Document xjXq181maR7omw4zaQRj4E3Dg

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 06/11-13/2018 Air Refinery Consent Decree Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Lion Oil Co. dba Delek US El Dorado Refinery 1005 Robert E. Lee Street El Dorado, AR 71731-7005 1005 Robert E. Lee Street El Dorado, AR 71731-7005 Union County Lance Thomasson Lance.thomasson@delekus.com Environmental Manager FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110017419667 AR0000000513900016 324110 2911 Personnel participating in inspection: Jim Gold US EPA/6EN-ASH Lance Thomasson Delek Alyse White Delek Alex Hulsey Delek Chad Stewart Delek Amanda Metzler Delek Mitch Colvin Delek Chet Chiles Delek Environmental Engineer Environmental Manager Environmental Engineer Environmental Specialist Sr. Environmental Engineer Rotational Engineer Environmental Specialist Corporate Environmental Director 281/983-2153 870/862-8111 870/862-8111 870/862-8111 870/862-8111 870/862-8111 870/862-8111 615/224-0849 EPA Lead Inspector Signature/Date gold.jim@epa.gov Jim Gold Digitally signed by gold.jim@epa.gov DN: cn=gold.jim@epa.gov Date: 2018.08.09 14:32:27 -05'00' {Inspector name} 7/11/2018 Date Supervisor Signature/Date SAMUEL TATES {Supervisor name} Digitally signed by SAMUEL TATES DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=SAMUEL TATES, dnQualifier=0000012566 Date: 2018.08.14 16:52:18 -05'00' Date Lion Oil Co. dba Delek U.S. - El Dorado Refinery Inspection Date 06/11-13/2018 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspector Jim Gold conducted an inspection of Lion Oil Co. dba Delek US - El Dorado, Arkansas Refinery (Lion Oil/Delek). At 1:00 pm on June 11, 2018, I met with Lance Thomasson, Environmental Manager the facility, for an opening conference and informed him that this was an EPA inspection to determine compliance with the federally issued Consent Decree (United States, et al. v. Lion Oil Company, Civ. No. 03-1028 entered June 12, 2003), and Stipulated Order (Case 1:03-cv-01028HFB entered September 14, 2009). I also informed Mr. Thomasson 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): Nitrogen oxide (NOx) and sulfur dioxide (SO2) reductions, leak detection and repair (LDAR), benzene waste operations (BWON), and, tail gas, acid gas, and hydrocarbon flaring. The consent decree (CD) consists of 19 Parts designated by Roman numerals I through XIX. Of these, Part V requires affirmative relief and is the focus of this inspection. Part IV contains the Consent Decree specific items numbers 11 through 26 that address the requirements of NOx, SO2, carbon monoxide (CO), particulate, volatile organic carbon (VOC), hydrogen sulfide (H2S), 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 the Lion Oil/Delek refinery. Photos taken during the inspection (15) are included as APPENDIX 1. FACILITY DESCRIPTION The facility has had multiple upgrades since original construction and now has the capacity to refine 70,000 barrels per day and operates as a fully integrated refinery with crude distillation, a fluid catalytic cracking unit (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 2. 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/lionoilcd.pdf. Section II - OBSERVATIONS Part V, Affirmative Relief/Environmental Projects 11. Control of NOx Emissions from FCCUs Status: Complete. Program Summary: Lion Oil shall limit NOx emissions from any FCCU to 20 parts per million by volume per day (ppmvd) NOx or less on a 365-day rolling average and 40 ppmvd NOx or less on a 7-day rolling average. Lion Oil/Delek operates one FCCU at the El Dorado refinery. Lion Oil Co. dba Delek U.S. - El Dorado Refinery Inspection Date 06/11-13/2018 APPENDIX 3 contains the NOx emission trends from June 1, 2017 to June 1, 2018, for both rolling averages. The trends demonstrate compliance for the 12 months preceding the inspection. The 20 ppm 365 day rolling average and 40 ppm 7 day rolling average limits are contained in the operating permit included as APPENDIX 12. I observed the FCCU NOx Continuous Emission Monitoring System (CEMS), and found that the calibration gases are of the correct concentrations and within current expiration dates. I reviewed the relative accuracy test audit (RATA) performed in May 2017 for the CEMS, and found the relative accuracies for the CEMS to be within allowable requirements of 40 Code of Federal Regulations (CFR), Part 60, Appendix F. 12. Control of SO2 Emission from FCCUs Status: Complete. Program Summary: Lion Oil/Delek 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 4 contains SO2 emissions trends for the FCCU from June 1, 2017 to June 1, 2018. The trends demonstrate compliance for the 12 months preceding the inspection, apart from exceeding the 365-day rolling average due to the refinery losing power on November 27, 2017. I observed the SO2 CEMS to be properly installed, and that the calibration gases are within current expiration dates and of the proper concentrations. I reviewed the RATA performed in May 2017 for the CEMS and found the relative accuracies for the CEMS to be within allowable requirements of 40 CFR, Part 60, Appendix F. 13. Control of Particulate Emissions from FCCUs Status: Complete. Program Summary: Lion Oil/Delek shall limit PM emissions from the FCCU to 0.5 pounds or less per 1000 pounds of coke burned in a 3-hour average basis. Lion Oil/Delek's El Dorado refinery 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. Liquid to gas (L/G) ratio for the wet gas