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Environmental Protactign
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Agency
Region 6 Compliance Assurance and Enforcement Division
INSPECTION REPORT
Inspection Date(s): Media: Regulatory Program(s)
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Contact
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F,RS Number: Identification/Permit Number: Media Number: NAICS: SIC:
Facility Representatives:
EPA Inspectors: State lnspector(s):,_
6/16-18/2014 '
Air
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Consent Decree, Civil Action SA-05-CA-0569
Valero Refining- Texas, L.P. Valero Port Arthur Refinery 1801 South Gulfway Dr. Port Arthur, TX 77640 P.O. Box909 Port Arthur, TX 77641-0909 Jefferson County Paula LaRocca Paula',larocca@valero.com
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I Manager Environmental Engineering
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NSR 6825A, PS[)-TX-49, N65, 0-0149B, 0-02229, 0-02227, 0-02228, 0-03423
AFS # 4824500004
324110
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2911
Paula LaRocca
Jim Gold DNA
. Manager Environmental Engr. Region 6, 6EN-ASH TCEQ Region 10
409/985-1200 281/983-2153
Other lnspector(s):
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."..' Subject:
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EPA Lead'1nspector Signature/Date
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Supervisor Signature/Date
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Valero Refining, Port Arthur Refinery, Port Arthur, Texas, Jefferson County US EPA Region 6 Compliance Assurance and Enforcement Division Dallas TX Partial Compliance Evaluation Inspection Report refinery consent decree (CD)
Jim Gold ~ ./:J_fi_U
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Samuel Tates NV!,, _jl 1~
1/17 /Zollj
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6ENFORM019-R3 (11/14/2013) EPA Inspection Report page 1 of 109
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION
EPA Region 6 inspector Jim Gold conducted an inspection of the Valero Refining - Port Arthur Refinery. At 1:30 pm on June 16, 2014, I met with Paula LaRocca, Manager Environmental Engineering for the facility, for an opening conference. I presented my credentials to Ms. LaRocca and informed her that this was an EPA inspection to determine compliance with the federally issued Consent Decree (Civil Action SA-05-CA-0569-RF). The Consent Decree (CD) is listed in 72 Federal Register notice 50124 as SA-07-CA- 0683-RF which is an addendum to Consent Decree CA-05-CA-0569-RF. The addendum is a result of the September 1, 2005 merger between Premcor Inc. and Valero Energy Corporation. The inspection was a Partial Compliance Evaluation (PCE), which included an evaluation of the consent decrees (CD) four marquee issues: NOx/SO2 reductions, leak detection and repair (LDAR), benzene waste operations (BWON) and flaring of both acid gases and hydrocarbons.
The CD consists of 26 Parts designated by Roman numerals. Of these, Parts IV - XIV requires affirmative relief, which was a 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. Each item in Parts IV - XIV was addressed. Note that these inspection findings pertain only to the compliance status affecting Valero's Port Arthur refinery. Photos taken during the inspection (26) are included as Appendix 1. A sign in sheet for the opening conference is included as Appendix 2.
FACILITY DESCRIPTION
The facility was originally built in 1901 and was acquired by Valero in 2007. The facility has had multiple upgrades and now has the capacity to refine 415,000 barrels per day and operates as a fully integrated refinery with crude distillation, FCCU, alkylation (hydrofluoric), catalytic reforming, hydrodesulphurization, sulfur recovery, and fuel blending. Main products are motor gasoline, diesel fuel, jet fuel, and fuel oil. Crude oil is obtained primarily by ship and pipeline, products leave the facility by pipeline, tank truck, and marine shipping. A plant wide process flow diagram is included in Appendix 3. An in-house CD tracking chart is included as Appendix 4.
A detailed list of processes and descriptions can be found in Appendix A of the CD. The CD can be accessed via internet at http://www2.epa.gov/sites/production/files/documents/valero-premcor-cd.pdf
6ENFORM-019-R3 (11/14/2013) EPA Inspection Report page 2 of 109
Valero, Port Arthur Refinery 6/19-22/2014
Section II - OBSERVATIONS
Part IV, NOx Emissions Reductions from Heaters and Boilers
Status: Complete.
