/mdlnfMni!l.lon. UN 3266, Corrosive liquid, basic, inorganic, n.o.s.(Sodlum Hydroxlde),6,111 0.08 lJ/854 UN 1208, Petroleum distillates, n.o.6.,3,11111 0.04 U/366 All Packed in One FIBREBOARD BOX !·········-----···········-·--·-····-··--·-·--··-···-···--··········------·-·-···········--·---·-·················-··· Addltloool Handling lnfarmalion 24-Hou, Em•lllt1!IOY Ro•ponse- CHEMTREC f-H00-42!-e31JO, CCN 201319 i='===========·"'"""'-"""'··""·"" ·,······· .. · I h....by ...iaro !!lot !ho eonlliolo of !Iilo ••••lgnm..l •ni Mly •no [ Namem11& ol S!goatoey ... umo!y d...r!!>&d obovo by !ho proporoilippl/lg """"'•""" "'" c!~fflH11 psk&ged, marked and l!BbellooipBsCJ!lrdad~ .&Rd B.rt In all MopoMI Go-,•mmoOlill iloglllli!lo... I ,..,lam !l!ot 111 of ti\& opp!lcabl• .i, 1ro,10porl ""lu!fflmon1'1 h""• boon mo!. ; BrO!!y HubbarolErnl!ronmenlal Cooraro 1'7. l~ 1 -------11(•,o..,........... p~ Emo,;.,.,yT-N,mbor "7/AA. /j FOO l'IAlllOMrmlE MA1'ERIAl. SlllPMEMT M:CEl'TAJ!LS FOR PASSENGER AIIWAAFT, TIIE SHIPIIIENT COOTMia RA!llOI\C!IVE MATl!Rl~lNTENOoO lllaCl'DElllTTO AE!ilf!AACH,, IM!::DICAL DIAQHOSIS ~ t Q=0.1 18004249300 -: ~ -t on 'fflEATM!N'T.ADR. EUROPEAN mANS?0KTSTA1EMEHT: CARRIAGE IN ACCOR.WCE wrrn i,·u.u lO'°OS!!~S:l'J!ili HilJ' Page 13 of23 UBt IN¢~ ~ ~ ~ ~ ~ ~ - EPA Inspection Report - Page 1881 of 1969 ; u~~ of thfa~m cionstitutet yoQ'.ir .1Jernema.nt to the seNla2 cond!Uon:!l: In the un·rant FedEx Servi~ Ga.iidlS. a:v.allab!a on ~°""' <>I $100 per package, whotiler'the res"ll of lo,i, dom•e,,, fad.,.wm. FedEx will mot be responsiblo fer •nv claim io . del(ly, no~eUverv. mls.deHwry, or milSiflformatton~ uni~$$ you d:esi::l~rie I! higher vnfue. p.siy afa addit!oneI ch.a.rge, documliSnt Y""' •otool lo,s and filer, timely Seivire Guld• opply. Yoor rlg~l\o r,:i:cwerfrom · ,. fedF.x fur ijrl'd' lo:i;s1 !nelud!ng lntrin$it v.s!ua tif the pacba;e; ros:!l: of s;.a!es~ lnoome lnter~l!:t1 profit) attome·i/:sfieoo, casts., a.i:ld' othorforms o! damage wheth•rdlract, ineldon!al, con,equentlal, or,pecial i, limited to the graoterof$l00crthe eothorired det:!ared V3h,!e. Reto'lffiry ieE:Brmat Exre.ecl a!ctusl dotumt1nted los.:s, Ma!(imum for item! of extr.t'lordln!tiry V(ilh.iie ls $1;000: &.g, Jowalr;, ~ratlou, metals, eegotlable ln:s!rumeoto and oi\hor Items ll, pm~ng ihls lobol: CONSIGNEE COl'Y, PLEASE Pl.ACE i~ F~Olli OF l'OUCH 'I. F~lt:I fu!'6 pri11~~t:a µsga i!'elong the hortwnte! tlnit'!. 2. P!.8.~& m.bs:! li:1 rehlpp!ng pooi;:h w:,rJ effuf: ~ lr.i. ye~r ~h!!}m~rel ·······co>;;cc·~> m en 41 ! C) -- ·-- --; ~ .... ·&· ~ . · . · « ~~~- ' ~i fl!:~ ~ 0 f ~ ii = .... ~ = El! s=:, i i! ---~~-~~----- ''=°', ~~ f )>O 0 !is: :..:: i:5 "" i,;i, ~ iii ;;a .... "' -...i _....i )l> :c~ 8 =i :{; .tlD1~ "Tl z :r0 0 0 0 0 (,) .i:,,. (,) ...... C =i "Tl Page 14 of23 fl) fi! f! "' I ;itl - N I F "'ii I 0 ""' ::I 0 RI ffl !JM1] ~ ;;a.,,11 0 ~ X =:I"' =, i"' ~ "'"" z~ Cl) m 00~ ;o c~ "'"" z> ::z z n '.'""'I iii= i} """' ~ d ~ ~ -< ~i Q mg: !J!O ~ fl; mO """ !l:-1..., ~ llli i; -.i 3: > 0 ;;; or 0 H,_;::i:;: ffl .... ;;;;; 2l"1i: ,I 551C1i006Cl104C ...,,.., ~~i ~ii: ~ril ~~ o<>;:: ~~ m.::!!,!.,::"' -- EPA Inspection Report - Page 1882 of 1969 17-May-2019 Corey Grandits ALS Environmental 10450 Stancliff Rd Suite 210 Houston, TX 77099 Re: HS19050684 Work Order: 19050888 Dear Corey, ALS Environmental received 4 samples on 14-May-2019 09:30 AM for the analyses presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental - Holland and for only the analyses requested. Sample results are compliant with industry accepted practices and Quality Control results achieved laboratory specifications. Any exceptions are noted in the Case Narrative, or noted with qualifiers in the report or QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained from ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. The total number of pages in this report is 9. If you have any questions regarding this report, please feel free to contact me: ADDRESS: 3352 128th Avenue, Holland, Ml, USA PHONE: +1 (616) 399-6070 FAX: +1 (616) 399-6185 Sincerely, Chad Whelton Project Manager Report of Lal::mratory Analysis Certificate No; MN 026-999-449 HFNA-000003432 EPA Inspection Report - Page 1883 of 1969 ALS Group, USA Client: Project: Work Order: Date: 17-May-19 ALS Environmental HS19050684 19050888 Work Order Sample Summary Lab Samp ID Client Sample :m Matrix Jag ~um~gr &;2IIection Date Date Received 19050888-01 19050888-02 19050888-03 19050888-04 Liquid Liquid Liquid Liquid S-1 S-3 S-5 S-6 5/9/2019 09:28 5/9/2019 09:39 5/9/2019 09:06 5/9/2019 09: 12 5il4/2019 09:30 5il4/2019 09:30 5/14/2019 09:30 5/14/2019 09:30 HS19050684-01 HS l 9050684-02 HS l 9050684-03 HS 19050684-04 Page 16 of 23 (.J\.Pl HC) (API Water) (T-40) (T-41) Hold Sample Summary Page l of l HFNA-000003433 EPA Inspection Report - Page 1884 of 1969 Date: 17-May-19 ALS Group, USA Client: Project: WorkOrder: Qualifier ALS Environmental QUALIFIERS, ACRONYMS, UNITS HS19050684 19050888 DescriJJtion Value exceeds Regulatory Limit ** ·a Estimated Value Analyte is non-accredited B Analyte detected in the associated Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time Hr BODiCBOD - Sample was reset outside Hold Time, value should be considered estimated. J ND Analyte is present at an estimated concentration between the .MDL and Report Limit Not Detected at the Reporting Limit Sample amount is > 4 times amonnt spiked 0 p Dual Column results percent difference> 40% R RPD above laboratory control limit s Spike Recovery outside laboratory control limits u Analyzed but not detected above the l\,IDL X Analyte was detected in the Method Blank between the MDL and Reporting Limit, sample results may exhibit background or reagent contamination at the observed level. Acronvm Description m.JP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate LOD Limit of Detection (see MDL) LOQ Limit ofQuantitation (see PQL) IvlBLK MDL MS Method Blank Method Detection Limit Matrix Spike MSD Matrix Spike Duplicate PQL Practical Quantitation Limit RPD Relative Percenr Difl:erence TDL Target Detection Limit TNTC Too Numerous To Count A APHA Standard Methods D ASTM E EPA SW Units Reported SW-846 Update m Description none Page 17 of23 QF Page 1 of 1 HFNA-000003434 EPA Inspection Report - Page 1885 of 1969 Date: 17-May-19 ALS Group, USA Client: Project: Sample ID: Collection Date: ALS Environmental HS19050684 Work Order: 19050888 HS 19050684-02 Lab ID: 19050888-02 5/9/2019 09:39 AM Matrix: LIQUID Result Analyses Qual Report Limit SPECIFIC GRAVITY Specific Gravity Note: Units D5057-90 1.00 Dilution Factor Date Analyzed Analyst: RZM none 5/17/2019 08:35 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page l of 3 Page 18 of 23 HFNA-000003435 EPA Inspection Report - Page 1886 of 1969 Date: 17-May-19 ALS Group, USA Client: ALS Environmental Project: HS19050684 Sample ID: HS 19050684-03 \VorkOrder: 19050888 Lab ID: 19050888-03 Collection Date: 5/9/2019 09:06 A.iv!. Analyses Matrix: LIQUID Result Qual SPECIFIC GRAVITY Specific Gravity Note: Report Limit Units D5057-90 1.14 Dilution Factor Date Analyzed Analyst: RZM none 5/17/2019 08:35 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 2 of 3 Page 19 of23 HFNA-000003436 EPA Inspection Report - Page 1887 of 1969 Date: 17-May-19 ALS Group, USA Client: ALS Environmental Project: HS19050684 Sample ID: HS 19050684-04 Work Order: 19050888 Lah ID: 19050888-04 Collection Date: 5/9/2019 09: 12 Al\t1 Analyses Matrix: LIQUID Result Qual SPECIFIC GRAVITY Specific Gravity Note: Report Limit Units D5057~90 1.14 Dilution Factor Date Analyzed Analyst: RZM none 5/17/2019 08:35 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 3 of 3 Page 20 of23 HFNA-000003437 EPA Inspection Report - Page 1888 of 1969 Date: l 7-May-19 ALS Group, USA Client: Work Order: Project: ALS Environmental 19050888 QC BATCH REPORT HS19050684 Instrument ID WETCHEM Batch ID: R.260636 D5057-90 Sample ID: 19050888-02.A DUP DUP Client ID: 1-1$19050684-02 Analyte Specific Gravity Units: none Result PQL SPK Val 1.007 0 0 SPKRef Value i905088802A Analysis Date: 5117/2019 08:35 PM SeqNo: 5662483 Run ID: WETCHEM_190517A The following samples were analyzed in this batch: Note: Method: %REC 0 1905088803A 0 Prep Date: Control Limit RPO Ref Value 0-0 1.004 DF: 1 %RPD 0.318 RPO Limit Qua/ 20 19050!l!l!l04A See Qualifiers Page for a list of Qualifiers and their explanation. QC Page: 1 of 1 Page 21 of23 HFNA-000003438 EPA Inspection Report - Page 1889 of 1969 \9osrr:~iz l'll."'l$><'\-"'~~1'4<:I>:!:·•.·:.;:•~:-:,,:' ,•:·-:-:,:,•,•,:-:·.·:~~ 10450 stanel!ff Rd, Ste 210 Houston, TX 77099 T: +1 281 530 S656 F: +l 28'1 530 5887 www.alsglobal.com ALS Group USA, Corp. 3352 - 128th Ave. Phone: Holland, Ml 494249253 +:I. 616 399 6070 INVOICE INFORMATI01'•1i: CUSTOMER INFORMATION: company: ALS Houston contact: Corey Grandlts Addren: 10450 Stancliff Rd, Ste 210 Address: 10450 Stancliff Rel, Ste 210 Phone: +l Phone: +1 281 530 5656 EmaU: Alternate Corey.Gram:lits@alsgiobal,com contact: Email: 1. ALS Houston Accounts Payable 281 530 5656 Jumoke M. Lawal Reference: HS19050684 TSR: Danielle Winnings jumoke.lawal@a!sg!obai.com HS190506S4--(U. Uquld S-1 (A.PI HC) Sub Specmc Gravity to ALS Holland 2.. HS190506S4-02 3. HS190506~3 Uquid S-3 (API Water) Sub Specific Gravity to ALS Hol!an19 09:39 17 May 2019 Liquid SwS {T"'40} 09 May 2019 O!:t.Of:i 17 May 2019 Sub Specific Gravity to ALS Holland 4. 09 May 2019 09:2.S 17 May 2019 l.iqulli S"'6 rr--41) 09 Mny 20H 09:12 17 May 2019 Sub Specific Gravity to ALS Holland comments: Please analyze for the analysis fisted above. Send report to the emaf!s shown above, QC: Level: STD (Lllboratory Standard QC: method blank and LCS required) Relinquished By: Date/Time: Received Sy: Date/Time: cooler lD{s): Page 22 of23 HFNA-000003439 EPA Inspection Report - Page 1890 of 1969 ALS Group, USA Sample Receipt Checklist Client Name: A!,,$ - HOUSTON Datemme Received: 14-MaJ;19J)9:30 Work Order: 19050888 Received by: DS Checklist completed by _JI-.,. ..,, ,S'L 14-May-19 eSignature Reviewed by: Date C~,t' JcJi?~-- 14-May-19 eS!gnature Date Matrices: Carrier name: Shipping container/cooler in good condition? Yes Ell No Not Present Custody seals intact on shipping container/cooler? Yes :il No Not Present Custody seals intact on sample bottles? Yes No Not Present Chain of custody present? Yes :;;,] No Chain of custody signed when relinquished and received? Yes :;.;] No Chain of custody agrees with sample labels? Yes is{J No Samples in proper container/bottle? Yes ~ No Sample containers intact? Yes ~ No Sufficient sample volume for indicated test? Yes ~ No All samples received within holding time? Yes ~ No Container!Temp Blank temperature in compliance? Yes ~ No Yes ~ No Sample(s) received on ice? Temperature( s)/Thermometer(s ): /3.2/3.2 ~ SR2 C Cooler(s )/Kit( s ): §!14/2019 11 ;25;i;J,;;_AM Date!Time sample(s) sent to storage: Water - VOA vials have zero headspace? Yes No No VOA vials submitted Water - pH acceptable upon receipt? Yes No NIA [ii{] pH adjusted? pH adjusted by: Yes No NIA fil{I ~ 1- Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: CorrectiveAction: Page n of23 SRC Page 1 of 1 HFNA-000003440 EPA Inspection Report - Page 1891 of 1969 10450 Stancliff Rd. Suite 210 Houston, TX 77099 T: +1 281 530 5656 F: +1 281 530 5887 May 17, 2019 Gabriela Combs Navajo Refining Company PO Box 1490 Artesia, NM 88211-1490 Work Order: HS19050685 Laboratory Results for: BWON Monthly Sampling (EOl) Dear Gabriela, ALS Environmental received 9 sample(s) on May 10, 2019 for the analysis presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Results are expressed as "as received" unless otherwise noted. QC sample results for this data met EPA or laboratory specifications except as noted in the Case Narrative or as noted with qualifiers in the QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained by ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. If you have any questions regarding this report, please feel free to call me. Sincerely, Generated By; JUMOKE.LAWAL Corey Grand!ts Project Manager Right Solutions Ri9ht Partner www.aisg1obaLcom Pagel of27 HFNA-000003441 EPA Inspection Report - Page 1892 of 1969 ALS Houston, US Date: Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Work Order: HS 19050685 1Hv1ay-19 SAMPLE SUMMARY LabSamp ID Client Sample ID Matrix HS19050685-01 S-1 (API HC) HS19050685-02 Collection Date Date Received Liquid 09-May-2019 09:28 10-May-2019 09:15 S-3 (API Water) Liquid 09-May-2019 09:39 10-May-2019 09:15 ~ ~) HS 19050685-03 S-5 {T-40) Liquid 09-May-2019 09:06 10-May-2019 09:15 c::J HS 19050685-04 S-6 (T-41} Liquid 09-May-2019 09:12 10-May-2019 09:15 [:] HS19050685-05 Field Blank Water 09-May-2019 09:30 10-May-2019 09:15 HS19050685-06 EQ Blank Port 1 Waler 09-May-2019 10:03 10-May-2019 09:15 L. .,J r. . . . . . 