:HOLLY
 

REFINING & MARKETING COMPANY - WOODS CROSS 

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

(801) 299·6600 • Fax (801) 299·6609 

~i(k ' 

~:(;rt.: It. .. 

111(., 

Mr. Neil Taylor 

Div. of Environmental Response & Remediation, SERC 1+'";" 

Utah Department of Environmental Quality . 

POBox 144840, 168 North 1950 West 

Salt Lake City, UT 84114 

Sgt. Brent Peters 

Davis County Sheriff's Department 

Davis County LEPC 

800 W. State Street 

Farmington, UT 84025 

RE:	 Reportable Event December 29, 2008 

Unavoidable breakdown of equipment 

To Whom It May Concern: 

CERTIFIED MAll...: 7007 14900001 3861 5891 

; \.. \~

CERTIFIED MAlL: 7007 14900001 3861 5877 

CERTIFIED MAll..: 7007 14900001 3861 5884 

In accordance with Section R307-107, Unavoidable Breakdown, of Utah Air Quality Rules; 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 CPR 302.6, Holly Refining & 

Marketing Company - Woods Cross Refinery notified your offices of excess emissions that resulted from an 

unavoidable breakdown that affected our Sulfur Recovery Unit (SRU). The event resulted in two separate 

.incidents of the SRU breaking down and both incidents are being reported in this report. 

Notification: Bo Bothwell notified the State Emergency Response Committee (SERC) and the Local 

Emergency Planning Conunission (LEPC) the morning of December 29, 2008. The following table 

details notifications for this event. 

Reported equipment breakdown. 12/29/200807:15..

Voice mail • Brent Peters Left a message. 12/29/2008 07:34· .'

Due to the duration of the event, Roy Helmick made additional notifications later the same day to the 

Division of Air Quality (DAQ), the State Emergency Response Committee (SERC) and the Local 

Emergency Planning Commission (LEPC). The following table details notifications for this event. 

._.~.-;
""'~7"--"".

, ;. 

December 29. 2008 

Mr. Neil Taylor, Sgt. Brent Peters 

Page 2 

DAQ 

SERC 

).' LEPC

Voice Mail 

Answering Service 

Voice mail-Brent Peters 

Left a message.
 

Reported equipment breakdown.
 

Left a message.
 

12129/200820:14 

12129/200820:16 

12129/200820:18 

Affected Units: .t\mll.le r.~e.(ltrnellt Unit (Unit 16), SRU (Unit 17), Sour Water Stripper (Unit 18), Gas Oil 

Hydrocracker (Unit 20), North Flare 

Cause and Nature of Event: There was an upset in Unit 20 during startup operations that cascaded to : 

several process units. During the activation of the catalyst in Unit 20, Dimethyl disulfide was added,to' 

Unit 20 at a rate of 5 gallons per minute (gpm) per operating procedures: The acid gas that was: created 

during catalyst activation was sent to Unit 16 and Unit 17 for treatment and overwhelmed the units, . 

'. . ,''' resulting in the interlock of the SRU and bringing the unit down twice); : ,,' ,; ,11 "I 

Duration of Event: Acid gas and sour water stripper gas were routed to the North Flare on December 29, 

2008 from 05:14 to 14:18 and again from 19:26 to 19:49. The total duration of the event was 9 hours and 

27 minutes. 

Estimated Quantity of Pollutants Emitted During the Event: 

Steps Taken to Control Emissions: After the upset condition in Unit 16 and 17 were identified, the feed 

of Dimethyl disulfide to Unit 20 was cut to 1 gpm to reduce acid gas formation. Unit 17 was started up 

as quickly as possible after both interlocks 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. 

In accordance with AO DAQE-ANOI0l230023~7paragraph 12, a sulfur balance was determined for the 

'SRU for January 2,2009 using the method prescribed in our Approval Order. The balance showed a 

sulfur recovery percentage of 95%. 

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

bo.bothwell@hollycorp.com. 

