Document 914LGy7d4vZXEook07rO8261p

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Shell Oil Products and Shell Chemical, Norco, Louisiana Constantinos Loukeris, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Shell Oil Products US Norco Refinery (Shell or Shell Refinery) Shell Chemical LP Norco West Plant (Shell or Shell Chemical) Shell Chemical LP Norco East Plant (Shell or Shell Chemical) Facility Location: 15536 River Rd, Norco, LA 70079 Date of Inspection: March 27-31, 2023 EPA Inspector(s): 1. Constantinos Loukeris, Environmental Engineer 2. Jason Schenandoah, Environmental Engineer 3. James Haynes, Physical Scientist 4. Ben Rosenthal, Physical Scientist 5. Bailey Brown, Physical Scientist 6. Prince Nfodzo, Environmental Engineer Other Attendees: 1. Patrick Foley, EPA HQ 2. Jodi Holewka, Inspector, Louisiana DEQ 3. Renee Toups, Shell 4. Laura Sabolyk, Shell 5. Janaa Bourier, Shell 6. Martin Padilla, Shell 7. Jacob Foy, Shell 8. Rusty Bayham, Shell 9. Paul Rome, Shell Page 1 of 7 10. Daniel Nelson, Shell 11. Ryan Hymel, Shell 12. John Hurst, Shell 13. Steve Dominguez, Shell 14. Brandon Michel, Shell 15. Shannon Richardson, Shell 16. Drew Landry, Shell 17. Derrick Adams, Shell 18. Marybel Loya, Shell 19. Shelita Williams, Shell 20. Fred King, Shell 21. Roy Kliebert, Shell 22. Jason Lowry, Shell 23. Danny Blak, Shell 24. Steven Dune, Shell Contact Email Address: Laura.Sabolyk@shell.com Purpose of Inspection: Inspect the benzene waste operations and volatile organic compounds (VOC) emissions from wastewater systems Facility Type: Petroleum Refinery and Chemical Plant Regulations Central to Inspection: Refinery wastewater subject to the New Source Performance Standards 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) Arrival Time: March 27, 2023, 8:45 am Departure Time: March 31, 2023, 10:40 am Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided CBI warning to facility The following information was obtained verbally from Shell personnel unless otherwise noted. Page 2 of 7 Process Description: Shell stated that the site operates under 3 separate permits (identified as "AIs" by the Louisiana Department of Environmental Quality). The facility is split into two areas referred to as the East and West plants. The East Plant is where the refinery and chemical plant, which are interconnected, are located. The West Plant is primarily the wastewater treatment plant. The chemical plant consists of three olefins units that process ethylene, propylene, and butadiene, respectively. The refinery has a crude capacity of 250,000 barrels per day. The entire facility has a total of nine flares, consisting of seven elevated flares and two ground flares. Shell provided an overview of the East Plant sour water flow and a Subpart FF compliance diagram. Shell does not control any of its American Petroleum Institute oil-water separators (APIs) or corrugate plate interceptors (CPIs) under Subpart FF. The CPIs located at the olefins process units are controlled under Subpart FF. Any oil that is collected from the APIs, CPIs, or any dissolved nitrogen flotation tanks is sent to the slop oil system. Recently, Shell constructed temporary benzene strippers downstream of tank, XC-7005, which had been put into service a week prior to EPA's inspection but were not operating at the time of the inspection due to operational issues. Shell also manages waste streams that contains benzene from a few of the neighboring facilities, Dow Chemical and W.R. Grace. Staff Interview: On March 28, 2023, EPA had a brief interview with Ms. Janaa