Document 0J1Bao97ga5mJyJ1eKwxJXXER

EPA Inspection Report - Page 1 of 105 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 10/23/2023 - 10/27/2023 Air Consent Decree, Civil Action H-01-0978 Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Shell Oil Products US Norco Refinery 15536 River Road Norco, LA 70079 P.O. Box 10 Norco, LA 70079 St. Charles Parish 504-465-7111 Renee' Toups Renee.Toups@shell.com Environmental Manager FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000448864 Agency Interest Number: 1406 Permit Numbers: 2602-V12, 2902-V5, 2502-V12, 2913-V11, 2600-V5 LA0000002208900002 324110 2911 Personnel participating in inspection: Prince Nfodzo U.S. EPA, Region 6, ECDAP Bailey Brown U.S. EPA Region 6, ECDAP Ashley Cessac Louisiana Department of Environmental Quality Tyler Williams Louisiana Department of Environmental Quality Dwayne Bertrand Louisiana Department of Environmental Quality Laura Sabolyk Shell Oil Products US Janna Bouvier Shell Oil Products US Sarah Hudson Shell Oil Products US Renee' Toups Shell Oil Products US Nick Reine Shell Oil Products US Marybel Loya Shell Oil Products US Environmental Engineer Physical Scientist Environmental Scientist Environmental Scientist Environmental Scientist Environmental Team Lead Environmental Team Lead Senior Environmental Engineer Environmental Manager Air Program Coordinator Environmental Engineer EPA Lead Inspector Signature/Date BAILEY BROWN Date: 2023.12.12 09:06:36 -06'00' Digitally signed by BAILEY BROWN Bailey Brown Date Supervisor Signature/Date DARRIN LARSON Date: 2023.12.13 12:29:26 -06'00' Digitally signed by DARRIN LARSON Darrin Larson Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 105 Section I - INTRODUCTION Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Prince Nfodzo and I, Bailey Brown conducted a consent decree ("CD") follow-up inspection of Shell Oil Products US ("Shell"), Norco Refinery ("Norco") from October 23, through October 27, 2023. The refinery is located at 15536 River Road, Norco, Texas. Shell became the sole owner of the facility in May of 2017 following the joint venture separation from Motiva Enterprises. We arrived at the facility on October 23, 2023, at 12:20 pm, and conducted a fence line survey. We made entry to the facility at 12:30 pm and met with representatives of Shell for an opening conference at 1:05 pm. Prince Nfodzo led the opening conference which included introductions, briefing on the purpose, and the scope of the inspection. The sign-in sheet for the opening and closing conference is included as Appendix 3. We presented our EPA inspector credentials to Ms. Renee' Toups, Environmental Manager, Ms. Sarah Hudson, Senior Environmental Engineer, and Ms. Janna Bouviev, Environmental Team Lead. We informed the representatives that this was an EPA inspection to evaluate compliance with the requirements outlined in the CD, Civil Action H-01-0978. The Louisiana Department on Environmental Quality ("LDEQ") participated in the inspection. The CD was entered on August 20, 2001, and consists of 19 Parts. The inspection was a Partial Compliance Evaluation ("PCE") that focused on Parts IV, V, VII, and VIII which require injunctive relief to address nitrogen oxides ("NOx"), sulfur dioxide ("SO2"), carbon monoxide (`CO"), particulate matter ("PM"), and volatile organic compounds ("VOCs") emission reductions through various construction projects, process additives, and program enhancements. The inspection included an evaluation of three marquee issues: NOx CO, PM, and SO2 reductions, Leak detection and repair (LDAR), and Control devices for flaring acid gases and hydrocarbons. FACILITY DESCRIPTION Norco is a petroleum refinery located next to the Mississippi River about 20 miles west of New Orleans and has a crude conversion capacity of approximately 240,000 barrels per day with operations including catalytic cracking, alkylation, reforming, hydrodesulphurization, isomerization, sulfur recovery, and fuel blending. The facility manufactures and processes petroleum products from crude oil, condensate, natural gas condensate, and partially refined products to produce liquefied petroleum gas, ethylene, propylene, chemical products, finished gasoline, diesel, aviation fuels, heating oils, residuals, petroleum coke, and sulfur. Crude oil is delivered to the refinery via pipeline and ship while products leave the facility by pipeline, railcar, tank truck, and marine shipping. A plant-wide process flow diagram and detailed facility description is included as Appendix 4. 2 EPA Inspection Report - Page 3 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 Section II - OBSERVATIONS At the time of the inspection, Norco was undergoing planned turnaround on several units including the Distillation Unit ("DU-5"), Coker Unit ("Coker"), Naptha Hydrotreater ("NHT"), Catalytic Reformer Unit ("CR-2"), Kerosene Unit ("Kero"), and Sulfur No. 2 Plant ("S-2"). The Diesel Hydrotreater ("DHT") unit was included in the planned turnaround and scheduled to return to operation the week of the inspection. The units not included in the turnaround were the Sulfur No. 3 Plant ("S-3"), Alkylation Unit ("Alky"), and Hydrocracking Unit ("HCU"). Shell representatives informed us that the Residual Catalytic Cracking Unit ("RCCU") and the Residual Gas Heater Treater ("RGHT") have not been in operation since Thursday, October 19, 2023, following a catalyst leak on the RCCU cyclone. PART IV: AFFIRMATIVE RELIEF A. NOx Emission Reductions from Fluidized Catalytic Cracking Units ("FCCUs") and Fluid Coker Unit ("FCU") Status: On schedule Program Summary: As specified in Part VI of the CD, Shell shall implement a program to reduce NOx emissions with the installation and the operation of a Selective Non-Catalytic Reduction (SNCR) system at the Norco FCCU. Shell shall incorporate lower NOx emission limits into operating permits and will demonstrate future compliance with the lower emission limits using continuous emission monitoring systems ("CEMS"). Shell refers to the FCCU as the RCCU due to residual oil being the primary feed material. During the inspection, we observed ammonia injection being used to reduce RCCU NOx emissions (see Photo No. 1 in Appendix 1. Norco is meeting the NOx emission limits of 150.8 parts per million by volume ("ppmv") on a 365-day rolling average and 203.1 ppmv on a 24-hour rolling average, both at 0% oxygen ("O2") with a NOx SNCR system and ammonia vaporizer. There are two separate analyzers associated with the RCCU that are intertwined into each reading. The first analyzer monitors SO2, NOx, and O2, while the other analyzer monitors CO. Shell has incorporated the NOx emission limits in permit 2602-V12 issued January 28, 2022. We observed that Norco has installed and is operating the RCCU NOx CEMS in accordance with the applicable requirements, and certification and concentrations of calibration gases were accurate and current. I verified that Norco conducted cylinder gas audits ("CGA") and relative accuracy test audits ("RATA") for the period January 2020 through June 2023 in accordance with the applicable requirements of 40 CFR, Part 60, Appendix F, except for RATAs conducted during the first quarter of 2020, CGAs performed during the third quarter of 2020, and the reporting requirements on the RCCU CEMS analyzer [see Area of Concern ("AOC") #s 1 and 2]. 3 EPA Inspection Report - Page 4 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 The trends for the RCCU NOx emission limits of 150.8 ppmv on a 365-day rolling average basis and 203.1 ppm on a 24-hour rolling average basis, both at 0% O2 from October 1, 2022, through September 30, 2023, are included as Appendix 5. No exceedances of the limits occurred during this period. B. SO2 Emission Reductions from FCCUs and FCU Status: On schedule Program Summary: As specified in Part V of the CD, Shell shall continue to operate the existing Wet Gas Scrubbers ("WGS") on the FCCU. Shell shall incorporate lower SO2 emission limits into operating permits and will demonstrate future compliance with the lower emissions limits using CEMS. In addition, Shell must comply with NSPS Subparts A and J for SO2, CO, PM, and opacity limits. Norco continues to operate the existing WGS on the RCCU to meet SO2 emission limits of 25 parts per million by volume, dry basis ("ppmvd") on a 365-day rolling average basis, and 50 ppmvd on a 7-day rolling average basis, both at 0% O2. A photograph of the WGS is included as Photo No. 2 in Appendix 1. Shell is required to comply with a CO emission limit of 500 ppmvd at 0% O2 on a 1-hour average basis. Shell has incorporated the SO2 and CO emission limits into permit 2602-V12 issued January 28, 2022. We observed that Norco has installed and is operating the RCCU SO2 and CO CEMS in accordance with the applicable requirements, and certification and concentrations of calibration gases were accurate and current. I verified that Norco conducted CGAs and RATAs for the period January 2020 through June 2023 in accordance with the applicable requirements of 40 CFR, Part 60, Appendix F, except for RATAs conducted during the first quarter of 2020, CGAs performed during the third quarter of 2020, and the reporting requirements on the RCCU CEMS analyzer (see AOC #s 1 and 2). On September 29, 2022, Norco installed a temporary analyzer for the CO CEMS (serial number CO3003-M) following issues related to calibration readings associated with the original analyzer (serial number A2A6694T). Analyzer CO3003-M became the permanent analyzer while repairs were being made by the manufacturer. Analyzer A2A6694T was no longer in operation but was still included in CEMS reports (see AOC #2). Norco performed the initial RATA on the uncertified analyzer on October 27, 2022 (see AOC #3). From the period September 29, 2022, through October 27, 2022, Norco categorized this period as CEMS downtime on quarterly reports while maintenance was being performed (see AOC #4). The trends for the RCCU SO2 emission limits of 25 ppmvd on a 365-day rolling average basis, and 50 ppmvd on a 7-day rolling average basis, both at 0% from October 1, 2022, through 4 EPA Inspection Report - Page 5 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 September 30, 2023, are included as Appendix 6. No exceedances of the limits occurred during the period. The trend for the RCCU CO emission limit of 500 ppmvd at 0% O2 on a 365-day rolling average basis from October 1, 2022, through September 30, 2023, are included as Appendix 7. No exceedances of the limit occurred during this period. EPA approved Shell's alternative monitoring plan ("AMP") for opacity in lieu of continuous opacity monitoring systems (COMS) per letter dated May 7, 2018. The approved AMP requires Norco to continuously monitor and record (i) the pressure drop ("P") across the WGS, (ii) the scrubber liquid-to-gas ("L/G") ratio, and (iii) the venturi inlet differential pressure ("Pv") to the four venturis directly upstream. Shell has not incorporated all the AMP parameters in permit 2602-V12 issued January 28, 2022. Permit 2602-V12 only refers to the requirements of 40 C.F.R. Part 63 Subpart UUU (see AOC #5). The RCCU parameter trends are included as Appendix 8. C. Program Enhancements RE: Leak Detection and Repair ("LDAR") Status: On schedule Program Summary: As specified in Part VII of the CD, Shell shall undertake audits of the components in light liquid and gaseous service at each of its refineries to determine compliance with all the requirements of the LDAR regulations and to correct any areas of non-compliance. In addition, Shell shall undertake the CD listed enhancements to its LDAR program consisting of refinery-wide measures to minimize or eliminate fugitive emissions from components in light liquid and gaseous services at its refineries in accordance with the schedule set forth. Shell utilizes two separate contractors to perform audits on the LDAR program. Alliance Source Testing, LLC ("Alliance") performs internal audits and PROtect, LLC ("PROtect") performs thirdparty external audits. Shell provides the internal and external CD LDAR audit reports to EPA. We observed that Norco carries out LDAR instrument calibration accurately utilizing an automated calibration system. The automated system performs mid-day and end-of-day calibration drift checks, as required by the CD. Photographs of the LDAR equipment and instrument calibration set-up are included as Photo Nos. 3, 4, 5, and 6 in Appendix 1. We verified that certification and concentration of calibration gases were accurate and current, and that Norco uses an electronic data collection software for LDAR monitoring by data loggers, leak tracking, and reporting known as SkyBridge. Photographs of the calibration gas cylinders and gauges located outside the LDAR storage are included as Photo Nos. 7 and 8 in Appendix 1. I reviewed records which showed Shell consistently maintains calibration records and conducts annual training and audits, as required by the CD. We walked through the units and observed that components were tagged with two types of identifiers, silver square tags and blue circular tags. The silver square tags are the updated identifiers and replace the older blue circular tags (see AOC #6). A photograph of an equipment piece containing both tags is included as Photo 5 EPA Inspection Report - Page 6 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 No. 9 in Appendix 1. We queried the LDAR monitoring and reporting software with randomly selected tag numbers from the units and found discrepancies with delay of repair ("DOR") and LDAR non-detect reports (see AOC #s 7 and 8). Excerpts of the DOR and LDAR non-detect reports are included as Appendix 9. Program Enhancements RE: NSPS Subparts A and J SO2 Emissions from Sulfur Recovery Plants ("SRP's") and Flaring Status: On schedule Program Summary: As specified in Part VIII of the CD, beginning immediately upon the lodging of this Consent Decree, Shell agrees to take the following measures at all its SRPs and certain flaring devices at the refineries identified in Paragraph 5. Shell shall eliminate all reasonably