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MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Exxon Mobil Corporation, Baytown, Texas FROM: Constantinos Loukeris, Environmental Engineer AECAB (MI/WI) THRU: Sarah Marshall, Section Supervisor AECAB (MI/WI) TO: File BASIC INFORMATION Facility Name: Exxon Mobil Corporation (XOM) Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6, 2024 - May 10, 2024 EPA Inspector(s): 1. Constantinos Loukeris, Environmental Engineer 2. James Haynes, Physical Scientist 3. Sophia Ong, Physical Scientist 4. Benjamin Rosenthal, Physical Scientist 5. Sydney Knodl, Physical Scientist 6. Colleen McCarthy, Life Scientist Other Attendees: 1. Kara Moore, Exxon, Environmental Advisor 2. Barbara Kellum, Exxon, Multimedia Supervisor 3. Adeniyi Adetayo, Exxon, Environmental 4. Kristin Henningson, Environmental Advisor 5. Joshua Kinnnger, Exxon, Air Section Supervisor 6. MaryCarmen Perales, Exxon, Wastewater Contact 7. Madison Kettler, Exxon, Environmental Advisor 8. Ty Hastriter, Exxon, GO&S Sustainability Advisor Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 9. Colt Schmidtke, Exxon, Counsel 10. Clinton Elliott, TRC, Senior Project Manager 11. George Rizzo, Exxon, Counsel 12. Stephen Codolato, Exxon, State Advisor 13. Amanda Wolsiefer, Exxon, Environmental Advisor 14. Cole Billeaux, Exxon, Environmental Advisor 15. Abraham Valdes, Exxon 16. Bo Anderson, Exxon, Unit Supervisor 17. Kayla Thorsteinson, Exxon, Sulfur Complex Engineer 18. Davina Peterson, Exxon, Chemical Plant 19. Chris Laskoskie, Exxon, CLEU#2 20. Lillian Sandeval, Exxon, Chem Plant Utilities Contract Engineer 21. Jim Kitchens, Exxon, DCU Operator 22. Sadir Shah, Exxon, Technician 23. Tom McClurg, Exxon, Dock Operator 24. Tim Bales, Exxon 25. Rodney Putt, Exxon, ECC Shift Team Leader 26. Juan Rodriguez, HPC Field Supervisor 27. Anthony Ardoin, HPC Utility Technician 28. John Dadurian, HPC Supervisor 29. Peter McKenzie, HPC, Camera Technician 30. John Godbee, Exxon, Supervisor 31. Ignacio Cruz Sanchez, Exxon, Process Technician 32. Lee Trader, Exxon, Shift Team leader 33. Molcom Goudeaux, Exxon Business Team Lead 34. Carl Cramer, Exxon, Shift Team Lead Fuels 35. Jack Dunn, Exxon, Process Mechanical Coordinator Contact Email Address: kara.moore@exxonmobil.com Purpose of Inspection: Inspect the benzene waste operations and volatile organic compounds (VOC) emissions from wastewater systems Facility Type: Petroleum Refinery, Chemical Plant, and Olefins Plant Regulations Central to Inspection: Refinery wastewater subject to the Standards of Performance for VOC Emissions from Petroleum Refinery Wastewater Systems, at 40 C.F.R. Part 60, Subpart QQQ (Subpart QQQ), and the National Emissions Standards for Hazardous Air Pollutants for Benzene Waste Operations, at 40 C.F.R. Part 61, Subpart FF (Subpart FF or BWON) Arrival Time: May 6, 2024, 2:30 pm Departure Time: May 10, 2024, 12:39 pm Inspection Type: Unannounced Inspection Announced Inspection Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Not a Small Business Provided CBI warning to facility The following information was obtained verbally from Exxon personnel unless otherwise noted. Process Description: The Baytown Refinery began operations in 1920 and became an Exxon Corporation refinery in 1972. The Baytown Refinery includes a refinery, chemical plant, and an olefins plant. XOM has split the refinery (BTRF), chemical plant (BTCP), and olefins units (BOP) into three sources for purposes of compliance with Subpart FF. The refinery has chosen the 6 Megagram per year (6 MG) option, while the chemical plant and the olefins unit each have chosen the 2 Megagram per year (2 MG) option. XOM indicated that BTRF, BOP, and BTCP operate under different Title V permits and different organizational structure, except that shared environmental services, and thus each part of the Baytown complex can have a separate Subpart FF compliance strategy and total annual benzene report. In addition, controlled wastewater streams and controlled slop oil streams