~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 of the Clean Air Act. 

Each of the 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 of Certification
 

I certify under penalty of law that I have examined and am familiar with the information in the enclosed 

documents, including all attachments. Based on my inquiry of those individuals with primary responsibility for 

obtaining the information, I certify that the statements and information are, to the best of my knowledge and 

belief, true and complete. I am aware that there are significant penalties for knowingly submitting false 

statements and information, including the possibility of fines 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) 299-6609 
May 24, 2010 

Emilio Llamozas, 8ENF-AT 

Page 3 

Request 1 For each day beginning on January 1, 2006, until the date ofyour receipt ofthis request, list 

the periods oftime (date, start time, and end time) that combustible material was routed to eachjlare at the 

Holly facility (Le., "venting periods "). For the purpose ofthis requestfor information, "jlare" should be 

broadly defined as any open combustion unit (i.e., lacking an enclosed combustion chamber) whose combustion 

air is provided by uncontrolled ambient air around the jlame, and that is used as a control or safety device. A 

flare may be equipped with a radiant heat shield (with or without a refractory lining), but is not equipped with 

ajlame air control damping system to control the airlfuel mixture. In addition, ajlare may also use auxiliary 

fuel. The combustionjlame may be elevated or at ground level. 

Response I 

The individual responsible for responding to Request I is Eric Benson. 

The people consulted in the preparation of Response 1 are Michael Astin and Bo BothwelL 

Documents consulted, examined, or referred to in the preparation of Response 1 or that contain information 

responsive to Request I include: 

Emissions reports 

Summary calculation sheets for emissions, both reportable and below reporting limits 

A copy each document, with the number of the response (l) in the upper right hand corner, is included on the 

enclosed disk in pdf format, 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 relief gases that generally come from units in the north portion of the refinery, and the South 

Flare handles relief gases that generally come from units in the south portion of the refinery. The Propane Flare 

handles relief gas from our propane storage facility only. At the end of last 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 of last year, this flare was replaced with an air assisted flare. 

Table 1 lists the date, start time, and end time of each period of time 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 1 is 

included on the enclosed disk in Excel format as Response1.xls. Flaring from the Propane Flare due to pressure 

relief from propane storage is rare and the times and dates of this flaring is not recorded. 

Request 2 For each venting period listed in response to Request 1 above, provide the average heating 

value, in BTU/sc.fofthe stream that was vented to each facility flare. The averaging time shall not be greater 

than one hour. Provide a narrative explanation and example calculations describing how you arrived at your 

response. 

Response 2 

The individual responsible for responding to Request 2 is Michael Astin. 

The people consulted in the preparation of Response 2 are Michelle Dunbar, Barry Christensen, and Conrad 

Jenson. 

No documents were consulted, examined, or referred to in the preparation of Response 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) 299-6609 
May 24,2010 

Emilio Llamozas, 8ENF-AT 

Page 4 

No samples of gas being vented were collected for any of the venting periods identified. There is no continuous 

monitoring, nor are regular sample collected from the flare headers. 

Request 3 For each venting period listed in response to Request 1 above, provide the average mass flow 

rate ofall material, combustible and non-combustible, in lb/hr, that was vented to each facility flare. The 

average time shall be no more than one hour. Provide a narrative explanation and example calculations 

describing how you arrived at your response. 

Response 3
 

The individual responsible for responding to Request 3 is Michael Astin.
 

The people consulted in the preparation of Response 3 are Barry Christensen and Conrad Jenson.
 

No documents were consulted, examined, or referred to in the preparation of Response 3, and no documents
 

contain information responsive 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 of the 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 of flaring from unknown sources. The results from
 

these meters have been 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 of the North Flare flow
 

monitor. On occasion, the meter readings 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
 

of these 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 venting period listed in re~pon.~e to Request 1 above, provide the average rate at 

which steam and/or air was being added to each facility flare, in lb/hr for steam and/or scjlhrfor air, at all 

locations on the flare (i.e., the sum o.fseal, upper, lower, winterizing, etc.) during each venting period. Provide 

a narrative explanation and example calculations, ~fappropriate, describing how you arrived at your response. 

Response 4
 

The individual responsible for responding to Request 4 is Michael Astin.
 

The people consulted in the preparation of Response 4 are Barry Christensen and Conrad Jenson.
 

No documents were consulted, examined, or referred to in the preparation of Response 4, and no documents
 

contain information responsive to Request 4.
 

Holly does not have a flow meter or otherwise collect data on the mass flow of steam 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) 299-6609 
May 24,2010 

Emilio Llamozas, 8ENF-AT 

Page 5 

Request 5 For each venting period listed in response to Request 1 above, provide the average steam-tovent gas or air-to-vent gas ratio (lb steam/lb vent gas or scfofair/lb ofvent gas) during any release to each 

facility flare. Provide a narrative explanation and example calculations, ifappropriate, describing how you 

arrived at your response. 

Response 5
 

The individual responsible for responding to Request 5 is Michael Astin.
 

The people consulted in the preparation of Response 5 are Barry Christensen and Conrad Jenson.
 

No documents were consulted, examined, or referred to in the preparation of Response 5, and no documents
 

contain information responsive to Request 5.
 

As indicated in Responses 3 and 4, we have no data on steam or air to vent gas ratios.
 

