Document 79p4Q8jeod0VVDMm9bveexj8

EPA Inspection Report-Page 1 of 89 EPA Inspection Report-Page 2 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Section I - INTRODUCTION PURPOSE OF THE INSPECTION Jim Gold and I (Prince Nfodzo), Environmental Protection Agency (EPA) Region 6 inspectors, conducted an inspection of Phillips 66 Company (Phillips 66) Alliance Refinery from August 15, 2016 through August 18, 2016. The Alliance Refinery is located at 15551 Highway 23 S, Belle Chasse, Louisiana. We arrived at the facility August 15, 2016 at 13:58 hours and went through the required facility safety training. Mr. Daniel Odem and Ms. Davina Witte from the Louisiana Department of Environmental Quality (LDEQ) joined the inspection on August 15-16, 2016 and August 17-18, 2016, respectively. On August 15, 2016, the inspection team met with representatives of the Alliance Refinery at 14:40 for an opening conference for introductions and briefing on the purpose and an overview of the inspection. Jim Gold presented his EPA Inspector credentials, and I presented a letter of authorization to participate in Clean Air Act inspections to Mr. Larry Poche, HSE Manager. Jim informed the representatives that this was an EPA inspection to evaluate implementation of the requirements in the federally-issued consent decree (CD), which is a national priority for EPA. On August 18, 2016, the inspection team met with the refinery representatives at 11:30 hours for the closing conference and presented preliminary findings of the inspection. We informed the representatives of the procedures that will follow the field inspection, and that the inspection report will be made public on EPA's website. The sign-in sheets for the opening and closing conferences are included as Appendix 2. The CD (Civil Action H-01-0258), which was originally entered August 5, 2005, consists of 19 Parts designated by Roman numerals and has been amended four times and filed as follows: First Amendment 01/11/2007; Second Amendment 08/11/2008; Third Amendment 02/28/2012; and Fourth Amendment 07/31/2012. The inspection was a Partial Compliance Evaluation (PCE) that focused on Part V which requires affirmative relief to address nitrogen oxides (NOx), sulfur dioxide (SO2), carbon monoxide (CO), particulate matter (PM), volatile organic compounds (VOCs), and benzene emission reductions through various construction projects, process additives, and process and program enhancements. The inspection included an evaluation of four marquee issues: NOx and SO2 reductions, leak detection and repair (LDAR), benzene waste operations NESHAPs (BWON), and flaring acid gases and hydrocarbons. 2 EPA Inspection Report-Page 3 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 FACILITY OVERVIEW The Alliance Refinery produces a wide range of petroleum products from crude oil, including liquefied petroleum gas (LPG), motor gasoline, jet fuel, diesel, carbon black feedstock, propane, propylene and coke, as well as petrochemicals, including benzene, toluene, xylene, and elemental sulfur. The permitted processing rate for the facility is 260,000 barrels crude oil input per day. A plant-wide process flow diagram and detailed facility description is included as APPENDIX 3. Section II - OBSERVATIONS PART V: AFFIRMATIVE RELIEF/ENVIRONMENTAL PROJECT A. NOx Emissions Reduction from FCCUs Status: On Schedule Program Summary: Phillips 66 will implement a program as set forth in Paragraphs 13-54 to reduce NOx emissions from the covered FCCUs, will incorporate lower NOx emission limits at the covered FCCUs into permits, and will demonstrate future compliance with the lower emission limits through the use of continuous emission monitoring systems (CEMS). Alliance Refinery notified EPA of Phillips 66's agreement to comply with NOx emission limits of 20 ppmvd on a 365-day rolling average basis and 40 ppmvd on a 7-day rolling average basis, at 0% oxygen, effective 12/31/2014, per letter dated 6/24/2010. Phillips 66 has incorporated the NOx emission limits in permit number 1810-V8 AA issued August 14, 2015. Alliance Refinery installed a selective catalytic reduction (SCR) unit with ammonia injection in order to meet NOx emission limits. We observed that Phillips 66 has installed and is operating NOx and O2 CEMS in accordance with the applicable requirements, and certification and concentrations of calibration gases were accurate and current. We verified that Phillips 66 conducted cylinder gas audits (CGA) and relative accuracy test audits (RATA) for the period January 2013 through June 2016 in accordance with the applicable requirements. Photographs of the CEMS are included as Photo No. 1 