Big West Oil Clean Air Act Settlement

(Denver, CO – August 23, 2013)  Big West Oil LLC has agreed to pay a $175,000 penalty and to spend approximately $18 million to install emission controls at its refinery in North Salt Lake, Utah, announced the Department of Justice and the U.S. Environmental Protection Agency (EPA) today. Big West Oil will also invest $253,000 to improve the monitoring and management of potential releases of hydrofluoric acid at the facility.

On this page:

• Overview of Company and Location of Facility
• Violations
• Injunctive Relief
• Supplemental Environmental Project 
• Pollutant Reductions
• Health and Environmental Effects
• Civil Penalty
• State Partner
• Comment Period
• Contact

Overview of Company and Location of Facility

Big West Oil operates a single refinery located in North Salt Lake City, Utah. Big West is a wholly owned subsidiary of FJ Management Inc. Big West supplies fuel products to customers in seven western states. Big West refines a combination of Utah, Wyoming and Canadian crude oils into motor fuels and other specialty chemicals. Big West also purchases and transports crude oil in Utah, Wyoming, and Colorado. The refinery has a capacity of 30,000 barrels per day.

Violations

The complaint alleges violations of Clean Air Act requirements covering the four main sources of emissions of SO₂, NO_x, VOCs, and benzene at the North Salt Lake City refinery:

• New Source Review/Prevention of Significant Deterioration (NSR/PSD), 40 C.F.R. Part 52
  • Fluid Catalytic Cracking Unit (FCCU)
  • Refinery Heaters and Boilers

• New Source Performance Standards (NSPS), 40 C.F.R. Part 60, Subparts A & J
  • Flares
  • Sulfur Recovery Units
  • Fuel Gas Combustion Devices (including heaters & boilers)
  • FCCU Catalyst Regenerators

• National Emission Standards for Hazardous Air Pollutants (NESHAP) for benzene wastes, 40 C.F.R. Part 61, Subpart FF
• Leak Detection and Repair (LDAR), 40 C.F.R. Part 60, Subpart VV and GGG;  40 C.F.R. Part 61, Subparts J and V; and 40 C.F.R. Part 63, Subparts F, H, and CC 

Injunctive Relief

The consent decree requires the following actions at the North Salt Lake City refinery, at an estimated cost of $18 million.

NSR/PSD

• Big West must comply with a final NO_x limit of 40 ppm (365-day, long-term) and 60 ppm (7-day, short-term).
• Big West must comply with a final SO₂ emissions limit of 25 ppm SO₂ (long-term) and 50 ppm SO₂ (short-term).
• Big West must comply with a FCCU emission limit of 0.5 pounds of PM per 1,000 pounds of coke burned on a 3-hour average basis by installing a Pall filter.
• Big West must also comply with the NSPS emission limit for carbon monoxide (CO) of 500 ppm on a 1-hour average.
• Big West must install and operate a Continuous Opacity Monitoring System (COMS) to monitor opacity at the FCCU.

NSPS and Flaring

• Big West will install next generation ultra low NO_x burners and meet emission limits of 0.035 lbs./mmBTU on 4 covered heaters and boilers.
• Big West will eliminate burning fuel oil in any refinery combustion device. 
• Big West will comply with SO₂ standards of NSPS Subpart J for all combustion devices burning refinery fuel gas.
• Big West will install two caustic scrubber systems on its sulfur recovery plant (SRP) and re-route all sulfur pit gases at the SRP so that sulfur pit gases are eliminated as a direct source of emissions.
• NSPS Subpart Ja will apply to Big West’s two flares and the company will install H₂S CEMS on its flares.
• Big West will comply with NSPS Subpart A, General Provisions, 40 C.F.R. § 60.11 (d), by conducting root cause analyses for all flaring events exceeding 500 lb/day of SO_2.

Benzene Waste National Emissions Standards for Hazardous Air Pollutants (NESHAP)

• Maintain facility waste at less than 10 megagrams (Mg) of total annual benzene (TAB) per year.
• Comply with the “6 BQ” compliance option for benzene if TAB exceeds 10 Mg.