preventable SO2 emissions from flaring. Shell will implement procedures for root cause analysis of acid gas flaring incidents at all refineries. Shell shall strive to extend the duration between SRP maintenance shutdowns (unscheduled or scheduled) to three years or greater. Norco operates four flares (RCCU Elevated Flare, West Ops Ground Flare, Hydrocracking Unit Flare, and Coker Flare) that are subject to NSPS Subpart Ja under the CD. Shell is operating and maintaining a flare gas recovery system (FGRS) to control continuous or routine combustion associated with the West Ops Ground Flare. Shell is complying with the H2S emission limits of 162 ppmv on a 3-hour rolling averaging basis for fuel gas combusted in flares. The Coker Flare and HCU Flare are equipped with a flare vapor recovery system ("FVRS") to compress vapors and remove excess sulfur bearing compounds to comply with the H2S emission limits of 162 ppmv on a 3-hour rolling average basis. Shell has incorporated the emission limits into permit 2502-V12 issued February 2, 2021, and 2913-V11 issued March 15, 2023. A description and diagram of the flare gas recovery systems are included as Appendix 10. Norco monitors H2S concentrations in the recovered flare gas using a continuous H2S analyzer. We observed that Norco installed and is operating CEMS in accordance with applicable requirements, and certification and concentration of calibration gases were accurate. During our inspection, we observed an expired calibration gas cylinder associated with the West Ops Ground Flare (see AOC #9). A photograph of the calibration gas cylinder is provided as Photo No. 10 in Appendix 1. Shell representatives provided clarification stating the calibration gas cylinder was not expired and later provided a certificate of analysis listing the correct expiration date. I verified that Norco conducted CEMS audits for the period of January 2020 through June 2023 in accordance with applicable requirements of 40 CFR, Part 60, Appendix F, except for a CGA conducted during the fourth quarter of 2021 on the Hydrocracking Unit Flare H2S CEMS (see AOC #10). The trends for the H2S emission limit on a 3-hour rolling average basis from October 1, 2022, through September 30, 2023, for all four flares are included as Appendix 11. Norco exceeded the emission limit multiple times during this period (see AOC #11). I verified that Norco properly documented and reported exceedances of the limit during the period. 6 EPA Inspection Report - Page 7 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 We observed all four flares using a FLIR GF320 optical gas imaging camera and only observed emissions from the RCCU Elevated Flare (see MOV_0048.mp4 in Appendix 2, AOC #12). A photograph of the RCCU Elevated Flare is provided as Photo No. 11 in Appendix 1. The facility uses two Claus Sulfur Recovery Units (S-2 and S-3) with two incinerators to comply with the SO2 emission limit of 250 ppmvd at 0% O2 on a 12-hour rolling average. Shell has incorporated the emission limit into permit 2902-V5 issued November 2, 2021, but does not include control of sulfur pit emissions (see AOC #13). We observed that Norco installed and is operating SO2 CEMS in accordance with applicable requirements, and certification and concentration of calibration gases were accurate and current. I verified that Norco conducted CEMS audits for the period of January 2020 through June 2023 in accordance with applicable requirements of 40 CFR, Part 60, Appendix F. Permitting Status: Needs revision Program Summary: As specified in Part IX of the CD, Shell agrees to apply for and make all reasonable efforts to obtain in a timely manner all appropriate federally enforceable permits (or construction permit waivers) for the construction of the pollution control technology to meet the above pollution reductions. Shell has incorporated the CD required emission limits and standards into permits 2602-V12, 2902-V5, 2502-V12, 2913-V11, and 2600-V, except for specifically outlining monitoring requirements and directly referencing regulatory requirements to fully comply with CD requirements (see AOC #s 5, 13, 14, and 15). Excerpts of the permits are included as Appendix 12. Section III - AREAS OF CONCERN 1. Shell conducted successive quarterly audits within less than two months at the RCCU CEMS. Paragraphs 19 and 54 of the CD require Shell to certify, calibrate, maintain, and operate FCCU NOx, SO2, and CO CEMS in accordance with the provisions of 40 C.F.R. Part 60 Appendices A, B, and F. Appendix F Section 5.1 states "Auditing Requirements. Each CEMS must be audited at least once each calendar quarter. Successive quarterly audits shall occur no closer than 2 months". Shell conducted CGAs at the RCCU 6/18/2020 and 8/12/2020. 2. We identified several quality assurance and control ("QA/QC") issues regarding CD reporting requirements. Shell submitted formal reports with inaccurate or conflicting information. We recommend that Shell update QA/QC procedures pertaining to report submissions. Shell conducted annual RATAs on the RCCU analyzers on January 30, 2020, but reported the audit performed as CGAs in the Second Half of 2020 Semi-Annual report. Shell reported CEMS data in quarterly reports for the incorrect and outdated CO analyzer on the RCCU. 3. The RCCU CO analyzer (serial number CO3003-M) was operating uncertified from September 29, 2022, through October 27, 2022. Paragraphs 19 and 52 require Shell to certify, calibrate, maintain, and operate FCCU NOx, SO2, and CO CEMS in accordance with the provisions of 40 7 EPA Inspection Report - Page 8 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 C.F.R. Part 60 Appendices A, B, and F. Shell installed a temporary CO analyzer September 29, 2022, but did not certify the analyzer until October 27, 2022. 4. Shell inaccurately categorizes CEMS downtime within semi-annual reports. CEMS downtime is inaccurately characterized pertaining to maintenance rather than QA/QC. Shell categorizes the uncertified RCCU CO analyzer (serial number CO3003-M) operation as downtime within semiannual reports during the period of September 29, 2022, through October 29, 2022. 5. The May 7, 2018, EPA-approved AMP requires Shell to monitor the L/G ratio across the WGS, and the venturi inlet differential pressure to the four venturis directly upstream. Permit 2602V12, special condition 59 does not include the requirements of 40 C.F.R. Part 60 Subpart J. Special condition 59 made a direct reference to the EPA-approved AMP for opacity dated November 5, 2015. The statement, "The following AMP, approved by EPA on November 5, 2015..." is no longer relevant as the most recent approval issued by EPA was on May 7, 2018. 6. LDAR monitored equipment and components have conflicting tags within the units. Old LDAR tags are not removed from equipment pieces and components subject to LDAR monitoring requirements. The blue circular LDAR tags are outdated and no longer monitored by Shell. 7. Components and equipment subject to LDAR monitoring requirements are included on DOR report when no longer considered in DOR status. The DOR report for LDAR Tag 0100561 identify the component as having four consecutive "passed" readings when monitored by LDAR technicians. The component is included in the DOR report although successfully meeting Shell's internal DOR removal process for components with four consecutive passed readings. 8. DOR and LDAR non-detect reports include conflicting and misleading information pertaining to dates and non-detection types. DOR reports include surpassed dates between the date a component was expected to be repaired and the date a DOR report is pulled for review. LDAR non-detect reports contain several classifications of non-detectable ("ND") components and equipment under the "Type" column which should be included in the "Class" column. We recommend that Shell updates their database to clarify all components and equipment under the report are included as ND under the "Type" column and the classifications are updated accordingly. 9. An expired H2S calibration gas cylinder (CC417779) was in use on the West Ops Ground Flare CEMS. The cylinder had an expiration date of August 9, 2023. Shell later clarified the gas cylinder was not expired and provided the certificate of analysis with an expiration date of August 9, 2025. The gas cylinder was mislabeled with inaccurate information and CEMS technicians did not observe this discrepancy. 10. Shell conducted successive quarterly audits within less than two months at the Hydrocracking Unit ("HCU") Flare CEMS. Paragraphs 145 of the CD require Shell to certify, calibrate, maintain, and operate CEMS in accordance with the provisions of 40 C.F.R. Part 60 Subpart J, and Appendices A, B, and F. Appendix F Section 5.1 states "Auditing Requirements. Each CEMS must be audited at least once each calendar quarter. Successive quarterly audits shall occur no closer than 2 months". Shell conducted CGAs at the HCU Flare on 9/30/2021 and 11/22/2021. 11. The CD requires Shell to comply with emission limits at several units. During the period of October 1, 2022, through September 30, 2023, Norco exceeded the H2S emission limit of 162 ppmv on a 3-hour rolling average at the HCU Flare, Coker Flare, RCCU Elevated Flare, and the West Ops Ground Flare. 12. Emissions observed from the RCCU Elevated Flare with the FLIR GF320. The flare pilot was ignited, and no visible emissions were observed. During the time of the observation, the RCCU was not operating. 13. Paragraph 137 of the CD requires Shell to re-route all sulfur pit emissions from the refinery, such that all sulfur pit emissions to the atmosphere are either eliminated, or included and monitored 8 EPA Inspection Report - Page 9 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 as part of the applicable SRP's emissions that meet the emissions limit of 250 ppmvd on a 12hour rolling average at 0% O2. Permit 2902-V5 includes the emission limits but does not reference the requirement of sulfur pit emissions to be routed to the incinerator outside of the inventory table. 14. The requirements of the CD should be specified to include the limits and regulations directly referenced. All permits using the terminology "in accordance with the Consent Decree" or "[Consent Decree]" should be revised to specifically incorporate the CD requirements and make direct reference to the regulatory requirements of 40 C.F.R. Part 60 and 40 C.F.R. Part 63. For example, permit 2602-V12, special conditions 98 through 103 refer to the CD requirements but do not specifically outline the requirements of 40 C.F.R. Part 60. 15. The permits for units demonstrating compliance with monitoring requirements through CEMS do not specify the requirements of 40 C.F.R. Part 60 Appendices A, B, and F. Special conditions referencing CEMS should be revised to include all monitoring requirements to fully comply with CD requirements. On October 27, 2023, we met with Shell representatives at 8:15 am for the closing conference and presented preliminary findings of the inspection and reviewed AOCs #s 2 - 9, and 12 - 15, which were noted during the onsite inspection. Prince informed the representatives of the procedures that will follow the field inspection including the inspection report that will be made public on EPA's website. AOC #s 1, 10, and 11 were determined after the conclusion of the onsite inspection and were not included in the closing conference. The attendance sheets for the opening and closing conferences are included as Appendix 3. Section IV - FOLLOW UP Additional information requested during the inspection was received on November 5, 2023. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 11 photos taken 10/23/23 - 10/27/23 Appendix 2 - Video Log - 1 FLIR video taken 10/26/23 Appendix 3 - Opening and closing conference sign-in sheets Appendix 4 - Plant-wide process flow diagram and written facility description Appendix 5 - FCCU NOx emission trends Appendix 6 - FCCU SO2 emission trends Appendix 7 - FCCU CO emission trends Appendix 8 - FCCU opacity AMP trends Appendix 9 - Excerpts of DOR and LDAR non-detect reports Appendix 10 - Description of flare gas recovery systems Appendix 11 - Flare H2S emission trends Appendix 12 - Excerpts of permits 9 EPA Inspection Report - Page 10 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 Appendix 1 Photograph Log EPA Inspection Report - Page 11 of 105 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Shell Oil Products US / Norco Refinery City: Norco Parish: St. Charles State: Louisiana Photo File Name: DSCN0855.JPG Date of Photo: 10/24/2023 Time of Photo: 9:26 am Photographer: Bailey Brown Description: Selective non-catalytic reduction (SNCR) system and ammonia vaporizer used for NOx emission reduction on the residual catalytic cracking unit (RCCU). EPA Inspection Report - Page 12 of 105 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Shell Oil Products US / Norco Refinery City: Norco Parish: St. Charles State: Louisiana Photo File Name: DSCN0857.JPG Date of Photo: 10/24/2023 Time of Photo: 9:57 am Photographer: Bailey Brown Description: Wet gas scrubber (WGS) used for SO2 emission reduction on RCCU. EPA Inspection Report - Page 13 of 105 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Shell Oil Products US / Norco Refinery City: Norco Parish: St. Charles State: Louisiana Photo File Name: DSCN0859.JPG Date of Photo: 10/27/2023 Time of Photo: 7:52 am Photographer: Prince Nfodzo Description: Left side storage shelving containing Leak Detection and Repair (LDAR) equipment beside automated calibration system. EPA Inspection Report - Page 14 of 105 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Shell Oil Products US / Norco Refinery City: Norco Parish: St. Charles State: Louisiana Photo File Name: DSCN0860.JPG Date of Photo: 10/27/2023 Time of Photo: 7:52 am Photographer: Prince Nfodzo Description: LDAR automated calibration system. EPA Inspection Report - Page 15 of 105 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Shell Oil Products US / Norco Refinery City: Norco Parish: St. Charles State: Louisiana