from the BOP and the BTCP are managed at the BTRF. At XOM, stormwater is fully integrated into the BTRF, partially integrated for the BOP, and segregated for the BTCP. At the BTRF's wastewater treatment plant, XOM stated that Subpart FF and Subpart QQQ do not apply. XOM indicated that generally Method 21 monitoring is performed using a flame ionization detector, and Method 21 breakthrough monitoring at carbon canisters is performed with a benzene-select photoionization detector. XOM reported that Method 21 monitoring is conducted by Clean Harbors, which recently acquired HydroChem PSC, and visual inspections are conducted by XOM operators. Staff Interviews: EPA requested interviews from XOM to better understand how wastewater is managed or treated across the refinery, chemical plant, and olefins unit. XOM provided the following individuals: A. May 7, 2024 at 12:30 pm: Kayla Thorsteinson, Exxon, Sulfur Complex Engineer Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 The olefins plant, chemical plant, and the refinery all send wastewater streams to the stripper feed tanks, 1032 and 1033. Each of these tanks has an external floating roof (EFR) and an oil skimming system. Typically, any oil skimmed is sent over once a week but no less frequent than once per month to the refinery's slop system. XOM uses two benzene steam strippers, T071 and T081, that vent vapors to the sulfur recovery unit and wastewater effluent continues to the east sewer line. Both strippers are designed with an identical capacity of 50,000 barrels per day. The effluent wastewater from each of the strippers is about 100-120 degrees Fahrenheit. For the sour water system, XOM operates two trains, each with two feed drums that route material to one of the stripper feed tanks, 1026 and 2000, then to another feed drum and finally onto one of three strippers, T051, T061, or T853. T051 and T061 are identical in capacity, and T853 has a smaller capacity. XOM uses the sour water exemption in Subpart FF for the wastewater streams that meet the qualifications. B. May 7, 2024 at 1 pm: Davina Peterson, Exxon, Chemical Plant EPA asked Ms. Peterson a few questions regarding the flow and location of wastewater generated from specific equipment at XOM's chemical plant. Ms. Peterson stated that she is not familiar with any wastewater or oil movements, where the wastewater or oil is generated within the chemical plant, or how wastewater or oil is sent from specific equipment to other parts of the refinery. C. May 8, 2024 at 1:15 pm: Lillian Sandeval, Exxon, Chemical Plant, Utilities, Contract Engineer XOM operates a benzene steam stripper, T150, that routes vapors to a flare through D-152 and sends effluent wastewater to the west sewer trunk. If T150 is down, the wastewater stream is not immediately sent over to the refinery. XOM operations manages which and when wastewater streams are sent over. Some wastewater streams are continuous and feed tanks, 1032 and 1033. XOM's chemical plant also sends over slop oil through tanks, 905 and 907, which are slop oil tanks used by the refinery, olefins plant, and chemicals unit. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: 1. Wash Slab: XOM indicated that the wash slab area is subject to Subpart QQQ. EPA observed that two ground level drains (Drains 1 and 2) had oily water pooled over them. In addition, EPA was unable to walk to the frac tank without water boots in this area since the walkway to the frac tank had an oily water level of 2-3 inches for at least a 25-foot length by 10 feet wide distance. The wastewater from the frac tank was discharged to an uncovered manhole. XOM indicated that the stream is not subject to Subpart QQQ at the manhole. Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 2. EPA requested that XOM show EPA inspectors how operators conduct visual inspections for Subpart FF in the CLEU #2 unit by walking the inspectors through XOM's visual inspection route. XOM personnel were in possession of the document used by operations for identifying the route to be used in conducting visual inspections. After observing approximately 7 pieces of equipment subject to Subpart FF visual inspections, XOM personnel stated that EPA inspectors had seen everything subject to Subpart FF in this unit. However, in response to EPA's onsite document request, the visual inspection document provided by XOM identified an additional 5 pieces of equipment that XOM operators did not show EPA inspectors during the visual inspection of CLEU #2. EPA inspectors advised XOM that for the remaining portion of the inspection, EPA expected XOM to provide complete and accurate information. 3. During the Method 21 monitoring at lift station, LS076, Ms. Madison Kettler, XOM's leak detection and repair coordinator, asked Clean Harbors what an instrument flameout was after EPA detected a flameout in the field. 4. Some of XOM personnel, including Mr. Adetayo, provided feedback to the FLIR optical gas imaging noting differences; however, the XOM personnel were not certified to use the FLIR camera. 5. All Subpart FF or other NESHAP lines from the docks are routed to Tank 38. 6. XOM indicated that several floating roof tanks subject to Subpart FF, including monitoring for breakthrough on the carbon canister by the docks, required a fresh breathing air apparatus ("fresh air"). XOM does not have a specific written procedure or policy requiring fresh air on the floating roof tanks or any signage at the stairwell of the tank for operators who are going up to the platform on top of the tank. Two EPA inspectors (Colleen McCarthy and Constantinos Loukeris) were provided fresh air by XOM to monitor the following tanks from the platform at the top of the tank's stairwell: TK 1001, TK 905, TK 907, TK 1071, TK 1499, and TK 2000. 7. XOM operates a vacuum truck unloading station at the ECC unit, which receives waste and wastewater from the BTRF, BOP and BTCP. The vacuum trucks unload to Pit 1, which XOM operates as an uncontrolled waste management unit for purposes of Subpart FF compliance. On May 10, 2024, EPA observed a vacuum truck with carbon canisters that was unloading waste to Pit 1. XOM personnel had previously stated that the vacuum trucks with carbon canisters are used for waste or wastewater streams requiring control under Subpart FF. 8. During the tank cleaning of Tank 1032, XOM utilized an air mover to pull solids into vacuum boxes. These solids are sent off-site for removal, and the empty vacuum boxes return to XOM. EPA observed detectable emissions on several vacuum boxes collecting solids from Tank 1032. Additionally, the discharge from the air mover was connected to ductwork that vented to the atmosphere from the top of the platform at Tank 1032 while it was in operation. Photos and/or Videos: were taken during the inspection and are listed in Appendix A. EPA imaged hydrocarbon emissions using a FLIR optical gas imaging camera, Models GF-320 and GFx-320. In addition, this FLIR camera was also used to take digital pictures and videos. See Appendix A for a summary of the videos and pictures taken. Field Measurements: were taken during this inspection and are listed in Appendix B. Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 EPA conducted Method 21 monitoring and testing using Thermo Scientific's Toxic Vapor Analyzers, Model 2020, equipped with a flame ionization detector. See Appendix B for the summary of the monitoring and testing. EPA also collected six summa canisters that are being analyzed per Method TO-15. The results of the summa canisters are pending. Summa Canister Location Summary: 1. LS204 2. LS239 3. LS265 4. LS204 5. ECC P3 Hatch 6. 