Bourier regarding her oversight of Shell's Subpart QQQ program. Ms. Bourier has been responsible for Shell's Subpart QQQ program for approximately three years. Shell indicated that operators conduct the visual inspection of the Subpart QQQ program through a software named Intelatrac. Ms. Bourier indicated that Shell has initiated a process to complete a waste stream re-inventory. From Ms. Bourier's knowledge, Shell has only maintained two years of records for Subpart QQQ, as the previous records did not get transferred from the individual who moved on from this role. EPA requested Subpart QQQ sewer diagrams and Ms. Bourier indicated that she did not have access to them and was unaware if they existed. Finally, Ms. Bourier indicated that Richard Hagland was the previous Shell personnel to maintain the Subpart QQQ program. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: Shell indicated to EPA that it considers some vacuum trucks uncontrolled and some controlled for the purposes of Subpart FF compliance. Shell operates an equipment cleaning operation (VAT), that removes any residual material and has several washing stages. Shell continuously runs firewater into the initial sump of the VAT and also uses vacuum trucks to skim off any oil that remains in the sump. Shell does not account for any residual process material that exists on the equipment brought over for cleanout on its total annual benzene report (TAB). Shell indicated that prior to 2021, the three inlet pipes into the bio treaters were not submerged fill and were filling at least two inches above the surface. As of 2021, Shell modified the lines to submerge fill at three feet below the surface of the bio treaters. EPA measured Method 21 emissions from the breather vents of internal floating roof tank T-251, ranging from 155-220 ppm from five of the breather vents. Page 3 of 7  EPA measured Method 21 emissions from the breather vents of external floating roof tank XC-429, ranging from 95-445 ppm from ten spots spread out across the openings of the roof. Shell indicated fixed roof tank T-409 has been in a "bypass mode" since June 2022 and material remains in the tank. EPA observed severe pitting across the entire fixed roof, as well as areas of cracks/openings with detectable emissions above 500 ppm. Shell operators indicated that the fixed roof of the tank is not inspected visually. At the Gasoline Blending area, Shell personnel indicated that there is not a water flush used after samples are drained into the waste sink for the area. In addition, EPA observed cracks/gaps on the sump cover as well as on the concrete portion of the surface impoundment. The uncovered API located in G01 South had water nozzles above the tank, and visible steam was evaporating from the liquid surface of the open API. For purposes of end-ofline sampling, Shell only measured the benzene in the wastewater split stream that comes out of the API effluent. Shell operate tank, XC-7000 as open to atmosphere and receives oily-water from the sump in the RCCU. Drains, DP7907 and DP7134, send waste to the oily-water sump and operate without a water seal. Shell indicated that tank, XC 7006, was worked on and redone in calendar year 2020. Shell operators indicated that they drain the slop header, cold and hot service, 1-2 times per day from PV1620 and PV1621 using a pump. EPA made the following Subpart QQQ observations: o The DEA and Drip and Drab Sumps were not caulked/sealed; o At the spent sulfide sump, the cover was warped, caulk was missing, and there were cracks in the existing caulk; o