Leak Detection and Repair (LDAR) Program

• Comply with LDAR requirements refinery-wide.
• Conduct training (including refresher courses) for refinery personnel with LDAR responsibility.
• Require LDAR compliance audits.
• Adopt strict internal leak definitions (500 ppm for valves and 2000 ppm for pumps).
• For valve leaks above 200 ppm, institute “internal first attempt at repair” procedures.  
• Install certified low-leaking valves or certified low-leaking valve packing technology for all newly-installed valves.
• Adopt more stringent chronic leaker definition (valve that leaks above 10,000 ppm twice in any two quarters between turnarounds must be completely replaced).

Supplemental Environmental Project (SEP)

Big West will install a laser detection system that will provide enhanced and earlier detection of hydrofluoric acid (HF) at the HF alkylation unit and perimeter of the Refinery, providing benefits to the Refinery workers and to the community. Even low level exposure to HF can cause serious health problems and even death. Breathing HF can burn lung tissue and cause swelling and fluid accumulation in the lungs; skin contact with HF may cause severe burns; HF gas can irritate the eyes, nose, and respiratory tract. The cost of the HF SEP is $253,000.

Pollutant Reductions

Once all emissions controls have been installed and implemented, this settlement is estimated to result in the following emissions reductions:

• 158 tpy of SO₂
• 32 tpy of NO_x
• The settlement will also result in additional reductions of volatile organic compounds, particulate matter, and carbon monoxide.

Health and Environmental Effects

• Nitrogen Oxides – Nitrogen oxides can cause ground-level ozone, acid rain, particulate matter, global warming, water quality deterioration, and visual impairment. Nitrogen oxides play a major role, with volatile organic chemicals, in the atmospheric reactions that produce ozone.  Children, people with lung diseases such as asthma, and people who work or exercise outside are susceptible to adverse effects such as damage to lung tissue and reduction in lung function.

• Sulfur Dioxide – High concentrations of SO2 affect breathing and may aggravate existing respiratory and cardiovascular disease. Sensitive populations include asthmatics, individuals with bronchitis or emphysema, children and the elderly. Sulfur dioxide is also a primary contributor to acid deposition, or acid rain.

• Volatile Organic Compounds - VOCs, along with NOx, play a major role in the atmospheric reactions that produce ozone, which is the primary constituent of smog.  People with lung disease, children, older adults, and people who are active can be affected when ozone levels are unhealthy. Ground-level ozone exposure is linked to a variety of short-term health problems, including lung irritation and difficulty breathing, as well as long-term problems, such as permanent lung damage from repeated exposure, aggravated asthma, reduced lung capacity, and increased susceptibility to respiratory illnesses such as pneumonia and bronchitis.

• Benzene - Acute (short-term) inhalation exposure of humans to benzene may cause drowsiness, dizziness, headaches, as well as eye, skin, and respiratory tract irritation, and, at high levels, unconsciousness.  Chronic (long-term) inhalation exposure has caused various disorders in the blood, including reduced numbers of red blood cells and anemia in occupational settings.  Reproductive effects have been reported for women exposed by inhalation to high levels, and adverse effects on the developing fetus have been observed in animal tests.  Increased incidences of leukemia have been observed in humans occupationally exposed to benzene.  EPA has classified benzene as a Group A human carcinogen.

Civil Penalty

Big West will pay a $175,000 civil penalty as follows:

• $157,500 to the United States
• $17,500 to the State of Utah

State Partner

The State of Utah participated in the settlement negotiations as a co-plaintiff and is a signatory to the Consent Decree.

Comment Period

The proposed settlement is lodged in the U.S. District Court for the District of Utah.  The consent decree will be subject to a 30-day public comment period and final court approval.  Information on submitting comments is available at the Department of Justice website.

Petroleum Refinery National Initiative Case Results

Through multi-issue, multi-facility settlements or detailed investigations and aggressive enforcement, this national priority addresses the most significant Clean Air Act compliance concerns affecting the petroleum refining industry.

See EPA’s National Petroleum Refining Initiative website for more information.

For more information, contact:

Technical Contact
Patrick W. Foley
Senior Environmental Engineer
U.S. Environmental Protection Agency (2242A)
1200 Pennsylvania Ave., N.W.
Washington, DC 20460
(202) 564-7978
Patrick Foley ([email protected])

Legal Contact
Melanie Shepherdson, Attorney
U.S. Environmental Protection Agency (2242A)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
(202) 564-8386
Melanie Shepherdson ([email protected])