..;. . ..	 

'.' ­

~HOLLY . . ; 

REFINING & MARKETING COMPANY - WOODS CROSS 

393 South 800 West. Woods Cross, Utah 84087-1435 

'"'f'.' (801) 299-6600 • Fax (801) 299-6609 

1anuary 7, 2007 

Mr. Neil Taylor 

Div,ofEnvironmentaJ Response & Remediation; SERC 

Utah D,epartment ofEnvironmental Quality 

PO BbxJ44840, 168 North 1950 West 

.>Salt Lake City, UT 84114 

Sgt. Sue Campbell
 

Davis\County Sheriff's Department
 

Davis County LEPC
 

800 W. State Street
 

Farmington, UT 84025
 ._ ',. 0"" '_~-"~~"""_" __~":"'~~ .' . 

".J" 

RE:	 Reportable Event Januft!1' 4, 2008
 

Unavoidable Breakdown
 

To:v,'hom It May Concern: 

CERTIFIED MAIL: 7006 0100 0002 95368283 

CERTIFIED MAIL: 7006 0100 000295368290 

lnac~ordance with the Emergency Planning and Cormnunity Right-to-Know Act (EPCRA), 40 CPR Part 355; and 

the Comprehensive Environmental Response, Compensation, and Liability Act (CERCIA) 40 CFR 302.6, we 

notified your office of a unit upset that resulted in an interlock of our Sulfur Recovery Unit (SRU). 

Notification: The following notifications were made: 

Kelly Gallagher made notifications at 9:45 a.m. the State Emergency Response Committee (SERC) and the 

Local Emergency Planning Commission (LEPC). In addition, a courtesy notification was made to the Division 

of Air Quality (DAQ) at the same time. All notifications were made on January 4, 2008. 

Affected Units: Amine Treatment Unit (Unit 16), SRU (Unit 17), Sour Water Stripper (Unit 18), North Flare 

Cause and Nature of Event: We have been experiencing foaming in the amine unit regenerator that causes upset 

in that unit, and have been investigating the potential causes of foaming so that we may eliminate them. At 

approximately 5:00 p.m. on January 4 we experienced one such foaming event. The resulting fluctuations in 

acid gas from the amine unit cause an interlock in the SRU 

Duration of Event: As a result of the interlock, acid gas was routed to the flare from 5:42 p.m. until 7:46 p.m. 

Sour water stripper gas was sent to the flare from 5:14 p.m. until 8:18 p.rn. The total duration of the event was 3 

hours'S minutes. 
December 10, 2007 

Mr. Neil Taylor, Sgt. Sue Campbell 

Page 2 

Estimated Ouantity ofPollutants Emitted During the Event: The estimated amount of excess emission was: 

I'. . , .... <'NOx '802···· '.' .'PM " JO .... ,... !:co woc· .,>So1lr.ce .' , ,. ... ,(lbs) ··'.(1bs) . .	 ,nbS) . :(1bS) :(lbs) 

North Flare 2600

Steps Taken-fa-Control Emissions: Operations personnel continued to stabilize the operation of the amine unit,
 

then restarted the SRU. Once the SRU was stabilized on acid gas feed, the sour water stripper gas was
 

reintroduced into the unit. All excess sour gas was combusted in the flare to prevent direct venting to the
 

atmosphere.
 

.Ifyoll have any questions or need additional information, please contact me at (801) 649-3615. 

Sincerely, 

;fi:#.A-Por ..........__ - _ __ _---­

Ralph Jobnson
 SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY 

Environmental Engineering SpeciaL . .1- Complete Items 1, 2, and 3. Also complete 

I Item 4 if-Restricted Delivery is desIred. ZFAgent 

O:\Environmental\Breakdown Reports\l - Print your name and address on the reverse "" X 0 Addressee 

so that we can retum the card to you. . . _ Attach this card to the back of the mailpiec,~j<~ : B. Received by (Printed Name) C. Date of Delivery cc: M. Astm (r) File S6·2 (4 or on the front If space permits. ~;:f!;"" 'o:-;;;;;;;:;;;;~.;rnr~~~/?-lq5--~O~S'~ C. Jenson'tho""'"10Yes 

