Document gaz4dd53KNr39qQRJ60qnmKJV

EPA Inspection Report1 of 106 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: FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: Facility Representatives: 2/10-12/2014 Air Consent Decree, Civil Action SA-05-CA-0569 Valero Refining- Texas, L.P. Valero Refining- Texas, L.P. Texas City Refinery 1301loop 197 South Texas City, TX 77590 P.O. Box3429 Texas City, TX 77592 Galveston County Jolanda Allison I Staff Environmental Engineer Jolanda.allison@valero.com .. 110032911669 0-01253, NSR-39142 AFS # 4816700161 324110 2911 Jolanda Allison Patrick Passantino Gino Paganucci Staff Environmental Engr. Environmental Manager Staff Environmental Engr. 409/948-7296 409/948-7296 409/948-7296 EPA Inspectors: State lnspector(s): Other lnspector(s): ... Title: "' -"o' Author: ."Q..J' Subject: 2 Keywords: EPA lead Inspector Signature/Date Supervisor Signature/Date Jim Gold Richard Gigger Paul Brandes Nader Masrour NA Region 6, 6EN-ASH Region 6, 6EN-ASH TCEQ Region 12 TCEQ region 12 281/983-2153 281/983-2015 713/767-3709 713/767-3611 Valero Refining, Texas City Refinery, Texas City, Texas, Galveston County US EPA Region 6 Compliance Assurance and Enforcement Division Dallas TX Partial Compliance Evaluation Inspection Report refinery consent decree (CD) Jim Gold Sam Tates v ~ ~ / /UU 1<k '/!T,u/tY Date 3/03/2014 4/3o/ 2o ;q. Date ' 6ENFORM-019-R3 (11/14/2013) EPA Inspection Report2 of 106 Valero, Texas City Refinery 2/10-12/2014 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Richard Gigger and I (Jim Gold) conducted an inspection of the Valero RefiningTexas City Refinery (VTCR). At 9:30am on February 10, 2014, we met with Jolanda Allison, Staff Environmental Engjneer for the facility, for an opening conference. I presented my credentials to Ms. Allison and informed her that this was an EPA inspection to determine compliance with the federally issued Consent Decree (Civil Action SA-05-CA-0569), 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: NOJS02 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 NO,, so,, 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 VTCR. Photos taken' during the inspection (26) are included s Appendix 1. Sing in sheet for the opening conference is included as Appendix 2. FACILITY DESCRIPTION VTCR was originally built in 1908 and was acquired by Valero in 1997. VTCR has had multiple upgrades and now has the capacity to refine 250,000 barrels per day and operates as a fully integrated refinery with crude distillation, FCCU, alkylation (hydrofluoric), catalytic reforming, hydrodesulphurization, isomerization; sulfur recovery, and fuel blending. VTCR's main products are motor gasoline, diesel fuel, jet fuel, liquefied petroleum gas, and fuel oil. Crude oil is obtained primarily by ship and pipeline at the facility. Products leave the facility by pipeline, railcar, 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. VTCR operates under a Title V permit and a New Source Review (NSR) permit. 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-cd.pdf. Section II- OBSERVATIONS Part IV, NO, Emissions Reductions from Heaters and Boilers Status: Complete. Program Summary: Valero will implement a program to reduce NO, emissions from refinery heaters and boilers greater than 40 Million British Thermal UnitS (MMBTU)/hr by committing to 2 EPA Inspection Report3 of 106 Valero, Texas City Refinery 2/10-12/2014 an interim, system-wide weighted average concentration emission limit for NO, of 0.060 lbs/MMBTU is to be achieved by December 31, 2009. A final, system-wide weighted average concentration emission limit for NO, 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. No heaters and boilers 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. 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 6 is the recorded NO, emission trends for the heaters and boilers equipped with NO, Continuous Emission Monitors (CEMs) from February 2013- February 2014. The trends also include individual emission limits for the heaters and boilers. The emission trends demonstrate compliance with the 365 day NO, rolling average limits for the 12 months before the inspection. There was several NOx spikes from heaters 44, 45, and 46 during start up after a major turnaround, which was completed in January of 2013. Several NO, spikes also occurred in August of 2013 due to power loss from a third party provider. Part V, NO, Emissions Reductions from FCCUs Status: Complete. Program Summary: Valero will implement a program to limit NO, emissions from its FCCU regenerators and CO boilers by achieving a system-wide average of unit-specific NO, concentration emission limits for each FCCU. This will be achieved by implementing certain emission control systems or. otherwise satisfying the NO, emission standards. Valero has set a final, 365 day rolling average of 19 parts per million (ppm). APPENDIX 7 is the FCCU NOx emission trends from February 2013- February 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. NO, from the FCCU is controlled by ozone injection. I observed the dual ozone generators in operation. A photo of the generators is included in the APPENDIX 1. Part VI, so, Emission Reductions from FCC Us Status: Complete. 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