and No. 2 in Appendix 1. The trends for the FCCU NOx emission limits of 20 ppmvd on a 365-day rolling average basis, and 40 ppmvd on a 7-day rolling average basis, at 0% oxygen from December 2015 - July 2016 are included as Appendix 4. No exceedances of the limits occurred during the period. We verified the Ammonia injection for the period July 2015 through June 2016. B. SO2 Emissions Reduction from FCCUs Status: On Schedule Program Summary: Phillips 66 will implement a program to reduce SO2 emissions from the covered FCCUs as set forth in Paragraphs 56-75. Phillips 66 will incorporate the lower SO2 emission limits at the covered FCCUs into permits, and will demonstrate future compliance with the lower emission limits 3 EPA Inspection Report-Page 4 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 through the use of CEMS. Alliance Refinery is required to comply with SO2 emission limits of 25 ppmvd on a 365-day rolling average basis, and 50 ppmvd on a 7-day rolling average basis, at 0% oxygen, effective 12/31/2009. Phillips 66 has incorporated the SO2 emission limits in permit number 1810-V8 AA issued August 14, 2015. Alliance Refinery installed a wet gas scrubber (WGS), Photo No. 3 in Appendix 1, in order to meet SO2 emission limits. We observed that Phillips 66 has installed and is operating SO2 and O2 CEMS in accordance with the applicable requirements, and certification and concentrations of calibration gases were accurate and current. We verified that Phillips 66 conducted CGA and RATA for the period January 2013 through June 2016 in accordance with the applicable requirements. Photographs of the CEMS are included as Photo No. 1 and No. 2 in Appendix 1. The trends for the FCCU SO2 emission limits of 25 ppmvd on a 365-day rolling average basis, and 50 ppmvd on a 7-day rolling average basis, at 0% oxygen from July 2015 - June 2016 are included as Appendix 5. No exceedances of the limits occurred during the period. C. PM Emissions Reduction from FCCUs Status: On Schedule Program Summary: Phillips 66 will implement a program to reduce PM emissions from the covered FCCUs as set forth in Paragraphs 77-83. Phillips 66 will incorporate the lower PM emission limits at the covered FCCUs into permits, and will demonstrate future compliance with the lower emission limits through annual performance testing. Alliance Refinery is required to comply with PM emission limits of 0.5 pound PM per 1000 pounds of coke burned on a 3-hour average basis determined by testing following test methods specified in 40 C.F.R. 60.106(b)(2), effective 12/31/2009. Phillips 66 has incorporated the PM emission limits in permit number 1810-V8 AA issued on August 14, 2015. We verified that Phillips 66 conducted annual PM performance testing for the years 2013 through 2015 in accordance with the applicable requirements. No exceedances of the limits occurred during the period. D. CO Emissions Reduction from FCCUs Status: On Schedule Program Summary: Phillips 66 will incorporate the lower CO emission limits at the covered FCCUs into permits, and will demonstrate future compliance with the lower emission limits through the use of CEMS. Alliance Refinery is required to comply with CO emission limits of 100 ppmvd on a 365-day rolling average basis, and 500 ppmvd on a 1-hour average basis, at 0% oxygen, effective 09/30/2005. The CO emission limits have been properly incorporated in permit number 1810-V8 AA issued August 14, 2015. Prior to the CD agreement, Alliance Refinery had installed a boiler in order to meet CO emission limits. We observed that Phillips 66 has installed and is operating CO and O2 CEMS in accordance with the applicable 4 EPA Inspection Report-Page 5 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 requirements, and certification and concentrations of calibration gases were accurate and current. We verified that Phillips 66 conducted CGA and RATA for the period January 2013 through June 2016 in accordance with the applicable requirements. A photograph of the CEMS is included as Photo No. 2 in Appendix 1. The trends for the FCCU CO emission limits of 100 ppmvd on a 365-day rolling average basis and 500 ppmvd on a 1-hour average basis, at 0% oxygen from July 2015 - June 2016 are included as Appendix 6. No exceedances of the limits occurred during the period. E. NSPS Applicability of FCCU-Catalyst Regenerators Status: On Schedule, except that AMP parameter limits have not been incorporated in permit. Program Summary: The FCCU catalyst regenerators will be subject to and will comply with NSPS Subparts A and J for SO2, PM and CO. Phillips 66 will demonstrate compliance with NSPS opacity limits through the use of