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|LDEQ Accident Number
|Point Source(s)||Notes||Amount of Release|
|No Information Given||Cause: The were no unauthorized discharges. This was a controlled early shutdown for schedule unit turnaround|
|No Information Given|
|No Information Given||Cause: No unautorized discharge occurred. This was an orderly controlled unit shutdown for unit maintenance|
|EQT 016 and EQT 029||Cause: Shut down for unit maintenance|
Notes: No information given
|Sulfur Dioxide: 755.2 pounds|
|FLARE: FCCU Unit||Cause: Flaring resulting from planned FCCU start-up. FLARE.|
Notes: BRQ. Refinery letter states that no reportable quantities were exceeded. No additional information given.
|FLARE: FCCU and sour water stripper|
FLARE: FCCU & sour water stripper
|Cause: "FCCU shut down to replace packing on Regen Slide valve." Flaring occurred upon restart of unit. FLARE.|
Notes: RQ. Incident exceeded reportable quantities for sulfur dioxide. LDEQ report states that incident investigation status is "deferred until next inspection." No information given regarding remedial actions. LDEQ report only. No refinery letter.
Volatile Organic Compounds (VOCs): 94.0 pounds
Sulfur Dioxide: 727.0 pounds
|No Information Given||Cause: Notification to LDEQ and SPOC of possible SO2 emissions due to planned work on preflash tower, but no flaring occurred.|
Notes: No information given.
|FLARE||Cause: "Unscheduled maintenance requiring shutdown of FCC Unit. The packing on the slide valve stem in the regenerator side of FCCU failed and had to shut down the unit and flaring ensued." No details given regarding what was emitted. FLARE.|
Notes: BRQ. Refinery letter states that no reportable quantities were exceeded during this incident. Valve removed and sent for repair.
|Flare||Cause: Placid Refining Company operates a flare gas recovery unit that recovers routinely generated gases that would have been otherwise flared in Source ID 18-74. The recovery unit was shut down due to turnaround related unit cleaning activities sending high concentrations of nitrogen and steam into the flare system. This control device bypass was not approved via a variance.|
Notes: Report states that no RQ's were exceeded. On the other hand, it also says that mass emission permit limits for the flare were exceeded. Placid has requested a GCXVII activity be added to their permit to cover monthly preventative maintenance on the system but this will only cover 5 hours per month. Operations will notify environmental department prior to shutting down system in the future so it can be addressed properly with the agency prior to activity. Report says to see an attached calculation with the name and quantity of released pollutants. Report shows no sign of such calculation.
|Carbon Monoxide: 1.2 pounds|
Nitric Oxide: 0.9 pounds
Particulate Matter 10: 0.0 pounds
Sulfur Dioxide: 0.1 pounds
Volatile Organic Compounds (VOCs): 0.4 pounds
|No LDEQ Reported|
|#1 Incinerator||Cause: The Sulfur Plant was shut down during the turnaround to replace the catalyst, as it was no longer active. Residual sulfur must be removed from the reactor beds to prevent the beds from plugging or solidifying. If the reactor beds are not swept of the residual sulfur, it becomes more hazardous to remove the old catalyst. The refinery notes that, even if the catalyst was not being replaced, it is likely that the catalyst would have plugged if the sweeping procedure was not performed, and it would not be able to achieve proper flow through the Sulfur Plant during startup.|
Notes: The refinery will contact a Sulfur Plant specialist to explore any other possible shutdown techniques for sweeping the catalyst that do not cause a TG incident.
|Sulfur Dioxide: 3,695.0 pounds|
|Tank: VOC control device||Cause: LDEQ states that the VOC stream from tank emissions was rerouted from one control device to another control device. No net emissions change from what was permitted was reported. The listed control device in the air permit for the VOC stream was taken out of service for unscheduled maintenance. It is reported that the alternate control device efficiency is equal or greater than that required by the permit.|
Notes: BRQ. No Information Given. LDEQ included. No Refinery Letter.
|SRU incinerator #1||Cause: A plugged quench tower in TGTU #1 that operated in conjunction with SRU #2 had to be taken out of service for cleaning resulting in a TGTU bypass which caused an increase in SO2 emissions from the SRU incinerator #1 on SRU#3.|
Notes: The maintenance cleaning activity on the plugged Quench Tower was performed quickly as possible and reduced acid gas production by reducing processing unit charge rates and shifting the maximum acid gas load possible to the SRU #3. Operator training is being conducted to prevent the initial incident earlier in the week. Offsite air monitoring occurred throughout the duration of the incident.Additional operator training and any findings or corrective actions that stem from the formal Root Cause Analysis
|Sulfur Dioxide: 407.0 pounds|
|No LDEQ Reported|
|#1 Incinerator||Cause: The Sulfur Plant was shutdown during thte turnaround to replace the catalyst as it was no longer active.|
Notes: No additional steps were taken as this activity is part of Placid Refining's standard procedure for shutting down the Sulfur Plant for scheduled maintenance. Residual sulfur must be removed from the reactor beds to prevent the beds from plugging or solidifying. If the reactor beds are not swept of the residual sulfur it makes it more hazardous to remove the old catalyst. Note, that even if the catalyst was not being replaced it is likely that the catalyst would have plugged if the sweeping procedure was not performed and we would not be able to get proper flow through the Sulfur Plant during start up.
|Sulfur Dioxide: 3,695.0 pounds|
|Incinerator #1||Cause: According to the Inspections Division, "At the time of the incident Placid was in the process of shutting down processing unit operations for turnaround maintenance. The only unit online at the time producing acid gas was the disel hydro treating unit; the Sulfur Plant No.2 shut down unexpectedly. Placid had already shut down Sulfur Plant No.3 and had to send the acid gas stream and the sour water stripper off gas to the flare while restarting Sulfur Plant No.2".|
Notes: Both LDEQ and State Police Report included. At 0319, same day, the acid gas was returned back to the sulfur plant and taken out of the flare, according to both the LDEQ and State Police reports. Placid will check electronic and communication systems to ensure that they are functioning properly and perform general maintenance to the operating equipment. Currently writing a Preventative Maintenance and Operational Plan for the sulfur plants as required by Settlement Tracking No. SA-MM-11-0021. reviewing Standard Operating Procedures SOPs and maintenance schedules to ensure work practices are in place to assist in the minimization of Sulfur recovery Units SRU incidents.
|Sulfur Dioxide: 511.0 pounds|
Acid gas: 458.0 pounds
|No LDEQ Reported|
|Reactor beds in the Sulfur Plant||Cause: The Sulfur plant was shutdown during the turnaround to replace the catalyst as it was no longer active. Residual sulfur was removed from the reactor beds to prevent the beds from plugging or solidifying. The statement includes a line that says the catalyst was not being replaced anyways. There is a contradiction.|
Notes: This was a planned shutdown and a variance was issued by LDEQ Office of Environmental Service. There is no LDEQ report and no SPOC report attached to this file. Residual sulfur must be removed from the reactor beds to prevent the beds from plugging or solidifying. If the reactor beds were not swept of the residual sulfur it makes it more hazardous to remove the old catalyst. Note, that even if the catalyst was not being replaced it is likely that the catalyst would have plugged if the sweeping procedure was not preformed and we would not be able to get proper flow through the Sulfur Plant during start up. Placid's procedure for sweeping the reactor beds is the standard procedure for preparing an SRU for shutdown.
|Sulfur Dioxide: 5,047.0 pounds|
|None Reported||Cause: Placid Refinery shut down entire facility beginning 9/1/14, caused intermittent flaring from 9/4/14 though 9/7/14.|
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