By Certified Mail Return Receipt Requested · 9/26/2019 · Operating Permits issued to Suncor Energy for the operation of the Commerce City refinery. Both operating permits specifically

September 26, 2019 By Certified Mail Return Receipt Requested Mark Little President and CEO Suncor Energy, Inc. PO Box 2844 150 – 6 Ave. SW Calgary, Alberta Canada T2P 3E3

Suncor Energy USA, Inc. 717 17th St. Denver, CO 80202

Re: Notice of Intent to File Suit Over Clean Air Act Violations at Suncor’s Commerce

City Oil Refinery North of Denver Dear Mr. Little:

Pursuant to the Clean Air Act, 42 U.S.C. § 7604(b)(1), this letter serves as notice that WildEarth Guardians intends to sue Suncor Energy, Inc. in federal court to enforce ongoing violations of the Clean Air Act at the company’s Commerce City oil refinery. Specifically, the company has violated and continues to violate permit conditions limiting the release of harmful emissions to ensure protection of public health and the environment.

For years, the company has regularly violated numerous emission limits at the Commerce

City refinery, including limits on hydrogen sulfide, sulfur dioxide, carbon monoxide, particulate matter, and more. In recent months, the company has regularly violated limits on opacity pollution, which is a measure of the thickness of pollution that is released from the refinery’s stacks. Opacity is an indicator of harmful emissions and violations of opacity limits at the Commerce City refinery is an indicator of dangerous pollution release. Based on Suncor’s own certified monitoring reports, there have been more than 2,750 violations of opacity limits at the refinery since December 31, 2018.

The Commerce City refinery is a chronic clean air violator and we intend to put an end to

that. With this notice letter, we are formally putting Suncor on notice of our intent to sue over

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many of these violations and to secure real accountability to public health and the environment in the Denver Metro Area and in Colorado.

Under the Clean Air Act, citizens are entitled to bring suit against any person who has violated “an emission standard or limitation.” 42 U.S.C. § 7604(a)(1). An “emission standard or limitation” includes “any emission limitation, standard of performance, or emissions standard” or “any standard, limitation, or schedule established under any permit issued pursuant to subchapter V [of the Clean Air Act].” 42 U.S.C. § 7604(f)(1) and (4). Citizens can file suit in federal court and enjoin violations of the Clean Air Act, seek civil penalties for such violations, and secure other relief. WildEarth Guardians intends to bring suit to enjoin violations of the Clean Air Act at Suncor’s Commerce City oil refinery, seek civil penalties for such violations, and secure other relief that may be necessary and appropriate.

Under the Clean Air Act, penalties of up to $99,681 per day per violation are provided to

deter future violations. See 84 Fed. Reg. 2056, 2059 (Feb. 6, 2019). We estimate that Suncor faces more than $274 million in penalties due to ongoing violations of the Clean Air Act.

I. The Commerce City Refinery and Emission Sources at Issue

The Commerce City oil refinery is located north of Denver, Colorado. The facility consists of three separate, but related and adjacent plants: A west plant, called Plant 1, an east plant, called Plant 2, and an asphalt plant, called Plant 3. Plant 1 and Plant 3 are located at 5801 Brighton Blvd., Commerce City, CO 80022. Plant 2 is located at 5800 Brighton Blvd., Commerce City, CO 80022. The refinery consists of numerous sources of air pollution, including storage tanks, fluid catalytic cracking units, internal combustion engines, heaters, boilers, sulfur recovery units, flares, and more.

Suncor Commerce City oil refinery. Photo by Suncor.

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According to Suncor’s air quality permitting information on file with the Colorado Air Pollution Control Division and data reported to the U.S. Environmental Protection Agency (“EPA”), the facility has the potential to release more than 900,000 tons of dangerous air pollutants, including particulate matter, sulfur dioxide, and greenhouse gases.

Emissions From Suncor Commerce City Refinery1

Pollutant Potential Emissions (tons per year)

Particulate Matter 1,072 PM10 810 Nitrogen oxides 2,238 Sulfur dioxide 5,424 Volatile organic compounds 1,822 Carbon monoxide 1,041 Greenhouse gas emissions 889,476

TOTAL 901,883 The refinery also releases a number of pollutants that are known to be especially toxic for human health, including benzene, a known carcinogen, and hydrogen sulfide, which is lethal at high levels. According to EPA’s Toxic Release Inventory data from 2017, the refinery releases thousands of pounds of toxic emissions. An abbreviated list of these toxic pollutants and total emissions is detailed in the table below:

2017 Air Toxics Emissions From Suncor Commerce City Refinery2

Pollutant Potential Emissions (pounds per year)

Ammonia 2,253 Benzene 4,233 Ethylbenzene 799 Hydrogen cyanide 18,511 Hydrogen sulfide 6,068 Lead compounds 82 Mercury compounds 4 Propylene 75,933 Toluene 5,665 Xylene 2,494

TOTAL 116,042

1 Emissions data from Technical Review Document for Operating Permit 96OPAD120 (Oct. 2003), available online at https://drive.google.com/file/d/0B0tmPQ67k3NVXzB5WWFTNHc4ak0/view?usp=sharing; Technical Review Document for Operating Permit 95OPAD108 (Sept. 2002), available online at https://drive.google.com/file/d/0B0tmPQ67k3NVcmtPR1BmdG1fVDA/view?usp=sharing; and EPA’s 2 Toxic Release inventory data for the Suncor refinery is available online here, https://iaspub.epa.gov/triexplorer/release_fac_profile?TRI=80022CNCDN5801B&TRILIB=TRIQ1&FLD=&FLD=RELLBY&FLD=TSFDSP&OFFDISPD=&OTHDISPD=&ONDISPD=&OTHOFFD=&YEAR=2015.

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The Commerce City refinery has been assigned Aerometric Information Retrieval System, or AIRS, ID 001-0003, which identifies the facility as a unique stationary source of air pollution. The refinery operates under two permits issued pursuant to Title V of the Clean Air Act.3 One permit governs operations of Plant 2, or the East Plant. See Operating Permit, Suncor Energy (U.S.A.) Inc. – Commerce City Refinery, Plant 2 (East), Operating Permit No. 96OPAD108 (hereafter “East Plant Title V Permit”).4 This permit, which has been assigned permit number 95OPAD108, was last revised June 15, 2009. The second permit governs operations of Plants 1 and 3, or the West Plant and Asphalt Unit. See Operating Permit, Suncor Energy (U.S.A.) Inc. – Commerce City Refinery, Plant 1 (West Plant) and Plant 3 (Asphalt Unit), Operating Permit No. 96OPAD120 (hereafter “West Plant Title V Permit”).5 This permit, which has been assigned permit number 96OPAD120, was last revised on February 22, 2018. At issue in this case is the operation of two Fluid Catalytic Cracking Units (“FCCUs”), one of which is located at the West Plant and the other at the East Plant. FCCUs are used to convert crude oil into more valuable petroleum products, including gasoline. Operation of the FCCUs at the Commerce City refinery are governed by Suncor’s Clean Air Act Title V Operating Permits. The East Plant Title V Permit addresses operation of its FCCU, identified as unit P003, at Section II, Condition 2. The West Plant Title V Permit addresses operation of its FCCU, identified as unit P103, at Section II, Condition 22.

II. Applicable Clean Air Act Requirements

Under the federally approved Colorado State Implementation Plan (“SIP”), which is a set of state regulations that have been incorporated into federal rules pursuant to the Clean Air Act, stationary sources of air pollution must limit the opacity of their emissions to no more than 20%. The SIP specifically states, “no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity.” Air Quality Control Commission (“AQCC”) Regulation No. 1, Section II.A.1. According to the SIP, “[t]his standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes.” Id.

This 20% limit on opacity has been incorporated into both Clean Air Act Title V

Operating Permits issued to Suncor Energy for the operation of the Commerce City refinery. Both operating permits specifically require that each emission point at the refinery meet the 20% opacity limit established by the SIP. See West Plant Title V Permit at Section II, Condition 35.1 and East Plant Title V Permit at Section II, Condition 19.1. Furthermore, both of Suncor’s Title V Operating Permits also specifically require compliance with the Colorado SIP’s 20% limit on opacity with regards to the operation of the FCCUs. See West Plant Title V Permit at Section II, Condition 22.7.1 and East Plant Title V Permit at Section II, Condition 2.8.

3 Title V requires that major sources of air pollution comply with operating permits to assure compliance with all applicable requirements under the Clean Air Act. 42 U.S.C. § 7661a. It is “unlawful” for any person to violate any requirement of a Title V Operating Permit. 42 U.S.C. § 7661a(a). 4 Title V Operating Permit for the East Plant is available on the Colorado Air Pollution Control Division’s website at https://drive.google.com/file/d/0B0tmPQ67k3NVQldDd0JrY2lITDA/view?usp=sharing. 5 The Title V Operating Permit for the West Plant is available on the Colorado Air Pollution Control Division’s website at https://drive.google.com/file/d/17Ft7iaBbIkfbgWnrZ_QXzFTVHa6rrbkl/view?usp=sharing

5

Both of Suncor’s Title V Operating Permits require the use of continuous opacity monitoring systems (“COMS”) to assure compliance opacity limits at the FCCUs. See West Plant Title V Permit at Section II, Conditions 22.9.3 and 59.1, and East Plant Title V Permit at Section II, Condition 19.5.2.

III. Opacity Violations at the Commerce City Refinery

Since December 31, 2018, Suncor has reported thousands of violations of applicable opacity limits at its FCCUs. According to the company’s own data submitted in certified semi-annual emission reports to the Colorado Air Pollution Control Division, the Commerce City refinery violated applicable 20% opacity limits for 14,526 minutes at the West Plant and 1,974 minutes at the East Plant. These violations are based on Suncor’s certified COMS.

Based on Suncor’s August 26, 2019 certified semi-annual deviation reports submitted to

the Air Division for the West and East Plants, there were at least 110 incidents between December 31, 2018 and June 30, 2019 where opacity exceeded the applicable 20% limit. Based on the fact that opacity violations are measured on a six-minute basis, the total number of violations amounts to 2,750. Suncor’s semi-annual deviation reports are attached to this notice letter as Exhibits 1 and 2.

A spreadsheet summarizing these violations is attached as Exhibit 3. This spreadsheet

identifies the date and time that the excess opacity incident started, the date and time that it ended, and applicable requirements. The violations include a stretch of excess opacity from January 1, 2019 to January 8, 2019 at the West Plant, a stretch of excess opacity from April 10, 2019 to April 12, 2019 at the West Plant, a stretch of excess opacity from May 24, 2019 to May 25, 2019 at the East Plant, among many other excess opacity incidents.

Total Minutes and Total Violations of 20% Opacity Limit at Commerce City Refinery

Plant Minutes of Opacity Above 20% Total Violations

East 1,974 329 West 14,526 2,421

TOTALS 16,500 2,750

Although Suncor may claim that these opacity violations occurred during startup, shutdown, and/or malfunction events, there are no exemptions to the Colorado SIP’s opacity limits. Nothing in the company’s Title V Operating Permits or the SIP provides an exemption to compliance with opacity requirements in the event of a startup, shutdown, and/or malfunction.

Accordingly, Suncor’s own monitoring shows the company has violated both the

Colorado SIP and its Title V Operating Permits on thousands of occasions since December 31, 2018. The company’s monitoring and reports show that over the last several months, the Commerce City refinery has regularly violated applicable opacity limits.

These opacity violations have come as Suncor has reported excess emissions from

numerous other sources at the Commerce City refinery, including excess hydrogen sulfide from

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flares, excess sulfur dioxide, and excess visible emissions from flares. The opacity violations seem indicative of an overall failure of Suncor to properly operate, maintain, and upgrade the Commerce City refinery in order to assure constant compliance with the Clean Air Act.

IV. Notice of Intent to File Suit

Under the Clean Air Act, citizens may file suit against any person who violates an emission standard or limitation.

Based on aforementioned ongoing violations at the Commerce City refinery, WildEarth Guardians intends to sue Suncor Energy in federal court to enjoin violations, seek civil penalties, and secure any additional relief that may be appropriate and necessary. We intend to file suit over the opacity violations listed in Exhibit 1 to this letter, which occurred between December 31, 2018 and June 30, 2019. We also intend to file suit over any additional opacity violations occurring subsequent to June 30, 2019.

We will file suit if we cannot achieve a resolution beforehand that addresses Suncor’s ongoing noncompliance and failure to operate the Commerce City refinery in accordance with the Clean Air Act. WildEarth Guardians is not barred from suing to enforce the aforementioned violations. Under 42 U.S.C. § 7604(a)(1) of the Clean Air Act, citizen suits are barred only where a state “has commenced and is diligently prosecuting a civil action in a court [] of a state.” 42 U.S.C. § 7604(b)(1)(B). No action has been filed in state court by the State of Colorado regarding the aforementioned opacity violations. Thus, no diligent prosecution is occurring.

If you have questions or would like to discuss this matter further, please contact me at the information below. Thank you. Sincerely,

Jeremy Nichols Climate and Energy Program Director WildEarth Guardians 2590 Walnut St. Denver, CO 80205 (303) 437-7663 [email protected]

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cc (by certified mail): Andrew Wheeler Gregory Sopkin Administrator Regional Administrator U.S. Environmental Protection Agency U.S. Environmental Protection Agency 1200 Pennsylvania Ave. NW EPA Region 8 Washington, D.C. 20460 1595 Wynkoop St

Denver, CO 80202 Jill Hunsaker Ryan Jared Polis Colorado Department of Public Health Governor State of Colorado and Environment 200 E. Colfax Ave., Room 136 4300 Cherry Creek Drive South Denver, CO 80203 Denver, CO 80246 Suncor Energy Registered Agent The Corporation Company 7700 E. Arapahoe Rd., Ste. 220 Centennial, CO 80112

Exhibit 1

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August 26, 2019

Suncor Energy

Commerce City Refinery

5801 Brighton Blvd.

Commerce City, Colorado 80022

Tel (303) 286-5701

Fax (303) 286-5702

www.suncor.com

Mr. Matt Burgett Colorado Department of Public Health and Environment

Air Pollution Control Division

Operating Permits Unit

APCD - SS - B1

4300 Cherry Creek Drive South

Denver, CO 80246-1530

Hand Delivered

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RE: Suncor Energy (U.S.A.) Inc. Denver Refinery (East Plant, Plant 2) Title V Operating Permit (950PAD108) Annual Compliance Certification Report July 1,2018 - June 30, 2019

Semi-Annual Deviation Report January 1, 2019 - June 30,2019

Dear Mr. Burgett:

Suncor Energy (U.S.A.) Inc. is submitting the attached Annual Compliance Certification Report and Semi-

Annual Deviation Report as required in Appendix B of our Operating Permit. The Annual Compliance Certification Report covers the annual period July 1, 2018 through June 30, 2019. The Semi-Annual

Deviation Report covers the period January 1, 2019 through June 30,2019.

The attachments include the Annual Compliance Certification Report (Attachment A) and the Semi-

Annual Deviation Report (Attachment B). As required under Appendix D of the Operating Permit, a

separate copy of the Annual Compliance Certification Report has also been submitted to the United

States Environmental Protection Agency, Office of Enforcement, Compliance and Environmental Justice.

Please feel free to contact Ramesh Gopal at (303) 286-5315 or [email protected] if you have any

questions.

Attachments (3)

cc: USEPA Region VIII, Denver, CO

Jason Long - APCD

Certified Receipt NO.7019-0140-0001-0119-3735

Certified Receipt NO.7019-0140-0001-0119-37 42

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ATTACHMENT 1

Annual Compliance Certification Report

Suncor Energy (U.S.A.) Inc.

Commerce City Refinery (East Plant, Plant 2)

Title V Annual Compliance Certification Report

FACILITY NAME: Suncor Energy (U.S.A.) Inc. - Commerce City Refinery (Plant 2) OPERATING PERMIT NO: 950PAD108

REPORTING PERIOD: 7/1/2018 - 6/30/2019

I. Facility Status

_

During the entire reporting period, this source was in compliance with ALL terms

and conditions contained in the Permit, each term and condition of which is identified

and included by this reference. The method(s) used to determine compliance is/are the

method(s) specified in the Permit.

~ With the possible exception of the deviations identified in the table below, this

source was in compliance with all terms and conditions contained in the Permit, each

term and condition of which is identified and included by this reference, during the entire

reporting period. The method used to determine compliance for each term and condition

is the method specified in the Permit, unless otherwise indicated and described in the

deviation report(s). Note that not all deviations are considered violations.