Photo File Name: DSCN0861.JPG Date of Photo: 10/27/2023 Time of Photo: 7:52 am Photographer: Prince Nfodzo Description: Right side storage shelving containing LDAR equipment beside automated calibration system. EPA Inspection Report - Page 16 of 105 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Shell Oil Products US / Norco Refinery City: Norco Parish: St. Charles State: Louisiana Photo File Name: DSCN0862.JPG Date of Photo: 10/27/2023 Time of Photo: 7:52 am Photographer: Prince Nfodzo Description: Complete overview of LDAR automated calibration system and equipment storage. EPA Inspection Report - Page 17 of 105 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Shell Oil Products US / Norco Refinery City: Norco Parish: St. Charles State: Louisiana Photo File Name: DSCN0863.JPG Date of Photo: 10/27/2023 Time of Photo: 7:54 am Photographer: Prince Nfodzo Description: Calibration gas cylinders located outside of LDAR storage and automated calibration system. EPA Inspection Report - Page 18 of 105 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Shell Oil Products US / Norco Refinery City: Norco Parish: St. Charles State: Louisiana Photo File Name: DSCN0864.JPG Date of Photo: 10/27/2023 Time of Photo: 7:55 am Photographer: Prince Nfodzo Description: Calibration gas gauges located outside of LDAR storage and calibration system. EPA Inspection Report - Page 19 of 105 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Shell Oil Products US / Norco Refinery City: Norco Parish: St. Charles State: Louisiana Photo File Name: DSCN0856.JPG Date of Photo: 10/24/2023 Time of Photo: 9:49 am Photographer: Bailey Brown Description: Equipment #FV-4333 with silver and blue LDAR tags. EPA Inspection Report - Page 20 of 105 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Shell Oil Products US / Norco Refinery City: Norco Parish: St. Charles State: Louisiana Photo File Name: DSCN0858.JPG Date of Photo: 10/26/2023 Time of Photo: 8:33 am Photographer: Prince Nfodzo Description: Expired hydrogen sulfide calibration gas cylinder on the West Ops Ground Flare continuous emission monitoring system. EPA Inspection Report - Page 21 of 105 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Shell Oil Products US / Norco Refinery City: Norco Parish: St. Charles State: Louisiana Photo File Name: DC_0049.JPG Date of Photo: 10/26/2023 Time of Photo: 8:15 am Photographer: Bailey Brown Description: RCCU Elevated Flare with pilot flame lit. EPA Inspection Report - Page 22 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 Appendix 2 Video Log EPA Inspection Report - Page 23 of 105 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 2 Location: Shell Oil Products US / Shell Norco Refinery City: Norco Parish: St. Charles State: Louisiana Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_0048.mp4 10/26/2023 8:15 am Bailey Brown The Residual Catalytic Cracking Unit (RCCU) Elevated Flare observed with emissions. Page 1 of 1 EPA Inspection Report - Page 24 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 Appendix 3 Opening and closing conference sign-in sheets EPA Inspection Report - Page 25 of 105 EPA Inspection Report - Page 26 of 105 EPA Inspection Report - Page 27 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 Appendix 4 Plant-wide process flow diagram and written facility description EPA Inspection Report - Page 28 of 105 NORCO000268 EPA Inspection Report - Page 29 of 105 Brief Written Facility Description of the Motiva Norco Refinery: The Norco Refining Company is located next to the Mississippi River, about 20 miles west of New Orleans, Louisiana. Headquartered in Houston, Texas, we refine and market gasoline to about 14,000 Shell-branded gasoline stations together with our affiliate Shell Oil Products US. Company assets include three refineries, capable of refining approximately 690,000 barrels per day (bpd) and ownership or partial interest in 50 products terminals. The Motiva Norco refinery supplies gasoline and low sulfur diesel to the New Orleans markets. We also supply jet fuel to the New Orleans International Airport. In addition, our products leave by ship and pipeline to destinations all over the southeast United States and abroad. Listed below is a typical daily production schedule: 170,000 barrels per day of gasoline 46,000 barrels per day of jet fuel 50,000 barrels per day of low sulfur diesel fuel Adjoining sites: Shell Chemical (integrated into site) Principal activities: Conversion of approximately 240,000 barrels per day of crude oil, which is made up of approximately 75% of Louisiana sweet crudes and 25% of foreign crudes. The refinery also converts approximately 20,000 - 40,000 barrels per day of other feedstocks into gasoline, jet fuel, diesel and byproducts. We are considered a light, sweet (low sulfur) crude oil refinery. NORCO000237 EPA Inspection Report - Page 30 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 Appendix 5 FCCU NOx emission trends EPA Inspection Report - Page 31 of 105 NOx - ppm RCCU NOx 365-day Rolling Average (Limit = 150.8ppm) 160 140 120 100 80 60 40 20 0 365-day Rolling Average 365-day Rolling Average Limit NORCO000693 EPA Inspection Report - Page 32 of 105 Hourly Average - ppm 24-hour Rolling Average - ppm RCCU NOx 700 250 600 200 500 150 400 300 100 200 50 100 0 0 01-Oct-22 01-Nov-22 01-Dec-22 01-Jan-23 01-Feb-23 01-Mar-23 01-Apr-23 01-May-23 01-Jun-23 01-Jul-23 01-Aug-23 01-Sep-23 Hourly Average - ppm 24-hour Rolling Average - ppm 24-hour Rolling Average Limit - ppm NORCO000255 EPA Inspection Report - Page 33 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 Appendix 6 FCCU SO2 emission trends EPA Inspection Report - Page 34 of 105 RCCU SO2 365-day Rolling Average (Limit = 25ppm) 30 25 20 SO2 - ppm 15 10 5 0 365-day Rolling Average 365-day Rolling Average Limit NORCO000695 EPA Inspection Report - Page 35 of 105 RCCU SO2 7-day Rolling Average (Limit = 50ppm) 60 50 40 SO2 - ppm 30 20 10 0 7-day Rolling Average 7-day Rolling Average Limit NORCO000694 EPA Inspection Report - Page 36 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 Appendix 7 FCCU CO emission trends EPA Inspection Report - Page 37 of 105 RCCU CO Hourly Average (Limit = 500ppm) 600 500 400 CO - ppm 300 200 100 0 01-Oct-22 01-Nov-22 01-Dec-22 01-Jan-23 01-Feb-23 01-Mar-23 Hourly Average - ppm 01-Apr-23 01-May-23 01-Jun-23 Hourly Average Limit - ppm 01-Jul-23 01-Aug-23 01-Sep-23 NORCO000692 EPA Inspection Report - Page 38 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 Appendix 8 FCCU opacity AMP trends EPA Inspection Report - Page 39 of 105 RCCU AMP FGS Liquid/Gas Ratio (13.86 minimum) 100 50 0 L/G Ratio -50 -100 -150 -200 01-Oct-22 01-Nov-22 01-Dec-22 01-Jan-23 01-Feb-23 01-Mar-23 01-Apr-23 01-May-23 FGS L/G Ratio FGS L/G Ratio 01-Jun-23 01-Jul-23 01-Aug-23 01-Sep-23 01-Oct-23 NORCO000689 EPA Inspection Report - Page 40 of 105 Presure - in H2O RCCU AMP FGS Inlet Pressure (25.80"H2O minimum) 50 45 40 35 30 25 20 15 10 5 0 01-Oct-22 01-Nov-22 01-Dec-22 01-Jan-23 01-Feb-23 01-Mar-23 Inlet Pressure 01-Apr-23 01-May-23 Inlet Pressure Limit 01-Jun-23 01-Jul-23 01-Aug-23 01-Sep-23 01-Oct-23 NORCO000690 EPA Inspection Report - Page 41 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 Appendix 9 Excerpts of DOR and LDAR non-detect reports EPA Inspection Report - Page 42 of 105 Repair Delay - Current List (R323_1) Report Parameters Unit: All Units Report Date: 10/23/2023 UNIT: ALKY Tag#: Drawing 0104493.02 Class CONECT E-01A-0248 Location Last Date AREA: LPG TREATERS Last Ref. PPM No. Reason For Delay Approved By Date Expected Delayed Repair Delayed for Unrepairable Shutdown T/2 PV-232 NSD PRV- 10/17/2023 47 Repair is technically infeasible Jeff Gribnau 2/4/2023 9/29/2023 Yes 332 ESD BLK WSD FLG without a process unit shutdown. Repair of this equipment shall occ This report produced by SkyBridge LDAR Page 8 of 51 NORCO002672 EPA Inspection Report - Page 43 of 105 Repair Delay - Current List (R323_1) Report Parameters Unit: All Units Report Date: 10/23/2023 UNIT: COKER Tag#: Drawing 1700135 Class VALVE E-05A-0105 Location Last Date AREA: SOUTH Last Ref. PPM No. Reason For Delay Approved By Date Expected Delayed Repair Delayed for Unrepairable Shutdown G/5 PV-904 15FT NE P- 8/15/2023 619 Repair is technically infeasible Joel Ortiz for 1/27/2021 2/28/2023 Yes 3135A SE INLET S BV without a process unit shutdown. Jeffrey Gribnau Repair of this equipment shall occ This report produced by SkyBridge LDAR Page 10 of 51 NORCO002674 EPA Inspection Report - Page 44 of 105 Repair Delay - Current List (R323_1) Report Parameters Unit: All Units Report Date: 10/23/2023 UNIT: CR2 Tag#: Drawing 0702683 Class VALVE E-07A-0216 16-18277 VALVE Location Last Date AREA: CR2 REACTORS Last Ref. PPM No. Reason For Delay Approved By Date Expected Delayed Repair Delayed for Unrepairable Shutdown 1P1/0 PV-953 NWSD 9/11/2023 1 Repair is technically infeasible Kimberly Goff 10/11/2022 3/31/2024 Yes CV MOV-9532 [A2] without a process unit shutdown. Repair of this equipment shall occ 6FT SE MOV MOV-E1 9/11/2023 2 Repair is technically infeasible Jeffrey Gribnau 12/16/2020 1/31/2023 Yes without a process unit shutdown. Repair of this equipment shall occ This report produced by SkyBridge LDAR Page 13 of 51 NORCO002677 EPA Inspection Report - Page 45 of 105 Repair Delay - Current List (R323_1) Report Parameters Unit: All Units Report Date: 10/23/2023 UNIT: NHT Tag#: Drawing 06N00046 Class PUMP E-06A-0206 06N00332 COMPR E-06A-0235 Location Last Date AREA: NHT - A Last Ref. PPM No. Reason For Delay Approved By Date Expected Delayed Repair Delayed for Unrepairable Shutdown G/0 PV-602 S 5FT P3158 8/14/2023 Equipment is isolated from the process and does not remain in VOC service. Kimberly Goff 8/29/2023 10/31/2023 G/0 PV-602 S 40FT K- 8/14/2023 2 Repair is technically infeasible Kimberly Goff 6/28/2022 3/31/2023 Yes 1539 without a process unit shutdown. Repair of this equipment shall occ This report produced by SkyBridge LDAR Page 31 of 51 NORCO002695 EPA Inspection Report - Page 46 of 105 Repair Delay - Current List (R323_1) Report Parameters Unit: All Units Report Date: 10/23/2023 UNIT: PA REFINERY Tag#: Drawing RM117521 Class CONECT Location NSD TK F-457 MANWAY Last Date AREA: GASZONE Last Ref. PPM No. Reason For Delay Approved By Date Expected Delayed Repair Delayed for Unrepairable Shutdown 8/23/2022 243 Repair is technically infeasible Olisa Ojeh 8/18/2015 1/21/2024 Yes without a process unit shutdown. Repair of this equipment shall occ RM55798.2 CONECT SLPR SW TK F-443 6/1/2022 6503 Repair is technically infeasible Eric Billingsley 6/1/2022 6/30/2023 Yes NSD MARK 44 without a process unit shutdown. Repair of this equipment shall occ This report produced by SkyBridge LDAR Page 36 of 51 NORCO002700 EPA Inspection Report - Page 47 of 105 Component Tag Area 0601491 FVR - D 0601492 FVR - D 0601493 FVR - D 0601494 FVR - D 0601501 FVR - D 0600971 FVR - C 0600972 FVR - C 0600973 FVR - C 0601502 FVR - D 0600974 FVR - C 0600975 FVR - C 0600976 FVR - C 0601503 FVR - D 0600977 FVR - C 0600978 FVR - C 0601504 FVR - D 0601505 FVR - D 0601392 FVR - C 0600984 FVR - C 0600985 FVR - C 0600986 FVR - C 0600987 FVR - C 0600988 FVR - C 0601402 FVR - C 0601506 FVR - D 0601507 FVR - D 0601508 FVR - D 0601509 FVR - D 0601510 FVR - D 0601511 FVR - D 0601512 FVR - D 0601513 FVR - D 0601011 FVR - C 0601514 FVR - D 0601515 FVR - D 0601516 FVR - D 0601517 FVR - D 0601518 FVR - D 0601519 FVR - D 0601520 FVR - D 0601521 FVR - D 0601550 FVR - D 0601551 FVR - D 0601559 FVR - D 0601560 FVR - D 0601666 FVR - D 0601667 FVR - D Process Unit HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU Class VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE PUMP VALVE VALVE VALVE VALVE VALVE PUMP VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE Type NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV ND NDVLV NDVLV NDVLV NDVLV NDVLV ND NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NEA NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV Category N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N Location G/1 PV 9227 N 30FT AH-021 SS G/1 PV 9227 N 30FT AH-021 SS G/1 PV 9227 N 30FT AH-021 SS G/1 PV 9227 N 30FT AH-021 SS G/3 PV 9227 N 30FT AH-021 SS PANEL 1/4 PV-9208 PFRM 8FT S BLEED S TX-PT2200C 1/4 PV-9208 PFRM 8FT S BLEED TOP TX-PT2200C 1/4 PV-9208 PFRM 8FT S BLEED S TX-PT2200B G/3 PV 9227 N 30FT AH-021 SS PANEL 1/4 PV-9208 PFRM 8FT S BLEED TOP TX-PT2200B 1/4 PV-9208 PFRM 8FT S BLEED S TX-PT2200A 1/4 PV-9208 PFRM 8FT S BLEED TOP TX-PT2200A G/3 PV 9227 N 30FT AH-021 SS PANEL 1/4 PV-9208 PFRM 8FT S BLEED S TX-PT2017 1/4 PV-9208 PFRM 8FT S BLEED TOP TX-PT2017 G/6 PV 9227 N 30FT AH-021 SS PANEL G/6 PV 9227 N 30FT AH-021 SS PANEL G/0 P-9229 SSD PV-9205A G/16 PV-9214 SWSD BLEED W TX-PT2058 G/16 PV-9214 SWSD BLEED W TX-PT2058 G/16 PV-9214 SWSD BLEED TOP TX-PT2058 G/16 PV-9214 SWSD BLEED E TX-PT2058 G/16 PV-9214 SWSD BLEED E TX-PT2058 G/0 P-9231 SSD PV-9205A G/6 PV 9227 N 30FT AH-021 SS PANEL G/6 PV 9227 N 30FT AH-021 SS PANEL G/6 PV 9227 N 30FT AH-021 SS PANEL G/6 PV 9227 N 30FT AH-021 SS PANEL G/6 PV 9227 N 30FT AH-021 SS PANEL G/4 PV 9227 30FT N. AH-021 SS PANEL G/4 PV 9227 30FT N. AH-021 SS PANEL G/4 PV 9227 30FT N. AH-021 SS PANEL G/2 PV-9214 15FT SESD CHK 5FT SE E-9242 G/4 PV 9227 30FT N. AH-021 SS PANEL G/4 PV 9227 30FT N. AH-021 SS PANEL G/4 PV 9227 30FT N. AH-021 SS PANEL G/4 PV 9227 30FT N. AH-021 SS PANEL G/4 PV 9227 30FT N. AH-021 SS PANEL G/4 PV 9227 30FT N. AH-021 SS PANEL G/4 PV 9227 30FT N. AH-021 SS PANEL AE-0112B G/4 PV 9227 30FT N. AH-021 SS PANEL AE-0112C G/10 PV 9232 12FT W PV 9227 15FT SW TX PT-0028 E VLV G/10 PV 9232 12FT W PV 9227 15FT SW TX PT-0028 TOP VLV G/5 PV 9232 12FT W BLD VLV PV 9227 12FT W. TX PT-0069 W G/5 PV 9232 12FT W BLD VLV PV 9227 12FT W. TX PT-0069 TO 1/3 STRUCT PV-9215 SESD BLD E TX-PT2070 1/3 STRUCT PV-9215 SESD BLD TOP TX-PT2070 Size Of State 0.25 GV 0.25 LL 0.25 GV 0.25 LL 0.25 GV 0.5 GV 0.5 GV 0.5 GV 0.25 GV 0.5 GV 0.5 GV 0.5 GV 0.25 GV 0.5 GV 0.5 GV 0.25 GV 0.25 GV 0 LL 0.5 GV 0.5 GV 0.5 GV 0.5 GV 0.5 GV 0 LL 0.25 GV 0.25 GV 0.25 GV 0.25 GV 0.25 GV 0.25 GV 0.25 GV 0.25 GV 6 GV 0.25 GV 