Holly Oil Refinery

EPA Considers Tougher Emission standards for Oil Refineries

2009-07-02T09:03:00.000-07:00

Here is an interesting article on the affects of benzine and other cancer causing emissions from oil refineries:

http://www.bloomberg.com/apps/news?pid=20601109&sid=aRHl__xeTUH

It says that EPA is now considering tougher standards. Perhaps, as a minimum, we should begin to more closely monitor the emissions and at least notify the public as to the level of emissions currently coming from the Holly Oil Refinery.

Proposed 'petcoke' power plant canceled

2009-05-14T20:22:00.000-07:00

The Salt Lake Tribune is reporting that the process for permitting the proposed petroleum coke plant in West Bountiful has expired and the Division of Air Quality will not act on the original permit request. This is good news for the residents of West Bountiful who have been concerned about the environmental affects that a co-generation plant would have on our community. However, I have been told by representatives of Consolidated Energy Services that it is their hope to design another co-generation plant which burns other petroleum-based fuels.

It is rumored that some of the primary investors behind the co-gen project have been reluctant to move forward with the proposed plant due to the public outcry over the original proposal. So it is possible that Consolidated Energy Services may not be able to continue with the project. On the other hand, the firm appears to have made a commitment to Holly Oil to try to develop an alternative design that will still provide the high pressure steam required by Holly's oil refining process. We anticipate that if Consolidated Energy Services is not successful in developing a new plant design, Holly Oil will still need to engage another firm to design a steam generating plant or the company will build a co-gen plant on its own.

During the past five months, Representative Roger Barrus and I have worked together to encourage Consolidated Energy Services and Holly Oil to develop an environmentally sound solution to the plant's steam generation needs. Roger and I will continue to work closely with those interested in building the co-gen plant and will make sure that whatever solution is selected, that it will reduce rather than add to the emissions from the Holly Oil Refinery.

Furthermore, it appears that Consolidated Energy Services is willing to work more closely with the local community than it did during its prior proposal. We pointed out that during the last go around, Consolidated Energy Services began the process by submitting a petition to the Division of Air Quality. This proposal came as a complete surprise to local city officials. We have advised the firm, and they have agreed, that before they seek state approval for a new co-gen plant, that they will first present their design to West Bountiful City and give our community an opportunity to consider the impacts. As a result, we expect to be much more involved in the process when and if new plans are developed. We will certainly provide notice to our residents when and if we receive a new proposal.

Proposed Co-Generation Power Plant for Holly Oil Refinery

2008-11-26T19:20:00.000-08:00

KSL news has recently reported that the Utah Department of Environmental Quality has issued a permit for the construction of a co-power generation plant next to Holly Oil. The city has not yet received an application for the construction of such a plant. However the city has received proposed site plans for such a site which we essentially rejected. The footprint for the plant was much larger than we would tolerate on that site, taking up nearly half of the buffer zone between the plant and the neighboring residents. The story can be viewed at:

Video Courtesy of KSL.com

Overview of Holly Study

2008-11-17T20:51:00.001-08:00

Bowen and Collins is a consulting firm hired by West Bountiful City to examine the environmental affects of Holly Oil Refinery. Even though they have not yet completed all of the assigned study areas, I've decided to post the completed studies on this blogsite. The only remaining study, an assessment of any groundwater contamination, is expected to be completed in the coming weeks. You can best access the study topics by clicking on the title in the Blog Archive section above.

Centralized Data Storage

2008-11-17T20:43:00.003-08:00

Approach

This assessment is being performed to identify plausible methods for collecting and centrally storing pertinent environmental information that would be readily accessible to residents and the general public. Specifically, a list of key information that may be of interest to the community, what benefit the information would provide to the community, how the information could be provided, where the information could be centrally stored, and which entity will be responsible to maintain and update the information.

Currently there is abundant environmental data available to the public about emissions, chemicals, and proposed operational changes at the Holly Refining facility. A key element in the public's ability to access desired information is an understanding of which regulatory agencies the data and reports can be requested. Currently, Holly Refining is required to submit regular environmental reports to EPA region VIII, the Utah Department of Environmental Quality (UDEQ), the Utah Division of Air Quality (UDAQ), The Utah Division of Water Quality (UDWQ), the Division of Solid and Hazardous Waste (DSHW), the Utah Division of Radiation Control (UDRC), and local emergency response agencies. The data, detail, and frequency of the regular reports are governed and driven by several federal and state rules. These rules are administered by several different agencies.

This assessment will outline the existing environmental data that is available to the public and the regulatory agency that administers and enforces the environmental reporting for the different media.

Background

Currently, Holly Refining is only obligated by Federal and State rules to submit environmental reports directly to the regulating agencies. There is no rule or statue requiring Holly to provide environmental reports to the community or citizens. The following are a list of State agencies that regulate Holly Refining activities along with a listing of environmental regulations that the agencies regulate.

Utah Department of Environmental Quality (UDEQ)
Utah Division of Air Quality (UDAQ)
- Authority to Regulate
  - Federal Clean Air Act
  - Utah Air Conservation Act
Utah Division of Drinking Water
- Authority to Regulate
  - Federal Safe Drinking Water Act
  - Utah Safe Drinking Water Act
Division of Environmental Response and Remediation
- Authority to Regulate
  - Comprehensive Environmental Response Compensation and Liability Act (CERCLA)
  - Emergency Planning and Community Right to Know Act (SARA Title III)
  - Subtitle I of Resource Conservation and Recovery Act (RCRA)
  - Underground Storage Tank Program
  - Voluntary Cleanup Program
  - Brownfields Redevelopment Program
Division of Solid and Hazardous Waste (DSHW)
- Authority to Regulate
  - Federal Resource Conservation and Recovery Act (RCRA)
  - Utah Solid and Hazardous Waste Act
  - Utah Used Oil Management Act
  - Waste Tire Recycling Act
Division of Water Quality
- Authority to Regulate
  - Federal Clean Water Act
  - Utah Water Quality Act
Division of Radiation COntrol
- Authority to Regulate
  - State Radiation Control Act
  - Federal Atomic Energy Act

The Environmental Protection Agency (EPA) is responsible to develop and enforce regulations that implement environmental laws enacted by Congress. EPA is responsible for researching and setting national standards for a variety of environmental programs, and delegates to states and tribes the responsibility for issuing permits and for monitoring and enforcing compliance. EPA delegates authority to UDEQ to administer and enforce the environmental regulations in the state of Utah. Where industries and environmental programs do not meet national standards, EPA can over file on UDEQ and issue sanctions and take other necessary steps to assist the state in reaching the desired levels of environmental quality. EPA is organizationally divided into 10 regional sections. The states of Utah , Colorado, Wyoming, Montana, North Dakota, and South Dakota all fall under EPA Region VIII, which is headquartered in Denver, CO.

Any regulatory document in possession by EPA or the state agencies listed above can be accessed via the Government Records Access and Management Act (GRAMA) request or the Freedom of Information Act (FOIA). These acts allow the public to request copies of records in the possession of federal agencies. According to federal regulations, FOIA requests for records from EPA must be submitted in writing to the Freedom of Information Officer. The requested records are typically released unless the record falls into one of the nine exemptions set forth under the Act. UDEQ records are available under the GRAMA rules. The two stated primary objectives of the GRAMA provisions are to provide the public's right of access to information concerning the conduct of the public's business; and to maintain the right of privacy in relation to personal data gathered by governmental entities. The Utah GRAMA Law is further outlined in detail in UACR 63-2-1001 through UACR 623-2-1001

Review

A review of the Holly Refining environmental reports and other data stored by UDEQ and EPA found that it is scattered among several agencies and may prove difficult to community citizens to acquire the specific information they are seeking without a more in-depth understanding of environmental programs. The following table lists contact information for the state and federal agencies and associated regulatory documents that Holly has submitted. The list is not to be considered comprehensive, but rather as a general guide of key agencies, environmental reports of potential interest, and contact information.

Agency: EPA Region VIII
Contact:	Office Location:
Frank Montarelli (303) 312-6780 montarelli.frank@epa.gov	US EPA Region 8 8OC-EISC 1595 Wynkoop St Denver, CO 80202-1129
Key Environmental Reports
All reports submitted to EPA are duplicate copies of media specific reports submitted directly to individual Utah State Divisions listed below

Agency: UDEQ
Director:	Office Location:
Rick Sprott Executive Director (801) 536-4404 rsprott@utah.gov	168 North 1950 West P.O. Box 144810 Salt Lake City, UT 84114-4810 Telephone: (801) 536-4402 Fax: (801) 536-0061 Website: http://www.deq.utah.gov
Key Environmental Reports	Report Contents
No reports are submitted directly to UDEQ. Reports are submitted directly to the regulating division with authority to regulate activities.

Agency: UDAQ
Director:	Office Location:
Cheryl Heying Director (801) 536-4415 cheying@utah.gov	150 North 1950 West P.O. Box 144820 Salt Lake City, UT 84114-4810 Telephone: (801) 536-4000 Fax: (801) 536-4099 Website: http://www.airquality.utah.gov
Key Environmental Reports	Report Content
Air Emissions Inventory (AEI)	Summary of regulated emissions emitted
Approval Orders	Operating conditions for facility operation
Notices of Intent	Proposed changes and associated emissions
RMP – Risk Management Plan	Facility plan to manage risk of chemicals on site
UDAQ Inspection Reports	Periodic UDAQ inspections of facility for compliance determinations

Agency: UDDW
Director:	Office Location:
Ken Bousfield Acting Director (801) 536-4207 kbousfield@utah.gov	150 North 1950 West 2^nd Floor P.O. Box 144830 Salt Lake City, UT 84114-4810 Telephone: (801) 536-4200 Fax: (801) 536-4211 Website: http://www.drinkingwater.utah.gov
Key Environmental Reports	Content
Compliance Monitoring Reports	Compliance reports for drinking water

Agency: UDERR
Director:	Office Location:
Brad Johnson Director (801) 536-4170 btjohnson@utah.gov	168 North 1950 West 1^st Floor P.O. Box 144810 Salt Lake City, UT 84114-4810 Telephone: (801) 536-4100 Fax: (801) 359-8853 Website: http://www.environmentalresponse.utah.gov
Key Environmental Reports	Content
Remedial Investigations Reports (RI)	Groundwater contamination investigation and findings
Groundwater Sampling Reports	Summary of groundwater sampling activities
Tier II Report	Summary of chemical use and activities on site

Agency: DSHW
Director:	Office Location:
Dennis Downs Director (801) 536-6170 ddowns@utah.gov	288 North 1460 West P.O. Box 144880 Salt Lake City, UT 84114-4810 Telephone: (801) 536-6170 Fax: (801) 538-6715 Website: http://www.hazardouswaste.utah.gov
Key Environmental Reports	Content
Waste Characterization Reports	Hazardous waste sampling and profiles
Biennial Hazardous Waste Report	Summary of hazardous waste activities on site

Agency: UDWQ
Director:	Office Location:
Walt Baker Director (801) 536-6147 wbaker@utah.gov	288 North 1460 West P.O. Box 144870 Salt Lake City, UT 84114-4810 Telephone: (801) 536-6146 Fax: (801) 538-6016 Website: http://www.waterquality.utah.gov
Key Environmental Reports	Content
UPDES – Utah Pollutant Discharge Elimination System Permit	Permit to discharge water from the facility
SWPPP – Storm Water Pollution Prevention Plan	Plan to minimize and mitigate contamination of storm water
SPCC - Spill Prevention, Control and Countermeasures Plan	Plan to minimize and mitigate potential spills of oils

All desired environmental reports and associated data sets can be directly accessed through these agencies by the citizens in the community. To reduce the potential repetitive requests to these agencies by several concerned citizens or groups in the community a centralized storage and retrieval option of the environmental reports and data should be considered.