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8002 FCCU Pre-Heater

F002 FCCU Fugitives

FOO? Reformer Fugitives

P004 Reactor-Regenerator

P014 Catalyst Handling

P005 Naphtha Hydrotreater/Reformer

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8004 Heater #2

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Regeneration)

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F009 Reactor #2 (Catalyst Unloading) -- -- X --

X--

F030 Reactor #2 (Catalyst Loading) -- -- X --

X--

P009 Sulfur Recovery Plant -- X X -- -- X

8011 Sulfur Recovery Unit Incinerator -- -- X --

X--

F013 Amine Unit and Fuel Gas X

Fugitives-- -- X -- --

P008 Amine Unit -- -- X --

X--

BOO -- _. X --

X--

~ -- -- X --

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-- 8504 -- -- X --

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-- 8505 -- -- X --

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P011 Cooling Tower -- -- X --

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F015 South Crude Unloading -- -- X --

X--

F016 North Crude Unloading -- -- X --

X--

F024 Truck Loading Dock -- -- X --

X--

F028 Aviation Fuel Transfer Station -- -- X --

X--

C005 Refinery Flare -- X X -- -- X

F018 Refinery Flare Fugitives -- -- X --

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F019 Railcar Dock -- -- X --

X--

F020 Truck Dock -- -- X --

X--

T050 Pressure Tank 50 -- -- X --

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Wastewater Treatment Plant -- -- X -- X --

F021 API Separators - Upper API X -- X -- -- X

2

Suncor Energy (U.S.A.) Inc. Commerce City Refinery (East Plant, Plant 2)

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F012 Gas Plant Fugitives / Sewers -- -- X --

X--

F025 Sour Water Stripper Sewers -- -- X --

X--

F027 South Crude Unloading Sewers -- -- X --

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T010 Tank 10 -- -- X --

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T011 Tank 11 -- -- X --

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T027 Tank 27 -- -- X --

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T030 Tank 30 -- -- X --

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T009 Tank 9 -- -- X --

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T042 Tank 42 -- -- X --

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T043 Tank 43 -- -- X --

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T045 Tank 45 -- -- X --

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T048 Tank 48 -- -- X --

X --

T049 Tank 49 -- -- X --

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T057 Tank 57 -- -- X --

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T004 Tank 4 -- -- X --

X --

T005 Tank 5 -- -- X --

X --

T031 Tank 31 -- -- X --

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T039 Tank 39 -- -- X --

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T055 Tank 55 -- -- X --

X --

T056 Tank 56 -- -- X --

X --

T006 Tank 6 -- -- X --

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T012 Tank 12 -- -- X --

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T020 Tank 20 -- -- X --

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T026 Tank 26 -- -- X --

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T038 Tank 38 -- -- X --

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T034 Tank 34 -- -- X --

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3



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T036 Tank 36

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T025 Tank 25

T028 Tank 28

T037 Tank 37

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F029 SEP Project

Refinery Fuel Gas System

Refinery Wide (Fugitives) 3

General Conditions4

Insignificant Activities4

llf deviations were noted in the previous deviation report (Le., for the first six months of the

annual reporting period), put an "X" under "previous." If deviations were noted in the current

deviation report (Le., for the last six months of the annual reporting period), put an "X" under

"current." Mark both columns if both apply.

2Note whether the method(s) used to determine the compliance status with each term and

condition was the method(s) specified in the permit. If it was not, mark "no" and attach additional

information/explanation.

3Note whether the compliance status with each term and condition provided was continuous or intermittent. "Intermittent Compliance" can mean either that noncompliance has occurred or that

the owner or operator has data sufficient to certify compliance only on an intermittent basis.

Certification of intermittent compliance therefore does not necessarily mean that any

noncompliance has not occurred.

4



The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the

Title V source can demonstrate whether it has operated in continuous compliance for the

duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its permit, even if such activities are done periodically and

not continuously, and if 2) such monitoring and recordkeeping does not indicate non-

compliance, and if 3) the Responsible Official is not aware of any credible evidence that

indicates non-compliance, then the Responsible Official can certify that the emission

point(s) in question were in continuous compliance during the applicable time period.

4 Compliance status for these sources shall be based on a reasonable inquiry using

readily available information.

II. Status for Accidental Release Prevention Program:

A. This facility is subject to the provisions of the Accidental Release

Prevention Program (Section 112(r) of the Federal Clean Air Act)

B. If subject: The facility is in compliance with the following requirements of section 112(r).

1. A Risk Management Plan has been developed and registered with the appropriate authority and/or the designated central

location by the required date.

5



III. Certification

have reviewed this certification in its entirety and, based on information and

belief formed after reasonable inquiry, I certify that the statements and

information contained in this certification are true, accurate and complete.

Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub-Section 18-1-501(6), C.R.S., makes any false material statement,

representation, or certification in this document is guilty of a misdemeanor and

may be punished in accordance with the provisions of Sub-Section 25-7 122.1, C.R.S.

Donald Austin

Printed or Typed Name

Vice President of Refinery Title

6

ATTACHMENT 2

Semi-Annual Deviation Report - Part I

Suncor Energy (U.S.A), Inc.

Commerce City Refinery (East Plant - Plant 2)

Monitoring and Permit Deviation Report - Part I

FACILITY NAME: Suncor Energy (U.S.A), Inc. - Commerce City Refinery, Plant 2

(East) OPERATING PERMIT NO: 950PAD108


P001 Crude Distillation Unit X

B001 Crude Heater X

B010 Vacuum Heater X

F001 Crude Unit Fugitives X

P003Fluid Catalytic Cracking Unit

X X(FCCU)

B002 FCC Pre-Heater

P004 Reactor -Regenerator X X

P014 Catalyst Handling X

F002 FCCU Fugitives X

P005 Naphtha Hydrotreater Reformer X

B003 Heater #1 X

B004 Heater #2 X

BOOS Heater #3 X

F004 Reactors (Catalyst Regeneration) X

P006 Polymerization Unit X

F008 Reactor #1 (Catalyst Unloading) X X

F009 Reactor #2 (Catalyst Unloading) X

F010 Polymerization Unit Fugitives X

P007 Gas Plant X

P009 Sulfur Recovery Plant X X

P008 Amine Unit X

Boiler 1 X

Boiler 2 X

goog Boiler 3 X

Boiler 504 X

Boiler 505 X

B011 Sulfur Recovery Unit Incinerator X

P011 Cooling Tower X

F015 South Crude Unloading X

F016 North Crude Unloading X

F024 Truck Loading Dock X

COOS Refinery Flare X 1 X

F019 Railcar Dock X

F020 Truck Dock X



T050 Pressure Tank 50 X










Wastewater Treatment System X

F021 API Separators - Upper API X

F022 API Separators - Middle API X

F023 API Separators - Lower API X

T029 Wastewater Tank X

F011 Gas Plant Sewers X

F025 Sour Water Stripper Sewers X

F027 South Crude Unloading Sewers X

goog Black Oil Heater X

T010 Tank 10 X

T011 Tank 11 X

T027 Tank 27 X

T030 Tank 30 X

+G4Q Tank 40 X

TM+ Tank 41 X

T004 Tank 4 X

T005 Tank 5 X

T031 Tank 31 X

T039 Tank 39 X

T055 Tank 55 X

T056 Tank 56 X

T006 Tank 6 X

T012 Tank 12 X

T020 Tank 20 X

T026 Tank 26 X

T028 Tank 28 X

T034 Tank 34 X

T038 Tank 38 X

T046 Tank 46 X

T047 Tank 47 X

T053 Tank 53 X X

2



T062

T079

T035

T036

T044

T052

T054

+G24

T025

T037

T058

Tank 62

Tank 79

Tank 35

Tank 36

Tank 44

Tank 52

Tank 54

Tank 24

Tank 25

Tank 37

Tank 58

Refinery Fuel Gas System

SEP Project

General Conditions

Insignificant Activities

x

X

X

X

X

X

X

X

X

X

X

X

X

X

X

1 See previous discussion regarding what is considered to be a deviation. Determination of

whether or not a deviation has occurred shall be based on a reasonable inquiry using readily available information.

2Use the following entries as appropriate:

1 = Standard:

2 = Process:

3 = Monitor:

4 = Test:

5 = Maintenance:

6 = Record:

7 = Report: 8 = CAM:

9 = Other:

When the requirement is an emission limit or standard When the requirement is a production/process limit When the requirement is monitoring When the requirement is testing When required maintenance is not performed When the requirement is record keeping When the requirement is reporting A situation in which an excursion or exceedance as defined in 40 CFR

Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred.

When the deviation is not covered by any of the above categories

3



Monitoring and Permit Deviation Report - Part III

REPORT CERTIFICATION

SOURCE NAME: Suncor Energy (U.S.A.) Inc. East Plant

FACILITY IDENTIFICATION NUMBER: 0010003

PERMIT NUMBER: 950PAD108

REPORTING PERIOD: 1/1/2019 - 06/30/2019 (see first page of the permit for specific

reporting period and dates)

All information for the Title V Semi-Annual Deviation Reports must be certified by a

responsible official. The responsible official signing this certification must be pre-

approved by the Division in accordance with Colorado Regulation NO.3, Part A, Section

I.B.54. This signed certification document must be packaged with the documents being submitted.

STATEMENT OF COMPLETENESS

I have reviewed the information being submitted in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the

statements and information contained in this submittal are true, accurate and

complete.

Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub-Section 18-1-501(6), C.R.S., makes any false material statement,

representation, or certification in this document is guilty of a misdemeanor and

may be punished in accordance with the provisions of Sub-Section 25-7 122.1, C.R.S.

Donald Austin


Vice President of Refinery

Title

lJIM ~/271/~, Date SignedSignature of Responsible Official

4

ATTACHMENT 3

Semi-Annual Monitoring and Permit Deviation Reports - Part II

Suncor Energy (U.S.A.) Inc. Commerce City Refinery

Monitoring and Permit Deviation Report - Part II

FACILITY NAME: Suncor Energy (U.S.A.) Inc. - Commerce City Refinery - Plant 2

(East Plant)

OPERATING PERMIT NO: 950PAD108

REPORTING PERIOD: 01/01/2019-06/30/2019

Is the deviation being claimed as an: Emergency: Upset: N/A: X

(For NSPS/MACT) Did the deviation occur during:Startup: Shutdown:

Malfunction: X

Normal Operation:OPERATING PERMIT UNIT IDENTIFICATION:

East Plant - P009 - Sulfur Recovery Plant (220)

OPERATING PERMIT CONDITION NUMBER CITATION (TV Permit No. 950PAD108)

CC - EP - 950PAD108, Section II -- Condition 5.8


EXPLANATION OF PERIOD OF DEVIATION

On February 7 2019, No. 3 Sulfur Recovery Unit (SRU) exceeded the 1.2% S02 (12 hour average) limit due to malfunction of tail gas analyzer. The malfunctioned analyzer displayed invalid data causing an upset in NO.3 SRU operations. The root cause for the incident was a failed power supply on the Tail Gas Analyzer. The power supply failure resulted in false indication into the Distributed Control System (DCS) which in turn

disrupted the automatic control system from keeping the unit on ratio. Operations personnel immediately called analyzer technicians to troubleshoot the analyzer in order to get it back to normal operation.

DURATION (START/STOP DATE & TIME)

No.3 5RU 502 Excess Emissions (1.20% by volume Corrected to 0% O2, 12-Hour

Rolling Average Basis) Start Date and Time: 02/07/19 12:00 hrs

End Date and Time: 02/07/1918:00 hrs

ACTION TAKEN TO CORRECT THE PROBLEM

The power supply on the analyzer was replaced and system returned to normal

operation.

MEASURES TAKEN TO PREVENT A REOCCURRENCE OF THE PROBLEM

N/A

DATES OF UPSETS/EMERGENCIES REPORTED (IF APPLICABLE)

Suncor notifed the CDPHE at approximately 07:45 hours on February 8, 2019.

Division Code QA: DEVIATION CODE: 1

Page 1 of 1 8/26/2019





(East Plant)



Is the deviation being claimed as an: Emergency:

Upset: N/A: X


Malfunction: X


East Plant - P006 - Polymerization Unit - Reactor #1 (F008)


CC - EP - 950PAD1 08, Section II -- Condition 4.4


On February 11 2019, during catalyst dump at Plant 2 Poly unit reactor R-301, the

catalyst blowdown bag ripped apart emitting catalyst dust to atmosphere. Upon

investigation, it was determined that the bag used for the process was defective.


Poly unit Reactor Opacity (20%, 6-minute block average (State)) Start Date and Time: 02/11/19 14:18 hrs

End Date and Time: 02/07/19 14:24 hrs


Suncor has contacted the manufacturer about the incident and plans to re-enforce the

corners of the bags to provide more integrity.


Suncor plans to add an item on the verification of bag corners integrity before each poly

dump to contractor’s work checklist.


Suncor notifed the CDPHE at approximately 08:00 hours on February 12, 2019.


Page 1 of 1 8/26/2019





(East Plant)




(For NSPS/MACT) Did the deviation occur during:Startup: X

Shutdown:

Malfunction:

Normal Operation:

OPERATING PERMIT UNIT IDENTIFICATION:

East Plant - C005 - Main Flare - 279





On February 28th 2019, Poly reactor guard case was in the process of being placed back

in service. During start-up of the guard case, vent line to the flare is typically opened to

achieve stable temperature and pressure in the guard case. As per procedure, guard case vent line to Plant 2 flare was opened during feed introduction to Poly reactor guard case. The increased flow to the flare, from Poly reactor guard case, caused visible

emissions at the flare which lasted over 5 minutes during 2 consecutive hours.


Visible emissions exceeding 5 minutes during 2 consecutive hours

Start Date and Time: 02/28/19 14: 19 hrs



Board operators immediately made adjustments to flare steam flow in order to stop visible

emissions.


Operations plan to update Poly Reactor guard case procedure to include an additional

step, which will increase steam flow to flare prior to placing guard case back in service.

Additional training will be provided to shift teams on flare management.


Suncor notifed the CDPHE at approximately 09:45 hours on March 1, 2019.


Page 1 of 1 8/26/2019





(East Plant)




(For NSPS/MACT) Did the deviation occur during: Startup: Shutdown: X

Malfunction: X

Normal Operation:

OPERATING PERMIT UNIT IDENTIFICATION

East Plant - C005 (Plant 2 Main Plant Flare) - 279

East Plant - FCCU Regenerator (P004)

OPERATING PERMIT CONDITION NUMBER CITATION








On March 29 2019, boiler B-504 main air blower 51 F504 and #2 FCC blower C-201 lost

power and shut down. After the power loss to the blower, #2 FCC process unit was

immediately shutdown using emergency shutdown procedure. The process upset and

subsequent shutdown caused by sudden loss of power at C-201 lead to exceedance of

opacity and CO limits. Visible emissions lasting greater than 5 minutes were also

observed at Plant 2 flare. Upon further investigation, Suncor discovered that the loss of

power was caused by the trip of a protection relay at Sub 41 in Plant 2. The protection relay tripped due to loose sensor connections to the relay.


Plant 2 No.2 FCC

CO 500 ppm, Corrected to 0% O2 per Consent Decree & NSPS Ja, 1 Hour Average Start Date and Time: 03/29/19 05:00 hrs


Opacity (>20%, 6-Minute Block Average Basis; State Regulation - Normal

Operations) Start Date and Time: 03/29/19 04:36 hrs


Page 1 of 2 8/26/2019


Start Date and Time: 03/29/19 05:00 hrs




Opacity (>30%, 6-Minute Block Average Basis; Federal Regulation - MACr,

Subpart UUU) Start Date and Time: 03/29/2019 04:36 hrs




Plant 2 Flare

Visible emissions (> 5 Minutes in 2 consecutive hours) Start Date and Time: 03/29/2019 12:30 hrs



As an immediate corrective action, Suncor tightened the loose sensor connections to the

protective relay and performed additional checks before starting up NO.2FCC unit.


Suncor plans to develop a plan to check and verify all Basler Relay internal terminals at

Sub 41. Adjustments will also be made to current settings of protective relay.


Suncor notified CDPHE on March 29 2019 at approximately 11 :00 AM

Suncor notified CDPHE on April 01 2019 at approximately 09:00 AM


Page 2 of 2 8/26/2019




(East Plant)




(For NSPS/MACT) Did the deviation occur during: Startup: X Shutdown:

Malfunction:

Normal Operation: X



East Plant - FCCU Regenerator (P004)






On March 29th 2019, #2FCC blower C-201 unexpectedly lost power and shut down.

