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Motiva Enterprises (2719), Convent

Causal Factor: Weather

LDEQ Accident Number
Accident Date
Point Source(s) Notes Amount of Release

Dirty Oil Water sewer system
Cause: Heavy rains and flooding conditions from Hurricane Rita caused the DOW sewer system to overflow the process slabs thereby allowing material to enter the Clean Storm Water Sewer System.

Followup: No

Notes: Sheen of oil discovered in stormwater ditch, stormwater pond and canal leading to St. James drainage system. Placed absorbent booms and spill containment booms and vacuum trucks were used to remove hydrocarbon release. Follow up report will inlcude testing results of samples taken from the storm water pond and canal.
Oil and Process Waste Water: 85.0 gallons

Flares 1 and 2
Cause: Related to Hurricane Rita but no information given

Followup: No

Notes: telephone report have estimated exceedances of Sox Nitrogen Oxide Hydrogen Sulfide and Volatile Organic Compoundss


Process Wastewater Treatment Unit
Cause: Excessive rainfall from Hurricane Rita resulted in the Process WasteWater treatment Unit tank filling to storm water surge capacity. In order to alleviate flowing within the refinery and maximize flow throught he treatment system the final pressures and filters of the WWTU were bypassed.

Followup: No

Notes: In order to ensure that permit limits are not exceeded, Motiva carefully monitors the bypass as long as it is occurring.


None Reported
Cause: Flaring resulting from a total shutdown of the refinery in preparation for Hurricane Katrina and restart of the refinery after storm damage had been repaire

Followup: Yes

Notes: Any permit deviations of additional information will be reported in the 3rd quarter Condition R Title V deviation report and the semi-annual Title V certification.

Tank 20D-12
Cause: Floating roof on Tank 20D-12 partially collapsed into the hydrocarbon product during heavy rains, releasing product to ground via the roof drain and into air via evaporation. Exceeded RQs. No LDEQ report in this file--hazmat and two letters.

Followup: Yes

Notes: discontinued product transfers to and from tank and began preparations to remove product from the floating roof and the tank.
Light Catalytic Reformed Naphtha (LCR): 168.0 gallons
Benzene: 855.3 pounds
Hexane: 1,573.7 pounds
Xylene: 342.1 pounds

Outfall 001
Cause: Heavy rains during the week of 10/19 caused Motiva to bypass final pressure and sand filters of the Process Wastewater Treatment Unit (WWTU) to alleviate flooding of facility. Inactive MTBE/TAME Process Unit was overwhelmed with stormwater and flooded. Sampling of water showed no permit limits were exceeded. Dates on this incident are confusing; the two letters detail different flooding problems from the same storm, and one letter is dated 2005 but looks like it should be 2006. LDEQ report states "letter states SPOC notified of bypass 10/19/05, bypassing occurred 9/24/05. These dates are wrong" and that they contacted someone for a corrected letter.

Followup: No

Notes: no information given
Stormwater: 5,000.0 gallons

no information given
Cause: Gas oil released from process unit sewer due to heavy rain--permitted outfall to onsite pond.

Followup: No

Notes: no information given
Gas Oil: 126.0 gallons

no information given
Cause: Leaking avjet (aviation jet fuel) filters were replaced due to a leak, old ones placed in a dumpster with an open top, new ones not used until the next day. Dumpster overfilled and leaked during heavy rain; new filters leaked avjet into a catch basin and sprayed into shell area. One bbl spilled to shelled area, one bbl to nearby ditch, 15 bbls to a catch basin.

Followup: No

Notes: Vacuum truck used to clean up spill to ditch and catch basin, contaminated soil removed. "The dumpster will have a lid in the future and taken to appropriate waste slab after the job is complete. Personnel will be instructed on the proper installation of "O" ring around the lid of the canister.
Aviation Fuel: 714.0 gallons

Flare CAP (19F-3, 19AH-901, 19G-310, 19G302)
Cause: Hurricane Gustav prompts preparatory shutdown. Natural gas was cutoff by provider (highly unusual - didn't happen w/ Katrina). Flaring occurred b/c there was not enough time for material to be processed by downstream units

Followup: Yes

Notes: Motiva currently trying to regain power for start-up of all units. Follow-up report revises prior calculation of SO2 emissions from 2600 lbs to BRQ.
Hydrogen Sulfide: 3.0 pounds

No LDEQ Reported

FCCU wet gas scrubber
Cause: Sudden temperature drop due to severe thunderstorm upset Fluid Catalytic Cracking Unit, sending it into partial-burn mode, resulting in increased emissions.