Benefits of a centralized data storage system include four main areas:

A single centralized location for citizens and groups to find environmental data and reports without a detailed understanding of environmental rules and regulations that require facilities to perform monitoring, keep records, and submit reports.
A centralized system of housing environmental data and reports in the community can be scaled and expanded to include other facilities, operations, and companies that the citizens, community, or groups have an interest in becoming involved.
A centralized system will limit the impacts upon Holly staff in continually supporting repeated data requests from non regulating entities.
A centralized system will better inform and involve the community in the businesses and operations in the community that have an environmental impact on the surroundings.

Recommendations

Issues to consider in identifying options include consideration of what resources are available to host data, accessibility to the general community, and what additional reporting burden is placed on Holly Refining, if any. Scalability and sustainability of a centralized data storage program that includes other regulated sources and industries in the community should also be considered. A comprehensive list of issues considered during the evaluation of options includes:

Scalability of the program to other industrial sources and operations
Sustainability of maintaining and updating environmental data and reports
Minimal reporting burden on industrial sources and staff
Data accessibility to the community
Centralized location for differing types of media including environmental data and reports

Based on these factors, the best agency or group to host the data is West Bountiful City. West Bountiful City is an interested organization that has physical resources available to host and maintain data from multiple industrial sources and provide relative ease in access to the citizens. It is recommended that the City utilize their website to host and distribute reports to the community and citizens. It is also recommended that the city request past environmental reports and data submitted to the individual regulatory agencies and provide Adobe Portable Document Format (PDF) versions of the reports on the city's website. Individuals without internet or web access could physically request records at the City offices. This system will provide access either online or at the city offices with minimal photocopying and reproduction of bulky reports. It will also reduce repetitive data requests from the regulating agencies and minimize potential resource requirements of Holly staff. This system allows for future scalability to include other industrial sources that may have an environmental impact in the community.

It is also recommended that Holly Refining and other potential industrial sources provide a voluntary courtesy copy of any regulatory driven future reporting to the city as a service to streamline and support the public access and involvement. This will increase the sustainability of the program and also reduce the burden to the city, EPA, and UDEQ of consistently requesting data and reports. It should be noted that there are no regulatory drivers to require industries or sources to participate in this type of program. Any involvement from the sources would and should be voluntary in an effort to be further integrated into the community in which they operate.

West Bountiful City should identify the environmental areas of concern impacting local residence, to outline the primary environmental reports that contain the data residence are seeking. Not all require regulatory reports that Holly Refining generates and submits to regulatory agencies will be of interest or concern to the community. Based on preliminary information of community concerns, the annual air emissions inventory report, the toxic release inventory report, the spill prevention controls and countermeasures (SPCC) plan, and periodic ground water monitoring reports will contain the greatest concentration of environmental data, emissions, and facility controls and procedures concerning citizens.

Conclusions

Bowen Collins & Associates recommends the City of West Bountiful to be the centralized entity for collecting and hosting environmental data and reports for the community, citizens, and interested groups. West Bountiful City should request key historical documents from the appropriate regulatory agencies and make them available in PDF format via the City web page. The city should also request courtesy copies of key future regulatory reporting required by Holly Refining that is of interest to the citizens and community.

Chemical Storage

2008-11-17T20:43:00.001-08:00

Approach

The assessment of the chemical storage and usage at the Holly Refining facility included using metrics and thresholds from several federal and state guidelines, rules, regulations and standards. In 1990, Congress made extensive amendments to the Clean Air Act (CAA) and added Section 112(r) that requires owners and operators for stationary sources to identify hazards, and prevent, and minimize the effects of accidental releases whenever extremely hazardous substances (EHS) are present at their facility. All facilities are required to either submit and implement a Risk Management Plan (RMP) or comply with the General Duty Clause (GDC). Facilities that have hazardous substances exceeding any threshold quantity for any one of 140 regulated compounds are required to submit a RMP to both Federal and sate agencies. The RMP submittal is a formal process that requires significant documentation for hazard assessments, prevention programs, and emergency response programs as well as detailed coordination with municipal, state, and federal government agencies. Facilities that have hazardous substances, which do not exceed any threshold quantity, fall under the general provisions of the GDC of the CAA that do not require the formalities of the RMP. In general, the GDC requires "owners and operators…to identify hazards which may result from…releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur."

Emergency Planning and Community Right-to-Know Act (EPCRA) regulates the emergency release notification requirements for facilities. If an accidental chemical release exceeds the applicable minimal reportable quantity, the facility must notify State Emergency Response Commissions (SERCs) and Local Emergency Planning Committees (LEPCs) for any area likely to be affected by the release and the National Response Center. This notification is also followed by a detailed written follow-up as soon as practicable. Information about accidental chemical releases must be made available to the public. The EPCRA consolidated chemical list can be found on EPA's website at the following internet address: http://epa.gov/OEM/content/epcra/epcra_report.htm#regulated. The list contains a consolidated list of chemicals subject to the Emergency Planning and Community Right-To-Know Act (EPCRA) and Section 112(r) of the Clean Air Act.

Background

The risks associated with the refining industry are commensurate with the nature of the operations. Apart from their utility, crude oils being refined have their own inherent properties and hazards. The inherent hazards include flammability, explosivity, toxicity, and/or corrosivity. The whole lifecycle of refining crude oils were considered when assessing the operational dangers.

Although improper facility and process layout can adversely affect potential dangers from chemicals onsite, no site specific facility engineering review was performed by BC&A. This type and level of evaluation is beyond the scope of BC&A's contract review. Issues such as location of the plant in relation to the tank farm, emergency response resources near processing areas, process areas close to public roads, and wrong material selection for equipment can all be items of potential concern. Other program areas not reviewed but with potential impacts to chemicals stored, processed, and used onsite include the following areas:

Electrical Safety – A review of hazardous concerns involving electrical components including:

Hazardous Area Classification (base standard: IS 5572)
Selection of Electrical Equipment for Hazardous Areas (base standard: IS 5571)
Lightning Protection (base document: IS: 2309 /NFPA 780 /BS 6651)
NFPA 70 B Recommended Practice for Electrical Equipment Maintenance
NFPA 70 E Standard for Electrical Safety in Employee Work places
Identification & Control of Electro-Static Hazards
Electrical Risk Assessment (fire, shock explosion) using Semi-Quantitative Risk Ranking (SQRR) technique

Process Safety Management – A hazardous operation assessment (HAZOP) including a reliability assessment of process equipment including:

Hazard & Operability (HAZOP) studies
Failure Tree Analysis (FTA)
Event Tree Analysis (ETA)
Primary Hazard Analysis (PHA)
Risk Assessment (with risk ranking technique)

Fire Protection – A review of adequate fire protection that meets National Fire Protection Act (NFPA) guidelines including:

Identification & assessment of fire risks during operations in receipt, storage, transfer and handling of chemicals (raw materials and finished products)
Identification & control of ignition sources in areas where flammable chemicals are stored / handled / transferred
Review of chemical compatibility in storage areas and to suggest appropriate fire loss control measures
Review of fire detection measures adopted in the plant & to suggest suitable improvement measures
Review of the various active (fire hydrant, sprinkler, portable fire extinguishers) and passive fire protection requirements for chemical storage and handling areas and to suggest improvements as necessary
Review of contractor safety awareness (chemical spill, fire fighting, emergency communication, knowledge of plant hazards & safety regulations) and to recommend suitable improvement measures to enhance contractor safety
Review of safety awareness and safety training requirements (training identification and efficacy) of plant employees with respect to hazards present in the plant

Safety Audits - Periodical assessment of safety procedures and practices, performance of safety systems and plans including:

Identification of scenarios of potential disasters / emergencies leading to loss of life, property damage etc. and qualitative assessment of their likelihood.
Quantitative risk assessment for selected scenarios of major credible events.
Recommendations for risk control measures wherever applicable.
Preparation of onsite emergency preparedness plan

It should be noted that the initial data and information presented to BC&A during the assessment review indicated that these areas of potential concern have been adequately addressed by Holly Refining. Although a review in these programs were outside BC&A's scope of services, no issues were identified to raise potential concerns in this area.

Review

A review of Holly Refining chemical storage on site yielded that there are several Risk Management Plan (RMP) regulated chemicals at the refinery as either process intermediates or finished produces. The RMP regulated flammable substances are typically mixtures of gas subcomponents such as butane, pentane, ethane, propane, and methane. These flammable mixtures can be found in varying concentrations in most refining processes at the facility.

There is only one RMP regulated toxic chemical onsite above the reportable quantity (RQ). Hydrofluoric (HF) acid is above the RMP RQ threshold and is used in and primarily limited to the alkylation unit.

There are other chemicals in varying amounts that have fire hazard potential, risks of sudden releases due to process pressure, and chemical reactivity potential with both acute (immediate) and chronic (delayed) effects. These chemicals have all been quantified and accurately reported on the Toxic Release Inventory (TRI) by Holly Refining.

There have been no reportable accidents in the last 5 years at the Holly site, as regulated by the RMP rules.

Risks

Scoping a facility-level risk assessment defines what is and is not to be included. A proper risk analysis identifies the chemical sources of concern, the potential exposure pathways, potential exposed populations, and the potential health effects due to exposure. A worst case scenario (WCS) assessment associated with toxic substances is a catastrophic release of maximum quantities possible. No consideration is typically given to any existing active or passive mitigation controls while evaluating probable consequences. While there may be no credible evidence, precedence, or practical probability of the WCS occurring, RMP regulations require the analysis to be conducted for proper facility planning.

An alternate case scenario (ACS) is typically a more probable scenario that estimates a release or failure that poses a risk to the facility and surrounding community. In the ACS, credit is given to existing active and passive mitigation controls to reflect the facilities response to the incident. Active and passive controls can be things such as alarms, automated shut off valves, facility staff intervention, or emergency response procedures.

There are four main pathways of potential exposure or harm to the surrounding community. These are a gaseous release to the atmosphere, a liquid release to the ground surface or waters, a release to soils and subsurface ground waters, and flammable explosions. There are both potential acute and chronic dangers from each of these release pathways. RMP evaluations only address potential atmospheric releases and are not inclusive of releases to the surface or groundwater.

Evaluations for both WCS and ACS associated with toxic substances at Holly Refining were conducted by Holly in development of their RMP plan. A WCS for a catastrophic release of 74,200 lbs HF acid from the alkylation settler/cooler vessels was modeled to determine maximum impacts. This WCS is not highly probably and there have been no similar historical credible scenarios furthering support of this estimation. The more probable ACS release of a piping leak was also modeled. It was assumed that a 0.2" diameter process piping leak of HF acid occurred for 12 minutes, releasing approximate total mass of 27 lbs. The scenario included both active and passive control mitigation including water spray/deluge systems, rapid acid transfer system, ReVap process, audible alarms, and operator interventions. The ReVAP catalyst is a proprietary system to Holly and can achieve a 60 to 90% reduction in airborne catalyst vapors, if a leak were to occur, when compared to traditional HF catalyst systems. This process has significantly reduced the societal risk associated with a potential leak, allowing a higher level of protection to the surrounding community. Modeling of the HF ACS yielded a maximum distance to the toxic concentration endpoint of 0.016 mg/l at 316 feet from the leak source using EPA's OCA Guidance Reference Equations. The maximum distance fell within the facilities fence line and does not result in an offsite impact in the community.

