Document rev63b1MN2gdBg4nvMwVpBeKv

EPA Inspection Report - Page1 of 103 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 FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: Facility Representatives: 8/22-24/2.017 Air Consent Decree, Civil Action 07-CV-00248-MAC Total Petrochemicals and Refining USA, Inc. Port Arthur Refinery 7600 32"0 Street Port Arthur, TX 77642-7901 P.O. Box 849 Port Arthur, TX 77641-0849 Jefferson County Jannetta Ned I Environmental Engineering Advisor 409/985-0268 110000755200 EIS It 324110 2911 Jannetta Ned Consent Decree Coordinator 409/985-Q268 EPA Inspectors: State lnspector{s): Other lnspector(s): -f! Title: '"0' A.uthor: "OJ' Subject: 2 Keywords: EPA Lead Inspector Signature/Date Supervisor Signature/Date Jim Gold Prince Nfodzo Region 6, 6EN-ASH Region 6, 6EN-AA 281/983-2153 214/665-7491 NA Total Petrochemicals and Refining, 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 (/#, 7)_jjjj Report delayed due! Hurricane Harvey and RSC duty. Sam Tates .0 A /J/1 J/ 'J<tX:3 10/31/2017 Date ;;I rJ2.()1? Date 6ENfORM019-R3 (11/14/2013) EPA Inspection Report - Page2 of 103 Total Petrochemicals and Refining, Port Arthur Refinery 8/22-24/2017 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Jim Gold and Prince Nfodzo conducted an inspection of the Total Petrochemicals and Refining USA, Inc. Port Arthur, Texas Refinery. At 1:00 pm on August 22, 2017, we met with Jannetta Ned, Environmental Engineering Advisor for the facility, for an opening conference. I presented my credentials to Ms. Ned and informed her that this was an EPA inspection to determine compliance with the federally issued Consent Decree (Civil Action Number 07-CV-00248-MAC). I also informed Ms. Ned that the inspection would be a Partial Compliance Evaluation (PCE), which includes an evaluation of the four marquee issues addressed by the Consent Decree (CD): NOx/SO2 reductions, leak detection and repair (LDAR), benzene waste operations (BWON) and flaring of both acid gases and hydrocarbons. The CD consists of 15 Parts designated by Roman numerals I through XV. Of these, Parts V through IX require affirmative relief and is the focus of this 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. The consent decree was amended in 2013 to a 6BQ option for Benzene Waste NESHAP and an Alternative Monitoring Plan was approved for wet gas scrubber (WGS) monitoring serving the fluidized catalytic cracking unit (FCCU). Note that these inspection findings pertain only to the compliance status affecting Total's Port Arthur refinery. Photos taken during the inspection (25) are included as APPENDIX 1. Sign in sheets for the opening conference and each day of the inspection is included as APPENDIX 2. FACILITY DESCRIPTION The facility has had multiple upgrades since original construction and now has the capacity to refine 232,000 barrels per day and operates as a fully integrated refinery with crude distillation, FCCU, alkylation (sulfuric acid), catalytic reforming, hydrodesulphurization, sulfur recovery, and fuel blending. Main products are transportation fuels. Crude oil is obtained primarily by ship and pipeline, products leave the facility by pipeline, railcar, tank truck, and marine shipping. A plant wide process flow diagram, written facility description and aerial photo are included as APPENDIX 3. A detailed list of processes and descriptions can be found in Appendix A of the CD. The CD can be accessed via internet at https://www.epa.gov/sites/production/files/documents/total-cd.pdf 6ENFORM-019-R3 (11/14/2013) EPA Inspection Report - Page3 of 103 Total Petrochemicals and Refining, Port Arthur Refinery 8/22-24/2017 Section II - OBSERVATIONS Part V, New Source Review/Prevention of Significant Deterioration Requirements ("NSR/PSD") A. Control of NOx Emissions from FCCUs Status: Complete. Program Summary: TOTAL shall limit NOx emissions from any FCCU to 30 ppmvd NOx or less on a 365 day rolling average and 60 ppmvd NOx or less on a 7-day rolling average. TOTAL operates one FCCU at the Port Arthur facility. APPENDIX 4 contains the NOx emission trends from August 1 2016 to August 1, 2017. for both rolling averages. The trends