S. James 1. Artlcle Addressed to:~'1:'	 0 No 

I . ~'fr!6

Mr. Neil Taylor, SERC 

J U!ah Department of Env. Quality 

DIY. ofEnv. Response & Remediation 

168 NOlth 1950 West 

I 

3. Salt Lake City, UT 84]14 . 

Yes 

2.	 Article Number . 

(Transfer-fro",,'; serJtbe iabel) 7006 0100 OOO~ 9536.8283

IPS Form ~~11, FebruarY 2004 , Dom~tic!~etum Receipt 102595-02·M-154< 

Ii ~~~~l~~~~;P;~~~iffs-D-e-p-ar-tl-l1-el-lt-~e-~:,J~
 

I 2. Article Number 

i (Transfer from seMee label) 7006 0100 0002 953b 8290 

j I Da1f1s County LEPC , 

) 800'W. State Street 

I' Farmington, UT 84025 

! 

3.	 Service Type ' . 

lit CertlflBd Mall OExp~ Mall 

o Registered 0 RErturn 'Receipt for Merchandls 

o Insured Mall 0 C.O.O; 

4. Restricted Oelivery? (Extra Fee) Dyes 

i	 D~~~t)c Return Receipt 102595-02·M·15 

Holly Refining & Markeling Company - Woods Cross Refinery, 393 South 800 West, Woods Cross. UT 84087-1435, Phone (801) 299·6600, Fax (801) 299-6609 
't, 

Date 'Time 

1141085:14 PM
 

1141088:19 PM 13.85 17.35 3.0833 32% 63% 40.41
 

Total S02 = 2586.0 

H2S Concentration 

from 8107 performance 

····-··tesl '. 

Wet Basis 

Test 

1 

2 

3 

4 

Average 

Acid Gas 

60.81% 

62.35% 

65.72% 

63.19% 

63.02% 

SWS Gas 

32.04% 

28.49% 

33.18% 

33.89% 

31.90% 

H2S Concentration 

, from 8107 performance 

test 

Dry Basis 

Test 

1 

2 

3 

4 

Average 

\cid Gas H2:.cid Gas H213WS Gas H2~ SWS Gas H20 

72.50% 16.13% 46.89% 31.68% 

74.47% 16.28% 47.14% 39.56% 

74.84% 12.18% 47.81% 30.59% 

74.99% 15.73% 46.85% 27.66% 

74.20% 47.17% 
~HOLLr
 REFINING & MARKETING COMPANY - WOODS CROSS
 

393 South 800 West. Woods Cross, Utah 84087·1435
 

(801) 299·6600 • Fax (801) 299·6609
 

April 25, 2008 

Ms. Cheryl Heying, Director	 CERTIFIED MAJL 7007 14900012386165679, 

Division of Air Quality 

Utah Dept. of Environmental Quality 

150 North 1950 West 

Salt.Lake City, Utah 84114 

Mr. Neil Taylor "	 CERTIFIED MAJL 700714900012386165686 

Utah Department of Environmental Quality 

Div. of Environmental Re.sponse & Remediation, SERC 

PO Box 144840, 168 North 1950 West 

Salt Lake City, UT 84114 

Dep.BtenfPeterlf-- . CERTIFIED MAJL 7007 ·1490 0012 38616 5693 

Davis County Sheriffs Department 

Davis County LEPC 

800 W. State Street 

Farmington, UT 84025 

RE:	 Reportable Event April 23-25, 2008 

Unavoidable Breakdown 

To Whom,It May Concern: 

In accClrdiinc,~,with Section R307-107, Unavoidable Breakdown, of the Utah Air Compliance 

Ru1es;,tj]~':EhiergencyPlanning and Community Right-to-Know Act (EPCRA), 40 CPR Part 355; 

and,fhe':~E>niprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 40 

CFR,-,307.6,H61ly Refilling & Marketing, Woods Cross Refinery (Holly) notified your office of an 

equipm~ntbieakdown on Apri123-25, 2008 because of a power outage. 