scrubber and a minimum pressure drop have been established by stack testing. APPENDIX 5 contains both pressure drop and L/G ratio trends for the wet gas scrubber from June1, 2017 to June 1, 2018. The trends demonstrate compliance with the established minimums. The FCCU was tested for particulate emission in May 2017. A summary of the test results is included in APPENDIX 5. I observed the opacity from the wet scrubber to be less than 10% on the days of the inspection. No Method 9 observation was necessary during the inspection. Lion Oil Co. dba Delek U.S. - El Dorado Refinery Inspection Date 06/11-13/2018 D. Control of CO Emissions from FCCUs Status: Complete. Program Summary: LION OIL/DELEK shall limit CO emissions from any FCCU to 500 ppmvd or less on a 1hour average basis and 100 ppmvd or less on a 365-day average basis. APPENDIX 6 contains the FCCU CO emission trends for the FCCU from June 1, 2017 to June 1, 2018. The 1-hour 500 ppm limit was exceeded due to the refinery losing power. 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 in May 2017 for the FCCU CEMS and found the relative accuracies for the CEMS to be within allowable requirements of 40 CFR, Part 60, Appendix F. 14. New Source Performance Standards (NSPS) Subparts A and J Applicability to FCCU Regenerator Status: Complete. Program Summary: Lion Oil/Delek 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 as shown in Appendices 3-5. 16. Control of NOx Emissions from Heaters and Boilers Status: Complete. Program Summary: Lion Oil/Delek 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 7 is an up to date list of heaters and boilers at the refinery covered by Appendix A to the CD and a list of heaters and boilers with heat input greater than 100 MMBTU/hr. requiring CEMs. APPENDIX 7 also contains a list of heaters and boilers with installed NOx controls (loNOx burners) Trends for heaters with NOx CEMS from June 1, 2017 to June 1, 2018 are also included in APPENDIX 7. I reviewed the RATA results for each heater and boiler CEMS performed November 2017 and found the relative accuracies for the CEMS to be within allowable requirements of 40 CFR, Part 60, Appendix F. 17. Control of SO2 Emissions from, and NSPS Applicability to, Heaters and Boilers Status: Complete. Program Summary: Lion Oil/Delek shall comply with 40 C.F.R. Part 60, Subparts A and J for fuel combustion devices. Lion Oil/Delek `s El Dorado refinery operates a single fuel gas system. A written description is included in APPENDIX 8. Also included in APPENDIX 8 is a Platformer Heater and Crude Atmospheric Heater SO2 trends for June 1, 2017 to June 1, 2018. The facility monitors SO2 from these two heaters in lieu of Lion Oil Co. dba Delek U.S. - El Dorado Refinery Inspection Date 06/11-13/2018 using an H2S analyzer on the fuel gas system. The # 9 Platformer Heater is designated as the primary source for compliance allowed in condition PW 11 of the Title V operating permit contained in Appendix 8. And as allowed under 40 CFR 105(a) 3(iv). I reviewed the relative accuracy test audit (RATA) results for the SO2 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 within current expiration dates. 18. NSPS Applicability of and Compliance for Sulfur Recovery Plant According to permit conditions and SO2 emission trends the facility is complying with NSPS applicable requirements with the exceptions of upsets as shown in Appendix 9. 19. NSPS Applicability of and Compliance for Flaring Devices Status: Complete, pending review by EPA Region 6. Program Summary: Lion Oil/Delek's Sulfur Recovery Plants (SRPs) shall comply with 40 CFR Part 60, Subparts A and J. Lion Oil/Delek's El Dorado refinery operates one SRP. SO2 emission trends for the thermal oxidizers from June 1, 2017 to June 1, 2018 is included in APPENDIX 9. 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. 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 with current expiration dates. Lion Oil/Delek's El Dorado refinery operates two flaring devices, the Low Pressure (LP) flare and the High Pressure (HP) flare. Both flares are subject to NSPS requirements and are tied together with a flare gas recovery system. The flare gas recovery system consists of three liquid ring sealed compressors. Appendix 10 includes operational trends of the compressors from June 1, 2017 to June 1, 2018. The charts indicate that the operational capacity of the system is adequate to recover the flare gases under normal operating conditions. Appendix 10 contains a list of all hydrocarbon flaring events since the CD was entered. Reports have been generated and submitted to EPA as required. I observed no smoke or flames being emitted by the flares. I also observed the flares using an optical gas infrared imaging device, and did not observe any abnormal flaring activity (e.g. puffing or indications of incomplete combustion). During the inspection, the High-Pressure flare was combusting a small amount of process gas due to operational adjustments. 