0.25 GV 0.25 GV 0.25 GV 0.25 GV 0.25 GV 0.25 GV 0.25 GV 0.5 GV 0.5 GV 0.5 GV 0.5 GV 0.5 GV 0.5 GV NORCO002918 EPA Inspection Report - Page 48 of 105 Component Tag 0601668 0601669 0601916 0601917 0601918 0601919 0601690 0601691 0601692 0601926 0601927 0602135 0602136 0602137 0602138 0602139 0602145 0602146 0602147 0602148 0602152 0602153 0602149 0602154 0602156 0602627 0602628 0601093 0602172 0602173 RM132508 RM132549 RM132528 RM126784 RM132834 RM132838 RM132844 RM132839 RM132610 H25508 17-6027 17-4876 17-4899 40-9036 172206 40-9365 17-1759 Area FVR - D FVR - D FVR - D FVR - D FVR - D FVR - D FVR - D FVR - D FVR - D FVR - D FVR - D FVR - C FVR - C FVR - C FVR - C FVR - C FVR - C FVR - C FVR - C FVR - C FVR - C FVR - C FVR - C FVR - C FVR - C FLARE FLARE FVR - C FVR - C FVR - C BD/BPS STORAGE BD/BPS STORAGE BD/BPS STORAGE BD/BPS STORAGE BD/BPS STORAGE BD/BPS STORAGE BD/BPS STORAGE BD/BPS STORAGE NORTHEAST EX PROBE SOUTH PROPERTY EAST NHT - D NHT - D NHT - D MIDZONE SOUTH MIDZONE SOUTH Process Unit HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU HCU PA SHELL PA SHELL PA SHELL PA SHELL PA SHELL PA SHELL PA SHELL PA SHELL DU5 PA SHELL NHT NHT NHT PA REFINERY COKER PA REFINERY COKER Class VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE Type NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NEA NDVLV NDVLV NDVLV NEA NDVLV NEA ND Category N N N N N N N N N N N D D D D D N N N N N N N N N D D N N N N N N N N N N N N N N N N N N N N Location 1/4 STRUCT PV-9215 SSD BLD E TX-PT1070B 1/4 STRUCT PV-9215 SSD BLD TOP TX-PT1070B T/4 PV-9227 SE BLEED S TX-PT2074A T/4 PV-9227 SE BLEED TOP TX-PT2074A T/4 PV-9227 E BLEED S TX-PT1074A T/4 PV-9227 E BLEED TOP TX-PT1074A 1/4 STRUCT PV-9232 NSD BLD W TX-PT1074B 1/4 STRUCT PV-9232 NSD BLD TOP TX-PT2074B 1/4 STRUCT PV-9232 BLD W TX-PT2074B T/4 PV-9232 NE NDVLV N BLW TX-PT0070 T/4 PV-9232 NE NDVLV S BLW TX-PT0070 PR3/0 K-9210 NSD PV-9210C 8FT W PDT-2028 NV W PR3/0 K-9210 NSD PV-9210C 8FT W PDT-2028 NV NW PR3/0 K-9210 NSD PV-9210C 8FT W PDT-2028 NV TOP PR3/0 K-9210 NSD PV-9210C 8FT W PDT-2028 NV NE PR3/0 K-9210 NSD PV-9210C 8FT W PDT-2028 NV E PR3/0 K-9205 SSD PV-9205A 5FT W PDT-1018 NV E PR3/0 K-9205 SSD PV-9205A 5FT W PDT-1018 NV NE PR3/0 K-9205 SSD PV-9205A 5FT W PDT-1018 NV TOP PR3/0 K-9205 SSD PV-9205A 5FT W PDT-1018 NW NV PR3/0 K-9205 NSD PV-9205C 9FT W PDT-1028 NV E PR3/0 K-9205 NSD PV-9205C 9FT W PDT-1028 NV NE PR3/0 K-9205 SSD PV-9205A 5FT W PDT-1018 NV W PR3/0 K-9205 NSD PV-9205C 9FT W PDT-1028 NV TOP PR3/0 K-9205 NSD PV-9205C 9FT W PDT-1028 NV W G/22 PV 3233 E 25FT TX FT-7344 LDAR RK 4 PS20 N 4FT TOP VL G/22 PV 3233 E 25FT TX FT-7344 LDAR RK 4 PS20 N 4FT N VLV 1/8 PV-9210E SESD BLD N TX-PDT2085 G/25 PV-206 8FT N NV G/25 PV-206 8FT N NV TOP 0/1 PV-495 E SLPR2 MARK 3 ESD NV S 0/1 PV-495 E SLPR2 MARK 3 ESD NV 0/1 PV-495 E SLPR2 MARK 3 ESD NV N 0/1 PV-495 E SLPHR2 MARK 3 ESD NV E 0/1 PV-495 E SLPHR2 MARK 3 ESD NV BTM 0/1 PV-495 E SLPHR2 MARK 3 ESD NV W 0/3 PV-495 E SLPHR2 MARK 2 WSD NV N 0/3 PV-495 E SLPHR2 MARK 2 WSD NV S 7/4 PV-752 E TX PDT-2435 WSD NV S G/3 TK F-434 SWSD CHK T/4 PV-630 WSD TX LT-1211 SESD NV BTM T/4 PV-630 WSD TX LT-1211 SESD NV MID T/4 PV-630 WSD TX LT-1211 SESD NV TOP G/2 TK F-479 NWSD CHK T/1 PV-2915 8FT E PT-2673 N NDL G/1 RK1 ESD PS111 SSD CHK (9TH ST SLPR) 12FT N E-1155 P-3165A DIS CHK Size Of State 0.5 GV 0.5 GV 0.5 GV 0.5 GV 0.5 GV 0.5 GV 0.5 GV 0.5 GV 0.5 GV 0.5 GV 0.5 GV 0.25 GV 0.25 GV 0.25 GV 0.25 GV 0.25 GV 0.5 GV 0.5 GV 0.5 GV 0.5 GV 0.25 GV 0.25 GV 0.5 GV 0.25 GV 0.25 GV 0.5 GV 0.5 GV 0.5 GV 0.25 GV 0.25 GV 0.5 LL 0.5 LL 0.5 LL 0.5 LL 0.5 LL 0.5 LL 0.5 LL 0.5 LL 0.5 HL 2 HL 0.25 HL 0.25 HL 0.5 HL 6 LL 0.5 GV 6 LL 3 LL NORCO002919 EPA Inspection Report - Page 49 of 105 Component Tag 40-9906 40-9907 42-11342 RM132749 RM200301 40-9880 41-3380 41-3382 1606114 0101236 0101237 0101238 RM200000 06N02736 42-6152 H19776 H19783 H21217 H21225 H21248 H21249 H21266 H21720 H22003 H22006 H22014 H22628 4000661 4000740 RM200186 RM200185 RM200183 5304235 5304236 5304237 0103612 0103949 0102536 1602573 1605797 0701907 0702579 3901375 3900267 1000607 1000576 41-10467 Area BD/BPS STORAGE BD/BPS STORAGE NORTH PROPERTY SOUTH PROPERTY MVR BD/BPS STORAGE GASZONE BD/BPS STORAGE BD/BPS STORAGE 2ND STAGE MID EAST DEPROPANIZERS DEPROPANIZERS DEPROPANIZERS NORTH PROPERTY NHT - D NORTH PROPERTY SOUTH PROPERTY EAST SOUTH PROPERTY EAST DOCKS BERTH-1 DOCKS BERTH-1 DOCKS BERTH-1 DOCKS BERTH-1 DOCKS BERTH-1 DOCKS BERTH-1 DOCKS BERTH-1 DOCKS BERTH-1 DOCKS BERTH-1 DOCKS BERTH-1 GASZONE NEW BLENDER GASZONE NEW BLENDER NORTH PROPERTY NORTH PROPERTY NORTH PROPERTY R&R WEST R&R WEST R&R WEST K-1696 COMP K-1100 COMP K-2960 COMP 1ST STAGE NORTHWEST 1ST STAGE NORTHWEST CR2 COMPRESSORS CR2 COMPRESSORS COMPRESSOR COMPRESSOR SOUTHWEST SOUTHWEST SOUTH PROPERTY EAST Process Unit PA SHELL PA SHELL PA REFINERY PA REFINERY PA SHELL PA REFINERY PA SHELL PA SHELL HCU ALKY ALKY ALKY PA REFINERY NHT PA REFINERY PA REFINERY PA REFINERY PA REFINERY PA REFINERY PA REFINERY PA REFINERY PA REFINERY PA REFINERY PA REFINERY PA REFINERY PA REFINERY PA REFINERY PA REFINERY PA REFINERY PA SHELL PA SHELL PA SHELL RCCU RCCU RCCU ALKY ALKY ALKY HCU HCU CR2 CR2 DHT DHT DU5 DU5 PA REFINERY Class VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE VALVE COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR Type NDVLV NDVLV ND NDVLV NEA ND NEA NEA NDVLV NDVLV NDVLV NDVLV NEA NDVLV NEA NEA NEA ND ND ND ND ND ND ND ND ND NEA NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV NDVLV SSVC SSVC SSVC SSVC SSVC SSVC SSVC SSVC SSVC SSVC SSVC SSVC Category N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N Location G/6 P-5652 5FT NE @ S.P. NSD W BLK G/6 P-5652 5FT NE @ S.P. NSD E BLK G/5 SW TK F-516 SESD P-4570 CHK AH E-145 AT5736 MVR AREA NE PV-495 45FT N P-2548 NESD SKID NSD RVO-1729 CHK G/2 TK F-477 WSD MOV HV-1010 NWSD BLK G/2 PV-495 E P-5652 W 5FT CHK NSD BLD G/2 PV-495 E P-5652 NW 5FT BLD G/4 PV-822 NE 4FT A-3408 [ON PANEL] BV G/3 E-626 NSD CV FCV-128 NESD FT-128 WSD NV N G/3 E-626 NSD CV FCV-128 NESD FT-128 WSD NV TOP G/3 E-626 NSD CV FCV-128 NESD FT-128 WSD NV S NSD TK F-484 CHK T/2 PV-608 NSD PT-5018 ESD NV G/3 TK F-466 N 3FT WATER DRAW LN CHK W TK F-490 WSD P-2807 CHK W TK F-490 WSD P-2808 CHK DOC1A NSD CATWALK ESD VLV BROWN CHK DOC1A NSD CATWALK ESD VLV A-6455B CHK DOC1A NWSD CATWALK WSD VLV A-6454B CHK DOC1A SWSD CATWALK WSD VLV A-6454A CHK DOC1A SSD CATWALK ESD VLV A-6455A CHK DOC1 SSD CATWALK ESD VLV 6566A CHK DOC1 SSD CATWALK ESD VLV 6562B CHK DOC1 SSD CATWALK ESD VLV 6562A CHK DOC1 NSD CATWALK ESD VLV 6562D CHK DOC1 SSD CATWALK ESD HGO VLV CHK G/5 NEW BLNDR SSD HDR14 G/3 NSD PROVER G/1 TK F-499 SW P-5610 SW 12FT TX FT-5257 WSD NV S G/1 TK F-499 SW P-5610 SW 12FT TX FT-5257 WSD NV MID G/1 TK F-499 SW P-5610 SW 12FT TX FT-5257 WSD NV N 14P1/4 [RR STRUCT] SESD SE-7000 SE 4FT PDT-1232 NSD NV W 14P1/4 [RR STRUCT] SESD SE-7000 SE 4FT PDT-1232 NSD NV TO 14P1/4 [RR STRUCT] SESD SE-7000 SE 4FT PDT-1232 NSD NV E 1/0 PV-410 S 10FT K-1696 T/0 E-651 NW 8FT K-1100 G/0 FF E-2903C SE 12FT K-2960 1/3 K-1928 COMP SEAL 1/0 C X-1929 1/0 K-2056 1/0 K-2057 1/0 PV-2028 SW 15FT K-5339 1/0 PV-1978 N 20FT K-5337 G/0 K-1883 G/0 E-1494 NE 15FT K-1879 TOP PV-2981 COMP K-4582 Size Of State 0.5 LL 0.5 LL 3 LL 0.25 GV 6 LL 2 LL 0.75 LL 0.75 LL 0.5 LL 0.5 LL 0.5 LL 0.5 LL 3 LL 0.5 GV 4 LL 6 LL 6 LL 0.5 LL 0.5 LL 0.5 LL 0.75 LL 0.5 LL 0.5 LL 0.5 LL 0.5 LL 0.5 LL 0.5 LL 0.5 LL 0.5 LL 0.5 LL 0.5 LL 0.5 LL 0.25 GV 0.25 GV 0.25 GV 0 GV 0 GV 0 GV 0 GV 10 GV 8 GV 0 GV 0 GV 0 GV 0.25 GV 0 GV 0 GV NORCO002920 EPA Inspection Report - Page 50 of 105 Component Tag 5308794 5701739 1607113 1601369 1700222 5305590 5305591 5305632 06N00332 06N00358 RM64447 RM64457 RM64823 RM67945 06N00421 1602771 0601156 0601285 1606067 1606066 Area GAS PLANT EAST EASTSIDE 2ND STAGE NORTHEAST 1ST STAGE SOUTHEAST SOUTH FLARE FLARE FLARE NHT - A NHT - A SOUTH PROPERTY MVR SOUTH PROPERTY MVR SOUTH PROPERTY MVR SOUTH PROPERTY MVR NHT - A 2ND STAGE EAST FVR - C FVR - C 1ST STAGE NORTHEAST 1ST STAGE NORTHEAST Process Unit RCCU LSG HCU HCU COKER RCCU RCCU RCCU NHT NHT PA REFINERY PA REFINERY PA REFINERY PA REFINERY NHT HCU HCU HCU HCU HCU Class COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR COMPR Type SSVC SSVC SSVC SSVC SSVC SSVC SSVC SSVC SSVC SSVC ND ND ND ND SSVC SSVC SSVC SSVC SSVC SSVC Category N N N N N N N N N N N N N N N N N N N N Location 1P1/0 PV-7108 S 20FT K-7130 1/0 K-8100 G/7 PV-859 W 6FT K-1968 G/5 PV-810 NE 15FT K-2515 1/4 K-2178 G/3 PV-7052 W 20FT K-7072 G/1 PV-7052 W 20FT K-7071 G/0 PV-7052 SW 20FT K-7070 G/0 PV-602 S 40FT K-1539 G/0 K-1536 NSD C K-6321 I/B-O/B C K-6320 I\B-O/B C K-6322 I/B-O/B C K-6323 I/B-O/B G/0 PV-886 N 15FT K-1537 G/4 PV-946 S 10FT K-1931 1/0 K-9210 NESD PV-9210E 1/0 K-9205 NESD PV-9205E 1/0 PV-801 E 12FT K-1927 1/5 PV-803 E 12FT K-1926 Size Of State 1 GV 0 GV 0 GV 4 GV 10 GV 0.75 GV 0 GV 14 GV 0 GV 0.25 GV 0 GV 0 GV 0 GV 0 GV 0 GV 8 GV 0 GV 0 GV 2 GV 2 GV NORCO002921 EPA Inspection Report - Page 51 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 Appendix 10 Description of flare gas recovery systems EPA Inspection Report - Page 52 of 105 Shell Norco Refinery - Flare Gas Recovery Systems The Shell Norco Refinery owns and operates two flare recovery systems: 1) West Ops Flare Gas Recovery 2) Flare Vapor Recovery. West Ops Flare Gas Recovery The West Ops (WO) System receives waste gas from the refinery and the Shell Chemical manufacturing units. The refinery vents include gases from Alky and Logistics (spheres/storage, tank car/truck loading), and the chemical vents include gases from two Shell Chemical ethylene manufacturing units. The WO system includes the following equipment: 1) Flare gas recovery (FGR) compressors 2) West Ops Ground Flare (WOGF) 3) West Ops Elevated Flare (WOEF) - Owned/Operated by Shell Chemical 4) GO-1 Elevated Flare (GO-1 EF) - Owned/Operated by Shell Chemical The FGR system consists of three compressors, associated piping, knock-out drums, and seal pots. The FGR compressors are sized to recover 3.6 MMSCFD of vent gas. Typically, all normally produced waste gas is recovered by the FGR and routed to the site's fuel gas system. If the FGR compressors are at capacity, vent gas will be preferentially routed to the WOGF for flaring. During larger flaring or other atypical scenarios, vent gas may be routed to the secondary flaring devices, either the WOEF or GO-1 EF. NORCO002649 EPA Inspection Report - Page 53 of 105 Flare Vapor Recovery System The Flare Vapor Recovery (FVR) System collects vapors from both the Coker and HCU Flare systems, compress the vapors, remove excess sulfur bearing compounds, and routes the recovered vapor to the site fuel gas system for reuse. The Coker Flare system includes waste gases from the following areas: Coker, S2, DHT, SWS, GHT, and NHT. The HCU Flare header includes waste gases from the following areas: HCU, CR2, and FGT. The recovered flare vapor is processed in a dedicated fixed catalyst bed hydrotreater to convert organic sulfur species such as mercaptan to non-sulfur bearing hydrocarbon and H2S. The vapor then contacts lean amine in an H2S absorber to remove the H2S. The vapor then passes through a fixed adsorbent bed to remove residual sulfur bearing compounds prior to being blended into the existing site fuel gas system. Parallel compressor and hydotreater trains were designed to handle 6 MMSCFD each. The system may operate in either single train (6 MMSCFD) or dual train (12 MMSCFD) modes. Each piece of major equipment throughout the system is designed to handle 6 MMSCFD. The exception is in the Steam Out Cooler which is designed to handle 50,000 lb/hr steam plus 6 MMSCFD Flare vapor that is saturated with water. NORCO002650 EPA Inspection Report - Page 54 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 Appendix 11 Flare H2S emission trends EPA Inspection Report - Page 55 of 105 HCU Flare H2S 3-hour Rolling Average (Limit = 162ppm) 25000 20000 15000 H2S - ppm 10000 5000 0 01-Oct-22 01-Nov-22 01-Dec-22 01-Jan-23 01-Feb-23 01-Mar-23 3-hour Rolling Average 01-Apr-23 01-May-23 01-Jun-23 3-hour Rolling Average Limit 01-Jul-23 01-Aug-23 01-Sep-23 NORCO002655 EPA Inspection Report - Page 56 of 105 H2S - ppm HCU Flare H2S 3-hour Rolling Average (Limit = 162ppm) 1000 900 800 700 600 500 400 300 200 100 0 01-Oct-22 01-Nov-22 01-Dec-22 01-Jan-23 01-Feb-23 01-Mar-23 3-hour Rolling Average 01-Apr-23 01-May-23 01-Jun-23 3-hour Rolling Average Limit 01-Jul-23 01-Aug-23 01-Sep-23 NORCO002656 EPA Inspection Report - Page 57 of 105 Coker Flare H2S 3-hour Rolling Average (Limit = 162ppm) 120000 100000 80000 H2S - ppm 60000 40000 20000 0 01-Oct-22 01-Nov-22 01-Dec-22 01-Jan-23 01-Feb-23 01-Mar-23 3-hour Rolling Average 01-Apr-23 01-May-23 01-Jun-23 3-hour Rolling Average Limit 01-Jul-23 01-Aug-23 01-Sep-23 NORCO002657 EPA Inspection Report - Page 58 of 105 H2S - ppm Coker Flare H2S 3-hour Rolling Average (Limit = 162ppm) 2000 1800 1600 1400 1200 1000 800 600 400 200 0 01-Oct-22 01-Nov-22 01-Dec-22 01-Jan-23 01-Feb-23 01-Mar-23 3-hour Rolling Average 01-Apr-23 01-May-23 01-Jun-23 3-hour Rolling Average Limit 01-Jul-23 01-Aug-23 01-Sep-23 NORCO002658 EPA Inspection Report - Page 59 of 105 RCCU Flare H2S 3-hour Rolling Average (Limit = 162ppm) 600 500 400 H2S - ppm 300 200 100 0 01-Oct-22 01-Nov-22 01-Dec-22 01-Jan-23 01-Feb-23 01-Mar-23 3-hour Rolling Average 01-Apr-23 01-May-23 01-Jun-23 3-hour Rolling Average Limit 01-Jul-23 01-Aug-23 01-Sep-23 NORCO002659 EPA Inspection Report - Page 60 of 105 WOGF Flare H2S 3-hour Rolling Average (Limit = 162ppm) 600 500 400 H2S - ppm 300 200 100 0 01-Oct-22 01-Nov-22 01-Dec-22 01-Jan-23 01-Feb-23 01-Mar-23 3-hour Rolling Average 01-Apr-23 01-May-23 01-Jun-23 3-hour Rolling Average Limit 01-Jul-23 01-Aug-23 01-Sep-23 NORCO002660 EPA Inspection Report - Page 61 of 105 Shell Oil Products US / Norco Refinery Inspection Date: 10/23/2023 - 10/27/2023 Appendix 12 Excerpts of permits EPA Inspection Report - Page 62 of 105 NORCO000248 EPA Inspection Report - Page 63 of 105 NORCO000249 EPA Inspection Report - Page 64 of 105 NORCO000250 EPA Inspection Report - Page 65 of 105 NORCO000251 EPA Inspection Report - Page 66 