Document 1q4my625Ye565vr18YnZKNZX

EPA Inspection Report - Page1 of 74 ""' ft EPAJnlradSW.. . 0 E!MrcrurmJ!BIProtecllon . Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT . Inspection D9te(s): Media: Regulatory Program(s) 3/28-30/2016 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 Contact: Motiva Enterprises LLC Motiva Enterprises LLC Port Arthur Refinery 2555 Savannah Ave. Port Arthur, TX 77460 P.O. Box712 Port Arthur, TX 77460 Jefferson County Damian Fryoux I Environmental Manager Damian.fryoux@Motivaent.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110000464024 0-01386 AFS # 4824500020 324110 2911 Facility Representatives: EPA Inspectors: State lnspec;tor(s): Other lnspector(s): Damian Fryoux .Jim Gold Prince Nfodzo Did not attend NA . Environmental Manager Region 6, 6EN-ASH Region 6, 6EN-AA 504/275-8782 281/983-2153 214/665-7491 ~I-~TI~It~le~:_ _ _ _ _ _ _ _ _ _ _ _ _ _I-M~o=tiv~a~R~e~fitn~in~g~,P~o~rt~A~rt~h~u~r~R~e~fi~ne~ry~,~P~o~rt~A~rt~h~u~~~T~e~xa~s~,~Jeffe rn=o~n~C~o~un~ty~---i 10 7 777 ., Author: US EPA Region 6 Compliance Assurance and Enforcement Division Dallas TX ~~s=ub~~~ect~:------------1-P~a~rt~ia~I~C~o~m~p~lia~n~c~e~E~va~l=ua~t~io~n~ln=s=p~ect~lo~n~R~e~p~ort~~~~~~~==~~__, 2~~~--------~~~~~~~~~~~~~------~------~ Keywords: refinery consent decree (CD) EPA Lead Inspector Signature/Date Jim Gold ~ ./::L J.J! 0. Date 4/27/2016 Supervisor Signature/Date Sam Tates K...... Jlf//dl: I s /a/Zollo. Da(e ' 6ENFORM-019-R3 (11/14/2013) EPA Inspection Report - Page2 of 74 Motiva Enterprises LLC, Port Arthur Refinery 3/28-30/2016 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Prince Nfodzo and I (Jim Gold) conducted an inspection of the Motiva Enterprises LLC Port Arthur, Texas Refinery. At 1:00 pm on March 28, 2016, we met with Damian Fryoux, Environmental Manager for the facility, for an opening conference. We presented our credentials to Mr. Fryoux and informed him that this was an EPA inspection to determine compliance with the federally issued Consent Decree (Civil Action H-01-0978), which is a national priority for EPA. The inspection was a Partial Compliance Evaluation (PCE), which included an evaluation of the consent decree's (CD) four marquee issues: nitrogen oxides and sulfur dioxide (NOx/SO2) reductions, leak detection and repair (LDAR), benzene waste operations (BWON) and flaring of both acid gases and hydrocarbons. The CD consists of 19 Parts designated by Roman numerals. Of these, Parts IV - VIII requires affirmative relief, which was the focus of the inspection. These Parts address the requirements of NOx,SO2, CO, particulate, VOC, and benzene emission reductions through various construction projects, process additives, and process and program enhancements. The applicable consent decree (H-01-0978) originally entered August 21, 2001 most recently was amended January 19, 2006 to remove conditions pertaining to heaters and boilers and referred to as "the heater and boiler CD". The heaters and boilers CD was previously terminated and therefore heaters and boilers were not part of this inspection. Note that these inspection findings pertain only to the compliance status affecting Motiva's Port Arthur refinery. Photos taken during the inspection (11) are included as Appendix 1. Note that the date stamp shown in the photos is dated 1/1/2012. The actual dates of the photographs are 3/29/2016. Sign in sheet for the opening conference is included as Appendix 2. FACILITY DESCRIPTION Motiva's Port Arthur refinery began a major expansion in 2008 to 2012 with the addition of a new crude oil distillation capacity, delayed coking, hydrotreating, catalytic cracking, sulfur recovery and other downstream processing. The permitted processing rate for the facility is now 635,000 barrels crude oil input per day. The refinery produces motor gasoline, diesel fuel, jet fuel, liquefied petroleum gas, and fuel oil. Crude oil is obtained primarily by ship and pipeline, 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 in APPENDIX 3. 