Document yrG7GaL81vGBmqgkeZzqrYK9E

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Cenovus Lima Refining Company (LRC), Lima, Ohio Laura Steel, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Cenovus Lima Refining Company (LRC) Facility Location: 1233 S Metcalf St., Lima, OH 45804 Date of Inspection: June 27-30, 2022 EPA Inspector(s): 1. Constantinos Loukeris, Environmental Engineer 2. Veronica Fischer, Environmental Engineer 3. Laura Steel, Environmental Engineer 4. Scott Hamilton, Environmental Scientist 5. Katherine Haile, Physical Scientist 6. Diana Degen, Life Scientist Other Attendees: 1. Jim Fain, Senior Environmental Manager 2. Claudio Ingaramo, VP U.S. Refining - General Manager 3. Gary Vonderembse, Senior Environmental Engineer 4. Eric Wireman, Senior Operations Manager 5. Matt Elkins, Environmental Manager 6. Anthony Milianti, Senior Environmental Manager 7. Amy Rahrig, Operations Manager 8. Doug Knapke, Process Engineering Manager 9. Sierra Slusser, Environmental Technologist 10. Emily Kerber, Senior Environmental Technologist (QQQ/wastewater) Page 1 of 9 11. Melanie Reese, Environmental Analyst 12. Marta Mata, Senior Environmental Engineer 13. Amanda Richey, Environmental Engineer 14. Bailey Lininger, Air Compliance Co-Op 15. Alex Lause, Co-Op 16. Nathan Turner, LRC Personnel 17. Collin Wurth, LRC Personnel 18. Vincent Ruscio, LRC Personnel 19. Greg Phillips, LRC Personnel 20. Chad Ulm, LRC Personnel Contact Email Address: Jim.Fain@cenovus.com Purpose of Inspection: To assess compliance with requirements of NESHAP Subpart FF, NSPS QQQ, and LRC's Consent Decree Facility Type: Refinery Regulations Central to Inspection: National Emission Standards for Hazardous Air Pollutants for Benzene Waste Operations (BWON) at 40 C.F.R. Part 61, Subpart FF and New Source Performance Standards for VOC Emissions from Petroleum Refinery Wastewater Systems (QQQ) at 40 C.F.R. Part 60, Subpart QQQ Arrival Time: 2:20 PM ET on June 27, 2022 Departure Time: 11:30 AM ET on June 30, 2022 Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility The following information was obtained verbally from LRC representatives unless otherwise noted. Company Ownership: LRC's ownership changed from Husky Energy to Cenovus Energy in 2021. Page 2 of 9 Process Description: LRC provided EPA an overview of their equipment and sewers/drains subject to BWON and QQQ. The facility consists of 13 process units, including three flares and twelve tanks (ten slop oil tanks - 26, 28, 72, 77, 84, 78, 79, 256, 255, 253 - and two off spec wastewater tanks - 172, 173). All tanks have an internal floating roof (IFR) except 72 and 84, which have a closed vent system and fixed roof to flare gas recovery. LRC uses piping and instrumentation diagrams (P&IDs) to track BWON and QQQ-applicable refinery elements. The refinery has two different sewer systems that are controlled. BWON sewers start at the facility's sulfur recovery units (SRUs) and continue through 2 induced nitrogen gas floats, 2 corrugated plate interceptor units (CPIs), three American Petroleum Institute (API) separators, and the tank farm. The combined sewer collects storm water and process water; however, in 2014, the hydrotreater systems were segregated into storm drains, process drains, and closed drains. The controlled streams from the combined sewer are to two "off-spec" water tanks. The streams from the BWON tanks and offspec water tanks are then fed into aeration basins. The sludge from the off-spec water tank is processed by a third party that is located onsite. The benzene extraction unit has its own closedvent system with a tetralin glycol scrubber, and its sewer is not controlled. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA conducted leak detection and repair monitoring using a Toxic Vapor Analyzer Model 2020 (TVA 2020) flame ionization detector on LRC's BWON sewer system components that are required to be designed to operate with no detectable emissions (NDE), which is indicated by an instrument reading of less than 500 ppm. Several pieces of equipment were missing LDAR tags (hatch on PR100036, 3 gate valves near CPIs). EPA was unable to perform Method 21 monitoring at the West IGFU due to significantly high background readings (greater than 1000 ppm). There was also a visible pool of liquid at plate 1 on the West IGFU, as well as a strong odor. EPA Region 5's Air & Radiation Division (ARD) mobile monitoring van conducted ambient air monitoring along access roads within the refinery. The mobile monitoring van detected toluene and benzene near the CPIs and aeration basin, hydrogen sulfide next to a loading asphalt truck, and toluene near Tank 108. Suma canisters (6L) were taken by ARD from the following: one of the pressure relief valves on the CPI, the aeration basin, and API C. In addition, EPA visually inspected drain hubs and other QQQ equipment, including the BWON drain in the Gasoline Distillate Unit, drains in the Boilerhouse, and drains and junction boxes in the Crude Unit. LRC's total annual benzene (TAB) typically amounts to 40-80 Megagrams (Mg) controlled and 3 Mg uncontrolled. LRC normally conducts end-of-line (EOL) sampling monthly and increases to weekly when the facility detects high levels of benzene. The facility's QQQ program is managed through LeakDAS. LRC conducts quarterly visual monitoring and annual "no detectable emissions" (NDE) monitoring with EPA Method 21, and monthly visual inspections on QQQ drains. LRC personnel stated that when performing Method 21 monitoring, the valves themselves are not monitored--only capped ends or second valves. The facility employees Page 3 of 9 approximately 125 embedded contractors with approximately 450-500 FTE and is currently using Hydro Chem as a leak detection and repair contractor, as they have been since 2019. Photos and/or Videos: were taken during the inspection. Field Measurements: were taken during this inspection. The table below summarizes EPA's TVA 2022 monitoring results: Component ID Tag 19194 Tag 19151 Tag 179159 Tag 97542 Tag 97551 Tag 97528 Tank 35191433 API A API A API B API B API B API B API B API B API B API B API B API B API B API C API C Inlet sump to APIs Equipment Type East CPI West CPI EPA's Reading (ppm) 43,000 45,000 Southeast CPI cover plate Northeast CPI cover plate Cover plate sight glass Cover plate sight glass Tank 35 glycol flange Seal on PRV Seal Uncapped OEL, double block closed Southwest corner Southwest seam Southwest seam South seam Northwest seam Northwest seam