continuous opacity monitoring system (COMS) or with an EPA approved alternative monitoring plan (AMP). EPA approved Alliance Refinery's AMP for monitoring opacity in lieu of COMS per letter dated June 24, 2014. The approved AMP requires the Alliance Refinery to monitor parameters on the wet gas scrubber (WGS) and comply with minimum liquid-to-gas (L/G) ratio of 29.8 gallons per 1000 actual cubic feet (G/KACF) on a 3-hour rolling average basis, and minimum slurry liquid circulation pump discharge pressure (Pdisch) of 125.8 pounds per square inch (psig) on a 3-hour rolling average basis. Phillips 66 has not incorporated the WGS scrubber parameter limits, L/G ratio and slurry liquid circulation pump discharge pressure in the refinery's Title V operating permit (see AOC #1). The trends for the L/G ratio and Pdisch limits from July 2015 - June 2016 are included as Appendix 7. Exceedances of the limits occurred during the period. According to Alliance Refinery representatives, the exceedances of L/G ratio and Pdisch in July 2015, and L/G ratio in February 2016 were due to power failure, and planned shutdown, respectively. EPA will review the company's excess emissions report for this period separately, and will determine whether these exceedances will result in stipulated penalties. F. NOx Emissions Reduction from Combustion Units Status: On Schedule Program Summary: Phillips 66 will implement a program to reduce and monitor NOx emissions from the combustion units, will incorporate lower NOx emission limits at the covered combustion units into permits, and will demonstrate future compliance with the lower emission limits through the use of CEMS. Alliance Refinery is required to comply with NOx emission limits of 0.040 lb/MMBtu and 0.0185 lb/MMBtu on a 365-day rolling average basis for ten (10) and one (1) combustion units, respectively. Phillips 66 has incorporated the NOx emission limits in permit numbers: 1810-V8 AA issued August 14, 2015 for unit 1291- H2/H3 (common stack); 2180-V4 issued May 13, 2013 for Unit 191-H1; 2512-V4 issued July 7, 2014 for units 491-H1 and 491-H2; 2775-V5 issued August 14, 2015 for units 291-H2, 1391-H1, 1391-H2/H3 (common stack), 1391-H4 and 1792-H1. 5 EPA Inspection Report-Page 6 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Alliance Refinery operates eleven (11) combustion units, out of which ten (10) are equipped with ultra-low NOx burners (ULNB), and one (1) has selective catalytic reduction (SCR) control devices in order to meet NOx emission limits. We observed that Phillips 66 has installed and is operating NOx and O2 CEMS on all covered combustion units in accordance with the applicable requirements, and certification and concentrations of calibration gases were accurate and current. We verified that Phillips 66 conducted CGA and RATA for the period January 2013 through June 2016 in accordance with the applicable requirements. Photographs of the CEMS and NOx control devices are included as Photo Nos 4-10, 12-14 and 16-19 in Appendix 1. The trends for the combustion units' NOx emission limits on a 365-day rolling average basis, at 0% oxygen from July 2015 - June 2016 are included as Appendix 8. Alliance Refinery exceeded the 365-day rolling average emission limit of 0.040 lb/MMBtu for Unit 1391-H2/H3 for the period January 24, 2016 through March 14, 2016. According to Alliance Refinery representatives, the exceedance was the result of low firing during shutdown, regeneration, and startup of the unit. EPA will review the company's excess emissions report for this period separately, and will determine whether these exceedances will result in stipulated penalties. No other exceedances of the emission limits occurred during the period. G. SO2 Emissions Reduction from and NSPS Applicability to Heaters and Boilers Status: On Schedule Program Summary: The covered heaters and boilers will be subject to and comply with the applicable requirements of NSPS Subparts A and J for fuel gas combustion devices. Phillips 66 will not burn fuel oil in any existing combustion device. Alliance Refinery is required to comply with H2S emission limits of 162 ppmv on a 3-hour rolling average basis for fuel gas combusted in heaters and boilers. Phillips 66 has incorporated the H2S emission limits, and the requirement that Phillips 66 will not burn fuel oil in any existing combustion device in the refinery's permits. Alliance Refinery monitors the fuel gas into the heaters and boilers at units 1391 and 301-B-3 and 491 in order to meet H2S emission limits. We observed that Phillips 66 has installed and is operating the H2S CEMS in accordance with the applicable requirements, and