6ENFORM-019-R3 (11/14/2013) EPA Inspection Report - Page3 of 74 Motiva Enterprises LLC, Port Arthur Refinery 3/28-30/2016 Section II - OBSERVATIONS Part IV, NOx Emissions Reductions from Fluidized Catalytic Cracking Units (FCCU's) and Fluid Coker Units (FCU's) Status: Complete. Program Summary: Motiva shall incorporate lower NOx emission limits into operating permits and will demonstrate future compliance with the lower emission limits through the use of continuous emission monitoring systems (CEMS). Motiva shall begin using NOx reducing catalyst at the Port Arthur FCCU and report the results of the optimization study. The FCCU will be operated at less than 20 ppm NOx on a 365 rolling day average and 40 ppm NOx on a rolling three hour average APPENDIX 5 contains the FCCU NOx 365 day and 24 hour rolling average emission trends from March 2015 - March 2016. No exceedances of the limits occurred during the time period. We observed the FCCU CEMS and that the calibration gases were of the correct concentration and up to date. I reviewed the relative accuracy test audit (RATA) results for the CEMs and found the relative accuracies to be within allowable requirements of 40 CFR, Part 60, Appendix F. Part V, Reductions of SO2 Emissions FCCU's and FCU's Status: Complete. Program Summary: Motiva shall continue to operate the existing wet gas scrubber and incorporate lower SO2 emissions into operating permits and demonstrate future compliance with the lower limits through use of CEM's. Motiva shall operate the Port Arthur FCCU so that SO2 emissions do not exceed 25 ppm on a 365 day rolling average and 50 ppm based on a 7 day rolling average and shall monitor SO2 emissions using CEMS. Part V also requires compliance with NSPS Subparts A and J for SO2, CO, particulate matter (PM) and opacity limits. Appendix 6 contains FCCU SO2 365 day and 7 day rolling average trends from March 2015 - March 2016. No exceedances were recording during the time period. During the inspection we observed the CEMS to be properly installed and that the calibration gases were up to date and of the proper concentrations. I reviewed the RATA results for the CEMS and found the relative accuracies for the CEMS to be within allowable requirements of 40 CFR, Part 60, Appendix F. Appendix 7 is the FCCU CO one-hour rolling average trend from March, 2015 to March, 2016. Spikes in CO emissions during March, 2015 and October, 2015 are a result of the malfunctions previously reported to the State of Texas Excess Emissions Reporting System. The FCCU is equipped with an oxygen enrichment system if needed. EPA Inspection Report - Page4 of 74 Motiva Enterprises LLC, Port Arthur Refinery 3/28-30/2016 Part VI, Program Enhancements Regarding Benzene Waste NESHAP. Status: On schedule. Program Summary: Motiva shall undertake refinery-wide audits to determine its compliance with all Benzene Waste NESHAPS requirements and to take corrective action where any areas of non- compliance are identified. In addition Motiva shall undertake refinery wide measures to minimize or eliminate fugitive benzene waste emissions at the refinery. Motiva is implementing the 2BQ compliance option of Subpart FF using upstream controls. A schematic of the process is included as APPENDIX 8. Compliance sampling conducted at the outlet of treatment plant from January, 2015 to December, 2015 is included as APPENDIX 8. The trend indicates the 10 ppm limit imposed by NESAHP Subpart FF has not been exceeded. I reviewed the sampling procedure and standard operating procedures (SOPs) being used and found the procedures written in a formal SOP and consistent with BWON sampling techniques required by 40 CFR 61.355. Part VII, Program Enhancements RE: Leak Detection and Repair (LDAR) Program Enhancements Status: On schedule. Program Summary: Motiva shall undertake audits of the components in light liquid and gaseous service at each of its refineries to determine compliance with all of the requirements of the Leak Detection and