# ~HOLLY**~.** -. fa w " - ? .., .., , REFINING & MARKETING COMPANY - WOODS CROSS 

## MAY.**~'7'** 

## 2Q1aj 393 South 800 West. Woods Cross, Utah 84087-1435 (801) 299-6600 • Fax (801) 299-6609 

# .....
May 24,2010 Emilio Llamozas, 8ENF-AT CERTIFIED MAIL: 7009341000023633 1927 U.S. Environmental Protection Agency 1595 Wynkoop Street Denver, Colorado 80202-1129 Dear Mr. Llamozas: This letter responds to your request for infonnation from Holly RefIning & 

### Marketing Company

- Woods Cross dated April 22, 2010 pursuant to Section 114 ofthe Clean Air Act. Each ofthe EPA's questions is provided below in italics, followed by Holly's response in regular font. Referenced documents and tables are included on the enclosed disk.

Michael S. Astin, P.R Environmental Manager Enclosure

- Disk with the following mes: Response1 2006.pdf Response1 2007.pdf Response1 2008.pdf Response1 2009.pdf Responsel 2010.pdf Response! .xls 

### Response7.pdf Response7.xls Response8.pdf Responsel0.pdf

c: 

### L. Keddington 

### D. 

### McWatters T.L. Garrett, Esq.May 24,2010 Emilio Llamozas, 8ENF-AT Page 2

Information Request Statement ofCertification I certify under penalty oflaw that I have examined and am familiar with the information in the enclosed documents, including all attachments. Based onmy inquiry ofthose individuals withprimary responsibility for obtainingthe information, I certifythat the statements and information are, to the best ofmy knowledge and belief, true and complete. I am aware that there are significant penalties for knowingly submitting false statements and information, including the possibility offines or imprisonment pursuant to section 113(c)(2) of the Act, and 18 U.S.C. §§ 1001 and 1341.

# ~din~~~ Vice President/Refinery Manager May 24,2010

Holly Refining & Marketing Company
- Woods Cross Refinery, 393 South 800 West, Woods Cross, UT 84087-1435, Phone (801) 299-6600, Fax (801) 299-6609May 24, 2010 Emilio Llamozas, 8ENF-AT Page 3
Request 1 

### For each day beginning on January 1, 

### 2006, until the date of your receipt of this request, list theperiods of time (date, start time, and end time) that combustible material was routed to eachjlareat the Hollyfacility (Le., "ventingperiods "). For thepurpose of this request for information, "jlare" shouldbe broadly defined as any open combustion unit (i.e., lacking an enclosedcombustion chamber) whose combustion air isprovided by uncontrolledambientairaround thejlame, and that is usedas a control orsafety device. A flare may be equippedwith a radiant heatshield (with orwithouta refractory lining), but is not equippedwith ajlame air control damping system to control the airlfuel mixture. In addition, ajlare may also use auxiliary fuel. The combustionjlame may be elevatedoratground level. Response I The individual responsible for responding to Request I is Eric Benson. The people consulted in the preparation ofResponse 1 are Michael Astin and Bo BothwelL Documents consulted, examined, or referred to in the preparation ofResponse 1 or that contain information responsive to Request I include: Emissions reports Summary calculation sheets for emissions, bothreportable and below reporting limits A copy each document, with the number ofthe response (l) in the upper right hand corner, is included on the enclosed disk in pdfformat, under the files Response1 2006.pdf, Response 1 2007.pdf, Response1 2008.pdf, Response1 2009.pdf, and Response1 2010.pdf. The Woods Cross Refinery has 3 flares: the North Flare, the South Flare, and the Propane Flare. The North Flare handles reliefgases that generally come from units in the north portion ofthe refinery, and the South Flare handles reliefgases that generally come from units in the south portion ofthe refinery. The Propane Flare handles reliefgas from our propane storage facility only. At the end oflast year, the north and south headers were combined into the North Flare alone, and the South Flare was idled. The Propane Flare has never had steam addition. At the end oflast year, this flare was replaced with an air assisted flare. Table 1 lists the date, start time, and end time ofeach period oftime that combustible material was routed to the North and South Flares. We have included all events that have been reported in our annual emission inventory, including those that were reportable as well as those that were below regulatory reporting limits. Table 1is included on the enclosed disk in Excel format as Response1.xls. Flaring from the Propane Flare due to pressure relieffrom propane storage is rare and the times and dates ofthis flaring is not recorded.
Request 2 

### For each ventingperiod listed in response to Request 1 

### above, provide the average heating value, in BTU/sc.f of the stream that was vented to eachfacilityflare. The averaging time shall not be greater than one hour. Provide a narrative explanation and example calculations describing howyou arrivedatyour response. Response 2 The individual responsible for responding to Request 2 is Michael Astin. The people consulted in the preparation ofResponse 2 are Michelle Dunbar, Barry Christensen, and Conrad Jenson. No documents were consulted, examined, orreferred to in the preparation ofResponse 2, and no documents contain information responsive to Request 2.
Holly Refining & Marketing Company
- Woods Cross Refinery. 393 South 800 West, Woods Cross. UT 84087-1435. Phone (801) 299-6600. Fax (801) 299-6609May 24,2010 Emilio Llamozas, 8ENF-AT Page 4