certification and concentrations of calibration gases were accurate and current. We verified that Phillips 66 conducted CGA and RATA for the period January 2013 through June 2016 in accordance with the applicable requirements. Photographs of the CEMS are included as Photo No. 21 and No. 22 in Appendix 1. The trends for the combustion units' H2S emission limits on a 3-hour rolling average basis from July 2015 - June 2016 are included as Appendix 9. Alliance Refinery exceeded the 3-hour rolling average emission limit of 162 ppmv in July 2015. No other exceedances of the emission limit occurred during the period. H. NSPS Applicability of Sulfur Recovery Plants Status: On Schedule Program Summary: Sulfur recovery plants will be subject to and comply with the applicable requirements 6 EPA Inspection Report-Page 7 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 of NSPS Subparts A and J. Phillips 66 will incorporate SO2 emission limits into permits, and will demonstrate future compliance with the lower emission limits through the use of CEMS. The CD requires the Alliance Refinery to comply with SO2 emission limits of 250 ppm on a 12-hour rolling average basis at all tail gas emission points. Phillips 66 has incorporated the SO2 emission limit in permit number 2774-V4 issued July 17, 2014. Alliance Refinery operates a sulfur recovery unit (SRU), and monitors SO2 emissions at the tail gas emission point in order to meet SO2 emission limits. We observed that Phillips 66 installed and is operating SO2 CEMS in accordance with the applicable requirements, and certification and concentrations of calibration gases were accurate and current. We verified that Phillips 66 conducted CGA and RATA for the period January 2013 through June 2016 in accordance with the applicable requirements. A photograph of the CEMS is included as Photo No. 20 in Appendix 1. The trends for the SRU SO2 emission limits on a 12-hour rolling average basis from July 2015 - June 2016 are included as Appendix 10. No exceedances of the limit occurred during the period. J. NSPS Applicability of Flaring Devices Status: On Schedule Program Summary: Phillips 66 will operate flaring devices in compliance with NSPS applicability. Alliance Refinery elected to operate and maintain a flare gas recovery system to control continuous or routine combustion in the flaring devices and is required to comply with H2S emission limits of 162 ppmv on a 3-hour rolling average basis for fuel gas combusted in the flares. Phillips 66 has incorporated the NSPS requirements into permit number 2779-V3 issued July 25, 2012. Alliance Refinery operates two flares (high and low pressure) and has installed and is operating a flare gas recovery system, routing the recovered flare gas to amine treating for use in the refinery fuel gas system, and monitors H2S and total reduced sulfur (TRS) concentrations with gas chromatograph (GC) and TRS analyzer, respectively. Photographs of the flare gas recovery system and monitoring equipment are included as Photo Nos. 23-27 in Appendix 2. We observed that Phillips 66 has wrongly labeled the TRS Analyzers in the field for both flares (see AOC #2). The trends for the flare gas recovery and H2S emission limits on a 3-hour rolling average basis from July 2015 - June 2016 are included as Appendix 11 and 12, respectively. We verified that Alliance Refinery properly documented and reported exceedances of limits during the period. We did not observe visible emissions from the flares. We observed the flares with the forward looking infra- red (FLIR) camera and did not see any significant trail of unburned hydrocarbons. N. Benzene Waste Operations NESHAP Program Enhancements Status: On Schedule 7 EPA Inspection Report-Page 8 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Program Summary: Phillips 66 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 Phillips 66 shall undertake refinery wide measures to minimize or eliminate fugitive benzene waste emissions at the refinery. The CD requires the Alliance Refinery to implement the 6BQ compliance option of Subpart FF using upstream controls, and replace any single carbon canisters (CCs) or dual canister systems in parallel with primary and secondary CCs, and operate them in series. A schematic of the BWON process is included as APPENDIX 13. Compliance sampling conducted at the outlet of strippers from July 2015 - June 2016 is included as APPENDIX 14. We verified that Phillips 66 took appropriate corrective actions regarding exceedances of the 10 ppm limit required by NESAHP Subpart FF that occurred on July 2, 2015, July 27, 2015, and April 21, 2016. We reviewed the sampling procedure and