demonstrate compliance for the 12 months preceding the inspection with the exception of exceeding the 60 ppmvd 7-day rolling average due to a flaring incident that occurred February 7, 2017. The flaring event was a reportable event and was reported in the State of Texas Environmental Electronic Reporting System (STEERS). I observed the FCCU Continuous Emission Monitoring System (CEMS) and that the calibration gases are of the correct concentration and current. I reviewed the relative accuracy test audit (RATA) performed December 21-23, 2016 for each CEMS and found the relative accuracies for the CEMS to be within allowable requirements of 40 CFR, Part 60, Appendix F. B. Control of SO2 Emission from FCCUs Status: Complete. Program Summary: TOTAL shall limit SO2 emissions from any FCCU to 25 ppmvd on a 365 day rolling average and 50 ppm on a 7 day rolling average. APPENDIX 5 contains SO2 emissions trends for the FCCU from August 1, 2016 to August 1, 2017. The trends demonstrate compliance for the 12 months preceding the inspection with the exception of exceeding the 50 ppmvd 7-day rolling average due to a flaring incident that occurred February 7, 2017. The flaring event was a reportable event and was reported in STEERS. I observed the SO2 CEMS to be properly installed and that the calibration gases are current and of the proper concentrations. I reviewed the RATA performed December 21-23, 2016 for each CEMS and found the relative accuracies for the CEMS to be within allowable requirements of 40 CFR, Part 60, Appendix F. EPA Inspection Report - Page4 of 103 Total Petrochemicals and Refining, Port Arthur Refinery 8/22-24/2017 C. Control of Particulate Emissions from FCCUs Status: Complete. Program Summary: TOTAL shall limit PM emissions from any FCCU to 0.5 pounds or less per 1000 pounds of coke burned in a 3-hour average basis. TOTAL Port Arthur FCCU operates in full burn mode and PM emissions are controlled by a wet gas scrubber. Continuous parameter monitoring of pressure drop and liquid to gas (L/G) ratios. A 0.022 L/G ratio for the wet gas scrubber and a minimum pressure drop of 15.0 inches of water has been established by stack testing. APPENDIX 6 contains both pressure drop and L/G ratio trends for the wet gas scrubber from August, 2016 to August 2017. The trends demonstrate compliance with the established minimums with the exception of the February 7 flaring incident reported in STEERS. The FCCU was tested for particulate emission in May, 2013. I observed the opacity from the wet has scrubber to be less than 10% throughout the inspection. D. Control of CO Emissions from FCCUs Status: Complete. Program Summary: TOTAL shall limit CO emissions from any FCCU to 500 ppmvd or less on a 1-hour average basis and 100 ppmvd or less on a 365-day average basis. APPENDIX 7 contains the FCCU CO emission trends for the FCCU from August 1, 2016 to August 1, 2017. The 1-hour 500 ppm limit was exceeded due to the flaring incident of February 7, 2017 as reported in STEERS. The 365-day average of 100 ppmvd was exceeded four times during the time period due to hydrocarbon flaring incidents. I observed the CEMS to be properly installed and that the calibration gases are current and of the proper concentrations. I reviewed the RATA performed December 21-23 for the FCCU CEMS and found the relative accuracies for the CEMS to be within allowable requirements of 40 CFR, Part 60, Appendix F. E. NSPS Subparts A and J Applicability to FCCU Regenerator Status: Complete. Program Summary: TOTAL shall comply with all requirements of 40 CFR Part 60, Subparts A and J for each relevant pollutant. The emission trends demonstrate that the emission limits contained in NSPS Subparts A and J are being met with the exception of flaring incidents. EPA Inspection Report - Page5 of 103 Total Petrochemicals and Refining, Port Arthur Refinery 8/22-24/2017 F. Control of NOx Emissions from Heaters and Boilers Status: Complete. Program Summary: TOTAL shall install NOx control technology covered heaters and boilers as listed in Appendix A of the CD with a refinery wide NOx emission limit of no greater than 0.052 pounds of NOx per mmBTU. APPENDIX 8 is