Request 6 Provide a one-hour average ofthe concentration ofeach constituent in the vent stream during 

venting periods for the dates beginning one month prior to your receipt ofthis request, until the date ofreceipt 

ofyour request. 

Response 6
 

The individual responsible for responding to Request 6 is Michael Astin.
 

The people consulted in the preparation of Response 6 are Michelle Dunbar, Barry Christensen, and Conrad
 

Jenson.
 

No documents were consulted, examined, or referred to in the preparation of Response 6, and no documents
 

contain information responsive to Request 6.
 

Holly does not have data on the concentrations of constituents in the vent gas during venting periods.
 

Request 7 Provide a list ofthe primmy constituents in the vent stream released to eachflarefor venting 

periods since JanuaJy 1, 2006, and an estimated range ofeach constituent's concentration. Exceptfor the 

period specified in Request 6, you need not determine the exact concentration ofall compounds for each period 

oftime, but only the most prominent compounds and an approximate range ofconcentration. 

Response 7
 

The individual responsible for responding to Request 7 is Michael Astin.
 

The people consulted in the preparation of Response 7 are Bo Bothwell, Michelle Dunbar, Barry Christensen
 

and Conrad Jenson.
 

Documents that were consulted, examined, or referred to in the preparation of Response 7, or that contained
 

information responsive to Request 7 are included on the enclosed disk under the file Response7.pdf, with the
 

number of the response (7) in the upper right hand comer of each document.
 

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

gas and typical refinery plant gas were made, and that data is included in the enclosed documentation. Holly 

has no other specific data related to the concentration of constituents for the listed venting periods. Table 7 is 

included on the enclosed disk in Excel format as Response7.xls. 

Request 8 For eachfacilityflare, provide the minimum steam or air addition rate, in lb/hrfor steam 

and/or scflhrfor air, at all locations on the flare (.\·eal, upper and lower). To the extent that the minimum steam 

or air addition rate changes on a seasonal basis, state the minimum rate for each season and the time periods 

during which each season's minimum rate applies. 

Response 8
 

The individual responsible for responding to Request 8 is Conrad Jenson.
 

The people consulted in the preparation of Response 8 are Barry Christensen and Brian Harris.
 

Documents that were consulted, examined, or referred to in the preparation of Response 8, or that contained
 

information responsive to Request 8 are included on the enclosed disk under the file Response8.pdf, with the
 

number of the response (8) in the upper right hand comer of each document.
 

Minimum steam flow rates to the North and South Flares are given on the drawings provided by the
 

manufacturer for each flare tip. The flare tip for the South Flare has been replaced, 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 ofany and all documents in your possession, custody, or control that prescribe 

or recommend the amount ofsteam or air to be added to each facility flare. Provide a copy ofthe entire 

document ~r within the document it states the maximum steam or air rate, minimum steam or air rate, steam or 

air addition rate associated with a vent scenario, general steam-to-vent gas or air-to-organic gas/vent gas 

ration, or any other reference to steam addition. 

Response 9
 

The individual responsible for responding to Request 9 is Conrad Jenson.
 

The people consulted in the preparation of Response 9 are Barry Christensen and Brian Harris.
 

Documents that were consulted, examined, or referred to in the preparation of Response 9, or that contained
 

information responsive to Request 9 are included on the enclosed disk under the file Response8.pdf, with the
 

number of the response (8) in the upper right hand comer of each document.
 

No documentation other than 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) 299-6609 
May 24, 2010 

Emilio Llamozas, 8ENF-AT 

Page 7 

Request 10 For each facili ty flare, state with specificity which, ifany. Federal and/or state regulations 

regulate/apply to each flare. frany facility flare is listed in a permit issued under Federal and/or state 

regulations, provide an electronic copy, preferably in "PDF" format, ofeach currently effective permit. 

Response 10
 

The individual responsible for responding to Request lOis Michael Astin.
 

The people consulted in the preparation of Response 10 are Bo Bothwell and Eric Benson.
 

Documents that were consulted, examined, or referred to in the preparation of Response 10, or that contained
 

information responsive to Request 10 are included on the enclosed disk under the file Response 1O.pdf, with the
 

number of the response (10) in the upper right hand comer of each document.
 

Holly does not believe it appropriate for EPA to pose legal questions in a Section 114 request for information.
 

That being said, our understanding 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 of 40 CFR 60.482 and State Rule R307-326-8 apply
 

to all 3 flares.
 

Request 11 For each facility flare, state whether the flare is configured to receive gases/vapors from a 

pressure reliefdevice, which is a safety device used to prevent operating pressures from exceeding the 

maximum allowable working pressure ofthe process equipment. Also state whether the flare and its associated 

closed vent system is used as the method ofcompliance with any Federal leak detection and repair (LDAR) 

provision. 

Response 11
 

The individual responsible for responding to Request 11 is Michael Astin.
 

The people consulted in the preparation of Response 11 are Bo Bothwell and Eric Benson.
 

No documents were consulted, examined, or referred to in the preparation of Response 11, and no documents
 

contain information responsive to Request 11.
 

Each of the 3 flares is or has been configured to receive gases/vapors from pressure relief devices, which are
 

safety devices to prevent operating pressures from exceeding the maximum allowable working pressures of the
 

process equipment. Since all 3 flares now receive gases/vapors from pressure relief devices, 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