Following the loss of power to the blower, #2FCC process unit was shut down using

emergency shutdown procedure. It was later determined that the loss of power was caused by the trip of a protection relay at Sub 41 in Plant 2. In a separate incident on

March 29th 2019, level transmitter (L T303) on stripper charge drum water boot (09V251) at Unsaturated Gas process unit malfunctioned and started displaying random readings. The erratic readings caused the level controller at stripper charge drum (09V251) to increase flow to sour water surge drum at No.3SRU. The increase in flow from stripper

charge drum (09V251) to No.3SRU, eventually lead to hydrocarbon carryover into the

Sour Water Stripper (SWS). The hydrocarbon carryover also contaminated the No.3SRU

catalyst reactor bed.

On April 2nd 2019, No.2FCC was restarted after restoring power to blower C-201 and

repairing the malfunctioned level transmitter (L T303) on charge drum 09V251 in Plant 2.

The start-up of the unit increased acid gas feed flow to thermal reactor at No.3SRU. Due

to hydrocarbon contaminated catalyst reactor bed (March 29th event), the reactor

pressure started to increase above the expected level during the start-up of No.2FCC. In order to avoid an unsafe operating condition at No.3SRU, acid gas from the regenerator and sour water stripper off-gases were required to be relieved to the flare on April 2nd, 2019. Operations personnel worked to stabilize the unit as expeditiously as possible and had stabilized enough by approximately 10:00 hours on April 4th 2019 when acid gas flaring stopped.

Page 1 of 2 8/26/2019



Upon investigation, it was identified that the level transmitter on stripper charge drum

water boot (09V251) malfunctioned possibly due to stuck float. This in turn increased

flow from the water boot of the charge drum and eventually led to hydrocarbon carryover in to No.3SRU. Hydrocarbon contamination typically creates abnormally high back

pressure in the system and inadequate catalyst bed temperatures that restricts proper SRU operation. SRU Operators response to this event was impacted by No.2FCC

shutdown process, which occurred on the same day (March 29th).

The root cause of the event was the mechanical failure experienced by level transmitter

(L T303) on charge drum 09V251. The failed level transmitter (L T303) had prior known

issues.


Plant 2 Flare

Flare Gas H2S (162 ppm, 3-hour average) Start Date and Time: 04/03/19 02:00 hrs


Plant 2 NO.2 FCC

CO 500 ppm, Corrected to 0% O2 per Consent Decree & NSPS Ja, 1 Hour Average Start Date and Time: 04/02/19 08:00 hrs


Plant 2 Flare

S02 500 Ibs 24-Hour Rolling Total




During the start-up of No.2FCC on April 2nd, in order to avoid an unsafe operating condition at No.3SRU, acid gas from the regenerator and sour water stripper off-gas were

required to be relieved to the flare. Operations made every attempt to contain the existing acid gas within the No. 3 SRU process vessels, and only that volume required to be

relieved for safety purposes were sent to the flare.


Suncor plans to explore the option of installing a different type of level instrument on the

stripper charge drum to improve reliability.


Suncor notified CDPHE on April 3 2019 at approximately 9:20 hrs




Page 2 of 2 8/26/2019




(East Plant)




Upset: N/A: X

(For NSPS/MACT) Did the deviation occur during: Startup: Shutdown:

Malfunction: X

Normal Operation:OPERATING PERMIT UNIT IDENTIFICATION

East Plant - C005 (Plant 2 Main Plant Flare)- 279


CC - EP - 950PAD108, Section II -- Condition 8.4 (NSPS Ja)


On April 4 2019, Plant 2 main flare gas H2S concentration started increasing and

eventually exceeded the permit limit of 162 ppm (3 hour rolling average). Upon

investigation, it was determined that the high H2S concentration in the flare gas was

caused by a seal leak in inner cooler pump P252B. The leaking pump seal routed high H2S process stream to the Plant 2 flare.


Plant 2 Flare




Operations immediately blocked in the seal and this in turn reduced the H2S concentration

in Plant 2 flare gas.


Operations created a work notification and initiated the process to repair the leaking

pump seal.




Page 1 of 1 8/26/2019




FACILITY NAME: Suncor Energy (U.S.A) Inc. - Commerce City Refinery - Plant 2

(East Plant)





Malfunction: X

Normal Operation:OPERATING PERMIT UNIT IDENTIFICATION



CC - EP - 950PAD108, Section II -- Condition 8.4 (NSPS Ja)


On April 8th 2019, Plant 2 main flare gas H2S concentration started increasing and

eventually exceeded the permit limit 162 ppm (3 hour rolling average). Upon

investigation it was determined that the high H2S concentration in the flare gas was

caused by three leaking intercooler pumps (P252A, P252B and P-253). The leaking

pump seals routed high H2S process streams to the Plant 2 flare.


Plant 2 Flare






Operations immediately blocked in the seals and this in turn reduced the H2S

concentration in Plant 2 flare gas.


A repair notification was entered by operations for the leaking pump seals.





Page 1 of 1 8/26/2019



Monitoring and Permit Deviation Report - P~rt II


(East Plant)




Upset: N/A: X


Malfunction:

Normal Operation: X






CC - EP - 950PAD1 08, Section II -- Condition 32


On April 8th 2019, visible emissions were observed at the Plant 2 flare. Operations

attempted to stop visible emissions by adjusting steam flow to the flare. However, initial

adjustments could not stop the exceedance of visible emissions permit condition. Later

in the afternoon, Net Heating Value (NHV) of Plant 2 flare combustion zone gas started

decreasing and eventually dropped below 270 btu/scf (15-minute block period). The

exact reason for visible emissions from Plant 2 flare is unknown, it is suspected that the

event could be related to the upset that occurred in Plant 2 on March 29th 2019. It is

also believed that the drop in NHV occurred due to several spikes in the waste gas flow

to the flare. Large fluctuations in waste gas flow impacted the city gas flow controller at

the Plant 2 flare.


Plant 2 Flare



End Date and Time: 04108/19 17: 18 hrs

Plant 2 Flare

Net Heating Value (NHV) (at or above 270 btu/scf) Start Date and Time: 04/08/2019 18:00 hrs

End Date and Time: 04/08/2019 18: 15 hrs


Page 1 of 2 8/26/2019


Operations contacted process operations group to help trouble shoot the RSR flare controls. DCS engineering support was also contacted. Plant 2 operators made

adjustments to flare steam flow in order to stop visible emissions and adjusted city gas flow to increase NHV.


Process control and projects team will be working with unit operators and shift

supervisor to address any flare Refinery Sector Rule (RSR) control concerns. If

required, additional training on RSR controls will be provided to operators.


Suncor notifed the CDPHE at approximately 10:30 hours on April 9, 2019


Page 2 of 2 8/26/2019





(East Plant)





Malfunction:

Normal Operation: X




CC - EP - 950PAD1 08, Section II -- Condition 8.4/NSPS Ja


On April 17 2019, Plant 2 main flare gas H2S concentration started increasing and

eventually exceeded the permit limit 162 ppm (3 hour rolling average). Upon

Investigation, it was determined that the high H2S concentration in the flare gas was caused by intercooler pump P252B. The pump had prior known seal issues at the time

of the event. The leaking pump seal routed high H2S process streams to the Plant 2

flare. Operations immediately blocked in the seals and this in turn reduced the H2S

concentration in Plant 2 flare gas.


Plant 2 Flare




The intercooler pump was shut down and isolated after the event. The leaking seals are

planned to be repaired.


An evaluation will be performed for the redesign of the intercooler pumps currently used by Plant 2 operations. An evaluation will also be performed to determine the feasibility of

bringing local flow indications for inner cooler pumps into the DCS to provide continuous

monitoring and alarming capabilities.


Page 1 of 2 8/26/2019


Suncor notifed the CDPHE at approximately 09:55 hours on April 18, 2019


Page 2 of 2 8/26/2019





(East Plant)




Upset: N/A: X


Malfunction:

Normal Operation: X






On April 23 2019, between approximately 14:54 hrs and 14:56 hrs, thermocouple

monitoring data used to verify the continuous presence of a pilot flame at Plant 2 flare per 40 CFR 63.670(g) became unavailable in Suncor’s data historian (PI) server. Based on a

review of temperature data before and after the event, Suncor believes the pilot flame(s)

were not lost during the data gap. This deviation report is submitted as records are not

available for the above mentioned period. Please note that the actual loss of data lasted

for approximately 1 minutes, but the entire 15-minute block, as required by 40 CFR

63.655(g)(11 )(i), is reported under this deviation report.


Plant 2 Flare

Pilot flame monitoring (continuously monitor the presence of pilot flame) Start Date and Time: 4/23/19 14:45 hrs



N/A


N/A


N/A


Page 1 of 1 8/26/2019




(East Plant)




Upset: N/A: X

(For NSPS/MACT) Did the deviation occur during:Startup: X Shutdown:

Malfunction:







On May 1 sl 2019, Poly reactor (R-303) guard case was in the process of being placed

back in service. During start-up of the guard case, vent line to the flare is typically

opened to achieve stable temperature and pressure in the guard case. As per

procedure, guard case vent line to Plant 2 flare was opened during feed introduction to

Poly reactor guard case. The increased flow to the flare, from Poly reactor guard case, caused visible emissions at the flare which lasted over 5 minutes during 2 consecutive

hours.






Board operators immediately made adjustments to flare steam flow in order to stop visible

emissions.


Operations plan to update Poly Reactor guard case procedure to include an additional

step, which will increase steam flow to flare prior to placing guard case back in service.

Additional training will be provided to shift teams on flare management.


Suncor notifed the CDPHE at approximately 10:00 hours on May 2, 2019.


Page 1 of 1 8/26/2019




(East Plant)



Is the deviation being claimed as an: Emergency: Upset: N/A: ~


Malfunction:

Normal Operation: ~


East Plant- Unpermitted Fugitive Emissions


CC - EP - 950PAD108 - Condition 27.8

CC - EP - 950PAD1 08 - Condition 32

CC - EP - 950PAD1 08 - Condition 30


On May 10, 2019, one (1) open-ended line was discovered at the East Plant tank

farm. This was plugged on the same day.

5 valves and 11 connectors in the East Plant were discovered in the field as

subject to LDAR monitoring requirements but had not previously been included in

the LDAR inspection program. The components were added to the LDAR

inspection program for continual monitoring.


OELs

Start Date and Time: 5/10/201908:00 hrs


Components Start Date and Time: 1/1/201900:00 hrs



A plug was put in place on the OEL the same day it was identified. The

components were added to the LDAR inspection program for continual monitoring.

Page 1 of 2 8/22/2019



The LDAR coordinator is working closely with operations to ensure open-ended line LDAR requirements are met in the field, as well as operation and maintenance teams to ensure all field changes are correctly captured by Suncor’s Management of Change (MOC) process.



Page 2 of 2 8/22/2019




(East Plant)





Malfunction: X

Normal Operation:


East Plant - FCCU Regenerator (P004) East Plant - C005 (Plant 2 Main Plant Flare) - 279




CC - EP - Construction Permit 09AD0961, Condition 27(c) CC - EP - 950PAD1 08, Section II -- Condition 8.4 (NSPS Ja)


On May 24th 2019, Plant 2 operations began the process of bringing No.2 FCC slurry

recycle circuit online after completion of planned maintenance. When placing the

recycle circuit in service, the reactor dilute phase temperature (02TC434) and the upper riser temperature (02TI479) began to drop sharply and the No.2 FCC process unit went

into an upset mode. Feed to No.2 FCC unit was immediately pulled out by operations.

Upon investigation, it was determined that the upset was likely caused by plugging of the

bottom portion of slurry settler 02V213. When slurry recycle circuit was originally taken

offline for maintenance, slurry settler 02V213 was still in service and in a stagnant condition. The stagnant state of 02V213 likely led to the slurry settling up in the bottom

of the vessel and the piping. When slurry recycle circuit was started up, plugging caused by slurry settlement prevented flow from 02V213. Operations made adjustments to the slurry recycle control valves 1 bypass and eventually unplugged the slurry settler

(02V213). Upon unplugging 02V213, a surge of cold heavy material hit the riser causing a loss of heat balance and upsetting the unit. Due to the status of the recycle circuit,

operations were not able to limit the effect of the cold slurry that entered the riser.

During the unit upset, the regen pressure (02PI209) reduced to a lower value and this

resulted in a higher regen velocity. High regen velocity lead to high opacity in the unit.

Additionally, No.2 FCC suffered high catalyst loss when the feed was cut after the upset.

Page 1 of 2 8/26/2019



No.2 FCCU

CO (500 ppm hourly average at 0% 02) Start Date and Time: 5/24/19 13:00 hrs



End Date and Time: 5/25/19 01 :00 hrs

Opacity (20%, 6-minute block average (State)) Start Date and Time: 5/24/19 13:00 hrs




Opacity (30%, 3-hour rolling average (Federal)) Start Date and Time: 5/24/19 15:00 hrs


Plant 2 Flare






As an immediate corrective measure, feed to NO.2 FCC unit was immediately pulled out

by operations. During the upset, both the Spent Slide Valve DP, 02PC206, and the reactor pressure, 02P1213, were found to be reading incorrectly. Both indications

appeared to have been reading correctly prior to the unit upset but during the unit

instability, they were reading incorrectly. When troubleshooting the spent slide valve

DP, a tap was found plugged with catalyst. The tap was cleared and the pressure to the

tap was increased to prevent catalyst from re-plugging the tap.


Plant 2 operations plan to repair the slurry recycle flow indication at NO.2 FCC.

Additional guidance (procedures) will also be provided to NO.2 FCC operators on placing slurry recycle circuit in service in future. Procedures on Regen velocity and pressure profile will also be updated to address high opacity scenarios.


Suncor notifed the CDPHE at approximately 11 :00 hours on May 28, 2019.


Page 2 of 2 8/26/2019





(East Plant)




Upset: N/A: ~


Malfunction:

Normal Operation: ~


EP - Tank 53 (Group E Tanks- Tanks with Unique requirements)


CC - EP - 950PAD1 08, Section II - Condition 15.2

CC - EP - 950PAD1 08, Section II - Condition 15.8

CC - EP - 950PAD108, Section 11- Condition 15.9


On May 25 2019, the Oil Movement Division (OMD) operators found product on

the roof of Tank 53. Tank 53 is an internal floating roof petroleum products tank.

Upon investigation it was discovered that during start-up of NO.2 Fluidized

Catalytic Cracking (FCC) unit on May 25th, a valve which transfers debut gasoline to Tank 53 was inadvertently left open. The debut gasoline flow to Tank 53

caused unstable material in that stream to vaporize in the tank and eventually led

to product on the roof of Tank 53.


Start Date and Time: OS/25/2019 01 :30 hrs

End Date and Time: OS/26/2019 00:00 hrs


As an immediate correction action, the valve which was inadvertently left open was

blocked in by OMD operations.


Operations plan to update emergency shutdown procedures to ensure isolation of

rundown lines and unit stabilizing actions are followed during a hot re-start of FCC.


NA

Page 1 of 2 8/22/2019



Page 2 of 2 8/22/2019





(East Plant)





Malfunction: ~ Normal Operation: ~


East Plant - Refinery Fuel Gas System East Plant - Plant 2 Main Plant Flare

East Plant - Sulfur Recovery Plant

East Plant - FCCU

East Plant - B504 (not in current TV Permit) East Plant - B505 (not in current TV Permit) East Plant - P009 and Refinery Fuel Gas System East Plant - B001 (Crude Heater) East Plant - B01 0 (Crude Vacuum Heater) East Plant - B002 (FCCU Preheater) East Plant - B003 (Heater 1) East Plant - B004 (Heater 2) East Plant - B005 (Heater 3)


CC - EP - 950PAD1 08, Section -- Condition 1.3







CC - EP - 950PAD108, Section -- Condition 7.2


CC - EP - 950PAD1 08, Section -- Condition 22.5.2


There were periods of continuous emissions monitor (CEM) downtime recorded during the

semi-annual period. An explanation of the cause, and where applicable, the corrective

actions taken were provided in the Ouarterly Excess Emissions Reports (EERs) submitted

to the Division on April 29, 2019 and July 25, 2019 for 01 and 02, respectively, for each

reported period of downtime.