Sincerely

~~

.--1....",/J /~

Bo Bothwell
 

Environmental Engineering Specialist
 

RE 2008-13 SRU (20081229).doc 

cc: M. Astin (r) File S6-2 (4) 

"
 

Holly Refining & Marketing Company - Woods Cross Refinery, 393 South 800 West. Woods Cross. VT 84087-1435, Phone (801) 299-6600, Fax (801) 299-6609 
34.998 

Holly Refining and Marketing - Woods Cross Refinery 

Estimate of Emissions During SRU Upset 

Date/Time 

12/29/08 5:14 AM 

12129/087:49 PM 36.25 9.71 31% 55% 43.63 2792.1
 

Total SO~ '"
 

TonsS02 '"
 

H2S Concentration Test Acid Gas SWS Gas 

frooJ 10/06 perfonnance Average 55.00% 31.00% 

test 

WelBasls 

2792.1 

1.4 

RE 2008-13 SRU upset (20081229) 5/7/20109:41 AM
 

EmiSSions Page 1 of 1
 
HOLLY'
 

,Jr~bru.~)~,.209~,>,i".', . '.. , .• ..... .' ,. " . . - .. ,,' . 1. '_ '. .~'.;' _. 

CERTIFIED MAlL: 7007 14900001 3861 6034

--:(,'""'"~C~'-'-~,-"-i:'att"";""t""'lm"';t""!~-':F=-':''''''l:-:-:-:m''''''''''e~,~=~ ,,:,!:i~~~f~:"~~~.. ,~;li;r.t~§lO~ < "," , CERTIFJED MAJL: 7007 14900001 3861 6041 

,';;,' "';~,\DhLonEIlvironme~tal Response & Remediation, SERC
 

',:r?t;',,{':'(Jtah,Depa.¥leptof Environmental Quality
 

,.:" 'P013ox'14484Q;J68 North 1950 West
 

,',' ,{i,:,i""·~a.rt:B*~.:~t}i::pr,, 84114 

,':·::~6~,j~·~~.fifb~r~~1~':~'-""'· CERTIFIED MAll..: 7007 14900001 3861 6058 

,,',,( :-'IDavis"Coun~y.s~eriff' s Department 

, . 

','" ,'ffio,:WhomltMay Concern: 

,::'::i.k'~f6;di1be:,~ith Section R307-107, Unavoidable Breakdown, ofUtah Air Quality Rules; the Emergency 

''';'';gi~nriirig:~dCommunity Right-to-Know Act (EPCRA), 40 CPR Part 355; and the Comprehensive 

:i,EIlv.iI:o~:rita1Response, Compensation, and Liability Act (CERCLA) 40 CPR 302.6, Holly Refining & 

"J:dl~4~e@g~OornpaI)y - Woods Cross Refinery notified your offices of excess emissions that resulted from an 

~,·':/~ti.n~v:qiq,aWe;preakdoWD that affected our Sulfur Recovery Unit (SRU). The event resulted in two separate 

"':~:';Jncideiitso£dJ:ie;SRU breaking down and both incidents are being reported in this report. ' 

,::: .. :;~~::~;?~~'.: ,,:.:.~;/ .:/.::.?:" ,;-\~ ..:', .. '. . ',:' 

, "',Notifica1ion: Bo Bothwell notified the State Emergency Response Connnittee (SERe) and the Local 

,;;':.']:~tr#gency:Planning Commission (LEPC) on February 11, 2009. The following table details
 

,: ..;,,, n~tificatiO:ils'f()r this event.
 

02/11/200917:05 

Left a message. 02/11/200916:40

Reported equipment breakdown. 

Gave incident information and told 

agency personnel would be in 

contact. 

Voice mail- BrentPeters 

Michael Zucker 

" :.,".... ~,

SERC 

"'Li::PC, 

' ..~.,
1~>:,.