corner Northwest seam Northwest seam Northwest inner corner seam bolt Sampling drain Northwest seam Vent seam Center manhole cover (MH 13 36") 6,800 1,280 100,000 3,371 1,497 25,262 1,800 25,266 6,732 11,400 1,376 6,300 2,283 1,400 3,413 13,800 3,300 250 25,278 3,100 670 LRC's Reading (ppm) >50,000 >50,000 5,838 6,850 104,501 80,116 - 860 - - - 688 - Additional Notes See Image 2 See Image 3, two busted gaskets See Image 4 See Image 5 See Image 6 See Image 7 See Images 8 and 9 - - - - Page 4 of 9 Inlet sump to APIs Inlet sump to APIs Inlet sump to APIs Inlet sump to APIs WWTP WWTP E-1 WWTP E-1 East manhole cover (MH 14 36") Southwest plate (MH 12) MH 15 MH 5A East 48" opening CB-1 drain In-ground lift station In-ground lift station Tank 1 Top of Tank 84 Gage arm Conservation vent 1 5,100 680 2,200 2,300 710,500 4,600 650 533 16,000 Top of Tank 84 Top of Tank 84 Sample Box 90784 Top of Tank 100173 Top of Tank 100173 Top of Tank 100173 Top of Tank 100173 Top of Tank 100173 Sample Box next to TK 100173 Top of Tank 100172 Top of Tank 100172 Conservation vent 2 Conservation vent 3 Door (open) Vent 1 Vent 2 Vent 3 Vent 4 Vent 6 Door Vent 2 Vent 3 5,000 13,000 1,500 1,070 1,024 805 975 540 22,000 732 760 Page 5 of 9 - - - Opening of manhole - 2 openings, no seal - - - Dry drain - Door opening to lift station weir - Cracked caulk on side panels of lift station - - - Vent numbering for all tanks starts at the vent to the right of the stairwell moving counterclockwise - - - - - No water seal - - - - - - - - - - - - - - - - Top of Tank Vent 4 700 - - 100172 Top of Tank Vent 5 700 - - 100172 Top of Tank Vent 6 950 - - 100172 Top of Tank Center vent 677 - - 100172 Top of Conservation vent 970 8,720 - Equalization 1 Tank Top of Conservation vent 85,000 - - Equalization 2 Tank Top of Conservation vent 22,000 - - Equalization 3 Tank Top of Vacuum breaker 580 - - Equalization Tank The table below summarizes the number of visual inspections completed by EPA by process unit: Process Unit/Equipment Type Drains Open-ended lines (OELs) Valves Tanks Number Visually Inspected 40 22 63 34 Notes 7 OELs with no cap, 2 were fixed during the inspection The table below summarizes the visual inspection observations identified by EPA in the GDU (BWON), Boilerhouse (QQQ), and Crude (QQQ) process units: Component ID CB-2 MH-1 MH-2 MH-3 P-111 P-110 P-109 Equipment Type Drain Manhole Manhole Manhole Drain Drain Drain Observation Oily sheen on top of water and around drain cover/no seal Rocks and debris on top of manhole cover, cracking on the outside of its seal, CPC to make sure Rocks and debris on top of manhole cover Rocks and debris on top of manhole cover Caulk around drain is peeling up/no seal Can't see down the drain to verify water seal Oily residue around covered drain/no seal--lots of debris inside, difficult to see Page 6 of 9 HUB-2 P-106 Not identified in LRC's QQQ program CB-3-LIU CB-4-LIU CB-7 CB-6 CB-8 CB-9 C-1-LIU T-6-A T-6-B T-6-F T-6-D T-6-C T-6-E T-6-G T-6-J CO-6-A CO-6-B CO-buried T-6-G Manhole near froth tank Manhole 12 Manhole 15 Sample box 90784 100173 Dike HUB-5 CB-5-LIU T-6-H LDAR 14626 drain hub LDAR 14993 drain hub Grated drain next to Recycle Comp KO Drum (PR160116) Manhole Drain Drain Drain Drain Drain Drain