The spent cresylic caustic sump had nine bolts missing as well as caulk missing on the sump cover; o In the RCCU process unit, the lab sump had caulk that was peeled off and the inner seal was worn and missing in some places; o In the HCU unit, EPA identified six drains with oil and no water seal, one dry drain, and seven drain hubs that were not capped or were without a water seal; and o In the S3-sulfur unit, Shell has hard piped streams through tanks to manage the refinery wastewater. However, all of the pump drain hubs in the S3 sulfur-unit, as well as all of the pump drain hubs in the RCCU unit, which receive pump seal leaks and maintenance refinery wastewater are not designed with a water seal and are sent to an uncovered oil-water separator in the RCCU process unit. Photos and/or Videos: were taken during the inspection. EPA imaged hydrocarbon emissions using a FLIR optical gas imaging camera, Model GF-320. In addition, this camera was also used to take digital pictures and videos. See Appendix 1 for the summary of the videos and pictures taken. Field Measurements: were taken during this inspection. EPA conducted Method 21 monitoring and testing using Thermo Scientific's Toxic Vapor Analyzers, Model 2020, equipped with a flame ionization detector. See Appendix Page 4 of 7 2 for the summary of the monitoring and testing. EPA also collected six summa canisters that were analyzed per Method TO-15. CLOSING CONFERENCE Provided EPA point of contact to the facility Requested documents: 1. 2018-2022 Subpart FF quarterly reports 2. 2018 - 2022 TAB reports 3. NESHAP FF visual inspections 4. 2018-2022 Subpart QQQ quarterly reports 5. Subpart QQQ visual inspections 6. LeakDAS backup files 7. SOPs for all control equipment 8. Documentation of training on SOPs 9. Engineering design documents for all waste management units 10. Waste stream inventory annual changes 11. 2018-2022 quarterly end of line sampling 12. End of line Drawing and sampling plan 13. Last API inspection and seal gap measurements for all BWON IFR and EFR tanks 14. Last 5 years incoming Benzene reports from Dow Chemical? and W.R. Grace 15. 1 month log of vacuum trucks for January 2023 16. Shell's BWON Manual 17. Shell's QQQ Applicability Manual 18. Last two years of QQQ leak spreadsheet analysis 19. Training for QQQ - Frequency and training content 20. Title V permit 21. 3/27/2023 Vac Truck log including entries for approximately 1 pm 22. Crude intake properties from 2015 through present 23. Fresh Air Policy and list of tanks currently under this policy 24. 5 years of QQQ - Tracking Spreadsheet 25. QQQ Sewer Drawings that identify each individual drain system, drain, junction box, and oil-water separator that is subject to QQQ 26. Complete vacuum truck example for the VAT displayed during discussion 27. Environmental contact at the NORF 28. All schematics referenced in the Section 5 of the Shell Refinery BWON manual Concerns: At the closing conference, EPA identified the follow areas of concern: Subpart QQQ 1. Shell has not maintained records clearly identifying equipment subject to Subpart QQQ. Page 5 of 7 2. Shell has not properly conducted visual inspection of all equipment in each individual drain system. The visual inspection forms that have been used do not specifically identify which equipment is to be inspected and/or what they are to be inspected for. 3. Shell has improperly classified drain hubs and oil-water separators exempt from the individual drain system requirements of Subpart QQQ for not receiving refinery wastewater; however, Shell sends refinery maintenance wastewater, inprocess pump seal leaks, and other similar drips and drabs to the drain hubs without covers or water seals, as well as to uncovered oil-water separators. 