Ndtiii'6~tidili"Gary Olsen of Holly notified the State Emergency Response Committee (SERe) 

and.theLocal EinergencyPlanning Commission (LEPC). The following table details 

notifications Jotthis event. " ,i '.:~" ,: •...', ::x . ,." -.. " ".' 

Left a message. 

Notified of incident in progress. 

" " 'Voice mail-Brent Peters 

Affect~d:uliits: Entire Refmery 

.,C~u~e~~nd Nature of Event: A fork lift operator for a contractor company hit a power line 

wit;h:equipmentthat was being moved. This incident occurred at a contractor work area located 
April 25, 2008 

Mr. Cheryl Heying, et al. 

Page 2 

across 500 S. Street from the Woods Cross Refinery. This incident resulted in a power outage 

for the entire refinery and the emergency shutdown of all operating units. 

Duration of Event: The outage occurred at 17:07 on April 23, 2008. Power to the refinery was 

restored at 20:09 that evening. The restart of most units commences immediately after the 

--~-,- restoratfonofpower·toHolly. The initial batch of operating unit restarts was completed by , 

21 :44. It took between 3 and 10 bours to restart the various units in the refinery in an orderly , 

manner. 

The North and South Flares (66-1, 66-2) were smoking at the onset of this incident because of 

the emergency shutdown of the refinery. This flaring subsided by 19:53. Additional flaring was 

recorded between 20:44 after power restoration as a result of operating unit restarts. Intennittent 

flaring continued as additional units were restarted until 23:10 on April 23, 2008. 

Estimated Quantity of Pollutants Emitted During the Event: The estimated amounts of excess 

emissions because of this event are presented in the table below: 

North and South Flares 1241 53 285 108 

CO Boiler (51-6) 30 

Event Total 1241 o 53 315 109 

Steps Taken to Control Emissions: All available operations and maintenance personnel were 

called out on an emergency basis to assist with the orderly shutdown and restart of the refinery. 

Maintenance personnel were able to use an alternate feeder to provide power to the affected area. 

Charge was gradually restored and the boilers were restarted. Flare steam was increased to the 

flare to reduce visible emissions. 

Please contact me with any questions or comments at (801) 299-6619. I can be reacbed by email 

at ralph.jolmson@hollycorp.com. 

Sincerely, 

AM~~ Ralph Johnson
 

Environmental Engineering Specialist
 

.:200"::ll:::80423J'OO 

.c. . C. Jenson 

S. James 

B. Firth 

.~. Holiy'Hefinfng & Marketing Company - Woods Cross Refinery, 393 S, 800 West, Woods Cross, UT 84087-1435, Phone 801-299·6600, Fax 801-299-6609 

:"_::. . 
Holly Refining and Marketing· Woods Cross Refinery 

Estimate of Flaring Upset (monitored flow) 

