Document 8N5Zp2Mn8LqQd18EvR2B8zeo

EPA Inspection Report page 1 of 74 EPA. 0ft. Un:":e::iStatas Environ:na:~:el Protectlcr. Ag en..-y Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date{s): 6/23,23 &25/2014 ! Media: I Air I I Regu latory Program{s) I Consent Decree, Civil Action H-01-0978 Company Name: Motiva Enterprises LLC I Facility Name: Motiva Enterprises LLC Convent Refinery ' Facility Physical Location: , Hwy 44 & 70, Convent, Louisiana {city, state, zip code) Convent, LA 70723 Mailing address: PO Box 37 {city, state, zip code) Convent, LA 70723 County/Parish: Facility Contact: , St. James Parish i Kyle LeJeune J Environmental Engineer Kyle .lejeune@Motivaent.com I ' : FRS Number: 220930006 i Identification/Permit Number: 2560-0001 VII ! ' Media Number: AFS # 2209300001 ' ! NAICS: i 324110 i SIC : 2911 ! Facility Representatives: . EPA Inspectors: Oliver Boyd Environmental Manager : 22 ~-562-6747 ! Kyle LeJeune . Environmental Engineer 22 ~-562-8379 i Youn Kim ; Environmental Engineer ! 22 p-562-6646 : Anthony Schexnayder i Richard Gigger LDAR Inspector : 22 p-562-6424 28 -983-2105 State lnspector{s): Other lnspector(s): .r..o.. Title: ro "0 Author: .r..o.. <lJ Subject : ~ I: Keywords: ' EPA Lead Inspector Signature/Date Superviso r Signature/Date Jason Fontenot Yanfu Zhao Mike Miller NA LDEQ ! I LDEQ I LDEQ 22 -219~3028 22 -219-3613 22 -219-3028 ! I I I I ! Motiva Refining, Convent Refinery, Convent, Louisiana, St.James Parish i I i US EPA Region 6 Compliance Assurance and Enforcement Division Dallas TX l. i Partia l Compliance Eva luation Inspection Report ' ! refinery consent decree (CD) ( r Richard Gigge r .I/f/:" .1., ".VJ'li~t/'-J / ~~ zrt~~ // lit -2-- ur'T: Da e "' li Samuel Tates ./M }/1~ 9 V1I/ 2oJ4- Dat e 6ENFORM-019-R3 (11/14/2013} EPA Inspection Report page 2 of 74 Motiva Enterprises LLC, Convent Refinery 6/23-25/2014 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspector Richard Gigger and representatives from the Louisiana Department of Environmental Quality (LDEQ) conducted an inspection of the Motiva Enterprises LLC Convent, Louisiana Refinery. At 3:00 pm on June 23, 2014, I met with Oliver Boyd, Environmental Manager for the facility, Kyle LeJeune, and other Environmental staff, for an opening conference. I presented my credentials to Mr. Boyd and informed him that this was an EPA inspection to determine compliance with the federally issued Consent Decree (Civil Action H-01-0978), which is a national priority for EPA. The inspection was a Partial Compliance Evaluation (PCE), which included an evaluation of the consent decree's (CD) four marquee issues: nitrogen oxides and sulfur dioxide (NOx/SO2) reductions, leak detection and repair (LDAR), benzene waste operations (BWON) and flaring of both acid gases and hydrocarbons. The CD consists of 19 Parts designated by Roman numerals. Of these, Parts IV - VIII requires affirmative relief, which was the focus of the inspection. These Parts address the requirements of NOx, SO2, CO, particulate, VOC, and benzene emission reductions through various construction projects, process additives, and process and program enhancements. Note that these inspection findings pertain only to the compliance status affecting Motiva's Convent refinery. Photos taken during the inspection are included as Appendix 1. Sign in sheet for the opening conference is included as Appendix 2. FACILITY DESCRIPTION Motiva's Convent refinery is located next to the Mississippi River between New Orleans and Baton Rouge, and has the capacity to refine 250,000 barrels of crude oil per day. The facility has had multiple upgrades and now operates as a fully integrated refinery with crude distillation, Fluid Catalytic Cracking Unit (FCCU), alkylation (sulfuric acid), catalytic reforming, hydrodesulphurization, isomerization, sulfur recovery, and fuel blending. The refinery produces motor gasoline, diesel fuel, jet fuel, liquefied petroleum gas, and fuel oil. Crude oil is obtained primarily by ship and pipeline, while products leave the facility by