4. Shell does not maintain the covers without visual defects (e.g., EPA observed cracks/gaps and peeled off caulk and in some instances missing seals/bolts). 5. Shell had several missing covers, dry drains, and oil in various drain hubs in its newest affected unit, HCU. 6. Shell may have issues with the design of its underground individual drain system based on EPA's observation of emissions from cracks in the concrete that convey the hard pipes to tanks. 7. Shell owns open top tank, T-252, that receives benzene wastewater from Dow and W.R. Grace, and is then routed to the bio treaters. Subpart FF 8. Shell has not maintained its Subpart FF manual updated to the current implementation strategy. 9. Shell has not designed and operated all of its waste management units controlled for Subpart FF, including the following units: GO1 South API; XC-7005; XC429; XC-7006; XC-409; T-251; T-252; and Gasoline Blending lab sink and sump. 10. Shell has not conducted no detectable emissions (NDE) testing on any waste management unit subject to Subpart FF for at least the past two years. 11. Shell may not be meeting the 6 Megagram (6 BQ) compliance option based on several of the waste management units identified as controlled by Shell that were not controlled and had not been designed to be controlled. In addition, by not conducting NDE monitoring on all Subpart FF waste management unit, Shell should have included these waste streams as uncontrolled as they enter into each of the waste management units. 12. Shell has not identified all points of generation. 13. Shall has not designed and operated the hatch on W-415 to NDE. 14. Shell should not be using the enhanced biodegradation unit exception of less than 10 ppm benzene that is allowed under the 6 BQ compliance option, since all waste management units upstream were not tested, designed and operated to NDE (e.g., the lack of submerged fill for the individual drain system into the bio treater prior to 2021). Page 6 of 7 DIGITAL SIGNATURES CONSTANTIN CONSTANTINOS LOUKERIS Digitally signed by Date: 2024.01.08 15:58:12 Report Author: __O_S__L_O_U__K_E_R_I_S_-_06_'00_' ________________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL Date: 2024.01.08 _M__A_R__S_H__A_L_L___16_:0_4:_47_-0_6_'00_' _____________ Page 7 of 7 Facility Name: Shell Oil Products US Norco Refinery, Shell Chemical LP Norco West Plant, Shell Chemical LP Norco East Plant Facility Location: 15536 River Rd, Norco, LA 70079 Date of Inspection: March 27-31, 2023 APPENDIX A: DIGITAL IMAGE/VIDEO LOG 1. Inspector Names: James Haynes and Ben Rosenthal 2. Archival Record Location: C:\Users\cloukeri\OneDrive - Environmental Protection Agency (EPA)\Shell Norco Refining (R5 Lead) Image Number 1 2 File Name R0010065.JPG R0010066.JPG Date 03/27/2023 03/27/2023 3 R0010067.JPG 03/27/2023 4 R0010068.JPG 03/27/2023 5 R0010069.JPG 03/27/2023 6 R0010070.JPG 03/27/2023 7 R0010071.JPG 03/27/2023 8 R0010072.JPG 03/27/2023 9 R0010073.JPG 03/27/2023 10 R0010074.JPG 03/27/2023 11 R0010075.JPG 03/27/2023 12 R0010076.JPG 03/27/2023 13 R0010077.JPG 03/27/2023 14 R0010078.JPG 03/27/2023 15 R0010079.JPG 03/27/2023 16 R0010080.JPG 03/27/2023 17 R0010081.JPG 03/27/2023 18 R0010082.JPG 03/27/2023 19 R0010083.JPG 03/27/2023 20 R0010084.JPG 03/27/2023 Image Description Overview of VAT sump Vacuum truck removing liquids from VAT sump (going to NORF) Vacuum truck