February 17, 2009
 

·····Ms.Cheryl Heying. Mr. Neil Taylor, Sgt. Brent Peters
 

. Page 1. ."
 

"Duet~the d~~~()~(jftheevent, Tom Yarrington made additional notifications to the Division of Air 

." Qmility.(DAQ), th~ State Emergency Response Committee (SERe) and the Local Emergency Planning 

:/':C<nniAission(LEPy);Thefollowing table details notifications for this event. 

0211212009 03:45 

0211212009 03:30 

0211212009 03:45 

Reported equipment breakdown. 

.:: Voice mail-Brent Peters Left a message. 

A:ff~tedUhitS:hnmeTreatment Unit (Unit 16), SRU (Unit 17), Sour Water Stripper (Unit 18), North 

Plate"':''::'' .:"". 

':;,:-caris~·.:hH'&afur'eofEvent: In order to perform some maintenance on the SRU, the combustion air 

b1()wers heededto be changed from one blow to the other. During the switching process, the SRU 

.. mterlocked and shutdown. The SRU was restarted and acid gas was reinterduced, but as the sour water 

C', stfipp~rgas was feed back into the SRU, a high temperature resulted and the gas was removed. The high 

temperatUre is the result of hydrocarbons in the feed to SRU corning from Unit 18. The root cause of the 

ripse(:is:'~till under investigation. 

. oiirairQ~-~fEvent:ACid gas and sour water stripper gas were routed to the North Flare on February 11, 

2009ftoin 10:58 to 00:24 on February 12, 2009. The total duration of the event was 13 hours and 26 

.\·mill:utes. Acitl:gas was sent to the flare for a total of 2 hours and 2 minutes during the event. Sour water 

strippeigas was·sent to the flare for a total of 7 hours and 22 minutes during the event.
 

. 'Esilinated ()u~tity ofPollutants Emitted During the Event:
 :'~.;,!\ ".:'l-: ,:..'i .' 

".,' 

Steps Taken to Control Emissions: When it was discovered that the source of the hydrocarbons was 

coming from Unit 18, the feed to the unit was shutoff. This prevented the flaring of acid gas from Unit 

18 while the hydrocarbon issue was investigated further. 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. 

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

bo.bothwell@hollycorp.com. 

Sincerely, 

1!Y'~

Bo Bothwell 

Environmental Engineering Specialist 

RE2009-03 SRU (20090211).doc 

cc: M. Astin (r) File 56-2 (4) 

C. Jenson 

S. James 

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

Estimate of Emissions During SRU Upset 

Date I Time 

2f11f0910;58AM 

2f1210912:24AM 35.20 7.94 13.4333 32% 65% 43.18 2763.5 

Total S02 = 2763.5 

H2S Concentration 

from if09 CCI 

performance lest 

Wet Basis 

Test 

Average 

Acid Gas 

65% 

SWS Gas 

32% 

(2)
 

RE 2009-03 SRU (20090211) 517/2010 9:55 AM
 

Emissions Page 1 of 1
 
REFINING & MARKETING COMPANY - WOODS CROSS 

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

(801) 299·6600 • Fax (801) 299·6609 

March 2, 2009 

--Mr:-Nei:i-T-aylor-~---- - . CERTIFIED MAll...: 7007 14900001 3861 6089 

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 MAll..: 70071490000138616096 

Davis County Sheriff's Department 

Davis County LEPC 

800 W. State Street 

Fannington, UT 84025 

RE: -Reportable Event February 27, 2009 

Unavoidable breakdown of equipment 

To Whom It May Concern: 

In accordance with Section R307-107, Unavoidable Breakdown, of Utah Air Quality Rules; 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 CPR 302.6, Holly Refining & 

Marketing Company - Woods Cross Refinery notified your offices of excess emissions that resulted from an 

unavoidable breakdown that affected our Sulfur Recovery Unit (SRU). 

Notification: Roy Helmick Jr. notified the Division of Air Quality (DAQ), the State Emergency 

Response Committee (SERe) and the Local Emergency Planning Commission (LEPC) on February 27, 

2009.· The following table details notifications for this event. 