standard operating procedures (SOPs) that Phillips 66 uses. The procedures were written in a formal SOP and consistent with BWON sampling techniques required by 40 CFR 61.355. We verified that Phillips 66 conducted annual employee training and lab audits as required. Alliance Refinery has engaged the services of Evoqua and ERM for monitoring, and scheduling the monitoring of the CCs, respectively. We observed that Phillips 66 monitored CC breakthrough, and conducted waste sampling consistent with regulatory requirements and the SOP. O. Leak Detection and Repair (LDAR) Program Enhancements Status: On Schedule Program Summary: In order to minimize or eliminate fugitive emissions of volatile organic compounds (VOCs), benzene, volatile hazardous air pollutants (VHAPs), and organic hazardous air pollutants (HAPs) from equipment in light liquid and/or in gas/vapor service, Phillips 66 will undertake enhancements to its LDAR program including to develop and maintain a written LDAR program for compliance with all regulations, conduct LDAR training, conduct internal and third party audits, maintain an electronic database for storing and reporting data, and retain a third party contractor to develop and implement procedures for QA/QC reviews of data generated by monitoring. Alliance Refinery retains the services of a contractor (Guardian Compliance) to conduct LDAR services. We verified that Alliance Refinery conducts beginning and end of day drift checks, as required by the CD. We observed that Phillips 66 carried out the calibration of instrument (Thermo Scientific TVA-1000) accurately. We verified that certification and concentrations of calibration gases were accurate and current, and that Alliance Refinery uses electronic data collection for LDAR monitoring by using data loggers, and leak tracking and reporting software (LEAK DAS V4). We reviewed records which showed that Phillips 66 consistently maintains equipment calibration records and conducts annual training and audits, as required. We walked through the units and observed that components were properly tagged, and we noticed one open-ended line (see AOC #3). We 8 EPA Inspection Report-Page 9 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 queried the LDAR monitoring and reporting software with randomly selected tag numbers from the units, and we did not find any discrepancy except for the one open-ended line. P. Incorporation of Consent Decree Requirements into Federally Enforceable Permits Status: Ongoing Program Summary: Phillips 66 will submit complete applications to the applicable state/local agency to incorporate the emission limits and standards required by the CD into federally enforceable minor or major new source review permits or other permits that will ensure that the underlying emission limit or standard survives the termination of this CD. Alliance Refinery has incorporated all the required emission limits and standards into current operating permits, except for the limits of monitoring parameters for an EPA approved AMP in lieu of COMS. The AMP was approved June 24, 2014. Section III - AREAS OF CONCERN 1. Phillips 66 has not incorporated the Wet Gas Scrubber operating parameter limits approved in the June 24, 2014 AMP in lieu of COMS into their Title V operating permit as required by Paragraph 257 of the CD. 2. The TRS analyzer for the flares have been mislabeled in the field. 3. Alliance Refinery is required to equip each open-ended valve or line with a cap, blind flange, plug, or second valve. We observed one open-ended line in the field. Section IV - FOLLOW UP N/A Section V - LIST OF APPENDICES Appendix 1 - Photograph Log Appendix 2 - Opening and closing conference sign-in sheets Appendix 3 - Plant wide process flow diagram and written description Appendix 4 - FCCU NOx emission trends Appendix 5 - FCCU SO2 emission trends Appendix 6 - FCCU CO emission trends Appendix 7 - FCCU L/G ratio and Discharge pressure trends Appendix 8 - Combustion units NOx emission trends Appendix 9 - Fuel gas H2S emission trends Appendix 10 - SRU SO2 emission trends Appendix 11 - Flare gas recovery trends 9 EPA Inspection Report-Page 10 of 89 Appendix 12 - Flare H2S emission trends Appendix 13 - BWON process schematic Appendix 14 - Benzene stripper outlet concentration trends Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 10 EPA Inspection Report-Page 11 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Appendix 1 Photograph Log 6ENFORM-019-R3 (11/14/2013) EPA Inspection Report-Page 12 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: NOx = 10 ppm IMG_0001.JPG 08/17/2016 9:52 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery FCCU Wet Gas Scrubber (WGS) NOx and SO2 CEMS Page 1 of 29 EPA Inspection Report-Page 13 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: O2 = 3.49% CO = 6.61 ppm IMG_0002.JPG 08/17/2016 9:53 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery FCCU WGS O2 and CO CEMS Page 2 of 29 EPA Inspection Report-Page 14 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: IMG_0003.JPG 08/17/2016 9:59 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery FCCU WGS Page 3 of 29 EPA Inspection Report-Page 15 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: NOx = 14 ppm IMG_0004.JPG 08/17/2016 10:02 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 1291-H2/H3 NOx CEMS Page 4 of 29 EPA Inspection Report-Page 16 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: O2 = 11.92% IMG_0005.JPG 08/17/2016 10:03 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 1291-H2/H3 O2 CEMS Page 5 of 29 EPA Inspection Report-Page 17 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: IMG_0006.JPG 08/17/2016 10:06 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 1291-H2 Ultra-low NOx Burner (ULNB) Page 6 of 29 EPA Inspection Report-Page 18 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: IMG_0007.JPG 08/17/2016 10:08 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 1291-H3 ULNB Page 7 of 29 EPA Inspection Report-Page 19 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: NOx = 23 ppm IMG_0008.JPG 08/17/2016 10:17 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 491-H1 NOx CEMS Page 8 of 29 EPA Inspection Report-Page 20 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: O2 = 6.44% IMG_0009.JPG 08/17/2016 10:17 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 491-H1 O2 CEMS Page 9 of 29 EPA Inspection Report-Page 21 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: NOx = 24 ppm IMG_0010.JPG 08/17/2016 10:18 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 491-H2 NOx CEMS Page 10 of 29 EPA Inspection Report-Page 22 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: H2S = 23.86 ppm IMG_0019.JPG 08/17/2016 10:30 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Refinery Fuel Gas H2S CEMS Page 11 of 29 EPA Inspection Report-Page 23 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: NOx = 4.2 ppm IMG_0020.JPG 08/17/2016 10:41 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 191-H1 NOx CEMS Page 12 of 29 EPA Inspection Report-Page 24 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: NOx = 10.9 ppm IMG_0021.JPG 08/17/2016 10:46 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 291-H2 NOx CEMS Page 13 of 29 EPA Inspection Report-Page 25 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: IMG_0022.JPG 08/17/2016 10:50 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 291-H2 ULNB Page 14 of 29 EPA Inspection Report-Page 26 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: IMG_0023.JPG 08/17/2016 10:52 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Carbon Canister (CC) set-up Page 15 of 29 EPA Inspection Report-Page 27 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: NOx = 18 ppm IMG_0024.JPG 08/17/2016 10:56 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 1792-H1 NOx CEMS Page 16 of 29 EPA Inspection Report-Page 28 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: NOx = 26 ppm IMG_0026.JPG 08/17/2016 11:09 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 1391-H2/H3 NOx CEMS Page 17 of 29 EPA Inspection Report-Page 29 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: NOx = 23 ppm IMG_0027.JPG 08/17/2016 11:10 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 1391-H4 NOx CEMS Page 18 of 29 EPA Inspection Report-Page 30 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: NOx = 18 ppm IMG_0029.JPG 08/17/2016 11:11 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 1391-H1 NOx CEMS Page 19 of 29 EPA Inspection Report-Page 31 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: SO2 = 41 ppm IMG_0030.JPG 08/17/2016 11:28 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Sulfur Recovery Unit (SRU) SO2 CEMS Page 20 of 29 EPA Inspection Report-Page 32 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: IMG_0031.JPG 08/17/2016 11:37 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Heater 1391-H1 Fuel Gas H2S CEMS Page 21 of 29 EPA Inspection Report-Page 33 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: H2S = 24.35 ppm IMG_0032.JPG 08/17/2016 11:43 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Boiler 301-B3 Fuel Gas H2S CEMS Page 22 of 29 EPA Inspection Report-Page 34 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: IMG_0033.JPG 08/17/2016 2:06 