Date 1TIme 

4/23108 5:00 PM 

4123/08 11 :10 PM 4.75 

( 6.17 

South Flare (66-1) 4.27 4669.16 

North Flare (66-2) 0.55 3219.04 

Average BTU/lb 21850 

AP-42 Emission Factors THC CO 

(Ib/million BTU) 0.14 0.37 

Ibllbmol BTU/set 

2.016 324 

16.043 1009.7 

30.07 1768.8 

44.097 2517.5 

58.124 3257 

72.151 4000 

86.178 4751 

S. Flare N. Flare 

Duration 256 33 

107.71 284.67 52.32 

60.94 161.06 29.60 

46.n 123.62 22.72 

NOx 

0.068 

379.49 setllbmol 

BTUllb 

60989.4643
 

23884.0026
 

22322.6442
 

21665.1036
 

21264.8636
 

21038.655
 

20921.3139
 

Criteria 

S. Flare I N. Flare 

>0 I >0 

RE 08 04 Power Outage Flaring (20080423) 4/24/2008 8:26 AM
 

Shutdown (Flare Monitors) Page 1 of 9
 
Holly Refining and Marketing· Woods Cross Refinery 

Estimate of Emissions During SRU Upset 

Date/TIme 

4123/08 6:00 PM 

4124/08 2:30 AM 18.32 2.42 9.5000 32% 63% 19.39 1241.0 

Total 5°2 • 1241.0 

H2S COncentration Test Acid Gas SW5Gas 

from 8/07 performance 1 60.81% 32.04%
 

test 2 62.35% 28.49%
 

Wet Basis 3 65.72% 33.18%
 

4 63.19% 33.89%
 

Average 63.02% 31.90%
 

H2S Concentration Test \cld Gas H21.cid Gas H2(5WS Gas H2E SW5 Gas H20 

from 8/07 performance 1 72.50% 16.13% 46.89% 31.68% 

test 2 74.47% 16.28% 47.14% 39.56% 

Dry Basis 3 74.84% 12.18% 47.81% 30.59% 

4 74.99% 15.73% 46.85% 27.66% 

Average 74.20% 47.17% 

RE 08 04 Power Outage, SRU (20080423) 4/25/20082:21 PM 

Emissions Page 1 of 9 
I 

- -

\ HOLLY

REFINING & MARKETING COMPANY - WOODS CROSS 

393 South 800 West. Woods Cross, Utah 84087·1435 

(801) 299-6600 • Fax (801) 299-6609 

July 12,2008 

Mr. Neil Taylor CERTIFIED MAlL: 7007 14900001 3861 5808 

Div. of Environmental Response & Remediation, SERC 

Utah Department of Environmental Quality 

PO Box 144840, 168 North 1950 West 

Salt Lake City, UT 84114 

Sgt. Brent Peters CERTIFIED MA1L: 7007 149000013861 5815 

Davis County Sheriffs Department 

Davis County LEPC 

800 W. State Street 

Farmington, UT 84025 

RE:	 Reportable Event July 5,2008
 

Unavoidable breakdown of equipment
 

To Whom It May Concern: 

In accordance with the Emergency Planning and Conununity Right-to-Know Act (EPCRA), 40 CPR Part 

355; and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 40 

CPR 302.6, Holly Woods Cross Refinery notified your offices of excess emissions that resulted from an 

unavoidable breakdown of our Sulfur Recovery Unit (SRU). 

Notification: Kelly Gallagher of Holly notified the State Emergency Response Conunittee (SERC) and 

the Local Emergency Planning Commission (LEPC). The following table detail..s notifications for this 

event. 

UDAQ 

SERC 

LEPC 

No answer. 

Craig Barwitz 

Voice mail-Brent Peters 

None. 

Notified of incident. 

Left a message. 

7/5/200817:00 

7/5/200817:05 

7/5/200817:10 

Affected Units: Amine Treatment Unit (Unit 16), SRU (Unit 17), Sour Water Stripper (Unit 18), North 

Flare 

Cause and Nature of Event: Preliminary results from the investigation indicate that the SRU 

shutdown because the air-demand monitor gave false readings to the unit control system. The readings 

from the monitor did not trigger an automatic shutdown interlock of the SRU. Under this set of 

conditions, the SRU could be restarted, but the unit would not run. 

Duration of Event: Acid gas and sour water stripper gas were routed to the North Flare between 14:47 and 

16:54 on July 5,2008. The total duration of the event was 2 hours and 7 minutes. 
July 12, 2008 

Mr. Neil Taylor, Sgt. Brent Peters 

Page 2 

Estimated Quantity of Pollutants Emitted During the Event: The estimated amount of excess 

emissions resulting from this event was: 

Steps Taken to Control Emissions: The operators attempted to restart the unit several times. 

Maintenance was called out to assist. After the SRU was stabili:red on acid gas feed, the sour water 

stripper gas was reintroduced into the unit. All excess sour gas was combusted in the flare to prevent 

direct venting to the atmosphere. After repairs were made, feed streams were routed back to the SRU 

during the unit's startup. 