pipeline, railcar, tank truck, and marine shipping. A plant wide process flow diagram is included in APPENDIX 3. Section II - OBSERVATIONS Part IV, NOx Emissions Reductions from Fluidized Catalytic Cracking Unit (FCCUs): Status: Complete. There have been no NOx emission limits exceeded during the past year. Program Summary: Motiva shall implement a program to reduce NOx emissions with the installation and the operation of a Selective Non-Catalytic Reduction (SNCR) system at the Convent FCCU. Motiva shall incorporate lower NOx emission limits into operating permits and will demonstrate future compliance with 2 EPA Inspection Report page 3 of 74 Motiva Enterprises LLC, Convent Refinery 6/23-25/2014 the lower emission limits through the use of continuous emission monitoring systems (CEM's). Motiva has established and EPA approved a final, 365 day rolling average of 73 parts per million (ppm) and 24 hour rolling average of 98.2 ppm. APPENDIX 4 contains the FCCU NOx 365 day and 24 hour rolling average emission trends from June 2013 - June 2014. 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 the CEMs and found the relative accuracies to be within allowable requirements of 40 CFR, Part 60, Appendix F. Part V, SO2 Emissions Reductions FCCUs Status: Complete. Program Summary: Motiva shall continue to operate the existing Wet Gas Scrubber (WGS) on the FCCU. Motiva shall incorporate lower SO2 emission limits into operating permits and will demonstrate future compliance with the lower emission limits through the use of CEMs. Part V also requires compliance with NSPS Subparts A and J for SO2, CO, particulate matter (PM) and opacity limits. Appendix 5 contains FCCU SO2 365 day and 7 day rolling average trends from June 2013 -June 2014. The seven day rolling average limit is 50 ppm, and the 365 day rolling average limit is 25 ppm. During the inspection I observed the CEM 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 CEM and found the relative accuracies for the CEMs to be within allowable requirements of 40 CFR, Part 60, Appendix F. There were no acid gas or hydrocarbon releases in the past year. Appendix 6 is the FCCU CO one-hour rolling average trend (ppm and pounds per hour) from June, 2013 to June, 2014. Appendix 7 is the most recent stack test results Part VI, Program Enhancements Regarding Benzene Waste NESHAP. Status: Complete. Program Summary: Motiva shall undertake refinery-wide audits to determine its compliance with all Benzene Waste NESHAPS requirements and to take corrective action where any areas of non- compliance are identified. In addition Motiva shall undertake refinery wide measures to minimize or illuminate fugitive benzene waste emissions at the refinery. Process water is sent to two API separators, then to two SATSU (stage activated sludge treatment units). Benzene concentrations are required to be monitored at the SATSU inlet and outlet. Analytical results for the past year are included as Appendix 8. The results are well below permit limits. 3 EPA Inspection Report page 4 of 74 Motiva Enterprises LLC, Convent Refinery 6/23-25/2014 Benzene containing waste is stored in tanks 18d1, 20AT907, 20D36, 20D47,20T202,20T206, 20T 210, 20T303 (internal floating roof) and 37T314, 37T315, 37T316, 37T317 (external floating roof). Motiva provided copies of the most recent seal gap inspections. During the inspection I reviewed inspection results of the storage tanks and found the tanks being inspected at the frequency required using the correct measurement methods. No carbon canisters are used for BWON compliance at the facility. I reviewed the sampling procedure and standard operating procedures (SOPs) being used and found the procedures written in a formal SOP and consistent with BWON sampling techniques required by 40 CFR 61.355. Part VII, Program Enhancements RE: Leak Detection and Repair (LDAR) Program Enhancements Status: Complete. Program Summary: Motiva shall undertake audits of the components in light liquid and gaseous service at each of its refineries to determine compliance with all of