3053 TWD Pump# 91B CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: 1. Wastewater flow diagrams, including a description or color-coding indicating compliance points for Benzene Waste NESHAP (BWON) and NSPS Subpart QQQ 2. Total Annual Benzene Reports - most recent 5 years, including supporting calculations and/or sampling 3. Quarterly BWON Reports - most recent 5 years 4. Visual Inspection records for BWON - most recent 5 years 5. Detectable Emission Testing Results for BWON and NSPS Subpart QQQ (Method 21)- most recent 5 years 6. Repair Records for detectable emissions and visual inspection deficiencies, including information required by 40 C.F.R. 61.356(h) 7. Database of Detectable Emission testing and visual inspection results, including calibration and repair records 8. Engineering Design Documentation for each waste management unit and treatment process required by 40 C.F.R. 61.356(d) 9. Carbon Canister Design Evaluations for Each Carbon System (BWON and NSPS Subpart QQQ) 10. Carbon Canister Breakthrough Monitoring results for Each System (BWON and NSPS Subpart QQQ) - most recent 5 years 11. Individual Drain Systems (IDS) for BWON and NSPS Subpart QQQ - identification of all components and respective compliance strategy 12. Semi-Annual NSPS Subpart QQQ Reports - most recent 5 years 13. Database and/or records of NSPS Subpart QQQ visual inspection results - most recent 5 years 14. Parametric Monitoring Data for Treatment Processes - most recent 5 years 15. Process units and/or IDS grandfathered under NSPS Subpart QQQ 16. Floating Roof Tanks Complying with NSPS Kb (For either BWON or QQQ) - Most recent API 653 and primary seal/secondary seal inspection report Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 17. End of Line Sampling Results for past 2 years 18. BWON Manual 19. NSPS QQQ Manual 20. Exxon's Corporate Policy for BWON and QQQ 21. Vacuum Truck Log - past 5 years: Include destination of each vacuum truck, operated with a control device or counted against the BWON compliance option for the respective site 22. When did Exxon begin operation of the temporary system regarding Lift Station 243. Provide MOC and/or other documentation as to demonstrating compliance under BWON and QQQ 23. List of all the BWON (e.g. NESHAP tagged in the field) sampling points, description, which line item in the TAB each location correlates to, location and most recent 5 years of sampling results. (including separator 13,14, 15, and 17) 24. MOC or other documentation of why access was not allowed to conduct visual inspection in the DCU on May 9, 2024 25. Status of document request from EPA email on May 6, 2024. 26. CBT training for the environmental stewards. I think we wanted to see if there is any wastewater info within the training modules 27. Blank QQQ form for CDU 28. Crosswalk of sample data points (from the process flow diagrams) and how that corresponds to the TAB 29. HU9 (subject to QQQ) sewer diagram noting drains and all access points Concerns: At the closing conference, EPA identified the follow areas of concern: 1. XOM has improperly split up its refinery, olefins, and chemical plant into three total annual benzene reports with separate compliance strategies for Subpart FF. EPA pointed to the regulatory definitions of "petroleum refinery," defined as "a facility engaged in producing gasoline, kerosene, distillate fuel oils, residual fuel oils, lubricants, or other products through the distillation of petroleum, or through the redistillation, cracking, or reforming of unfinished petroleum derivatives and to "Facility," defined as "all process units and product tanks that generate waste within a stationary source, and all waste management units that are used for waste treatment, storage, or disposal within a stationary source." 2. As one facility under Subpart FF, XOM would not be able to comply with any of the three compliance options in Subpart FF (6 MG, 2 MG, and 1 MG) 3. XOM did not identify all of its points of generation in the annual TAB reports as required by Subpart FF for at least the past 5 years. 4. In its TAB reports, XOM does not account for all benzene emissions in the TAB that have been volatilized to atmosphere based on its sampling locations. See for example, separators 13, 14, 15, 17, and 19. 5. XOM's lift station, LS 265, which supports the benzene loading dock, is not designed or operated to no detectable emissions and also had significant visible defects. 