Please contact me with any questions or comments at (801) 299-6619. I can be reached by email at
 

ralph.johnson@hollycorp.com.
 

~~lt~ Environmental Engineering Specialist 

RE 2008-09 SRU (20080705).doc 

cc: M. Astin (r)~~')1'

C. Jenson 

S. James 

Holly Relining & Marketing Company' Woods Cross Refinery, 393 South 800 West, Woods Cross, UT 84087-1435, Phone (801) 2.99-6600, Fax (801) 2.99-6609 
Emission calculations for the North Flare (66-2) because of a SRU upset. 

8.45 2.117 32% 

7/5/082:47 PM 

7/5/084:54 PM 8.19 

Date / Time 

63% 20.90 1337.5 

Total 802 = 1337.5 

H28 Concentration _.-;T,;;.es;.;t__-:..=..;;;.:::.-_~;.;;..=~ Acid Gas 8W8Gas

from 8107 performance 1 60.81% 32.04%
 

test 2 62.35% 28.49%
 

Wet Basis 3 65.72% 33.18%
 

4 63.19% 33.89%
 

Average 63.02% 31.90%
 

H28 Concentration Test Acid Gas H28 Acid Gas H208W8 Gas H28 SW8 Gas H20 

from 8107 performance 1 72.50% 16.13% 46.89% 31.68% 

test 2 74.47% 16.28% 47.14% 39.56% 

Dry Basis 3 74.84% 12.18% 47.81% 30.59% 

4 74.99% 15.73% 46.85% 27.66% 

Average 74.20% 47.17% 

Flaring During the Previous Day 7/812008 

Compound THe 802 

(Ibslhr.) 

Note: 

Follow up: 

Yes NG Reportable Event. 

Yes NG Startup, Shutdown and Malfunction Log. 

Yes Annual Emission Inventory 

Yes NG Consent Decree Root-Causa Analysis 

RE 2008·09 SRU Upset (20080705) 7/1212008 2:45 PM
 

Emissions Page 1 of 5
 
..-. 

.,'''''',_.. ".;"{ tr . 

. ":.j' .. ·t,· • '. C' 

.~ 0 .. •• [ • 

REFINING & MARKETING COMPANY - WOODS CROSS
 

'393 South 800 West. Woods Cross, Utah 84087·1435
 

(801) 299·6600 • Fax (801) 299-6609
 

July 29, 2008 

--- Ms: Cberyi'HeYln-g~'birector CERTIFIED MAIL 7007 14900001 3861 5846 

Division of Air Quality 

Utah Dept. of Environmental Quality 

150 North 1950 West 

Salt Lake City, Utah 84114 

Mr. Neil Taylor CERTIFIED MAIL 7007 149000013861 5853 

Utah Department of Environmental Quality 

Div. of Environmental Response & Remediation, SERC 

PO Box 144840, 168 North 1950 West 

Salt Lake City, UT 84114 

Sgt. Brent Peters. CERTIFIED MAn... 7007 14900001 3861 5860 

Davis County Sheriffs Department 

Davis County LEPC 

800 W. State Street 

Farmington, UT 84025 

RE:	 Reportable Event July 23, 2008 

Unavoidable 'Breakdown .	 : ,: ..... 

To Whom:;!t May Concern:	 . 

In accordih2i:~ith'B~dtion R307-107, Unavoidable Breakdown, of the Utah Air Compliance Rules; the 

EmergehCiY~larthi~g~'cl Community Right-to-Know Act (EPCRA), 40 CFR Part 355; and the 

Comprehen~tve EIlvironmental Response, Compensation, and Liability Act (CERCLA) 40 CFR 302.6, 

Holly Refinirig&Marketing Woods Cross Refinery (Holly) notified your office of an equipment 

breakdown onJiily 23, 2008 because of a power outage. 

Notificatio~;'/Ralphijohnson of Holly notified the Utah Division of Air Quality (UDAQ), the State 

Emergency Response Committee (SERC) and the Local Emergency Planning Commission (LEPC). 