22. Benzene Waste Operations National Emission Standards for Hazardous Air Pollutants (BWON NESHAP) Program Enhancements Lion Oil Co. dba Delek U.S. - El Dorado Refinery Inspection Date 06/11-13/2018 Status: Compliance. Program Summary: In addition to complying with 40 CFR Part 61 Subpart FF (BWON NESHAP), Lion Oil/Delek shall comply with Paragraphs B through N of the consent decree. At the time the CD was entered Lion Oil/Delek's El Dorado refinery was determined to have a benzene annual total benzene (TAB) of less than 10 megagrams (Mg). The desalter wastewater steam is sent to a flash separator, where hydrocarbons are flashed off before the water is sent to an uncovered API oil/water separator. Appendix 11 contains trends showing continuous operation of the flash separator. The water stream from the flash separator is sent to equalization tanks, which in turn feed an uncovered API oi/water separator that is now subject to NESAHP Subpart FF. Since the facility has exceeded 10 Mg Total Annual Benzene (TAB) the 6 Benzene Quantity (6BQ) option of 40 CFR 61.342(e) has been implemented. Since the benzene quantity leaving the equalization tanks is less than 6 Mg/year the API separator is part of the waste water treatment system and no further controls are needed. I reviewed inspection reports for the above ground storage tanks (external floating roof tanks), and found the gap measurements of both primary and secondary seals to be within the allowable gaps allowed by NESHAP Subpart FF. I reviewed canister inspection records for May 2018 that indicate canisters experiencing break-through have been replaced. The canister systems observed during the inspection were double canisters arranged in series as required. During the inspection I observed refinery personnel monitoring the canisters at the outlets of the primary canister, as required. 23. Leak Detection and Repair ("LDAR") Program Status: Complete. Program Summary: Lion Oil/Delek shall implement measures to enhance the refinery's LDAR program under 40 CFR Part 60 Subpart GGG, Part 61 Subparts J and V, and Part 63 Subparts F, H and CC. Lion Oil/Delek's El Dorado refinery uses a contractor to conduct leak detection monitoring, repair and follow-up monitoring. Chronically leaking components are tracked and replaced. Drill and tap repair techniques are used on leaking valves if the 500 ppm limit is exceeded and the valve cannot be repaired using conventional methods. The plant wide delay of repair list was found to be up to date and lists approximately 60 components that currently require a shut down for repair. I reviewed the contractors instrument calibration logs. End of day drift check required by the CD as well as a mid-day drift check are being performed for each instrument when used. I reviewed the quarterly precision test results for the instruments used at the facility and calibration gas certificates. I reviewed calibration records for May 2018 and found the records to be consistently 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 conducted using data loggers with leak tracking and reporting software. Records indicate annual training is conducted and incorporated into new employee orientation. I walked through the FCCU, Crude Unit, SRU Unit, Platformer, Wastewater Treatment Plant, fuel gas area, and covered boilers process units, and observed no open-ended lines or valves. Lion Oil Co. dba Delek U.S. - El Dorado Refinery Inspection Date 06/11-13/2018 24. Permitting and Alternative Monitoring Status: Complete. APPENDIX 12 contains excerpts from the most recent Title V operating permit imposing emission limits and CEMS quality assurance requirements contained in the CD. Alternative Monitoring Plans addressing equipment pertaining to CD requirements have been approved by EPA and are attached to the permit. CD-imposed limits and continuous emission monitoring requirements are incorporated in federally enforceable operating permits and authorizations. Section III - AREAS OF CONCERN At the time the consent decree was entered the facility's total annual benzene (TAB) was less than 10 megagrams (Mg), exempting the facility from applying controls under NESHAP Subpart FF. However, beginning in 2010 the TAB exceeded 10 Mg. In the third quarter of 2009 the facility installed a secondstage desalter followed by a flash separator to reduce the TAB prior to the desalter water stream being sent to the process and storm water sewer system. The wastewater streams are collected and sent to equalization tanks prior to the wastewater treatment plant. The equalization tanks feed an above ground, uncovered API oil/water separator which feeds the waste water treatment plant Section IV - POST INSPECTION DEBRIEFING AND FOLLOW UP A closing conference was held with personnel listed as participating in the inspection at 11:00 a.m. on June 13th. Photos taken and process units visited during the inspection were discussed as well as LDAR spot checking. The open API separator was discussed and the need for follow-up discussions and review of the BWON program were agreed upon. It was determined that because the 6BQ option has been implemented the API separator is part of the waste water treatment system and no further controls are needed. Section V - LIST OF APPENDICES Appendix 1 - Photo Log Appendix 2 - Plant wide process flow diagram, written description. Appendix 3 - FCCU NOx emission trend. Appendix 4 - FCCU SO2 emission trend. Appendix 5 - FCCU Wet Gas Scrubber Parameter Monitoring. Appendix 6 - FCCU CO emission trends with excursion explanations. Appendix 7 - Updated list of boilers, heaters with NOx controls, NOx trends. Appendix 8 - Refinery fuel gas system monitoring description and permit requirements. Plat and Vac Heater S02 emission trends. Appendix 9 - SRP SO2 emission trends. Appendix 10 - Flare Gas Recovery Compressors Recorded Operational Parameters. Appendix 11 - BWON diagram and Desalter water flash separator operation. Appendix 12 - Operating Permits Excerpts. CBI - not applicable.