removing liquids from VAT sump (going to NORF) Oil layer at uncovered PPI in DU-5 Inlet at uncovered PPI in DU-5 Overview of uncovered PPI in DU-5 Drain hub at crude sample line in DU-5 Drain hub at desalter sample line in DU-5 Desalter sump in DU-5 Back of Tag # BWN 1168 in Berth 1 Dock sump in Berth 1 Overview of dock sump in Berth 1 Drain line near 1B loading arm in Berth 1 Overview of drain line near 1B loading arm in Berth 1 Main manifold drain in Berth 1 Main manifold drain in Berth 1 Front angle of W428 sump in Berth 2 Front angle of W428 sump in Berth 2 Back of W428 sump in Berth 2 Drain line near F loading arm in Berth 2 Appendices Page 1 of 7 Facility Name: Shell Oil Products US Norco Refinery, Shell Chemical LP Norco West Plant, Shell Chemical LP Norco East Plant Facility Location: 15536 River Rd, Norco, LA 70079 Date of Inspection: March 27-31, 2023 21 R0010085.JPG 03/28/2023 Storm hub/catch basin in GO-1 North/OP-1 22 R0010086.JPG 03/28/2023 Open hatch at sump in caustic area in GO-1 North/OP-1 23 R0010087.JPG 03/28/2023 Pump (DP-5761) in caustic area in GO-1 North/OP-1 24 R0010088.JPG 03/28/2023 Drain behind DP-5761 25 R0010089.JPG 03/28/2023 Incidental Photo 26 R0010090.JPG 03/28/2023 Pump (DP-5765A) in caustic area in GO-1 North/OP-1 27 R0010091.JPG 03/28/2023 Drain behind DP-5765A 28 R0010092.JPG 03/28/2023 Pump (DP-5765B) in caustic area in GO-1 North/OP-1 29 R0010093.JPG 03/28/2023 Drain behind DP-5765B 30 R0010094.JPG 03/28/2023 BFW Pump (P3365) to E1816 from PV1563 31 R0010095.JPG 03/28/2023 Drain and sample system behind P3365 32 R0010096.JPG 03/29/2023 Inlet to API basin in West Plant 33 R0010097.JPG 03/29/2023 Overview of API basin in West Plant 34 R0010098.JPG 03/29/2023 Far-side of inlet to biotreatment tank T352 in West Plant 35 R0010099.JPG 03/29/2023 Near-side of weir system to biotreatment tank T352 in West Plant 36 R0010100.JPG 03/29/2023 Tank vent and canister grab at tank T-251 in West Plant 37 R0010101.JPG 03/29/2023 Hatch (Tag # BWN 0039) on XC409 38 R0010102.JPG 03/29/2023 Level gauge (Tag # BWN 0035) on XC409 39 R0010103.JPG 03/29/2023 Rust and pitting on XC409 40 R0010104.JPG 03/29/2023 Rust and pitting on XC409 41 R0010105.JPG 03/29/2023 Rust and pitting on XC409 42 R0010106.JPG 03/29/2023 Rust and pitting on XC409 43 R0010107.JPG 03/29/2023 Overview of closed vent system piping on XC409 Appendices Page 2 of 7 Facility Name: Shell Oil Products US Norco Refinery, Shell Chemical LP Norco West Plant, Shell Chemical LP Norco East Plant Facility Location: 15536 River Rd, Norco, LA 70079 Date of Inspection: March 27-31, 2023 44 R0010108.JPG 03/29/2023 Pressure gauge on piping of closed vent system on XC409 45 R0010109.JPG 03/29/2023 Holes in fixed roof of XC7005 46 R0010110.JPG 03/29/2023 Vapor combustion system controlling vent stream for new air strippers 47 R0010111.JPG 03/29/2023 Front of new air stripper unit 48 R0010112.JPG 03/29/2023 Back of new air stripper unit 49 R0010113.JPG 03/29/2023 Tank vent and canister grab at tank XC429 50 R0010114.JPG 03/30/2023 Drain hub and canister sample at desalter sample line in DU-5 51 R0010115.JPG 03/30/2023 Drain hub and canister sample at crude/naphtha sample line in DU-5; shows naphtha signage. 52 R0010116.JPG 03/30/2023 Drain hub and canister sample at crude/naphtha sample line in DU-5; shows crude signage. 