8/26/2019


To demonstrate compliance with the visible emissions requirement of 40 CFR 63.670 (c) for MACT CC applicable flares, Suncor began monitoring flames using newly installed flare video cameras in

compliance with 40 CFR 63.670 (h) on January 30, 2019. 40 CFR Part 63.670(h)(2) requires video surveillance records to be recorded at least once every 15 seconds and storage for a minimum of

three years. At the time of installation, the cameras were configured to record video at a rate of 1

image every second. In April 2019, Suncor corporate security performed a configuration change to the recording system known as "video thinning". The video thinning process compresses the recorded images after a defined period of time has lapsed down in order to minimize the usage network disk space. In June 2019, it was discovered that the video thinning decreased recorded

camera frame rate to one image every thirty seconds (half of the frequency required by the

regulation). Suncor was not aware of the reduction in recorded camera frame rate at the time of video thinning implementation and as of a result approximately 4 Y:z months of recordkeeping data didn’t meeting the defined monitoring requirements of 40 CFR 63.670(h)(2). Upon discovery of the

issues, Suncor corporate disabled the video thinning system.


The duration of each CEMS downtime event is included in the Quarterly EERs.


Descriptions of the actions taken to return the CEMS to service are included in the

Quarterly EERs.


CEMS analyzers run continuously; therefore, some parts wear out or may be prone to failure. The standard operating procedure for any CEMS program is to repair the systems as expeditiously as possible in order to return them to service and minimize downtime. Preventative maintenance is conducted on a weekly and monthly basis in order to keep CEMS downtime to a minimum.


Division Code QA: DEVIATION CODE: 3, 6

8/26/2019

Exhibit 2

August 26,2019

&~\) ~ \~~

\~ ~~~ 9

~S~,,~; S’;~ ~~

DO/-DD051 q(;DP,AD l2D

t2~OY-t---S ~SUNC~

Suncor Energy


5801 Brighton Blvd.

Commerce City, Colorado 80022

Tel (303) 286-5701

Fax (303) 286-5702

www.suncor.com

Mr. Matt Burgett Colorado Department of Public Health and Environment

Air Pollution Control Division, Operating Permits Unit

APCD - SS - B1

4300 Cherry Creek Drive South

Denver, CO 80246-1530

Hand Delivered

RE: Suncor Energy (U.S.A.) Inc. Commerce City Refinery (West Plant, Plants 1 & 3) Title V Operating Permit (960PAD120) Annual Compliance Certification Report July 1, 2018 - June 30, 2019

Semi-Annual Deviation Report - January 1, 2019 - June 30, 2019

Dear Mr. Burgett:

Suncor Energy (U.S.A.) Inc., submits the attached Annual Compliance Certification Report as required in

Appendix B of our Operating Permit. This report covers the annual period of July 1, 2018 through June

30, 2019. Suncor is also submitting the Semi-Annual Deviation Report for the period of January 1, 2019

through June 30,2019.

The attachments include the Annual Compliance Certification Report (Attachment A) and the Semi-

Annual Deviation Report (Attachment B). As required under Appendix D of the Operating Permit. a

separate copy of the Annual Compliance Certification Report has also been submitted to the United

States Environmental Protection Agency, Office of Enforcement, Compliance, and Environmental Justice.

Please feel free to contact Ramesh Gopal at (303) 286-5315 or [email protected] if you have any

questions.

Sincerely,

~CNeil V ~~sm~ Lead, Environmental

Attachments (2)

cc: USEPA, Region VIII (Mail Stop 8P-AR) Jason Long (APCD)

Receipt No.7019-0140-0001-0119-3711

Receipt NO.7019-0140-0001-0119-3728

15 SARJ Ate-

ATTACHMENT A

Annual Compliance Certification Report

Suncor Energy (USA) Inc.

Commerce City Refinery, (West Plant, Plants 1 & 3)

Title V Annual Compliance Certification Report

FACILITY NAME: Suncor Energy (U.S.A.), Inc. - Commerce City Refinery, Plant 1 (West Plant) and Plant 3 (Asphalt Unit)



RECEIVED

AUG 2 8 2019

APeD

S!.I!(i!~nlU) :)~Y!lill!i

_

During the entire reporting period, this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included

by this reference. The method(s) used to determine compliance is/are the method(s) specified in the Permit.

I. Facility Status

~ With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference, during the entire reporting period. The

method used to determine compliance for each term and condition is the method specified in the Permit, unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations.

0-811 Storage Tank 0-811 X X




T1 Storage Tank T1 X X X

T2 Storage Tank T2 X X















Suncor Energy (USA) Inc. Commerce City Refinery, (West Plant, Plants 1 & 3)

T70 Storage Tank T70 X









































2



,10.; ,~~:’t:Je~r’G:~tr~t1fStorage Tank T4501 (Part of the

T4501 Plant 1 Wastewater Treatment X

System - F201)

T7208 Storage Tanks T7208 X

Pipeline Receipt Station Sump X

H-6 Process Heater H6 X X X X

H-10 Process Heater H 1 0 X X X X

H-11 Process Heater H 11 X X X X






H-20 Process Heater H2O X X X X

H-21 Process Heater H21 X



H-28,29, Process Heaters H28, H29, andX

X

30 H30 X X







H-2101 Process Heater H21 01 X X X X


B-4 Steam Boiler B4 X X X X



Sulfur Recovery Units (p101- SRU

H-25#1 and P1 02 - SRU #2) with Tail

X X XGas Unit (TGU) and TGU X

Incinerator (H-25)

P103 FCC Regenerator X X X X

P104 Catalytic Reforming Unit X

R101 Rail Loading Rack and FlareNCU X

R102 Truck Loading Rack X

F1 Main Plant Flare X X X X

F2 Asphalt Unit Flare X X X X

F3 GBR Unit Flare X X X X

3


A1Groundwater Treatment Unit with

XAir Strippers

SV1Soil Vapor Extraction Unit - Engine

X(non-road engine)

F201 - Plant 1 Wastewater Treatment

uncontrolle System - uncontrolled sources &X

d sources sumps (see equipment list in

& sumps Section I, Condition 5.1)

F201 -Plant 1 Wastewater Treatment

controlledSystem - controlled sources (see

Xequipment list in Section I,

sourcesCondition 5.1)

Plant 1 Wastewater Treatment

F201 -System - Centrifuge System

Centrifugehandling effluent from T-4516 (if

Xrouted to the RTO the centrifuge

SystemlTOsystem will be addressed under the

Plant 1 WWTS controlled sources)

F101Asphalt Unit (Plant 3) Wastewater

XTreatment System

F102 Asphalt Processing Unit Fugitives X

F103 NO.3 Hydrodesulfurizer Fugitives X

F104Cryogenic Vapor Recovery

XFugitives


F106Light Straight Run Distillate

XFugitives

Plantwide Fugitive Emissions not

F107 Subject to Construction Permit X X X X

Requirements

F108Fugitives from Vapor Recovery Unit

XDebutanizer


F110Tail Gas Unit Amine Treatment

XSystem Fugitives

F111Sour Water Stripper System

XFugitives

F112Modified Tank Farm Piping

XFugitives

F113Catalytic Reforming Unit

XModification Fugitives

F114Equipment Leaks Associated with

XGBR Unit

F115Equipment leaks associated with

XBio-Diesel

4



F116

F200

F202

0001

0002

0003

P1AC1 &

P1AC2

P1EG1

P1DGTO

MPVs

Y2

Y1

Y3

Y4

Pt606

Pt615

Pt636

Pt616

Pt 617

Pt618

Pt621

Pt622

Pt623

Pt624

Pt625

Pt634

Pt635

Pt637

LO-1

Equipment leaks associated with the Relief Valve Project

Pipeline Receipt Station Fugitives

Equipment Leaks associated with

the MPV Project

Cold Cleaner Solvent Degreasers

Emergency Engines

Emergency Generator - P1 Control Room

x

X

X

X

X

X

Emergency Engines

Emergency Engine

Tank Degassing

Miscellaneous Process Vents

Plant 3 Cooling Tower

Y1 Plant 1 Cooling Tower



Recovery Trench AS/SVE System Zone F & G

Suncor Western Property Boundar AS/SVE S stem

NW Boundary Uncontrolled Zones 3 & 4 AS S stem onl

M & E East AS/SVE System

RPC AS/SVE System Zone 2

Metro Utility Corridor AS/SVE

S stem Zones 1 & 2

Metro M & E West AS/SVE System Zone 2


Metro South Secondary Area

AS/SVE S stem Zone 1

Metro South Secondary Area

AS/SVE S stem Zone 2

Recovery Trench AS/SVE System Zone E & H

Metro Utility Corridor AS/SVE

S stem Zones 3 & 4

PCA Subslab Depressurization

Laboratory SVE

Loading of recovered

asoline/reformate into tank trucks

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

5



0-20

Horizontal above ground 21,150 gallon tanks for

storage of recovered

gasoline/reformate. The tank is vented to two (2) carbon

canisters in series.

Two (2) 525 gallon tanks for storage of recovered gasoline/reformate

General Conditions X

Insignificant Activities4 X

If deviations were noted in a previous deviation report, put an "x" under "previous". If deviations were

noted in the current deviation report (i.e. for the last six months of the annual reporting period), put an "x"

under "current". Mark both columns if both apply.

X

17675 &

20529X

2 Note whether the method(s) used to determine the compliance status with each term and condition was

the method(s) specified in the permit. If it was not, mark "no" and attach additional

information/explanation.

3 Note whether the compliance status with each term and condition provided was continuous or

intermittent. "Intermittent Compliance" can mean either that noncompliance has occurred or that the

owner or operator has data sufficient to certify compliance only on an intermittent basis. Certification of

intermittent compliance therefore does not necessarily mean that any noncompliance has occurred.

NOTE:

The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source can

demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and recordkeeping required in its permit, even if

such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not indicate non-compliance, and if 3) the Responsible Official is not aware of any credible evidence

that indicates non-compliance, then the Responsible Official can certify that the emission point(s) in

question were in continuous compliance during the applicable time period.

4 Compliance status for these sources shall be based on a reasonable inquiry using readily available

information.

6


II. Status for Accidental Release Prevention Program:

A. This facility is subject to the provisions of the Accidental Release Prevention

Program (Section 112(r) of the Federal Clean Air Act)

B. If subject: The facility is in compliance with the following requirements of section

112(r).

1. A Risk Management Plan has been developed and registered with the

appropriate authority and/or the designated central location by the

required date.

III. Certification

I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete.

Please note that the Colorado Statutes state that any person who knowingly, as defined in ~18-1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in

accordance with the provisions of ~25-7 122.1, C.R.S.

Donald Austin


Vice President of Refinery Title

;JILL Signatur

j27Lr;J Date Sign’ed

7

ATTACHMENT 8

Semi-Annual Deviation Report

Suncor Energy (USA), Inc. Commerce City Refinery (West Plant - Plants 1 and 3)

Monitoring and Permit Deviation Report - Part I

1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. The Table below must be

completed for all equipment or processes for which specific Operating Permit terms exist.

2. Part II of this Appendix B shows the format and information the Division will require for

describing periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g. EER’s or malfunctions) may be referenced and the form need not be filled out in its entirety.

FACILITY NAME: Suncor Energy (U.S.A.), Inc. - Commerce City Refinery, Plant 1 (West Plant) and Plant 3 (Asphalt Unit)



;..’ ’ ~’:.." .f (f)"", ",~,,~

0-811 Storage Tank 0-811 X























Suncor Energy (USA), Inc.

Commerce City Refinery (West Plant - Plants 1 and 3)

"91:....T74 Storage Tank T74 X






































2



T4501Storage Tank T4501 (Part of the Plant 1

XWastewater Treatment System - F201)


Pipeline Receipt Station Sump X

H-6 Process Heater H6 X 1 X

H-10 Process Heater H 1 0 X 1 X

H-11 Process Heater H 11 X 1 X






H-20 Process Heater H2O X 1 X

H-21 Process Heater H21 X



H-28, 29,30 Process Heaters H28, H29, and H30 X 1 X







H-2101 Process Heater H21 01 X 1 X

H-2410 Process Heater H241 0 X 1 X

B-4 Steam Boiler B4 X 1 X



Sulfur Recovery Units (P101 - SRU #1 &H-25 P1 02 - SRU #2) with Tail Gas Unit X X

(TGU) and TGU Incinerator (H-25)

P103 FCC Regenerator X X

P104 Catalytic Reforming Unit X

R101 Rail Loading Rack and VCU X

R102 Truck Loading Rack X

F1 Main Plant Flare X 1 X

F2 Asphalt Unit Flare X 1 X

F3 GBR Unit Flare X 1 X

A1Groundwater Treatment Unit with Air

XStrippers

3


SV1Soil Vapor Extraction Unit - Engine

X(non-road engine)

F201 - Plant 1 Wastewater Treatment System -

uncontrolled uncontrolled sources & sumps (see Xsources & equipment list in Section I, Condition

sumps 5.1 )

F201 - Plant 1 Wastewater Treatment System -

controlled controlled sources (see equipment list in X

sources Section I, Condition 5.1)

F101Asphalt Unit (Plant 3) Wastewater X

Treatment System

F102 Asphalt Processing Unit Fugitives X


F104 Cryogenic Vapor Recovery Fugitives X


F106 Light Straight Run Distillate Fugitives X

F107Plantwide Fugitive Emissions not subject

X 3 Xto Construction Permit Requirements

F108Fugitives from Vapor Recovery Unit X

Debutanizer


F110Tail Gas Unit Amine Treatment System

XFugitives

F111 Sour Water Stripper System Fugitives X

F112 Modified Tank Farm Piping Fugitives X

F113Catalytic Reforming Unit Modification X

Fugitives

F114Equipment Leaks Associated with the X

GBR Unit

F115Equipment leaks associated with Bio- X

Diesel

F116Equipment leaks associated with the X

Relief Valve Project

F200 Pipeline Receipt Station Fugitives X

DOO1 Cold Cleaner Solvent Degreasers X

DOO2 Emergency Engines X

DOO3Emergency Generator - P1 Control X

Room

P1AC1 & P1AC2 Emergency Engines X

P1EG1 Emergency Engine X

P1DGTO Tank Degassing X

Y2 Plant 3 Cooling Tower X

4


Y1

Y3

Y4

Pt606

Pt615

Pt616

Pt617

Pt618

Pt 621

Pt622

Pt623

Pt624

Pt625

Pt634

Pt635

Pt636

Pt637

LO-1

0-20

17675 & 20529

’. .’ III" ." 11’

:. ~i~ ’r’.. i."!16~




Recovery Trench AS/SVE System Zone F&G

Suncor Western Property Boundary AS/SVE S stem

M & E East AS/SVE System

RPC AS/SVE System Zone 2

Metro Utility Corridor AS/SVE System Zones 1 & 2



Metro South Secondary Area AS/SVE S stem Zone 1

Metro South Secondary Area AS/SVE S stem Zone 2

Recovery Trench AS/SVE System Zone E&H

Metro Utility Corridor AS/SVE System Zones 3 & 4

PCA Subslab Depressurization

NW Boundary Uncontrolled Zones 3 & 4 AS S stem onl

Lab Subslab Depressurization AS/SVE S stem

Loading of recovered

asoline/reformate into tank trucks

Horizontal above ground 21,150

gallon tanks for storage of

recovered gasoline/reformate. The tank is vented to two (2) carbon canisters in series.

Two (2) 525 gallon tanks for storage of recovered gasoline/reformate

General Conditions

Insignificant Activities

x

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

1 See previous discussion regarding what is considered to be a deviation. Determination of whether or

not a deviation has occurred shall be based on a reasonable inquiry using readily available information.

2 Use the following entries as appropriate:

5



1 = Standard:

2 = Process:

3 = Monitor:

4 = Test:

5 = Maintenance:

6 = Record:

7 = Report: 8 = CAM:

9 = Other:

When the requirement is an emission limit or standard

When the requirement is a production/process limit

When the requirement is monitoring When the requirement is testing When required maintenance is not performed When the requirement is record keeping When the requirement is reporting A situation in which an excursion or exceedance as defined in 40 CFR Part 64

(the Compliance Assurance Monitoring (CAM) Rule) has occurred.

When the deviation is not covered by any of the above categories

6



REPORT CERTIFICATION

SOURCE NAME: Suncor Energy (U.S.A.), Inc. - Commerce City Refinery, Plant 1 (West Plant) and Plant 3 (Asphalt Unit)

FACILITY IDENTIFICATION NUMBER: 0010003

PERMIT NUMBER: 960PAD120

REPORTING PERIOD: 1/1/2019 - 6/30/2019 (see first page of the permit for specific reporting period and dates)

All information for the Title V Semi-Annual Deviation Reports must be certified by a responsible official as defined in Colorado Regulation No.3, Part A, Section I.B.38. This signed certification document must be packaged with the documents being submitted.

STATEMENT OF COMPLETENESS

I have reviewed the information being submitted in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this submittal are true, accurate and complete.

Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub-Section 18-1-501 (6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in

accordance with the provisions of Sub-Section 25-7 122.1, C.R.S.

Donald Austin

Printed or

7j LVice President of Refinery

Title

Signature of Responsible Official

g }7 /ri ~ JDate Signed

7



FACILITY NAME: Suncor Energy (U.S.A.) Inc. - Commerce City Refinery - Plants 1 & 3 (West Plant and Asphalt Unit)





Malfunction:

Normal Operation: X


West Plant - TGU Incinerator (H-25) West Plant - NO.1 FCCU (P103) West Plant - Plant 1 Main Flare (F1) West Plant - Process Heater H-6

West Plant - Process Heater H-10, H-11, H-16, H-18, H-20, H-22, H-27 and B-4

West Plant - Boiler B-6 & B-8

West Plant - Process Heaters H-13 and H-17

West Plant - Process Heater H-19

West Plant - Process Heaters H-28, H-29, H-30





West Plant - Process Heater H-241 0


CC - WP - 960PAD120, Section -- Condition 20.1





CC - WP - 960PAD120, Section -- Condition 29.2- Main Plant Flare




CC - WP - 960PAD120, Section -- Condition 22.7-FCC Opacity CC - WP - 960PAD120, Section -- Condition 22.1 0.1-CO FCC

CC - WP - 960PAD120, Section -- Condition 22.12-CO FCC

CC - WP - 960PAD120, Section I -- Condition 11.3- H-6

CC - WP - 960PAD120, Section II -- Condition 12.3- H-10, H-11, H-16, H-18, H-20, H-

22, H-27 and B-4

CC - WP - 960PAD120, Section II -- Condition 13.3-B6 & B8

Page 1 of 6 8/20/2019


CC - WP - 960PAD120, Section -- Condition 14.3- H-13 & H-17

CC - WP - 960PAD120, Section -- Condition 15.3- H-19

CC - WP - 960PAD120, Section -- Condition 16.3- H-28, H-29, H-30

CC - WP - 960PAD120, Section -- Condition 17.3- H-31 and H-32



CC - WP - 960PAD120, Section -- Condition 27.3-H2101


CC - WP - 960PAD120, Section - Condition 38


On the evening of December 31, 2018, Boiler 8 tripped offline causing a slump in steam

supply and an upset in various process units, including the No. 1 Fluidized Catalytic

Cracking Unit (FCCU), No.3 Hydrodesulfurizer (HDS) and No.4 HDS. As the steam

system stabilized around 01 :30 hours on January 1, 2019, pressure swings occurred

within the No.3 and 4 HDS amine systems sending increased acid gas flow to the Sulfur

Recovery Units (SRUs). The increased flow initially tripped the No.1 SRU offline due to

elevated system pressure and required acid gas to be sent to the Plant 1 Main Flare.

Operations personnel were able to restart the No.1 SRU briefly, but it tripped again and

remained down. The upsets resulted in ongoing elevated pressures within the sulfur

recovery complex, and therefore acid gas was being sent to the Plant 1 Main Flare

intermittently from different locations on January 1-2, 2019 in an attempt to relieve the

system pressure and avoid tripping the No.2 SRU offline as well. With the process unit

upsets causing instability in the acid gas production and the sulfur recovery units being

impacted, elevated S02 emissions occurred at the Tail Gas Incinerator (H-25).

In addition to the above events, the level controller on the Absorber Tower in the Vapor

Recovery Unit (VRU) began to malfunction on January 1, 2019, and therefore, was not

able to maintain a proper level in the tower. Liquid hydrocarbons carried over from the

tower to the Main Plant Amine System and ultimately to the No.2 Sulfur Recovery Unit

(SRU). The No.2 SRU tripped offline twice due to high liquid level in the knockout drum

on January 1, 2019 resulting in additional acid gases being sent to the Plant 1 Main

Flare. The above events also resulted in additional S02 emissions at H-25.

Note: This event, which started on Dec 31512018, was reported in 2H2018 semi-annual deviation report. The impacts from the event on the various amine systems within Plant

1 lingered for several days and led to exceedances occurring intermittently in January 2019. All exceedances which occurred in 2019 are captured in this semiannual reporting

period.


Plant 1 Fuel Gas

H2S in Fuel Gas (162 ppm 3-hr rolling average) Start Date and Time: 1/1/201904:00 hrs





End Date and Time: 1/2/201921 :00 hrs


Page 2 of 6 8/20/2019





H-25

S02 (500 Ibs in 24-hour period) Start Date and Time: 01/01/201901:00 hrs

End Date and Time: 01102/2019 23:00 hrs

No.1 FCCU

CO (500 ppmv, Corrected to 0% O2 per Consent Decree, 1-Hour Average Basis) Start Date and Time: 01101/201900:00 hrs


Start Date and Time: 01101/201907:00 hrs






Start Date and Time: 01/02/2019 11 :00 hrs








CO (500 ppmv, MACT Subpart UUU, 1-Hour Average Basis) Start Date and Time: 01/01/201902:00 hrs













Operations) Start Date and Time: 12/31/201815:36 hrs





Page 4 of 6 8/20/2019




H2S in Plant 1 Flare Gas (162 pprn 3-hr rolling average) Start Date and Time: 01/01/201902:00 hrs


















Plant 1 Main Flare



H-25

SOzC15.68 Ibs/hr)











H-25

S02 (250 pprn Corrected to 0% 02 on a 12-hour rolling average, NSPS Subpart J) Start Date and Time: 01/01/201901:00 hrs




H-25

S02 (250 pprn Corrected to 0% 02 on a 12-hour rolling average, MACT UUU) Start Date and Time: 01/01/201901 :00 hrs


Page 3 of 6 8/20/2019







Opacity (>30%, 6-Minute Block Average Basis; State Regulation - Sandblasting Operations) Start Date and Time: 01/01/201901:49 hrs


Refinery wide S02 emissions (0.3 Ib/bbl. oil processed per day - Colorado Reg 1) Start Date and Time: 01/01/201900:00 hrs



Operations and maintenance personnel worked safely and efficiently to troubleshoot all of the issues taking place and stabilize the process units. Operational adjustments were made to minimize the amount of acid gas production, including maintaining the No. 1 FCCU at minimum rate (post-upset) and putting the No. 3 and No. 4 HDS units on circulation.

The cause of the Boiler 8 trip and steam supply instabilities was scaffolding constructed by a contractor which was located next to the damper valves. The scaffolding restricted the

dampers from opening to the required position, which ultimately caused the unit to trip due to a loss of flame. The cause of the hydrocarbon carryover from W-37 on January 1, 2019 and the No.2 SRU tripping offline was a malfunctioning level controller valve positioner. A

contributing factor was that the No.2 SRU knockout drum pumps did not function properly when liquid was introduced into the system. This allowed the liquid level in the No.2 SRU knockout drum to increase, and caused the No. 2 SRU to automatically trip offline, as

designed.


The valve positioner on the level controller at W-37 was reset after the event. An

evaluation of improvements to the pre-job walkthrough and permitting processes in order to help ensure that scaffolding installations do not interfere with the operation of equipment was completed.


Suncor notified the CDPHE on -

~ 1/02/2019 at approximately 10:30 hrs.

. 1/03/2019 at approximately 09:00 hrs. ’1/04/2019 at approximately 08:00 hrs.

,\ 1/09/2019 at approximately 07:00 hrs.

. .1/11/2019 at approximately 09:00 hrs. ..1/14/2019 at approximately 07:00 hrs.

~’1/15/2019 at approximately 07:00 hrs.

Page 5of6 8/20/2019




Page 6 of 6 8/20/2019









Malfunction:

Normal Operation: X


West Plant -Tank 1 (050)


CC - WP - 960PAD120, Section II -- Condition 2.2



On January 6, 2019 OMD operators discovered that gas oil on top of the floating roof at Tank 1. As an External Floating Roof (EFR) tank, Tank 1 is permitted as a Group 1 MACT CC storage tank. However, due to operational circumstances and other tanks maintenance outages, heavier products are stored in Tank 1 on an as needed basis. In

this case, gas oil, which is not a material subject to Group 1 MACT CC requirements, was stored in the tank. When gas oil is stored in an external floating roof tank, the material tends to stick to the tank walls as the floating roof descends, and later gets wiped onto the seal as the floating roof ascends. With rising ambient temperatures, the

product on the seal becomes less viscous and flows to the roof drain of the floating roof.

With its very low vapor pressure, gas oil can be stored in fixed roof tanks that do not

have any controls. It is because of the aforementioned?spects that Suncor does not believe unregulated material on a tank roof is a deviation. However, this event is being reported as a conservative measure to be consistent with past reporting practices.

It should also be noted that the storage of gas oil in Tank 1 (an EFR tank) versus the usual Tank 2 or 3 (the fixed roof tank) results in a reduction of emissions outside of the

periods in which a small amount gets on the roof





Page 1 of 2 8/26/2019


Operations personnel cleaned up the spilled material from the ground on January 9, 2019. The product on the roof was cleaned up on January 16, 2019.


Efforts are made to minimize the usage of T-1 for heavier products such as gas oil to

prevent this issue from occurring.


NA


Page 2 of 2 8/26/2019



FACILITY NAME: Suncor Energy (U.S.A.) Inc. - Commerce City Refinery - West Plant





Malfunction:

Normal Operation: X


West Plant- Unpermitted Fugitive Emissions


CC - 960PAD120 - Condition 43.8

CC - 960PAD120 - Condition 47

CC - 960PAD120 - Condition 53


On January 10, 2019, four (4) open-ended lines were discovered at the West Plant wastewater treatment system API closed vent system. These were plugged on the

same day.

8 valves, 35 connectors and 3 other components in the West Plant were

discovered in the field as subject to LDAR monitoring requirements but had not

previously been included in the LDAR inspection program. The components were added to the LDAR inspection program for continual monitoring.


OEls



.

Components Start Date and Time: 1/1/201900:00 hrs



Plugs were put in place on the 4 OELS the same day they were identified. The

components were added to the LDAR inspection program for continual monitoring.

Page 1 of 2 8/21/2019




The LDAR coordinator is working closely with operations to ensure open-ended line LDAR requirements are met in the field, as well as operation and maintenance

teams to ensure all field changes are correctly captured by Suncor’s Management of Change (MOC) process.



Page 2 of 2 8/21/2019








Upset: N/A: X

(For NSPS/MACT) Did the deviation occur during:Startup: Shutdown: X

Malfunction:

Normal Operation:


West Plant - Plant 1 Main Flare (F1) West Plant - Plant 1 GBR Flare (F3)


CC - WP - 960PAD120, Section" -- Condition 29.9- Main Plant Flare

CC - WP - 960PAD120, Section" -- Condition 46.8- Main Plant Flare

CC - WP - 960PAD120, Section" -- Condition 31.2- GBR Flare


On January 15 2019, the No.4 HDS began shutting down for a planned maintenance

outage and repairs. Part of the unit was depressured and purged to remove all products within the system. For a portion of the shutdown and purging process, the first stage of the flare gas recovery system (FGRS) had to be taken offline, and the gases were routed to the flare. The shutdown of 4HDS caused hydrogen imbalance in Plant 1 and

as a result significant amount of hydrogen was sent to the GBR flare for an extended

period.


H2S in Plant 1 Flare Gas (162 pprn 3-hr rolling average) Start Date and Time: 01/15/2019 10:00 hrs


GBR Flare

Flare Gas Flow (6,123 Mscf 24-hour rolling average-Alternate Operating Baseline) Start Date and Time: 01/20/2019 12:00 hrs



Shutdown procedures were followed to safely and efficiently bring part of 4HDS unit down and to reduce flaring during the shutdown.

Page 1 of 2 8/20/2019




Flaring of process gases during unit shutdown and purging activities is necessary to

maintain safe refinery operations. Suncor operations and environmental personnel

continuously monitored the unit shutdown to ensure flaring was minimized and safe

operating conditions were maintained.


Suncor notified the CDPHE on 1/16/2019 at approximately 10:00 hrs.



Page 2 of 2 8/20/2019



Monitoring and Permit Deviation Report - Part "






Malfunction: X


West Plant - Plant 1 Main Flare (F1) - 073





On January 24th 2019, at around 8:30 am, the pressure on Xcel Energy line supplying natural gas to the refinery suddenly dropped from 448 psig to 331 psig. The sudden

drop in city gas pressure caused Hydrogen plant to trip and shutdown. Natural gas from Xcel Energy is a feed to the Hydrogen Plant. Due to the process upset at Hydrogen Plant, the first stage of the Flare Gas Recovery System (FGRS) had to be taken offline to prevent system overload by off gases. This event resulted in H2S containing gases being sent to the flare.


H2S in Plant 1 Flare Gas (162 pprn 3-hr rolling average) Start Date and Time: 01/24/2019 11 :00 hrs



Suncor immediately took actions to restore pressure in the natural gas supply line and the

Hydrogen Plant was restarted shortly.


After the incident, Xcel Energy informed Suncor that the diaphragm for the pilot on the monitor at station F-790 was found ruptured and this most likely caused the pressure drop. As an immediate follow up, regulators were manually adjusted by Xcel workers at F-790 to control flow out of the station. To prevent recurrence of the incident, Xcel added a low flow

set point in their alert system.



Page 1 of 2 8/20/2019




Page 2 of 2 8/20/2019









Malfunction:

Normal Operation:


West Plant - Plant 1 Main Flare (F1) West Plant - TGU Incinerator (H-25)


CC - WP - 960PAD120, Section II -- Condition 29.9- Main Plant Flare


CC - WP - 960PAD120, Section II -- Condition 20.1 - H-25





On Jan 28th 2019, No.4 HDS, Hydrogen Plant and NO.1 SRU at Plant 1 began starting

up following a planned maintenance outage at No.4 HDS. During the start-up, the first

stage of the flare gas recovery system (FGRS) had to be taken offline, and as a result

high H2S gases were routed to the flare. On February 2 2019, the tail gas incinerator H- 25 experienced an increase in S02 emissions during the planned startup of the NO.1 SRU.


H25 in Plant 1 Flare Gas (162 ppm 3-hr rolling average) Start Date and Time: 01/28/2019 06:00 hrs


H-25

502 (15.68 Ibs/hr)





Page 1 of 2 8/20/2019


H-25

S02 (250 ppm Corrected to 0% 02 on a 12-hour rolling average. NSPS Subpart J) Start Date and Time: 02/02/2019 02:00 hrs


H-25

S02 (1200F Minimum Hourly Average during Startup/Shutdown. MACT UUU) Start Date and Time: 02/02/2019 13:00 hrs



Start-up procedures were followed to safely and efficiently bring the units back online and

resume normal operations.


Suncor operations continuously monitored the unit start-up to ensure flaring was minimized and safe operating conditions were maintained.


tSuncor notified the CDPHE on 1/28/2019 at approximately 09:00 hrs.

t Suncor notified the CDPHE on 1/30/2019 at approximately 08:30 hrs.

I Suncor notified the CDPHE on 1/31/2019 at approximately 08:30 hrs.

J.. Suncor notified the CDPHE on 2/1/2019 at approximately 07:30 hrs

. Suncor notified the CDPHE on 2/4/2019 at approximately 08:00 hrs


Page 2 of 2 8/20/2019




FACILITY NAME: Suncor Energy (U.S.A.) Inc. - Commerce City Refinery - Plants 1

& 3 (West Plant and Asphalt Unit)


REPORTING PERIOD: 01101/2019-6/30/2019



Malfunction:

Normal Operation: X


West Plant - Plant 1 Main Flare (073)


CC - WP - 960PAD120, Section" -- Condition 29.10



On February ih 2019, Plant 1 main flare combustion zone gas Net Heating Value (NHV) started to decrease and eventually dropped below 270 btu/scf (15-minute block period).

Upon investigation it was determined that the flare flow controls were in manual mode at

the time of the event and couldn’t be adjusted soon enough to prevent the non-

compliance. The flare flow controls were placed on manual mode due to suspected

pressure swings in the city gas supply line from Xcel Energy.


Plant 1 Main Flare




Operator increased the city gas flow to the flare and the NHV of flare combustion zone gas increased to above 270 btu/scf


Process control and projects team will be working with unit operators and shift supervisor to address any flare Refinery Sector Rule (RSR) control concerns. If required, additional

training on RSR controls will be provided to operators.