6. Based on the number of visible defects EPA found including an opening to atmosphere in a manhole, XOM's visual inspections are not identifying defects as required by Subpart FF and Subpart QQQ. Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 7. XOM is sending vacuum trucks that require control with Subpart FF standards to Pit 1, which is operated as an uncontrolled waste management unit. 8. XOM did not design or operate the barscreen with no detectable emissions as required0020under Subpart FF after EPA detected greater than 500 ppm from the door accessing the barscreen area. 9. Based on the number of detectable emissions and design issues with waste management units across the Baytown complex, XOM may not be complying with the 6 MG or 2 MG compliance options in Subpart FF. 10. During the inspection, XOM was operating a temporary sewer line due to extended maintenance being performed at lift station, LS 243. XOM did not evaluate any applicability and compliance with Subpart QQQ for the new individual drain system that had been used for multiple months. DIGITAL SIGNATURES CONSTANTIN CONSTANTINOS LOUKERIS Digitally signed by Date: 2024.07.09 15:07:50 Report Author: ___O__S__L_O_U_K_E__R_I_S_-0_5'0_0'_______________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL Date: 2024.07.09 _____M_A__R_S__H_A_L__L__1_5:_30_:1_8 _-05_'0_0'__________ Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log 2. Appendix B: Field Measurement Data 3. Appendix C: Method 21 Calibration Data 4. Appendix D: Subpart QQQ Observations Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Constantinos Loukeris and Videos Archival Record Location: May 2024 Inspection - Pictures Image Number 1 File Name FLIR0037.jpg 2 FLIR0038.jpg 3 FLIR0039.jpg 4 FLIR0040.jpg 5 FLIR0041.jpg 6 FLIR0042.jpg 7 FLIR0043.jpg 8 FLIR0044.mp4 9 FLIR0045.mp4 10 FLIR0046.mp4 11 FLIR0047.mp4 12 FLIR0048.jpg 13 FLIR0049.jpg 14 FLIR0050.jpg 15 FLIR0051.jpg 16 FLIR0052.jpg Camera C027003 C027003 C027003 C027003 C027003 C027003 C027003 C027003 C027003 C027003 C027003 C027003 C027003 C027003 C027003 C027003 Date 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/7/2024 Time 10:18 10:19 10:44 10:48 10:50 10:52 10:52 11:23 14:50 14:51 14:55 15:21 15:30 16:37 16:38 16:52 Inspector McCarthy McCarthy McCarthy McCarthy McCarthy McCarthy McCarthy McCarthy Loukeris Loukeris Loukeris McCarthy McCarthy McCarthy McCarthy McCarthy Image description Dewatering Pump 186-10 historic leak Overview of Dewatering Pump 186-10 including drain Conservation Vent at P-6 and P259-5 pump area Liquid leak at valve. LDAR Tag NETF 11 0066 Liquid leak at V09028 fill to Tk 1070. Back of liquid leak at V09028 fill to Tk 1070. Back of liquid leak at V09028 fill to Tk 1070. Hydrocarbon (HC) emissions from open-ended line plug on P194-10. Oil ring observed Incidental video HC emissions from east vacuum breaker on Tank 1033 HC emissions from seal and east vacuum breaker on Tank 1033 Flange on vacuum box Drain clogged at slop pump PS258 P-5 Wash Slab near drain 1 Wash Slab near drain 2 Frac Tank at Wash Slab Notes - - - Kosta TVA: 2900ppm - - - - Haynes has box number. Haynes TVA: 1600 confirmed by HPC at bottom of flange along gasket - Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 Hazardous Waste Satellite Accumulation with no accumulation start date near 17 FLIR0053.jpg C027003 5/8/2024 10:19 McCarthy D-8 in CLEU. - 18 FLIR0054.jpg C027003 5/8/2024 15:10 McCarthy Lift Station 076 hatch - 19 FLIR0055.jpg C027003 5/8/2024 15:15 McCarthy Lift Station 076 hatch No gasket. Retrofitted plate. Kosta TVA 400 then flameout on hinge Lift Station 076. Cracks and 20 FLIR0056.jpg C027003 5/8/2024 15:19 McCarthy gaps. - Lift Station 076. Cracks and 21 FLIR0057.jpg C027003 5/8/2024 15:32 McCarthy gaps. - 4 Spot 1 Dock overview of 22 FLIR0058.jpg C027003 5/8/2024 15:55 McCarthy catch basin - HC emissions from unbolted 23 FLIR0059.mp4 C027003 5/8/2024 16:36 McCarthy cover on Lift Station 239 - HC emissions from visible crack 24 FLIR0060.mp4 C027003 5/8/2024 16:40 McCarthy in sealant on Lift Station 265 - HC emissions from pump cover observed with gaps on Lift 25 FLIR0061.mp4 C027003 5/8/2024 16:52 McCarthy Station 265 - Overview of Lift Stations 265 26 FLIR0062.jpg C027003 5/8/2024 16:55 McCarthy and 239 - Visible gap in sealant/caulk on Area of 27 FLIR0063.jpg C027003 5/8/2024 16:59 McCarthy Lift Station 265 Video 24 28 FLIR0064.jpg C027003 5/8/2024 16:59 McCarthy Overview of Lift Station 265 - 29 FLIR0065.jpg C027003 5/8/2024 17:00 McCarthy Side of Lift Station 265 - Rusted piping on Lift Station 30 FLIR0066.jpg C027003 5/8/2024 17:00 McCarthy 239 - Unbolted cover and debris on 31 FLIR0067.jpg C027003 5/8/2024 17:01 McCarthy Lift Station 239 - 32 FLIR0068.jpg C027003 5/8/2024 17:01 McCarthy Lift station 239 - 33 FLIR0069.jpg C027003 5/9/2024 9:45 McCarthy Solid drain behind P610A DCU 34 FLIR0070.jpg C027003 5/9/2024 9:52 McCarthy Manhole cover near E-617 - 35 FLIR0071.jpg C027003 5/9/2024 10:09 McCarthy Dry drain at P-619A - 36 FLIR0072.jpg C027003 5/9/2024 10:13 McCarthy Incidental photo - 37 FLIR0073.jpg C027003 5/9/2024 10:15 McCarthy Manhole cover in DCU - 38 FLIR0074.jpg C027003 5/9/2024 10:16 McCarthy DHX3P18 dry drain - 39 FLIR0075.jpg C027003 5/9/2024 10:17 McCarthy MH3P27 Manhole cover - MHCB3P25 Manhole cover 40 FLIR0076.jpg C027003 5/9/2024 10:23 McCarthy missing caulking - Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 41 FLIR0077.jpg C027003 5/9/2024 10:24 McCarthy MHCB3P17 Catch basin - 42 FLIR0078.jpg C027003 5/9/2024 10:25 McCarthy MHCB316 Catch basin - 43 FLIR0079.jpg C027003 5/9/2024 10:26 McCarthy Manhole in DCU - MHCB3N05 Manhole cover 44 FLIR0080.jpg C027003 5/9/2024 10:28 McCarthy with sand - Manhole cover rusted and 45 FLIR0081.jpg C027003 5/9/2024 10:38 McCarthy covered in liquid. - near tank 46 FLIR0082.mp4 C027003 5/9/2024 10:44 McCarthy HPC monitoring manhole cover 601 Manhole cover open with cone near tank 47 FLIR0083.jpg C027003 5/9/2024 10:47 McCarthy in center 601 Manhole cover open with cone near tank 48 FLIR0084.jpg C027003 5/9/2024 10:47 McCarthy in center 601 49 FLIR0085.jpg C027003 5/9/2024 11:52 McCarthy MH7 Manhole cover SCU MH7 Manhole cover opened to check for water seal. HC 50 FLIR0086.mp4 C027003 5/9/2024 11:53 McCarthy emissions - MH1 Manhole cover opened to check for water seal. HC 51 FLIR0087.mp4 C027003 5/9/2024 11:58 McCarthy emissions - HC emissions at preseparator 52 FLIR0088.mp4 C027003 5/9/2024 14:41 Loukeris 14 - HC emissions at preseparator 52 FLIR0089.mp4 C027003 5/9/2024 14:44 Loukeris 13 - NESHAP FF sample point between pumps 2 and 3 at 53 FLIR0090.jpg C027003 5/9/2024 14:51 McCarthy preseparators 13 and 14 - EPA 15,000ppm; HC emissions from NESHAP FF HPC 54 FLIR0091.mp4 C027003 5/9/2024 14:52 McCarthy sample point at preseparators 18,000ppm HC emissions from sump cover between pumps 3 and 4 at 55 FLIR0092.mp4 C027003 5/9/2024 14:55 McCarthy preseparators 13 and 14 - EPA Sump cover between pumps 3 20,000ppm; and 4 at preseparators 13 and HPC 56 FLIR0093.jpg C027003 5/9/2024 14:56 McCarthy 14 20,000ppm Unbolted sump covers with holes and no seal at 57 FLIR0094.jpg C027003 5/9/2024 14:57 McCarthy preseparators - 58 FLIR0095.jpg C027003 5/9/2024 15:02 McCarthy Gap in preseparator 13 EPA 7500ppm, HPC 7500ppm Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 Gap and missing concrete at 59 FLIR0096.jpg C027003 5/9/2024 15:07 McCarthy preseparator 13 - 60 FLIR0097.jpg C027003 5/9/2024 15:18 McCarthy Preseparator 15 - 61 FLIR0098.jpg C027003 5/9/2024 15:19 McCarthy Preseparator 15 - 62 FLIR0099.jpg C027003 5/9/2024 15:19 McCarthy Preseparator 15 - 63 FLIR0100.jpg C027003 5/9/2024 15:20 McCarthy Preseparator 15 - 64 FLIR0101.mp4 C027003 5/9/2024 15:22 McCarthy Incidental video - 65 FLIR0102.jpg C027003 5/9/2024 15:22 McCarthy Preseparator 15. Liquid leak. - HC emissions at preseparator 66 FLIR0103.mp4 C027003 5/9/2024 15:23 McCarthy 15 - HC emissions at Temporary Lift EPA 1,100 67 FLIR0104.mp4 C027003 5/9/2024 15:26 Loukeris Station Assembly ppm HC emissions at hole in Pit 1 oil EPA 15,000 68 FLIR0105.mp4 C027003 5/9/2024 15:42 