The following table details notifications for this event. 

UDAQ Cindy Beem Notified of incident 7/23/2008 09:25 

SERC Mike Zucker Notified of incident 7/23/200809:30 

LEPC Voice mail-Brent Peters Left a message. 7/23/200809:42 

Affected Units: Entire Refinery 

Cause and Nature of Event: Two primary power fuses burned out in Rocky Mountain Power 

Company's Woods Cross Substation. Holly operators witnessed a lightning strike nearby moments 
July 29, 2008 { . Ms. Cheryl Heying, et al.
 

. Page 2
 

before the power outage. This incident resulted in a power outage for the entire refinery and the 

emergency shutdown of all operating units. 

Flaring was recorded during the emergency shutdown, and then intermittently during startup of the 

units. 

,.,....,..---··--·Th~·-H~S j-hour average concentration limit of 160 ppmv for plant fuel gas was exceeded for two 

hours. This exceedance was due to the high hourly concentration averages during the hours ending 

at 02:00 and 03:00. During those hours the refinery was without power and plant fuel gas was not 

being created. Plant fuel gas was not being used because the heaters and boilers were offline. 

Duration of Event: The outage occurred at 00:30 on July 23, 2008. Power to the refinery was 

restored at 04: 16 that morning. The restart of most units commenced immediately thereafter. It took 

between 2 and 23 hours to restart the various units in the refinery in an orderly manner. 

Estimated Quantity of Pollutants Emitted During the Event: The estimated amounts of excess 

emissions because of this event are presented in the table below: 

South Flare 150 180 990 370 

North Flare 7800 50 250 90 

CO Boiler (51-6) 150 o 

Event Total 7950 o 230 1390 460 

Steps Taken to Control Emissions: All available operations and maintenance personnel were called 

out on an emergency basis to assist with the orderly shutdown and restart of the refinery. 

Maintenance personnel were able to use an alternate feeder to provide power to the affected area. 

Charge was gradually restored and the boilers were restarted. Flare steam was increased to the flare 

to reduce visible emissions. 

Please contact me with any questions or comments at (801) 299-6619. I can be'reached by email at 

ralph.johnson@hollycorp.com. 

Sincerely, 

~~-gr: Environmental Specialist 

RE 2008·10 Power Outage, Refinery (20080723).doc 

CC: 

c. 

M. 

Jenson 

Astin (r) ~/

S. James 

B. Firth 

1. Wager 

Holly Refining & Marketing Company· Woods Cross Refinery, 393 S. BOO West, Woods Cross, UT B40B7-1435, Phone 901-299·6600. Fax 801-299-6609 

 

Holly Refining and Marketing - Woods Cross Refinery 

Estimated Emissions Calculations for SRGP Compressor Upset. 

Date/Time 

7/23106 00:35 

7/2310607:27 214.65 6.6667 72.47 191.52 35.20 150.7 

AP-42 Emission Factors 

(Iblmillion BTU) 

THe 

0.14 

co 

0.37 

NOx 

0.068 

Fuel Stream 

Sent to Fuel Gas? 

Heat Content [BTU/sef) 

Total Flows (mscf) 

Avg. H2S Content (%) 

116 Crude OH 119 HDS Str. OH 

No No 

2624.00 399.63 

176.99 0.06 

0.16 17.00 

#9 LP Rash 

No 

399.63 

2.30 

17.00 

#11 DeC20H 

Yes 

1366.64 

0.00 

0.61 

#12 Stab OH 

Yes 

1406.16 

0.00 

0.10 

#6 Pre!. OH 

No 

3202.60 

5.67 

0.40 

#13 Stab OH19 Str OH Ace 

Yes No 

1576.80 1020.00 

0.00 27.63 

0.00 0.54 

2409.19 

214.65 

0.42 

Flaring During the Previous Day: 7/2212006 

Compound THC S02
 

(Ibslhr.) 141.9 117.6
 

Note: 

Clark shutdown because of a Load Too High interlock due to a head-gasket failure. 