Drain Drain Manhole Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Manhole Manhole Manhole Manhole Manhole Manhole Drain Drain Manhole Manhole Drain Caulk around drain is peeling up/no seal (see Image 80) Oily residue around covered drain, lots of debris Covered drain next to CB-011--oily sheen on top of water/no seal Oily residue around covered drain, lots of debris Oily sheen on top of water/no seal Oily residue around covered drain Oily residue around covered drain Oily residue around covered drain Oily residue around covered drain Sewer sample point, covered. 10.5 ppm benzene detected, not a sealed drain (see Image 86) Covered in rocks No cap or water seal No water seal Covered in rocks, completely buried drain (see Images 92 and 93) Drain covered in rocks/not visible (see Image 91) No water seal, dry drain Cap off No water seal Not sealed, clean out drain Open clean out Condensate drip drain, completely buried Uncapped, LRC needs to figure out if it is in service Partially buried No seal and opening No seal and 2 openings No seal No seal and 6 bolt openings Caulk around drain is peeling up/no seal (see Image 79) Oily sheen on top of water/no seal (see Images 82 and 83) No water seal, dry drain (see Image 95) Caulk around drain is peeling up/no seal (see Images 102 and 103) Caulk around drain is peeling up/no seal (see Image 104) Oily sheen on top of water/no seal, debris (see Images 105-107) Page 7 of 9 RECORDS REVIEW 1. P&ID of BWON equipment and drains/sewers 2. P&ID of QQQ drains/sewers 3. Daily sign-in sheets for Cenovus meetings and debriefs (6/27 afternoon, 6/29 morning and afternoon, and 6/30 afternoon) 4. BWON Quarterly Reports CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: 1. BWON Quarterly Reports (2019 - 2021) 2. BWON Annual Inspection Reports (2019 - 2021) 3. BWON Annual Certifications and TAB Reports (2019 - 2021) 4. NSPS Subpart QQQ Semi-Annual Inspection Reports (2019 - 2021) 5. LeakDAS backup data for BWON and QQQ 6. Engineering Design Documentation for the Controlled Waste Management Units 7. Emails from Jim Fain on July 4, 10, and 18, 2022: EPA Audit Follow-up 8. P&ID of BWON equipment and drains/sewers 9. P&ID of QQQ drains/sewers LRC provided the requested documents above via a Microsoft OneDrive link provided by EPA to LRC, except for #5, 8, and 9. Concerns: BWON: Numerous units (e.g. CPIs, API, IGFU) had detectable emissions above 500 ppm across BWON waste management units complying with the BWON control requirements; The West IGFU Top North Mixer was unable to be inspected/approached due to high background (detected by TVA); The BWON stream from the equalization tank became open to atmosphere prior to being sent for further control in the aeration basins; Numerous units (e.g. CPI's, API, IGFU) had detectable emissions above 500 ppm across BWON waste management units complying with the BWON control requirements Fixed roof and floating roof tanks with venting from safety devices above detectable emissions; The current Method 21 program needs to be reviewed and updated to include tanks/portions of tanks in the BWON program; Subpart FF-applicable manhole cover was found to be unsealed with benzene emissions of 10.5 ppm detected near the cover; and No engineering design