Evaluations were also conducted for a WCS and ACS associated with flammable substances for the facility. The WCS for flammable substances estimated a vapor cloud explosion (VCE) involving 1,045,800 lbs of natural gas liquids from a storage tank in the west tank farm. The natural gas liquids or liquid petroleum gas (LPG) included propane, butane, isobutane, and pentane. The maximum quantity was derived from estimations of the maximum quantity that could be released from the largest LPG tank resulting in a VCE. The WCS did not include active of passive mitigation controls, as per RMP regulations, and according to previous risk studies performed in accordance with API RP 752, a VCE of this type would most likely not occur. The most probable ACS associated with flammable substances is a VCE or flash fire involving a release of butane caused by a hose leak during railcar loading in the east tank farm. The ACS estimated approximately 11,200 lbs of butane are released over a 10 minute period. Credit for active and passive mitigation controls were applied for this scenario. These controls included combustible gas detectors, high flow shutoff valves, fire waters monitors, and operator intervention. The maximum distance to an explosion pressure differential of 1 pound per square inch (psi) endpoint (or lower flammability level) was 316 feet calculated using EPA's OCA Guidance Reference Equations. This distance exceeds the fence line boundary and could potentially impact the public roadway of 800 West between the railcar loading spur and the processing units.

Holly refining has an RMP document in place that outlines the chemical risks and mitigation measures being performed by Holly to minimize those risks. The facility is also subject to the OSHA process safety management (PSM) standard that was promulgated in 1992. Programmatic elements from the PSM standard have been implemented and in place for several years.

A process hazard analysis (PHA) has been conducted by the facility for each process. The facility followed the hazard and operability study technique (HAZOP) methodology in performing all PHAs. The PHA(s) are a systemic and methodical study of the processes, equipment, operations, and chemicals onsite to identify and analyze the significance of potential hazards that exist. The PHA(s) provide sensitive information to the refinery management and employees in making decisions for improving the safety and reducing the consequences of undesirable or unplanned release of highly hazardous chemicals. All PHA findings were classified into one of two categories. The categories are Recommendations which are issues that could result in a catastrophic event and Advisories which are issues that could lead to injury or damage to property/environment but will not lead to a catastrophic event. Operating procedures, training, maintenance, and safe work practices have all been used to address individual process specific PHA findings. A compliance audit is conducted at the facility at least once every three years by a combination of internal staff and third party auditors to confirm mitigation measures and identify potential new hazards. Public release of specific PHA's conducted at the facility is not advisable for security reasons and no details of audit findings will be given in this report. All audit findings are addressed by plant management to mitigate risk to the employees and community.

Conclusions

A review of the chemicals stored onsite, flammable substances, and the risk management plan indicated that Holly Refining is complying with the applicable rules and regulations of the Emergency Planning and Community Right-To-Know Act (EPCRA) and Section 112(r) of the Clean Air Act. Holly Refining has identified potential hazards through facility PHAs and implemented policies, procedures, and controls to prevent and minimize the potential effects of accidental releases of extremely hazardous substances (EHS) that are present at the facility. Holly Refining was required to submit and implement a Risk Management Plan (RMP) for the Woods Cross facility. The RMP was prepared and submitted to the regulatory authorities and was most recently updated in January of 2007. The RMP was prepared in accordance with industry standards and a WCS and ACS scenarios were modeled in accordance with EPA's OCA Guidance Reference Equations. Pending physical construction completion of the proposed modifications at the facility, Holly Refining will need to revisit the RMP to make any necessary changes or modifications to the plan as identified in specific PHA(s) for the modified processes, equipment, and facility.

2008-11-17T20:42:00.001-08:00

Assessment of Odors from Facility Operations

Approach

The assessment of the Holly Refining odor releases included a review of existing formal and informal odor complaint identification and corrective action mitigation measures. Currently, federal and state air quality regulations are in place to protect human health and ecology and are not tailored to solely address odor. The primary reason for this condition is that odor is extremely subjective to individuals, populations, and communities.

Odor mitigation regulations are primarily dealt with on a community by community basis through local nuisance ordinances. Since odors and smells are subjective, there are no direct quantitative measures for applying regulations or emission limits to operations for the sole purpose of odor. There are qualitative tools and parametric monitoring techniques that can be utilized to identify potential odor sources for mitigation purposes. Odor sources that can be directly tied to a chemical analyte can then be regulated through more quantitative emission concentration standards.

The odor assessment consisted primarily of an evaluation of the procedures, policies, and practices in place at Holly Refining to identify odor sources. The assessment also included plant mitigation activities to control odorous chemical emissions and comparisons to other industry best practices for odor elimination.

Background

The study of odors is a growing field but is a complex and difficult one. The human olfactory system can detect many thousands of scents based on only very minute airborne concentrations of a chemical. The study of odors is also further complicated due to the complex chemistry taking place at the moment of a smell sensation. Odors must be linked back to a chemical compound causing the fragrance or smell in order to qualitatively and quantitatively identify and control the source compound, if it is deemed economically and technically feasible to do so.

Ambient air in the community holds a mixture of odorous chemical (odorants) from the everyday activities of its citizens and the commercial and industrial enterprises that exist in the area. The daily exposure to odorants is a part of life and a part of the community. However, from time to time, citizens and individuals may find some odors objectionable and a nuisance.

As previously noted there are no direct ordinances in West Bountiful City or implemented by UDAQ to regulate air emissions solely for the purpose of odor control. This is primarily due to UDAQ regulating emissions and ambient air concentrations based on health standards. The Occupational Health and Safety Administration (OSHA) have established work place air standards. Although there are OSHA workplace standards in place, many compounds can be detected at relatively low ambient air concentrations. The compound's air concentration will be detectable by smell well before a regulatory health limit is exceeded which would enact stricter air emission controls or emission limits through existing regulations. For illustration purposes, here are a few of the HAP compounds released by Holly in 2006 and their associated workplace and odor detection threshold values.

Compound	*Workplace Threshold (mg/m³)**	Odor Threshold (mg/m³)**
Benzene	0.3	5
Toluene	377	10
Xylene	434	8
Naphthalene	52	0.5
Formaldehyde	1.2	0.1
* Workplace air standards as presented by either ACGIH (TLVs) or NIOSH (TWAs). Where two values were listed, the more conservative (lower) of the two is presented. Values are not equivalent to residential exposure.
**Odor Threshold is a rough estimate of the lowest concentration in air noticeable by smell as presented in Verschueren (1983)

Another key issue related to odor regulations is the several technical challenges related to odor identification, monitoring, and enforcement. This issue is further compounded by a phenomenon known as olfactory fatigue. Olfactory fatigue is a temporary adaptation of the normal inability to distinguish a particular odor after a prolonged exposure to that airborne compound. Olfactory fatigue is very similar to neural adaptation or sensory adaptation. Human bodies become desensitized to stimuli in order to prevent the over loading of the nervous system, thus allowing it to respond to new stimuli. Depending on a citizen's individual exposure to air in the community, some smells may be strong and offensive, while others may not notice significant odors being present. This was expressed, in the odor complaint data reviewed, when an individual drives from another location through West Bountiful City and calls to report foul and offensive odors.

The most significant technical challenge associated with regulating odors is that an identified odor must be traced back to an individual chemical compound that can be monitored. Without direct correlations to a monitored chemical compound, compliance and enforcement become subjective and problematic. Some smells and odors are a combination of chemicals and compounds thus requiring multiple compounds to be monitored. Further complications present themselves as chemical reactions take place in ambient air from multiple sources to create nuisance odors.

Best Management Practices (BMPs) for sources with significant odor problems from industrial activities or biogenic sources, such as concentrated animal feed farms, require sources to implement an odor mitigation plan. The odor abatement or mitigation plan may include, but is usually not limited to, provisions for documentation of structural emission controls, citizen complaints, corrective action measures, documentation of site specific Best Management Practices (BMP), and other recordkeeping provisions. More specifically, an odor abatement plan addresses the specific methods of odor reduction that are tailored to each facility and are created to address each cause of odor of concern. The plan is typically reviewed at least annually to evaluate the effectiveness of the plan, modify for changed conditions at the facility and determine if there are economically feasible or technological advances which are available and appropriate for the facility to incorporate into the plan.

Odor Sources

Crude oil processing can potentially release multiple compounds that may produce strong and offensive odors. Refinery operational smells are generally associated with compounds containing sulfur where even insignificant losses are capable of causing a noticeable odor. There are several sources of potential odor that are emitted as a fugitive emission or via a point source from Holly Refining operations. Point source emission releases allow for straight forward monitoring practices and potential control options. Fugitive emissions are harder to monitor and control. The Clean Air Act (CAA) regulation requires refineries to develop and implement a Leak Detection and Repair (LDAR) program to control fugitive emissions. Fugitive emissions occur from valves, pumps, compressors, pressure relief valves, flanges, connectors and other piping components. Holly Refining's LDAR program routinely monitors for leaks and fixes any leaking equipment to control VOC and other hazardous chemical emissions.

There are also other significant sources of air emissions in the surrounding area that can contribute to or be the primary source of odors in the community. These include biogenic sources of vegetative plant decay, farm animal waste, municipal sewer lines, major transportation corridors, competing refineries, and asphalt plants. Without a long term monitoring network system in place to determine quantified air emissions, wind flows, ambient temperatures, solar radiation, and atmospheric mixing, odors in the community can not be absolutely attributed to any one source with current data sets. Even with better data sets available for analysis, as noted previously there are complex chemical reactions not yet fully understood that are limiting the ability to positively identify a range of smells to one operation or source in a mixed use community as West Bountiful City.

In an effort to identify possible odorants, Holly Refining has taken some air samples for laboratory analysis and identification of chemical analytes present. Of the evaluations performed to date, it appears that the majority of odorous emissions from Holly operations are associated with sulfide and mercaptan compounds. These compounds are negligible subsets of emissions reported as SO_X and VOC emissions on UDAQ's annual emission inventory reports. The proposed modifications at the facility, according to the NOI, will result in a decrease of SO_X stack emission by 81.89 tons per year with an increase of VOC emissions by 15.95 tons per year. Other fugitive emissions points from sewer, process valves, and other off gassing sources may increase emission rates of these odorous compounds. No direct quantified odorous compounds emission rate can be correlated to the proposed facility modifications or stack emissions.