E~~-r-~~·"",·~"",,,=·~~-,,,~?·T""'·"'··"'="""'··';"'c.,,,,~1'·~'ffi~r.··'l'"'''''.",~~~'~

it~{~i~~~ --­ -~

. "DAQ Voice Mail 

ill1~~~ - -~---

Left a message. 02127/200915:52 

SERe Voice Mail Left a message. 02127/200915:53 

LEPC Voice mail- Brent Peters LE;!ft a message. 02127/200915:57 

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

Flare 

Cause and Nature of Event: 

The ,SRU'had been exhibiting signs of partial plugging through the unit as the differential pressure in the 

'unit had increased. It was discovered that the second leg of the reactor was plugged due to a steam trap 

malfunction. As a result of the plugged leg, pressure increased in the reactor and acid gas was vented to 

the flare. 
; ... 

March 2, 2009 

Mr. Neil Taylor, Sgt. Brent Peters 

Page 2 

Duration of Event: Acid gas was routed to the North Flare on February 27, 2009 from 12: 12 to 15:49. The 

total duration of the event was 3 hours and 37 minutes. 

Estimated Quantity of Pollutants Emitted During the Event: 

Steps Taken to Control Emissions: 

When the source of the plugging in the unit was discovered, the problem was quickly resolved. The 

steam trap was repaired and the increased temperature cleared the blockage. Unit 18 was shutdown to 

decrease the amount of gas being feed into the SRU. The decreased feed to the SRU relieved the excess 

pressure in the unit and prevented the acid gas from going to the flare. All excess acid gas was combusted 

in the flare to prevent direct venting to the atmosphere. 

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

bo.bothwell@hollycorp.com. 

Sincerely, 

Bo 

~~

Bothv.:ell 

Environmental Engineering Specialist 

RE 2009-04 SRU (20090227).doc . 

cc: M. Astin (r) File S6-2 (4) 

C. Jenson 

S. James 

",'~H~iiY;R~flning.&MarKeting Company - Woods Cross RefineI)', 393 South 800 West. Woods Cross, LIT 84087·1435, Phone (601) 299-6600, Fax (801) 299·6609 .,.~~ :... : .....;.,", ',' 

......,>.•. 
Holly Refining and Marketing - Woods Cross Refinery 

Estimate of Emissions During SRU Upset 

0.00 

~Time L..-.=~~~--l'L,;,'_--_-_-_-_­ ::" ' 

2/27/0912:12 PM 

2127109 3:49 PM 14.70 3.6167

_-:.- - -_- ' -..-_.~-;";I;';', ' 

32% 

.;.;7­..• ­ - - - ' 

65% 

-._- ­ -;.;. . - "' ' 

25.08 

'..--_.- - ,,--;­ ·­..c_,··,·_--··~' ' 

1605.3 

,;,;., _ 7, ' 

Total So, = 1605.3 

H2S Concentration 

from 1/09 CCI 

perfonnance test 

WeI Basis 

Test 

Average 

Acid Gas 

65% 

SWS Gas 

'32% 

(3
 

RE 2009-04 SRU (20090227) 5/7/20109:55 AM
 

Emissions Page 1 of 1
 
REFINING & MARKETING COMPANY - WOODS CROSS 

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

(801) 299-6600 • Fax (801) 299-6609 

May 6, 2009 

___--,Mr..-NeiJ.-l'ay10r---------oo-oo CERTIFIED MAIL: 7OQ7 1490000138616157 

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 CERTJFIED MAIL: 7007 1490000138616171 

Davis County Sheriff s Department 

Davis County LEPC 

800 W. State Street 

Farmington, UT 84025 

RE: Reportable Event May 5, 2009 

Unavoidable breakdown of equipment 

To Whom It May Concern: 

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

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

CPR 302.6, Holly RefIning & Marketing Company - Woods Cross Reflnerynotifled your offices of excess 

emissions that resulted from an unavoidable breakdown that affected our Sulfur Recovery Unit (SRU). 