1. 1... . . . . ..1 HS19050685-07 EQ Blank Port 2 Water 09-May-2019 10:03 10-May-201909:15 HS19050685-08 Duplicate Liquid 09-May-2019 00:00 10-May-2019 09:15 HS 19050685-09 Trip Blank Water 09-May-2019 00:00 10-May-2019 09:15 TagNo Hold ,;...._.._.._v.; ~ ::: ~ ,.._.._..,\ ~n) ,:................~ ~ ~ f. . . . . . . .l L. . . .J t. . . . . . . r. l. . . .J r. . . . . . . . ~ L. . .J Page 2 of27 HFNA-000003442 EPA Inspection Report - Page 1893 of 1969 AlS Houston, US Client: Project: Navajo Refining Company BWON Monthly Sampling {EOL) Work Order: HS19050685 Date: 17-May-19 CASE NARR.ATIVE GCMS Volatiles by Method SW8260 Batch m: R.338330 Sample ID: S-5 (T-40 S-6 {T-41)) (HS19050685-03, 04) • Surrogates failure for HS19050685-03, 04 due to sample matrix. Batch m: R338280,R338610 • The test results meet requirements of the current NELAP standards, state requirements or programs where applicable. Page 3 of27 HFNA-000003443 EPA Inspection Report - Page 1894 of 1969 A.LS Houston, US Client Project: Sample ID: Collection Date: ANALYSES Date: 17-May-19 RESULT QUAL VOLATILES BY SWS260C Benzene ANALYTICAl REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-1 (API HC) 09-May-2019 09:28 220 MDL Method:SWS260 2.4 WorkOrder: HS 19050685 Lab !D:HS19050685-01 Matrix:Uquid REPORT LIMIT UNITS 24 mg/Kg DILUTION FACTOR DATE ANALYZED Analyst: WLR 5000 14-May-2019 11 :56 Surr: 1, 2-Dichforoethane-d4 94.4 70-1213 %REC 5000 14-May-2019 11:58 Surr: 4-Bromofluorobenzene 95.1 70-130 %REC 5000 14-May-2019 11:58 Surr: Dibromofluoromethane 92.9 70-130 %REC 5000 14-May-2019 11:56 Surr: Toluene-dB 97.6 70-130 %REC 5000 14-May-2019 11:56 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 4 of27 HFNA-000003444 EPA Inspection Report - Page 1895 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 17-May-19 ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling {EOl) WorkOrder:HS 19050685 lab !D:HS19050685-02 S-3 (AP! Water) 09-May-2019 09:39 RESULT QUAL Matrix:Liquid MDL REPORT LIMIT UNITS DILUTION DATE FACTOR ANALYZED ................................ i'ifOLATILES • SW8260C Method:SWS260 1.3 Benzene 0.030 Analyst: PC 0.25 Surr: 1,2-Dichforoethane-d4 84.6 70-126 Surr: 4-Bromofluorobenzene 97.5 82-124 Surr: Dibromofluoromethane 87.2 77-123 106 82-127 Surr: Toluene-dB mg/L 50 17-May-2019 07:19 %REC %REC %REC %REC 50 17-May-2019 07:19 50 17-May-2019 07:19 50 17-May-2019 07:19 50 17-May-2019 07:19 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 5 of27 HFNA-000003445 EPA Inspection Report - Page 1896 of 1969 ALS Houston, US Client Date: 17-May-19 Project: Sample !D: Navajo Refining Company BWON Monthly Sampling (EOL) S-5 (T-40) Collection Date: 09-May-2019 09:06 ANALYSES RESULT QUAL ANALYTICAL REPORT WorkOrder:HS 19050685 Lab ID:HS19050685-03 Matrix:Uquid MDL REPORT LIMIT UNITS DILUTION DATE FACTOR ANALYZED ••••••••••••••••••••••••••••••••••••••••••••••••••••••···••ss•ss------ ,VOLATILES BY SWS260C Benzene Method:SW8260 0.26 0.025 Analyst: WLR Surr: 1, 2-Dichforoethane-d4 96.4 70-1215 %REC Surr: 4-Bromofluorobenzene 105 70-130 %REC 50 50 50 70-130 %REC 50 14-May-2019 10:41 70-130 %REC 50 14-May-2019 10:41 Surr: Dibromofluoromethane 66.2 Surr: Toluene-dB 99.3 s 0.25 mg/Kg 14-May-2019 10:41 14-May-2019 10:41 14-May-2019 10:41 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 6 of27 HFNA-000003446 EPA Inspection Report - Page 1897 of 1969 A.LS Houston, US Client Project: Sample ID: Collection Date: ANALYSES Date: 17-May-19 ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) WorkOrder:HS 19050685 S-6 (T-41) 09-May-2019 09:12 RESULT QUAL :vrn.ATllES BY SW8260C Lab ID:HS19050685-04 Matrix:Uquid MDL REPORT LIMIT UNITS DILUTION FACTOR 0.24 mg/Kg 50 14-May-2019 11 :06 70-126 %REC 50 14-May-2019 11:06 Method:SW8260 Benzene < 0.024 Surr: 1, 2-Dich!oroethane-d4 96.1 Surr: 4-Bromofluorobenzene 101 Surr: Dibromofluoromethane 69.5 Surr: Toluene-dB 98.1 0.024 s DATE ANALYZED Analyst: WLR 70-130 %REC 50 14-May-2019 11:06 70-130 %REC 50 14-May-2019 11:06 70-130 %REC 50 14-May-2019 11:06 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 7 of27 HFNA-00000344 7 EPA Inspection Report - Page 1898 of 1969 A.LS Houston, US Date: 17-May-19 ANALYTICAL REPORT Client Navajo Refining Company Project: Sample ID: CoHection Date: BWON Monthly Sampling (EOL) ANALYSES Lab !D:HS19050685-05 09-May-2019 09:30 Matrix:Water RESULT QUAL VOLATILES· $WS2GOC Benzene Work Order: HS 19050685 Field Blank: MDL REPORT LIMIT UNITS DILUTION FACTOR Analyst: PC l\liethod:SW3260 < 0.00060 0.00060 DATE ANALYZED 0.0050 mg/L 12-May-2019 22:46 Surr: 1, 2-Dich!oroethane-d4 96.4 70-126 %REC 1 12-May-2019 22:46 Surr: 4-Bromofluorobenzene 96.4 82-124 %REC 1 12-May-2019 22:46 Surr: Dibromofluoromethane 97.7 77-123 %REC 105 82-127 %REC Surr: Toluene-dB 12-May-2019 22:46 1 12-May-2019 22:46 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 8 of27 HFNA-000003448 EPA Inspection Report - Page 1899 of 1969 A.LS Hcn.1stcm, IJS CHent: Date: 17-May-19 ANALYTICAL REPORT Navajo Refining Company Project BWON Monthly Sampling (EOL) Sample ID: EQ Blank Port 1 Lab ID:HS19050685-06 Collection Date: 09-May-2019 10:03 Matrix:Water ANALYSES RESULT QUAL MDL WorkOrder:HS 19050685 REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED •••••••••••••••••••••••••••••••••••••••ss,••ssssssssss,•••••••••••ss••• :VCII.ATILES • SWl.!250C Benzene < 0.00060 Method:SW8260 0.00060 Analyst: PC 0.0050 mg/L 12-May-2019 23:10 Surr: 1, 2-Dich/oroethane-d4 95.0 70-126 %REC 1 12-May-2019 23:10 Surr: 4-Bromofluorobenzene 99.8 82-124 %REC 1 12-May-2019 23:10 Surr: Dibromof/uoromethane 94.8 77-123 %REC 1 12-May-2019 23:10 104 82-127 %REC 1 12-May-2019 23:10 Surr: Toluene-dB Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 9 of27 HFNA-000003449 EPA Inspection Report - Page 1900 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 17-May-19 ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) EQ Blank Port 2 09-May-2019 10:03 RESULT QUAL MDL WorkOrder:HS 19050685 Lab ID:HS 19050685-07 Matrix:Water REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED -~-----------------············································· ·············-------------------- Method:SW8260 :VoLATILES - SW8260C Benzene < 0.00060 0.00060 Analyst: PC 0.0050 mg/L %REC 12-May-2019 23:34 Surr: 1,2-Dichloroethane-d4 97.8 70-126 Surr: 4-Bromofluorobenzene 101 82-124 %REC 1 12-May-2019 23:34 Surr: Dibromofluoromethane 98, 1 77-123 %REC 1 12-May-2019 23:34 101 82-127 %REC 1 12-May-2019 23:34 Surr: Toluene-dB 1 12-May-2019 23:34 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 10 of27 HFNA-000003450 EPA Inspection Report - Page 1901 of 1969 ALS Houston, US Client: Project: Sample ID: Collection Date: ANALYSES Date: 17-May-19 ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) Duplicate 09-May-2019 00:00 RESULT QUAL -----------····················"""""""""""" MDL WorkOrder: HS 19050685 lab ID:HS19050685-08 Matrix:liquid REPORT LIMIT UNITS DILUTION FACTOR ··········································································~------------~ VOLATILES - SWS260C DATE ANALYZED •••••••••••••ss•••••ssssss• Analyst: PC 1.4 Benzene 0.030 0.25 mg/L 50 17-May-2019 07:43 Surr: 1, 2-Dichloroethane-d4 84.6 70-126 %REC 50 17-May-2019 07:43 Surr: 4-Bromofluorobenzene 100 82-124 %REC 50 17-May-2019 07:43 Surr: Dibromofluoromethane 87.3 77-123 %REC 50 17-May-2019 07:43 103 82-127 %REC 50 17-May-2019 07:43 Surr: Toluene-dB Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 11 of27 HFNA-000003451 EPA Inspection Report - Page 1902 of 1969 ALS Houston, US Date: 17-May-19 Client: Project: Sample ID: Navajo Refining Company BWON Monthly Sampling (EOl) Trip Blank Collection Date: 09-May-2019 00:00 ANALYSES ANALYTICAL REPORT WorkOrder:HS 19050685 Lab ID:HS19050685-09 Matrix:Water DILUTION REPORT RESULT QUAL MOL UNITS FACTOR LIMIT --------------------------------------------------------------------"-" ""·------------------- DATE ANALYZED ••••••••••••••••ssssssss•• MOL.ATILES • SW8260C Benzene Method:SWS260 < 0.00060 0.00060 Analyst; PC 0.0050 mg/L 1 12-May-2019 22:21 Surr: 1,2-Dichforoethane-d4 96.3 70-126 %REC 1 12-May-2019 22:21 Surr: 4-Bromofluorobenzene 99.5 82-124 %REC 1 12-May-2019 22:21 Surr: Dibromof/uoromethane 97.6 77-123 %REC 1 12-May-2019 22:21 Surr: Toluene-dB 99.8 82-127 %REC 1 12-May-2019 22:21 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 12 of27 HFNA-000003452 EPA Inspection Report - Page 1903 of 1969 AlS Houston, US Date: 17-May-19 WEIGHT LOG Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) WorkOrder: HS 19050685 - - - Batch ID: 3060 SamplD --- Method: Container HS 19050685-01 HS 19050685-03 HS 19050685-04 VOLATILES BY SW8260C Sample WtNol Final Volume Weight Factor 5.267 (g} 4.973 (g) 5.115 (g) 5(mL) 5 (ml) 5 (ml) 0.95 i .01 0.98 Container Type Bulk (5030B) Bulk (5030B) Bulk (5030B) Page 13 of27 .····· ..·,····py.,,··,····,.· ·:·.·....·.·.··.·.........·.·.·.·.·.·,·.·.·.w.·.·.» HFNA-000003453 EPA Inspection Report - Page 1904 of 1969 ALS Houston, US Dale: 17-May-19 Navajo Refining Company BWON Monthly Sampling (EOL) Client: Project: WorkOrc!er: Client Samp ID Sample ID ------"""'"""""'"'"'""' $atch ID DATES REPORT HS19050685 R.338280 Collection Date TCLP Date Analysis Date Prep Date .. ,,,,,,,,,,,,v ...... •••••••••••·,~· .. ••••••••••••••••••••~ss.....,.••••,••.,.,.,.,.,.,_,~~"" Test Name: VOLATILES• SW8260C ·--.~~~~~~~~-~~~~~~- Matrix: Water HS19050685-05 Field Blank 09 May 2019 09:30 12 May 2019 22:46 HS19050685-06 EQ Blank Port 1 09 May 2019 10:03 12 May 2019 23:10 HS19050685-07 EQ Blank Port 2 09 May 2019 10:03 12 May 2019 23:34 HS19050685-09 Trip Blank 09 May 2019 00:00 12 May 2019 22:21 Sate!"