Holly Refining has identified the primary potential key odorous compounds and associated smell descriptors, from air sampling efforts, as the following:

Chemical Analyte	Odor Descriptor
n-Butyl Mercaptan	Strong Unpleasant Odor; Skunk-Like Odor
t-Butyl Mercaptan	Strong Unpleasant Odor; Skunk-Like Odor
Carbon Disulfide	Aromatic Odor, Slightly Pungent; Sweet/Pungent
Carbonyl Sulfide	Rotten Eggs
Diethyl Sulfide	Pungent, Garlic-Like Odor
Dimethyl Sulfide	Rotting Vegetables; Repulsive Odor
Ethyl Mercaptan	Decayed Cabbage
Hydrogen Sulfide	Nauseating; Rotten Eggs
Isopropyl Mercaptan	Skunk-like Oror; Gas-Like Odor
Methyl Mercaptan	Decaying Cabbage/Onions; Rotting Cabbage
n-Propyl Mercaptan	Unpleasant Odor; Skunk-Like Odor
Tetrahydrothiphene (Thiophane)	Pungent Odor
Thiophene	Faint/Sweet Odor
Dimethyl Disulfide	Unpleasant Odor; Strong Garlic-Like Odor

There may be additional analytes to consider adding to the current list with further air sampling being performed in the community and area.

Review

To assess the odor mitigation steps performed by the Holly Refining staff, BC&A engineers reviewed the internal Holly Refining procedures for odor detection, citizen odor complaint records, and facility corrective actions taken.

There are several current odor abatement activities being conducted at the Holly facility. As odors are noticed by facility staff or identified through citizen complaints, an incident report is filed in the Woods Cross Refinery Immediate Incident Report Database. The data collected from an odor complaint is outlined in the odor complaint logsheet shown in Appendix C. The database logs the date and time of the incident report, who the odor was reported by, description of the smell/incident, contributing factors, and corrective action taken to mitigate the odor.

In order to better understand the source of the odor location emission point, Holly has installed a wind monitor and datalogger to monitor and record the wind speed and direction at their facility. Using this data in conjunction with reported odor smells and locations provides information as to possible origination points of odor sources. Once analytes and smells have been identified, potential economic and technologically feasible control options and odor mitigation steps can be further identified.

In conjunction with the wind monitor, Holly Refining has also collected ambient air samples. When a confirmed sustained odor has been reported to Holly, their environmental staff has collected tedlar bag air samples for analysis. Tedlar bags are manufactured from PVF (Tedlar) film. They are chemically considered inert and can be used to collect samples containing common solvents, hydrocarbons, chlorinated solvents, and many other classes of compounds. Tedlar bags are also commonly used to collect low-level sulfur gases when collection fittings and tubing are non-metallic (e.g. polypropylene, Teflon, or Nylon). The analysis is vital to understanding the analytes present, the associated odor, and the odor possible origination source location. A critical component in the sampling campaign is the time between the sample collection and analysis. The sample hold time, or time from sample collection to laboratory analysis, will vary for different classes of compounds. Chemically active compounds and Sulfur gases, especially hydrogen sulfide and methyl mercaptans should not have sample hold times in excess of 24 hours. Any chlorinated solvents or aromatic compounds should not exceed 72 hours hold time. If the sample hold times are exceeded then chemical absorption on the tedlar film or further gas reactions will render the analysis suspect. Limited Holly Refining air sampling efforts to date have followed the industry approved hold times, collection methods, and analysis methods addressed above.

The primary emission sources of odorous compounds are from point sources (stacks, vents, etc.), fugitive sources (LDAR emission points), and off gassing from sources such as the sewer lines. Each of these sources will require different control and mitigation activities.

Holly uses a sewer line from the facility to discharge brackish water. The water may contain dissolved sulfur compounds that can volatilize prior to arrival at the waste water treatment plant. Sulfur-containing compounds also have the potential to build up on the sewer pipe walls. To address confirmed odors emanating from the sewer line, Holly has permanently sealed a sewer manhole to prevent off gassing in a specific section of the community. Further sealing of manhole lids are being considered in specific areas and are subject to engineering review for feasibility options. Manholes are required by Utah Code to gain access to sewer pipe sections and prevent over pressurization of the pipe.

Overall, Holly Refining is expending adequate time, resources, and capital monies to address odors emanating from their facility into the surrounding community. Holly Refining does not have a formalized odor mitigation plan to track odor complaints, emission sources, and mitigation/corrective action measures taken by plant personnel. However, Holly Refining is currently practicing all of the key elements needed to create a formalized odor mitigation plan. The key elements currently in practice at the refinery include:

Tracking of all odor complaints in the logbook or system;
Performing and documenting facility mitigation steps and corrective actions taken;
Recording localized wind speed and direction to determine possible upwind contributors or sources;
Conducting an ambient air sampling program via tedlar bags to identify chemical compounds of concern during odorous emission episodes.

Conclusions and Recommendations

Based on BC&A's review, there are currently adequate initial informal and internal practices being conducted by Holly staff for trouble shooting odorous emissions from the facility. There are no formalized plans or procedures to address obnoxious odors of community concern. It is recommended that Holly Refining formalize a voluntary odor abatement plan with input from interested and invested parties. The plan should be reviewed annually and include feedback from West Bountiful City council and citizens that want to find economical and technically feasible methods to improve the effectiveness of the odor abatement plan. There are several benefits to a voluntary odor abatement plan. Some of these benefits include:

Annual review for plan effectiveness by Holly, West Bountiful City, and involved citizens;
Outlining of responsibilities, actions, and records to be retained;
Citizens involvement and support on potential odor abatement activities;
Increased accountability for odors and increased opportunities to improve.

The odor abatement plan should include continued meteorological monitoring to collect wind direction and speed readings. The plan should also have a continued tedlar bag sampling and analysis campaign for confirmed odor emanating from the Holly Refining plant operations. The sampling will further refine specific chemical emissions responsible for odorous smells thus allowing potential control strategies to be improved.

In order for the plan to be effective, concerned citizens should be actively engaged in providing constructive and objective observations with appropriate feedback on odors detected at their place of residence or in the community. A detailed accounting of odor issues, associated smells, times, dates, wind direction, and facility operations will yield better analysis as to potential odorous emissions sources and available institutional control and mitigation options.

Overall, additional data and continued analysis of odor issues will lead to a more comprehensive understanding of potential available solutions. Currently, with the initial information available at the time of this review, specific control options and detailed odor mitigation activities for Holly Refining can not be recommended.

Currently it appears that most odor causing sources are from fugitive area sources of sour water in the sewer lines, fugitive VOC and SO_X compounds from pumps, valves, and flanges, and other area sources. Control options and additional specific BMPs to minimize odors from these sources are difficult to identify and implement without additional data. Further analysis and investigations are required to form more detailed conclusions and recommendations. Additional specific activities can then be identified and implemented.

Realistic expectations from the formalized plan should be based on continual minimization of odors from Holly Refining and not a total elimination of odors. It should also be cautioned that not all odorous air emissions should automatically be attributed to Holly Corp operations. As indicated previously, the mixed use community has numerous other potential odorous emitting activities present and should be taken into account.

2008-11-17T20:41:00.001-08:00

Assessment of Existing Air Emission Releases and Potential Future Emissions

Approach

The assessment of the Holly Refining facilities air emission releases included using metrics and limits from several federal and state guidelines, rules, regulations and standards. The metrics and limits used for the assessment are found in the following:

The Clean Air Act (CAA),
the National Ambient Air Quality Standards (NAAQS),
the Utah Administrative Code (UAC),
the Utah State Implementation Plan (SIP),
the New Source Performance Standards (NSPS),
the National Emission Standards for Hazardous Air Pollutants (NESHAPS) and,
the Utah Annual Air Monitoring Network Plan 2007

Background

The 1990 Clean Air Act (CAA) is the most recent version of a law first passed in 1970 to clean up air pollution. CAA amendments were also adopted in 1990. The CAA mandated that EPA establish health and public welfare oriented standards for specific pollutants know as the criteria pollutants. The criteria pollutants are Oxides of Sulfur (SO_X), Oxides of Nitrogen (NO_X), Carbon Monoxide (CO), Particulate Matter (PM), and Volatile Organic Compounds (VOCs). The emission standards for criteria pollutants were established to primarily protect sensitive population groups, such as the young, elderly, and those with respiratory ailments as well as protect secondary receptors such as indirect impacts to vegetation, soils, and structures.

National Ambient Air Quality Standards (NAAQS) were also determined to specify various acceptable ambient air concentrations of the criteria pollutants over given time averaging periods. The NAAQS were established to coincide with the standards set in place to protect the public health and general welfare.

In addition to the NAAQS, the CAA requires the US EPA to regulate emission of hazardous air pollutants under regulations known as Maximum Achievable Control Technologies (MACTs). The MACTs are embodied in the National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations.

New Source Performance Standards (NSPS) are additional federal standards promulgated for major and minor sources on an industry or equipment category specific basis. NSPS are national emission standards that are progressively tightened over time to achieve a steady rate of air quality improvement without unreasonable economic disruption. The NSPS imposes uniform requirements on new and modified sources through the nation. These standards are based on the best demonstrated technology (BDT). BDT refers to the best system of continuous emissions reduction controls that have been demonstrated to work in a given industry, considering economic costs and other factors, such as energy use. Overall, NSPS regulations require any new source of air pollution must install the best control system currently in use within that industry.

In addition to the federal regulations listed above, there are also state agencies and regulations that monitor air quality, inspect facilities under their jurisdictions and enforce Clean Air Act regulations. Utah regulates industrial pollution industries and sources under the Utah Administrative Code (UAC). The UAC outlines procedures and limitations for an industrial source to apply for and gain operational permission with associated monitoring, recordkeeping, reporting, and emission standards.

The State of Utah has developed State Implementation Plans (SIPs) that specifically outline how Utah will control air pollution under the Clean Air Act. The SIP is a collection of regulations, programs and policies that is geared toward the specific complexities of local pollution sources, geography/topography, population bases, localized air transport mixing phenomena, and regional specific climate conditions. The State of Utah and the Utah Division of Air Quality (UDAQ) use the SIP to clean up polluted areas and meet federal NAAQS standards. UDAQ involves both the public and industries, through hearings and public outreach meetings, to facilitate beneficial progress and feedback on the development of the SIP.

Air quality models are used to determine compliance with NAAQS, and other regulatory requirements such as New Source Review (NSR) and Prevention of Significant Deterioration (PSD) regulations. Dispersion modeling uses mathematical formulations to characterize the atmospheric processes that disperse a pollutant emitted by a source. Based on emissions and meteorological inputs, a dispersion model can be used to predict concentrations at selected downwind receptor locations. These models are addressed in Appendix A of EPA's Guideline on Air Quality Models (also published as Appendix W of 40 CFR Part 51), which was originally published in April 1978 to provide consistency and equity in the use of modeling within the U.S. air quality management system. These guidelines are periodically revised to ensure that new model developments or expanded regulatory requirements are incorporated.

The American Meteorological Society/Environmental Protection Agency Regulatory Model Improvement Committee (AERMIC) was formed to introduce state-of-the-art modeling concepts into the EPA's air quality models. Through AERMIC, a modeling system, AERMOD, was introduced that incorporated air dispersion based on planetary boundary layer turbulence structure and scaling concepts, including treatment of both surface and elevated sources, and both simple and complex terrain.

There are two input data processors that are regulatory components of the AERMOD modeling system: AERMET, a meteorological data preprocessor that incorporates air dispersion based on planetary boundary layer turbulence structure and scaling concepts, and AERMAP, a terrain data preprocessor that incorporates complex terrain using USGS Digital Elevation Data. AERMOD is the approved and recommended near-field dispersion model for determining potential impacts at selected receptors. Near-field modeling is a localized modeling approach and does not take into account potential long range transport of pollutants. Typically, pollutant concentrations are determined at the facilities fence line and beyond to determine the significant impact area (SIA) and radius of impact (ROI) and thereby defining the maximum pollutant impact.

