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|State Police #||14-02905|
|Pollutant||Duration||Point Source||Greenhouse Gas||Criteria Pollutant||Ozone forming chemical||Amount of Release|
|Carbon Monoxide||12h 24m||3700 Sulfur Recover Unit||NO||YES||NO||10.3 pounds|
|NOx||12h 24m||3700 Sulfur Recover Unit||NO||NO||YES||1.9 pounds|
|Particulate Matter||12h 24m||3700 Sulfur Recover Unit||NO||YES||NO||0.1 pounds|
|Volatile Organic Compounds (VOCs)||12h 24m||3700 Sulfur Recover Unit||NO||NO||YES||33.2 pounds|
|Sulfur Dioxide||12h 24m||3700 Sulfur Recover Unit||NO||YES||NO||21.7 pounds|
|Hydrogen Sulfide||12h 24m||3700 Sulfur Recover Unit||NO||NO||NO||0.1 pounds|
Accident Classified As: No Information Given
The 3700 Sulfur Recover Unit (SRU) furnace main air safety shutdown valve closed unexpectedly, which initiated a 3700 SRU trip and led to excess emissions of sulfur dioxide. While troubleshooting the malfunction, operators shifted the amine acid gas feed (AAG) from 3700 SRU to two remaining units (1600 and 30 SRU). The move caused excess emissions from the 30 SRU while stabilization was in process. About 30 minutes later, the malfunctioning valve reopened, reintroducing AAG into SRU 3700 and causing a RQ emission for sulfur dioxide. Later in the same day, at approximately 20:45 the 3700 SRU reaction furnace main air safety shutdown valve closed again. After the second malfunction, Valero purposely shut down the 3700 SRU in order to further troubleshoot the issue, and then implemented sulfur shedding in order to reduce sulfur loading to the SRUs. Sulfur shedding included: decreasing throughput of the Hydro-Treater, Hydro-Cracker (HTHC) unit to minimum rates, reducing overall refinery crude throughput, shifting amine acid gas feed to the two remaining operating SRUs (1600 and 30 SRUs), and shutting down sour water acid gas feed (SWAG) to the remaining two SRUs. The quick shift in AAG feed to the remaining two SRUs resulted in excess emissions from the 30 and 1600 SRUs for approximately 1 hour while making the necessary adjustments for the increased AAG loading to the units. The additional loading at the 30 SRU caused the 30 Thermal Oxidizer (TOX) to trip offline at 21:52 hrs due to low oxygen for combustion. It was brought back online at approximately 23:32. However, during the outage Valero experienced elevated hydrogen sulfide emissions from the 30 TOX. When the 30 TOX tripped, they had trouble restarting it due to wires that were found to be corroded and detached from the terminated position. The wire was tied to a system that was needed to complete the logic to start the TOX. The corroded wires were repaired, the termination box was properly sealed and the TOX was restarted. An investigation into the SRU 3700 reaction furnace main air safety shutdown valve malfunction revealed a loose wire as the cause. Valero repaired it, restarted the 3700 SRU, and resumed normal operation.
This incident is not considered reasonably preventable. The wire that became loose was likely the result of cabinet vibration by surrounding equipment. The wire's terminal was last serviced in 2012 and had not caused any issue until the incident.
Emissions were minimized by shutting down the 3700 and reducing the feed to upstream operating units. Subsequently, repairing and restarting the 3700 SRU reduced sulfur loading on the 30 and 1600 SRU, which allowed those units to resume normal operation. Air monitoring was conducted in the downstream wind direction within and around the refinery, and no detectable SO2 or H2S was found using portable air monitoring equipment. The following corrective actions were identified: 1) Review the incident with all affected personnel 2) Review the requirement to evaluate the condition of the sealing system of any instrument enclosure that is opened while performing any maintenance task associated with routine or preventative maintenance 3) Remove the logic for the 30 SRU atomizing stream valve from the purge permissive and pilot permissive.
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