documentation as specified in BWON 61.356(d) for any waste management units. Page 8 of 9 QQQ: Numerous QQQ drains were found without a water seal, LRC has not identified all drains associated with each QQQ junction box as part of the program, LRC's QQQ maps were missing information, grated drains did not have manhole covers. DIGITAL SIGNATURES Digitally signed by Steel, Steel, Laura Date: 2022.08.24 Laura Report Author: __________________08_:3_7:_52_-_05_'00_' ________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL Date: 2022.08.24 ______M_A__R_S__H_A_L__L__0_8:_42_:1_7 _-0_5'0_0'_________ Page 9 of 9 Facility Name: Lima Refining Company Facility Location: 1233 S Metcalf St., Lima, OH 45804 Date of Inspection: June 27, 2022 APPENDIX A: DIGITAL IMAGE LOG Inspector Name: Veronica Fisher, Laura Steel Archival Record Location: OneDrive: https://usepa-my.sharepoint.com/:f:/r/ personal/fischer_veronica_epa_gov/Documents /Cases/Cenovus/Cenovus%20Lima?csf=1&web= 1&e=Mue0PM Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 File Name IMG_0007.JPG IMG_0008.JPG IMG_0009.JPG IMG_0010.JPG IMG_0011.JPG IMG_0012.JPG IMG_0013.JPG IMG_0014.JPG IMG_0015.JPG IR_0327.jpg MOV_0328.mp4 MOV_0329.mp4 MOV_0330.mp4 MOV_0331.mp4 MOV_0332.mp4 MOV_0333.mp4 Date and Time (incl. Time zone and DST) 6/28/22 10:21 AM ET 6/28/22 10:57 AM ET 6/28/22 10:58 AM ET 6/28/22 11:15 AM ET 6/28/22 11:20 AM ET 6/28/22 11:24 AM ET 6/28/22 11:31 AM ET 6/28/22 11:57 AM ET 6/28/22 11:57 AM ET 6/28/22 1:58 PM ET 6/28/22 1:59 PM ET 6/28/22 2:02 PM ET 6/28/22 2:12 PM ET 6/28/22 2:14 PM ET 6/28/22 2:15 PM ET 6/28/22 2:17 PM ET Description of Image Uncovered/unsealed hazardous waste tank, TVA reading of ~3 ppm East CPI West CPI IGFU Southeast CPI cover plate IGFU Northeast CPI cover plate, broken seal IGFU cover plate sight glass (5th leak) IGFU cover plate sight glass (6th leak) Glycol flange (7th leak) Glycol flange (7th leak) East CPI Hydrocarbon emissions imaged from the East CPI PRV Hydrocarbon emissions imaged from the West CPI PRV Hydrocarbon emissions imaged from the West IGFU plate 1 and agitator Hydrocarbon emissions imaged from the West IGFU plate 2 and agitator Hydrocarbon emissions imaged from the West IGFU plate 3 and agitator Hydrocarbon emissions imaged from the West IGFU plate 4 and agitator Appendices Page 1 of 6 Facility Name: Lima Refining Company Facility Location: 1233 S Metcalf St., Lima, OH 45804 Date of Inspection: June 27, 2022 17 MOV_0334.mp4 6/28/22 2:21 PM ET 18 IMG_0016.JPG 6/28/22 2:46 PM ET 19 IMG_0017.JPG 6/28/22 4:58 PM ET 20 IMG_0018.JPG 6/28/22 4:58 PM ET 21 IMG_0019.JPG 6/28/22 4:58 PM ET 22 IMG_0020.JPG 6/28/22 4:59 PM ET 23 IMG_0021.JPG 6/28/22 4:59 PM ET 24 IMG_0022.JPG 6/28/22 4:59 PM ET 25 IMG_0023.JPG 6/28/22 4:59 PM ET 26 IMG_0024.JPG 6/28/22 4:59 PM ET 27 IMG_0025.JPG 6/28/22 5:04 PM ET 28 IMG_0026.JPG 6/28/22 5:05 PM ET 29 MOV_0335.mp4 6/29/22 9:09 AM ET 30 MOV_0336.mp4 6/29/22 9:11 AM ET 31 MOV_0337.mp4 6/29/22 9:13 AM ET 32 MOV_0338.mp4 6/29/22 9:15 AM ET 33 MOV_0339.mp4 6/29/22 9:18 AM ET 34 MOV_0340.mp4 6/29/22 9:23 AM ET 35 MOV_0341.mp4 6/29/22 9:24 AM ET 36 MOV_0342.mp4 6/29/22 9:25 AM ET 37 MOV_0343.mp4 6/29/22 9:27 AM ET 38 MOV_0344.mp4 6/29/22 9:30 AM ET Appendices Page 2 of 6 Hydrocarbon emissions