an up to date list of heaters and boilers at the refinery covered by Appendix A to the CD. APPENDIX 8 also contains a list of heaters and boilers with installed NOx controls (lo- NOx burners) Trends for heaters with NOx CEMS from August 1, 2016 to August 1, 2017 is also included in APPENDIX 8. In addition, APPENDIX 8 includes a bar chart showing NOx emission prior to and after implementation of the CD based on stack tests and CEM data. I reviewed the RATA results for each heater and boiler CEMS performed November 2, 2016 and found the relative accuracies for the CEMS to be within allowable requirements of 40 CFR, Part 60, Appendix F. G. Control of SO2 Emissions from, and NSPS Applicability to, Heaters and Boilers Status: Complete. Program Summary: TOTAL shall comply with 40 C.F.R. Part 60, Subparts A and J for fuel combustion devices. TOTAL `s Port Arthur refinery operates a single fuel gas system. A written description is included in APPENDIX 9. Also included in APPENDIX 9 is a fuel gas H2S trend for August 1, 2016 to August 1, 2017.The NSPS H2S fuel gas content limit of 160 ppm was exceeded once due to a hydrocarbon flaring incident occurring October 27, 2016 as reported in STEERS. I reviewed the relative accuracy test audit (RATA) results for the H2S 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 H2S analyzers were installed correctly and that the calibration gases are of the correct concentration and current. Part VI, New Source Performance Standards ("NSPS") and Flaring Status: Complete, pending review by EPA Region 6. Program Summary: TOTALs Sulfur Recovery Plants (SRP's) shall comply with 40 CFR 60 Subparts A and J. TOTAL's Port Arthur refinery operates four SRP's (SRU-1, SRU-3, SRU-4 and SRU-5) SRUs 1 and 3 share a common tail gas treatment unit and thermal oxidizer. SO2 emission trends for the three thermal oxidizers from August 1, 2016 to August 1, 2017 are included in APPENDIX 10. The trends show compliance with NSPS emission limits for the 12-month period preceding the inspection. I observed that the sulfur pits were vented to the tail gas treatment units. EPA Inspection Report - Page6 of 103 Total Petrochemicals and Refining, Port Arthur Refinery 8/22-24/2017 I reviewed the relative accuracy test audit (RATA) results for the 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 analyzers were installed correctly and that the calibration gases are of the correct concentration and current. TOTAL 's Port Arthur refinery operates four flaring devices. The East flare was installed in 2010 after the CD was entered to serve a delayed coker unit. All four flares are subject to NSPS requirements. All four flares are tied together with a flare gas recovery system, however the Middle flare is now isolated and used only for maintenance. The refinery operates two flare gas recovery units. Flare Gas Recovery Unit No. 1 consist of three two-stage compressors while Flare Gas Recovery System No. 2 uses one two-stage compressor. Appendix 11 are operational trends of the four compressors from August 1, 2016 to August 1, 2017. The chart indicates that the operational capacity of the system is adequate to recover the flare gases under normal operating conditions. Appendix 12 contains a list of all hydrocarbon and acid gas flaring events since the CD was entered. Reports have been generated and submitted to EPA as required. The preventive maintenance and operating plan was submitted to EPA January 8, 2008. I observed no smoke or flames being emitted by the flares. I also observed the flares using an infrared gas 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. VII. Benzene Waste Operations NESHAP ("BWON") Program Enhancements Status: Complete. Program Summary: In addition to complying with 40 CFR 61 Subpart FF (Benzene Waste NESHAP) TOTAL shall comply with the 6BQ compliance option (40 CFR 61.342(e)). TOTAL's Port Arthur refinery is implementing the 6BQ compliance option of Subpart FF following the first amendment to the CD file September 20, 2013 using upstream controls and covered enhanced biological waste water treatment system. A written description of the system and simplified process diagram are