Program Summary: Valero will implement a program to reduce NOx emissions from refinery heaters and boilers greater than 40 Million British Thermal Units (MMBTU)/hr by committing to an interim, system-wide weighted average concentration emission limit for NOx of 0.060 lbs/MMBTU to be achieved by December 31, 2009. A final, system-wide weighted average concentration emission limit for NOx of 0.044 lbs/MMBTU is to be achieved by December 31, 2011.
APPENDIX 5 is a list of up to date heaters and boilers at the refinery with greater than 40 MMBTU/hr heat input. Boilers at Boiler House 16 were taken out of service as a result of CD imposed emission limits. I observed the Continuous Emission Monitors (CEMs) monitoring the heaters and boilers and observed that the calibration gases were of the correct concentration and up to date. A complete list of CEMs required by the consent decree is included as APPENDIX 6. I reviewed the relative accuracy test audit (RATA) results for each heater and boiler 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 recorded NOx emission trends for the heaters and boilers equipped with NOx Continuous Emission Monitors (CEMs) from June 2013 - June 2014. The trends also include individual emission limits for the heaters and boilers. The emission trends demonstrate compliance with the 365 day NOx rolling average limits for the 12 months before the inspection.
Part V, NOx Emissions Reductions from FCCUs
Status: Complete.
Program Summary: Valero will implement a program to limit NOx emissions from its FCCU regenerators and CO boilers by achieving a system-wide average of unit-specific NOx concentration emission limits for each FCCU. This will be achieved by implementing certain emission control systems or otherwise satisfying the NOx emission standards.
NOx from the FCCU is controlled by controlling oxygen levels in the regenerator.
Valero has set a final, 365 day rolling average of 50 parts per million (ppm). APPENDIX 8 is the FCCU NOx emission trends from June 2013 - June 2014, which demonstrates compliance for the 12 months preceding the inspection.
I 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 each heater and boiler CEMs and found the relative accuracies for the CEMs to be within allowable requirements of 40 CFR, Part 60, Appendix F.
EPA Inspection Report page 3 of 109
Valero, Port Arthur Refinery 6/19-22/2014
Part VI, SO2 Emission Reductions from FCCUs Status: Complete.
Program Summary: Valero shall implement a program to reduce SO2 emissions from their FCCUs, which shall include the installation of wet gas scrubber ("WGS") technology systems on selected FCCUs and otherwise limiting SO2 emissions from other FCCUs, including, in certain cases, through the use of SO2 reducing catalyst additives and/or hydrotreating.
Appendix 9 contains a trend for FCCU SO2 emissions from June 2013 - June 2014, which demonstrates compliance with the 25 ppm, 365 day rolling average emission limit. The FCCU is equipped with SO2, NOx, and O2 CEMs. I 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 the FCCU CEMs and found the relative accuracies for the CEMs to be within allowable requirements of 40 CFR, Part 60, Appendix F. Valero uses a wet gas scrubber to control SO2 emissions.
Part VII, CO, Opacity and Particulate Emissions from FCCUs
Status: Complete.
Program Summary: Valero shall implement a program to limit CO and particulate emissions from their FCCUs and shall implement monitoring of each FCCU sufficient to demonstrate compliance with emission standards specified in this Part.
Valero's Port Arthur FCCU operates in full burn mode and the regenerator stack is controlled for particulate matter by a wet gas scrubber. An Alternative Monitoring Plan (AMP) to monitor the FCCU wet scrubber parameters rather than an opacity monitor was approved on June 20, 2014.
APPENDIX 10 contains the FCCU CO emission trend from June 2013 - June 2014. The one hour 500 ppm limit was exceeded several times in the 12 months preceding the inspection due to various upset conditions. I 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 FCCU CEMs and found the relative accuracies for the CEMs to be within allowable requirements of 40 CFR, Part 60, Appendix F.
I observed that the opacity from the FCCU regenerator stack was less than 5% throughout the inspection.
Part VIII, NSPS Applicability to SO2 Emissions from FCCU Regenertors
Status: Complete.
Program Summary: Valero shall comply with all requirements of 40 CFR Part 60, Subparts A and J for SO2 emissions from the FCCU regenerator.
APPENDIX 9 is an SO2 emission trend, which demonstrates continuous compliance with NSPS Subparts A and J (50 ppmwd 7 day and 25 ppmwd 365 day rolling averages). I observed that the SO2 CEM was properly installed and that calibration gas was of the correct concentration and up to date.