N/A


Page 1 of 1 8/20/2019








Malfunction:

Normal Operation:


West Plant - Plant 1 Main Flare (F1)






On February 9 2019, the NO.1 Crude unit began shutting down for a planned maintenance outage. The unit was depressured and purged to remove all products within the system. For a portion of the shutdown and purging process, the first stage of the flare gas recovery system (FGRS) had to be taken offline, and the gases were routed to the flare.


H28 in Plant 1 Flare Gas (162 ppm 3-hr rolling average) Start Date and Time: 02/09/2019 11 :00 hrs


Plant 1 Main Flare

802 (500 Ibs in 24-hour period) Start Date and Time: 02/10/2019 07:00 hrs



Suncor operations personnel followed planned shutdown procedures in order to bring the

process units offline safely and efficiently. The second stage of the FGRS also remained online to reduce the amount of gases sent to flare, and the first stage of the FGRS was also kept online to the extent practicable.


Page 1 of 2 8/20/2019


Flaring of process gases during unit shutdown and purging activities is necessary to

maintain safe refinery operations. Suncor operations and environmental personnel

continuously monitored the unit shutdown to ensure flaring was minimized and safe

operating conditions were maintained.



2/11/2019 at approximately 10:00 hrs.



Page 2 of 2 8/20/2019








Malfunction:

Normal Operation:







On February 13 2019, NOS unit at Plant 1 was in the process of starting up following a

planned maintenance outage. During the start-up, the first stage of the Flare Gas

Recovery System (FGRS) had to be taken offline, and as a result high H2S gases were routed to the flare.







Start-up procedures were followed to safely and efficiently bring the units back online and resume normal operations.





2/14/2019 at approximately 07:30 hrs. 2/15/2019 at approximately 7:30 hrs

Page 1 of 2 8/20/2019



Page 2 of 2 8/20/2019








Malfunction: X

Normal Operation:


West Plant - Plant 1 Main Flare (F1)


CC - WP - 960PAD120, Section II -- Condition 29.9- Main Plant Flare CC - WP - 960PAD120, Section II -- Condition 46.8- Main Plant Flare


On February 20 2019, one of the feed gas flow transmitters at Hydrogen Plant

malfunctioned and started displaying spurious low values. The values displayed by malfunction transmitter caused a surge in feed gas flow to the Hydrogen Plant. Sudden increase in feed gas flow to Hydrogen Plant caused the unit to trip. As a result of the

process upset, the first stage of the Flare Gas Recovery System (FGRS) had to be taken offline to prevent system overload. This allowed H2S-containing gases to be routed to the flare.


H2S in Plant 1 Flare Gas (162 ppm 3-hr rolling average) Start Date and Time: 02/20/2019 17:00 hrs



Suncor immediately addressed the issue which caused the process upset by reconfiguring flow transmitters.


The malfunctioned transmitter was later replaced during Hydrogen Plant shutdown.




Page 1 of 1 8/20/2019



FACILITY NAME: Suncor Energy (U.S.A.) Inc. - Commerce City Refinery -

Plants 1 & 3 (West Plant and Asphalt Unit)





Malfunction:

Normal Operation: X


West Plant -Tank 775 (042) - Tanks with Unique Requirements





On February 21, 2019, OMD operator discovered product on the roof of Tank 775. Upon further assessment, it appeared that the product had reached the roof

through the gauge pole area of the tank.





The product on the roof was cleaned up on March 6, 2019.


NA


NA


Page 1 of 1 8/26/2019


Monitoring and Permit Deviation Report - Part 1/





(For NSPS/MACT) Did the deviation occur during:Startup: X Shutdown: X

Malfunction: X

Normal Operation:


West Plant - No.1 FCCU (P103) - 025 West Plant - Plant 1 Main Flare (F1) - 073






CC - WP - 960PAD120, Section -- Condition 22.7-FCC Opacity CC - WP - 960PAD120, Section -- Condition 22.10.1-CO FCC



On 2/21/2019 at around 22:45 hrs, the No.1 Fluidized Catalytic Cracking Unit (FCCU) began to experience a process upset condition. The upset occurred at the FCC converter section (W-53) where the catalyst flow between the disengager and stripper began to drop. The decrease in catalyst flow from the disengager impacted catalyst circulation and upset the unit operation. At approximately 00:00 hrs on 2/22/2019, operations shut down the FCCU. With the FCCU offline, the wet gas compressor in the

Vapor Recovery Unit (VRU) had to be shut down, which required the first stage of the Flare Gas Recovery System (FGRS) to be taken offline to prevent system overload. This allowed H2S containing gases to be routed to the flare.


Plant 1 Main Flare



Page 1 of 7 8/20/2019



Plant 1 Main Flare

S02 (500 Ibs in 24-hour period) Start Date and Time: 02/22/2019 19:00 hrs


NO.1 FCCU

CO (500 ppmv, Corrected to 0% O2 per Consent Decree, 1-Hour Average Basis) Start Date and Time: 02/22/2019 00:00 hrs










CO (500 ppmv, MACT Subpart UUU, 1-Hour Average Basis) Start Date and Time: 02/22/2019 00:00 hrs




























Page 2 of 7 8/20/2019

Suncor Energy (US.A.) Inc.





























Start Date and Time: 02/23/1921 :00 hrs
























Page 3 of 7 8/20/2019





















































Page 4 of 7 8/20/2019

















Opacity (>30%, 6-Minute Block Average Basis; State Regulation - Sandblasting Operations) Start Date and Time: 02/22/2019 00:41 hrs































Page 5 of 7 8/20/2019



















Opacity (>30%, 6-Minute Block Average Basis; Federal Regulation - MACT,

Subpart UUU) Start Date and Time: 02/22/201900:36 hrs


















Opacity (>20%, 3-Hour Rolling Average Basis; Federal Regulation - MACT,

Subpart UUU) Start Date and Time: 02/22/201901 :00 hrs








Page 6 of 7 8/20/2019



Suncor operations personnel worked safely and efficiently to shut down No.1 FCC unit.

The second stage of the FGRS remained online to reduce the amount of gases sent to

flare, and the first stage of the FGRS was brought back online as soon as possible.

Upon troubleshooting the FCC convertor, it was determined that the drop in catalyst flow

was caused by an obstruction in the section between disengager and stripper. Suncor

suspects that a coke ball formed between the disengager and stripper, which caused the

restriction and loss of catalyst circulation.

Suncor operations and maintenance personnel worked safely and efficiently to remove obstruction in the FCC converter section. The line between the disengager and stripper was steamed out and the circulation of the catalyst was reestablished. After confirming the removal of the obstruction in the catalyst line the feed to FCCU was introduced and the

unit was started up on 2/23/2019.


Suncor performed thermal and radiation scan on the line between the disengager and

stripper to ensure no additional obstructions exist




" J Suncor not!f!ed the CDPHE on 2/27/2019 at approx!mately 08:.30 hrs.

’It. Suncor notified the CDPHE on 2/28/2019 at approximately 09:55 hrs. . Suncor notified the CDPHE on 3/01/2019 at approximately 09:45 hrs.


Page 7 of 7 8/20/2019








Malfunction:

Normal Operation: X


West Plant - Plant 1 Main Flare (073) West Plant - GBR Flare (139)


CC - WP - 960PAD120, Section 11-- Condition 29.10

CC - WP - 960PAD120, Section II -- Condition 53.91 CC - WP - 960PAD120, Section 11-- Condition 31.10


On February 22 2019, GBR flare Net Heating Value (NHV) started to decrease and

eventually dropped below 270 btu/scf (15-minute block period). On February 24 2019 Plant 1 main flare Net Heating Value (NHV) started to decrease and eventually dropped below 270 btu/scf (15-minute block period). Upon investigation it was determined that

the flare flow controls were in manual mode during the event and couldn’t be adjusted soon enough to prevent the non-compliance. The flare flow controls were placed on manual mode due to unexpected shutdown of Hydrogen Plant on February 20th 2019 and unstable conditions after re-start of Hydrogen Plant.


GBR Flare



Plant 1 Main Flare

Net Heating Value (NHV) (at or above 270 btu/scf) Start Date and Time: 2/24/201907:15 hrs




Page 1 of 2 8/20/2019

Suncor Energy (U.S.A) Inc. Commerce City Refinery





N/A


Page 2 of 2 8/20/2019








Malfunction:

Normal Operation: X


West Plant - GBR Flare (139)


CC - WP - 960PAD 120, Section II -- Condition 31.10




On the morning of February 27 2019, when GBR unit was brought online, visible emissions were observed at the GBR flare in Plant 1. It is believed that the visible

emissions at the GBR flare were caused by an overhead pressure controller at Reformer

Splitter Tower. Operations attempted to stop visible emissions by increasing the steam

flow, but could not immediately stop the presence of visible emissions. Later in the day, Net Heating Value (NHV) of GBR flare combustion zone gas started decreasing and

eventually dropped below 270 btu/scf (15-minute block period). The larger flow controller at GBR flare was in manual mode during the event due to prior issues with the valve operation and so did not open automatically when NHV dropped.


GBR Flare



Visible Emissions (exceeded 5 minutes during any 2 consecutive hours) Start Date and Time: 2/27/201908:35 hrs





Page 1 of 2 8/20/2019



Operator made adjustments to steam flow and city gas flow to the flare to stop visible

emissions at GBR flare and increase the NHV of flare combustion zone gas increased to

above 270 btu/scf.


Operations plan to update GBR startup procedure to include monitoring of GBR flare for

visible emissions. Process control and projects team will be working with unit operators and shift supervisor to address any flare Refinery Sector Rule (RSR) control concerns. If

required, additional training on RSR controls will be provided to operators.


Suncor notified the CDPHE on February 28 2019 at 09:55 AM


Page 2 of 2 8/20/2019








Malfunction: X

Normal Operation:







On March 12 2019, Plant 1 Hydrogen Plant operator discovered a fire under heater H- 2101 on the west side at the entrance to the collector tube and the Hydrogen Plant was immediately shutdown. During shutdown, the first stage of the Flare Gas Recovery System (FGRS) had to be taken offline to prevent system overload by off gases. This resulted in H2S containing gases being sent to the flare.

On March 17 2019 process unit NoAHDS, previously shutdown and under pressure (not completely de-inventoried) due to Hydrogen Plant unavailability, developed leaks in at least 3 different locations. As a result of the leaks, NoAHDS was immediately de-

pressurized and H2S containing gases were sent to the flare

Upon further assessment after Hydrogen Plant shutdown, a cracked weld was

discovered at H-2101 on the 8" collector to transfer line. During preparation of the heater for repair work, water unexpectedly entered the Hydrogen Plant from the steam side of the mix tee in the front end of the unit. On March 24 2019, the dry out of process of hydrogen plant began by utilizing four temporary burners. During the dry out process H2S containing gases were sent to the Plant 1 flare.







Page 1 of 2 8/22/2019







Suncor operations personnel followed planned shutdown procedures in order to bring the

Hydrogen Plant offline safely and efficiently.


Upon investigation, a crack on the H-2101 effluent line was discovered in the unit and was

determined to be the cause of the fire. Suncor repaired the crack and restarted the

Hydrogen Plant.



, 3/13/2019 at approximately 10:00 hrs.

"3/14/2019 at approximately 11 :20 hrs.

.3/18/2019 at approximately 10:05 hrs.



( 3/27/2019 at approximately 09:35 hrs.

,f 3/28/2019 at approximately 09:00 hrs.

....3/29/2019 at approximately 10:00 hrs.

,4/01/2019 at approximately 09:00 hrs.


Page 2 of 2 8/22/2019








Malfunction: X

Normal Operation:


West Plant - TGU Incinerator (H-25) West Plant - Plant 1 Main Flare (F1)










On March 13th 2019 at approximately 10:46 Hrs., high winds associated with a winter storm at Commerce City affected Xcel Energy power supply systems which in turn

caused blips in electric power supply to the refinery. The blips in electric power supply shutdown the recycle compressor C-18 and interrupted the feed flow to the Plant 1 NO.2

Hydrodesulfurizer (HDS) and Naphtha Desulfurizer (NDS)/Reformer process units.

Attempts to restart C-18 and other impacted equipment were unsuccessful and as a result impacted units were safely shutdown. The shutdown of the Reformer unit resulted in the loss of hydrogen production to the #3 HDS. The #1 Sulfur Recovery Unit (SRU) was also shut down. The unplanned shutdown resulted in high H2S gases being sent to H-25 and Plant 1 main flare. Elevated S02 emissions continued from H-25 while

personnel worked to restart the process units after the storm.


Plant 1 Flare



Page 1 of 3 8/22/2019


Plant 1 Flare



H-25

S02(15.68 Ibs/hr)







H-25

S02 (250 ppm Corrected to 0% 02 on a 12-hour rolling average, NSPS Subpart J)



H-25

S02 (250 ppm Corrected to 0% 02 on a 12-hour rolling average, MACT UUU)



H-25




Operations and maintenance personnel worked safely and efficiently to troubleshoot all of

the issues taking place and stabilize the process units. The No.1 SRU was shutdown to

improve stability of the No.2 SRU. The second stage of the flare gas recovery system

(FGRS) remained online to reduce the amount of gases sent to flare, and the first stage of

the FGRS was brought back online as soon as possible.

The unexpected and unplanned blips in electric power supply caused by strong winds

associated with a winter storm on March 13, 2019 resulted in the malfunction and

shutdown of process units at the refinery. Suncor reacted promptly and correctly to the

electrical power interruption by shutting down units using applicable shutdown procedures. Planned startup of the process units following the winter storm was performed by

methodically sequencing unit startups and working diligently to minimize emissions.


Suncor plans to review and determine if any improvements can be made to compressor C-

18 in order to overcome electric power blips in the future

Page 2 of 3 8/22/2019



Suncor notified CDPHE on March 142019 at approximately 11 :20 AM

Suncor notified CDPHE on March 15 2019 at approximately 09:50 AM Suncor notified CDPHE on March 18 2019 at approximately 09:50 AM


Page 3 of 3 8/22/2019









Malfunction:

Normal Operation: XOPERATING PERMIT UNIT IDENTIFICATION:

West Plant - Plant 1 Main Flare (073)





On March 19 2019, Plant 1 main flare Net Heating Value (NHV) started to decrease and

eventually dropped below 270 btu/scf (15-minute block period). Upon investigation it

was determined that the city gas controllers associated with Plant 1 flare were placed in

manual mode prior to the event. Operations placed the city gas controllers in manual mode due to oscillating behavior of flare supplemental city gas flow controller. The

manual mode prevented sufficient supplemental city gas flow to the flare and as a result the NHV dropped below permitted limit.


Plant 1 Main Flare









Suncor notified the CDPHE on 3/20/2019 at approximately 09: 1 0 hrs

Division Code QA: DEVIATION CODE:

Page 1 of 1 8/22/2019








Malfunction:

Normal Operation: X







On March 20, 2019 OMD operators discovered gas oil on top of the floating roof Tank 1. Gas oil had also drained to the ground through the roof drain on Tank 1. As an External

Floating Roof (EFR) tank, Tank 1 is permitted as a Group 1 MACT CC storage tank.

However, due to operational circumstances and other tanks maintenance outages, heavier products are stored in Tank 1 on an as needed basis. In this case, gas oil, which is not a material subject to Group 1 MACT CC requirements, was stored in the tank. When gas oil is stored in an external floating roof tank, the material tends to stick to the tank walls as the floating roof descends, and later gets wiped onto the seal as the

floating roof ascends. With rising ambient temperatures, the product on the seal becomes less viscous and flows to the roof drain of the floating roof.


have additional control measures. It is because of the aforementioned aspects that Suncor does not believe unregulated material on a tank roof is a deviation. However, this event is being reported as a conservative measure to be consistent with past reporting practices.

It should also be noted that the storage of gas oil in Tank 1 (an EFR tank) versus the usual Tank 2 or 3 (the fixed roof tank) results in a reduction of emissions outside of the

periods in which a small amount gets on the roof




Page 1 of 2 8/26/2019




The product on the roof was cleaned up on April 26, 2019.





NA


Page 2 of 2 8/26/2019








Malfunction:

Normal Operation: X







On March 28, 2019 JFS contactors discovered gas oil on the roof of Tank 58 when

performing a routine seal inspection. As an External Floating Roof (EFR) tank, Tank 58 is permitted as a Group 1 MACT CC storage tank. However, due to operational circumstances and other tanks maintenance outages, heavier products are stored in Tank 58 on an as needed basis. In this case, gas oil, which is not a material subject to

Group 1 MACT CC requirements, was stored in the tank.