imaged from the West IGFU plate 4, agitator, and tank seam Manhole cover outside IGFU In-ground Lift Station Sump In-ground Lift Station Sump In-ground Lift Station Sump Sump junction box 2 cover Sump junction boxes 1 and 2 covers Sump junction box 3 cover Manhole near sump Manhole near sump Manhole in road near sump Manhole in road near sump Hydrocarbon emissions imaged from the southwest corner of API C Hydrocarbon emissions imaged from the west side of API C Hydrocarbon emissions imaged from the sample drain on API C Hydrocarbon emissions imaged from the northwest corner of API C Hydrocarbon emissions imaged from the north side of API C Hydrocarbon emissions imaged from the northeast corner of API C Hydrocarbon emissions imaged from the east conservation vent on API C Hydrocarbon emissions imaged from the southeast corner of API C Hydrocarbon emissions imaged from the south side of API C Hydrocarbon emissions imaged from the west conservation vent on API C Facility Name: Lima Refining Company Facility Location: 1233 S Metcalf St., Lima, OH 45804 Date of Inspection: June 27, 2022 39 MOV_0345.mp4 6/29/22 9:32 AM ET 40 MOV_0346.mp4 6/29/22 9:34 AM ET 41 MOV_0347.mp4 6/29/22 9:39 AM ET 42 MOV_0351.mp4 6/29/22 10:03 AM ET 43 MOV_0354.mp4 6/29/22 10:28 AM ET 44 MOV_0355.mp4 6/29/22 10:29 AM ET 45 MOV_0356.mp4 6/29/22 10:46 AM ET 46 MOV_0357.mp4 6/29/22 10:52 AM ET 47 MOV_0358.mp4 6/29/22 10:54 AM ET 48 MOV_0361.mp4 6/29/22 11:03 AM ET 49 MOV_0362.mp4 6/29/22 11:41 AM ET 50 MOV_0363.mp4 6/29/22 11:44 AM ET 51 MOV_0364.mp4 6/29/22 11:47 AM ET 52 MOV_0365.mp4 6/29/22 11:50 AM ET 53 IMG_0027.JPG 6/29/22 2:10 PM ET 54 IMG_0028.JPG 6/29/22 2:10 PM ET 55 IMG_0029.JPG 6/29/22 2:11 PM ET 56 MVI_0030.MP4 6/29/22 2:11 PM ET 57 MVI_0031.MP4 6/29/22 2:16 PM ET 58 MVI_0032.MP4 6/29/22 2:17 PM ET 59 MOV_0366.mp4 6/29/22 2:18 PM ET Appendices Page 3 of 6 Hydrocarbon emissions imaged from the northwest corner of API A Hydrocarbon emissions imaged from the sample drain on API A Hydrocarbon emissions imaged from the east conservation vent on API A Hydrocarbon emissions imaged from the in-ground Lift Station Sump Hydrocarbon emissions imaged from the CPI PRV Hydrocarbon emissions imaged from the CPI PRV Hydrocarbon emissions imaged from the Tank 79 Hydrocarbon emissions imaged from the Tank 79 Hydrocarbon emissions imaged from the Tank 78 conservation vent Hydrocarbon emissions imaged from the sample station near Tank 79 Hydrocarbon emissions imaged from the above ground junction boxes into aeration basin Hydrocarbon emissions imaged from the above ground junction boxes into aeration basin Hydrocarbon emissions imaged from the conservation vent on equalization tank Corrupted file Flare visible from aeration basin Flare visible from aeration basin Flare visible from aeration basin Flare visible from aeration basin Flare visible from aeration basin Flare visible from aeration basin Hydrocarbon emissions imaged from the above ground concrete basins into aeration basin Facility Name: Lima Refining Company Facility Location: 1233 S Metcalf St., Lima, OH 45804 Date of Inspection: June 27, 2022 60 MOV_0367.mp4 6/29/22 2:21 PM ET 61 MOV_0368.mp4 6/29/22 2:40 PM ET 62 MOV_0369.mp4 6/29/22 2:42 PM ET 63 MOV_0370.mp4 6/29/22 2:46 PM ET 