included in APPENDIX 13. Also included in APPENDIX 13 is a list of above ground storage tanks in BWON service. I reviewed the most recent inspection record for these tanks and found the inspections frequency and findings consistent with BWON tanks seal gap requirements. I reviewed the analytical result of the treatment plant effluent for May - July, 2017 and found benzene results were all non-detectable. A master list of all carbon canisters in BWON service is also included in APPENDIX 13. I reviewed canister inspection records for July, 2017 that indicate canisters experiencing break-through have been replaced as required. The canister systems observed during the inspection were double canister system arranged in series as required. Monitoring personnel were observed monitoring the canisters at the EPA Inspection Report - Page7 of 103 Total Petrochemicals and Refining, Port Arthur Refinery 8/22-24/2017 outlets of the primary canister as required. However, monitoring personnel are using a TVA 1000 to monitor breakthrough of the primary canister. I recommended an instrument with more accuracy in the low ppm range be used. 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. VII. Leak Detection and Repair ("LDAR") Program Status: Complete. Program Summary: TOTAL shall implement measures to enhance the refinery's LDAR program under 40 CFR Subpart GGG, Part 61 Subparts J and V and Part 63 Subparts F, H and CC. TOTAL Port Arthur refinery uses Dexter Field Services to conduct repairs and follow-up monitoring. 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 was found to be up to date and lists approximately 300 components that currently require a shut down for repair. I reviewed instrument calibration logs. Dexter Field Services has implemented an end of day drift check required by the CD as well as a mid-day drift check. I reviewed the quarterly precision test results for the instruments being used at the facility and calibration gas certificates. I reviewed calibration records for July, 2017 and found the records to be consistently being logged with instrument drift calculations included. 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 (Leak DAS 4.0). Records indicate annual training is being conducted and is incorporated into new employee orientation. I walked through the FCCU, Crude Unit, DeMex Unit, the SRU Units, Boiler House `s 300 and 350, NHT Reformer, Waste Water Treatment Plant, fuel gas area, and covered boilers process units and observed no open ended lines or valves. A third party audit of the LDAR program was conducted by EMSI Environmental Services June 26-29, 2017. The audit found the facility to be meeting the CD requirements. EPA Inspection Report - Page8 of 103 Total Petrochemicals and Refining, Port Arthur Refinery 8/22-24/2017 IX. Permitting Status: Complete. APPENDIX 14 contains excerpts from the most recent NSR operating permits 18936, 46396, PSD-TX- 1073M2 and NO44 imposing emission limits and CEM QA requirements contained in the CD. Section III - AREAS OF CONCERN The affirmative relief items contained in part V of the CD appear to have been met. Alternative Monitoring Plans addressing equipment pertaining to the CD have been approved. CD imposed limits and continuous emission monitoring requirements are incorporated in federally enforceable operating permits and the permits. I recommended that a more sensitive instrument be used to monitor breakthrough of primary carbon canisters in BWON service. 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, written description. Appendix 4 - FCCU NOx emission trend. Appendix 5 - FCCU SO2 emission trend. Appendix 6 - FCCU Wet Gas Scrubber Parameter Monitoring. Appendix 7 - FCCU CO emission trends with excursion explanations. Appendix 8 - Updated list of boilers, heaters with NOx controls, NOx trends, NOx emission prior to and after implementation of the CD. Appendix 9 - Refinery fuel gas system written description, mix drum H2S analyzer trend. Appendix 10 - SRP's SO2 emission trends. Appendix 11 - Flare Gas Recovery Compressors Recorded Operational Parameters. Appendix 12 - Hydrocarbon and Acid Gas Flaring Events Appendix 13 - BWON