pm Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery High Pressure Flare Gas Chromatograph (GC) for H2S monitoring (Labeled wrongly as TRS Analyzer) Page 23 of 29 EPA Inspection Report-Page 35 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: IMG_0034.JPG 08/17/2016 2:07 pm Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Low Pressure Flare Gas Chromatograph (GC) for H2S monitoring (Labeled wrongly as TRS Analyzer) Page 24 of 29 EPA Inspection Report-Page 36 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: IMG_0037.JPG 08/17/2016 2:24 pm Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Flare Gas Recovery Compressors Page 25 of 29 EPA Inspection Report-Page 37 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 26 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: IMG_0038.JPG 08/17/2016 2:31 pm Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Low Pressure Flare Total Reduced Sulfur (TRS) Analyzer Page 26 of 29 EPA Inspection Report-Page 38 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 27 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: IMG_0039.JPG 08/17/2016 2:33 pm Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Low Pressure Flare TRS Analyzer Page 27 of 29 EPA Inspection Report-Page 39 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 28 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: IMG_0001.JPG 08/18/2016 10:12 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Benzene Stripper Outlet Sampling Point Page 28 of 29 EPA Inspection Report-Page 40 of 89 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 29 Location: Phillips 66 Company - Alliance Refinery City: Belle Chasse Plaquemines Parish State: LA Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: IMG_0002.JPG 08/18/2016 10:12 am Tom Morgan, Environmental Team Lead, Phillips 66 Alliance Refinery Benzene Stripper Outlet Sampling Point Page 29 of 29 EPA Inspection Report-Page 41 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Appendix 2 Opening and closing conference sign-in sheets EPA Inspection Report-Page 42 of 89 EPA Inspection Report-Page 43 of 89 EPA Inspection Report-Page 44 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Appendix 3 Plant-wide process flow diagram and written description EPA Inspection Report-Page 45 of 89 EPA Inspection Report-Page 46 of 89 Phillips 66 Alliance Refinery Facility Overview Phillips 66 Company owns and operates Alliance Refinery, a petroleum refinery located in Belle Chasse, Louisiana. Figure 1-1 shows the location of the Phillips 66 Company-Alliance Refinery (Alliance Refinery). The Alliance Refinery produces a wide range of petroleum prodncts from crude oil such as LPG, motor gasoline, jet fuel, diesel, carbon black feedstock, propane, propylene, and coke. The Refinery also produces petrochemicals such as benzene, tolnene, xylene, and elemental sulfur. Emission sources at the refinery include process heaters, boilers, storage vessels, loading facilities, fugitive emissions from equipment, cooling water towers, process vents, diesel driven air compressors, wastewater collection and treatment operations, and flares. Unit 191/7991 - Crude/Sat Gas Unit 191 - Crude Unit is designed to process crude oil into the following unit products, unstabilized naphtha, light vacuum gas oil, light furnace oil, heavy vacuum gas oil, heavy furnace oil, vacuum tower bottoms, atmospheric gas oil, and atmospheric tower bottoms. Preheated crude enters the desalters where salts, water, aud sediment are removed. The crude furnace heats the crude before it enters the atmospheric tower for fractionation into the products listed above. The lighter oils are extracted from the tower top sections. The heavier oils feed the crude vacuum tower unit for distillation under a vacuum to recover gas oils. The atmospheric tower bottoms are heated and enter the vacuum tower. The overhead vapors are burned in a furnace. The overhead liquid is recycled to the crude charge. The heaviest material, vacuum tower bottoms, is used as coker feed stock. Unit 7991 - Saturate Gas Unit recovers propane and heavier products from various refine1y liquids and vapors containing primarily saturated hydrocarbons. The unit produces the following products: propane, mixed butanes, light straight run gasoline, and straight run gasoline. The unit consists of two sections, the debutanizer section and the absorber stripper-fractionation section. In the debutanizer section, the crude unit naphtha is processed and sent on as feedstock to the Naphfining Unit. The absorber-stripper-fractionator section produces the propane/butane feedstock for the alkylation unit. Unit 293 - Gulfiner Unit 293 Gulfining Unit hydrogenates