of 105 NORCO000252 EPA Inspection Report - Page 67 of 105 NORCO000253 EPA Inspection Report - Page 68 of 105 NORCO002752 EPA Inspection Report - Page 69 of 105 NORCO002753 EPA Inspection Report - Page 70 of 105 NORCO002754 EPA Inspection Report - Page 71 of 105 LDEQ-EDMS Document 12978383, Page 2 of 67 NORCO002922 EPA Inspection Report - Page 72 of 105 NORCO002923 LDEQ-EDMS Document 12978383, Page 10 of 67 EPA Inspection Report - Page 73 of 105 NORCO002924 LDEQ-EDMS Document 12978383, Page 11 of 67 EPA Inspection Report - Page 74 of 105 NORCO002925 LDEQ-EDMS Document 12978383, Page 13 of 67 EPA Inspection Report - Page 75 of 105 NORCO002926 LDEQ-EDMS Document 12978383, Page 14 of 67 EPA Inspection Report - Page 76 of 105 NORCO002927 LDEQ-EDMS Document 12978383, Page 16 of 67 EPA Inspection Report - Page 77 of 105 NORCO002928 LDEQ-EDMS Document 12978383, Page 24 of 67 EPA Inspection Report - Page 78 of 105 NORCO002929 LDEQ-EDMS Document 12978383, Page 25 of 67 EPA Inspection Report - Page 79 of 105 NORCO002930 LDEQ-EDMS Document 12978383, Page 34 of 67 EPA Inspection Report - Page 80 of 105 NORCO002931 LDEQ-EDMS Document 12978383, Page 35 of 67 EPA Inspection Report - Page 81 of 105 NORCO002932 LDEQ-EDMS Document 12978383, Page 36 of 67 EPA Inspection Report - Page 82 of 105 NORCO002933 LDEQ-EDMS Document 12978383, Page 37 of 67 EPA Inspection Report - Page 83 of 105 NORCO002934 LDEQ-EDMS Document 12978383, Page 38 of 67 EPA Inspection Report - Page 84 of 105 NORCO002935 LDEQ-EDMS Document 12978383, Page 39 of 67 EPA Inspection Report - Page 85 of 105 NORCO002936 LDEQ-EDMS Document 12978383, Page 40 of 67 EPA Inspection Report - Page 86 of 105 NORCO000285 EPA Inspection Report - Page 87 of 105 NORCO000286 EPA Inspection Report - Page 88 of 105 NORCO000239 EPA Inspection Report - Page 89 of 105 NORCO000240 EPA Inspection Report - Page 90 of 105 NORCO000241 EPA Inspection Report - Page 91 of 105 NORCO000242 EPA Inspection Report - Page 92 of 105 NORCO000243 EPA Inspection Report - Page 93 of 105 NORCO000244 EPA Inspection Report - Page 94 of 105 JOHN B EL EDWARDS GO VERNOR ~tate of JLoutgtana DEPARTMENT OF ENVIRONMENTAL QUALITY ENVIRONMENTAL SERVICES ROGER w. GINGLES SECRETARY Certified Mail No. 9589 0710 5270 0644 2644 07 Mr. Jack Holden Production Manager - Norco Manufacturing Complex Equilon Enterprises LLC d/b/a Shell Oil Products US P.O. Box 10 Norco, LA 70079 Activity No. : PER20220012 Agency Interest No. 1406 RE: Part 70 Operating Permit Renewal with Minor Modification Equilon Enterprises LLC - Norco Refinery, Alkylation Unit Norco, St. Charles Parish, Louisiana Dear Mr. Holden: This is to inform you that the permit renewal with mi.nor modification for the above referenced facility has been approved under LAC 33:III.501. The permit is both a state preconstruction and Part 70 Operating Permit. The submittal was approved on the basis of the emissions reported and the approval in no way guarantees the design scheme presented will be capable of controlling the emissions as to the types and quantities stated. A new application must be submitted if the reported emissions are exceeded after operations begin. The synopsis, data sheets and conditions are attached herewith. It will be considered a violation of the permit if all proposed control measures and/or equipment are not installed and properly operated and maintained as specified in the application. Operation of this facility is herebit{:orized under the terms and conditions of this permit. This authorization shall expire at midnight on the of o~~~ , 2028, unless a timely and complete renewal application has been submitted six onths prior to expiration. Terms and conditions of this permit shall remain in effect until such time as the permitting authority takes final action on the application for permit renewal. The permit number and agency interest number cited above should be referenced in future correspondence regarding this facility. Please be advised that pursuant to provisions of the Environmental Quality Act and the Administrative Procedure Act, the Department may initiate review of a permit during its term. However, before it takes any action to modify, suspend or revoke a permit, the Department shall, in accordance with applicable statutes and regulations, notify the perrnittee by mail of the facts or operational conduct that warrant the intended action and provide the perrnittee with the opportunity to demonstrate compliance with all lawful requirements for the retention of the effective permit. Done this :f-/11 day of Oi.,}p ~ , 2023. Perrnit No.: 2600-V5 Sincerely, ~ ~ fyy-- Assistant Secretary BMH:mat c: EPA Region VI Post Office Box4313 Baton Rouge, Louisiana 70821-4313 Phone 225-219-3181 Fax 225-219-3309 www.deq.louisiana.gov NORCO003095 EPA Inspection Report - Page 95 of 105 SPECIFIC REQUIREMENTS Al ID: 1406 - Equllon Enterprises LLC - Norco Refinery Activity Number: PER20220012 Permit Number: 2600-VS Air - Title V Regular Permit Renewal/Minor Mod EQT 0391 LPG LPG Drier Desiccant Change at Alky (PV-232, 233, 234, 293) 88 [LAC 33:lll.2 115.L] 89 [LAC 33 :ll.50 1.C.6] Equipment/operational data recordkeeping by electronic or hard copy at the regulation's specified frequency. Maintain the records specified in LAC 33 :lll.211 5.L. I through L.3. Maintain records on the premises for at least two years and make such information available 10 representatives of the Louisiana Department of Environmental Quality and the Environmental Protection Agency upon request. Emissions are routed to the West Ops Ground Flare, Emission Point 9-84 and the West Ops Elevated Flare, Emission Point 5-84, as an alternati ve control device. These flares are permitted under Permit o. 2913-V I1 and Permit No. 2520-VIO[Al 26336], or the more current versions, respectively. EQT 0392 Vent - Miscellaneous Maintenance Vent 90 [LAC 33 :III.2 115.B) 9 1 [LAC 33:ID.2115.J] 92 [LAC 33:ID.2 115.K.. l] 93 [LAC 33:111.2115.L] 94 [LAC 33:111.501.C.6] onhalogenated hydrocarbon burning: Temperature >= 1300 F (704 degrees C) for 0.3 second or greater in a direct-flame afterburner or an equally effective device which achieves a removal efficiency of 95 percent or greater, as determined in accordance with LAC 33:111. 2 I 15.K. l, or if emissions are reduced to 50 ppm by volume, whichever is less stringent. Which Months: All Year Statistical Basis: one specified Determine compliance with LAC 33 :ill.2115.B through H by applying the test methods specified in LAC 33 :lll.2 115.J. l through J.5, as appropriate. Demonstrate compliance with LAC 33:ill.2 115 as requested by DEQ. Equipment/operational data recordkeeping by electronic or hard copy at the regulation's specified frequency. Maintain the records specified in LAC 33:lll.2 115.L. l through L.3. Maintain records on the premises for at least two years and make such information available to representati ves of the Louisiana Department of Environmental Quality and the Environmental Protection Agency upon request. Emissions are routed 10 the West Ops Ground Flare. Emission Point 9-84 and the West Ops Elevated Flare, Emission Point 5-84. as an alternative control device. These flares are permitted under Permit o. 2913-V 11 and Penni! No. 2520-V IO [Al 26336], or the more current versions, respectively. FUG 0016 3000-95 Fugitive Emlsslons-Alkylatlon Unit 95 [40 CFR 63. 162(c)] 96 [40 CFR 63 .162{f)] 97 [40 CFR 63. l 63(b)(1)] Identify each piece o f equipment in a process unit such that it can be distinguished readily from equipment that is not subject to 40 CFR 63 Subpart H. Subpart H. [40 CFR 63. l 62(c)] Clearly identify leaking equipment, for leaking equipment detected as specified in 40 CFR 63.163, 40 CFR 63.164, 40 CFR 63. 168, 40 CFR 63. I69, and 40 CFR 63.172 through 63. 174. The identification may be removed after the equipment is repaired, except for valves or for connectors subject to 40 CFR 63. l74(c)(l )(i). The identification on a valve may be removed after it has been monitored as specified in 40 CFR 63.168(()(3) and 63. I75(e)(i)(D), and no leak has been detected during the follow-up monitoring. Ir electing to comply using the provisions or 40 CFR 63. l74(c)(l )(i), the identification on a connector may be removed after it is monitored as specified in 40 CFR 63. 174 (c)(l){i) and no leak is detected during that monitoring. Subpart H. [40 CFR 63. 162(()] Pumps in light liquid service: Organic HAP monitored by 40 CFR 60, Appendix A, Method 2 1 monthly to detect leaks, except as provided in 40 CFR 63 .162(b) and 63. l63(e) through G). t r a reading of I0,000 ppm (phase I); 5,000 ppm (phase II); or 5,000 ppm (phase ill, pumps handling polymerizing monomers), 2,000 ppm (phase Ill, pumps in foocVmedical service), or I,000 ppm (phase ITJ, all other pumps) or greater is recorded, a leak is detected. Ir a leak is detected, initiate repair provisions speci lied in 40 CFR 63. 163(c). Subpart H. [40 CFR 63. 163(b)( l)) Which Months: All Year Statistical Basis: None specified Page 8 of 23 P340_AP_SPEC_REQT NORCO003096 EPA Inspection Report - Page 96 of 105 SPECIFIC RECVIREMENJS Al ID: 1406 - Equilon Enterprises LLC - Norco Refinery Activity Number: PER20220012 Permit Number: 2600-VS Air - Title V Regular Permit Renewal/Minor Mod FUG 0016 3000-95 - Fugitive Emissions-Alkylation Unit 98 [40 CFR 63.163(b)(3)] 99 [40 CFR 63.163(c)] 100 [40 CFR 63.163(d)(2)] 101 [40 CFR 63. I 63(d)(4)] 102 [40 CFR 63. l 63(e)(l )] 103 [40CFR63. 163(e)(2)] 104 [40 CFR 63. 163(e)(3)] 105 [40 CFR 63. 163(e)(4)] 106 [40 CFR 63. 163(e)(6)(i)] 107 [40CFR63. 163(e)(6)] Pumps in light liquid service: Presence of a leak monitored by visual inspection/determination weekly (calendar). Monitor for indications of liquids dripping from the pump seal. If there are indications of liquids dripping from the pump seal, a leak is detected. If a leak is detected, initiate the repair provisions specified in 40 CFR 63.163(c). Subpart H. [40 CFR 63. 163(b)(3)] Which Months: All Year Statistical Basis: None specified Pumps in light liquid service: Make a first attempt at repair no later than 5 calendar days after a leak is detected, and complete repairs no later than 15 calendar days after the leak is detected, except as provided in 40 CFR 63.163(c)(3) and 40 CFR 63.171. Subpart H. [40 CFR 63.163(c)] Pumps in light liquid service: Implement a quality improvement program for pumps that complies with the requirements of40 CFR 63.176, if, in Phase III, calculated on a 6-month rolling average, the greater of either 10 percent of the pumps in a process unit or three pumps in a process unit leak. Subpart H. [40 CFR 63.163(d)(2)] Pumps in light liquid service: Determine percent leaking pumps using the equation in 40 CFR 63.163(d)(4). Subpart H. [40 CFR 63.163 (d)(4)] Pumps in light liquid service (dual mechanical seal system): Operate with the barrier fluid at a pressure that is at all times greater than the pump stuffing box pressure; or equip with a barrier fluid degassing reservoir that is routed to a process or fuel gas system or connected by a closed-vent system to a control device that complies with the requirements of40 CFR 63. 172; or equip with a closed-loop system that p urges the barrier fluid into a process stream. Comply with this requirement instead of the requirements in 40 CFR 63 .163(a) through (d). Subpart H. [40 CFR 63.163(e)(l)] Pumps in light liquid service (dual mechanical seal system): Ensure that the barrier fluid is not in light liquid service. Comply with this requirement instead of the requirements in 40 CFR 63.163(a) through (d). Subpart H. [40 CFR 63.163(e)(2)] Pumps in light liquid service (dual mechanical seal system): Equip barrier fluid system with a sensor that will detect failure of the seal system, barrier fluid system, or both. Comply with this requirement instead of the requirements in 40 CFR 63.l 63(a) through (d). Subpart H. [40 CFR 63.163(e)(3)] Pumps in light liquid service (dual mechanical seal system): Presence of a leak monitored by visual inspection/determination weekly (calendar). Monitor for indications ofliquids dripping from the pump seal. Ifthere are indications of liquid dripping from the pump seal at the time of the weekly inspection, monitor the pump as specified in 40 CFR 63.180(b) to determine ifthere is a leak of organic HAP in the barrier fluid. If an instrument reading of 1,000 ppm or greater is measured, a leak is detected. If a leak is detected, initiate the repair provisions in 40 CFR 63. l 63(e)(6). Comply with this requirement instead of the requirements in 40 CFR 63. I 63(a) through (d). Subpart H. [40 CFR 63.163(e)(4)] Which Months: All Year Statistical Basis: None specified Pumps in light liquid service (dual mechanical seal system): Determine, based on design considerations and operating experience, criteria that indicates failure of the seal system, the barrier fluid system, or both. Comply with this requirement instead of the requirements in 40 CFR 63.163(a) through (d). Subpart H. [40 CFR 63.163(e)(6)(i)] Pumps in light liquid service (dual mechanical seal system): Make a first attempt at repair no later than 5 calendar days after each leak is detected, and complete repairs no later than 15 calendar days after the leak is detected, except as provided in 40 CFR 63.17 1. Comply with this requirement instead of the requirements in 40 CFR 63. 163(a) through (d). Subpart H. [40 CFR 63.l 63(e)(6)] Page 9 of 23 P 3 4 0 _ A P_ S P EC_ R E Q T NORCO003097 EPA Inspection Report - Page 97 of 105 SPECIFIC REQUIREMENTS Al ID: 1406 - Equilon Enterprises LLC - Norco Refinery Activity Number: PER20220012 Permit Number: 2600-VS Air - Title V Regular Permit Renewal/Minor Mod FUG 0016 3000-95 - Fugitive Emissions-Alkylation Unit 108 [40 CFR 63.163(e)) 109 [40 CFR63.163(j)(I)] 110 [40 CFR 63.163(j)(2)] 111 [40 CFR 63.164(a)) 112 [40 CFR63.164(b)] 113 [40 CFR 63.164(c)] 114 [40 CFR 63.164(d)) 115 [40 CFR 63.164(e)(2)] 116 (40 CFR 63. l 64(g)] 117 [40 CFR 63.164(i)(2)] I 18 [40 CFR 63. I64] 119 [40 CFR 63. 