description and Flow Diagram, Carbon Canisters and BWON Storage tanks. Appendix 14 - Operating Permits Excerpts. Appendix CBI (None) EPA Inspection Report - Page9 of 103 Total Petrochemicals and Refining USA Inc./Port Arthur Refinery Inspection Date: 08/22-24/20167 Appendix 1 Photograph Log EPA Inspection Report - Page10 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas Boiler's 350 and 300 CEMS. (Shared stack) NOx = 17.5 ppm CO = -0.5 ppm O2 = 4.9% EPA Inspection Report - Page11 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas Condensate Splitter CEMS. NOx = 28.1 ppm CO = - 5.0 ppm O2 = 5.14% EPA Inspection Report - Page12 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas Crude Heater 101 CEMS. NOx = 28.0 ppm CO = 1.35 ppm EPA Inspection Report - Page13 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson O2 = 4.33% State: Texas Crude Heater 101 Lo-NOx burners EPA Inspection Report - Page14 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas Crude Heater 201 CEMS NOx = 20.3 ppm CO = -1.6 ppm EPA Inspection Report - Page15 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson O2 = 4.97 ppm State: Texas Crude Heater 201 Lo-NOx burners. EPA Inspection Report - Page16 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas Crude Heater 202A CEMS. NOx = 39.15 ppm EPA Inspection Report - Page17 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson CO = -0.27 ppm O2 = 6.84 ppm State: Texas Crude Heater 202B CEMS. NOx = 40.50 ppm CO = -0.11 ppm EPA Inspection Report - Page18 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson O2 = 6.7% State: Texas Crude Heater 301 CEMS NOx = 21.1 ppm CO = 0.08 ppm EPA Inspection Report - Page19 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson O2 = 3.09 % State: Texas Crude Heater 301 Lo-NOx burners. EPA Inspection Report - Page20 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas Reformer Heaters 1 - 6 CEMS. Shared Stack. NOx = 16.3 ppm CO = -2.2 ppm O2 = 6.94 % EPA Inspection Report - Page21 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas Reformer Heater H-101 Lo NOx burners. EPA Inspection Report - Page22 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas Reformer Heater H-102 Lo NOx burners. EPA Inspection Report - Page23 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas FCCU CEMS. NOx = 23.93 ppm SO2 = 1.96 ppm CO = 30.32 ppm O2 = 0.95 % EPA Inspection Report - Page24 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas FCCU Wet Gas Scrubber Stack EPA Inspection Report - Page25 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas SRU 4 CEMs NOx = 19.5 ppm CO = 5.8 ppm SRU 4 CEMS SO2 = 109.2 ppm O2 = 4.9 % EPA Inspection Report - Page26 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas SRU 5 CEMS NOx = 17.7 ppm CO = 21.4 ppm SRU 5 CEMS SO2 = 98.8 ppm O2 = 5.99 % EPA Inspection Report - Page27 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas SRU 1 and 2 CEMS (Shared Stack) Photo shows calibration span gas concentrations, stack concentrations below: SO2 = 51.18 ppm CO = 28.2 ppm O2 = 4.02 % EPA Inspection Report - Page28 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas Unibon CEMS. NOx = 17.8 ppm CO = -0.1 ppm O2 = 6.13 % EPA Inspection Report - Page29 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas Unibon Heater Lox burners. EPA Inspection Report - Page30 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas Demex Heater 4 Lo NOx burners. EPA Inspection Report - Page31 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas Refinery Fuel Gas Mix Drum H2S Analyzer. H2S = 39.42 ppm EPA Inspection Report - Page32 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 23 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas Flare Gas Recovery 1 Compressors EPA Inspection Report - Page33 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 24 Location: Total Petrochemicals and Refining USA Inc. City: Port Arthur County/Parish: Jefferson State: Texas Flare Gas Recovery 2 Compressors. EPA Inspection Report - Page34 of 103 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 25 Location: Total Petrochemicals and Refining USA Inc. 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