! IO R.338330 Test Name : VOLJ.TILES BY SW8260C DF Matrix: Liquid HS19050685-01 S-1 (API HC} 09 May 2019 09:28 14 May 2019 11 :56 5000 HS19050685-03 S-5 (T-40) 09 May 2019 09:06 14 May 2019 10:41 50 HS 19050685-04 S-6 (T-41 ) 09 May 2019 09:12 14 May 2019 11:06 50 Batch ID R338610 Test Name; VOLATILES- SW8260C Matrix: Liquid HS19050685-02 S-3 (AP! Water) 09 May 2019 09:39 17 May 2019 07:19 50 HS 19050685-08 Duplicate 09 May 2019 00:00 17 May 2019 07:43 50 Page 14 of27 HFNA-000003454 EPA Inspection Report - Page 1905 of 1969 A.LS Houston, US Client: Project: WorkOrder: Batch U): Date: 17-May-19 Navajo Refining Company BWON Monthly Sampling (EOL) HS19050685 R,338280 ( O ) MBLK QC BATCH REPORT Sample ID: fnstru ment: Run ID: Result Analysis Date: 12-May-2019 14:39 SeqNo: 5071924 VOA6_338280 PQL SPKVal SPK Ref Value PrepDate: Control Limit %REC Surr: 1, 2-Dichloroethane-d4 48.02 0 50 0 96.0 70- 130 Surr: 4-Bromofluorobenzene 49.22 0 50 0 98.4 82 - 115 Surr: Dibromofluoromethane 48.48 0 50 0 97.0 73 - 126 Surr: Toluene-dB 49.76 0 50 () 99.5 81 - 120 LCS Sample ID: Units: ug/L VLCSW-190512 Client ID: Run ID: Analyte DF: 1 RPD Ref RPD Value %RPO Limit Qual 5.0 < 0.60 Benzene Method: VOLATILES• SW8260C Units: ug/L VBLKW-190512 Client ID: Analyte VOA6 Result VOA6_338280 Analysis Date: SeqNo:5071923 PrepDale: PQL SPKVal SPK Ref Value %REC Control Limit Benzene 17.76 5.0 20 0 88.8 74 - 120 Surr: 1, 2-Dichloroethane-d4 48.89 0 50 () 97.8 70 - 130 Surr: 4-Bromofluorobenzene 49.57 0 50 0 99.1 82- 115 Surr: Dibromofluoromethane 48.89 0 50 () 97.8 73 • 126 Surr: Toluene-dB 51.61 0 103 81 - 120 0 50 12-May-2019 13:51 DF: 1 RPD Ref RPD Value %RPD limit Qual \ I MS Sample ID: l Client ID: Il Analyte Benzene Units: ug/L HS19!l50571-01 MS Run ID: Result 21.7 VOA6_338280 Analysis Date: 12-May-2019 15:52 SeqNo: 5071927 PQL SPKVal SPK Ref Value 5.0 20 0 50 0 Surr: 4-Bromofluorobenzene 49.32 0 Surr: Dibromofluoromethane 49.2 0 50 50.74 0 50 PrepDale: %REC Control Limit 108 70 - 127 98.6 82- 124 DF: 1 RPD Ref RPD Value %RPD Limit Qual --~--"'"~''"''' Surr: Toluene-dB 0 98.4 77 - 123 101 82- 127 Page 15 of27 HFNA-000003455 EPA Inspection Report - Page 1906 of 1969 A.LS Houston, US Client: Project: WorkOrder: Batch II); Date: 17-May-19 Navajo Refining Company BWON Monthly Sampling (EOL) HS19050685 R33S2S0 ( 0 ) MSD Sample ID: Instrument: Analyte VOA6 HS19050571-01MSD Client ID: Run ID: Result QC BATCH REPORT Method: VOLATILES• SW8260C Units: ug/L VOA.6_338280 Analysis Date: 12-May-2019 16:16 SeqNo: 5071928 PQL SPK Val SPK Ref Value PrepDate: %REC Control Limit 99.8 70 - 127 DF: 1 RPD Ref RPD Value %RPD limit Qual Benzene 19.95 5.0 20 0 Surr: 1,2-Dich/oroethane-d4 50.56 0 50 0 101 70- 126 49.23 2.66 20 Surr: 4-Bromofluorobenzene 50.63 0 50 0 101 82- 124 49.32 2.62 20 Surr: Dibromofluoromethane 49.94 0 50 0 99.9 77 - 123 49.2 1.48 20 Surr: Toluene-dB 50.87 0 50 0 102 82- 127 50.74 0.251 20 The following samples were analyzed in thi.s batch; ........................• '"-----"---"" 21.7 8.39 20 rlS190506.~5.~°.5. . . . . . . . . . ~~.1.9. °.5.?.~.8.5. ~.°.~. . . . . . . . . . 1.·~~~-9(1=-°-~~-5.=°--7--- ~===°-=~-6-~==°-9 . . . . . . . . . . . . . . . . . "I Page 16 of27 HFNA-000003456 EPA Inspection Report - Page 1907 of 1969 AUS Houston, US Client: Project: Work:Order: Date: 17-May-19 Navajo Refining Company BWON Monthly Sampling (EOL) QC BATCH REPORT HS19050685 Method: VOLATILES BY SW8260C MBLK Sample ID: MBLKW1-051419 Run ID: Client ID: Analyte Result Benzene Units: ug/Kg VOAS_33S330 PQL <25 250 2340 0 Analysis Date: 14-May-2019 09:51 SeqNo: 5073455 PrepDate: SPK Val SPK Ref Value %REC Control Limit 2500 0 93.6 80-120 OF: SO RPO Ref RPD Value %RPO Limit Qual Surr: 1, 2-Dichloroethane-d4 Surr: 4-Bromofluorobenzene - ---- ................................................................................... .. Surr: Dibromofluoromethene 2228 0 2500 0 mu 8a - 119 Surr: Toluene-dB 2444 0 25{){) 0 97.8 81 - 118 _______ ·------------------------- -----------------l "" . LCS Sample ID: VLCSW1-051419 Client ID: Run ID: Analyte Result Units: ug/Kg VOA8_338330 PQL Analysis Date: 14-May-2019 09:01 SeqNo: 5073454 PrepDate: SPK Val SPK Ref Value %REC Control Limit Benzene 49.05 5.0 50 0 98.1 75- 124 Surr: 1,2-Dichloroethane-d4 51.09 0 5{) 0 102 76 - 125 Surr: 4-Bromofluorobenzene 51.86 0 50 0 104 80-120 Surr: Dibromof/uoromelhane 52.3 0 50 0 103 81-118 51.53 Surr: Toluene-dB MS Sample ID: HS19050546-02MS Run ID: Client ID: Analyte Benzene Result 26660 Units: ug/Kg VOA8_338330 DF: 1 · I RPD Ref RPD , . Value %RPD Limit ~ Analysis Date: 14-May-2019 13:11 SeqNo: 5074002 PQL SPK Val SPK Ref Value 2400 24000 0 PrepDate: %REC Control Limit 111 70 -130 Surr: 1,2-Dich/oroethane-d4 23380 0 24000 0 97.4 70-126 Surr: 4-Bromofluorobenz:ene 23430 0 24000 0 97.6 70- 130 Surr: Dibromofluoromethane 23660 0 2400{) 0 98.6 70- 130 Surr: Toluene-dB 23760 0 24000 0 99.0 70- 130 OF: 500 RPD Ref RPO Value %RPD Limit Qual Page 17 of27 HFNA-000003457 EPA Inspection Report - Page 1908 of 1969 AlS Houston, US Client: Project: WorkOrder: Batch ID: Date: 17-May-19 Navajo Refining Company BWON Monthly Sampling (EOL) HS19050685 R338330 ( 0 ) MSD Sample ID: Instrument: Method: VOLATILES BY SWS260C HS19050S46·02MSD Client ID: Analyte QC BATCH REPORT Units: ug!Kg Run ID: Result VOA8_338330 PQL SPKVal Analysis Date: 14-May-2019 13:37 SeqNo: 5074003 PrepDate: DF: 500 SPKRef Value %REC Control Limit 0 98.6 70 - 130 100 70- 126 23380 2.77 30 101 70- 130 23430 2.94 30 RPO Ref RPD Value %RPD limit Qual Benzene 23660 2400 24000 Surr: 1, 2-Dichloroethane-d4 24040 0 24000 Surr: 4-Bromofluorobenzene 24130 0 24000 0 Surr: Dibromofluoromethane 24250 0 24000 0 101 70 - 130 23660 2AfJ 30 Surr: Toluene-dB 24110 0 24000 0 100 70- 130 23760 1.45 30 The following samples were analyzed in this batch: ?IS19050685-0l .......... HS 19050685-03""""" i:i ···········································"--"--- 26660 11.9 30 HS J 9050685-04 ••••••••••••••••cccccccccc _ _ _ _ _ _ _ _ _ _ _ _ ,,,,,,,, ••••••••••••••••••••••••••••••••••• ••••••··•·•-- ······"•"•"•"•"•"•"•"•""""'""·' Page 18 of27 HFNA-000003458 EPA Inspection Report - Page 1909 of 1969 AlS Houston, US Client: Project: Work:Order: Batch ID: Date: 17-May-19 Navajo Refining Company BWON Monthly Sampling {EOL) HS19050685 R338610 ( 0 ) MBLK Sample ID: Instrument: Method: VOLATILES· SW8260C Units: ug/l Run ID: Analyte VOA.6 VBLKW-190516 Client lD: QC BATCH REPORT VOA.6_338610 PQL Result Analysis Date: 16-May-2019 22:53 SeqNo: 5078851 SPKVal SPK Ref Value %REC PrepDate: Control Limit < 0.60 5.0 Surr: 1, 2-Dich/oroethane-d4 42.12 0 50 0 84.2 70- 130 Surr: 4-Bromof/uorobenzene 50.32 0 50 0 101 82-115 Surr: Toluene-dB 52.26 0 50 D 105 81 .. 120 Benzene lCS Sample ID: VLCSW-190516 Client ID: Units: ug/l Run ID: VOA6_338610 Analysis Date: 16-May-2019 22:05 SeqNo: 5078850 SPK Ref Value PrepDate: RPD Ref %REC Limit Value SPKVal 19.29 5.0 20 0 96.5 74 • 120 50.8 0 50 0 102 70-130 Surr: 4-Bromofluorobenzene 52.72 0 50 0 105 82 - 115 Surr: Dibromofluoromethane 51.71 0 50 0 103 49.9 0 50 0 99.8 Benzene surr:·1:2}jfcii1oroeifiane~it4···· Surr: Toluene-dB II MS Sample ID: HS19050590-02MS Client ID: Run ID: Units: ug/l VOA.6_338610 Result SeqNo: 5078853 PQL SPKVal 20 16.6 5.0 Surr: 1, 2-Dichloroethane-d4 43.32 0 50 Surr: 4-Bromofluorobenzene 50.55 0 50 Benzene Value 0 ························o··· 0 Surr: Dibromof/uoromethane Surr: Toluene-dB 52.03 0 50 RPD %RPO Limit Qual 81 - 120 Analysis Date: 17-May-2019 02:06 SPK Ref I Analyte ! DF: 1 Control PQL Result Analyte DF: 1 RPD Ref RPD Value %RPO Limit Qual 0 PrepDate: %REC Control Limit 83.0 70 - 127 86.6 70- 126 101 82- 124 90.8 77- 123 104 82- 127 DF: 1 RPO Ref RPD Value %RPD Limit Qual Page 19 of27 HFNA-000003459 EPA Inspection Report - Page 1910 of 1969 A.LS Houston, US Date: 17-May-19 Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) Work:Order: HS19050685 Batch ID: R338610 ( 0) MSD Sample ID: Analyte VOA6 Instrument: HS19050590·02MSD Client ID: Run ID: Result QC BATCH REPORT Method: VOLATILE$ • SW8260C Units: ug/l VOA.6_338610 Analysis Date: 17-May-2019 02:30 SeqNo: 5078854 PQL SPKVal SPK Ref Value 2D 0 Control %REC Limit 82.3 70 - 127 16.45 5.0 Surr: 1, 2-Dichloroethane-d4 43.24 0 50 0 86.5 Surr: 4-Bromofluorobenzene 49.41 0 50 0 98.8 Surr: Dibromoffuoromethane 44.68 0 89.4 Surr: Toluene-dB 51.67 0 103 Benzene The following samples were analyzed in this batch: }JS19050685-02 50 HS 19050685-08 0 PrepDate: DF: 1 RPD Ref RPD Value %RPO Limit Qual 16.6 0.864 20 70-126 43.32 0.172 20 82- 124 50.55 2.27 20 77- 123 45.38 1.56 20 82- 127 52.03 0.7 20 ·----------- .......................................... 1............................................. Page 20 of27 HFNA-000003460 EPA Inspection Report - Page 1911 of 1969 ALS Houston, LIS Client: Project: WorkOrder: Date: 17-May-19 Navajo Refining Company BWON Monthly Sampling (EOL) QUALIFIERS, ACRONYMS, UNITS HS19050685 Qualifier ........................Description.. Value exceeds Regulatory Limit a Not accredited B Analyte detected in the associated Method Blank above the Reporting limit E Value above quantitation range H Analyzed outside of Holding Time J Analyte detected below quantitation limit M Manually integrated, see raw data for justification n Not offered for accreditation ND Not Detected at the Reporting limit 0 Sample amount is > 4 times amount spiked P Dual Column results percent difference > 40% R RPD above laboratory control limit S Spike Recovery outside laboratory control limits U Analyzed but not detected above the MDUSDL Acronym Description DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion limit SD Serial Dilution SDL Sample Detection Limit TRRP Texas Risk Reduction Program Unit Reported Description mg/Kg Milligrams per Kilogram mg/L Milligrams per Liter Page 2I of27 HFNA-000003461 EPA Inspection Report - Page 1912 of 1969 AlS Houston, US Date: 17-May-19 CERTIFICATIONS,ACCREDITATIONS & LICENSES Agency Number Expire Date • I··········'""'"'··········································································································· ············"'"'"'···················-+---------+----- ....................................; Illinois 004438 29-Jun-2019 03087 , 30-Jun-2019 i20-Dec-2021 ······························"'-~-------""~"''""""' ••••••••·•••••••··••••·································••••···· E-10352 2018-2019 31-Jul-2019 •••••••••••••••••••••cccccccc•+ccccccc _ _ _ _ _ _ __ Oklahoma 20'!8-156 North Carolina 624•2019 131-Aug-2019 ••••••••••••••••••••••••••••c•f-ccccc••-------- »••••••---••---••••••••---••• ••••••••••••••••• Maryland ••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••ssssss---- Arkansas 1 ···..··.·.·..··.·.·..··.·.·..··.·.·..··.·.·..··.·.·..··.·.·..··.·.·.·.... ::::::::::::::··:::::::::::::::::::::::::::::::::··::::::::.••..-.•••-••.. 343, 2018-2019 : 31-Dec-2019 • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • . { • • • • • • • = c c c c c c c_ _ _ _ _ _ _ _ , i30-Jun-2019 •••••••••••••••••••••••••••••••{ i27-Mar-2020 -.-------~-----;~~~~~!~~~~~-=:.:=2-.3-__:::::··::::::::]~o=A;;;~2020·:::::::::::::::::::::::: ... 19-028-0 _j Page 22 of27 HFNA-000003462 EPA Inspection Report - Page 1913 of 1969 ALS Houston, US Date: 17-May-19 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: 10-l\/lat-2019 09:1@ Work Order: HS19050685 Received by: .!BM Checklist completed by: Reviewed by: Raegen_ Giga _______________________,,____,,__ ~-O-Mav-2019 eSignature Corey Grandits Date 13-Mav-2019 --· Date eSignature Matrices: Carrier name: Shipping container/cooler in good condition? Custody seals intact on shipping container/cooler? Yes Yes Custody seals intact on sample bottles? Yes :;:.-..-...........'-: l~i ::.. -:: ............... T. . . .l ~ 1 ::.. ::: No D Not Present Not Present ~..................l:i VONTX1005/TX1006 Solids in hermetically sealed vials? Yes Chain of custody present? Yes Chain of custody signed when relinquished and received? Yes Samplers name present on COC? Yes Chain of custody agrees with sample labels? Yes Samples in proper container/bottle? Yes Sample containers intact? Yes Sufficient sample volume for indicated test? Yes All samples received within holding time? Yes Yes Container/Temp Blank temperature in compliance? Temperature(s)/Thermometer(s): r»........1..J Not Present ............... No[] Not Present ['i::] IR11 1.2c Cooler(s)/Kit(s): Foam Date/Time sample(s) sent to storage: i::i5/10/2019 19:30 Water - VOA vials have zero headspace? ·r _______ )i ............ ~~~··~~~~~~~~~~~- ~ ··········--------------------------4 No VOA vials submitted Water· pH acceptable upon receipt? N/A pH adjusted? NIA r"1 r"1-:: §..................~ ~............... pH adjusted by: login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 23 of27 HFNA-000003463 EPA Inspection Report - Page 1914 of 1969 Chain of Custody Form Page _1_ of --1_ 0 CincinMti, OH +I 513 733 5335 o 0 fverBtt, WA +1 425 3S6 2600 + I 616 399 5070 0 Hou,ton, TX D Fort Col/Ins, CO +I 970 49/J 1511 Enulronm entat @ill~~·········~:······~1·•·•t;!7;:.aw~~.~~·-"•= , ~·-- -- l l~lt~it~~·~....... N-M-8-82_1_1_-0_1_59·-----;:~{~)-i}~tf~i~ifi~ Artesia, New Mexico 88210 .#J1 ! %~::::~ : ~8~~0- ························· = .......·.....··~·("1ij7~31. +12815305656 Middletown, PA +I 717 944 5S41 O Salt Lake City, UT D Spring Oty, PA D York.PA 1:1 · :1; ··" - 1111111111 i ---+""'*- -------- ~:~~::~::::~~:~::}:::q?)jf[_ 1 :/f)S·!i (T-40) ,~c7c·t· ··----.--- ------- <~\1S·6 (T-41) 1 nk \f ::[EQ Blank Port 1 1 X 1 X /i::<:!EC Blank PorU X ·~:--. -;*';: rv-•,.0.:-· ::]/! Duplicate X : ] / Trip Blank 05/09119 }i~i: Temperature Blank 05/09119 8,1 X 2 quired Turnaround Time: STD 10 Wk Days l"2J 5 Wk Days 0241-!our Reilnqulsood II: Std QC + Raw Data V: SW846 CLP-Like I "Tl z :r0 0 0 0 0 (,) .i:,,. 0) .i:,,. +I 717 505 5280 BWON Monthly Sampling (EOL) ------- ------ :-:-:-:,:-:-:-:-:,:-·,·.·.·.·.·.·.·.·.·.·.·,· +I f.i!O 948 4903 HS19050685 -:-:-~.;,:-r.,. .. ,,. ... , HC) :rr:1:t?,,rrm~ + I 801 256 '1700 Navajo Refining Company P.O. Box 159, ~r!-e_s_!a-, Holland, Ml D Note: Any changes mm.t be made In writing once samples and cm:; form hW.'& tmmi l!l\ll)mltredtu AL"!i L.iJlrofl1• on redeicrom. FedElr will not bo ,e,pon,lble for anv claim in""""" of $100 po, ;,aokoll'!, whethorth• =•It of la,., dom&f"', delay, ooo-dollvory, ml,dolivery, "' ml•lnft>rmatloo, onle,so you deelore • higher value, poy M odditlooal ci>o,10, docomeot you, actual lo" and file• !lmcly clalm. limltatioosfoood In th" corroot fodEx Se1•i m i\ en ,,;;;,,,4G> !I!!!! r;,~:::c ~ """' !!!!, ~ ~1 ::! E! :§ ~I§ ~i .... ;;;;;; ,, Ii 2!:! ,,:~ 2!' ~ .... ..., ii :J ~ im>ii: ii ;il,i l ll8'11'lmlllllw "Tl z :r0 0 0 0 0 (,) .i:,,. 0) 01 j!!: oo :;g, »i!°i 5 z z ;;! ::;I p :;; 'Tl ..... 0):,, 0 w ~© Page 25 of27 oL!~ i ;· fl =i (II) ... , s~~ ,, ~ Sil i . I ,,l 'I -<, ...,, ~ _ ei ),o~i!; ~ .;;;i :::Cw c, t:iO "'C:: -I 11'11 ... ;~; ; Im~ ~m-00I Qj -<: rn~ lij., li ~ ~ "1:1 = I - Cl> :i!: u:::, ;;; I iloj m ' "' =? -., 001. . 8a1i~~ fijj el .. ~ ~Isl I I ii 1 l 5'.i1CliOOlC1104C EPA Inspection Report - Page 1916 of 1969 ~ ~ -~ ~ ~ --' ~ -~ ~ I "Tl z :r0 0 0 0 0 (,) .i:,,. 0) 0) ~ ~ ~ -- SHIPPER'S DECLARATION FOR DANGEROUS GOOPS ARTESIA Air W•ybl» llo. 709308590773 Pall$ 1 of 1 Page{SI Shipp.,... Rofereo"' Nomlmr foptlonal) NM88210 US c....1g... FX 18 Compliant CoreyGrarsdils ALS 10450 S!!!m;iiff Sul!e.210 HOUSTON ~ t {Provide ot leaot throe cople$ b:i airline.) Sl>lppor NAVAJO REFINING COMPANY C/0 AOU/1 MICROBICS 501 EMAIN ® Express CAFE3211 TX 77099 US WARNING CO#Dplll!lfb1d and slg.naf.l copl'&S ii,frhls DeeJm116'ioo must be ham:l«t to the ope.mtOr Failure to comply with all respects with tile TAA~Sl'ORT DETAILS Thl:!li .shipment!:& within thu llmltalloos P'""•rlbod for. applicable Dangerous Goods Regulations may be in breach ofthe applicable law ,subject to legal penalties. All)'ort of Dopa,turo ARTESIA !do!ot• ••• oppl!o>ble) Al'J>O'l ol llostln•tion: HOUSTON P:E!SGRA NATURE AND QUANTITY OF DANGEROUS GOODS ur; ll•mb•nnldMffllcol/001\1111111>,.,; P"'l""sll/pp/119 "1qll/ra,//nfonmal/M. "'""°' Cl..., orllMofon {••bsi...-Yrlsi\l, p..lrJltfJ-(/f "1qlll,od,), ••doll othor UN 3266, Corrosive liquid, basic, inorganic, n.o.s,(Sodium Hydrnxide),8,111 0.08 lJ/854 UN 1268, Petroleum distillates, n.g.s.,3,11111 0.04 L/1366 All Pac:ked In One FIBREBOARD BOX Q = 0.1 -~ ~ ~ ~ ~ t t --·-··············-···········-----·-----······----------------··---·-···--------------------------------·-·-···_J Addillorral HaNdl!ng lnfom,a!lan 24-Hoor Ernergor,oy R..pooso- CHEMTREC 1-000424-9300, CCN 201319 I horooy d..loM thol ll!o ooolomo ofilllo ..,,..1gnmen! •ro fully ond I Nome/Tillo of Slg~alo!)I •=ra!o!y d..e,11,00 •l>ov• by Ill• pmp•• oh!pplog aome, ood ""'1 I Brody Hubl>Jm/Em.ironmenlal Cooro!notor ~ ~1;,":":r'!::':':r!':'i!'ni:~~=:·:":P::~h: I Place and Date anmmauonm and Natkmal Gcvt1mmental Reg&.1!Qtlons. I dechrim ttiat !Mesta, NM Iii of the appficaabl& air tramspDrt naqul'mmenti& hwa tffl!lln ml:t 051091.2019 J r Signohlm '"1_00_04_2_"9_30_0_______""'-._--,-y-r.,..-.--H-•m-bo-,"' ... "'i ,... .,..~-~ Brody Hul>bard $~ ~ ro~ R.IWSOACTNE MA'rl!RIAP.. SHlfflENT ACCBSPTABI.! FOR PMSEtdGEra ruRCMFr, THE SHIPN!!Nt OONTAU11$ R.AOIMC'mf5 MA'fi:fflALIHffl9UHED mR ua:e: BN OR ~!De~Tm Rle:SEARCH,~Dl!CAi. Pm.Gli0$!$ QR TRS:AtMENT. ADR. EUROP&Al!ll Tit!Ui1SPOR'tSTA11fMSf:ffr: CQIIUM3E IN AtCCRDAMi:'=WE'ffl 1.u.a:.1 LICl>!.iJ~!'t!:in~s iuu: Page 26 of27 ~ ~ :: EPA Inspection Report - Page 1917 of 1969 ~ ~ ~ ~ -~ ~ ~ ~ ~ ~ ~ ~ I "Tl z :r0 0 0 0 0 (,) .i:,,. 0) -..,J - W(;.OS $tS)';t~'J !Pmvid<> at least three copies lo airline.I SHIPPER'S DECLARATIO!\I FOR DANGEROUS GOODS Shlppor NAVAJO REFINING COMPANY C/0 AQUA MICROBiCS 501 EMAIN j lllrW"Yhlllllo. 709308590773 1 Page 1 of 1 Page{s) ARTESIA {Shlppef"s: RaferancQ Number NM88210 US (OJ!l/a••Q Co,,ofgo.. FX 18 Compliant CoreyGrnndlts ALS 1Q450Smns:liff Suilo210 HOUSTON ® Express TX noog CAFE3211 us 1Wl!!l .co.mpleusd and s(.Qn&d mples of fir~ Dm:lamfion must iOO handed to tho ope!1Slor WARNING TRANSPORT DETAILS Failure to comply witll all respects with tho applleab!e Dangerous Goods Regulatlona may be in breach of tho applicable law ,subject to legal penalties. Toils: &hlpmBnt 1, within ths llml!.1tl<>ns P""'Orlbod for: Affport of Dapartum ARTESIA (dololo non •pplloablo) CMGO AIMM!'T Q~LY .<"i,<>«. of D°"linotloo: HOUSTON ABSGRA NATURE AND QUANTITY OF DANGEROUS GOODS UN Number or ldontlflcafll>n /lumber, pmJl!Ir&' 1'.'qUlmo'lnfomR1ffon. UN 3266, Corrosive liquid, basic, iJ)organic, n.o.s.(Sodlum Hydroxlde),8,11/ 0.08 IJ/854 UN 1268, Petroleum dilllillates, n.o.s.,3,11111 0.04 U/366 All Packed In One FIBREBOARD BOX Q.=0.1 Addltlanol Hondllng Information 24-Hoor E'""'ll"'•Y Rosf'lll•<>- CHEMTREC HO!l-424-0000, CCN 201$19 [Y'.o,· .•,,,,,,.•,,,,,. ·-·-···{'.'.'.''"···«·····cc· ·········--C'.''%«".y C'.''."'.''."0%·<"'.'.'" I h.,.l!y detl!!m lilattoo oontonls of !hill cons!gnmont am lilliJf and act1.um:eiy described QOOye by the proper shlppl'.ng mrme~ and lillH& """"""''" ,.,,................,.,,, ..., ,,,,,,,~... Namo!Tftlo of Slgn""'ry Brody Hut>ilon!/En,romnenla! Coorolnatm olo!!olllod, pool111god, m•l'l!od ••d lallollildJpi"""rdod, ••d am In oil Place and Daw raopm:ill In propo, oondltlon lor imllOporl •=rdlog to opplloobl• MMle,NM 0~19 lntematlcnl!t! and Natlonal Governmental ~latlons.. I dedam that au of th• applicolllo olr lnn•port n,qulmmenili have l>i!en met. Sigmdure 18004249300 .fmi1R1'6FQMyT.s.l,phMI~ (> ...............) .. r,;::7.,,., An. IJ i~~ ill,idyH•bbard Fem R.MOOA.tWE MATEfWU.. S:HIPM!!lrf ACCEPTABLE FOR PAV.hllllG.ER. .NR.CRAPT, THE SHIPMSST CONTAINS AADIOAC"nVE l!'i'AAil!RlAL!PITI:NDEl.l FOR US! R9 OR INCIDEMT'TO RESEAAe!i, ME.l'JiCAL OIAGNOS:IS Ori: nmATMEMT. MIil EURillPEAIII 1M811SPOR'Ti!BTATEMENT: e.MruA.Ge IH ACCORDAIIJC!! WITH 1.1.U.1 ~rn:.o Page 27 of27 ~ ~ -~ ~ -~ ~ -~ -~ ~ :- EPA Inspection Report - Page 1918 of 1969 10450 Stancliff Rd. Suite 210 Houston, TX 77099 T: +1 281 530 5656 F: +1 281 530 5887 June 14, 2019 Gabriela Combs Navajo Refining Company PO Box 1490 Artesia, NM 88211-1490 Work Order: HS19060420 Laboratory Results for: BWON Monthly Sampling {EOL) Dear Gabriela, ALS Environmental received 3 sample(s) on Jun 07, 2019 for the analysis presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Results are expressed as "as received" unless otherwise noted. QC sample results for this data met EPA or laboratory specifications except as noted in the Case Narrative or as noted with qualifiers in the QC batch information. Should this laboratory report need to be reproduced, it should be reproduced in full unless written approval has been obtained by ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. If you have any questions regarding this report, please feel free to call me. Sincerely, Generated By: DAYNA.FISHER Corey Grandits Project Manager Right Solutions · Right Partner www.ahgk4:iaLrnrn Page 1 of25 HFNA-000003468 EPA Inspection Report - Page 1919 of 1969 AlS Houston, US Client: Project: Work Order: Date: 14-jun-19 Navajo Refining Company SAMPLE SUMMARY BWON Monthly Sampling (EOL) HS19060420 LabSamp ID Client Sample ID Matrix HS19060420-01 S-1 {API HC) HS19060420-02 HS19060420-03 Collection Date Date Received Liquid 06-Jun-2019 09: 19 07-Jun-2019 09:00 L.wJ S-3 (API Water) Liquid 06-Jun-2019 09:33 07-Jun-2019 09:00 L. . . . . .J S-5 {T-40} Liquid 06-Jun-2019 08:51 07-Jun-2019 09:00 [::] TagNo Hold ,:.-..............~ ~ ~ f. . . . . . . .l Page 2 of25 HFNA-000003469 EPA Inspection Report - Page 1920 of 1969 ALS Houston, US Date: 14-Jun-19 ==============----=-"=·=~·-·=····=····=···-----==== ========····=····=··-·=·---=-·····,,:·········,:,:,:.~=~~=, : Client: Project: Work Order: Navajo Refining Company BWON Monthly Sampling (EOL) CASE NARR.ATIVE HS19060420 Work Order Comments • The analysis for Specific Gravity was subcontracted to ALS Environmental in Holland, Ml. Final report attached. Page 3 of25 HFNA-0000034 70 EPA Inspection Report - Page 1921 of 1969 AUS Houston, US Client Project: Sample ID: Collection Date: ANALYSES Date: 14-Jun-19 Subcontract Analysis WorkOrder:HS 19060420 lab 1D:HS19060420-01 06-Jun-2019 09:19 RESULT QUAl $1.JBCONTAACTED ANALYSIS SPECIFIC: ~~VJIT ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-1 (AP! HC) Matrix:Llquid MDL REPORT LIMIT UNITS Dill.JTION FACTOR DATE ANALVZED M~t-ho~diNPi~""""""""""""""""""""""""'"""""'" ···········································-------·· See Attached 0 NA Analyst: SUBHO 14-Jun-2019 08:46 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 4 of25 RIGHT SOLUTIONS 1RIGHT PARTNER. HFNA-000003471 EPA Inspection Report - Page 1922 of 1969 ALS Houston, US C!ient Project: Sample ID: Collection Date: ANALYSES Date: 14-Jun-19 ANALYTICAl REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-3 (API Water) WorkOrder:HS 19060420 lab lD:HS19060420-02 06-Jun-2019 09:33 RESULT QUAL Matrix:Liquid MDL REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED Analyst: SUBHO Sul:Jcontrac! Analysis See Attached 0 NA 14-Jun-2019 08:46 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 5 of25 HFNA-0000034 72 EPA Inspection Report - Page 1923 of 1969 A.LS Houston, US Client Project: Date: 14-Jun-19 Navajo Refining Company BWON Monthly Sampling (EOL) ANALYTICAL REPORT WorkOrder: HS 19060420 Sample ID: S-5 (T-40) Lab ID:HS19060420-03 Collection Date: 06-Jun-2019 08:51 Matrix:Liquid ANALYSES REPORT LIMIT _____M_e_t-ho-a-:N-A-------·-···························--------------- RESULT QUAL SUBCONTRACTED ),NALYSIS SPECIFIC - MDL UNITS See Attached 0 DATE ANALYZED ···············--------,--,,---Analyst SUBHO 'GRAVITV Subcontract Analysis DILUTION FACTOR NA 14-Jun-2019 08:46 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 6 of25 HFNA-0000034 73 EPA Inspection Report - Page 1924 of 1969 ALS Houston, US Date: Navajo Refining Company BWON Monthly Sampling (EOL) Client: Project: WorkOrder: DATES REPORT HS19060420 Client Samp ID Sample ID Collection Date R340484 Analysis Date Prep Date TCLP Date - -.. ~ - - - - - - - - - - - - - - - ~ · · " " " " " " " " " ' · · · " " " " " ' · · · · ······-··········......................... .Batch ID 14-Jun-19 ~ Test Name: SUBCONTRACTED ANALYSIS SPECIFIC GRAVITY DF ..