When gas oil is stored in an external floating roof tank, the material tends to stick to the tank walls as the floating roof descends, and later gets wiped onto the seal as the

floating roof ascends. With rising ambient temperatures, the product on the seal becomes less viscous and flows to the roof drain of the floating roof.


have additional control. It is because of the aforementioned aspects that Suncor does

not believe unregulated material on a tank roof is a deviation. However, this event is

being reported as a conservative measure to be consistent with past reporting practices.

It should also be noted that the storage of gas oil in an EFR tank versus the usual fixed roof tank results in a reduction of emissions outside of the periods in which a small amount gets on the roof




Page 1 of 2 8/26/2019




The product on the roof was cleaned up on May 1, 2019.




DATES OF UPSETS/EMERGENCIES REPORTED (IF APPLICABLE) NA


Page 2 of 2 8/26/2019








Malfunction:

Normal Operation: X


West Plant - NO.1 FCCU (P103) - 025









CC - WP - 960PAD120, Section -- Condition 22.7-FCC Opacity CC - WP - 960PAD120, Section -- Condition 22.1 0.1-CO FCC



On April 9 2019 at approximately 7: 11 pm, Plant 1 operator was in the process of

performing a scheduled lube oil change on NO.1 FCC charge pump P-3510. When pump P-3510 was switched to full size spare pump P-3511, charge to NO.1 FCC started to drop and the unit went into an upset mode. The upset lasted for close to 2.5 hours and

ultimately resulted in reverse flow of FCC regen catalyst into compressor C-16 discharge pipe. The reverse flow of catalyst caused the failure of weld in C-16 discharge pipe. Upon noticing catalyst flowing out of the venture flow meter and out of the C-16 vent line, operations initiated emergency shutdown of NO.1 FCC unit.

During investigation it was determined that the root cause of the event was the

inadvertent closure of warm line valve on spare pump P3511. The closed warm up line

valve led to accumulation of water in the suction side of spare pump P3511. When the

spare pump P3511 was placed in service, accumulated water flowed into FCC heater and caused the unit upset.


Page 1 of 5 8/22/2019


Plant 1 Main Flare









Plant 1 Main Flare

Net Heating Value (NHV) (at or above 270 btu/scf) Start Date and Time: 4/10/2019 01 :00 hrs


Plant 1 Flare

Visible Emissions (exceeded 5 minutes during any 2 consecutive hours) Start Date and Time: 4/09/201921 :22 hrs


No.1 FCCU



















CO (500 ppmv, MACT Subpart UUU, 1-Hour Average Basis) Start Date and Time: 04/09/2019 19:00 hrs




Page 2 of 5 8/22/2019

































Opacity (>30%, 6-Minute Block Average Basis; State Regulation - Sandblasting Operations) Start Date and Time: 04/09/2019 19: 19 hrs


Opacity (>30%, 6-Minute Block Average Basis; Federal Regulation - MACT, Subpart UUU) Start Date and Time: 04/09/2019 19:18 hrs










Page 3 of 5 8/22/2019











End Date and Time: 04/10/2019 18:30 hrs Start Date and Time: 04/10/2019 18:42 hrs






















Operations made every possible effort to stabilize the unit during the upset. However,

upon noticing catalyst flowing out of the venture flow meter and out of the compressor C-

16 vent line, operations initiated emergency shutdown of NO.1 FCC unit.


Suncor plans to establish the use of high regen pressure override DCS control.

Emergency procedures will be updated to include clearer definition of conditions that

require an emergency shutdown. Additional training will be provided to shift teams to

handle similar events in the future.




Suncor notified CDPHE on April 122019 at approximately 09:30 hrs


Page 4 of 5 8/22/2019




Page 5 of 5 8/22/2019








(For NSPS/MACT) Did the deviation occur during:Startup: X

Shutdown:

Malfunction:







On April 15 2019, No.4 HDS and Hydrogen Plant at Plant 1 began starting up following a maintenance and repair outage. During the start-up, the first stage of the Flare Gas

Recovery System (FGRS) had to be taken offline, and as a result high H2S gases were routed to the flare.








resume normal operations.




Suncor notified the CDPHE on 4/16/2019 at approximately 09:25 hrs

Suncor notified the CDPHE on 4/18/2019 at approximately 09:45 hrs Suncor notified the CDPHE on 4/22/2019 at approximately 09:50 hrs


Page 1 of 1 8/22/2019









Malfunction: X

Normal Operation:


West Plant - TGU Incinerator (H-25)




On April 23rd at around 12 pm, operators noticed a high level alarm on drum 0-7706 at Plant 1 Sulfur Recovery Unit (SRU). The high level in drum 0-7706 automatically shut down booster blower, tripped valves and diverted tail gas to H-25 incinerator. This in turn caused an exceedance of hourly S02 permit limit at H-25 incinerator. Upon investigation it was determined that the upset was caused by a plugged p-trap in drum 0-7706. The

plugged p-trap led to high level in drum 0-7706.


H-25

SOz(15.68 Ibs/hr)




Once the alarm came in to indicate that the booster blowers had tripped, operations

opened bypass valve to ensure tail gas is routed to the treating section of the tail gas unit instead of H-25.


Operators cleared the plugged p-trap and returned the unit to normal state.




Page 1 of 1 8/22/2019








Malfunction:

Normal Operation: X






On April 23 2019, the p-trap in drum 0-7706 at No.1 SRU plugged and as a result the blowers tripped causing gases to be routed directly to H-25. The booster blower bypass was then enabled by the operators to divert Tail Gas Unit (TGU) flow around the booster blowers.

On April 24 2019, SRU board operator attempted to return the 0-7706 blower bypass back to "normal" state. In the SRU board display there are options available to enable/disable individual bypasses around H-25/TGU, and there is also a common switch. Instead of utilizing the individual bypass option, SRU operator inadvertently utilized the common switch to put 0-7706 blower bypass back to "normal" state. When the common switch was put back to "normal" state, all the SRU gases were diverted back to H-25 and this lead to permit limit exceedance at H-25. Initial interviews revealed

confusion across multiple operators around how the bypass screen is configured and used.


H-25

802 (15.68 Ibs/hr)




SRU operators immediately re-enabled the TGU bypass and got the gases diverted back to TGU.

Page 1 of 2 8/22/2019



Suncor will be evaluating improvements to simply and improve the bypass capabilities #1

SRU, #2 SRU, TGU and H-25. Suncor plans to develop and conduct training with

operations on the bypass capabilities.


Suncor notified CDPHE on April 242019 at approximately 10:30hrs


Page 2 of 2 8/22/2019



FACILITY NAME: Suncor Energy (U.S.A.) Inc. - Commerce City Refinery - Plants 1 & 3 (YVest Plant and Asphalt Unit)





Malfunction:

Normal Operation:


West Plant - NO.1 FCCU (P103) West Plant - Plant 1 Main Flare (F1)








CC - WP - 960PAD120, Section -- Condition 22.10.1




On April 25 2019, Suncor began its planned start-up of No. 1 Fluid Catalytic Cracking (FCC) process unit after an emergency shutdown of the unit in the second week of April 2019. During the NO.1 FCC startup, there was a period of time when high volumes of

gas were routed to the flare. The first stage of the Flare Gas Recovery System (FGRS) had to be taken offline to prevent system overload.

High volumes of gas were routed to the flare between introduction of feed into the FCC unit and start-up of the Wet Gas Compressor (WGC). Prior to introduction of feed, there was insufficient volume of gas to operate the WGC. Once the feed was introduced a

high volume of low pressure gas was produced and since the WGC was not on-line, the

gas was routed to the flare in order to control the system pressure. After introduction of

feed, the FCC structure was stabilized, the main fractionator was started up and

stabilized, and then the WGC was started up.

After multiple start-up attempts, due to operational issues within slurry pump around

circuit, NO.1 FCC was successfully started up on April 26th 2019 (next day).

Page 1 of 4 8/22/2019



Plant 1 Main Flare









Plant 1 Main Flare



Plant 1 Flare







NO.1 FCCU















NO.1 FCCU

S02 (50 ppmv, Corrected to 0% O2, 7-day Rolling Average Basis) Start Date and Time: 04/26/2019 23:00 hrs


Page 2 of 4 8/22/2019



































Opacity (>30%, 6-Minute Block Average Basis; State Regulation - Sandblasting Operations) Start Date and Time: 04/24/2019 09:00 hrs




Opacity (>30%, 6-Minute Block Average Basis; Federal Regulation - MACT, Subpart UUU) Start Date and Time: 04/20/2019 23:06 hrs


Page 3 of 4 8/22/2019











Suncor operations personnel followed planned start-up procedures in order to bring the

No. 1 FCC process unit online safely and efficiently. The second stage of the FGRS

remained online to reduce the amount of gases sent to flare. Reducing the suction of the

first stage of the FGRS prevented a trip of the unit which would have resulted in increased

flaring.






, Suncor notified the CDPHE on 04/26/2019 at approximately 09:30 hrs lJ$uncor notified the CDPHE on 04/25/2019 at approximately 17: 1 0 hrs

"’Suncor notified the CDPHE on 04/29/2019 at approximately 09:50 hrs Q Suncor notified the CDPHE on 04/30/2019 at approximately 09:35 hrs

~uncor notified the CDPHE on 05/01/2019 at approximately 07:30 hrs

\ Suncor notified the CDPHE on 05/02/2019 at approximately 10:00 hrs


Page 4 of 4 8/22/2019








Malfunction:

Normal Operation: X







CC - WP - 960PAD120, Section" -- Condition 45.12.1



On April 28 2019, NO.3HDS and NO.1 SRU at Plant 1 began starting up following a maintenance outage. During the start-up, the fi~t stage of the Flare Gas Recovery System (FGRS) had to be taken offline, and as a result high H2S gases were routed to the flare.

Operations started NO.1 SRU on city gas and as a result gases were sent directly to H- 25 causing exceedance of S02 limit. On May 5 2019 operations began charging the NO.1 SRU with acid gases from both NO.3HDS and NoAHDS. Introduction of acid gases

initially stopped the S02 permit limit exceedance at H-25, but eventually S02 emissions increased and caused non-compliance with permit limit. Upon investigation it was

determined that the S02 exceedance at H-25 was caused by a non-functional ratio

analyzer on the NO.1 SRU and this was a prior known issue.


Plant 1 flare gas

Plant 1 Flare Gas H2S limit 162 ppm ( 3 hour rolling average) Start Date and Time: 04/29/2019 00:00 hrs




Page 1 of 3 8/22/2019



H-25

S02 (15.68 Ibs/hr)























H-25

S02 (250 pprn Corrected to 0% 02 on a 12-hour rolling average, NSPS Subpart J) Start Date and Time: 04/29/2019 00:00 hrs










resume normal operations. SRU board operators took all possible measures to reduce

S02 emissions from H-25 till replacement parts for the non-functional ratio analyzer were ordered. This included increase in O2 and addition of fresh amine in TGU.


Suncor plans to update spare parts for the non-functional tail gas S02 analyzer.





Page 2 of 3 8/22/2019


Suncor notified the CDPHE on 05/06/2019 at approximately 10:00 hrs Suncor notified the CDPHE on 05/07/2019 at approximately 10:25 hrs Suncor notified the CDPHE on 05/08/2019 at approximately 10: 15 hrs

Division Code QA: DEVIATION CODE:

Page 3 of 3 8/22/2019




FACILITY NAME: Suncor Energy {U.S.A.) Inc. - Commerce City Refinery - Plants 1 & 3 (West Plant and Asphalt Unit)





Malfunction: X

Normal Operation:


West Plant - Asphalt unit flare (074)




On May 5th 2019 at approximately 03:23 am Plant 3 flare seal drum (0-002) had

a breakthrough and gases from the seal drum were routed to the flare. As a result of the seal drum breakthrough, Asphalt unit flare gas H2S limit (162 ppm, 3 hour average) was exceeded. Upon investigation, it was determined that the flare gas compressor (C-21) screen was plugged and the plugging in turn caused the breakthrough in the seal drum (0-002).


Asphalt Unit Flare - F2

H2S in Flare Gas (162 ppm, 3-hour average) Start Date and Time: 05/05/2019 05:00 hrs



The plugged screen was cleaned and reinstalled. Compressor C-21 was restarted.


On May 7th 2019, compressor C-21 screen was found to be plugged again. The screen was permanently removed from the compressor after the second plugging event. It is

suspected that a leaking overhead condenser at vac tower W-76 might have caused the

plugging / fouling in the system. The overhead leak has been temporarily repaired.


Suncor notified the CDPHE on 5/5/2019 at 9:50 AM


Page 1 of 1 8/22/2019








Upset: N/A: X


Malfunction: X

Normal Operation:


West Plant - No.1 FCCU (P103) West Plant - Plant 1 Main Flare (F1)




CC - WP - 960PAD120, Section II -- Condition 22.7-FCC Opacity CC - WP - 960PAD120, Section II -- Condition 22.1 0.1-CO FCC

CC - WP - 960PAD120, Section II -- Condition 22.12-CO FCC


On May 6th 2019, No.1 Fluidized Catalytic Cracking (No.1 FCC) unit feed pumps P-3510 and P-3511 unexpectedly shutdown and the unit went into an upset mode. Attempts to start spare pump failed and emergency shutdown of No.1 FCC unit was initiated. Upon initial investigation, it was determined that the feed pumps shutdown due to loss of feed flow into the unit. The exact reason of feed flow loss is unknown. It is suspected that

possible changes in FCC feed composition could have caused the feed pumps to shut down.


Plant 1 Main Flare



No.1 FCCU

CO (500 pprnv, Corrected to 0% O2 per Consent Decree, 1-Hour Average Basis) Start Date and Time: 05/06/201914:00 hrs


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CO (500 ppmv, MACT Subpart UUU 1-Hour Average Basis) Start Date and Time: 05/06/201914:00 hrs






After evaluating the state of the unit, NO.1 FCC was restarted and the feed was

reintroduced to the unit.


Due to process upset and subsequent shutdown / start-up, Opacity and CO limits at NO.1

FCC and Plant 1 flare gas H2S limit were exceeded. Operations continue to evaluate

NO.1 FCC feed composition.


Suncor notified CDPHE on May 7 2019 at approximately 10:25 AM


Page 2 of 2 8/22/2019









Malfunction: X

Normal Operation:


West Plant - Asphalt unit flare (074)




On May 7th 2019 at approximately 08:00 pm Plant 3 flare seal drum (D-002) had a

breakthrough and gases from the seal drum were routed to the flare. As a result of the seal drum breakthrough, Asphalt unit flare gas H2S limit (162 ppm, 3 hour average) was exceeded. Upon investigation, it was determined that the flare gas compressor (C-21) screen was plugged and the plugging in turn caused the breakthrough in the seal drum

(D-002). Compressor C-2 was immediately started up and C-21 was taken offline.






Compressor C-2 was immediately started up and C-21 was taken offline. The plugged screen on C-21 was permanently removed after the event.


The plugged screen was permanently removed from compressor C-21 after the event. It

was suspected that a leaking overhead condenser at vac tower W-76 might have caused the plugging / fouling in the system. The overhead leak has been temporarily repaired.


Suncor notified the CDPHE on 5/8/2019 at 10:20 AM


Page 1 of 1 8/22/2019








Malfunction: X

Normal Operation:


West Plant - No.1 FCCU (P103)




On May 14th 2019, the Catalyst Fines Hopper at No.1 Fluidized Catalytic Cracking (No.1 FCC) was taken offline for scheduled maintenance. When performing scheduled

maintenance, internal erosion damage was discovered in the Hopper by the

maintenance crew. Upon further assessment it was determined that in order to repair the Hopper’s internal damage, replacement parts were required. The replacement parts were not immediately available and in an effort to prevent process unit upset, the

Catalyst Fines Hopper was returned to service on the same day. The unanticipated delay in completing the scheduled maintenance lead to significant accumulation of

catalyst at the fourth stage separator and this in turn caused opacity exceedance when the Hopper was placed back in service. On May 15th 2019, after securing replacement parts required for Hopper repair, Catalyst Fines Hopper was taken offline and the repair work completed. The repaired Hopper was placed back in service on May 15th 2019. The additional time taken to complete the Hopper repair lead to significant accumulation of catalyst at the fourth stage separator and this in turn caused opacity exceedance when the Hopper was placed back in service.


Plant 1 FCC








Page 1 of 2 8/22/2019




The replacement parts required to fix Hopper’s internal damage were not immediately available and in an effort to prevent process unit upset, the Catalyst Fines Hopper was

returned to service on the same day.


On May 15th 2019, after securing replacement parts required for Hopper repair, Catalyst Fines Hopper was taken offline and the repair work completed.