the requirements of the Leak Detection and Repair ("LDAR") regulations and to correct any areas of non-compliance. In addition, Motiva shall undertake the CD listed enhancements to its LDAR program consisting of refinery-wide measures to minimize or eliminate fugitive emissions from components in light liquid and gaseous service at its refineries in accordance with the schedule set forth. Third party audits, periodic reports and other requirements of Part XI of the consent decree have been previously reported to EPA and LDEQ. Motiva uses TEAM to conduct LDAR monitoring, 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. I reviewed instrument calibration logs and found that equipment calibration records are complete. TEAM has implemented a mid day and the end of day drift check. End of day drift checks are 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. There are approximately 90 valves on the delay of repair (DOR) list for the entire refinery. 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 several process units and observed no open ended lines or valves. Sage Environmental Consulting did a third party audit starting on February 17, 2014. The executive summary is included as Appendix 9. 4 EPA Inspection Report page 5 of 74 Motiva Enterprises LLC, Convent Refinery 6/23-25/2014 Part VIII, Program Enhancements RE: NSPS Subparts A and J SO2 Emissions from Sulfur Recovery Plants (SRP's) and Flaring Status: On schedule. Program Summary: Beginning immediately upon the lodging of this Consent Decree, Motiva agrees to take the following measures at all of its SRPs and certain flaring devices at the refineries identified in Paragraph 5. Motiva shall eliminate all reasonably preventable SO2 emissions from flaring. Motiva will implement procedures for root cause analysis of acid gas flaring incidents at all refineries. Motiva shall strive to extend the duration between SRP maintenance shutdowns (unscheduled or scheduled) to three years or greater. The facility uses four refinery flares (numbered 1, 2, 3, and 4) subject to NSPS Subpart J. There is also a flare associated with the marine vapor recovery system (no. 5). This flare is not idled when not in use. Prior to each use the pilot gas is turned on and ignited by an electric spark. Refinery fuel gas (RFG) is used as pilot gas. It is measured for SO2 at the east-side fuel gas drum. I observed and photographed the refinery flare gas recovery system compressors. The recovered gas is treated to remove sulfur before being sent into the fuel gas system. A description and diagram of the flare gas recovery system is included as APPENDIX 10. Since the CD was entered there have been 28 reportable acid gas and hydrocarbon flaring events at the facility, none within the past year. I observed no smoke or flames being emitted by the flares. I also observed each flare using a FLIR optical imaging device and observed no following plumes that would indicate the possibility of un- combusted hydrocarbon being present. The facility uses five sulfur recovery units with five incinerators (APPENDIX 11). The 12 hour average SO2 emissions trends, as recorded by CEM, for the incinerators are included in APPENDIX 12. The trends show the 250 ppm limit has not been exceeded for the 12 months prior to the inspection, with the exception of spikes on TGTU1 (tail gas treatment unit) and TGTU5. I observed that the SO2 analyzer was installed correctly and the calibration gas was of the correct concentration and up to date. I reviewed the RATA results for the SRU CEMs and found the relative accuracies for the CEMs to be within the allowable requirements of 40 CFR, Part 60, Appendix F. IX Permitting Status: Complete. Motiva agrees to apply for and make all reasonable efforts to obtain in a timely manner all appropriate federally enforceable permits (or construction permit waivers) for the construction of 'the pollution control technology required to meet the above pollution reductions. The facility has no un-approved AMPs 5 EPA Inspection Report page 6 of 74 Motiva Enterprises