Followup: Yes

Notes: "Immediate and appropriate action was taken by operations to address the situation by slowing down and/or shutting down multiple units throughout the refinery." Will modify procedures, train operations, field test oxygen analyzers on the FCCU to verify accurate readings.
Carbon Monoxide: 215,800.0 pounds

Vacuum Pipe-Still No. 2 Unit Atomospheric Heater
Cause: Severe thunderstorm caused water to enter the oxygen analyzer probe of the VPS-2 Atmospheric Heater resulting in erroneous analyzer readings--caused exceedance of BACT box minimum oxygen hourly average for one hour. No reportable quantities exceeded.

Followup: Yes

Notes: Analyzer repaired, gave correct readings after fixed.


TGTU incinerator
Cause: Booster blower motor failed to due to lubrication problem caused by rain getting inside it during a heavy storm--automatic oiler did not replenish oil that was drained off with the water afterward. Motor failure caused Tail Gas Treating Unit (TGTU) 4 to unexpectedly shut down and unit charge was diverted to the TGTU incinerator from the SRU (sulfur recovery unit); sour gas combustion then resulted in excess emissions. Exceeded RQ's. No DEQ report in this file--hazmat and follow-up only.

Followup: Yes

Notes: Made efforts to reduce operating rates on units producing acid gas or rich amine and to distribute the acid gas flow to other operating SRU/TGTUs. Installed motor from another piece of idled equipment in booster blower and restarted it.
Sulfur Dioxide: 1,554.0 pounds
No LDEQ Reported

Tank 37T-315
Cause: STORMS. Excess rainwater accumulated at site during severe rainstorm causing Surge Tank (37T-315) to fill. Tank level gauge malfunctioned indicating level was lower than actual water level causing secondary seal to breach, but letter states that no material was released.

Followup: No

Notes: Upon discovering malfunction, operations were shutdown to drain water to another surge tank, which then lowered the level in Tank 37T-315 within an hour and primary seal remained intact. There was no spill nor were there any other emissions exceedances related to this event. They claim that the apparent excursion of the secondary seal general requirement did not cause an emergency condition as defined in LAC 33:I:3905. In addition, Motiva upholds the claim that the incident was due to the occurrence of an upset.


Outfall 002
Cause: Upset conditions which led to a LPDES bypass as a result of Hurricane Isaac and the associated internal facility flooding that occurred as a result.

Followup: No

Notes: The bypass consisted of excess stormwater mixed with process wastewater and was made to the LPDES permitted stormwater pond which discharged via Outfall 002 to the Ascension Ditch, to the St. James Canal, and then to the Blind River. The stormwater drainage system was still compromised by flooding conditions and Outfall 002 continued to discharge until 09/01/2012 at 8:30pm. They mention that complete details are provided in a written report submitted on 09/07/2012 but we were unable to find this report. The facility claims that all permit required analytical information for Outfall 002 were within permit limits in august and september. The results show that the bypass didn't cause a water quality violation, exceed any reportable quantity, or exceed any permit limit.


Unit slab
Cause: On March 12, 2012, Motiva Convent Refinery reported an offsite discharge event due to a wastewater treatment bypass where during heavy rains approximately 60 gallons of wastewater overflowed a containment slab and flowed through the facility fenceline to a ditch that (while still on Motiva property) did not discharge through a monitored Outfall. The incident began at 08:05 AM and ended at 11:55 AM on March 12, 2012. The incident was caused when a surface drain could not keep up with the unusually high rainfall rate. A follow-up investigation revealed that the perimeter ditch outside of this fenceline redirects all possible fenceline discharges back into the facility via subsurface drainage for discharge through monitored Outfall 002 (stormwater). The source of the wastewater bypass consisted of contact stormwater from a waste container storage slab, which is normally routed to wastewater treatment for discharge through Outfall 001 (process wastewater), but instead entered the monitored Outfall 002 (stormwater) drainage system.

Followup: No

Notes: The release was halted when the rainfall slowed and the area pump could maintain drainage from the slab. Wastewater which exited the site could not be recovered.
Wastewater: 60.0 gallons

outfall 001
Cause: Upset conditions which led to a Louisiana Pollutant Discharge Elimination System (LPDES) bypass as a result of extraordinary amounts of rainfall brought by slow moving thunderstorms that caused flash flooding over several days. The facility was being operated properly prior to conditions brought on by the severe weather event but the excessive amounts of rainfall over an extended number of days consumed the refinery's wastewater treatment system as well as all of it's surge capacity to a point at which there was a significant threat to the facility's infrastructure and safety of its employees operating energized equipment.