Suncor notified CDPHE on May 15 2019 at approximately 09:05hrs

Suncor notified CDPHE on May 16 2019 at approximately 10: 1 Ohrs


Page 2 of 2 8/22/2019








Malfunction:

Normal Operation: XOPERATING PERMIT UNIT IDENTIFICATION:

West Plant - TGU Incinerator (H-25) West Plant - Plant 1 Main Flare (F1)









On May 14th 2019 at around 12:55 PM, significant foaming was observed at amine

regenerator (W-88) located at NO.3 Diesel Hydrodesulphurization Unit (No.3 HDS). Upon initial investigation, it was determined that the foaming was caused by hydrocarbon carry over from High Pressure Cold Separator Drum (0-339) at NO.3 HDS process unit. The

hydrocarbon liquid eventually carried over into NO.1 Sulfur Recovery Unit (No.1 SRU) and

tripped the unit down. NO.1 SRU tripped due to high level of hydrocarbon liquid in Acid Gas Stop Drum (0-206). The acid gas stop drum pump (P-280) did not function during the event. In order to prevent shutdown of No. 2 SRU, during the event, operations immediately diverted acid gas from amine regenerator W-88 to Plant 1 flare. Preventing shutdown of NO.2 SRU during the event minimized the duration of acid gas flaring as acid

gases from No.4 HDS and main plant amine regenerators were not routed to the Plant 1 flare.








Page 1 of 3 8/22/2019


Plant 1 Main Flare



H-25

502 (15.68 Ibs/hr) Start Date and Time: 05/14/19 13:00 hrs














H-25

502 (250 ppm Corrected to 0% 02 on a 12-hour rolling average, NSPS Subpart J) Start Date and Time: 05/14/2019 13:00 hrs


H-25

502 (250 ppm Corrected to 0% 02 on a 12-hour rolling average, MACT UUU)



H-25




As an immediate corrective measure, unit operators added anti foam to the amine

system and utilized vacuum trucks to empty Acid Gas Stop Drum (D-206) at NO.1 SRU

and Acid Gas Knock Out Drum (D-2000) & Sour Water Stripper Knock Out Drum (D-

2001) at NO.2 SRU. Operations and maintenance personnel worked safely and

efficiently to troubleshoot all of the issues taking place and stabilize the process units.

The second stage of the FGRS remained online to reduce the amount of gases sent to

flare. Reducing the suction of the first stage of the FGRS prevented a trip of the unit

which would have resulted in increased flaring. Operational adjustments were made to

ensure NO.2 SRU stayed online during the incident. Preventing shutdown of NO.2 SRU

during the event minimized the duration of acid gas flaring as acid gases from No.4 HDS

and main plant amine regenerators were not routed to the Plant 1 flare. Once the unit

stabilized NO.1 SRU was brought back on-line and acid gas flaring was stopped.

Page 2 of 3 8/22/2019




Valve at 0-339 was steamed out to remove any possible obstruction. Level controller

LC 109 and LC 115 was recalibrated after the event. Suncor plans to investigate available

improvements for level controllers LC-109 and LC-115. Suncor also plans to evaluate the SRU knockout drum pump system.


Suncor notified the CDPHE at the following times regarding the exceedances:


05/16/2019 at approximately 10: 1 0 hrs


Page 3 of 3 8/22/2019








Malfunction:

Normal Operation: X


West Plant - TGU Incinerator (H-25) West Plant - Plant 1 Main Flare (F1) West Plant - Process Heater H-6

West Plant - Process Heater H-10, H-11, H-16, H-18, H-20, H-22, H-27 and B-4

West Plant - Boiler B-6 & B-8



West Plant - Process Heaters H-28, H-29, H-30





West Plant - Process Heater H-241 0








CC - WP - 960PAD120, Section I -- Condition 11.3- H-6

CC - WP - 960PAD120, Section II -- Condition 12.3- H-10, H-11, H-16, H-18, H-20, H-

22, H-27 and B-4

CC - WP - 960PAD120, Section -- Condition 13.3-B6 & B8

CC - WP - 960PAD120, Section -- Condition 14.3- H-13 & H-17

CC - WP - 960PAD120, Section -- Condition 15.3- H-19

CC - WP - 960PAD120, Section -- Condition 16.3- H-28, H-29, H-30





Page 1 of 4 8/22/2019



CC - WP - 960PAD120, Section 11-- Condition 28.3-H2410



On May 16th 2019 an upset began at NO.3 Diesel Hydrodesulphurization Unit (No.3 HDS) amine system. The upset was caused by hydrocarbon carryover within the amine system and ultimately lead to hydrocarbon carryover from High Pressure Cold Separator Drum (0-

339) to the NO.1 and NO.2 Sulfur Recovery Units (SRUs). The NO.1 and NO.2 SRUs

tripped offline resulting in acid gases being sent to the Plant 1 Flare and H-25.


Plant 1 Fuel Gas

H25 in Fuel Gas (162 ppm 3-hr rolling average) Start Date and Time: 05/16/19 16:00 hrs










Start Date and Time: OS/20/19 02:00 hrs




H25 in Plant 1 Flare Gas (162 ppm 3-hr rolling average) Start Date and Time: 05/17/19 12:00 hrs




Plant 1 Main Flare



Plant 1 Flare

Visible Emissions (exceeded 5 minutes during any 2 consecutive hours) Start Date and Time: 5/16/2019 18:29 hrs




H-25

502 (15.68 Ibs/hr) Start Date and Time: 05/16/19 15:00 hrs


Page 2 of 4 8/22/2019











H-25

S02 (250 ppm Corrected to 0% 02 on a 12-hour rolling average. NSPS Subpart J) Start Date and Time: 05/16/2019 15:00 hrs


H-25

S02 (250 ppm Corrected to 0% 02 on a 12-hour rolling average. MACT UUU) Start Date and Time: 05/16/2019 15:00 hrs


H-25




Operations and maintenance personnel worked safely and efficiently to troubleshoot the No. 3HDS amine system and return the system to stable conditions. Operational adjustments were made to minimize the amount of acid gas production, including reducing the NO.1 FCCU rate and placing the NO.3 HDS unit on circulation. The second stage of the Flare Gas Recovery System (FGRS) compressor remained online to the extent practicable to help minimize the volume of gases sent to the flare.

The root cause of the hydrocarbon carryover was a malfunctioning level controller

(LC115) on drum 0-339. A contributing factor is believed to be a plugged level control

valve, associated with LC 109 at the bottom of drum 0-339, that prevented flow of sour water from 0-339. A second contributing factor was the SRU knockout drum pumps which did not function properly when liquid was introduced into the system. This caused the liquid levels in the SRU knockout drums to increase, the No. 1 and No. 2 SRUs to

automatically trip offline, as designed and acid gas flaring to occur.


Valve at 0-339 was steamed out to remove any possible obstruction. Level controller

LC 109 and LC 115 was recalibrated after the event. Suncor plans to investigate available

improvements for level controllers LC-109 and LC-115. Suncor also plans to evaluate the SRU knockout drum pump system.


Suncor notified the CDPHE at the following times regarding the exceedances:


OS/20/2019 at approximately 07:45 hrs

Page 3 of 4 8/22/2019



OS/21/2019 at approximately 06:30 hrs

OS/28/2019 at approximately 11 :00 hrs


Page 4 of 4 8/22/2019









Malfunction:

Normal Operation: X


West Plant - GBR Flare (139)





At the beginning of morning shift on May 24th 2019, Plant 1 operator observed the

presence of a large flame on GBR flare. After confirming that process conditions were not contributing to the large flame at GBR flare, operator manually reduced the city gas flow to GBR flare in order to mitigate the large flame. City gas flow valves were on manual mode during the event. Reduction in city gas flow eliminated the presence of

large flame at GBR flare, however the reduction lead to drop in Net Heating Value (NHV) of flare combustion zone gas. The NHV eventually dropped below 270 btu/scf (15- minute block period).


GBR Flare

Net Heating Value (NHV) (at or above 270 btu/scf) Start Date and Time: 5/24/2019 05: 15 hrs



Operator immediately re-opened the city gas flow valves to the flare and the NHV of flare combustion zone gas increased to above 270 btu/scf




Page 1 of 2 8/22/2019



Suncor notified the CDPHE on May 24 2019 at 10:00 AM


Page 2 of 2 8/22/2019









Malfunction:

Normal Operation: X


West Plant - H-25 (100)




On June 13 2019, significant foaming was observed at amine regenerator (W-88) located at NO.3 Diesel Hydrodesulphurization Unit (No.3 HDS). Upon investigation, it

was determined that the foaming was caused by hydrocarbon carryover from High Pressure Cold Separator Drum (D-339) at NO.3 HDS process unit. The hydrocarbon liquid eventually carried over into No. 1 Sulfur Recovery Unit (No.1 SRU) and this resulted in acid gases being sent to H-25. The root cause of the hydrocarbon carryover was a malfunctioning level controller (LC 115) on drum D-339. A contributing factor was the NO.1 SRU knockout drum pumps which did not function properly when liquid was introduced into the system.


H-25

502 (15.68 Ib/hr) Start Date and Time: 06/13/2019 19:00 hrs



As an immediate corrective measure, operations added anti-foam to NO.3HDS amine unit to stop foaming at amine regenerator (W-88).


Plant 1 Operations will be closely monitoring the level at drum D-339 by performing routine field visual observations. Suncor plans to investigate available improvements for level controller (LC 115) at drum D-339. An evaluation of the SRU knockout drum pump system is also planned.

Page 1 of 2 8/22/2019




Suncor notifed the CDPHE at approximately 10:05 hrs on June 14, 2019.


Page 2 of 2 8/22/2019








Upset: N/A: X


Malfunction: X

Normal Operation:


West Plant - Asphalt unit flare (F2 - 074)


CC - WP - 960PAD120, Section /I -- Condition 30.10

CC - WP - 960PAD120, Section /I -- Condition 46.8


On June 16th 2019 at approximately 7: 18 PM, H2S concentration in Plant 3 Asphalt flare

gas started increasing to a higher level. Elevated flare gas H2S concentration eventually led to exceedance of 162 ppm (3 hour rolling average) flare gas H2S permit limit. Upon

investigation it was determined that the H2S exceedance was caused by low water level in flare liquid seal drum (0-002) at Plant 3. Operations were not able to determine the exact cause of level drop in seal drum (0-002). It is suspected that the low water level in

flare liquid seal drum was caused by either a significantly leaking internal weir or a non- functional drain line.






As an immediate corrective measure, operators increased water flow to seal drum (0-002) to regain level and decrease H2S concentration in flare gas. The makeup water source was also moved downstream of the control valve to provide more reliable flow to the seal drum.


A complete assessment of flare liquid seal drum is planned to be performed during 2021

turnaround, when the drum is expected to be offline.

Page 1 of 2 8/22/2019



Suncor notified CDPHE on June 17 2019 at approximately 09:00 hrs


Page 2 of 2 8/22/2019








Malfunction: X

Normal Operation:


West Plant - Main Plant Flare F1 (073)





On June 28 2019, H2S concentration in Plant 1 Main Flare gas increased and eventually exceeded the 162 ppm (3 hour rolling average) permit limit. Upon investigation, it was determined that the exceedance was caused by a sudden increase in pressure at the sweet fuel gas drum 0193. It is believed that hot ambient temperatures around noon time on June 28th caused an increase in volume of fuel gases sent to sweet fuel gas drum 0193. The additional fuel gas volume potentially pressured up fuel gas drum

(0193) and caused the drum to vent excess fuel gas to the flare. It is also suspected that calibration issues associated with H2S analyzer may have contributed to this exceedance.


Plant 1 flare gas Plant 1 Flare Gas H2S limit 162 ppm ( 3 hour rolling average) Start Date and Time: 06/28/2019 11 :00 hrs



As an immediate corrective measure, operators removed propane from fuel gas system and implemented measures to improve fuel gas balance. During the event sweet fuel

gas was sampled for H2S by operations and the concentration recorded was found to be low (approximately 50 ppm H2S).

Page 1 of 2 8/20/2019




Sight glass on fuel gas transfer line from plant 1 to plant 2 was repaired and the transfer

line was brought back into normal operation. Testing and validation cycle was performed on Plant 1 flare H2S analyzer to ensure accuracy of analyzer readings.


Suncor notified CDPHE on July 1 2019 at approximately 10:40 AM


Page 2 of 2 8/20/2019








Malfunction: X

Normal Operation: X


West Plant - H-6

West Plant - H-1 0, H-11, H-16, H-18, H-20, H-22, H-27 and B-4 West Plant - Boiler 6

West Plant - Boiler 8

West Plant - H-13 and H-17

West Plant - H-19

West Plant - H-28, H-29, H-30 and P104



West Plant - Sulfur Recovery Units, TGU and TGI West Plant - H-1716 and 1717

West Plant - FCCU

West Plant - H-241 0

West Plant - Main Plant Flare

West Plant - Asphalt Unit Flare West Plant - GBR Unit Flare


CC - WP - 960PAD120, Part II, Condition 11.3




CC - WP - 960PAD120, Part II, Condition 13.8 CC - WP - 960PAD120, Part II, Condition 14.3






CC - WP - 960PAD120, Part II, Condition 22.2,22.3 CC - WP - 960PAD120, Part II, Condition 22.4


8/26/2019







There were periods of continuous emissions monitor (CEM) downtime recorded during the semi-

annual period. An explanation of the cause, and where applicable, the corrective actions taken

were provided in the Quarterly Excess Emissions Reports (EERs) submitted to the Division on April

29, 2019 and July 25, 2019 for Q1 and Q2, respectively, for each reported period of downtime.

To demonstrate compliance with the visible emissions requirement of 40 CFR 63.670 (c) for MACT

CC applicable flares, Suncor began monitoring flames using newly installed flare video cameras in

compliance with 40 CFR 63.670 (h) on January 30, 2019. 40 CFR Part 63.670(h)(2) requires video

surveillance records to be recorded at least once every 15 seconds and storage for a minimum of

three years. At the time of installation, the cameras were configured to record video at a rate of 1

image every second. In April 2019, Suncor corporate security performed a configuration change to

the recording system known as "video thinning". The video thinning process compresses the

recorded images after a defined period of time has lapsed down in order to minimize the usage network disk space. In June 2019, it was discovered that the video thinning decreased recorded

camera frame rate to one image every thirty seconds (half of the frequency required by the

regulation). Suncor was not aware of the reduction in recorded camera frame rate at the time of

video thinning implementation and as of a result approximately 4 ~ months of record keeping data

didn’t meeting the defined monitoring requirements of 40 CFR 63.670(h)(2). Upon discovery of the

issues, Suncor corporate disabled the video thinning system.


The duration of each CEMS downtime event is included in the Quarterly EERs.


Descriptions of the actions taken to return the CEMS to service are included in the Quarterly EERs.


CEMS analyzers run continuously; therefore, some parts wear out or may be prone to failure. The

standard operating procedure for any CEMS program is to repair the systems as expeditiously as

possible in order to return them to service and minimize downtime. Preventative maintenance is

conducted on a weekly and monthly basis in order to keep CEMS downtime to a minimum.


Division Code QA: DEVIATION CODE: 3, 6

8/26/2019

Exhibit 3

Opacity Violations Reported by Suncor Energy for the Commerce City Oil Refinery, Dec. 31, 2018-June 30, 2019.

Date Opacity Violation Started

Time Opacity Violation Started

Date Opacity Violation Ended

Time Opacity Violation

Ended

Total Minutes of Violation

PlantEmission

Point Permit No. Permit Term Limit Source of LimitTotal

Number of Violations

12/31/18 15:36 12/31/18 15:54 18 West FCCU, P103 96OPAD120Section II, Condition 22.7.1; Condition 35.1 20% Opacity CO SIP, AQCC Reg. 1, II.A.1 3


1/1/19 1:24 1/8/19 15:00 9,576 West FCCU, P103 96OPAD120Section II, Condition 22.7.1; Condition 35.1 20% Opacity CO SIP, AQCC Reg. 1, II.A.1 1596








































































































3/29/19 4:36 3/29/19 4:54 18 East FCCU, P003 96OPAD108Section II, Condition 2.8; Condition 19.1 20% Opacity CO SIP, AQCC Reg. 1, II.A.1 3




5/24/19 13:48 5/25/19 20:54 1,866 East FCCU, P003 96OPAD108Section II, Condition 2.8; Condition 19.1 20% Opacity CO SIP, AQCC Reg. 1, II.A.1 311

Documents

By Certified Mail Return Receipt Requested · 9/26/2019 · Operating Permits issued to Suncor Energy for the operation of the Commerce City refinery. Both operating permits specifically