165(a)] Pumps in light liquid service (dual mechanical seal system - sensor): Equipment/operational data monitored by visual inspection/determination daily, or equip with an audible alarm unless the pump is located within the bow1dary of an wimanned plant site. lf the sensor indicates failure ofthe seal system, the barrier fl uid system, or both based on the criteria established in 40 CFR 63.l 63(e)(6), a leak is detected. If a leak is detected, initiate repair provisions specified in 40 CFR 63. I63(e)(6). Comply with this requirement instead of the requirements in 40 CFR 63. J63(a) through (d). Subpart H. [40 CFR 63.163(e)] Which Months: AU Year Statistical Basis: None specified Pumps in light liquid service (unsafe-to-monitor): Determine that the pump is unsafe-to-monitor because monitoring personnel would be exposed to an immediate danger as a consequence of complying with 40 CFR 63.163(b) through (d). Comply with this requirement instead of the requirements in 40 CFR 63. I63(b) through (e). Subpart H. [40 CFR 63.163(j)(l )] Pumps in light liquid service (unsafe-to-monitor): Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 at the regulation's specified frequency. Maintain a written plan that requires monitoring ofthe pump as frequently as practicable during safe-to-monitor times but not more frequently than the periodic monitoring schedule otherwise applicable. Comply with this requirement instead of the requirements in 40 CFR 63.163(b) through (e). Subpart H. [40 CFR 63.163(j)(2)] Which Months: All Year Statistical Basis: None specified Compressors: Equip with a seal system that includes a barrier fluid system and that prevents leakage of process fluid to the atmosphere, except as provided in 40 CFR 63 .162(b) and 40 CFR 63.164(h) and (i). Subpart H. [40 CFR 63. l64(a)) Compressors: Operate the seal system with tho:: barrio::r fluid at a pressure that is greater than the compressor stuffing box pressure; or equip with a barrier fluid system degassing reservoir that is routed to a process or fuel gas system or connected by a closed-vent system to a control device that complies with the requirements of 40 CFR 63 .172; or equip with a closed-loop system that purges the barrier fluid directly into a process stream. Subpart H. [40 CFR 63. I64(b)) Compressors: Ensure that the barrier fluid is not in light liquid service. Subpart H. [40 CFR 63 .164(c)) Compressors: Equip each barrier fluid system as described in 40 CFR 63.164(a) through (c) with a sensor that will detect failure of the seal system, barrier fluid system, or both. Subpart 1-1. [40 CFR 63.164(d)) Compressors (sensor): Determine, based on design considerations and operating experience, a criterion that indicates failure of the seal system, the barrier fluid system, or both. Subpart H. [40 CFR 63. I64(e)(2)) Compressors: Make a first attempt at repair no later than 5 calendar days after each leak is detected, and complete repairs no later than 15 calendar days after each leak is detected, except as provided in 40 CFR 63.171. Subpart H. (40 CFR 63.!64(g)) Compressors (no detectable emissions): Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 once initially and annually, and at other times requested by DEQ. Comply with this requirement instead of the requirements in 40 CFR 63.164(a) through (h). Subpart H. [40 CFR 63.164(i)(2)] Which Months: All Year Statistical Basis: None specified Compressors (sensor): Equipment/operational data monitored by visual inspection/determination daily, or equip with an alarm, unless the compressor is located within the boundary ofan unmanned plant site. If the sensor indicates failure ofthe seal system, the barrier fluid system, or both based on the criterion determined wider40 CFR 63.l64(e)(2), a leak is detected. lfa leak is detected, initiate repair provisions specified in 40 CFR 63. 164(g). Subpart H. Which Months: All Year Statistical Basis: None specified Pressure relief device in gas/vapor service: Organic HAP < 500 ppm above background except during pressure releases, as determined by the method specified in 63.180(c). Subpart H. (40 CFR 63. 165(a)) Which Months: All Year Statistical Basis: None specified Page 10 of 23 P340_AP_SPEC_REQT NORCO003098 EPA Inspection Report - Page 98 of 105 SPECIFIC REQUIREMENTS Al ID: 1406 Equllon Enterprises LLC Norco Refinery Activity Number: PER20220012 Permit Number: 2600-VS Air Title V Regular Permit Renewal/Minor Mod FUG 0016 3000-95 Fugitive Emisslons-Alkylation Unit 120 (40 CFR 63. I65(b)(I )] 12 l [40 CFR 63. I65(b)(2)] 122 [40 CFR63. 165(d)(2)] 123 (40 CFR 63.166] 124 (40 CFR 63 .1 67] 125 [40 CFR63. 168(c)) 126 (40 CFR 63. 168(c)) 127 (40 CFR 63. !68(d)(l)) 128 (40 CFR 63. 168(d)(2)) 129 (40 CFR 63. l68(e)( l )] 130 [40 CFR 63. l68(t)(3)] Pressure relief devices in gas/vapor service: After each pressure release, return to a condition indicated by an instrument reading of less than 500 ppm above background, as soon as practicable, but no later than 5 calendar days after each pressure release, except as provided in 40 CFR 63.17 1. Subpart H. [40 CFR 63.165(b)(l)] Pressure reliefdevices in gas/vapor service: Organic HAP monitored by 40 CFR 60, Appendix A, Method 2 1 with in 5 days (calendar) after the pressure release and being returned to organic HAP service, to confirm the condition indicated by an instrument reading of less than 500 ppm above background, as measured by the method specified in 40 CFR 63. lS0(c). Subpart H. [40 CFR 63.165(b)(2)] Which Months: All Year Statistical Basis: None specified Pressure reliefdevices in gas/vapor service (rupture disk): After each pressure release, install a new rupture disk upstream ofthe pressure relief device as soon as practicable, but no later than 5 calendar days after each pressure release, except as provided in 40 CFR 63. 171 . Comply with this requirement instead of the requirements in 40 CFR 63. I65(a) and (b). Subpart H. [40 CFR 63.165(d)(2)] Sampling connection systems: Equip with a closed-purge, closed-loop, or closed-vent system, except as provided in 40 CFR 63.I62(b). Operate the system as specified in 40 CFR 63.l66(b). Subpart H. Open-ended valves or lines: Equip with a cap, blind flange, plug, or a second valve, except as provided in 40 CFR 63.162(b) and 40 CFR 63.167(d) and (e). Ensure that the cap, blind flange, plug or second valve seals the open end at all times except during operations requiring process fluid flow through the open-ended valve or line, or during maintenance or repair. Operate each open-ended valve or line equipped with a second valve in a manner such that the valve on the process fluid end is closed before the second valve is closed. Subpart H. Valves in gas/vapor service or light liquid service (Phase 1): Organic HAP monitored by 40 CPR 60, Appendix A, Method 21 quarterly, as specified in 40 CFR 63. l 80(b). Ifan instrument reading of I0,000 ppm or greater is recorded, a leak is detected. If a leak is detected, initiate repair provisions in 40 CPR 63.l68(t). Subpart H. [40 CFR 63.!68(c)] Which Months: All Year Statistical Basis: one specified Valves in gas/vapor service or light liquid service (Phase [I): Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 quarterly, as specified in 40 CFR 63.1S0(b). If an instrument reading of 500 ppm or greater is recorded, a leak is detected. If a leak is detected, initiate repair provisions in 40 CFR 63. l 68(f). Subpart H. [40 CFR 63.168(c)] Which Months: All Year Statistical Basis: None specified Valves in gas/vapor service or light liquid service (Phase Ill, 2 percent or greater leaking valves): Organic HAP monitored by 40 CFR 60, Appendix A, Method 2 1 monthly, as specified in 40 CFR 63.180(b); or implement a quality improvement program for valves that complies with the requirements of40 CFR 63.175 and monitor quarterly. If an instrument reading of 500 ppm or greater is recorded, a leak is detected. If a leak is detected, initiate repair provisions in 40 CFR 63.168(). If electing to implement a quality improvement program, follow the procedures in 40 CFR 63. 175. Subpart H. [40 CFR 63.1 68(d)(1)] Which Months: All Year Statistical Basis: None specified Valves in gas/vapor service or light liquid service (Phase Ill, less than 2 percent leaking valves): Organic HAP monitored by 40 CFR 60, Appendix A, Method 2 1 quarterly, as specified in 40 CFR 63. l 80(b). If an instrument reading of 500 ppm or greater is recorded, a leak is detected. Ifa leak is detected, initiate repair provisions in 40 CFR 63. l 68(t). Permittee may elect to comply with the alternate standards in 40 CFR 63.I68(d)(3) and (d)(4). Subpart H. [40 CFR 63. l68(d)(2)] Which Months: All Year Statistical Basis: None specified Valves in gas/vapor service or light liquid service: Determine percent leaking valves using the equation in 40 CFR 63. I68(e)( I). Subpart H. [40 CFR 63.!68(e)(l)] Valves in gas/vapor service or light liquid service (after leak repair): Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 once within three months (at least) after repa ir to determine whether the valve has resumed leaking. Subpart H. [40 CFR 63 .168(t)(3)] Which Months: All Year Statistical Basis: None specified Page 11 of 23 P340_AP_ SPEC_REQT NORCO003099 EPA Inspection Report - Page 99 of 105 SPECIFIC REQUIREMENTS Al ID: 1406 - Equilon Enterprises LLC - Norco Refinery Activity Number: PER20220012 Permit Number: 2600-VS Air - Title V Regular Permit Renewal/Minor Mod FUG 0016 3000-95 - Fugitive Emisslons-Alkylation Unit 131 (40 CFR 63. l 68(f)) 132 (40 CFR 63. l 68(h)(l)] 133 (40 CFR 63. l68(h)(2)) 134 (40 CFR 63.168(i)( l)) 135 [40 CFR 63. l 68(i)(3)] 136 [40 CFR 63. l69(a)) 137 [40 CFR 63. l69(c)) 138 [40 CFR 63. 170) 139 [40 CFR 63. 172(f)( I)(i)) 140 [40 CFR 63. l72(f)( I)(ii)] Valves in gas/vapor service or light liquid service: Make a first auempt at repair no later than 5 calendar days after a leak 1s detected, and complete repairs no later than 15 calendar days after the leak is detected, except as provided in 40 CFR 63.171 . Subpart H. [40 CFR 63. l 68(f)) Valves in gas/vapor service or light liquid service (unsafe-to-monitor): Demonstrate that the valve is unsafe to monitor because monitoring personnel would be exposed to an immediate danger as a consequence ofcomplying with 40 CFR 63. l 68(b) through (d). Comply with this requirement instead ofthe requirements in 40 CFR 63. l 68(b) through (f). Subpart H. [40 CFR 63. l68(h)(I)) Valves in gas/vapor service or light liquid service (unsafe-to-monitor): Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 at the regulation's specified frequency. Maintain a written plan that requires monitoring of the valves as frequently as practicable during safeto-monitor times, but not more frequently than the periodic monitoring schedule otherwise applicable. Comply with this requirement instead ofthe requirements in 40 CFR 63.168(b) through (f). Subpart H. [40 CFR 63.168(h)(2)) Which Months: All Year Statistical Basis: one specified Valves in gas/vapor service or light liquid service (difficult-to-monitor): Demonstrate that the valve cannot be monitored without elevating the monitoring personnel more than 2 meters above a support surface or it is not accessible at anytime in a safe manner. Comply with this requirement instead of the requirements in 40 CFR 63. l68(b) through (d). Subpart H. (40 CFR 63. l 68(i)(l )) Valves in gas/vapor service or light liquid service (difficult-to-monitor): Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 annually. Maintain a written plan that requires monitoring of the valves at least once per calendar year. Comply with this requirement instead of the requirements in 40 CFR 63. I68(b) through (d). Subpart H. [40 CFR 63. l68(i)(3)) Which Months: All Year Statistical Basis: one specified Pumps, valves, connectors, and agitators in heavy liquid service; instrumentation systems; and pressure relief devices in liquid service: Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 within 5 days (calendar) if evidence of a potential leak to the atmosphere is found by visible, audible, olfactory, or any other detection method. !fa reading of 10,000 ppm for agitators, 5,000 ppm for pumps handling polymerizing monomers, 2,000 ppm for all other pumps (including pumps in food/medical service), or 500 ppm for valves, connectors, instrumentation systems, and pressure relief devices, or greater is recorded, a leak is detected. If a leak is detected, initiate repair provisions specified in 40 CFR 63. l69(c). Subpart H. (40 CFR 63. I69(a)] Which Months: All Year Statistical Basis: one specified Pumps, valves, connectors, and agitators in heavy liquid service; instrumentation systems; and pressure relief devices in liquid service: Make a first attempt at repair no later than 5 calendar days after each leak is detected, and complete repairs no later than 15 calendar days afier it each leak is detected, except as provided in 40 CFR 63. 171. Subpart H. (40 CFR 63. I69(c)] Surge control vessels and bouoms receivers: Equip with a closed-vent system that routes the organic vapors vented from the surge control vessel or bottoms receiver back to the process or to a control device that complies with the requirements of 40 CFR 63.172, except as provided in 40 CFR 63. l62(b), or comply with the requirements of40 CFR 63. l l9(b) or (c), if surge control vessel or bottoms receiver is not routed back to lhe process and meets the conditions specified in 40 CFR 63 Subpart H Table 2 or Table 3. Subpart H. Closed-vent system (hard-piping): Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 once initially according to the procedures in 40 CFR 63. 1S0(b). If an instrument reading greater than 500 ppm above background is recorded, a leak is detected. If a leak is detected, initiate repair provisions in 40 CFR 63. l72(h). Subpart H. [40 CFR 63. l72(f)(I )(i)) Which Months: All Year Statistical Basis: None specified Closed-vent system (hard-piping): Presence of a leak monitored by visual, audible, and/or olfactory annually. If a leak is detected, initiate repair provisions in 40 CFR 63. l72(h). Subpart H. (40 CFR 63. l72(f)(l)(ii)) Which Months: All Year Statistical Basis: one specified Page 12 of 23 P340_AP_ SPEC_REOT NORCO003100 EPA Inspection Report - Page 100 of 105 SPECIFIC REQUIREMENTS Al ID: 1406 Equllon Enterprises LLC Norco Refinery Activity Number: PER20220012 Permit Number: 2600-VS Air Title V Regular Permit Renewal/Minor Mod FUG 0016 3000-95 Fugitive Emlsslons-Alkylation Unit 141 [40 CFR 63. l 72(f)(2)(i)] 142 [40 CFR 63. l 72(f)(2)(ii)] 143 [40 CFR 63. 