No samples ofgas being vented were collected for any ofthe venting periods identified. There is no continuous monitoring, nor are regular sample collected from the flare headers.
Request 3 For each ventingperiod listed in response to Request 1 above, provide the average mass flow rate of all material, combustible and non-combustible, in lb/hr, that was vented to eachfacilityflare. The average time shall be no more than one hour. Provide a narrative explanation and example calculations describing howyou arrived atyour response. Response 3 The individual responsible for responding to Request 3 is Michael Astin. Thepeople consulted in the preparation ofResponse 3 are Barry Christensen and Conrad Jenson. No documents were consulted, examined, orreferred to in the preparation ofResponse 3, and no documents contain informationresponsive to Request 3. We do not possess reliable mass flow data for the venting events provided in response to Request 1. Prior to the idling ofthe South Flare, Holly installed mass flow meters on the North and South Flare headers for the purposes of l) testing the technology and its usefulness in quantifying flaring, 2) automatically controlling steam use in the flares, and 3) improving identification offlaring from unknown sources. The results from these meters havebeen in question since installation. This was most apparent when the South Flare was idled and the flow from the south flare header was routed to the North Flare upstream ofthe North Flare flow monitor. On occasion, the meterreadings for the flow in the south flare header exceed the total flow to the North Flare, which is physically not possible. We are working with the manufacturer to improve the accuracy ofthese instruments so that we may have reliable mass flow data and automatic steam control to the North Flare in the future.
Request 4 For each ventingperiod listed in**re~pon.~e** to Request 1above,provide the average rate at which steam and/or air was being added to eachfacilityflare, in lb/hr for steam and/orscjlhrforair, at all locations on the flare (i.e., the sum o.fseal, upper, lower, winterizing, etc.) during each ventingperiod. Provide a narrative explanation and example calculations,**~f** appropriate, describing howyou arrived atyour response. Response 4 The individual responsible for responding to Request 4 is Michael Astin. The people consulted in the preparation ofResponse 4 are Barry Christensen and Conrad Jenson. No documents were consulted, examined, orreferred to in the preparation ofResponse 4, and no documents contain information responsive to Request 4. Holly does not have a flow meter or otherwise collect data onthe mass flow ofsteam or air used for the flares.

Holly Refining &Marketing Company
- Woods Cross Refinery, 393 South 800 West, Woods Cross, UT 84087-1435, Phone (801) 299-6600, Fax (801) 299-6609May 24,2010 Emilio Llamozas, 8ENF-AT Page 5
Request 5 For each ventingperiod listed in response to Request 

### 1 above,provide the average steam-toventgas orair-to-ventgas ratio (lb steam/lb ventgas orscf of air/lb of ventgas) during any release to each facilityflare. Provide a narrative explanation and example calculations, if appropriate, describing howyou arrivedatyour response. Response 5 The individual responsible for responding to Request 5 is Michael Astin. The people consulted inthe preparation ofResponse 5 are Barry Christensen and Conrad Jenson. No documents were consulted, examined, orreferred to in the preparation ofResponse 5, and no documents contain information responsive to Request 5. As indicated in Responses 3 and 4, we have no data on steam or airto vent gas ratios.
Request 6 Provide a one-houraverage of the concentration of each constituent in the vent stream during ventingperiods for the dates beginning one monthprior to your receipt of this request, until the date of receipt of

your request. Response 6 The individual responsible for responding to Request 6 is Michael Astin. Thepeople consulted in thepreparation ofResponse 6 are Michelle Dunbar, Barry Christensen, and Conrad Jenson. No documents were consulted, examined, orreferred to in the preparation ofResponse 6, and no documents contain information responsive to Request 6. Holly does not have data on the concentrations ofconstituents in the vent gas during venting periods.
Request 7 Provide a list of theprimmy constituents in the vent stream released to eachflareforventing periodssinceJanuaJy 1, 2006, and an estimatedrange of each constituent's concentration. Exceptfor the periodspecified in Request 6, you need notdetermine the exact concentration of all compounds for eachperiod of time, but only the mostprominent compounds and an approximate range of concentration. Response 7 The individual responsible for responding to Request 7 is Michael Astin. The people consulted in the preparation ofResponse 7 are Bo Bothwell, Michelle Dunbar, Barry Christensen and Conrad Jenson. Documents that were consulted, examined, or referred to in the preparation ofResponse 7, or that contained information responsive to Request 7 are included on the enclosed disk under the file Response7.pdf, with the number ofthe response (7) in the upper right hand comer ofeach document.