Repair ("LDAR") regulations and to correct any areas of non-compliance. In addition, Motiva 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 service at its refineries in accordance with the schedule set forth. Third party audits, periodic reports and other requirements of Part XI of the consent decree have been previously reported to EPA and TCEQ. Motiva uses in-house employees to conduct repairs and follow-up monitoring at the Port Arthur refinery. I reviewed instrument calibration logs and found that equipment calibration records are not being consistently signed by operators. Motiva has implemented a mid-day and the end of day drift check, as required by the CD. I reviewed the quarterly precision test results for the instruments being used at the facility, calibration gas certificates, and the most recent third party audit findings. Calibration gases observed were up to date and approximately equal to the leak definitions required by EPA Method 21. I observed that electronic data collection for LDAR monitoring is being conducted by using data loggers and leak tracking and reporting software. Records indicate annual training is being conducted and is incorporated into new employee orientation. EPA Inspection Report - Page5 of 74 Motiva Enterprises LLC, Port Arthur Refinery 3/28-30/2016 I walked through FCCU3, HTU 3 and 4, SRU 3, 4 and 5 and the waste water treatment plant and observed one open ended valve. Missing and illegible tags were evident in FCCU 3. Part VIII, Program Enhancements RE: NSPS Subparts A and J SO2 Emissions from Sulfur Recovery Plants (SRP's) and Flaring Status: On schedule. Program Summary: Beginning immediately upon the lodging of this Consent Decree, Motiva agrees to take the following measures at all of its SRPs and certain flaring devices at the refineries identified in Paragraph 5. Motiva shall eliminate all reasonably preventable SO2 emissions from flaring. Motiva will implement procedures for root cause analysis of acid gas flaring incidents at all refineries. Motiva shall strive to extend the duration between SRP maintenance shutdowns (unscheduled or scheduled) to three years or greater. All flares at the facility are connected to one of two flare gas recovery systems installed as a result of the consent decree. A graph of compressor operation (APPENDIX 12) shows the systems have sufficient compression and flow capacity. I observed no smoke or flames being emitted by the flares. I also observed each flare using a FLIR optical imaging device and observed no abnormal operation such as puffing or presence of non- combusted hydrocarbons. The facility operates one SRU covered by the consent decree (SRU 1). The 12 hour average SO2 emissions trend as recorded by CEMS is included as APPENDIX 11. The trend show the 250 ppm limit was exceeded at SRU1 in November, 2015 due to a unit trip. I observed that the SO2 analyzer was installed correctly and the calibration gas was of the correct concentration and up to date. I reviewed the RATA results for SRU CEMs and found the relative accuracies for the CEMS to be within the allowable requirements of 40 CFR, Part 60, Appendix F. IX Permitting Status: Complete. Motiva 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 required to meet the above pollution reductions. Appendix 14 contains excerpts from the most recently revised NSR operating permits. Specific CD imposed limits are incorporated into the NSR permits and the Title V permit by reference. EPA Inspection Report - Page6 of 74 Motiva Enterprises LLC, Port Arthur Refinery 3/28-30/2016 Section III - AREAS OF CONCERN An alternative monitoring plan for monitoring wet gas scrubber parameters for FCCU 1 has been provisionally approved due to a performance test conducted in 2014. However, the AMP has not been formally approved at this time. Section IV - FOLLOW UP N/A Section V - LIST OF APPENDICES Appendix 1 - Photo Log (11 photos taken 3/29-30/2016) Appendix 2 - Opening conference sign-in sheet Appendix 3 - Plant wide process