Follow up: 

Yes NG Reportable Event. 

Yes NG Startup, Shutdown and Malfunction Log. 

Yes NG Annual Emission Inventory 

Yes NG Consent Decree Root-Cause Analysis 

RE 2008-10 Power Outage, Clark Upset (20080723) 7/30/200810:59 AM
 

Emissions Page 1 of 17
 
Holly Refining and Marketing - Woods Cross Refinery 

Estimate of Emissions During SRU Upset 

Dale/Time 

7123108 12:30 AM 

7123/084:13 PM 57.54 44.33 15.7167 32% 63% 121.82 7796.7 

Total 502 =' n96.7 

H2S Concentration 

from 8107 performance 

test 

Wet Basis 

Test 

2 

3 

4 

Average 

Acid Gas 

60.81% 

62.35% 

66.72"10 

63.19% 

63.02% 

SWSGas 

32.04% 

28.49% 

33.18% 

33.89% 

31.90% 

H2S Concentration 

from 8/07 performance 

test 

Dry Basis 

Test 

1 

2 

3 

4 

Average 

kid Gas H2hcid Gas H2(3WS Gas H2~SWS Gas H2O 

72.60% 16.13% 46.89% 31.68% 

74.47% 16.28% 47.14% 39.56% 

74.84% 12.18% 47.81% 30.59% 

74.99% 15.73% 46.85% 27.66% 

74.20% 47.17% 

RE 2008-10 Power Outage, SRU (20080723) 7/24/20088:15 AM 

Emissions Page 1 of 29 

... ­ --_._-----­
[HOLLY]
 

_~.~,,-..,.,..... ·:~.S~pt~m~er 25, 2008 

.....:.. )::.. ,-e; .Mr:-N"eiiTayior ':~'::,~::.~. .' 

REFINING & MARKETING COMPANY - WOODS CROSS 

393 South 800 West. Woods Cross, Utah 84087·1435 

(601) 299-6600 • Fax (801) 299·6609 

CERTIFIED MAlL: 7007 14900001 3861 5921 

'v .',+"'t>tv. ot"Environmental Response & Remediation, SERe 

i, ''''::Utah Department of Environmental Quality 

} .. , "POBox 144840, 168 North 1950 West 

,; Salt Lake City, UT 84114 

Sgt. Brent Peters CERTIFIED MAll...: 7007 1490 0001 3861 5945 

Davis County Sheriffs Department 

Davis County LEPC 

800 W. State Street 

Farrrrington, l!T 84025 

RE:	 Reportable Event September 19-20, 2008
 

Unavoidable breakdown of equipment
 

To Whom It May Concern: 

In accordance with the Emergency Planning and Community Right-to-Know Act (EPCRA), 40 CPR Part 

355; and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 40 

CFR 302.6, Holly Woods Cross Refinery notified your offices of excess emissions that resulted from an 

unavoidable breakdown of our Sulfur Recovery Unit (SRU). 

Notification: Roy Helmick of Holly attempted to notify the State Emergency Response Corrunittee 

(SERC) and notified the Local Emergency Planning Commission (LEPC). Ralph Johnson contacted the 

Utah Division of Air Quality (UDAQ). The following table details notifications for this event. 

UDAQ 

SERC 

LEPC 

Harold Burges 

No answer. 

Voice mail-Brent Peters 

Reported equipment breakdown. 

None (3 attempts).. 

Left a message. 

9/25/200813:00 

9/19/2008 15:37 

9/1912008 15:40 

Affected Units: Amine Treatment Unit (Unit 16), SRU (Unit 17), Sour Water Stripper (Unit 18), North 

Flare 

Cause and Nature of Event Preliminary results from the investigation indicate that the SRU shutdown 

because the tail-gas incinerator flame detector gave false readings to the unit control system. The 

readings from the detector triggered an automatic shutdown interlock of the incinerator. This resulted in 

a time-out interlock of the thermal reactor that ended in the shut down of the entire unit. 