Review

To assess the emissions from the Holly facility operations several data sets were reviewed and evaluated. The data sets included, the annual air emissions inventory (AEI), the expansion project Notice of Intent (NOI) with the associated dispersion modeling data, the Toxic Release Inventory (TRI), and the State of Utah Annual Ambient Air Network Plan (AAANP).

Specific areas evaluated were an assessment of emissions, expected emissions impacts, UDAQ's ambient air monitoring network, and necessity of a health risk assessment. Each of these areas are covered below.

Emissions Assessment

To determine emissions impacts of the proposed modification a baseline emissions profile was established by Holly Refining. Due to process and operational variability at facilities across Utah, State rules allow for a facility to define any two consecutive years in the last 10 years as being the most representative for reasons such as process up-time, market conditions (supply-demand), and other contributing factors. Regulations allow for the baseline emission determinations to be made on a pollutant by pollutant basis. Based upon AEI data submitted to UDAQ, Holly choose the following baseline years and emission levels for each criteria air pollutant.

Pollutant	Years	Tons/Yr
PM	2000 and 2001	120.16
SO_X	1997 and 1998	519.29
NO_X	1998 and 1999	281.86
VOC	2000 and 2001	8.23
CO	2000 and 2001	162.44

These values were validated and approved by UDAQ in award of the AO. Emissions from new and proposed modifications were based on empirical manufacturer data, EPA AP-42 emission factors, and other operational parameters. The estimate code provide on the AEI submittal to UDAQ indicates that code 08 was used to estimate emissions. Code 08 correlates to EPA's AP-42 published emission factors. There are some advantages and disadvantages to using EPA's AP-42 emission factors (emission factors can be found online at http://www.epa.gov/ttn/chief/ap42/index.html).

An advantage to utilizing AP-42 emission factors is that EPA has spent considerable effort in researching, testing, and verifying the published emission factors (EFs). The EFs are widely accepted and used through out the regulated community to estimate emissions. By use of the EPA's EFs, the subjectivity involved with use of user defined emission estimates is removed.

A significant disadvantage to utilizing AP-42 is that the emission factors essentially represent an average of a range of emission rates. Approximately half of the subject sources will have emission rates greater than the emission factor and the other half will have emission rates less than the published factor. As such, with AP-42 being an average of sources, half of the sources using an AP-42 emission factor would theoretically be in noncompliance for emitting pollutants in excess of the averaged values and the other half of sources would theoretically be overestimating actual emissions and by physically emitting less than the averaged AP-42 values. In lieu of specific stack tests or continuous emission monitors (CEMs), this methodology is widely accepted and practiced in the industry.

Hazardous Air Pollutants (HAPs) that were emitted and reported to UDAQ were also reviewed. The Hazardous Air Pollutant Emissions Inventory reported to UDAQ on Form F1 was compared to emissions reported on the Toxic Release Inventory (TRI). Both reports are required and submitted under different regulatory drivers and have separate calculation methodologies to estimate emissions. The unique regulatory drivers and calculation methodologies in estimating emissions create an opportunity to cross validate emission estimates. It was found that the differences in reported emissions from both reports fell within numerical rounding and calculation methodology tolerances providing a higher level of confidence in reported values. This is in addition to the review and scrutiny of submitted emissions by UDAQ technical staff. The graph below outlines the reported calendar year (CY) 2006 HAP emissions in excess of 100 lbs.

In determining emission limitation and control device requirements, Holly Refining followed the top down BACT selection process outlined by EPA. BACT determinations are made on a case-by-case basis that involves an assessment of the availability of applicable technologies capable of sufficiently reducing specific pollutant emissions with considerations given to economic, energy, and environmental impacts of using each technology. The NOI submitted to UDAQ selected the best control technologies that weren't eliminated based on technological feasibility or adverse impacts to the other selection criteria.

Emissions Impact

To demonstrate conformity to the rule, regulations, and emission levels, Holly Refining has submitted a Notice of Intent (NOI) proposing the facilities modifications and estimated emission impacts. Based on the NOI, predicted emission changes at the Holly Refinery due to the proposed modifications will include some emission increases and some emission decreases. The estimated emission changes are listed below:

Net Emissions Difference over Baseline Emissions (Tons/yr)
NO_x	SO_X	VOC	PM₁₀	CO	HAPS
-80.73	-81.89	15.95	-83.88	167.91	3.99

The proposed net increase and decrease of emissions from modification of operations are due to several factors. One of the key factors that will increase emissions is the expansion of operations and increased processing capacity. More oil processed and refined in operations at the facility will result in a direct proportional emissions increase. Reductions in current baseline emissions are a combination of proposed equipment changes. Low-NO_X burners are proposed and incorporated into the air permit NOI. The low-NO_Xburners are designed to produce less NO_X while meeting operational design specifications. Inclusion of the low-NO_X burners in the NOI have resulted in regulatory controls with monitoring, recordkeeping, and reporting provisions being placed upon Holly Refining.

Other changes impacting emissions are change out of two older 2-cycle gas compressor engines for electric compressors, increased capacity of the Sulfur Recovery Units (SRU) to meet total sulfur loading per day, and meeting Best Available Control Technology (BACT) emission limitations on all proposed changes. These equipment modifications along with process changes will yield a varied impact of emissions released to the atmosphere. Overall, NO_X, SO₂, and PM₁₀ emissions will decrease with significant increases in CO and minor increases in VOC, lead and combined HAPs.

It should be noted that although Holly Refining has met BACT on all required criteria pollutants, there are potentially stricter emission rates known as the Lowest Achievable Emission Rate (LAER) that were not reviewed and are not required by State and Federal regulations for the proposed modifications. LAER is only required for criteria specific pollutants in non-attainment area designations of the state. Davis county is attainment for all criteria pollutants and has been designated a maintenance area for Ozone.

As per Utah Administrative Code Rule (UACR) R307-405-6(2)(B), a significance impact level (SIL) modeling analysis was performed. AERMOD was the model utilized to estimate ambient pollutant concentrations at Holly's fence line, the SIA, and ROI. AERMET data used for the model was prepared by UDAQ and consisted of four years of North Salt Lake surface metrological data from 1992-1995. Associated with this data set were four years of corresponding upper air data collected by the National Weather Service at Salt Lake City International airport.

To demonstrate air quality impacts from these emissions, Holly Refining conducted near-field dispersion modeling. According to State and Federal regulations, only CO was required to be modeled because the emissions increase exceeded 100 tons/yr. Other pollutant levels were reduced through newer technologies being employed and/or installation of pollution control devices or had emission increases that did not trigger modeling thresholds.

Variability in the model predictions can arise from the selected meteorological data sets and the user defined receptor locations. The 1992-1995 meteorological data sets are the most complete and available for the area. The data was originally scrubbed and prepared for the latest SO₂ SIP modeling exercise performed by UDAQ. The data was collected at the North Salt Lake Station on a 10 meter tower.

Optimal meteorological data for the area would include data collected on a 50 meter tower with temperature collection points at 2 meter, 10 meter, and 50 meter height increments. Solar radiation levels would also be collected in addition. Without these stratified temperature differences (ΔT), the AERMOD assumptions make the model perform similar to an ISC model. Even with the meteorological data being less than ideal, all sources being permitted for air emissions, which require air dispersion modeling, have been using the 1992-1995 meteorological data sets. Any AERMOD modeling assumptions based on using the 1992-1995 meteorological data sets have been consistently applied to all industrial sources modeled in the area, including Holly Refining.

The only other meteorological data set in the area was collected at the Tesoro site through a Sodar system. Sodar (sonic detection and ranging) systems are used to remotely measure the vertical turbulence structure and the wind profile of the lower layer of the atmosphere. Sodar systems are like radar (radio detection and ranging) systems except that sound waves rather than radio waves are used for detection. Many problematic issues have been associated with collection of this data set due to major noise interference in the area. Noise interference has come from industrial sources, freeway noise, and air traffic control patterns. This data set was excluded from consideration of modeling the Holly emissions for these reasons.

The PSD Class II SIL for CO is 2000 μg/m3 per 1-hour averaging period and 500 μg/m3 per 8-hour averaging period. Based on the meteorological data set and chosen receptor locations the AERMOD modeling results yield a maximum 1-hour CO concentration of 234.2 μg/m³ in the 1993 data year and a maximum8-hour concentration of 85.0 μg/m³ which occurred in the 1992 data year. Based on these findings, the proposed Holly Refining modifications should not cause nor contribute to any violation of the CO NAAQS. No long-range transport modeling was required for impacts to National Parks (Class I) air sheds due to Holly Refineries proximity to the nearest Class I area.

Holly Refining Monitoring

Holly Refining does have some inline opacity monitors for air quality monitoring purposes. There are no other regulatory driven continuous emission monitors (CEMS) onsite or in use at the facility. A CEM is the total equipment necessary for the determination of a gas or particulate matter concentration or emission rate using pollutant analyzer measurements. The CEM data is converted via equation, graph, or computer program to produce results in units of the applicable emission limitation or standard. This type of monitoring is expensive to install, operate, maintain and is not regulatorily required of Holly's operations.

Ambient Air Monitoring Network

The State of Utah currently operates a network of ambient air monitors and meteorological stations to collect pollutant concentration data at selected locations throughout the state. Utah has prepared an Annual Ambient Air Network Plan (AAANP) for 2007 through discussions with UDAQ, EPA, and the various communities. The current system is based upon known and perceived issues as well as limitations with resources and funding. There is a current trend to divert resources and funding from monitoring some criteria pollutants to non-criteria pollutants known as toxic air pollutants. This trend is due to long term monitoring of select criteria pollutants with no detected violation of the NAAQS as well as a need to better understand transport phenomenon of the toxic air pollutants.

Historically there have been two monitoring stations located within close proximity to the Holly Refining facility. As of May 23, 2007 those stations were Bountiful #2 and North Salt Lake #2. Not all of the Utah stations monitor the same pollutant data nor have the same monitoring objectives. A station may be designated National Air Monitoring Station (NAMS), State and Local Air Monitoring Station (SLAMS), or Special Purpose Monitor (SPM). The monitoring objectives (population exposure, source impact, highest expected concentration, or background station) and the spatial scale of representativeness (micro, middle, neighborhood, urban or regional scales) are also designated for each station in the AAAMP. Spatial scale of representativeness is described in terms of the physical dimensions of the air parcel surrounding an air monitoring station, throughout which pollutant concentrations are reasonably homogeneous. The scales of representativeness, as listed in the Utah AAAMP, used for Utah's network are in the following ranges:

Micro Scale: Several meters to about 100 meters
Middle Scale: About 100 meters to 0.5 kilometers
Neighborhood Scale: About 0.5 to 4.0 kilometers
Urban Scale: Overall citywide conditions, usually about 4.0 to 50 kilometers. Requires more than one station to define
Regional Scale: Defines a rural area, usually of reasonably homogeneous geography, extending for tens to hundreds of kilometers
National/Global: Characterizes the nation or globe as a whole.

The following table outlines the Bountiful #2 and North Salt Lake #2 stations and pollutants being monitored.