LLC, Convent Refinery 6/23-25/2014 Appendix 13 contains excerpts from the most recently revised NSR operating permits. Specific CD imposed limits are incorporated into the NSR permits and the Title V permit by reference. Section III - AREAS OF CONCERN None noted. Section IV - FOLLOW UP N/A Section V - LIST OF APPENDICES Appendix 1 - Photo Log Appendix 2 - Opening conference sign-in sheet Appendix 3 - Plant wide process flow diagram Appendix 4 - FCCU NOx emission trends Appendix 5 - FCCU SO2 emission trend Appendix 6 - FCCU CO emission trend Appendix 7 - Most recent stack test results Appendix 8 - benzene concentrations from SATSU inlet and outlet Appendix 9 - executive summary of third party LDAR audit Appendix 10 - description and diagram of flare gas recovery system Appendix 11 - simplified SRU description and diagram Appendix 12 - TGTU SO2 12 hour rolling averages Appendix 13 - Operating permit excerpts Appendix CBI (None) 6 EPA Inspection Report page 7 of 74 Appendix 1 Photos EPA Inspection Report page 8 of 74 Appendix 1 Photograph Log EPA Inspection Report page 9 of 74 CEMs on the FCCU EPA Inspection Report page 10 of 74 CEMs on TGTU 1 EPA Inspection Report page 11 of 74 CEMs on TGTU 2 EPA Inspection Report page 12 of 74 CEMs on TGTU 3 EPA Inspection Report page 13 of 74 CEMs on TGTU 4 EPA Inspection Report page 14 of 74 Compressors on Flare Gas Recovery System EPA Inspection Report page 15 of 74 CEMs on TGTU 5 EPA Inspection Report page 16 of 74 EPA Inspection Report page 17 of 74 Appendix 2 Opening conference sign-in sheet EPA Inspection Report page 18 of 74 EPA Inspection Report page 19 of 74 EPA Inspection Report page 20 of 74 Appendix 3 Process Flow Diagram EPA Inspection Report page 21 of 74 EPA Inspection Report page 22 of 74 Appendix 4 FCCU NOx emission trends EPA Inspection Report page 23 of 74 EPA Inspection Report page 24 of 74 EPA Inspection Report page 25 of 74 Appendix 5 FCCU CO Emission Trends EPA Inspection Report page 26 of 74 EPA Inspection Report page 27 of 74 Appendix 6 FCCU SO2 Emission Trends EPA Inspection Report page 28 of 74 EPA Inspection Report page 29 of 74 EPA Inspection Report page 30 of 74 Appendix 7 Most recent stack test results EPA Inspection Report page 31 of 74 EPA Inspection Report page 32 of 74 EPA Inspection Report page 33 of 74 EPA Inspection Report page 34 of 74 EPA Inspection Report page 35 of 74 EPA Inspection Report page 36 of 74 Appendix 8 BWON flow diagram EPA Inspection Report page 37 of 74 EPA Inspection Report page 38 of 74 Appendix 9 Third Party LDAR Audit EPA Inspection Report page 39 of 74 EPA Inspection Report page 40 of 74 EPA Inspection Report page 41 of 74 EPA Inspection Report page 42 of 74 EPA Inspection Report page 43 of 74 EPA Inspection Report page 44 of 74 EPA Inspection Report page 45 of 74 EPA Inspection Report page 46 of 74 EPA Inspection Report page 47 of 74 EPA Inspection Report page 48 of 74 EPA Inspection Report page 49 of 74 EPA Inspection Report page 50 of 74 EPA Inspection Report page 51 of 74 EPA Inspection Report page 52 of 74 Appendix 10 Flow diagram - SRU block EPA Inspection Report page 53 of 74 EPA Inspection Report page 54 of 74 Appendix 11 SRU SO2 emission trends EPA Inspection Report page 55 of 74 EPA Inspection Report page 56 of 74 Appendix 12 SRU RATA results EPA Inspection Report page 57 of 74 EPA Inspection Report page 58 of 74 EPA Inspection Report page 59 of 74 EPA Inspection Report page 60 of 74 EPA Inspection Report page 61 of 74 EPA Inspection Report page 62 of 74 EPA Inspection Report page 63 of 74 Appendix 13 Heater NOx emission trends EPA Inspection Report page 64 of 74 EPA Inspection Report page 65 of 74 EPA Inspection Report page 66 of 74 EPA Inspection Report page 67 of 74 EPA Inspection Report page 68 of 74 EPA Inspection Report page 69 of 74 Appendix 14 Fuel gas SO2 trends EPA Inspection Report page 70 of 74 EPA Inspection Report page 71 of 74 Appendix 15 Fuel gas system RATA results EPA Inspection Report page 72 of 74 EPA Inspection Report page 73 of 74 EPA Inspection Report page 74 of 74