64 MOV_0371.mp4 6/29/22 2:48 PM ET 65 MOV_0372.mp4 6/29/22 2:49 PM ET 66 MOV_0373.mp4 6/29/22 2:50 PM ET 67 MOV_0374.mp4 6/29/22 3:01 PM ET 68 MOV_0375.mp4 6/29/22 3:03 PM ET 69 MOV_0376.mp4 6/29/22 3:04 PM ET 70 MOV_0377.mp4 6/29/22 3:06 PM ET 71 MOV_0378.mp4 6/29/22 3:08 PM ET 72 MOV_0379.mp4 6/29/22 3:09 PM ET 73 MOV_0380.mp4 6/29/22 3:34 PM ET 74 MOV_0381.mp4 6/29/22 3:37 PM ET 75 MOV_0382.mp4 6/29/22 3:40 PM ET 76 MOV_0383.mp4 6/29/22 4:03 PM ET 77 MOV_0384.mp4 6/29/22 4:06 PM ET 78 IMG_0033.JPG 6/30/22 8:49 AM ET 79 IMG_0034.JPG 6/30/22 8:53 AM ET 80 IMG_0035.JPG 6/30/22 9:00 AM ET Appendices Page 4 of 6 Hydrocarbon emissions imaged from the above ground concrete basins into aeration basin Tank 77 sample station Tank 77 sample station Hydrocarbon emissions imaged from Tank 173 Hydrocarbon emissions imaged from Tank 173 Hydrocarbon emissions imaged from Tank 173 Hydrocarbon emissions imaged from Tank 173 Hydrocarbon emissions imaged from Tank 173 Hydrocarbon emissions imaged from Tank 172 Hydrocarbon emissions imaged from Tank 172 Hydrocarbon emissions imaged from Tank 172 Hydrocarbon emissions imaged from Tank 172 Hydrocarbon emissions imaged from Tank 172 Hydrocarbon emissions imaged from Tank 72 Hydrocarbon emissions imaged from Tank 72 Hydrocarbon emissions imaged from Tank 72 Hydrocarbon emissions imaged from Veolia's Oily Sludge Tank Conservation Vent Hydrocarbon emissions imaged from Veolia's Oily Sludge Tank Conservation Vent MH-1 HUB-5 HUB-2 Facility Name: Lima Refining Company Facility Location: 1233 S Metcalf St., Lima, OH 45804 Date of Inspection: June 27, 2022 81 IMG_0036.JPG 6/30/22 9:15 AM ET 82 IMG_0037.JPG 6/30/22 9:21 AM ET 83 IMG_0038.JPG 6/30/22 9:21 AM ET 84 IMG_0039.JPG 6/30/22 9:34 AM ET 85 IMG_0040.JPG 6/30/22 9:34 AM ET 86 IMG_0041.JPG 6/30/22 9:41 AM ET 87 IMG_0042.JPG 6/30/22 9:46 AM ET 88 IMG_0043.JPG 6/30/22 10:02 AM ET 89 IMG_0044.JPG 6/30/22 10:03 AM ET 90 IMG_0045.JPG 6/30/22 10:04 AM ET 91 IMG_0046.JPG 6/30/22 10:04 AM ET 92 IMG_0047.JPG 6/30/22 10:05 AM ET 93 IMG_0048.JPG 6/30/22 10:06 AM ET 94 IMG_0049.JPG 6/30/22 10:10 AM ET 95 IMG_0050.JPG 6/30/22 10:10 AM ET 96 IMG_0051.JPG 6/30/22 10:13 AM ET 97 IMG_0052.JPG 6/30/22 10:22 AM ET 98 IMG_0053.JPG 6/30/22 10:22 AM ET 99 IMG_0054.JPG 6/30/22 10:22 AM ET 100 IMG_0055.JPG 6/30/22 10:24 AM ET 101 IMG_0056.JPG 6/30/22 10:24 AM ET 102 IMG_0057.JPG 6/30/22 10:25 AM ET 103 IMG_0058.JPG 6/30/22 Appendices Page 5 of 6 Grounding rod access point with accumulated oily liquid CB-5-LIU CB-5-LIU Amine tank Amine tank C-1-LIU, Sewer sample point Manhole cover with debris T-6-B T-6-A T-6-F T-6-C T-6-D T-6-D T-6-E T-6-H CO-6-B GDU Sump LDAR tag GDU Sump LDAR tag GDU Sump LDAR tag GDU manhole GDU manhole LDAR 14626 drain hub LDAR 14626 drain hub Facility Name: Lima Refining Company Facility Location: 1233 S Metcalf St., Lima, OH 45804 Date of Inspection: June 27, 2022 10:26 AM ET 104 IMG_0059.JPG 6/30/22 10:30 AM ET 105 IMG_0060.JPG 6/30/22 10:33 AM ET 106 IMG_0061.JPG 6/30/22 10:33 AM ET 107 IMG_0062.JPG 6/30/22 10:34 AM ET LDAR 14993 drain hub Grated drain next to Recycle Comp KO Drum (PR160116) Grated drain next to Recycle Comp KO Drum (PR160116) Grated drain next to Recycle Comp KO Drum (PR160116) with tote Appendices Page 6 of 6