UNITED STATES

ENVIR~~~~~J:L PROTECTION AGENCRECEI'IEO NOV 18 2010

1595 Wynkoop Street
DENVER, CO 80202-1129
Phone 800-227-8917
http://wNw.epa.gov/region08

Ref: 8ENF-AT
M. P. Bellinger
Refinety Manager
Sinclair Wyoming Refining Company
P.O. Box 277
Sinclair, WY 82334
RE:

NOV 1 5 2010

Sinclair Wyoming Refining Company (SWRC)

Consent Decree Paragraph 68
Civil Action No. 08CV 020-D
Submittal of Alternative Monitoring Plan for# 1 TGTU Bypass Stack

Dear Mr. Bellinger:

The United States Environmental Protection Agency (EPA) received Sinclair Wyoming
Refining Company's (SWRC) submittal of the Alternative Monitoring Plan for #1 Tail Gas
Treatment Unit (TGTU) Bypass Stack. As required by Paragraph 68 of the consent decree,
SWRC shall monitor all tail gas emissions points to the atmosphere. During the life of the
consent decree, SWRC shall monitor these emissions with a continuous emissions monitor
unless an S0 2 alternative monitoring procedure has been approved by EPA per
40 C.P.R. 60.13(i).
The Alternate Monitoring Plan submitted by SWRC documents the calculation
methodology used to quantifY the #L TGTU Bypass Stack S0 2 mass emissions rate during a #1
TGTU malfunction. During normal operations, the #1 and #2 Sulfur Recovery Plants (SRPs) tail
gas streams are routed to an incinerator/waste heat boiler system followed by treatment in the
# 1 TGTU. However, during a # 1 TGTU malfunction the tail gas stream from the SRPs is
rerouted, via a locking valve, to a bypass incinerator and then released directly into the
atmosphere. The calculated SOz mass emission rate is used to determine if a Root Cause Failure
Analysis is required per Paragraph 93 of the consent decree.
The submitted Alternate Monitoring Plan correlates acid gas charge rate and S0 2 tail gas
mass rate from 5 previous testing events. The tests were performed under different past process
flow configurations prior to the installation of the # 1TGTU and do not represent the current
process. The tests were performed in September 2002, September 2003, and October 2005, and
thus more than 5 years old. The 5 data points used to describe a linear relationship presents
itself as a cluster around 15 LTPD and one outlying data point at 46.3 LTPD leaving a large data

gap between them of unknown relationship. Removing one data point could shift the slope
significantly. Moreover, using the linear expression derived from the data, an acid gas charge rate
of zero gives a S02 emission rate of minus 10.2 lb. S02/hr. EPA was not able to reproduce the
same results using standard linear regression analysis.
The Alternate Monitoring Plan does not provide any details on the methodology for
measuring the Acid Gas Charge Rate other than mentioning the values are monitored as patt of
the refine1y's process control system. And, no process control parameters are shown in the plan.
Therefore after reviewing the Alternative Monitoring Plan for #1 Tail Gas Treatment
Unit (TGTU) Bypass Stack submitted on April27, 2010, EPA finds the plan insufficient and
unreliable for use in predicting the S02 mass emission rate during periods of# 1 TGTU
malfi.mction and by-passing of the tail gas stream.
If SWRC elects to submit a revised alternative monitoring plan, the plan must be based
upon a valid statistical model. The model should at least:

provide a greater number of data points to yield greater confidence in the results,
provide more recent emission test measurements representing current process
configurations,
include data points of acid gas charge rates over the entire range of anticipated flows and
have no gaps in the data range,
explain the basis for a linear relationship of the correlation between charge rate and S02
emissions
describe the methodology for measuring the acid gas charge rate and its degree of
accuracy and precision
provide a current process flow configuration, and
give any process operational parameters affecting the correlation between acid gas charge
rate and S02 mass emission rate and provide values observed during tests.

Should you have any questions regarding this request, please contact Scott Whitmore of
my staff at (303) 312-6317, email: whitmore.scott@epa.gov and for inquiries of a legal nature
contact Sheldon Muller at (303) 312-6916, email: muller.sheldon@epa.gov.
Sincerely,

Cynthia J. Reynolds, Director

Office of Enforcement, Compliance,
& Environmental Justice

Certified Mail
Retum Receipt Requested

# 7008 0500 0001 0313 5988

July 28, 2011

Ms. Cynthia J. Reynolds, Director

Office of Enforcement, Compliance and Environmental Justice
United States Environmental Protection Agency Region 8
1595 Wynkoop Street
Denver, CO 80202-1129
Re:

Sinclair Wyoming Refining Company

Civil Action No. 08CV 020-D, Consent Decree Paragraph 68
#I TGTU Bypass Stack - Update on Plan to Monitor S02 Emissions
Letter Ref: 8ENF-AT

Dear Ms. Reynolds:

On November 15, 2010, EPA issued a letter to Sinclair Wyoming Refining Company (SWRC)
regarding SWRC's previously submitted Alternative Monitoring Plan (AMP) for the #1 TGTU
Bypass Stack. On January 14,2011, SWRC submitted its response to EPA's letter and included
a plan to address EPA's issues with the AMP. SWRC has concluded that the AMP for the #1
TGTU Bypass Stack cannot be implemented in a manner that provides reliable and accurate S02
data due to the extreme intennitancy and variability of the emissions from the # 1 TGTU Bypass
Stack. Nonetheless, to achieve the objectives of the Consent Decree, SWRC is committing to
install a Continuous Emission Monitoring System (CEMS) at the #I TGTU bypass stack.
SWRC is currently in the process of obtaining cost estimates for installation of the CEMS.
Once an equipment selection has been made, SWRC will update EPA on the installation
schedule for the CEMS. Please contact Mr. John Pfeffer, Environmental Manager, at (307)
328-3548 with any questions or comments regarding this correspondence.

Sincerely,

n aguire
Refinery Manager
Sinclair Wyoming Refining Company
JM/sbg

Sinclair Wyoming Refining Company

P.O. BOX 277, SINCLAIR, WYOMING 82334
AREA CODE (307) 3243404