EPA Inspection Report page 4 of 109
Valero, Port Arthur Refinery 6/19-22/2014
Part IX, SO2 and NSPS Requirements for Heaters and Boilers Status: Complete. Program Summary: Valero shall undertake the following measures at Valero Refineries covered by this Consent Decree to reduce SO2 emissions from heaters and boilers by eliminating or minimizing the burning of fuel oil and complying with 40 C.F.R. Part 60, Subparts A and J, as such provisions apply to fuel gas combustion devices. APPENDIX 11 contains a description and schematic of the three fuel gas systems. Fuel gas H2S trends from June 2013 to June 2014 is included as APPENDIX 12 which demonstrates that the 162 ppm H2S limit imposed by NSPS is being met, with the exception of various upsets conditions. I observed that the three H2S analyzers were installed correctly and that the calibration gas was of the correct concentration and up to date.
Part X, Benzene Waste NESHAP Program Enhancements Status: Complete. Program Summary: Valero shall undertake measures set forth in Part X establishing enhancements to 40 CFR Part 61, Subpart FF ("Benzene Waste NESHAP) to minimize or eliminate fugitive benzene waste emissions.
Valero's Port Arthur refinery is implementing the 6BQ compliance option of Subpart FF using upstream controls. A schematic of the process is included as APPENDIX 13. The facility does not use stripping technology to remove benzene from waste waters.
Valero's Port Arthur refinery is using 29 carbon canister stations to control benzene emissions as shown in APPENDIX 14. I reviewed the carbon canister sampling data and practices. The canisters are all arranged in series as required (with sampling points located between the primary and secondary canisters). The sampling data indicates that all canisters are being sampled anywhere from daily to monthly based on break through frequency. The end of line sampling plan required by paragraph 164 of the CD has previously been submitted to EPA.
I reviewed the sampling procedure and standard operating procedures (SOPs) used by the facility and found the procedures written in a formal SOP and consistent with BWON sampling techniques required by 40 CFR 61.355.
I reviewed the most recent BWON storage tanks inspection records. The tanks seals are being inspected annually as required (using industry standard techniques)
EPA Inspection Report page 5 of 109
Valero, Port Arthur Refinery 6/19-22/2014
Part XI, Leak Detection and Repair Program Enhancements Status: Complete. Program Summary: Valero shall undertake the measures listed in Part XI to enhance the Valero's Port Arthur Refinerys LDAR program.
Third party audits, periodic reports and other requirements of Part XI of the consent decree have been previously reported to EPA and TCEQ.
Valero's Port Arthur refinery uses TEAM Inc. to conduct repairs and follow-up monitoring. TEAM personnel are authorized to make first attempt at repair on most valves. Chronically leaking components are tracked and replaced. Drill and tap repair techniques are being used on leaking valves if the 500 ppm limit is exceeded and cannot be repaired using conventional methods. The plant wide delay of repair list up to date and lists 29 components, which will require a shut down for repair. I reviewed instrument calibration logs. TEAM 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.
I walked through the HCU -943, HCU 942, DCU 843, AVU 147, AVU 146, SRU 545, SRU 546 and CRU 1344 process units and observed no open ended lines or valves.
Part XII, Program Enhancements RE: NSPS Subparts A and J SO2 Emissions from Claus Sulfur Recovery Plants and Flaring Status: Complete. Program Summary: Beginning immediately upon the lodging of this Consent Decree, Valero agrees to take the following measures at all of its SRPs and certain flaring devices at Valero's Refineries. Valero will install additional equipment at certain refineries to achieve additional SO2 emission reductions and further reduce flaring incidents. Valero will implement procedures for root cause analysis of acid gas and hydrocarbon flaring incidents and tail gas incidents at all refineries.
The facility operates ten flares. Eight of the flares are tied into flare gas recovery. The number 5 flare (used for emergencies and maintenance operations) and the number 13 flare (serving the Alkylation unit) are not tied into flare gas recovery systems. There are three flare gas recovery systems at the
EPA Inspection Report page 6 of 109
Valero, Port Arthur Refinery 6/19-22/2014
facility: Flare Gas Recovery Units (FGRU) 7042, 7043 and 7044. FGRU 7042 recovers gas from flares 23 and 26. FGRU 7043 recovers gas from flares 15, 18 and 20. FGRU 7044 recovers gas from flares 19, 22 and 103B. The FGRU compressors are liquid ring sealed. During the inspection I observed the FGRU's compressors using an infrared optical imaging device and observed there were no leaks from the compressors or associated equipment. Each FGRU has an amine section to remove H2S from the recovered gas so the recovered gas can be used in the refinery fuel gas system. Gas flow to each of the FGRU's are included as APPENDIX 15.