172(h)] 144 [40 CFR 63. I72(j)( I)] 145 [40 CFR 63.172(j)(l)] 146 [40 CFR 63. l 72(j)(2)] 147 [40 CFR 63. 172(j)(2)] 148 [40 CFR 63. I72(k)(l )] 149 [40 CFR 63. l 72(k)(2)] 150 [40 CFR 63. I72(1)( I)] 151 [40 CFR 63 .172(1)(2)] 152 [40 CFR 63 .l 72(m)] Closed-vent system (duct work): Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 once initially according to the procedures in 40 CFR 63. 1S0(b). If an instrument reading greater than 500 ppm above background is recorded, a leak is detected. If a leak is detected, initiate repair provisions in 40 CFR 63. l72(h). Subpart H. [40 CFR 63. l 72(1)(2)(i)] Which Months: ALI Year Statistical Basis: None specified Closed-vent system (duct work): Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 annually according to the procedures in 40 CFR 63.IS0(b). If an instrument reading greater than 500 ppm above background is recorded, a leak is detected. If a leak is detected, initiate repair provisions in 40 CFR 63. l72(h). Subpart H. [40 CFR 63. I72(1)(2)(ii)] Which Months: All Year Statistical Basis: None specified Make a first attempt at repair no later than 5 calendar days afier each leak is detected, and complete repa irs no later than 15 calendar days after it each leak is detected, except as provided in 40 CFR 63.I 72(i). Subpart 1-J. [40 CFR 63. l 72(h)] Closed-vent system (bypass lines): Flow monitored by flow indicator once every 15 minutes. Install flow indicator at the entrance to any bypass line. Subpart H. [40 CFR 63.172(j)(J )] W hich Months: All Year Statistical Basis: one specified Closed-vent system (bypass lines): Flow recordkeeping by electronic or hard copy once every 15 minutes. Generate records as specified in 40 CFR 63. l 18(a)(3). Subpan H. [40 CFR 63.172(j)(l )) Closed-vent system (bypass lines): Seal or closure mechanism monitored by visual inspectio11/dete1minati on monthly to ensure the valve is maintained in the non-diverting position and the vent stream is not diverted through the bypass line. Subpart H. [40 CFR 63 .172(j)(2)] Which Months: All Year Statistical Basis: None specified Closed-vent system (bypass lines): Secure the bypass line valve in the non-diverting position with a car-seal or a lock-and-key type configuration. Subpart H. [40 CFR 63. 172(j)(2)] Closed-vent system (unsafe-to-inspect) : Demonstrate that the equipment is unsafe to inspect because inspecting personnel would be exposed to an imminent or potential dangers as a consequence of complying with 40 CFR 63. 172(1)(1) or (f)(2). Comply with this requirement instead of the requirements in 40 CFR 63 .l 72(f)(l) and (f)(2). Subpart H. [40 CFR 63 . I72(k)( I)] Closed-vent system (unsafe-to-inspect): Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 at the regulation's specified frequency. Maintain a written plan that requires inspection of the equipment as frequently as practicable during safe-to-inspect times, but not more frequently than annually. Comply with this requirement instead of the requirements in 40 CFR 63. I72(f)( I) and (t)(2). Subpart H. [40 CFR 63. 172(k)(2)] Which Months: A ll Year Statistical Basis: None specified Closed-vent system (difficult-to-inspect): Demonstrate that the equipment cannot be inspected without elevating the inspecting personnel more than 2 meters above a support surface. Comply with th is requ irement instead of the req uirements in 40 CFR 63.172(1)(1) and (t)(2). Subpart H. [40 CFR 63 .172(1)( I)] Closed-vent system (difficult-to-inspect): Organic HAP monitored by 40 CPR 60, Appendix A, Method 21 once every five years. Maintain a written plan that requires inspection of the equipment at least once every five years. Comply with this requirement instead of the requirements in 40 CFR 63. l72(t)( I) and (1)(2). Subpart H. [40 CFR 63. 172(1)(2)] Which Months: All Year Statistical Basis: None specified Ensure that the closed-vent system or control device is operating whenever organic HAP emissions are vented to the closed-vent system or control device. Subpart H. [40 CFR 63. l72(m)] Page 13 of 23 P340_AP_SPEC_REQT NORCO003101 EPA Inspection Report - Page 101 of 105 SPECIFIC REQUIREMENTS Al ID: 1406 - Equilon Enterprises LLC - Norco Refinery Activity Number: PER20220012 Permit Number: 2600-VS Air - Tltle V Regular Permit Renewal/Minor Mod FUG 0016 3000-95 - Fugitive Emlsslons-Alkylatlon Unit 153 [40 CFR 63. I73(a)] 154 [40 CFR 63. l 73{b)] 155 [40 CFR 63.I 73(c)] 156 [40 CFR 63. I 73(d)(i )] 157 (40 CFR 63. l 73(d)(2)] 158 (40 CFR 63. l73(d)(3)] 159 [40 CFR 63.I 73(d)(4)) 160 (40 CFR 63. I73(d)(6)(i)] 161 [40 CFR 63. I73(d)(6)] 162 [40 CFR 63. l73(d)] Agitators in gas/vapor service or light liquid service; Organic HAP monitored by 40 CFR 60, Appendix A, Method 2 1 monthly to detect leaks, as specified in 40 CFR 63. IS0{b). Jfan instrument reading of 10,000 ppm or greater is recorded, a leak is detected. !fa leak is detected, initiate repair provisions in 40 CFR 63.173(c). Subpart H. [40 CFR 63.173(a)] Which Months: All Year Statistical Basis: None specified Agitators in gas/vapor service or light liquid service: Presence ofa leak.monitored by visual inspection/determination weekly (calendar) for indications of liquids dripping from the agitator. If there are indications of liquids dripping from the agitator, a leak is detected. If a leak is detected, initiate repair provisions in 40 CFR-63. I 73(c). Subpart H . [40 CFR 63.173{b)] Which Months: All Year Statistical Basis : None specified Agitators in gas/vapor service or light liquid service: Make a first attempt at repair no later than 5 calendar days after each leak is detected, and complete repairs no later than 15 calendar days after it each leak is detected, except as provided in 40 CFR 63.171. Subpart H. [40 CFR 63 . l73(c)] Agitators in gas/vapor service and light liquid service (dua l mechanical seal system): Operate with the barrier fluid at a pressure that is at all times greater than the agitator stuffing box pressure; or equip with a barrier fluid degassing reservoir that is routed to a process or fuel gas system or connected by a closed-vent system to a control device that complies with the requirements of40 CFR 63 .172; or equip with a closed-loop system that purges the barrier fluid into a process stream. Comply with this requirement instead of the requirements in 40 CFR 63.173(a). Subpart H. [40 CFR63.173(d)(I)] Agitators in gas/vapor service and light liquid service (dual mechanical seal system): Ensure that the barrier fluid is not in light liquid organic HAP service. Comply with this requirement instead of the requirements in 40 CFR 63.173(a). Subpart H. (40 CFR 63.I 73(d)(2)] Agitators in gas/vapor service and light liquid service (dual mechanical seal system): Equip barrier fluid system with a sensor that will detect failure of the seal system, barrier fluid system, or both. Comply wi th this requirement instead of the requ irements in 40 CFR 63. 173 (a). Subpart H. [40 CFR 63.173(d)(3)] Agitators in gas/vapor service or Light liquid service (dual mechanical seal system); Presence of a leak monitored by visual inspection/determination weekly (calendar). Monitor for indications of liquids dripping from the agitator seal. If there are indications of liquid dripping from the agitator seal at the time of the weekly inspection, monitor the agitator as specified in 40 CFR 63.1S0(b) to determine the presence oforganic HAP in the barrier fluid. If an instrument reading of I0,000 ppm or greater is measured, a leak is detected. If a leak is detected, initiate the repair provisinns in 40 CFR 63. l73(d)(6). Comply with this requirement instead of the requirements in 40 CFR 63. J73(a). Subpart H. (40 CFR 63. I73(d)(4)] Which Months: All Year Statistical Basis: None specified Agitators in gas/vapor service and light liquid service (dual mechanical seal system): Determine, based on design considerations and operating experience, criteria that indicates failure of the seal system, the barrier fluid system, or both. Comply with this requirement instead of the requirements in 40 CFR 63.I73(a). Subpart H. [40 CFR 63.173(d)(6)(i)] Agitators in gas/vapor service and light liquid service (dual mechanical seal system); Make a firs t attempt at repair no later than 5 calendar days after each leak is detected, and complete repairs no later than 15 calendar days after tbe leak is detected, except as provided in 40 CFR 63. 171. Comply with this requirement instead of the requirements in 40 CFR 63. l73(a). Subpart 1-1. [40 CFR 63. I 73(d)(6)] Agitators in gas/vapor service or light liquid service (dual mechanical seal system - sensor): Equipment/operational data monitored by visual inspection/detennination daily, or equip with an audible alarm unless the agitator is located within the boundary ofan unmanned plant site. If the sensor indicates fai lure of the seal system, the barrier fluid system, or both based on the criteria established in 40 CFR 63. l 73(d)(6), a leak is detected. If a leak is detected, initiate repair provisions specified in 40 CFR 63. l73(d)(6). Comply with this requirement instead ofthe requirements in 40 CFR 63.173(a). Subpart 1-1. (40 CFR 63. l73(d)] Which Months: All Year Statistical Basis; None specified Page 14 of 23 P340_AP_ SPEC_REQT NORCO003102 EPA Inspection Report - Page 102 of 105 SPECIFIC REQUIREMENTS Al ID: 1406 - Equilon Enterprises LLC - Norco Refinery Activity Number: PER20220012 Permit Number: 2600-VS Air - Title V Regular Permit Renewal/Minor Mod FUG 0016 3000-95 - Fugitive Emissions-Alkylatlon Unit 163 [40 CFR 63.173(h)(l)] 164 [40 CFR 63.173(h)(3)] 165 (40 CFR 63.173(j)(I)] 166 [40 CFR 63. l 73(j)(2)] 167 [40 CFR63.174(b)(l)] 168 [40 CFR 63.174(b)(2)] 169 [40 CFR63.174(b)(3)(i)] 170 [40 CFR 63. 174(b)(3)(ii)] 171 [40 CFR63.174(c)(l)(i)] 172 [40 CFR 63.174(c)(2)(i)] Agitators in gas/vapor service or Light liquid service (difficult to monitor): Demonstrate that the agitator cannot be monitored without elevating the monitoring personnel more than two meters above a support surface or it is not accessible at anytime in a safe manner. Comply with this requirement instead of the requirements in 40 CFR 63.173(a) through (d). Subpart H. [40 CFR 63.l 73(h)(l )] Agitators in gas/vapor service or light liquid service (difficult-to-monitor): Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 annually. Maintain a written plan that requires monitoring of the agitator at least once per calendar year. Comply with this requirement instead of the requirements in 40 CFR 63. l 73(a) through (d). Subpart H. [40 CFR 63.173(h)(3)] Which Months: All Year Statistical Basis: None specified Agitators in gas/vapor service or light liquid service (unsafe-to-monitor): Demonstrate that the agitator is unsafe to monitor because monitoring personnel would be exposed to an immediate danger as a consequence ofcomplying with 40 CFR 63. I73(a) through (d). Comply with this requirement instead of the requirements in 40 CFR 63. I73(a) through (d). Subpart H. [40 CFR 63. 173(j)(I)] Agitators in gas/vapor service or light liquid service (unsafe-to-monitor): Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 at the regulation's specified frequency. Maintain a written plan that requires monitoring of the agitator as frequently as practicable during safe-to-monitor times, but not more frequently than the periodic monitoring schedule otherwise applicable. Comply with this requirement instead of the requirements in 40 CFR 63.173(a) through (d). Subpart H. [40 CFR 63. 173(j)(2)] Which Months: All Year Statistical Basis: None specified Connectors in gas/vapor service or Light liquid service: Organic HAP monitored by 40 CFR 60, Appendix A. Method 21 once within 12 months after the compliance date, except as provided in 40 CFR 63.174(1) through (h). If an instrument reading of 500 ppm or greater is recorded, a leak is detected. If a leak is detected, initiate repair provisions in 40 CFR 63.174(d). Subpart H. [40 CFR 63. I74(b)(I )) Which Months: AIL Year Statistical Basis: None specified Connectors in gas/vapor service or light liquid service: Organic HAP monitored by 40 CFR 60, Appendix A, Method 2 1 oace within the first 12 months after initial startup or by no later than 12 months after the date of promulgation ofa specific subpart that references 40 CFR 63 Subpart H, whichever is later, except as specified in 40 CFR 63. 174(1) through (h). If an instrument reading of 500 ppm or greater is recorded, a leak is detected. Jf a leak is detected, initiate repair provisions in 40 CFR 63.I74(d). Subpart H. [40 CFR 63. I74(b)(2)] Which Months: All Year Statistical Basis: None specified Connectors in gas/vapor service or light liquid service (0.5% or greater leaking): Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 annually. Subpart H. [40 CFR 63 .174(b)(3)(i)) Which Months: All Year Statistical Basis: None specified Connectors in gas/vapor service or light liquid service (less than 0.5% leaking): Organic HAP monitored by 40 CFR 60, Appendix A, Method 2 1 once every two years. Subpart H. [40 CFR 63. 174(b)(3)(ii)] Which Months: AIL Year Statistical Basis: None specified Connectors in gas/vapor service or light liquid service (opened or otherwise had the seal broken): Presence of a leak monitored by 40 CFR 60, Appendix A, Method 21 within tl1ree months after being returned to organic HAP service or when it is reconnected. If monitoring detects a leak, repair according to the provisions of40 CFR 63.l74(d), as specified, except as provided in 40 CFR 63. I74(c)( L)(ii). Subpart H. [40 CFR 63.174(c)(l)(i)] Which Months: All Year Statistical Basis: None specified Connectors in gas/vapor service or light liquid service (2 inches or less in nominal diameter): Comply with the requirements of 40 CFR 63.169. Subpart H. [40 CFR 63. I74(c)(2)(i)] Page 15 or 23 P340_AP_SPEC_REQT NORCO003103 EPA Inspection Report - Page 103 of 105 SPECIFIC REQUIREMENTS Al ID: 1406 - Equllon Enterprises LLC - Norco Refinery Activity Number: PER20220012 Permit Number: 2600-VS Air - Title V Regular Permit Renewal/Minor Mod FUG 0016 3000-95 - Fugitive Emlsslons-Alkylation Unit 173 [40 CFR 63. l74(c)(2)(ii)] 174 [40 CFR 63. l74(d)] 175 (40 CFR 63.174(1)(1)] 176 [40 CFR 63.174(1)(2)] 177 [40 CFR63.174(g)] 178 (40 CFR 63.174(h)(2)] 179 (40 CFR 63. I74(i)] 180 (40 CFR 63.180] 181 (40CFR 63. 