Station Location	SO₂	CO	O₃ (Ozone)	NO2	Lead	PM₁₀	PM_2.5
Bountiful #2 (171 W.1370 N.) Bountiful	SLAMS Impact Neigh.	x	NAMS* High Neigh.	SLAMS Population Neigh.	x	x	SLAMS Population Neigh.
North Salt Lake #2 (1795 N. 1000 W.) SLC	SLAMS** High Middle	x	x	x	x	NAMS High Middle CO-Loc	SPMS High Middle
Indicates Seasonal Monitoring * Should be re-designated to NAMS x Indicates no pollutant monitor Source Information from Table 1 Utah Annual Air Monitoring Network Plan 2007

Holly Refining operations are a significant industrial source in the North Salt Lake and Bountiful areas. Emission from industrial source reporting annual emissions inventories are summarized by county and made available by UDAQ to the public for select past historical years. Based on the reported emission levels from Holly Refining the following table shows the relative contribution of reported emissions in the Salt Lake and Davis County areas for the available historic 2002 and 2005 inventory years.

Holly's Contribution to Criteria Pollutants in SL/Davis County from Point Sources
Year	PM₁₀	PM_2.5	SO_X	NO_X	VOC	CO
2002	1.67%	3.41%	6.67%	2.99%	4.58%	13.06%
2005	1.60%	3.09%	7.12%	3.29%	5.38%	6.89%

Based on the data, SO_X and CO are the two pollutants from Holly operations that are the highest contributors to the overall emission in the air shed. Each of these pollutants will be discussed further in greater detail.

CO

Currently there is no CO monitoring taking place in the North Salt Lake/Bountiful area. This is based on the face that the CO NAAQS has not been violated for many years and the major CO pollution in the state comes not from stationary sources, but rather mobile vehicle emissions. The State CO monitors have therefore been strategically places next to major transportation routes and corridors associated with Utah Department of Transportation (UDOT) traffic patterns and highest traffic densities.

The last time the CO standard was violated was in 1993. SIP modeling and restrictions has been performed for the Salt Lake-Davis County non-attainment areas. Emission control measures identified in the SIP have been implemented along with automobile emission controls through the federal motor vehicle control programs. The resulted SIP implementation measures have resulted in no areas in Utah that have violated the CO NAAQS.

Proposed modifications at the Holly facility will result in an additional 167.91 tons of CO being released annually. Dispersion modeling done in conjunction with the air permitting process yielded no indication of potential CO NAAQS violations. The highest modeled concentration of CO are at maximum 11.7% of the NAAQS 1-hour averaging period and 17.0% of the 8-hour NAAQS averaging periods. Installing a CO ambient air monitor in the vicinity of Holly's operations will yield little to no benefit for the investment of resources.

Raised CO levels will be expected from the Holly modifications; however the ambient concentrations are estimated to be substantially below the NAAQS. Ambient air monitoring at the Holly refining location would confirm the modeled and expected emission levels. Potential placement of a CO monitor at Bountiful #2 or North Salt Lake #2 could be addressed with UDAQ for consideration in out year monitoring plans, however there would be limited to no benefit for the investment of resources. Currently no additional CO studies or monitoring are planned for the North Salt Lake/Bountiful area by UDAQ.

SO_X

The SO_X monitors were placed in their present locations based on emission inventory data, computer modeling, and public community concerns expressed to UDAQ. The area north of Beck Street was on of the areas with expected higher concentrations of SO_X. Specifically, both the Bountiful #2 and North Salt Lake #2 stations have been monitoring SO₂. Since collecting SO₂ data at these locations, there have been no violations of SO₂ standards since 1981.

UDAQ has determined that continued monitoring of SO₂ at the North Salt Lake #2 location is no longer necessary. This is in part due to its original sitting location being based off of Kennecott's Smelter operations. Operational changes with the Kennecott smelter operation have reduced SO₂ emissions by approximately 80%. The Holly Refining proposed modification will result in substantial reductions in SO₂. Based on the NOI submitted to the State, annual SO₂ emissions will be reduced by 81.89 tons from the baseline emissions estimate. Even with the reduction in SO₂ emissions from the Holly facility, UDAQ will continue to monitor SO₂ at the Bountiful #2 location year round. Currently, monitored ambient SO₂ emissions at the Bountiful #2 and North Salt Lake #2 stations are significantly below the 24-hr SO₂ standards. Based on past monitoring data and a proposed reduction in Holly Refining SO₂ emission releases, UDAQ ambient air monitoring of SO₂ is sufficient in this area as it relates to the Holly Refining operations.

It should be noted that SO₂may be a concern as it has an important role in the formation of particulate matter (PM) through secondary sulfate particles and atmospheric chemical reactions. More data and analysis is being conducted on a state and national level to further understand this phenomenon better.

Ozone (O3)

Ozone is a pollutant of concern along the Wasatch Front. Unlike other pollutants, ozone is not emitted directly into the atmosphere. Ozone is produced in the atmosphere as NO_X and hydrocarbons (e.g. VOCs) react in the presence of sunlight to form a number of photochemical compounds. Ozone is primarily a problem in the summer months when there is more direct sun light available for photochemical reactions to take place in the atmosphere. Ozone is also a highly reactive compound and has a short formation life. Only ground level Ozone formation is of a concern where it could come into contact with human and ecological receptors. Salt lake and Davis Counties are maintenance areas for Ozone.

Annual NO_X emissions from the proposed Holly modifications will be reduced by 80.73 tons. Annual VOC emission (hydrocarbons) will increase 15.95 tons over baseline estimates. Ozone formation from these two compounds is a complex and inexact science that is dependent on atmospheric mixing conditions, sunlight exposure, and Ozone formation location.

No Ozone modeling was required or conducted in conjunction with the Holly modifications or NOI for an air permit. Holly's reduced NO_X emissions will result in less NO_X to react with available hydrocarbons from other regional sources to form Ozone, however increased VOC emissions may result in increase Ozone formations. It is indeterminate the extent of impacts, however based upon overall mass emission levels, it is expected that fewer Ozone emissions will be formed from the proposed Holly modifications and operation.

Ozone is a problem and continues to be a problem along the Wasatch Front. 8-hour Ozone concentrations have been measured close to the standard of 0.08 parts per million (PPM). Continued ambient air monitoring is recommended to evaluate the air concentrations. Currently, there is an Ozone monitor at the Bountiful #2 location. Air monitoring at this location should suffice for the North Salt Lake/Bountiful area. If exceedences are detected, the State of Utah will enact an Ozone SIP to place tighter regulatory controls on emitting sources to mitigate the problem and bring ambient concentrations below EPA standards. Currently an Ozone maintenance plan for Salt Lake and Davis Counties is in place.

Other Parameters

Complex air dispersion modeling requires enormous amounts of data to more accurately predict emissions fate and transport. Currently there is a need to increase the amount of site specific meteorological data to account for valley topography and geographic features. Additional solar radiation and temperature variations at 2 meter and 10 meters need to be installed at sites around the valley. More specific data sets in these areas will help better predict and reflect current complex wind patterns along with transport of pollutants from the sources of release.

The Code of Federal Regulations (40 CFR Part 58 Appendix A) requires that measures of data quality be aggregated and reported by primary quality assurance objectives. The quality assurance program and requirement are in place to define the precision or bias/accuracy among all monitoring stations in the organization can be expected to be reasonably homogenous, based on common factors such as:

operation by a common team of field operators;
use of a common quality assurance project plan (QAPP) or standard operating procedure;
common calibration facilities and standards;
oversight by a common quality assurance organization; and
support by a common laboratory or headquarters.

Precision, accuracy, and bias are key important factors when reviewing and validating any data collected prior to use in modeling programs. Precision is defined as the average repeatability of all the instruments of the organization during the calendar quarter. Accuracy can be defined as the degree of agreement between an observed value and an accepted reference value. Accuracy includes a combination of random error (precision) and systematic error (bias) and the term is used when these two types of errors can't be separated. Bias is defined as the systematic or persistent distortion of a measurement process which causes errors in one direction.

Although the ultimate truth of the measured values cannot be known, values determined by National Institute of Standards and Technology (NIST) or other nationally recognized measurement standards body are accepted as the closest to the truth. Bias and accuracy measurements are made by challenging the monitors with independent audits (materials or devices) having traceability as directly as possible to NIST standards.

The precision and accuracy checks conducted by UDAQ are one component of a quality assurance program to validate data collected. The findings of precision and accuracy data enable UDAQ to identify aspects of their quality assurance programs that may need strengthening. This also enable the EPA to determine ways in which the quality of ambient data can be improved, such as additional research on measurement procedures, increased quality control for certain types of measurements, or technical assistance to areas of the country needing improved quality control.

Any additional air monitoring and sampling done in the community needs to conform to the requirements outlined in 40 CFR part 58. Ambient air data collected in the community not conforming to 40 CFR 58 will not meet minimum requirements outlined by EPA and can not be used for air quality analysis purposes. Refer to Appendix A and E of 40 CFR part 58 for the entire specifications outlining data quality assurance and monitoring station requirements.

Ambient Air Monitoring Limitations

The current State ambient air monitoring system is adequate to measure when criteria pollutant concentrations are approaching unhealthy concentrations as determined by EPA standards. The States current predications of air quality conditions meet the objective of the ambient air monitoring network design. The network data and system provides sufficient information to UDAQ for release and dissemination to the community through local media outlets UDAQ's website.

The system is not nor was ever intended to provide real time alerts to specific instantaneous high concentration readings of any given pollutant. If there was an instantaneous increased release of a particular compound from Holly Refining operations due to upset conditions, the ambient air monitoring network would not be capable of alerting the public. Real-time facility and fence line monitoring systems are typically employed to detect and alert for the presence of specific acutely toxic compounds. These systems are typically geared toward the health and safety of workers on site. The greatest threat of exposure from an acutely toxic airborne compound is to those individuals in closest proximity to the highest concentrations found at the point of release. With radial distance to the release, mixing and dilution provide mitigating conditions that lessen the risk. If an accidental release of a toxic airborne chemical were to occur at Holly Refining, the most efficient and effective community notification and evacuation plan would be through the first emergency response professionals (e.g. Fire and Police Departments). Other types of monitoring and notification systems for a community are not typically practical.

There is not any ambient air monitoring equipment or network in place on the Holly Refining property. General fence line monitoring of criteria pollutants is not a feasible approach to detecting criteria emissions. This is due in part to the proximity of the plant in relation to major transportation corridors and surrounding facilities emitting similar compounds. Another critical factor is related to the emission points of the regulated pollutants. The majority of emissions are sent through emission stacks. The purpose of the stack is to provide speed and loft to the emissions, dispersing the emissions higher in the atmosphere thereby allowing wind mixing and dilution prior to any pollutant settling back to ground level to with in inhalation range by the community. Utilizing a line monitoring system will most likely not achieve the desired results of detecting criteria pollutant emissions exceedences and is not warranted by current modeling and predicted emissions concentration data.

Currently there is limited information on monitored toxic air pollutants both locally and nationally. Toxic air pollutant monitoring in the Bountiful area by UDAQ needs additional consideration. An evaluation as to which toxic pollutants warrant specific modeling should be performed. This evaluation should be conducted in conjunction with State and EPA toxicologists to an exposure assessment and risk characterization for the pollutants.