53 R0010117.JPG 03/30/2023 Hydrocarbon sump behind building at motor lab 54 R0010118.JPG 03/30/2023 Hydrocarbon sump behind building at motor lab 55 R0010119.JPG 03/30/2023 Hydrocarbon sump behind building at motor lab 56 R0010120.JPG 03/30/2023 Hydrocarbon sump behind building at motor lab 57 R0010121.JPG 03/30/2023 Drain line of N19-2 going below concrete surface in S3 58 R0010122.JPG 03/30/2023 Cracked sealant material over buried sewer lines in S3 59 R0010123.JPG 03/30/2023 Access plate over buried sewer lines in S3 60 R0010124.JPG 03/30/2023 Cracked hatch at P7300 DEA sump 61 R0010125.JPG 03/30/2023 Warped cover, rust, and gaps at P7404 sulfidic sump 62 R0010126.JPG 03/30/2023 Additional view of P7404 sulfidic sump 63 R0010127.JPG 03/30/2023 Additional view of P7404 sulfidic sump 64 R0010128.JPG 03/30/2023 Additional view of P7404 sulfidic sump 65 R0010129.JPG 03/30/2023 Additional view of P7300 DEA sump 66 R0010130.JPG 03/30/2023 Additional view of P7300 DEA sump Appendices Page 3 of 7 Facility Name: Shell Oil Products US Norco Refinery, Shell Chemical LP Norco West Plant, Shell Chemical LP Norco East Plant Facility Location: 15536 River Rd, Norco, LA 70079 Date of Inspection: March 27-31, 2023 67 R0010131.JPG 03/30/2023 Additional view of P7300 DEA sump 68 R0010132.JPG 03/30/2023 View of spent cresylic caustic sump 69 R0010133.JPG 03/30/2023 Cracked hatch on spent cresylic caustic sump 70 R0010134.JPG 03/30/2023 Additional view of spent cresylic caustic sump 71 R0010135.JPG 03/30/2023 Additional view of spent cresylic caustic sump 72 R0010136.JPG 03/30/2023 LT5911 lab pit sump 73 R0010137.JPG 03/30/2023 Additional view of LT5911 sump 74 R0010138.JPG 03/30/2023 View of P4255 chemical lift station in HCU 75 R0010139.JPG 03/30/2023 Additional view of P4255 chemical lift station in HCU 76 R0010140.JPG 03/30/2023 Drain behind pump (P4264) in HCU 77 R0010141.JPG 03/30/2023 Additional view of drain behind P4264 in HCU 78 R0010142.JPG 03/30/2023 Drain behind pump (P4265) in HCU 79 R0010143.JPG 03/30/2023 Drain behind pump (P4266) in HCU 80 R0010144.JPG 03/30/2023 Drain behind pump (P4267) in HCU 81 R0010145.JPG 03/30/2023 Drain behind pump (P4259) in HCU 82 R0010146.JPG 03/30/2023 Drain behind pump (P4258) in HCU 83 R0010147.JPG 03/30/2023 Drain behind pump (P4261) in HCU 84 R0010148.JPG 03/30/2023 Drain behind pump (P4260) in HCU 85 R0010149.JPG 03/30/2023 Drain near exchanger (X4260) in HCU 86 R0010150.JPG 03/30/2023 Canister grab at P4255 chemical lift station in HCU 87 MOV_0202 3/27/2023 HC emissions from open Drain Funnel located in DU-5 adjacent to FCV-226. 88 MOV_0203 3/27/2023 HC emissions from P-2801 and P-2802 sump 89 MOV_0204 3/27/2023 HC emissions from P-2801 and P-2802 sump 90 MOV_0207 3/27/2023 HC emissions from uncapped line in piping manifold associated to components W-427 and RN-61444. 91 MOV_0209 3/27/2023 HC emissions from uncapped line in piping manifold associated to components W-427 and RN-61444. 92 MOV_0210 3/27/2023 HC emissions from open drain on deck of dock. Appendices Page 4 of 7 Facility Name: Shell Oil Products US Norco Refinery, Shell Chemical LP Norco West Plant, Shell Chemical LP Norco East Plant Facility Location: 15536 River Rd, Norco, LA 70079 Date of Inspection: March 27-31, 2023 93 MOV_0211 3/29/2023 HC emissions from vent on NW side of IFR tank 409. 94 MOV_0212 3/29/2023 HC emissions from vent on N side of IFR tank 409. 95 MOV_0213 3/29/2023 HC emissions from vent on N side of IFR tank 409. Opposite angle of MOV_0212. 96 MOV_0215 3/29/2023 HC emissions from gauge hatch on tank XC- 409. 97 MOV_0216 3/29/2023 HC emissions from gauge hatch on tank XC- 409. 98 MOV_0217 3/29/2023 HC emissions from gooseneck on tank XC-409 99 MOV_0219 3/29/2023 HC emissions from gauge hatch on tank XC- 409. 