According to Valero's records there have been 79 reportable hydrocarbon and five acid gas flaring events since the CD has been entered. These events are recorded in the State of Texas Excess Emission Reporting System (STEERS).
I observed no smoke or flames being emitted by the flares. I also observed the flares using an infrared optical imaging device and did not observe any abnormal flaring activity (e.g. puffing or indications of incomplete combustion). All flares observed were operating on pilot fuel only.
The facility operates four Claus sulfur recovery units (SRU 543, 544, 545 and 546). Each SRU has its own dedicated four tail gas incinerator. The 12 hour average SO2 emissions trends, as recorded by CEM, for the four incinerators are included in APPENDIX 16. The trends show the 250 ppm limit has not been exceeded for the 12 months prior to the inspection with the exception of two incidents at SRU 543 and five incidents at SRU 544. The spikes in SO2 emissions were caused by power failures and maintenance activities. I observed that the H2S analyzer was installed correctly and the calibration gas was of the correct concentration and up to date. I reviewed the RATA results for each SRU CEMs and found the relative accuracies for the CEMs to be within the allowable requirements of 40 CFR, Part 60, Appendix F.
XIII - Refinery Self Evaluations and Audits
Valero's Port Arthur refinery has elected to conduct audits of their NSPS QQQ programs and Refinery MACT programs. The NSPS QQQ audit was performed in April/May 2008 and the Refinery MACT audit was performed in July - November of 2008.
XIV Permitting Status: Complete. Appendix 17 contains excerpts from the most recently revised NSR operating permit incorporating permits # 6825A, PSDTX49 and N65. Specific CD imposed limits are incorporated into the NSR permit and the Title V permit by reference.
EPA Inspection Report page 7 of 109
Valero, Port Arthur Refinery 6/19-22/2014
Section III - AREAS OF CONCERN
I observed no areas of concern at the time of the inspection. The affirmative relief items contained in parts IV - XIV of the CD have been met. The AMP regarding the measurement of opacity on the FCCU was received in June, 2014. Also discussed during the closing conference was the suggestion of labeling the LDAR calibration gas tubing at the location where instruments are calibrated to reduce human error in the calibration process. Also visited during the inspection is a community health clinic built as a supplemental environmental program (SEP) under Section XIX of the consent decree. The facility was in operation and being maintained and personnel were observed entering and leaving the building. The parking lot contained six vehicles during the visit.
Section IV - FOLLOW UP
N/A
Section V - LIST OF APPENDICES
Appendix 1 - Photo Log (27 photos taken 6/17-18/2014) Appendix 2 - Opening conference sign-in sheet Appendix 3 - Plant wide process flow diagram Appendix 4 - CD implementation chart Appendix 5 - Updated list of heaters and boilers Appendix 6 - List of CD required CEMs Appendix 7 - Heaters and Boilers NOx emission trends Appendix 8 - FCCU NOx emission trend Appendix 9 - FCCU SO2 emission trend Appendix 10 - FCCU CO emission trend Appendix 11 - Refinery fuel gas diagram Appendix 12 - Mix drums H2S analyzer trend Appendix 13 - BWON schematic Appendix 14 - BWON Carbon Canister Appendix 15 - Flare gas recovery gas flows Appendix 16 - SRU SO2 emission trends Appendix 17 - Operating permit excerpts
Appendix CBI (None)
EPA Inspection Report page 8 of 109
Valero / Port Arthur Refinery Inspection Date 06/16-18/2014
Appendix 1 Photograph Log
EPA Inspection Report page 9 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Hydrocracker Unit (HCU) 943 F1 and F2 heaters, combined stack NOx = 16.1 ppm O2 = 16.55 % CO = 0.3 ppm
EPA Inspection Report page 10 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
HCU 943 Heater F-3 NOx = 6.8 ppm O2 = 7.92 % CO = 3.9 ppm
EPA Inspection Report page 11 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Ammonia Injection equipment for HCU 943 F3 heater Selective Catalytic Reduction (SCR)
EPA Inspection Report page 12 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
HCU 943 F-3 heater ammonia tanks used for SCR.