and desulfurizes a mixture of cracked furnace oils to produce a product suitable for blending into diesel fuel. The hydrodesulfurization is accomplished by treating the furnace oil mixture with hydrogen in the presence of a catalyst (hydro-treating process) at an elevated temperatnre. Cracked furnace oil is combined with separator off-gas from the Naphfining Unit (Unit 291) and then heated before being fed to the reactor. In the reactor, the combined feed stream flows through a series of five catalyst beds within the reactor vessel. The reactor effluent is cooled to 350 degrees Fahrenheit and flashed to produce a vapor. This vapor is cooled and flashed again to produce recycle hydrogen and quench hydrogen gas. The net production of separator (hydrogen-rich) off-gas is sent to the amine contactor for hydrogen sulfide removal and is used as Thermal Hydrodealkylation Unit make-up hydrogen and fuel gas. The liquids produced by the flash separations of the reactor effluent are fractionated in the stabilizer. The Gulfiner light furnace oil and heavy furnace oil from the stabilizer are cooled and sent to storage as a blend stock for diesel. EPA Inspection Report-Page 47 of 89 EPA Inspection Report-Page 48 of 89 EPA Inspection Report-Page 49 of 89 EPA Inspection Report-Page 50 of 89 EPA Inspection Report-Page 51 of 89 EPA Inspection Report-Page 52 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Appendix 4 FCCU NOx emission trends EPA Inspection Report-Page 53 of 89 45.00 40.00 35.00 30.00 25.00 20.00 15.00 10.00 5.00 0.00 31-Dec-15 00:00:00 FCCU NOx Consent Decree Trend (12/31/2015 - 7/31/2016) 365-day Rolling Average 365-day Limit 7-day Rolling Average 7-day Limit 31-Jan-16 00:00:00 29-Feb-16 00:00:00 31-Mar-16 00:00:00 30-Apr-16 00:00:00 31-May-16 00:00:00 30-Jun-16 00:00:00 31-Jul-16 00:00:00 ppm EPA Inspection Report-Page 54 of 89 FCCU NOx 365-day Consent Decree Limit Trend (12/31/2015 7/31/2016) Hourly Average 365-day Average 365-day Consent Decree Limit 60.00 50.00 40.00 ppm 30.00 20.00 10.00 0.00 31-Dec-15 00:00:00 31-Jan-16 00:00:00 29-Feb-16 00:00:00 31-Mar-16 00:00:00 30-Apr-16 00:00:00 31-May-16 00:00:00 30-Jun-16 00:00:00 31-Jul-16 00:00:00 EPA Inspection Report-Page 55 of 89 FCCU NOx 7-day Consent Decree Limit Trend (12/31/2015 - 7/31/2016) Hourly Average 7-day Average 7-day Consent Decree Limit 60.00 50.00 40.00 ppm 30.00 20.00 10.00 0.00 31-Dec-15 00:00:00 31-Jan-16 00:00:00 29-Feb-16 00:00:00 31-Mar-16 00:00:00 30-Apr-16 00:00:00 31-May-16 00:00:00 30-Jun-16 00:00:00 31-Jul-16 00:00:00 EPA Inspection Report-Page 56 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Appendix 5 FCCU SO2 emission trends EPA Inspection Report-Page 57 of 89 EPA Inspection Report-Page 58 of 89 EPA Inspection Report-Page 59 of 89 EPA Inspection Report-Page 60 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Appendix 6 FCCU CO emission trends EPA Inspection Report-Page 61 of 89 EPA Inspection Report-Page 62 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Appendix 7 FCCU L/G ratio and Discharge pressure trends EPA Inspection Report-Page 63 of 89 EPA Inspection Report-Page 64 of 89 EPA Inspection Report-Page 65 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Appendix 8 Combustion units NOx emission trends EPA Inspection Report-Page 66 of 89 EPA Inspection Report-Page 67 of 89 EPA Inspection Report-Page 68 of 89 EPA Inspection Report-Page 69 of 89 EPA Inspection Report-Page 70 of 89 EPA Inspection Report-Page 71 of 89 EPA Inspection Report-Page 72 of 89 EPA Inspection Report-Page 73 of 89 EPA Inspection Report-Page 74 of 89 EPA Inspection Report-Page 75 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Appendix 9 Fuel gas H2S emission trends EPA Inspection Report-Page 76 of 89 EPA Inspection Report-Page 77 of 89 EPA Inspection Report-Page 78 of 89 EPA Inspection Report-Page 79 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Appendix 10 SRU SO2 emission trends EPA Inspection Report-Page 80 of 89 EPA Inspection Report-Page 81 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Appendix 11 Flare gas recovery trends EPA Inspection Report-Page 82 of 89 EPA Inspection Report-Page 83 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Appendix 12 Flare H2S emission trends EPA Inspection Report-Page 84 of 89 EPA Inspection Report-Page 85 of 89 EPA Inspection Report-Page 86 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Appendix 13 BWON process schematic EPA Inspection Report-Page 87 of 89 EPA Inspection Report-Page 88 of 89 Phillips 66 Company / Alliance Refinery Inspection Dates 08/15-18/2016 Appendix 14 Benzene stripper outlet concentration trends EPA Inspection Report-Page 89 of 89