-.... Matrix: Liquid HS19060420-01 S-1 (API HC) 06 Jun 2019 09:19 14 Jun 2019 08:46 HS19060420-02 S-3 (API Water) 06 Jun 2019 09:33 14 Jun 2019 08:46 HS19060420-03 S-5 (T-40) 06 Jun 2019 08:51 14 Jun 2019 08:46 Page 7 of25 HFNA-0000034 74 EPA Inspection Report - Page 1925 of 1969 ALS Houston, US Client: Project: WorkOrder: Date: Navajo Refining Company BWON Monthly Sampling (EOL) 14-Jun-19 QUALIFIERS, ACRONYMS, UNITS HS19060420 Qualifier ........................ Description .. Value exceeds Regulatory Limit a Not accredited B Analyte detected in !he associated Method Blank above the Reporting Limit E Value above quantitation range H Analyzed outside of Holding Time J Analyte detected below quantitation limit M Manually integrated, see raw data for justification n Not offered for accreditation ND No! Detected at the Reporting Limit 0 Sample amount is > 4 times amount spiked p Dual Column results percent difference > 40% R RPD above laboratory control limit s u Spike Recovery outside laboratory control limits Analyzed but not detected above the MDUSDL Acrcmym ______--_D_e_s_c_r~ip~t_io_n_ DCS Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit SD Serial Dilution SOL Sample Detection Limit TRRP Texas Risk Reduction Program Page 8 of25 HFNA-000003475 EPA Inspection Report - Page 1926 of 1969 AlS Houston, US Date: 14-Jun-19 CERTIFICATIONS,ACCREIJITATIONS & UCENSES Agency Number Illinois 004438 Louisiana 03087 Expire Date 29-Jun-2019 30-Jun-2019 Dept of Defense 20-Dec-2021 Kansas Oklahoma 019 31-Jul-2019 2018-156 31-Aug-2019 North Carolina 624-2019 31-Dec-2019 Maryland 343, 2018-2019 30-Jun-2019 Arkansas Texas Page 9 of25 HFNA-0000034 76 EPA Inspection Report - Page 1927 of 1969 AlS Houston, US Client: Navajo Refining Company Project: BWON Monthly Sampling {EOL) Work Order: HS 19060420 Lab Samp ID 14-jun-19 Date: Client Sample ID Action Date Person New Location HS 19060420-01 S-1 (API HC} Login 08/06/2019 14:47:22 PMG Sub HS 19060420-02 S-3 (API Water} Login 08/06/2019 14:47:22 PMG Sub HS19060420-03 S-5 (T-40) Login 08/06/2019 14:47:22 PMG Sub Page 10 of25 HFNA-0000034 77 EPA Inspection Report - Page 1928 of 1969 AlS Houston, US Date: 14-Jun-19 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: QI::JJ!rt:l.Q.1.!Hl!tft!l Work Order: HS19060420 Received by: NDR Checklist completed by: Paresh M Giga eSignature I ' Reviewed by: 8-Jun-2019 Date Corey Grandits eSignature Matrices: 10-Jun-2019 Date ·--····· Carrier name: Shipping container/cooler in good condition? Not Present Custody seals intact on shipping container/cooler? Not Present Custody seals intact on sample bottles? Not Present VOA!TX1005/TX1006 Solids in hermetically sealed vials? Not Present Chain of custody present? 1 Page(s) Chain of custody signed when relinquished and received? COG 1Ds:None Samplers name present on COG? Chain of custody agrees with sample labels? Samples in proper container/bottle? Sample containers intact? Sufficient sample volume for indicated test? All samples received within holding lime? Container/Temp Blank temperature in compliance? Temperature(s )!Thermometer( s ): 1.5c U/c Cooler(s)/Kit(s): HazmatPak Date/Time sample{s) sent to storage: $/7/19 20:00 Water - VOA vials have zero headspace? · Yes [ ] ············ Water - pH acceptable upon receipt? Yes pH adjusted? Yes r"l ~...............::: ·········N·o No No D LJ ..... ~~ ~ LJ ·····-N~; VOA vials submitted NIA NIA f0l ::.................~ E::] pH adjusted by: Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 11 of25 HFNA-0000034 78 EPA Inspection Report - Page 1929 of 1969 HS19060420 Chain of Custody Form Page _1_ of __j_ J Navajo Refining Company BWON Monthly Sampling (EOLJ 11111111111111 11 Enuironmantal IV, UT 7700 PA 4903 5280 . k.:·y>:/::::::::::::::~r~~~~r:~~tiQr,j:~$q~~~:~r.:~JY:~i.$::::::::::::::::=::::·:::::::: ::::::::::::::;:;:::::;:;:::::::cusitomer-:lnfotmadijtr·.••· .··•· ~:/M~~,J~:¥~c::~· ·.....·-·-·-·---~ ·· 'Grkoi.c.1:er'.l :~:;specific Gravity .·.",·.·.·.·.-.·.··}, :){~~~f~,~::: Navajo Refining Company LLC /:{~~~~\~~~f -;:-:. O O O • • O. 0 . ' ' " • • • 0 ' • • 0 < 0 • <" >. • SO.< 0 T)'l•rTumer 0 0 0 Ga1>1comils _ ,w,w,-.-.-. • }}/\}/{~~;*: · ;~.:;.>c:;;: '.,'.;:;:::;:::;:;:;;;'. ·····················-· .,, 0 P.O. Box 159 _,_:i_\_1:-:::_\_)-~-#-~i-.#-~-)~~~:[Susie Aguilar --.-•• ~-:-:··:~·:·:·:·:·:··;·:;·:·;·:·.-.---:·:-~·:·;·:·::~·.-·;:·~·.-:-:?·;-~;:·-·i-···-········ (}/{{:}::;~rf{ · 501 Eait Main ______,,,,..·..,>..c>:,,..,:_·:-_:,;"-,:"-.:,c;,;..,,..·,;~.;:w>~:::~:::~::~:<...,:,----------------i-.-4----------------------------- ):/:}~/fyf.~~t~?t( Artesia, NM 88211-0159 ... , .......... , , ... , , ' :::::::::::::i:/::::::::~ijj,~~(575) 748-3311 ................ .. , ·.·,·.·.·.·.·.·.·.·.·.·,·.·.·,·.· """1 :-:-:-:-:,:,:.:,:.:,:,:•:•:-:.-:-:....,;.;.·1 ,,.. lit',1"7"'17'"" ... " ..,, ........ -.--,-,.··-··,··,··-··;··-··,··.-·;··.··.-·,··-··,··.··-· .·.·,·.·.-.·.·,·.·,·,·.·.·····-···· /{JS-1 (API HC) :;:jf;:ls-3 (AP! Water) 06/06119 9:33AM } } ) S-5 (T-40) 06/06119 8:51 AM I Liquid a I 1 Liquid ·· · 11 ······1··········· 1 ..+! ..-Xt - - ::::it< }i,:.;,;.;;,i-,-.. ,_,,h,•,· ....•..•. ,,,.. .,,,,..•.. ,,,,,.,., ......... ·'<•·»••••··••··•'··· ·:-.-.f-y C ... ·::;, ;; . ···•• . -~»- . . .- .-- ~~~ -~-1"0:> •• Required Turnaround Time: D STD 10 Wk Days 0 S Wk Days I "Tl z :r0 0 0 0 0 (,) .i:,,. -..,J (!) Note: Any changes must be mad& in writing once samples and COC Form have been submitted to ALS laboratory Group. Page 12 of25 (tl (jf er Co~t/~$1.aboratory Group EPA Inspection Report - Page 1930 of 1969 u.,, of thiuystom oonstitut•• yooragroomentto the ,eNice condition, In ti,e ,u,raot fedE, Servioe Gulde, avallablo "" · feclex.onsibleforony clolm in exre,..:lf$100 par poci<&a!!", wh•therthe re,ult of los;,domogo, deley, flOi'!-deii1.11MY, mlii:cle!hl'ery, ot n;;hsfriforrnatlori, urdffl you ded~re PJ higher veiu~, pisy an sdd!tf.ona! ch.srge1 do~~ment y<3ur actual I°"' ond file• timely ---,m (n C) ."'""" . ._;;a . -:-:•> ir~a~~~~ I~i! fiilii el~ ;::: 1jl(l')ITl0 f c: =i ui 00 ffl~ '"-I ~ .. ;;;,;, '" ~\\ \j ii·g. . ...a co ...;;j """'j ;;;. -g 2!! 'Tl ~ C~ -,i ·...a g ;;:i JtO . 111 ,, ~ I ~[ 0 dz ~Cl>),," ~ iii! iiii5! ii w i: g0 ,, "Tl . ~ii -< ffii!! G'J, lij;;; z g i I' =I >~ !--- :::oi ::11:1 - , ~ii ~ 0 ""' -""" >g~ i!. !"? ... 5i ::c (D < :::i .;; : -< -.i' G') iii '· <..! ~ >; ~- .) "Tl z :r0 (,) .i:,,. OJ 0 '·1 -1 -11:Sh~iw 0 0 0 0 . ! ~,.. ~I! i Page 13 of25 ~ ~ ~- Ai ... I i w' m,~ I ~ -I =i ,13 $;. iio1C1,!l210~04C !:!!iii'& ~o!s ~6~ ;1.i EPA Inspection Report - Page 1931 of 1969 -~ t t ~ t ~ I Sti!PPER'S DECLARATION FOR DANGEROUS GOODS t (i'mvld• !!I l•••t !hmo coplO!I to •irlloo,l Shipper Air Wsybm No. NAVAJO REFINING COMPANY C/0 AQUA MICROS!CS 709308590784 501 EMAIN ARTESIA ~ Roforn...,NM~ ContJgnfffl' FX 18 Compliant COi"!!'/ Grandi!& ALS 10450 Sll!neliff Sulte210 HOUSTON Express WARNING l'liR> oomplo!od ami &/gnM ropios of this Declitmllo• mu.t b• h"""'1dll>lh0Dpoi1IIM This •~lpmenl lo wffllln lh• -~ CAFE3211 TX 77099 US llmlla!U<>M pre.. ribod for. !d- """ •ppli..bl•I ~ ® Fa!lum to comply with all respects with the applicable Dangerous Goods Regulations may be in breach of tile applicable law ,subject to legal penalties. AJrpoovo by Ill• p-oblpplng name, •nd oro clanlllod, p,okagl!d, mBrill!d lllld labolll!dlplacordl!d, and ... in ml Namemtm cf S1gB1lllory Brady Hulll>omlJE"""'nmemal Coorolno!cr Plaai and Datil ro•pocts In pmpor oondl!lon far lrl!noporl aooorolng oo appiloallle lnli!rmrt!onol ond Nlllonol Governmamal Regull!!lo!IS. l doclSIO lhlrt Me>la, NM •ff ofttm •ppllooblo air iraRoport n,qulremonto hov,, l>ooo Old. 18004249300 E.,,..,,...,r_... _. I Slgna!uro dfflw,m>,g- .i:,,. -·--, . ] ~~ ~ I ;';, , ! FOR ~ffi/'E MATERW..SHffilW!N'f ACeut,run..e FORPAS~E~AmCMFi, ffl!:B'HIPMl!!:NTOOHTA1N1S RAl.'lroACiWE NATe:R.W..!NT!Nl)S) FOR US!~ OR : INCIOfNTTO ~ll!AIWH. M!DJCA!.. WAG NOBIS OR l'REATM1:1NT. MR fUROP!!AH TAANSPORTSTATEMEHT: CAR'RRAG5 JN N:-Coo.DARCE WITH 1.u.u i-=.·uuuu.- ·····----~·-·-·---~-~-·u.-.-.-.-.w~=~--n~NNNNNNN N~N. ~ loom 1Msn!ll!'f Hml Page 14 of25 (,) OJ ...... C!!/0012019 SOLUTiO\S ~ ~~~~----~-~--~-~--·-·NN~~ N 1 J .• t t ~ ~ EPA Inspection Report - Page 1932 of 1969 ~ ~ ~ ~ ~ -~ -~ AlrWaybm No. NAVAJO REFINING COMPANY C/0 AQUA MICROSICS 501 EMAIN ARTESIA ~ (l'ro.-!!le at least lllrt!E> coplaa to olrlloe.j SHIPPER'S DECLARATION FOR DANGEROUS GOODS ShlPI'"' -~ 709308590784 P•g• 1 cl 1 Poge(•I Shlppera Rofere"°" NM!ber NM88210 US /•pll<>••Q Consignee FX 18 Compliant Cfflll' Grandits ALS 10>45DSt.sncillf Suile210 HOUSTON Express """'°" oflhls WARNING l.leiSl'ORT llETAILS l'illls •hipmonl I• -In Illa lim-ns pm..tlood for: ! - rum spplltohlo) ~ CAFE3211 TX nD99 US Two oomp/ol"o$/dlolyrislr/, ptdlng group /!f ""l"lrod/, MIi a/1 othor ""'"''"" mlormB!Jli>o. UN 3266, Corrosive !!quid, basic, inorganic, n.o.s.(Sodium Hydn»dde),6,1// 0.04 U/654 UN 1266, Petroleum distillates, n.o.s.,3,1111/ D.04 U/366 All Paci>ced In One FIBREBOARD BOX Q=0.1 t ~ -t I "Tl z :r0 0 0 0 0 (,) .i:,,. OJ N ~~ [ Adil!tlonal Handling lrm>...,..ticn ' ; 24-Hoo, Eni"'l!ency R..PtlflS"" CHBi,!TREC H!00-424-9300, CCII 201319 I h.,..l,y o..i.ro 1rnit111o ...1e""' <>f !hlo oo~lgomoo!.,. lolly••• ~tcu~ d ~ atlwe .bytrMt pmpersbipplng n1m1&1 Rnd sre clal•ffled, pooi, lmlloportoeeorlertlonol GO'llfflffionlol Rogubllooo. l doolma tho! Mo~a. NM 00/001201 ~ all ilftl!i& l!lppllcabils air tmmpcrt requ$R'Sments hdw& been met. 18004249300 E~oo1T111dt.¢rQIP1 NwnM.r FOR !l.A!llOMffilE Ml\l'l!RIAJ. SHIPl.!Ellf ACOEPTJWU! ro• ·-••CE• Al!!C!WT, '!HE SHll'MEII'! COl!l'AIIIB IWl!OACmlE l\!Al'l!RW. !IITEHD!D !'fflt USE DI o• ffleffleH'f TO IWSEAR.CH, M!DICA:LD1AG~O!JS CR 'mlYt..TM!NT. Aim EUROPEAN iAAMSPl!JRTSTAffMENT: ~ ne ACCCIRDANC! Wl'rK 1,1A.%.'S ·~U~---~U I.CGOS.,'U31.:!l'S Wll Page 15 of 25 c~u ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ EPA Inspection Report - Page 1933 of 1969 ~ ~ ~ ~ SHIPPER'S DECLARATION FOR DANGEROUS GOODS l\lr Waybill No. NAVAJO REFINING COMPANY C/0 AQUA M!CRQBICS 501 EMAIN - ARTESIA , Rlll:fsmn~ Number (opliamil/ NMBS210 l.lS Con1lgno FX 18 Compliant Corey Gmndils AlS ® 104SO Sta11cliff Su~e210 Exoress CAFE3211 l'wi> COOIPleM!IOIIO pn,..ri!,°" I<,,: iaieJ NATURE AND QUANTITY OF DANGEROUS GOODS .~ I 709308590784 Poge 1 of 1 i'ag!1J/ d..1..., 111!11 !ho """"'f!!O ollllio 0<>ooignmont on, fKtufflt&'1 descrtbQd abov,e the proprar 1hJppin9 nema Iii~ u .... u Bradt Hubberu/En~roomGf!tal COOl'dlootof 1 ol'!nt.1.&Je ;l""3ml!llon•l ==:;:,~,~~==f~~==::.i~·:'~~~:b:i Place and Dale •nd Nm!o""i Gt>vommoi11al Rogula!iol1o. i d•ol8<0 ffl•t M••I•. NM OW00/2019 a!l llif Rhi!!' appl~ble nrrtmnspmt n,qulremS8m':9 hav1111 b&en mat. S!gnalurn !--------------.-------i( ... 