EPA Inspection Report page 13 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Saturated Gas Recovery Unit 7945 H2S = 7.23 ppm
EPA Inspection Report page 14 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 6
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Delayed Coking Unit (DCU) Fuel Gas Mix Drum H2S = 0.0 ppm
EPA Inspection Report page 15 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 7
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
DCU 843 heaters F-1000 and F-2000 Shared CEMs NOx = 33.3 ppm O2 = 4.99 % CO = -7.0 ppm
EPA Inspection Report page 16 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 8
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
DCU 843 heater F-3000 (Heater shut down for maintenance) NOx = 2.8 ppm O2 = 21.03 % CO = 0.0 ppm
EPA Inspection Report page 17 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 9
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
HCU 942 heaters F-1000, F-2000, F-3000 combined stack NOx = 33.0 ppm O2 = 3.3 % CO = 4.1 ppm
EPA Inspection Report page 18 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 10
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Underneath HCU 942 F-1000, retrofitted low NOx burners.
EPA Inspection Report page 19 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 11
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Atmospheric Vacuum Unit 147 Heater F-1200 NOx = 21.3 ppm CO = - 2.3 ppm O2 = 3.12 %
EPA Inspection Report page 20 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 12
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
AVU 147 Heater F-1100 NOx = 24.1 ppm CO = -0.1 ppm O2 = 3.64 %
EPA Inspection Report page 21 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 13
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Sulfur Recovery Unit (SRU) 545 SO2 = 45 ppm O2 = 4.36 % NOx = 7.3 ppm CO = 42.9 ppm
EPA Inspection Report page 22 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 14
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
SRU 545 H2S = 0.0 ppm
EPA Inspection Report page 23 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 15
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
SRU 546 NOx = 5. ppm CO = 16.7 ppm SO2 = 63.6 ppm O2 = 6.42 %
EPA Inspection Report page 24 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 16
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
BWON Carbon Canisters arranged in series.
EPA Inspection Report page 25 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 17
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Catalytic Reforming Unit (CRU) 1344 Heater 1 NOx = 36 ppm O2 = 4.73 ppm CO = -5.0 ppm
EPA Inspection Report page 26 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 18
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
CRU 1344 Heaters 2, 3, 32 Combined Stack NOx = 18.0 ppm O2 = 7.01 ppm CO = 1.0 ppm
EPA Inspection Report page 27 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 19
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Hydrofluoric Acid Unit (HFAU) 443 Heater 1 NOx = 42.8 ppm CO = 0.0 ppm O2 = 4.73 %
EPA Inspection Report page 28 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 20
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Boiler House (BH 15) Boiler 41 NOx = 12.0 ppm O2 = 11.63 ppm CO = 0.0 ppm
EPA Inspection Report page 29 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 21
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
BH 15 Boilers 42 and 43 combined NOx = 19.0 ppm O2 = 9.66 % CO = -7.0 ppm
EPA Inspection Report page 30 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 22
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Boiler House 15 Boiler 43 LoNOx burners
EPA Inspection Report page 31 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 23
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
AVU 146 Heater 101 cold bypass NOx = 28.5 ppm CO = - 3.0 ppm O2 = 9.61 %
EPA Inspection Report page 32 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 24
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
AVU 146 Heater 101 North and South Stacks Combined NOx = 54.9 ppm CO = -3.0 ppm O2 = 2.34 %
EPA Inspection Report page 33 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 25
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
AVU 146 Heaters A and B combined NOx = 27.7 ppm CO = -4.0 ppm O2 = 9.74%
EPA Inspection Report page 34 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 26
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
AVU 146 Heater 101 North Stack NOx = 16.5 ppm CO = -4.0 ppm O2 = 15.32 %
EPA Inspection Report page 35 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 27
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Fluidized Catalytic Cracking Unit (FCCU) 1241 Wet Gas Scrubber (WGS)
EPA Inspection Report page 36 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 28
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Calibration Gasses for Leak Detection and Repair monitoring instruments.
EPA Inspection Report page 37 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 29
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Flare Gas Recovery System (FGR) 7042 compressors (3)
EPA Inspection Report page 38 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 30
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
FGR 7043 compressors (2)
EPA Inspection Report page 39 of 109
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 31
Location: Valero Port Arthur refinery
City: Port Arthur
County/Parish: Jefferson
State: Texas
Community Health Center
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