Risk Assessment

A common critical question asked by communities and individual residences a like is that of potential health effects from pollutants in the air. EPA and UDAQ have based emission limits and ambient air pollutant concentration standards upon human health and ecological risk assessments. A health risk assessment is a scientific tool designed to help answer the question of health hazards from pollutant exposure. Government agencies rely on risk assessments to help them determine which potential hazards are the most significant. Risk assessments also guide regulators in abating environmental hazards. Becoming familiar with the basics of risk assessment procedures and processes can improve a communities understanding of both real and perceived environmental hazards, and can effectively improve discussions with decision makers on solutions to environmental problems.

In general a risk assessment is in part based upon past epidemiologic studies. Most epidemiologic studies evaluate whether past chemical exposures may be responsible for documented health problems in a specific group of people or community. In contrast, health risk assessments are used to estimate whether current or future chemical exposures will pose health risks to a broad population, such as a city or a community. Scientific methods used in health risk assessment cannot be used to link individual illnesses to past chemical exposures, nor can health risk assessments and epidemiologic studies prove that a specific toxic substance caused an individual's illness.

The risk assessment process is typically described as consisting of four basic steps: hazard identification, exposure assessment, dose-response assessment, and risk characterization. In the first step, hazard identification, scientists determine the types of health problems a chemical could cause by reviewing studies of its effects in humans and laboratory animals. In exposure assessment, scientists attempt to determine how long people were exposed to a chemical; how much of the chemical they were exposed to; whether the exposure was continuous or intermittent; and how people were exposed—through eating, drinking water and other liquids, breathing, or skin contact. In dose-response assessment, scientists evaluate the information obtained during the hazard identification step to estimate the amount of a chemical that is likely to result in a particular health effect in humans. This includes a specific cancer and non-cancer health effect analysis component. The last step in risk assessment brings together the information developed in the previous three steps to estimate the risk of health effects in an exposed population.

No activities or emission rates associated with the Holly Refining modifications triggered thresholds or requirements necessitating a site specific risk assessment evaluation for Holly operations. Based upon current EPA data and understanding, a risk assessment of the Holly operations will not yield significant additional insight into public health effects from operations and emissions at the refinery. Existing risk assessment data and pollutants emissions studies are adequate for addressing the emissions and operations at Holly Refining.

Conclusions

A review of the submitted NOI to UDAQ was found to meet the conditions and requirements set forth in State Rules (R307) and in applicable federal regulations. Appendix A of this report contains an outline of the regulations and applicability to the proposed modifications at Holly Refining. Permitting efforts by Holly Refining conformed and followed UAC regulations. Expected increased CO air emissions from the proposed modifications are significantly below the NAAQS 1-hour and 8-hour averaging limits and are not expected to contribute to a violation of the NAAQS. VOC and HAP pollutants increase below threshold values for modeling and are not expected to contribute to significant declines in ambient air quality for the community. Other criteria pollutants are expected to decrease with the proposed modifications and will contribute to lowered ambient air concentration of those pollutants.

At this time the UDAQ AAAMP is adequately monitoring the pollutants of concern in the West Bountiful area with consideration being given to the limited distribution of monitoring resources in the state. No additional facility specific fence line or stack monitoring is recommended based on the NOI submitted to UDAQ and the modeled emission values and predicted ambient concentration values.

It is recommended that UDAQ evaluate the available options to begin collecting several years of meteorological data in the West Bountiful or North Salt Lake Area. This data set should include ΔT measurements at 2 meters, 10 meters, and 50 meter height increments. This data set would support enhanced use of AERMOD in estimating pollutant transport and deposition.

Noise Level Study

2008-11-17T20:39:00.001-08:00

Assessment of Sound Impacts Above Ambient Noise Levels

Approach

The assessment of the Holly Refining noise impacts to the community included a review of existing noise data sets and evaluation studies performed by Wasatch Ergonomics, LLC. Wasatch Ergonomics, LLC performed a comprehensive noise survey and evaluation to estimate the contribution to ambient community noise with sound measurements taken both on and off Holly property. The study included sound sampling on Holly property, outside of the fence line and property boundary, and inside a neighboring residential location. A second sound monitoring report specifically addressed noise impacts posed by the proposed addition of a new Gas Oil Hydrocracker (GHC) process at Holly Refining and Marketing Company's Woods Cross Refinery. Sound level meter recordings were collected at specific locations on Holly's facility in addition to fence line perimeter locations. The sound measurements were utilized to determine an empirical mathematical model to estimate sound propagation from the GHC addition.

Background

Sound wave propagation is a complex interaction of physical surroundings, geographic terrain, and atmospheric conditions. The variability of all of the possible permutations with varying potential scenarios can at best only predict the average ambient or instantaneous noise level at a given receptor location. It is industry practice to use mathematical modeling to estimate noise propagation and expected noise decibel levels rather than perform ongoing noise monitoring.

The common measurement of noise is measured and depicted on a logarithmic decibel (dB) scale. The logarithmic function indicates that the noise level will double for every increased measure of 10dB. As a reference to the potential noise levels at the Holly facility, the following table illustrates typical sound types and their corresponding decibel levels:

Typical Common Sound Levels
Sound Type	dB Level	Health Effects Threshold Notation
Weakest sound heard	0dB
Quiet living room	20dB
Whisper Quiet Library	30dB
Quiet conversation	40dB
Average office noise	50dB
Normal conversation (3-5')	60-70dB
Telephone dial tone	80dB
City Traffic (inside car)	85dB
Train whistle at 500', Truck Traffic	90dB
Subway train at 200'	95dB
	90 - 95dB	Level at which sustained exposure may result in hearing loss
Power mower at 3'	107dB
Snowmobile, Motorcycle	100dB
Power saw at 3'	110dB
Sandblasting, Loud Rock Concert	115dB
	125dB	Pain begins
Pneumatic riveter at 4'	125dB
	140dB	Even short term exposure can cause permanent damage - Loudest recommended exposure WITH hearing protection
Jet engine at 100', Gun Blast	140dB
	180dB	Death of hearing tissue
	194dB	Loudest sound possible

Typical community noise levels can vary depending on the population density and the activities that occur with in the community. Peak noises can also vary according to individual activities. Sustained ambient noise levels in a community are fairly consistent over time and have been documented based upon population densities. Data presented in Table 15.7 of "The Noise Manual" 5^th edition, AIHA Press, 2003, indicates common ambient community noise levels that can be expected. The data is represented in the table below:

Typical Community Noise Levels
Community Description	dB(A)
Rural and Sparsely Populated Areas	35-50
Quiet Suburban Community (Population Density <280 people/kM2 – Remote from Large Cities, Industrial, and Trucking Activities)	50
Normal Suburban Community (Population Density <770 people/kM2 – Not Located Near Industrial Activity)	55
Urban Residential Community (Population Density <2600 people/kM2 – Not Immediately Adjacent to Heavily Traveled Roads and Industrial Areas)	60
Noisy Urban Residential Community (Population Density <7700 people/kM2 – Near Relatively Busy Roads or Industrial Activity)	65
Very Noisy Urban Residential Community (Population Density <26,000 people/kM2)	70

It should be noted that, changes in sound levels by noise dosimeters can pick up and identify minute changes and ranges in noise fluctuations. The human ear however, can only discern between larger increases in decibel levels. Overall, a marked ability to discern a noise change will occur around 5dB. Changes of less than 3 dB are not typically perceptible by the general populace. The following table illustrates the ability of the human ear to detect increases in decibel levels.

Perceptions of Increases in Decibel Level
1dB	Imperceptible Change
3dB	Barely Perceptible Change
5dB	Clearly Noticeable Change
10dB	About Twice as Loud
20dB	About Four Times as Loud

The community noise standards and ordinance restrictions for West Bountiful City are addressed in city nuisance ordinance 8.12.020 subpart X. The ordinance states that it is unlawful for any person or group to create or permit any noise (regardless of its origin or definition) that may annoy or disturb a reasonable person with normal sensitivities or that injures or endangers the comfort, repose, health, hearing, peace or safety of two or more persons between the hours of ten p.m. and six a.m. (Ord. 268-00 § 1; Ord. 264-00 (part); prior code § 6-15-2). This is a subjective ordinance with no specified numerical decibel limits. The cities of Bountiful and Woods Cross have similar noise ordinances with Salt Lake City being the closest city with specified numerical limits. The limits are 50 dB(A) between 10 p.m. and 7 a.m. and 55 dB(A) all other times. These limits were used as surrogate values to determine reasonable quantified sound limits in the community for individuals with normal sensitivities, as defined by West Bountiful City ordinance. Based upon available data, using SLC nuisance limitations is deemed reasonable.

Noise Sources

There are several sources of equipment and operations that can produce noise from Holly Refining operations. The primary and major sources of noise from Holly operations have been associated with flaring operations. More specifically, steam injection into the flares for emissions control and smoke management purposes. There are two flares in operation at the facility.

There are also other notable sources of noise in the vicinity of Holly's facility. They are primarily airplane traffic from Salt Lake International, vehicular motor traffic, train operations, and residential activities. These other sources add to the overall ambient noise in the community and should be taken into account while evaluating community noise impacts. It is important to note that these additional noise sources were significant enough to impact the past efforts to collect meteorological data via Sodar technology in the North Salt Lake and Bountiful area. Sodar (sonic detection and ranging) systems are used to remotely measure the vertical turbulence structure and the wind profile of the lower layer of the atmosphere. Sodar systems are like radar (radio detection and ranging) systems except that sound waves rather than radio waves are used for detection. These noise contributions to noise in the community should be taken into account when evaluating Holly Refining's noise contribution levels.

Review

To assess the noise from the Holly facility operations, the available noise surveys and data presented in Wasatch Ergonomics, LLC reports dated 9/12/07 and 6/27/06 were reviewed and evaluated.

The data and findings of the report dated 6/27/06 indicated that the larger and newer flare performed more quietly than the older flare. The percentage of steam injection was the most significant contributor to noise from the flaring operation. The study found that the newer flare with 15% steam matched the older flare with 0% steam. No correlation was provided to determine if the noise ratio of the older and newer flares would increase on a linear scale with increased steam percentages. Data were collected in short-term samples and are reported as dB(A) (decibels A-scale weighting, sound energy equivalent level). Based on the data presented, the newer flare could operate under normal operating conditions and below the SLC noise ordinance dB(A) levels of 50 dB(A) and 55 dB(A). During upset conditions (non-normal) when the steam injection rate increased to 35%, the dB(A) levels beyond Holly property fence line increased slightly above the nighttime limit of 50 dB(A) and only one data point exceeded the daytime limit of 55 dB(A) level. The older flare was not in operation during the sound measuring period but could be safely assumed to have higher sound levels at each corresponding sound monitoring station.

Time Weighted Averages (TWA) could not be determined due to sound monitoring being conducted in one minute intervals. A TWA data set would provide another verification of noise levels over a longer time period which would include Holly process operating variabilities. Even though this extra verification would provide additional insights and confirmation to the conclusions of the report, it is not recommended due to the sound monitoring being in an uncontrolled monitoring environment. Other community sounds of overhead aircraft, vehicular motor traffic, and community noise (lawn mowers, snow blowers, barking dogs, etc.) can not be controlled to limit sound recordings being solely from the Holly Refining operations. Continued efforts should be made by Holly Refining to enhance operational procedures to primarily use the newer flare when ever possible to minimize the noise in the community.