18004249300 £m~yTef8fphQl'l1-Ntm1"bilr · ""11/n§-) BOlldyHabllal 4 times amount spiked P Dual Column results percent difference> 40% R RPD above laboratory control limit S Spike Recovery outside laboratory control limits U Analyzed but not detected above the MDL X Analyte was detected in the Method Blank between the MDL and Reporting Limit, sample results may exhibit background or reagent contamination at the observed level. Acronvm Description DUP Meihod Duplicate LCS Laboratory Coniml Sample LCSD Laboratory Control Sample Duplicate LOD Limit of Detection (see MDL) LOQ MBLK MDL MS Limit o:fQuantitation (see PQL) Method Blank Method Detection Limit Matrix Spike MSD Matrix Spike Duplicate PQL Praclical Quantitation Lim.it RPD Relative Percent Difference 1TIL Targei Deieclion Lirnit TNTC Too Numerous To Count A APHA Standard Methods D ASTM E EPA SW Units Reported SW-846 Update III Description none Page 19 of25 QF Pagel of 1 HFNA-000003486 EPA Inspection Report - Page 1937 of 1969 Date: 14-Jun-19 ALS Group, USA Client: ALS Environmental Pro.Ject: HS19060420 Sample ID: HS 19060420-0 I VVorkOrder: 19060672 Lab ID: 19060672-01 Matrh:: LIQUID Collection Date: 6/6/2019 09:19 AM Analyses Result Qua] SPECIFIC GRAVITY Specific Gravity Note: Report Limit Units D5057-90 0.844 Dilution Factor Date Analyzed Analyst: RZM none 6/13/2019 02:15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 1 of 3 Page 20 of25 HFNA-000003487 EPA Inspection Report - Page 1938 of 1969 Date: 14-Jun-19 ALS Group, USA Client: ALS Environmental Project: HS19060420 Sample ID: HS19060420-02 Work Order: 19060672 Lab ID: 19060672-02 Collection Date: 6/6/2019 09:33 AM Analyses Matrix: LIQUID Result Qual Report Limit Units SPECIFIC GRAVITY Specific Gravity Note: Dilution Factor Date Analyzed Analyst: RZM 1.00 none 6/13/2019 02:15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 2 of 3 Page 21 of25 HFNA-000003488 EPA Inspection Report - Page 1939 of 1969 Date: 14-Jun-19 ALS Group, USA Client: ALS Environmental Project: HS19060420 Work Order: 19060672 Lab ID: 19060672-03 Sample ID: HS l 9060420-03 Collection Date: 6/6i2019 08:51 AM Analyses Matrix: LIQlTID Result Qual SPECIFIC GRAVITY Specific Gravity Note: Report Limit Units D5057-90 1.17 none Dilution Factor Date Analyzed Analyst: RZM 6i13/2019 02:15 PM See Qualifiers page for a list of qualifiers and their definitions. Analytical Results Page 3 of 3 Page 22 of25 HFNA-000003489 EPA Inspection Report - Page 1940 of 1969 ALS Group, USA Client: Work Order: Project: ALS Environmental 19060672 HS19060420 Batch ID: R.262578 DI.JP Date: 14-Jun- l 9 QC BATCH REPORT Instrument ID WETCHEM Method: D5!l57-90 Sample ID: 19060672-02A DUP Client ID: HS19060420-02 Units: none Run ID: WETCHEM_190613M SeqNo: 5712799 SPK Ref Analyte Specific Gravity Result POL SPK Val 1.003 0 0 The following samples were analyzed in this batch: Note: Analysis Date: 6/13/2019 02:15 PM %REC Value i906067201A 0 0 Prep Date: Control Limit DF: 1 RPO Ref Value 0-0 19060672- 19060672- 02A 03A 0.9996 %RPO 0.3 RPD Limit Qual 20 See Qualifiers Page for a list of Qualifiers and their explanation. QC Page: 1 of 1 Page 23 of25 HFNA-000003490 EPA Inspection Report - Page 1941 of 1969 ., 10450 Stancliff Rd, Ste 210 Houston, TX 17099 iL,_,.,J,•>><<'·sr ''"""~ T; +1 281 530 5656 I": +l ZBl 530 S887 www.alsglobal.com Subcontrad: Chain of Custody A.LS Group USA, Corp. 3352 • 128th Ave Holland, Ml 494249253 INVOICE INIFORMATIONI: CUSTOMER INFORMATION: Company: ALS Houston Corey Grand!ts Contact: Accounts Payable 10450 Stancllff Rd, Ste 210 Address: 10450 Standlff Rd, Ste 210 Phone: +1 281 530 5656 Phone: +1 281 530 5656 Email: Corey.Gram:!tt:s@atsg!oba!.com Reference: HS19060420 TSR: Danielle wrnnlngs Company: Al.S Houston C:1:mtaict: Address: Altemate Contact: Email: 1, HS19060420-01 Uquld !iM. (API HC:} 2. HS1906M20..02 Liquid Sw:3 (API Water} HS1H6l>420•03 06 lun 2019 D!!il:33 14 Jun 2019 Sub Specific Gravity to Al.S Holland 3. 06 Jun 2019 O!ih19 14 Jun 2019 Sub Specific Gravity to Al.S Holland Liquid SwS (T-40) 06 Jun 2019 08:51 14 Jun 2019 Sub Specific Gravity to Al.S Holland Comments: Please analyze for the analysis listed above. Send report to the emails shown above. ,-'~elsAi1tted'i~idt, QC Level; STD (!..aboratory Standard QC: method blank and LCS required} Relinquished By: Date/Time: Received Ely: Date/Time: CoQler ID(s): Temperature(s): Page 24 of25 @ HFNA-000003491 EPA Inspection Report - Page 1942 of 1969 ALS Group, USA Sample Receipt Checldist Client Name: ALS-!iOUSTON Date/Time Received: '!1.Jun-19_ 09:30 Work Order: 19060672 Received by: BNF Checklist completed by ~ (;:?.;:."''"'" 11-Jun-19 eS;gna!ure Reviewed by: Date 11-Jun-19 eSignature Date Matrices: Carrier name: Shipping container/cooler in good condition? Yes '>/'! No Not Present Custody seals intact on shipping container/cooler? Yes !>/'! No Not Present Custody seals intact on sample bottles? Yes No Not Present Chain of custody present? Yes ~ No Chain of custody signed when relinquished and received? Yes ~ No Chain of custody agrees with sample labels? Yes ~ No Samples in proper container/bottle? Yes ~ No Sample containers intact? Yes No Sufficient sample volume for indicated test? Yes l~J lv'l No All samples received within holding time? Yes ~ No Container/Temp Blank temperature in compliance? Yes [;i'l No Yes iv'[ No Sample(s) received on ice? Temperature(s }/Thermometer(s ): 15.8/5.8 C Cooler(s)/Kit(s): 1 Date/Time sample(s) sent to storage: 6/1_1/2019_3:50:53.PM li] SR2 Water - VOA vials have zero headspace? Yes No No VOA vials submitted Water - pH acceptable upon receipt? Yes i>I'! No NIA pH adjusted? pH adjusted by: Yes No[.;ii NIA r~J Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: CorrectiveAction: Page 25 of25 SRC Page 1 of 1 HFNA-000003492 EPA Inspection Report - Page 1943 of 1969 10450 Stancliff Rd. Suite 210 Houston, TX 77099 T: +1 281 530 5656 F: +1 281 530 5887 June 20, 2019 Gabriela Combs Navajo Refining Company PO Box 1490 Artesia, NM 88211-1490 Work Order: HS19060423 Laboratory Results for: BWON Monthly Sampling (EOL) Dear Gabriela, ALS Environmental received 8 sample(s) on Jun 07, 2019 for the analysis presented in the following report. The analytical data provided relates directly to the samples received by ALS Environmental and for only the analyses requested. Results are expressed as "as received" unless otherwise noted. QC sample results for this data met EPA or laboratory specifications except as noted in the Case Narrative or as noted with qualifiers in the QC batch information. Should this laboratory report need to be reproduced, it should be reproduced In full unless written approval has been obtained by ALS Environmental. Samples will be disposed in 30 days unless storage arrangements are made. If you have any questions regarding this report, please feel free to call me. Sincerely, Generated Sy: JUMOKE.LAWAL Corey Grandits Project Manager Right Solutions Right Partner wwwA.isgb!:w.isom Pagel of27 HFNA-000003493 EPA Inspection Report - Page 1944 of 1969 ALS Houston, US Date: Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Work Order: HS19060423 20-jun-19 SAMPLE SUMMARY Lab Samp ID Client Sample ID Matrix HS 19060423-01 S-1 (API HC) HS 19060423-02 Collection Date Date Received Oil 06-Jun-2019 09:19 07-Jun-2019 09:00 S-3 {API Water) Liquid 06-Jun-2019 09:33 07-Jun-2019 09:00 HS 19060423-03 S-5 {T-40) Oil 06-Jun-2019 08:51 07.Jun-2019 09:00 HS 19060423-04 Field Blank Water 06-Jun-2019 09:37 07-Jun-2019 09:00 HS19060423-05 EQ Blank Port 1 Water 06-Jun-2019 09:50 07-Jun-2019 09:00 TagNo Hold t:1 D D L,J f''l 1::.................::: 1:...............::: HS 19060423-06 EQ Blank Port 2 Water 06-Jun-2019 09:50 07-Jun-2019 09:DO HS 19060423-07 Duplicate Liquid 06-Jun-2019 00:00 07-Jun-2019 09:00 D HS 19060423-08 Trip Blank Water 06-Jun-2019 00:00 07-Jun-2019 09:00 C. . .1 C&G101618-97 ~ ::: ~ ::: t_...............::: :::..................~ Page 2 of27 HFNA-000003494 EPA Inspection Report - Page 1945 of 1969 A.LS Houston, US Date: 20-Jun-19 = = = = = = = = = = = = = = = = = = = = = = - - - - = = = = = = = = = = = = = · · = ·"-···.."=........................... Client: Project: BWON Monthly Sampling (EOL) Work Order: HS19060423 Navajo Refining Company CASE NARR.ATIVE GCMS Volatiles by Method SW826Cl Batch ID: R340490,R340496,R340871 • The test results meet requirements of the current NELAP standards, state requirements or programs where applicable. Batch ID: R:340284 Sample ID: S-5 {T-40) (HS19060423-03) • Lowest practical dilution for HS19060423-03 due to sample matrix. Surrogate failure due to matrix. Page 3 of27 HFNA-000003495 EPA Inspection Report - Page 1946 of 1969 ALS Houston, US Client Project: Sample ID: Collection Date: ANALYSES -----------------------------------------------.-.---------- Date: 20-Jun-19 ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling {EOL) WorkOrder: HS 19060423 S-1 (AP! HC) Lab ID:HS19060423-01 Matrix:Oil 06-Jun-2019 09:19 RESULT QUAL REPORT LIMIT MDL -------------------"""""·-- ---------- .... ...................... , UNITS DILUTION FACTOR DATE ANALYZED ...................................... .............., ........, ........,,....,.,, Analyst: WLR 46 Benzene 0.24 2.4 mg/Kg 500 12-Jun-2019 01 :35 Surr: 1,2-Dich!oroethane-d4 91.8 70-126 %REC 500 12-Jun-2019 01:35 Surr: 4-Bromof!uorobenzene 95.5 70-130 %REC 500 12-Jun-2019 01:35 Surr: Dibramof/uoromethane 87.8 70-130 %REC 500 12-Jun-2019 01:35 Surr: Toluene-dB 99.9 70-130 %REC 500 12-Jun-2019 01:35 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 4 of27 HFNA-000003496 EPA Inspection Report - Page 1947 of 1969 ALS Houston, US Client: Project Sample ID: Collection Date: ANALYSES Date: 20-Jun-19 RESULT QUAL MDL ••.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•. WorkOrder:HS 19060423 Lab ID:HS19060423-02 Matrix:Uquld REPORT LIMIT """""""""""' VOi.ATiLES • SW8260C Benzene ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-3 (API Water) 06-Jun-2019 09:33 DILUTION FACTOR 0.59 0.030 DATE ANALYZED ............................................. ••••••••••••••••••ss,•••,••ss••••s,.......,.,.,... Method:SW8260 Analyst: 0.25 Surr: 1, 2-Dich/oroethane-d4 92.3 70-126 Surr: 4-Bromofluorobenzene 95.1 82-124 Surr: Dibromofluoromethane 98.5 77-123 100 82-127 Surr: Toluene-dB UNITS mg/L %REC %REC %REC %REC 50 PC 19-Jun-2019 22:56 50 19-Jun-2019 22:56 50 19-Jun-2019 22:56 50 19-Jun-2019 22:56 50 19.Jun-2019 22:56 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 5 of27 HFNA-000003497 EPA Inspection Report - Page 1948 of 1969 ALS Houston, US Client Project: Sample ID: Collection Date: ANALYSES Date: 20-Jun-19 ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling (EOL) S-5 (T-40) WorkOrder: HS 19060423 Lab ID:HS19060423-03 Matrix:Oi! 06-Jun-2019 08:51 RESULT QUAL MDL REPORT LIMIT DILUTION UNITS DATE FACTOR ANALYZED mg/Kg 50 Method:SWS2&0 VOLATILES BY SWS260C Analyst: WLR Benzene < 0.024 Surr: 1, 2-Dichloroethane-d4 93.2 70-126 %REC 50 12-Jun-2019 01:10 Surr: 4-Bromofluorobenzene 96.4 70-130 %REC 50 12-Jun-2019 01:10 Surr: Dibromofluoromethane 66.3 70-130 %REC 50 12-Jun-2019 01:10 Surr: Toluene-dB 96.7 70-130 %REC 50 12-Jun-2019 01:10 0.024 s 0.24 12-Jun-2019 01:10 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 6 of27 HFNA-000003498 EPA Inspection Report - Page 1949 of 1969 ALS Houston, LIS Client: Project: Sample ID: Collection Date: ANALYSES Date: 20.Jun-19 ANALYTICAl REPORT Navajo Refining Company BWON Monthly Sampling (EOl) Field Blank WorkOrder: HS 19060423 lab !D:HS19060423-04 Matrix:Water 06-Jun-2019 09:37 RESULT QUAL MDL REPORT LIMIT UNITS DILUTION FACTOR .