flow diagram and written description Appendix 4 - CEMS required by consent decree Appendix 5 - FCCU NOx emission trends Appendix 6 - FCCU SO2 emission trend Appendix 7 - FCCU CO emission trend Appendix 8 - BWON schematic Appendix 9 - BWON analytical data for feed Appendix 10 - SRU block flow diagram Appendix 11 - SRU SO2 emission trends Appendix 12 - Compressor inlet/outlet flows and spill back Appendix 13- Acid gas and hydrocarbon flaring events Appendix 14 - Operating permit excerpts Appendix CBI (None) EPA Inspection Report - Page7 of 74 Motiva Enterprises LLC/ Port Arthur Refinery Inspection Date {03/30/2016} Appendix 1 Photograph Log EPA Inspection Report - Page8 of 74 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Motiva Enterprises LLC City: Port Arthur Photo No. 1 County/Parish: Jefferson State: Texas FCCU NOx CEM NOx = 27.20 ppm EPA Inspection Report - Page9 of 74 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Motiva Enterprises LLC City: Port Arthur Photo No. 2 County/Parish: Jefferson State: Texas FCCU CO/SO2 CEMs. CO = 11.9 ppm SO2 = 10.8 ppm EPA Inspection Report - Page10 of 74 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Motiva Enterprises LLC City: Port Arthur Photo No. 3 County/Parish: Jefferson State: Texas FCCU O2 CEM O2 = 1.96 % EPA Inspection Report - Page11 of 74 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Motiva Enterprises LLC City: Port Arthur Photo No. 4 County/Parish: Jefferson State: Texas FCCU #3 Belco Wet Gas Scrubber EPA Inspection Report - Page12 of 74 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Motiva Enterprises LLC City: Port Arthur Photo No. 5 County/Parish: Jefferson State: Texas Sulfur Recover Unit #1 Tail Gas Unit SO2 CEM SO2 = 16.9 ppm EPA Inspection Report - Page13 of 74 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Motiva Enterprises LLC City: Port Arthur Photo No. 6 County/Parish: Jefferson State: Texas Sulfur Recovery Unit Tail Gas O2 CEM O2 = 4.65 % EPA Inspection Report - Page14 of 74 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Motiva Enterprises LLC City: Port Arthur Photo No. 7 County/Parish: Jefferson State: Texas Sulfur Recovery Unit Tail Gas Unit #2 SO2 CEM SO2 = 14.82 ppm EPA Inspection Report - Page15 of 74 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Motiva Enterprises LLC City: Port Arthur Photo No. 8 County/Parish: Jefferson State: Texas Sulfur Recovery Unit Tail Gas Unit #2 O2 CEM O2 = 4.374 % EPA Inspection Report - Page16 of 74 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Motiva Enterprises LLC City: Port Arthur Photo No. 9 County/Parish: Jefferson State: Texas Waste Water Treatment BWON Carbon Bed Control Display EPA Inspection Report - Page17 of 74 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Motiva Enterprises LLC City: Port Arthur Photo No. 10 County/Parish: Jefferson State: Texas Waste Water Treatment Plant BWON Carbon Beds with shut down Thermal Oxidizer. EPA Inspection Report - Page18 of 74 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Motiva Enterprises LLC City: Port Arthur Photo No. 11 County/Parish: Jefferson State: Texas Flare Gas Recovery Compressors. EPA Inspection Report - Page19 of 74 EPA Inspection Report - Page20 of 74 EPA Inspection Report - Page21 of 74 EPA Inspection Report - Page22 of 74 EPA Inspection Report - Page23 of 74 EPA Inspection Report - Page24 of 74 EPA Inspection Report - Page25 of 74 EPA Inspection Report - Page26 of 74 EPA Inspection Report - Page27 of 74 EPA Inspection Report - Page28 of 74 EPA Inspection Report - Page29 of 74 EPA Inspection Report - Page30 of 74 EPA Inspection Report - Page31 of 74 EPA Inspection Report - Page32 of 74 EPA Inspection Report - Page33 of 74 EPA Inspection Report - Page34 of 74 EPA Inspection Report - Page35 of 74 EPA Inspection Report - Page36 of 74 EPA Inspection Report - Page37 of 74 EPA Inspection Report - Page38 of 74 EPA Inspection Report - Page39 of 74 EPA Inspection Report - 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