18I] 182 (40 CFR 63. 182(b)] 183 [40 CFR 63.182(b)] 184 [40 CFR 63.182(b)] 185 (40 CFR 63. 182(c)] 186 [40 CFR 63. I82(d)] Connectors in gas/vapor service or light liquid service (2 inches or less in nominal diameter): Organic HAP monitored by technically sound method within three months after being returned to organic HAP service after having been opened or otherwise had the seal broken. If monitoring detects a leak, implement repair provisions in 40 CFR 63. I74(d). Subpart H. [40 CFR 63.l 74(c)(2)(ii)] Which Months: All Year Statistical Basis: None specified Connectors in gas/vapor service or light liquid service: Make a first attempt at repair no later than 5 calendar days after each leak is detected, and complete repairs no later than 15 calendar days after it each leak is detected, except as provided in 40 CFR 63.171 and 63.174 (g). Subpart H. (40 CFR 63. I74(d)] Connectors in gas/vapor service or Light liquid service (unsafe-to-monitor): Demonstrate that the connector is unsafe to monitor because personnel would be exposed to an immediate danger as a result of complying with 40 CFR 63 .I74(a) through (c). Comply with this requirement instead of the requirements in 40 CFR 63. I74(a). Subpart H. [40 CFR 63. 174(1)(1)] Connectors in gas/vapor service or light liquid service (unsafe-to-monitor): Organic HAP monitored by 40 CFR 60, Appendix A, Method 21 at the regulation's specified frequency. Maintain a written plan that requires monitoring ofconnectors as frequently as practicable during safe to monitor times, but not more frequently than the periodic schedule otherwise applicable. Comply with this requirement instead of the requirements in 40 CFR 63. I74(a). Subpart H. [40 CFR 63 .174(1)(2)] Which Months: All Year Statistical Basis: one specified Connectors in gas/vapor service or light liquid service (unsafe-to-repair): Demonstrate that repair personnel would be exposed to an immediate danger as a consequence ofcomplying with 40 CFR 63. I74(d). Comply with this requirement instead ofthe requirements in 40 CFR 63. I74(a), (d), and (e). Subpart H. [40 CFR 63. I74(g)] Connectors in gas/vapor service or light liquid service (inaccessible, ceramic. or ceramic-Lined): Make a first attempt at repair within 5 days after leak is detected by visual, audible, olfactory or other means, and complete repairs no later than 15 calendar days after leak is detected, except as provided in 40 CFR 63. 17 1 and 63 .I74(g). Comply with this requirement instead of the monitoring requirements of 40 CFR 63. l74(a) and (c) and from the recordkeeping and reporting requirements of40 CFR 63. 181 and 63.182. Subpart H. [40 CFR 63.174 (h)(2)] Connectors in gas/vapor service or light liquid service: Calculate percent leaking connectors as specified m 40 CFR 63.174(i)(l) and (i)(2). Subpart H. [40 CFR 63. l74(i)] Comply with the test methods and procedures requirements provided in 40 CFR 63.180. Subpart H. Equipment/operational data recordkeeping by electronic or hard copy at the regulation's specified frequency. Maintain records as specified in 40 CFR 63. 18l(a) through (k). Subpart H. Submit Initial Notification: Due within 120 days after the date of promulgation of the subpart that references 40 CFR 63 Subpart H. Include the information specified in 40 CFR 63. 182(b)(l). Subpart H. (40 CFR 63. I82(b)] Submit Initial otification: Due within 90 days after the date of promulgation of the subpart that references 40 CFR 63 Subpart H. Include the information specified in 40 CFR 63.182(b)(l). Subpart H. [40 CFR 63. 182(b)] Submit application: Due as soon as practicable before the construction or reconstruction is planned to commence (but it need not be sooner than 90 days after the date of promulgation of the subpart that references 40 CFR 63 Subpart H). Submit application for approval of construction or reconstruction required by 40 CFR 63.5(d) in lieu of the Initial otilication. Subpa11 H. (40 CFR 63.182(b)] Submit Notification of Compliance Status: Due within 90 days of the compliance dates specified in the 40 CFR 63 subpart that references 40 CFR 63 Subpart H. include the information specified in 40 CFR 63. l82(c}( I) through (c)(3). Subpart H. [40 CFR 63. l 82(c)] Submit Periodic Reports: Due semiannually starting 6 months after the Notification of Compliance Status, as required in 40 CFR 63.182 (c). Include the infonnation specified in 40 CFR 63 . I82(d)(2) through (d)(4). Subpart H. f40 CFR 63. 182(d)] Page 16 of 23 P340_AP_SPEC_REQT NORCO003104 EPA Inspection Report - Page 104 of 105 SPECIFIC REQUIREMENTS Al ID: 1406 Equilon Enterprises LLC Norco Refinery Activity Number: PER20220012 Permit Number: 2600-VS Air . Title V Regular Permit Renewal/Minor Mod FUG 0016 3000-95 Fugitive Emissions-Alkylation Unit 187 (40 CFR 63.648(j)(3)(iii)] 188 (40 CFR 63.6480)(4)) 189 (40 CFR 63.648(j)(6)] 190 (40 CFR 63.648(j)(7)] 191 [LAC 33: 111.21 l l) 192 [LAC 33:IIl.2199.B] 193 [LAC 33:IIl.2199.B) Calculate the quantity of organic HAP released d uring each pressure release event and report this quantity as required in 40 CFR 63.655(g) ( I0)(iii). Calculations may be based on data from the pressure relief device monitoring alone or in combination with process parameter monitoring data and process know ledge. Subpart CC. (40 CFR 63.648(j)(3)(iii)] Tfall releases and potential leaks from a pressure reliefdevice are routed through a closed vent system to a control device, back into the process or to the fuel gas system, the owner or operator is not required to com ply with paragraph (j)(l), (2), or (3) (if applicable) ofthis section. Both the closed vent system and control device (if applicable) must meet the requirements of 63.644. When complying with this paragraph (j)(4), all references to "Group 1 miscellaneous process vent" in 63.644 mean "pressure relief device." If a pressure relief device complyi ng with this paragraph (j)(4) is routed to the fuel gas system, then on and after January 30, 2019, any flares receiving gas from that fuel gas system must be in compliance with 63.670. Subpart CC. (40 CFR 63.648(j)(4)) A root cause analysis and corrective action analysis must be completed as soon as possible, but no later than 45 days after a release event. Special circumstances affecting th e number of root cause analyses and/or corrective action analyses are provided in paragraphs (j)(6)(i) through (iv) of this section. Subpart CC. (40 CFR 63.648(j)(6)] Each owner or operator required to conduct a root cause analysis and corrective action analysis as specified in paragraphs (j)(3)(iii) and (j) (6) of this section shall implement the corrective action(s) identified in the correct ive action analysis in accordance with the applicable requirements in paragraphs (j)(7)(i) through (iii) of this section. Subpart CC. (40 CFR 63.648(j)(7)] Equip aJJ rotary pumps and compressors handling volatile organic compounds having a true vapor pressure of 1.5 psia or greater at hand ling conditions with mechanical seals or other equivalent equipment. Comply with LAC 33:111.212 l ; NSPS 40 CFR 60 Subpart GGGa; and NESHAP 40 CFR 63 Subparts CC and H by implementing the Louisiana Consolidated Fugitive Emission Program Guidelines. Compliance is achieved through compliance with 40 CFR 63 Subpart H. Permittee shall comply with a streaml ined equipment leaks monitoring program. Compliance with the streamlined program in accordance with this specific condition.shall serve to comply with each of the fug itive emission monitoring programs being streamlined, as indicated in the following table. Noncompliance with the streamlined program in accordance with this specific condition may subject the permittee to enforcement action for one of the app licable fugitive emissions programs. (a) Streamlined program shall be app licable to the combined universe of components subject to any of the programs being streamlined. Any component type which does not require periodic monitoring under U1e overall most stringent program shall be monitored as requi red by the most stringent requirements of any other program being streamlined and will not be exempted. The streamlined program will include any exemptions based on size or component available in any of the programs being streamlined (b) Leak definitions and monitoring frequency shall be used based on the overall most stringent program. Percent leaker performance shall be calculated using the provisions of the overall most stringent program. Annual monitoring shall define as once every four quarters. Some allowance may be made in the first year on lhe streamlined program in order to allow for transition from existing monitoring schedules. (c) Permittee shall comply with recordkeep ing and reporting requirements of the overall most stringent program. Semiannual reports shall be submitted by March 31 for the preceding period encompassing July througb December, and by September 30 fo r the preceding period encompassing January through June. The semiannual reports shall include any monitoring performed within the reporting period. Paga 17 of 23 P340_AP_SPEC_REQT NORCO003105 EPA Inspection Report - Page 105 of 105 SPECIFIC REQUIREMENTS Al ID: 1406 - Equllon Enterprises LLC - Norco Refinery Activity Number: PER20220012 Permit Number: 2600-VS Air - Title V Regular Permit Renewal/Minor Mod FUG 0016 3000-95 - Fugitive Emlsslons-Alkylatlon Unit l 94 [LAC 33 :Ill.SOI .C.6) The number of each type ofcomponents required to be monitored for each monitoring period under applicable leak detection and repair programs shall be reported to the LDEQ by inclusion with each periodic monitoring report. Fugitive emission piping components may be added to or removed from the permitted units, without triggering the need to apply for a penn it modification, provided: A) Changes in components involve routine maintenance or are undertaken to address safety concerns or involve small piping revisions with no associated emissions increases except from the fugi tive emission components themselves; B) The changes do not involve any associated increase in the production rate or capacity, or tie in of new or modified process equipment other than the piping components; C) Actual emissions following the changes will not exceed the emission limits contained in this permit; and D) The components are promptly incorporated into any applicable leak detection and repair program. UNF 0003 ALKY - Alkylation Unit 195 [40 CFR 60.7(a)) 196 [40 CFR 60.7(b)) 197 [40 CFR 60.7(c)) 198 [40 CFR 60.7(d)] 199 [40 CFR 60.) 200 [40 CFR 61.145(b)(l)] 201 [40CFR61.148] 202 [40 CFR 61.342(e)( l )) 203 [40 CFR 61.342(e)(2)) 204 [40 CFR 61.355(k)] 205 [40 CFR 6l.356(b)(4)) Provide written or electronic notification to the Administrator the information specified in 40 CFR 60.7(a)(l) through (a)(7). Subpart A. [40 CFR 60.7(a)] Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation ofau affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. Subpart A. [40 CFR 60.7(b)) Submit excess emissions and monitoring systems performance report and/or summary report form (sec 40 CFR 60.7(d)): Due semiannually. All reports shall be postmarked by the 30th day following the end of each six-month period. Written reports of excess emissions shall include the information speci fied in 40 CFR 60.7(c)( l) through (c)(4). Subpart A. [40 CFR 60.7(c)] A summary report fo nn shall contain the in formation and be in the format shown in Figure l of this paragraph unless otherwise specified by the Administrator. One summary report form shall be submitted for each pollutant monitored at each affected facility. Subpart A. [40 CFR 60.7(d)) All affected facilities shall comply with all applicable provisions in 40 CFR 60 Subpart A. Provide DEQ with written notice of intention to demolish or renovate prior to performing activities to which 40 CFR 61 Subpart M app lies. DeItvery of the notice by U.S. Postal Service, commercial delivery service, or hand delivery is acceptable. Subpart M. [40 CFR 61. l 45(b) (I)] Do not install or reinstall on a facility component any insulating materials that contain commercial asbestos if the materials are either molded and friable or wet-applied and friable after drying. Subpart M. Benzene: As an alternative to the requirements specified in 40 CFR 61.342(c) and (d), the permittee shall manage and treat facility waste with a flow-weighted annual average water content of less than IO percent as per 40 CFR 61.342(c)( I). Subpart FF. [40 CFR 61.342(e)( I)) Benzene: As an alternative to the requirements specified in paragraphs (c) and (d) of this section, the pcrmittee shall manage and treat facility waste (including remediation and process unit turnaround waste) with a flow-weighted annual average water content of IO percent or greater, on a volume basis as total water, and each waste stream that is mixed with water or wastes at any time such that the resulting m ixture has an annual water content greater than 10 percent and the benzene quantity for the wastes must be equal to or less than 6.0 Mg/yr (6.6 ton/yr), as determined in 40 CFR 61.355(k). (40 C FR 6 l.342(e)(2)) Determine compliance with 40 CFR 6 1 Subpart FF using the test methods and procedures specified in 40 CFR 6 l.355(k) as applicable. Subpart FF. [40 CFR 6 1.355(k)] Equipment/operational data recorclkeeping by electronic or hard copy at the regulation's specified freq uency Maintain records as specified in 40 CFR 61.356(b)(4). Maintain each record .in a readily accessible location at the facility site for a period not less than two years from the date the information is recorded unless otherwise specified. Subpart FF. (40 CFR 6 l.356(b)(4)) Page 18 of 23 P 3 4 0_A P_ S P E C_ R E QT NORCO003106