Followup: Yes

Notes: The event was not considered an emergency condition. Process wastewater mixed heavily with rain water was discharge from Outfall 001 at an average rate of 650 gpm. Discharging began on 1/14/2013 at 2:35 pm and was intermittent until 1/17/2013 at 1:10 pm, at whihc time it was determined that the wastewater treatment system was no longer threatened and Motiva could process the remainder of the water consuming the capacity of the surge tanks and surge ponds. To minimize or eliminate threats, Motiva began discharging process wastewater mixed heavily with rain water from Outfall 001. This bypass was unavoidable as a result of the upset condition. Concurrently with the excessive stormwater runoff, there was an incident that caused a slightly higher pH in the wastewater treatment system. Two incidents where the pH exceeded 9.0 standard unites for greater than 60 minutes consecutively. Motiva immediately began implementation of measures to adjust the pH to within the permitted limits and began an investigation into the cause. The root cause is unknown and still under investigation. They claim that this process wastewater did not have a significant impact on the water quality of the Mississippi River and no exceedances of Motiva's LPDES Permi are anticipated


Outfall 001
Cause: Treated but unclarified wastewater was discharged from Outfall 001 at a rate of approximately 800 gpm. Discharging began at 7:50 pm on January 11, 2013 and ended at 4:00 am on January 12, 2013. An upset occurred at the facility due to extraordinary amounts of rainfall brought on by severe slow moving thunderstorms that caused flash flooding. The facility was being operated properly prior to conditions brought on by the severe weather event. Overwhelmed by the excessive amounts of rainfall, treated water overflowed a basin immediately prior to the system's clarifier, which is the final polishing section of the wastewater treatment system, resulting in a bypass of a de minimus amount of treated but unclarified wastewater. Accordingly, this bypass was unavoidable.

Followup: Yes

Notes: The discharge was made to the Mississippi River. As discharged material was treated but unclarified wastewater, it is not expected to have any impact to the water quality of the Mississippi River and no permit limit exceedances are anticipated. The event constituted an overflow of a de minimus amount of treated but unclarified wastewater. As operated prior to the initiation of the event, equipment was continued to be monitored and managed to not cause additional bypasses. The event was resolved as flash flooding diminished. The first written notification found was the final report; LABB was unable to find the online notification Motiva submitted on January 12, 2013.


LPDES Outfall 002
Cause: Heavy rains began during the early morning hours on 5/28, continuing through 5/30. This rainfall led to heavy flooding throughout the site. On 5/28 at 0716, oil was reported in the storm water ditch and notification was made to regulatory agencies of a possible release of oil exceeding 1 barrel. Additional calculation determined that the release was below RQ. At 1200, it was determined that the storm water with a "slight" oil sheen had migrated off site at two different locations: the St. James Canal and the Ascension Ditch. An overflow occurred, sending the contaminated water into the site stormwater ditch system. Oil containment and absorbent booms were deployed into the Ascension Ditch and the St. James Canal. Flooding continued across the site and storage capacity was exceeded. At 1300 on 5/28, discharge of process wastewater into the Storm Water System began to prevent the discharge of untreated process wastewater into the Mississippi River. Motiva also began to discharge from the Storm Water System via LPDES Outfall 002 to alleviate onsite flooding. On 5/30, another rainfall event affected the facility, resulting in additional flooding and the need for continuation of the emergency bypass operations. No offsite impacts. That 5/30 event also affected the facility steam system, which resulted in an upset of the Tail Gas Treating Unit No. 3 (TGTU-3). It was initially believed that this event led to exceedences for SO2, but calcuations determined that the RQ had not been exceeded.

Followup: No

Notes: Remedial actions were taken to contain and recover free oil onsite in order to minimize any potential for off-site impact. Motiva's primary Oil Spill Response Organization (ES&H) was immediately activated, along with additional support from United States Environmental Services (USES). The OSRO's worked around the clock deploying boom, recovering oil with vacuum trucks and discharging the oily water back into the refinery's slop oil system for reprocessing. "Extremely dilute" amounts of process water were discharged into the Ascension Ditch and St. James River.
Oil: 5.4 gallons