Notification: The Night Superintendent notified the Division of Air Quality (DAQ), the State Emergency 

Response Committee (SERC) and the Local Emergency Planning Commission (LEPC) on May 5, 2009. 

The following table details notifications for this event. 

DAQ 

SERC 

LEPC 

Voice Mail 

Voice Mail 

Voice mail - Brent Peters 

Attempted to leave a message. 

Left a message. 

Left a message. 

05/05/2009 19:25 

05/05/2009 19:30 

05/05/2009 19:35 

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

Hydro-Treater (Unit 19), North Flare 

Cause and Nature of Event: 

A pressure transmitter at Unit 19 was blocked in for maintenance, which caused a false reading that 

resulted in a unit upset and interlock. The upset in Unit 19 caused an increase in the fuel gas pressure 

that upset the fuel gas system. The upset in the fuel gas system caused the SRU to interlock and acid gas 

was sent to the flare. 

Duration of Event: Acid gas and sour water stripper gas were routed to the North Flare on May 5,2009 

from 15:16 to 19:51. The total duration of the event was 4 hours and 35 minutes. Acid gas was sent to the 
March 2,.2009 

Mr. Neil Taylor, 8gt. Brent Peters 

Page 2 

flare for a total of 3 hours and 43 minutes during the event. Sour water stripper gas was sent to the flare for 

a total of 4 hours and 26 minutes during the event. 

Estimated Quantity of Pollutants Emitted During the Event: 

Steps Taken to Control Emissions: 

Maintenance personnel were held over to address the problem with the pressure transmitter as quickly as 

possible. Mter the upset condition was corrected, all of the affected process units were started up. 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. 

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

bo.bothwell@hollycorp.com. 

Sincerely, 

BoBothwelI 

Environmental Engineering Specialist 

RE 2009-05 SRU (20090505).doc 

cc: M. Astin (r) File 86-2 (4) 

B. Christensen 

8. James 

'Holly. Refining & Marketing Company - Woods Cross Refinery, 393 South BOD West, Woods Cross. UT 84087-1435. Phone (B01) 299-6600, Fax (801) 299-6609 

I,", ", ..:.' .~ ••: .•" 
Holly Refining and Marketing - Woods Cross Refinery 

Estimate of' Emissions During SRU Upset 

I Date/Time 

5/5/093:16 PM 

515/097:51 PM 12.94 12.41 4.5833 32% 65% 32.07 

Total S02 = 

2052.7 

2052.7 

H2S Concentration Test Acid Gas SWS Gas 

from 1/09 eel Average 65% 32% 

perfonnance test 

Wet Basis 

8;
 

RE 2009-05 SRU (20090505) 517f2010 10:13 AM
 

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

Estimate of Emissions Durin9 SRU Upset from Drager Sample 

~Time 1 ~~..... ..'" '. I. .I".':'U'."'J .. ·' ...... " .... ... ~~"';. I. ..\.nv'~"'.~'6U'U"""": ., .. ;.I'U""'... , 

6/3/09 2:50 PM 

613/09 4:05 PM 32.04 1.2500 0.25 26.42 

Total 502 " 

1690.6 

1690.6 

H2S Concentralion 

from 6/312009 

Drager test 

Test 

Result 

Drager (ppmv) 

2500 

0.25 

Estimate of Emissions During SRU Upset from Mass Balance 

Date/Time ~"HG·!fiWl>.~.".··=""»j1\.\' G_.'!~!":f~~!,J!!

. Unit Feed: .. 

613/09 2:50 PM 

6/3/09 4:05 PM 320.00 1.2500 0.15 331.00 413.6 

Total 502 = 413.6 

NaHS Flaring, NR (20090603) 5/7/20102:39 PMeJ 

Emissions Page 1 of 1