100 MOV_0220 3/29/2023 HC emissions from foam line and vents on F- 427. 101 MOV_0221 3/29/2023 HC emissions from foam line and vents on F- 427. 102 MOV_0222 3/29/2023 HC emissions from triple vent on tank F-427. Opposite angle of MOV_220 & MOV_221. 103 MOV_0225 3/29/2023 Discolored patch on roof surface of tank F-427. TVA reading 730. 104 MOV_0227 3/29/2023 HC emissions from conservation vent/vacuum breaker vent on tank, XC-430. 105 MOV_0228 3/29/2023 HC emissions and significant odor from `guide pole' on tank XC-7006 (EFR). 106 MOV_0229 3/29/2023 HC emissions from roof vent on tank XC-439. 107 MOV_0230 3/29/2023 HC emissions from roof vent on tank XC-439. 108 MOV_0231 3/29/2023 HC emissions from roof vent on tank XC-439. 109 MOV_0232 3/29/2023 HC emissions from gooseneck on tank F-425. Kerosene tank. 110 MOV_0233 3/30/2023 Hatch on the roof of tank W-415. TVA reading above 9,700 ppm. 111 MOV_0234 3/30/2023 HC emissions from open Drain Funnel located in DU-5 adjacent to FCV-226. 112 MOV_0235 3/30/2023 HC emissions from drain in sink at the motor lab labeled "Hydrocarbon and Sour Water". 113 MOV_0236 3/30/2023 HC emissions from gasoline sump or surface impoundment by the motor lab. Tags on associated equipment: BWN 1178, BWN 1179, BWN 1180. Appendices Page 5 of 7 Facility Name: Shell Oil Products US Norco Refinery, Shell Chemical LP Norco West Plant, Shell Chemical LP Norco East Plant Facility Location: 15536 River Rd, Norco, LA 70079 Date of Inspection: March 27-31, 2023 APPENDIX B: FIELD MEASUREMENT DATA The table below summarizes the field measurements by EPA conducting Method 21 with a Thermo Scientific Toxic Vapor Analyzer, Model 2020, and when available confirmed by Shell. Where Shell did not have an instrument available to confirm, EPA confirmed with a 2nd instrument. Component ID VAT VAT - Vacuum truck (Plate# LAC380574) DU-5 CPI DU-5 PP1 DU-5 Trilines DU-5 DU-5 Desalter W-427 (Berth 1) Berth 1/1A Berth 1/1A W-428 D419 GO1 South (P3365) GO1 South (P3366) T-409 (BWN 0039) T-409 (BWN 0035) T-409 (near BWN 0033) Equipment Type Open grated walkway - about 3-4 feet above liquid surface Carbon outlet Open oil sump to W-415 Drain Hub Drain Hub Cleanout Funnel Sump RM124688 Manifold Drain Left of RM 124688 Cover Hatch Drain Hub Drain Hub Fixed Roof Fixed Roof Fixed Roof EPA's Reading (ppm) 78 Shell's Reading (ppm)* - 265 421 2,961 7,600 16,000 850 905 11,000 70,000 98,000 2,000 812 545 495 >10,000 1,200 >50,000 (flameout) 170 6,542 11,000 760 760 6,068 72,000 1,389 796 558 5,763 >50,000 (flameout) Additional Notes - - - Oil/debris present Oil present Liquid present 6-inch opening in sump, no seal Vent to atmosphere 5 drains in total open to atmosphere - - - Severe pitting, cracks/gaps 6-inch flare line Severe pitting, cracks/gaps Appendices Page 6 of 7 Facility Name: Shell Oil Products US Norco Refinery, Shell Chemical LP Norco West Plant, Shell Chemical LP Norco East Plant Facility Location: 15536 River Rd, Norco, LA 70079 Date of Inspection: March 27-31, 2023 XC7005 XC7005 W-415 (DU5) DU-5 Desalter Oil DU-5 Naptha Funnel Gasoline Blending Fixed Roof portion of IFR tank Hatches - 2 of them Hatch Drain Hub Drain Hub Waste Sink Gasoline Blending Gasoline Blending Sump Cover Sump PV/VB Gasoline Blending RCCU P4255 (HCU) Concrete portion of Sump Lab sump cover Sump cover 1,000 750 9,700 3,000 12,000 80,000 (flameout) 10,100 7,000 120 760 895 - 3 feet by 2-inch opening on fixed roof 19,092 Hatches not seated properly Left of ladder 12,156 - 70,000 (flameout) 7,188 7,663 (flameout) - - - - From cracks in the concrete Not sealed Appendices Page 7 of 7