McCarthy sump. ppm 69 FLIR0106.jpg C027003 5/9/2024 15:44 McCarthy Open inlet to Pit 1 - 70 FLIR0107.jpg C027003 5/9/2024 15:46 McCarthy Holes throughout Pit 1 - 71 FLIR0108.jpg C027003 5/9/2024 15:51 McCarthy Incidental photo - EPA 2400 HC emissions from cracked ppm, HPC 72 FLIR0109.mp4 C027003 5/9/2024 15:51 McCarthy concrete on corner of Pit 1 2700ppm HC emissions from inlet of Pit 1 while active vacuum truck 73 FLIR0110.mp4 C027003 5/9/2024 16:13 McCarthy unloading - HC emissions from inlet of Pit 1 while active vacuum truck 74 FLIR0111.mp4 C027003 5/9/2024 16:14 McCarthy unloading - Labeled piping to tanks from 75 FLIR0112.jpg C027003 5/9/2024 16:26 McCarthy Slab 112 - 76 FLIR0113.jpg C027003 5/10/2024 9:04 McCarthy Tank 1001 roof - 77 FLIR0114.jpg C027003 5/10/2024 9:22 Loukeris Incidental photo - HC emissions from seal on 78 FLIR0115.mp4 C027003 5/10/2024 9:23 Loukeris Tank 907 - 79 FLIR0116.mp4 C027003 5/10/2024 10:32 McCarthy HC emissions from Tank 1499 - 80 FLIR0117.mp4 C027003 5/10/2024 11:26 Loukeris HC emissions from Tank 2000 - 81 FLIR0160.jpg C027001 5/7/2024 16:00 Roll off boxes at Wash Lab - 82 FLIR0161.mp4 C027001 5/8/2024 10:18 Haynes Digital video at connector leak - Photo of connector leak in 83 FLIR0162.jpg C027001 5/8/2024 9:19 Haynes CLEU 2 - Photo of LV204, D-22 sour 84 FLIR0163.jpg C027001 5/8/2024 9:43 Haynes water to sour water unit - Photo of crack in cement 85 FLIR0165.jpg C027001 5/8/2024 14:54 Haynes around drain line at Dock 1 - 86 FLIR0166.jpg C027001 5/8/2024 15:56 Haynes Photo at LS204 - EPA 87 FLIR0167.mp4 C027001 5/8/2024 16:58 Haynes HC emissions at hole in LS204 15,000ppm Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 88 FLIR0168.jpg C027001 5/8/2024 16:01 Haynes Photo at LS203 - Photo of vapor line on 89 FLIR0169.jpg C027001 5/8/2024 16:02 Haynes pressure side of PVRV at LS204 - 90 FLIR0170.jpg C027001 5/8/2024 16:03 Haynes Photo of PVRV at LS204 - EPA Photo of leaking bolt at 760ppm, vacuum box V250496 from HPC 91 FLIR0171.jpg C027001 5/9/2024 9:11 Haynes T1032 1668ppm Photo of air mover used to fill 92 FLIR0172.jpg C027001 5/9/2024 9:32 Haynes vacuum box - Photo of vapor discharge line from air mover used to fill 93 FLIR0173.jpg C027001 5/9/2024 9:32 Haynes vacuum box - 94 FLIR0174.mp4 C027001 5/9/2024 14:48 Haynes Incidental Video - EPA 30,000ppm, Photo of separator 17 lid for HPC 95 FLIR0175.jpg C027001 5/9/2024 14:51 Haynes HCU 30,000ppm HC emissions from HC sink in EPA 96 FLIR0176.mp4 C027001 5/9/2024 16:25 Haynes lab 10,000ppm HC emissions from acid station 97 FLIR0177.mp4 C027001 5/9/2024 16:33 Haynes in lab - 98 FLIR0178.jpg C027001 5/9/2024 15:56 Haynes Incidental Photo - EPA 5,000ppm, HC emissions from sump lid HPC 99 FLIR0179.mp4 C027002 5/9/2024 16:56 Haynes behind lab 5,000ppm APPENDIX B: FIELD MEASUREMENT DATA Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 Date 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/7/2024 5/8/2024 5/8/2024 5/8/2024 5/8/2024 5/8/2024 5/8/2024 5/8/2024 Area Component Near Tank 1032/1033 - Container (V250596) - Bottom of gasket Tag: NETF 11 0066 Gasoline Water Draws Wash Slab Tag: OM1-4571 (V09028) Open-ended closure device on valve behind pump 194-P10 Rolloff Container (RT-251825) Wash Slab Rolloff Container (RT-251205) CLEU#2 LS239 LS 265 LS 265 LS 265 Flare Knock Out Drum - Sample Line Access Hatch North side of cover East side of cover South side of cover LS 265 LS 265 Manhole on top of cover South side of cover (Different location than above) EPA Reading (ppm) 1,600 - 2,900 14,000 760 205 - 9,000 3,400 750 3,600 2,900 1,600 XOM Reading (ppm) 1,600 Notes - - 6,392 37,908 Visible liquid (not actively dripping) Visible liquid Oily ring on plug 580 - - >500 >500 >500 >500 >500 >500 Not sealed, contains sludge/oily waste Tear in tarp cover, exchanger sludge Stain and liquid droplet on bottom of line Not bolted - 1.5 foot of detectable emission interface - - 5/8/2024 5/8/2024 5/8/2024 5/8/2024 5/8/2024 5/8/2024 5/8/2024 5/8/2024 5/8/2024 5/8/2024 5/8/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 