Duration of Event: Acid gas and sour water stripper gas were routed to the North Flare starting September 

19, 2008 at 6:56 and ending September 20, 2008 at 17:38. The total duration of the event was 34 hours and 

42 minutes. 
Septembef25,2008 

Mr,'Neil Taylor, Sgt. Brent Peters 

Page 2 

~. ; ~.~ , Estimated Quantity of-Pollutants Emitted During the Event: 

Steps Taken to Control Emissions: The operators attempted to restart the tail-gas incinerator several 

. time·s. Maintenance was called out to assist. After the SRU was stabilized on acid gas feed, the sour 

water stripper gas was reintroduced into the unit. All excess sour gas was combusted in the flare to 

prevent direct venting to the atmosphere. After repairs were made, feed streams were routed back to the 

SRU during the unit's startup, 

Please contact me with any questions or comments at (801) 299-6619. I can be reached by email at 

ralph.johnson@hollycorp.com. 

Sincerely, 

Allp I!J .~ '+zj:::

:a:~oh1o~ Environmental Engineering Specialist 

RE 2008-11 SRU (20Z;:­

CC: M. Astin (r) . 

C. Jenson 

S. James 

800 W. 3I!ateBtreet 3. Servioe Type I 

Farmington, UT 84025 ):1Cerllfled Men 0 Express Mall I 

o RegIstered 0 Retum Receipt for Merchandise I 

o Insured Mall 0 C.O.D. i 

4. Restricted Del/very? (Extra Feel 0 Yes 

!. Article Number 

(TtanSfet fromservfce IBbeQ 7007 1490 0001 3861 594-5 

'3 Fonn 3811, February 2004 

ENDER: COMPLETE: THIS SE:CTlON 

ENDER: COMPLETE THIS SECTION 

•	 Complete ftems 1, 2, and 3. Also complete 

Item 4 if Restricted Delivery Is desired. 

•	 Print~ur name and address on the reverse so th we can return the card to you. 

•	 Attac . his card to the back of the mmlplece, 

or on e front If space permits. \i", 

1. ArtIcle AcldlBSSedto: 

. Sgt. Br~ers

Davis C~.Sheriff' s Department 

Davis C*WLEPC 

-.:w~\ "'!';l,

., 

'j 

COMPLETE THIS SECTION ON DELIVERY 

COMPLETE THIS SECTIOIII ON DELIVERY 

by (Printed ~)

~A--~ D.	 Is delivery address different from Item 1? 

If YES, enter delivery address below: 

I 

I 

i' 

,.. Holly Rellnin.g& Marketing Company - Woods Cross Refinery, 393 South 800 Wesl. Woods Cross. UT 84087-1435. Phone (801) 299-6600, Fax (601) 299-6609 

t 
Holly Refining and Marketing· Woods Cross Refinery \ 

Estimate of Emissions During SRU Upset 

Date/Time 

9/19108 6:56 AM
 

9120108 5:38 PM 167.09 1.27 34.7000 32% 63% 142.37 9111.7
 

Total S02 = 9111.7 

Tons 01S02= 4.56 

H2S Concentration Test Acid Gas SWSGas Rate (Ibslhr.) = 262.59 

from 8/07 performance 1 60.81% 32.04% 

test 2 62.35% 28.49% 

Wet Basis 3 65.72% 33.18% 

4 63.19% 33.89% 

Average 63.02% 31.90% 

H2S Concentration Tesl \cld Gas H2~,cid Gas H2<3WS Gas H2:: SWS Gas H2O 

from 8107 performance 1 72.50% 16.13% 46.89% 31.68% 

lesl 2 74.47% 16.28% 47.14% 39.56% 

Dry Basis 3 74.84% 12.18% 47.81% 30.59% 

4 74.99% 15.73% 46.85% 27.66% 

Average 74.20% 47.17% 

RE 2008-11 SRU Interlock (20080919) 9/25/2008 4:36 PM
 

Emissions Page 1 of 50