----------·""'"'"""""""'"············· ····················-·· :VOL.ATU.ES • SWS260C Benzene ..""""""""""""" Methcd:SWS.260 < 0.00060 0.00060 DATE ANALVZED Analyst: PC 0.0050 mg/L 14-Jun-2019 05:58 Surr: 1,2-Dichloroethane-d4 97.6 70-126 %REC Surr: 4-Bromof/uorobenzene 98.4 82-124 %REC 1 14-Jun-2019 05:58 Surr: Dibromof/uoromethane 104 77-123 %REC 1 14-Jun-2019 05:58 Surr: Toluene-dB 101 82-127 %REC 1 14-Jun-2019 05:58 14-Jun-2019 05:58 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 7 of27 HFNA-000003499 EPA Inspection Report - Page 1950 of 1969 A.LS Houston, US Date: 20-Jun-19 ANALYTICAL REPORT Client: Navajo Refining Company Project: Sample ID: BWON Monthly Sampling (EOL) EQ Blank Port 1 Collection Date: 06-Jun-2019 09:50 ANALYSES Lab ID:HS19060423-05 Matrix:Water DILUTION DATE REPORT UNITS FACTOR ANALYZED LIMIT ···································-···--·-------~------------ """"'""""'"••••••••••••••••,ss••"""'""_ _ _ Method:SW8260 Analyst: PC RESULT QUAL 1VC>L.ATILES • SW8260C Benzene WorkOrder: HS 19060423 < 0.00060 MDL 0.00060 0.0050 mgiL 14-Jun-2019 06:23 Surr: 1,2-Dichforoethane-d4 102 70-126 %REC Surr: 4-Bromof/uorobenzene 93.0 82-124 %REC 14-Jun-2019 06:23 Surr: Dibromof/uoromethane 99.2 77-123 %REC 14-Jun-2019 06:23 103 82-127 %REC Surr: Toluene-dB 1 1 14-Jun-2019 06:23 14-Jun-2019 06:23 Note: See Qualifiers Page for a list of qualifiers and !heir explanation. Page 8 of27 HFNA-000003500 EPA Inspection Report - Page 1951 of 1969 ALS Houston, US Date: 20-Jun-19 ANALYTICAL REPORT Client Navajo Refining Company Project: BWON Monthly Sampling {EOl) WorkOrder: HS 19060423 Sample ID: EQ Blank Port 2 Lab ID:HS 19060423-06 Collection Date: 06-Jun-2019 09:50 Matrix:Water ANALYSES VOi.ATILES • SW82MC RESULT Qi.JAL MDL REPORT LIMIT UNITS ····················································""""""""""'"-"~------ --------- Benzene DILUTION FACTOR ························--·-------- Method:SW8260 < 0.00060 0.00060 DATE ANALYZED Analyst: PC 0.0050 mg/L 14-Jun-2019 06:48 Surr: 1,2-Dichloroethane-d4 96.7 70-126 %REC 1 14-Jun-2019 06:48 Surr: 4-Bromofluorobenzene 92.8 82-124 %REC 1 14-Jun-2019 06:48 Surr: Dibromof/uaromethane 101 77-123 %REC 1 14-Jun-2019 06:48 Surr: Toluene-dB 102 82-127 %REC 1 14-Jun-2019 06:48 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 9 of27 HFNA-000003501 EPA Inspection Report - Page 1952 of 1969 ALS Houston, US Date: 20-Jun-19 ANALYTICAl REPORT Client: Navajo Refining Company Project: BWON Monthly Sampling (EOL) Duplicate 06-Jun-2019 00:00 Sample ID: Collection Date: ANALYSES RESULT QUAL MDL WorkOrder:HS 19060423 Lab !D:HS19060423-07 Matrix:Uquid REPORT LIMIT UNITS DILUTION FACTOR ······························· ................,,.., •.•.•.,,,,,,,,··----------- :VOLATILES • SWS260C Benzene ..............,,,,,,,,,,,,,,,,,,,,,,,, l\llethod:SWS260 0.62 o.o:m DATE ANALVZED Analyst: PC mg/L 50 Surr: 1, 2-Dichloroethane-d4 93.9 70-126 %REC 50 19-Jun-2019 23:21 Surr: 4-Bromofluorobenzene 95.7 82-124 %REC 50 19-Jun-2019 23:21 Surr: Dibromofluoromethane 95.2 77-123 %REC 50 19-Jun-2019 23:21 100 82-127 %REC 50 19-Jun-2019 23:21 Surr: Toluene-dB 0.25 19-Jun-2019 23:21 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 10 of27 HFNA-000003502 EPA Inspection Report - Page 1953 of 1969 A.LS Houston, US Client Project: Sample !D: CoHection Date: ANALYSES Date: 20-Jun-19 ANALYTICAL REPORT Navajo Refining Company BWON Monthly Sampling {EOL) Trip Blank 06-Jun-2019 00:00 RESULT QUAL MDL WorkOrder:HS 19060423 Lab ID:HS19060423-08 Matrix:Water REPORT LIMIT UNITS DILUTION FACTOR DATE ANALYZED •.·.-~~~~~~~--. ........... VOLATILES • SW8260C Method:SW8260 < 0.00060 Analyst; PC 0.0050 mg/L 1 Surr: 1, 2-Dichloroethane-d4 105 70-126 %REC 1 13-Jun-2019 14:56 Surr: 4-Bromofluorobenzene 104 82-124 %REC 1 13-Jun-2019 14:56 Surr: Dibromofluoromethane 101 77-123 %REC 1 13-Jun-2019 14:56 Surr: Toluene-dB 106 82-127 %REC Benzene 0.00060 13-Jun-2019 14:56 13-Jun-2019 14:56 Note: See Qualifiers Page for a list of qualifiers and their explanation. Page 11 of27 HFNA-000003503 EPA Inspection Report - Page 1954 of 1969 ALS Houston, US Date: 20-Jun-19 WEIGHT LOG Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) WorkOrder: HS19060423 Batch 10: 3146 SamplD HS19D60423-01 HS19D60423-03 Method: Container VOLATILES BY SW8260C Sample WWol Final Volume Weight Factor 5.138 (g) 5.118 (g) 5 (mL) 5 (ml) 0.97 0.98 Container Type Bulk (50308) Bulk (50308) Page 12 of27 HFNA-000003504 EPA Inspection Report - Page 1955 of 1969 ALS Houston, US Date: Navajo Refining Company BWON Monthly Sampling (EOL) Client: Project: WorkOrder: DATES REPORT HS19060423 ·Client Samp ID Sample ID 20-jun-19 Collection Date TCLP Date Analysis Date Prep Date DF - - - - - - - - - " " " " " ' = " > " = • • » » • • • • • • • • • • • • • • • • • • • , s s • • • • • • s s - - - - - - - - - - - · · · • • • • • • • • • • • • • • • • • • • • • • • • • » • ...........................................•.••••••.•.•.•.•.•.•.•.•.•.•.•.•.•.•.•.·------- Batch ID R340284 Test Name: VOLATILES BY SWS260C Matrix: Oil HS19060423-01 S-1 (API HC) 06 Jun 2019 09:19 12 Jun 2019 01:35 500 HS19060423-03 S-5 (T-40) 06 Jun 2019 08:51 12 Jun 2019 01 :10 50 j3atch ID R340490 Test Name: VOLATILES-SW8260C Matrix: Water HS19060423-04 Field Blank 06 Jun 2019 09:37 14 Jun 2019 05:58 HS19060423-05 EQ Blank Port 1 06 Jun 2019 09:50 14 Jun 2019 06:23 HS19060423-06 EQ Blank Port 2 06 Jun 2019 09:50 14 Jun 2019 06:48 Batch ID R340496 HS19060423-08 ~atch ID Test Name: VOLATILES - SW8260C 06 Jun 2019 00:00 Trip Blank R340871 Test Name : VOLATILES - SWB260C Matrix: Water 13 Jun 2019 14:56 Matrix: Liquid HS19060423-02 S-3 (API Water} 06 Jun 2019 09:33 19 Jun 2019 22:56 50 HS19060423-07 Duplicate 06 Jun 2019 00:00 19 Jun 2019 23:21 50 Page 13 of27 HFNA-000003505 EPA Inspection Report - Page 1956 of 1969 A.LS Houston, US Client: Project: WorkOrder: Date: 20-Jun-19 Navajo Refining Company QC BATCH REPORT BWON Monthly Sampling (EOL) HS19060423 Instrument: MBLK Sample ID: MBLKW2-llS1119 Client ID: Run ID: Analyte Units: ug/Kg VOA.8_340284 PQL Result Benzene Method: VOLATILES BY SW8260C < 25 Analysis Date: 11.Jun-2019 23:30 SeqNo: 5117424 SPKVal SPK Ref Value %REC PrepDate: Control Limit DF: 50 RPD Ref RPD Value %RPD Limit Qual 250 """""""""-"" Surr: 1, 2-Dichloroethane-d4 2315 0 Surr: 4-Bromof!uorobenzene 2341 0 2500 0 93.6 80- 120 Surr: Dibromof/uoromethane 2149 0 2500 0 86.0 80-119 Surr: Toluene-dB 2405 0 2500 0 96.2 81 - 118 LCS Sample ID: VLCSW2-061119 Client ID: Run ID: Analyte Result Benzene Units: ug/Kg VOA.8_340284 Analysis Date: 11-Jun-2019 22:40 SeqNo: 5117423 PQL SPK Val SPK Ref Value 0 PrepDate: %REC Control Limit 91.5 75- 124 45.77 5.0 50 Surr: 1,2-Dich/oroethane-d4 46.38 0 50 0 92.8 76- 125 Surr: 4-Bromofluorobenzene 48.92 0 50 0 97.8 80-120 Surr: Dibromofluoromethane 44.17 0 50 0 88.3 80- 119 Surr: Toluene-dB 48.51 0 50 0 97.0 81 - 118 DF: 1 RPD Ref RPD Value %RPO Limit Qual ''''""~--- MS Sample ID: HS19060030-06MS Client ID: Run ID: Units: ug/Kg VOA8~340284 Analysis Date: 12.Jun-2019 00:20 SeqNo:5117426 PrepDate: Analyte Result PQL SPKVal SPK Ref Value Benzene 113000 4200 42500 Surr: 1, 2-Dich!oroethane-d4 38100 0 42500 Surr: 4-Bromof/uorobenzene 40110 0 42500 0 94.4 70 • 130 Surr: Dibromotluoromethane 36690 0 42500 0 86.3 70-130 Surr: Toluene-dB 42180 0 42500 0 99.3 70-130 %REC Control Limit 69320 103 70 -130 0 89,6 70-126 DF: 1000 RPD Ref RPD Value %RPD Limit Qual Page 14 of27 HFNA-000003506 EPA Inspection Report - Page 1957 of 1969 AlS Houston, US Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) HS19060423 WorkOrder: Batch ID: Date: 20-Jun-19 R340284 { 0 ) MSD Sample ID: lnstru ment VOAS HS19060030-06MSD Client ID: Run ID: QC BATCH REPORT Method: VOLATILE:$ BY SW8260C Units: ug/Kg VOA8_340284 Analysis Date: 12-Jun-2019 00:45 SeqNo: 5117427 Analyte Result PQL SPKVal SPK Ref Value Benzene %REC PrepDate: Control Limit DF: 1000 RPD Ref RPD Value %RPO Limit Qual 116700 4200 42500 69320 Surr: 1, 2-Dich/oraethane-d4 40750 0 42500 0 Surr: 4-Bromof/uorobenzene 43070 0 42500 0 101 70- 130 40110 7.12 30 Surr: Dibromof/uoromethane 38830 0 42500 0 91.4 70-130 Jiiaso··· 5.67 30 Surr: Toluene-dB 43940 0 42500 0 103 70- 130 42180 4.08 30 The following samples were analyzed in thls hatch: ps19060423-0l HS19060423-03 112 70 • 130 113000 3.27 30 38100 6.73 30 '""""""---"~'"" 95.9 70 - 126 --~---·································-----------~ Page 15 of27 HFNA-000003507 EPA Inspection Report - Page 1958 of 1969 ALS Houston, I.JS Date: 20-Jun-19 Client: Project: Navajo Refining Company BWON Monthly Sampling (EOL) WorkOrder: HS19060423 Batch ID: R.340490 ( 0 ) MBLK Sample ID: Instrument: Units: ug/L Run ID: < 0.60 Surr: 1,2-Dichforoethane-d4 VOA.9_340490 PQL Result Benzene Method: VBLKW-190613 Client ID: Analyte QC BATCH REPORT 96.4 70- 130 82- 115 50 0 99.1 73- 126 50 0 101 81 - 120 50 Surr: 4-Bromof!uorobenzene 47.32 0 50 Surr: Dibromofluoromethane 49.54 0 Surr: Toluene-dB 50.27 0 VLCSW-190613 Result SeqNo: 5122207 VOA9_340490 PQL SPKVal 20 0 96.7 74 - 120 0 97.2 82 • 115 101 73-126 98.4 81 • 120 19.34 5.0 46.43 0 Surr: 4-Bromofluorobenzene 48.58 0 50 50.69 0 50 49.2 0 50 """'""""""'--~ Surr: Dibromof!uoromethane Surr: Toluene-dB MS Sample ID: Run ID: Analyte Benzene Result 47560 ·······················o··· 0 Units: ug/l HS19060352-01MS Client ID: PrepDate: SPK Ref Value 1,2-Dichloroethane-d4 Benzene DF: 1 RPD Ref RPD Value %RPD Limit Qual Analysis Date: 13.Jun-2019 22:58 Units: ug/L Run ID: Analyte ····························o 94.6 0 Sample ID: %REC Control Limit 0 48.22 LCS SPK Ref Value 13.Jun-2019 23:48 PrepDa!e: 5.0 """""""'~"" Client ID: Analysis Date: SeqNo: 5122208 SPKVal VOLATILES· SW8260C VOA.9_340490 %REC Control Limit Analysis Date: SeqNo: 5122211 PQL SPKVal SPK Ref Value 2500 10000 35900 PrepDate: %REC Control Limit 117 70 • 127 DF: 1 RPD Ref RPO %RPO Limit Qual Value 14-Jun-2019 01:02 DF: 500 RPO Ref RPD Value %RPD Limit Qual ........................................................ ,,,,,,,,,,,,,,,,,,,,, .. " ' " ' - - - " " ···sui,:t:2=oichioroeThane~d4··· 23820 0 25000 0 95.3 70-126 Surr: 4-Bromofluorobenzene 24480 0 25000 0 97.9 82- 124 Surr: Dibromofluoromethane 25650 0 25000 0 103 77-123 Surr: Toluene-dB 25090 0 25000 0 100 82- 127 """""""""""""'"~- Page 16 of27 HFNA-000003508 EPA Inspection Report - Page 1959 of 1969 AUS Houston, US Client: Project: WorkOrder: Date: 20-Jun-19 Navajo Refining Company BWON Monthly Sampling {EOL) QC BATCH REPORT HS19060423 Instrument: MSD Sample ID: HS19060352-01MSD Client ID: Analyte Method: VOLATILES • SW8260C Units: ug/L Run ID: VOA9_340490 Result .................................... Analysis Date: 14.Jun-2019 01:27 SeqNo:5122212 PQL SPKVal SPK Ref Value PrepDate: Control %REC Limit DF: 500 RPD Ref RPD Value %RPD Limit Qual ~~~~~~~~~~~~~ Benzene 43240 2500 10000 35900 73.4 70 - 127 47560 9.51 20 Surr: 1, 2-Dich!oroethane-d4 23930 {) 250{)0 {) 95] 70 -126 23820 0.442 20 25000 0 94.9 82 - 124 24480 3.16 20 Surr: 4-Bromofluorobenzene 23720 0 Surr: Dibromofluoromethane 25310 {) 25000 0 101 77 - 123 25650 1.33 20 Surr: Toluene-dB 24390 0 25000 0 97.6 82-127 25090 2.85 20 The following samples were analyzed in this batch; :HS19060423-04 ---1 -~~=·1·=·~~~423-05 -- ·-····HS19060423-06 ........................................................................ Page 17 of27 HFNA-000003509 EPA Inspection Report - Page 1960 of 1969 A.LS Houston, US Client: Project: WorkOrder: Batch 10: Date: 20-Jun-19 Navajo Refining Company BWON Monthly Sampling (EOL) QC BATCH REPORT HS19060423 R.340496 { 0 ) Sample ID: MBLK VBLKW-190613 Client ID: Units: ug/L Run ID: Analyte Result Benzene Method: VOLATILES - SWS260C: VOAS Instrument: VOA.6_340496 PQL Analysis Date: 13..Ji.m-201911:20 SeqNo:5122301 SPKVal SPK Ref Value %REC Control Limit surr.:f2=b1ch1oroethane~d4··· 51.79 0 50 0 104 70- 130 Surr: 4-Bromofluorobenzene 52.14 0 50 0 104 82- 115 Surr: Dibromofluoromethane 49.75 0 50 0 99.5 73- 126 Surr: Toluene-dB 53.84 0 50 0 108 81- 120 Sample ID: VLC:SW-190613 Analyte '''''"""""'~"'-'" VOA6_340496 SeqNo: 5122300 PrepDate: PQL SPKVal SPK Ref Value 22.06 5.0 20 0 110 74 -120 54.14 0 50 0 108 70- 130 Result Benzene Analysis Date: 13.Jun-201910:31 Units: ug/L Run ID: Client ID: RPD Ref RPD Value %RPO Limit Qual 5.0 < 0.60 LCS DF: 1 PrepDate: %REC Control Limit DF: 1 RPD Ref RPD Value %RPO Limit Qual '""'·"""~ Surr: 1, 2-Dichloroethane-d4 Surr: 4-Bromofluorobenzene 51.65 0 50 0 103 82 - 115 su,,.:·oiii,omoiluo,ameiiiane··· 54.16 0 50 0 108 73 - 126 Surr: Toluene-dB 44.72 0 50 0 89.4 81 - 120 MS Sample ID: HS19060512-01 MS Client ID: Analyte Benzene Run ID: Result 17.99 Analysis Date: 13.Jun-201913:44 Units: ug/L VOA6_340496 SeqNo: 5122307 PQL SPKVal SPK Ref Value 5.0 20 0 OF: 1 PrepDate: %REC Control Limit 90.0 70-127 RPD Ref RPO Value %RPD Limit Qual ''''''''''''''''''''''''''''''''""""'""~------ Surr: 1, 2-Dichloroethane-d4 52.63 0 50 0 105 70- 126 Surr: 4-Bromofluorobenzene 53.28 0 50 0 107 82- 124 Surr: Dibromofluoromethane 50.85 0 50 0 102 77 - 123 Surr: Toluene-dB 52.89 0 50 0 106 82- 127 Page 18 of27 R.!GHT HFNA-000003510 EPA Inspection Report - Page 1961 of 1969 AlS Houston, IJS Client: Project: WorkOrder: Batch II); Dale: 20-Jun-19 Navajo Refining Company BWON Monthly Sampling {EOL) HS19060423 R340496 { 0 ) MSD QC BATCH REPORT Sample ID: Instrument: HS19060512.01MSD Client ID: Analyte VOA& Run ID: Result Method: VOLATILES· SWS2SOC Units: ug!L Analysis Date: 13-Jun-201914:08 SeqNo: 5122308 VOA.6_340496 PQL SPKVal SPK Ref Value PrepDate: %REC Control Limit Benzene 18.13 5.0 20 0 90.6 70 -127 Surr: 1, 2-Dichloroethane-d4 51.82 0 50 0 104 70- 126 Surr: 4-Bromofluorobenzene 52.15 0 50 0 104 82- 124 DF: 1 RPD Ref RPD Value %RPO Limit Qua! 17.99 0.73 20 53.28 2.16 20 ................. ?}ii;§ 1.54 20 Surr: Dibromofluoromethane 50.74 0 50 0 101 77 - 123 50.85 0.221 20 Surr: Toluene-d8 52.35 0 50 0 105 82- 127 52.89 ............................. 1.03 20 The following samples were imalyzed in this batch: ~tS19060423-08 L,········-----------ss·ss--nn.•.•.•,nn '••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••cccccccccc-------- Page 19 of27 HFNA-000003511 EPA Inspection Report - Page 1962 of 1969 ALS Houston, US Client: Project: Work:Order: Batch ID: Date: 20-.Jun-19 Navajo Refining Company BWON Monthly Sampling (EOL) HS19060423 R340871 { 0) MBLK QC BATCH REPORT Sample ID: Instrument: VBLKV\f.190619 Units: ug/L Run ID: Client ID: Analyte Method: VOLATILES • SW8280C VOA9_34087'1 PQL Result Analysis Date: SeqNo: 5131259 SPKVal SPK Ref Value %REC PrepDate: Control Limit < 0.60 5.0 Surr: 1, 2-Dich/oroethane-d4 44.62 0 50 0 8fi_2 70- 130 Surr: 4-Bromofluorobenzene 46.99 0 50 0 94.0 82- 115 Benzene 19-Jun-2019 13:51 DF: 1 RPD Ref RPO Value %RPO Limit Qual '''"""""""""""-----"" ''''''''''""""""""""""""""~,------- Surr: Dibromofluoromethane 47.95 0 50 0 95.9 73- 126 Surr: Toluene-dB 50.54 0 50 0 101 81 - 120 lCS Sample ID: Units: ug/1. VlCSW-190619 Run ID: Client ID: Analyte Benzene ···surr:·1,2~bichioroethane~d4··· VOA9_340S71 Analysis Date: 19-Jun-2019 13:01 SeqNo:5131258 Result PQL SPKVal SPK Ref Value 18.01 5.0 20 0 90.1 74 - 120 43.39 0 50 0 86.8 70 - 130 98.7 82 - 115 Surr: 4-Bromofluorobenzene 49.35 0 50 0 Surr: Dibromofluoromethane 49.22 0 50 0 51.8 0 50 0 Surr: Toluene-dB MS Sample ID: Units: ug/L HS19060847-01MS Client ID: Analyte PrepOate: Run ID: Result VOA.9_340871 %REC Control Limit ................ ,"""'.. """""--------~ 98.4 73- 126 104 81 - 120 Analysis Date: 19-Jun-2019 15:05 SeqNo: 5131261 PQL SPKVal SPK Ref Value 5.0 20 0 112 PrepDate: %REC Control Limit 70 - 127 Benzene 22.46 Surr: 1, 2-Dichforoethane-d4 43.58 0 50 0 87.2 70- 126 Surr: 4-Bromofluorobenzene 48.41 0 50 0 96.8 82- 124 51.75 0 50 0 104 82 - 127 Surr: Dibromof/uoromethane Surr: Toluene-dB DF: 1 RPO RPO Ref Value %RPO Limit Qual OF: 1 RPD Ref RPO Value %RPO Limit Qual 77-123 Page 20 of27 HFNA-000003512 EPA Inspection Report - Page 1963 of 1969 AlS Houston, US Client: Project: WorkOrder: Batch ID: Date: 20-Jun-19 Navajo Refining Company BWON Monthly Sampling (EOL) HS19060423 R.340871 ( 0 ) MSD Instrument: Sample ID: Method: VOLATILES• SW8260C HS19060S47-01MSD Client ID: Run ID: Analyte Result " Benzene QC BATCH REPORT ..................... Units: ug/L VOA9_340S71 Analysis Date: 19.Jun-201915:30 SeqNo: 5131262 PrepDate: DF: 1 PQL SPKVal SPKRef Value 5.0 20 0 99.7 70 - 127 22.46 11.9 20 %REC Control Limit RPD Ref RPD Value %RPD Limit Qual ~~~~~ 19.95 Surr: 1, 2-Dichloroethane-d4 44.56 0 50 0 89.1 70 - 126 ¥:fsa 2.22 20 Surr: 4-Bromofluorobenzene 47.62 0 50 0 95.2 82- 124 48.41 1.64 20 48.93 0.652 20 51.75 3.11 20 ""~---- Surr: Dibromofluoromethane 48.61 0 50 0 97.2 f1·~··123 Surr: Toluene-dB 50.17 0 50 0 100 82- 127 The following samples were analyzed in this batch: /tS19060423-02 HS19060423-07 •••••••••••••••••••••••••••••••••··ss·ss----··············1, Page 21 of27 HFNA-000003513 EPA Inspection Report - Page 1964 of 1969 .AlS Houston, !JS Date: 20-Jun-19 Client: Project Navajo Refining Company BWON Monthly Sampling (EOL) WorkOrder: HS19060423 Qualifier QUALIFIERS, .ACRONYMS, UNITS Descriptio1_1 Value exceeds Regulatory Limit a Not accredited B Analyte detected in the associated Method Blank above the Reporting Limit E Value above quanlitation range H Analyzed outside of Holding Time j Analyte detected below quantitation limit M Manually integrated, see raw data for justification n Not offered for accreditation ND Not Detected at the Reporting Limit 0 Sample amount is > 4 times amount spiked p Dual Column results percent difference > 40% R RPD above laboratory control limit s u Analyzed but not detected above the MDUSDL ~1::.r.?.~Y.~ DCS Spike Recovery outside laboratory control limits ........ Descripfton Detectability Check Study DUP Method Duplicate LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate MBLK Method Blank MDL Method Detection Limit MQL Method Quantitation Limit MS Matrix Spike MSD Matrix Spike Duplicate PDS Post Digestion Spike PQL Practical Quantitaion Limit so Serial Dilution SDL Sample Detection Limit TRRP Texas Risk Reduction Program !Jnit Report~~ ....... Descri.ption_ mg/Kg Milligrams per Kilogram mg/L Milligrams per Liter Page 22 of27 HFNA-000003514 EPA Inspection Report - Page 1965 of 1969 AlS Houston, US Date: 20-Jun-19 CERTIFICATIONS,ACCREDiiATIONS & LICENSES Agency Arkansas Number 19-028-0 Expire Date 27-Mar-2020 Dept of Defense 20-Dec-2021 Illinois 29-Jun-2019 Kansas 31-Jul-2019 Louisiana 30-Jun-2019 Maryland 343, 2018-2019 30-Jun-2019 North Carolina 624-2019 31-Dec-2019 Oklahoma Page 23 of 27 HFNA-000003515 EPA Inspection Report - Page 1966 of 1969 AlS Houston, US Client: Project: Work Order: Lab Samp ID 20-jun-19 Date: Navajo Refining Company SAMPLE TRACKING BWON Monthly Sampling (EOL) HS19060423 Client Sample ID Action Date Person New Location HS19060423-01 S-1 (API HC) Login 08/06/2019 15:04:48 PMG VOA254 HS 19060423-02 S-3 (API Water) Login 08/06/2019 15:04:48 PMG VOA254 HS 19060423-03 S-5 (T-40) Login 08/06/2019 15:04:48 PMG VOA254 HS 19060423-04 Field Blank Login 08/06/2019 15:04:48 PMG VOA254 HS19060423-05 EQ Blank Port 1 Login 08/06/2019 15:04:48 PMG VOA254 HS 19060423-06 EQ Blank Port 2 Login 08/06/2019 15:04:48 PMG VOA254 HS 19060423-07 Duplicate Login 08/06/2019 15:04:48 PMG VOA254 HS 19060423-08 Trip Blank Login 08/06/2019 15:04:48 PMG VOA254 Page 24 of27 WWW HFNA-000003516 EPA Inspection Report - Page 1967 of 1969 AlS Houston, US Date: 20-Jun-19 Sample Receipt Checklist Client Name: Navajo Refining Date/Time Received: Q7-Jun-20t~Jli;.ll!l Work Order: HS19060423 Received by: NDR Checklist completed by: Paresh }vf Giga es,griature·" " ···-i Reviewed by: 8-Jun-2019 Date Corer Grandits 10-Jun-2019 eSign.ature.,;,,,,;,;,,,,.;;,___ _ _ __.:.:::.__: Date Matrices: Carrier name: Shipping container/cooler in good condition? Yes f;;] ::.. Not Present Custody seals intact on shipping container/cooler? Yes Yes ~ r. . . l Not Present Custody seals intact on sample bottles? VOA/TX1005/TX1006 Solids in hermetically sealed vials? Yes Chain of custody present? Yes [;;) .................::: l ~...............~ e:....................::: f'. . . ..1 ..._,._......-) :-...................::: Chain of custody signed when relinquished and received? Yes Samplers name present on COC? Yes Chain of custody agrees with sample labels? Yes f;.?l ::...................::: Yes Sample containers intact? Yes Sufficient sample volume for indicated test? Yes No L. . J Cl Not Present Not Present i Page(s) COC 1Ds:none h.~il ::... ................~;;: ~"~~· Samples in proper container/bottle? No ,, t~l ~¥*1 ::........................::: ~41 f;?l ::.................-::: ~..................::: All samples received within holding time? Containerrremp Blank temperature in compliance? ~----------~································ Temperature( s)!Thermome!er(s ): .5c U/c Cooler(s )/Kit(s ): azmatPak Dateffime sample(s) sent to storage: 7/19 20:00 ~~:: ~....~:-..... '• Water - VOA vials have zero headspace? Yes Water - pH acceptable upon receipt? Yes pH adjusted? Yes hff~ ::: ~.................... ~¥-fl :;......................:;: No VOA vials submitted 1""'1 L . .~~J N/A NIA pH adjusted by: Login Notes: Client Contacted: Date Contacted: Contacted By: Regarding: Person Contacted: Comments: Corrective Action: Page 25 of27 HFNA-000003517 EPA Inspection Report - Page 1968 of 1969 Chain of Custody Form Page ··::::I::::::~:::::::::::::::1r.l.#~~~~~:1~r~£!t~~~::::: ::::<:f(~!$~5ij ;;;f\;;t;~;.:~~~:: ;11 ~~~tii~ Tyler Turner ~~~ Gabl Comoo of I _L_ ·. .. . . Navajo Refining Company LLC _c:,, HS19060423 y,UT ?70() Navajo Rennin~ Company 'A BWiiliiiiilll 1!103 ;zaa ··me~~~~~~·«;~;~;·;::~;~;~~·~~:rw1-1~~~:t:~f.:M~Jy~1.$:::::::_:;:::):?::;::::: :i): ~AF,;,,·:. . ... : . : .. :.; ···! _ ............ .. :l?.:1 . : : : : : : :·:::: :01 ·,'., ~ P.O~~ 159 :""'.•.'""'•.. -'-.•.•'""'.""::c:.:c..:::..:.:-'"':::.;.:""'::..:,..,::-~- ){ 501 tast Main ~ :t: /?\}¥~(.~r~~~~ Artesia, NM 88211-0159 .t -.------------+~----.---. -:ti 1; 1a ;~ ~ . . ~-~ ~~ ntt e,.t:~;~~:~~-~#~~ ·•·· (API Water) :t~~:~~l:i: ,~;: k-.-..-.::::________tL. i {~} EQ Blank Port _1 .-~-,....:::<.;-<-,: • :::::;;:::: EQ Blank Port 2 ...~;'~>'•' ~---w ------ ---· 06/06119 06/06119 ) ( } Du~_l i~~-te- -------- · /ft Trip~ !~~~- ------- 1 l )( 2 : .............- - j - - - - )( 1 : ) ( Temperatu re Blank ,ftt~fN7tr:ins~=:i: ~~:!~:::~:~:~~:~:'.:::1::::::::::~::;: 00!her _ _ _ • ~ 0 2 Wk Day.; 0 24 Houri P-Chec!dist I "Tl z :r0 0 0 0 0 (,) 01 ...... OJ N0:m, A11y cn~n~ltl rmtM oo nMt'k In writing once Hmp!es and cqc row have been submittlild to AUi laboratory Group. I Page 26 of27 /!LP¥ (( :o,:right 2~0-9 by. c!'~i-9: ALS laboratory Group 1 EPA Inspection Report - Page 1969 of 1969 IJ•• "fthl..yr '(,li•loformotlon, you deolare • hlghor,mlue, pay on addltlonol ,hOl&Q, dervlC of domoge wheth<>r dlMct, incidental, tOM'"'!Uentlol, '" ,pecl•i I• limited !<>the greoterof $100 artho ""thartrnd cl,ed.sred val!.sG, R:eco~ry i:am,ot 'l'!Keeed actual documem:isd fa&$. MMmum fur ltenu of mct:rnordina.rv v&IBJ~ l:-t :$~0001 e.g. - ~ . pi esduu!S tiiebds, itegot!iible frnst1 uments and other tnmm"i!~d~fa1iaute:-Wt1tt~11·cts1m~ntnrsttfeift~-iW-·· within mlct time llmlts, ... current FedE 1.!,r; 81 ll.l~ ~iii O \ """ ~o c: 2 r """, ~c:::::ju,WAI~ ".J = "'a~~ ! !!!!!!'I· le!i! 0 m ...,, :!!!!i =:: 0 :.1:m me z -I X ~ o > :z: O ~ m !!lli -< Q ~ wj!i is Z 2 ; . i ---o¥*--,,-~- ,,__ ~ !---.%. . . . . ~ ... j!.... I 0 i0 ;;ti J! ~ ! ,,~ 'Tl 0 2!,!j :::::i • l ~ -< !El! _..... -..i z z .... , )::i-0 :r.,, Q :c~ 0Cl I i ~ c: t...l m ;:a ~! ::c <::ii -I>: ~ "Tl z :r0 0 0 0 0 (,) 01 ...... (!) Page 27 of 27 S51C11ll21Dllll4C ij~; ~i -"f(l 1;i I ..