The data and finding of the report dated 9/12/07 indicated the proposed modifications at the Holly facility would yield a 1 dB increase in overall ambient noise. This level of noise increase is virtually an imperceptible noise change. This assessment comes from modeling of noise measurements collected on-site and at the perimeter of Holly Refining on 5/22/07, 6/12/07, 6/13/07, and 7/14/07. The sound monitoring locations are displayed in Appendix B. All sound measurements for characterization and modeling confirmation were done un-announced to Holly to ensure unbiased plant operational conditions. All sound collection sample dates were later confirmed with Holly to represent normal equipment operational conditions. Sound sampling measurements were also taken in all radial directions of the facility without consideration of the prevailing wind, which was less than 10 mph on the ground surface.

To verify the noise levels predicted, the assumptions used to estimate the noise levels were reviewed. Several issues and assumptions relating to the noise study, which were required for simplification of the complex noise interactions, may cause uncertainty in the findings. The assumptions and associated uncertainty can both increase or decrease the expected dB(A) levels that are being predicted. These assumptions and potential model variability from the assumptions are outlined below.

Wind and Temperature

Wind and temperature effects were omitted from the sound propagation model. This approach is consistent with typical sound investigation protocols of this type. Wind has the potential to both inhibit sound propagation and create potential sound focusing. Sound wave propagation can be expected downwind and impeded upwind of the sound emanation point. The variability of this parameter can consequently act as a sound dampening media or focus sound to a particular location and impact limited few in the community. Surface winds contributing to this phenomenon were not considered due absence of a consistent strong wind speed and direction at the site. Surface winds were therefore considered negligent to overall ambient sound propagation and may only have periodic and isolated effects on the community.

Temperature can have several effects. The most notable, but having the least impact to the sound study, is its effect on the speed sound travels. Sound travels faster in warmer air. All sound studies conducted were during warmer summer months and will represent a worst case scenario. A more consequential phenomenon of temperature variants is that of potential temperature thermo-climes developing in the upper air atmosphere. Distinct temperature thermo-climes can in effect cause atmospheric sound reflecting of noise back to the earth. This can occur when the clearing index is low. The clearing index is an Air Quality/Smoke Dispersal Index used to regulate open burning and is utilized as an input for other air quality decisions throughout Utah. The clearing index is defined as the mixing depth (depth of the mixed layer in 100s of feet above ground level) multiplied by the transport wind (average wind in the mixed layer in knots). Clearing index values below 500 are considered poor ventilation. Any clearing index values above 1000 are considered excellent ventilation and are referred to as 1000+. Sound reflecting from a low clearing index is more of an issue for instantaneous sound wave fronts rather than sustained noises.

The other more consequential temperature variable associated with sound propagation is snow cover on the ground. Snow cover on the ground acts as a sound absorber and diminishes transmission of sound waves over a given distance. Absence of snow cover on the ground during the sound studies will also present worst case parameters for sound propagation estimates and measurements.

Sound Barriers

Natural and man made sound barriers were omitted from the model except when sound focusing concerns were noted. This approach is consistent with the existing topography of the area where there are few earthen berms, trees, or elevation changes that would significantly impact noise propagation off site.

Man-made sound barriers with flat hard surfaces can redirect and focus sound. These structures that had potential sound focusing properties were included in the model. Natural sound barriers of geographic topography, vegetation, and foliage will help mitigate sound propagation. Without inclusion of natural sound barriers to the model, the estimated sound impacts at a distance from the facility will be artificially high and overestimate the actual decibel levels expected. This is a conservative approach and is a favorable method to protecting the community in the sound assessment and determinations of the report.

Model Validity

The Wasatch Ergonomics, LLC noise impact assessment report indicates that sound measurements were taken to verify the mathematical models ability to accurately predict sound levels at any given distances. Report finding and the calibration of expected sound levels to measured sound levels indicated that the model accurately predicts current sound and therefore has additional credibility in predicting future increases. Specific validity of the model would include sampling noise only from Holly operations at a given distance and then reproducing those values with the mathematical model. Obvious physical limitations are present in performing this type of model validity due to other uncontrollable noise sources in the area, including the interstate freeway, air traffic, industrial sources, and other community noises present. Although, there could be variability in the mathematical model due to the methodology used for calibration, the verification of the model results were performed consistent with industry standards noting the physical limitations present.

The mathematical model used to determine estimated process modification noise impacts at Holly facility boundaries is represented below.

Where: L_eq = Average noise level

L = average noise in dB(A)

Q = spherical noise propagation parameter

r = radius to boundary or receptor location

The mathematical model and specific calculations performed by Wasatch Ergonomics for the Holly facility were reviewed by Bowen Collins & Associates, independently validated, and found to be consistent of technical industry practices.

Conclusions and Recommendations

Based upon BC&A's review, Holly Corp has performed basic monitoring and evaluations to predict operational impacts on ambient noise in the community. Evaluations performed to date on typical operating conditions have included conservative assumptions leading to worst case scenario results. Findings indicate that the majority of noises emanating from the facility operations are associated with the use of flares. It is recommended that Holly Refining continue to implement and review operational procedures to utilize the newer flare where possible and minimize the older flare operation. These institutional operational controls should be clearly outlined and made available to the community to address procedures, processes, protocols and controls being taken to minimize noise impacts. Based on current sound monitoring data and evaluation studies, additional monitoring of normal operating conditions is not warranted from the data currently available as it indicates minimal potential noise nuisance disturbances with respect to neighboring community's noise ordinances thresholds and Holly Refining operational conditions.

There is limited noise data and expected decibel levels available for the facilities operation during true extreme upset conditions. It is estimated from existing data that noise from an operational upset condition would most likely exceed 55 dB(A) at the property boundaries. During an upset episode the facility is not operating normally and Holly staff work to correct the issues immediately and expeditiously. It is not recommended that further sound monitoring be conducted during plant upset conditions to quantify maximum dB(A) levels. These episodes are unplanned and therefore present additional logistical problems with having sound monitoring equipment available and on standby.

West Bountiful City also needs to evaluate and adopt a numerical noise limit based ordinance rather than the current subjective based approach. This change would allow for compliance limits to be in place and enforced. Currently the limits are subjective to the citizens in the community and industry alike. The subjectivity of the ordinance will lead to frustrated efforts by industry to meet the arbitrary noise standard, as well as frustrated citizens seeking compliance enforcement actions. Noise considerations for all industrial and residential activities should be evaluated prior to establishment and promulgation of a numerical based noise ordinance.

It is also recommended that Holly Refining consider and evaluate the option of facility landscaping modifications to include earthen burms in conjunction with dense and tall evergreen trees placed at or near the fence line for the purpose of sound mitigation. Strategic placement of ground level elevation changes, landscaping trees, and other shrubberies can help abate sound wave propagations to areas of current citizens concern. Current site topography and existing vegetation allow for relatively unmitigated sound propagation from facility operations. This natural sound mitigation barrier and technique may help defuse sound propagation from ground level sources and decrease ambient noise from facility operations.

News about Holly Oil Refinery

2008-08-13T09:00:00.001-07:00

Holly buying homes, easing hard feelings

1 comment for this page [ View ]
Wednesday, August 13, 2008
By BRYON SAXTON
Standard-Examiner Davis Bureau
bsaxton@standard.net

Refinery hopes measure cuts complaints

WEST BOUNTIFUL -- Getting out from underneath the smell and shadow of Holly Refinery has Nathan Long breathing easier.

After living there for seven years, Long sold his West Bountiful home, 186 N. 1000 West, to Holly Oil for fair market value.

The purchase by the refinery is designed to put more distance between residents and the noise and odors associated with the plant at 393 S. 800 West.

The purchases have nothing to do with plant expansion or a stratagem to reduce complaints, although refinery officials recognize that buying up neighboring properties in the end will likely result in the latter.

Neighbors have contended the noise and odor coming from the refinery, which straddles the Woods Cross and West Bountiful borders, know no bounds.

The noise and smell, trying to get refinery officials to address the problems and the city not taking action prompted his decision to sell, said Long, 32, who moved to Bountiful.

When he would call the refinery to complain about the smell, Long said, officials there would blame raccoons, the Bountiful landfill or the sewer treatment plant serving the south Davis area.

"There was several times (the smell from the refinery) made me nauseous. It was so strong and so foul, I absolutely almost lost it two or three times," he said.

When he initially bought his home in 2001, Long said, he was "a little worried" about odors and noise. It wasn't until after the previous owner of the plant, Phillips, sold the refinery to Holly several years ago that he noticed the odors.

Complaints are not new to the refinery.

The refinery garnered attention in April when it was ordered to pay a $120,000 "civil penalty" for violations of the Clean Air Act. The current owners said the violations occurred under the previous ownership.

That same month, the refinery experienced a small explosion created by a flare-up, resulting in one worker being injured.

The refinery also has received complaints from homeowners regarding the brightness of its flare-ups.

Mike Astin, Holly Refinery environmental manager, said it is attempting to put more distance between the plant and neighbors by buying up property as it becomes available.

But the handful of purchases it has made, he said, are not directed at hushing complaints or growing the refinery.

"We're not really out actively soliciting property.We don't want to own all the houses around here."

He said the refinery plans to rent out the homes.

Living next to the refinery is like living next to manufacturing, Astin said, and one benefit to the refinery's owning surrounding land is that it should reduce complaints.

Holly Refinery's efforts to create distance between it and neighbors' homes is not a new concept.

Before Holly Oil bought the plant, Phillips also purchased properties along 1100 West, Astin said.

West Bountiful City Administrator Wendell Wild said it is difficult for a refinery to be a good neighbor. With that in mind, he said, the company has attempted to expand the buffer between itself and neighboring residents.

"They have not actively solicited (homeowners) to buy property. The feeling is, if folks are interested, they can approach the refinery."

The city has an agreement with the refinery committing it to stay in the footprint of the city's industrial zone.

Comments

By: Jeff @ 08/13/2008, 6:48 AM

It is what it is....When you build or buy a house next to a refinery you are going to see the flare stack and smell hints of H2S (rotten egg smell). The Woods Cross refinery has been operating at that location since before World War 2.
Get over it or move.....

Salt Lake City and its surrounding areas need that refinery.

Holly Oil Refinery

EPA Considers Tougher Emission standards for Oil Refineries

Proposed 'petcoke' power plant canceled

Proposed Co-Generation Power Plant for Holly Oil Refinery

Overview of Holly Study

Centralized Data Storage

Approach

Background

Review

Recommendations

Conclusions

Chemical Storage

Approach

Background

Review

Risks

Conclusions

Assessment of Odors from Facility Operations

Approach

Background

Odor Sources

Review

Conclusions and Recommendations

Assessment of Existing Air Emission Releases and Potential Future Emissions

Approach

Background

Review

Emissions Assessment

Emissions Impact

Holly Refining Monitoring

Ambient Air Monitoring Network

CO

SOX

Ozone (O3)

Ambient Air Monitoring Limitations

Risk Assessment

Conclusions

Noise Level Study

Assessment of Sound Impacts Above Ambient Noise Levels

Approach

Background

Noise Sources

Review

Wind and Temperature

Sound Barriers

Model Validity

Conclusions and Recommendations

News about Holly Oil Refinery

Holly buying homes, easing hard feelings

Comments

SO_X