Holly Refining & Marketing Company
- Woods Cross Refinery, 393 South 800 West, Woods Cross, UT 84087-1435, Phone (801) 299-6600. Fax (801) 299-6609May 24,2010 Emilio Llamozas, 8ENF-AT Page 6

Table 7 lists the compounds typically found in vent gas sent to the refinery flares, along with a range of compositions. The compositional ranges are engineering estimates. Comparisons to data onpurchased natural gas and typical refinery plant gas were made, andthat data is included in the enclosed documentation. Holly has no other specific data related to the concentration ofconstituents for the listed venting periods. Table 7 is included onthe enclosed disk in Excel format as Response7.xls.
Request 8 For eachfacilityflare,provide the minimum steam orairaddition rate, in lb/hrforsteam and/orscflhr for air, at all locations on theflare (.\·eal, upperand lower). To the extent that the minimum steam orairaddition rate changes on a seasonal basis, state the minimum ratefor each season and the timeperiods during which each season's minimum rate applies. Response 8 The individual responsible for responding to Request 8 is Conrad Jenson. Thepeople consulted in the preparation ofResponse 8 are Barry Christensen and BrianHarris. Documents that were consulted, examined, orreferred to in the preparation ofResponse 8, or that contained informationresponsive to Request 8 are included onthe enclosed disk under the file Response8.pdf, with the number ofthe response (8) in the upper right hand comer ofeach document. Minimum steam flow rates to the North and South Flares are given on the drawings provided bythe manufacturer for each flare tip. The flare tip for the South Flare has beenreplaced, and so the minimum rate has changed. For the data period requested, the South Flare minimum rates were 525 lbslhr and 375 lbslhr. The North Flare minimum rate is 450 lbs/hr.
Request 9 Provide copies of any andall documents in yourpossession, custody, orcontrol thatprescribe or recommend the amount 

### of steam orair to be added to eachfacilityflare. Provide a copy of the entire document**~r** within the document it states the maximum steam orair rate, minimum steam orair rate, steam or air addition rate associated with a vent scenario, general steam-to-ventgas orair-to-organic gas/ventgas ration, orany other reference to steam addition. Response 9 The individual responsible for responding to Request 9 is Conrad Jenson. The people consulted in the preparation ofResponse 9 are Barry Christensen and Brian Harris. Documents that were consulted, examined, or referred to in the preparation ofResponse 9, or that contained information responsive to Request 9 are included onthe enclosed disk underthe file Response8.pdf, with the number ofthe response (8) in the upperright hand comerofeach document. No documentation otherthan that discussed under Response 8 was found on recommended steam rates.

Holly Refining & Marketing Company
- Woods Cross Refinery. 393 South 800 West. Woods Cross. UT 84087-1435, Phone (801) 299-6600, Fax (801) 299-6609May 24, 2010 Emilio Llamozas, 8ENF-AT Page 7
Request 10 For eachfacilityflare, state with specificity which, 

## if any. Federal and/or state regulations regulate/apply to eachflare. 

## fr any facilityflare is listed in apermit issued underFederal and/or state regulations, provide an electronic copy, preferably in "PDF" format, of each currently effectivepermit. Response 10 The individual responsible for responding to Request lOis Michael Astin. Thepeople consulted in the preparation ofResponse 10 are Bo Bothwell and Eric Benson. Documents that were consulted, examined, orreferred to 

### in the preparation ofResponse 10, orthat contained information responsive to Request 10 are included on the enclosed disk under the file Response1O.pdf, with the number ofthe response (10) inthe upper right hand comer ofeach document. Holly does not believe it appropriate for EPA to pose legal questions in a Section 114 request for information. Thatbeing said, ourunderstanding is that EPA considers that 40 CFR 60 Subparts A and 

### J apply to the North Flare, to the South Flare after 6/30/09, and to the Propane Flare after 12/31/09. The Approval Order for the refinery applies to all 3 flares. In addition, the provisions of40 CFR 60.482 and State Rule R307-326-8 apply to all 3 flares.
Request 11 For eachfacilityflare, state whether theflare is configured to receive gases/vaporsfrom a pressure relief device, which is a safety device used toprevent operatingpressures from exceeding the maximum allowable workingpressure of theprocess equipment. Also state whether theflare and its associated closed vent system is used as the method of compliance with any Federal leakdetection and repair (LDAR) provision. Response 11 The individual responsible for responding to Request 11 is Michael Astin. Thepeople consulted in the preparation ofResponse 11 are Bo Bothwell and Eric Benson. No documents were consulted, examined, orreferred to in the preparation ofResponse 11, and no documents contain information responsive to Request 11. Each ofthe 3 flares is orhas been configured to receive gases/vapors from pressure reliefdevices, which are safety devices to prevent operating pressures from exceeding the maximum allowable workingpressures ofthe process equipment. Since all 3 flares now receive gases/vapors from pressure reliefdevices, each also is considered an LDAR control device.

Holly Refining & Marketing Company
- Woods Cross Refinery, 393 South 800 West, Woods Cross, UT 84087-1435, Phone (801) 299-6600. Fax (801) 299-6609