LS 265 CLEU#2 LEFU LS097 LS097 LS204 LS204 LS204 LS076 LS076 Dock LS204 LS204 FCCU3 FCCU3 FCCU3 Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 West side of cover 2,800 Tag # 975.1 1,000 Drain under Flare #3 Knockout, D- 016 Hatch 47 1,700 Drain west of hatch Sump 635 15,100 Hatch (1 side) Hatch (other side) Hatch Elevated concrete hatch 6,000 4,000 >10,000 (flameout) 350 4-spot pit Cover Hatch Sump 19 P-17, vacuum Breaker P-17, manhole 275 1 inch from water level 15,000 6,000 550 3,400 1,100 >500 1,044 - >500 >500 13,000 2,156 3,572 Flameout - - >500 >500 1,900 2,403 1.5 foot of detectable emission interface XOM indicated component is on delay of repair - Hinge to hatch had missing caulk - Hole in sump corner Hole in caulk Hole in caulk At hinge Visible cracks in the concrete surrounding the square opening Wastewater level in pit, open to atmosphere Hole in cover Gap Latch - Hole in caulk around manhole adjacent to pump 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/10/2024 5/10/2024 FCCU3 FCCU3 Lab Lab Lab Lab Lab Lab ECC ECC ECC ECC ECC ECC ECC ECC ECC ECC ECC Hydrocracker ECC BTCP Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 P-17, manhole 22,000 P-17, kick hatch Post 4 Distillation Post Manual Ash Post Acid Post Sump Between P2 and P3 Between P3 and P4 Separator 13 Separator 15 Separator 14 Pit 1 Pit 1 Pit 1 Pit 1 Pit 1, fill hose (N) Pit 1, fill hose (S) Separator 17 Cover Door to Barscreen House # 14 12167 720 10,100 90,100 2,700 7,700 19,000 5,000 15,000 20,000 7,500 1,700 3,000 15,000 8,500 2,400 1,400 1,100 1,050 30,000 1,700 11,000 11,982 270 6,200 18,000 20,000 7,500 1,500 >500 2,700 30,000 1,850 8,000 Different hole in caulk around manhole adjacent to pump Hydrocarbon 4 Lid Separator 13/14 Separator 13/14 Gap/opening to atmosphere Gap/opening to atmosphere Gap/opening to atmosphere Hole in sump cover on slab Grated opening hole Crack in concrete Side Wall - - Suction line from 3053 TWD Pump# 91B Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 APPENDIX C: METHOD 21 CALIBRATION DATA Cylinder Information: Zero Air: Green Light Safety Lot# 269794 Expiration Date: 09/2025 500 ppm Methane: Green Light Safety Lot# 304-402311271-1 Expiration Date: 12/23/2025 2,000 ppm Methane: Gasco Lot# 304-402415357-1 Expiration Date: 04/20/2026 10,000 ppm Methane: Green Light Safety Lot# 304-402244727-1 Expiration Date: 10/04/2025 Daily Calibration: May 7, 2025, 8:25 am 500 ppm 2,000 ppm 10,000 ppm May 8, 2025, 9:05 am 500 ppm 2,000 ppm 10,000 ppm May 9, 2025, 8:55 am 500 ppm 2,000 ppm 10,000 ppm May 9, 2025, 6:40 pm 500 ppm 2,000 ppm 10,000 ppm May 10, 2025, 8:00 am 500 ppm 2,000 ppm 10,000 ppm B39303 476 1,931 9,844 B39303 477 1,908 10,100 B39303 502 1,942 9,932 Bump Check 570 2,200 11,300 B39303 499 1,975 9,804 B39302 1,990 10,100 B39302 513 2,020 10,300 B39302 497 2,012 10,000 For B39303 E04884 504 1,987 10,400 E04884 505 1,997 10,000 - APPENDIX D: SUBPART QQQ OBSERVATIONS Facility Name: Exxon Mobil Corporation Facility Location: 5000 Bayway Drive, Baytown, Texas 77520 Date of Inspection: May 6-10, 2024 Date 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 5/9/2024 Unit DCU DCU DCU DCU DCU DCU DCU DCU DCU DCU DCU DCU DCU DCU DCU DCU SCU-2 SCU-2 Component 619 A 618A Drain by IP008 circuit breaker Manhole (MH 3P27) Manhole (MHCB 3P25) SC962 SC 961 Manhole left of E617 Manhole right of E617 Manhole located at north side of unit, east of deluge Southwest of manhole (MHCB 3P17) Manhole (MHCB 3P16) Manhole (MHCB 3P15) Manhole (MHCB 3P05) Manhole by 644B Manhole by crane/outer road OWS 2 OWS 10 Observation No water seal Oily water No water seal Over half covered in black tarry material Missing caulk Solidified material in drain No water seal Partially covered by rocks Partially covered by rocks Debris covering good portion of manhole Tarry material covering manhole Missing caulk Missing caulk Debris covering good portion of manhole Partially under water Cone in manhole sample opening, open to atmosphere (250 ppm) No water seal No water seal (10 inches)