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|LDEQ Accident Number
|Point Source(s)||Notes||Amount of Release|
|Coke Conveyor Facilities|
isolated areas of standing stormwater
Wastewater treatment Unit
|Cause: Chalmette Refining LLC shut down operations because of the approach of Hurricane Isaac. Following established shutdown procedures and protocols, CRLLC was safely and systematically shutdown due to the approach of Hurricane Isaac. Likewise, CRLLC followed standard startup procedures and protocols and minimized excess emissions during recovery and startup efforts.|
Notes: There are three LDEQ incident numbers assigned for the events at Chalmette Refining LLC surrounding Hurricane Isaac: 142422, 142489, 143217. On August 27, 2012 the CRLLC began to safely shut down unit operations due to Hurricane Isaac. The emergency shut down resulted in potential permit deviations and reportable quantity exceedances. However CRLLC believes that this event qualifies as an upset as defined in LAC 33:III.507.J. Below are the detailed quantities released from each unit during the startup/shutdown activities: Acid Gas and Hydrocarbon Flaring: During the shutdown and equipment preparation, excess process gases were vented to the flare system in order to reduce emissions to the atmosphere. The duration of flaring was approximately 21.1 hours. Below are the emissions which occurred during shutdown activities: 23.6 Tons S02 126 lbs H2S 133 lbs NO 133 lbs N02 714 lbs CO 558 lbs VOC 72 lbs PM10 On August 31, 2012, CRLLC began start-up operations and equipment preparation which required periodic hydrocarbon flaring. There were temporary visible emissions of smoke from flaring activities. Further, during startup of the SRU, there was a transient period which resulted in flaring amine acid gas prior to directing to the SRU. Below are the estimated emissions during startup of refinery operations. The duration of the amine acid gas flaring was 89 minutes and the duration of the intermittent hydrocarbon flaring during startup was 84 hours. Actual emissions were: 10.03 Tons S02 (> 500 lbs RQ) 0.03 Tons H2S (> 100 lbs RQ) 0.28 Tons NO/N02 (> 1000 lbs RQ) 1.52 Tons CO 0.69 Tons VOC (>5000 lbs RQ) 0.08 Tons PM10 <1 00 lbs Benzene (> 10 lbs RQ) There were approximately 9 hours where the H2S 162 ppm 3-hour rolling flare limitation was exceeded during shutdown and startup activities. These excess emissions are covered under startup/shutdown provisions provided in NSR CD Paragraph 58. As such, no additional action is required by agency. Flare Gas Recovery equipment was being repaired and so no FGR was used during this process. Tail Gas Incident: On August 27, 2012 the CRLLC Sulfur Recovery Unit was safely shut down and equipment was prepared. During this process Tail Gas Incident resulted from Source ID EIQ193. Predicted emission estimates were approximately 25 tons S02 for the shutdown. On September 5-6, 2012 the Sulfur Recovery Unit was started-up. There were no tail gas incidents during this process. As such, no additional action is required by agency. Sulfur Pit Venting: Emission estimates were expected to be less than 200 pounds H2S during shutdown and start-up operations. It is important to note that these exceedances occurred during the period when CRLLC was shutting down equipment and subsequently starting up and lining out operations. Actual emissions were -72 lbs. H2S and -50 lbs. S02. These excess emissions are covered under startup/shutdown provisions provided in NSR CD Paragraph 58. As such, no additional action is required by agency. H2S Concentration of 162 ppm in Fuel Gas: During shutdown on August 27, 2012 the refinery had the potential to exceed the H2S concentration of 162 ppm in the fuel gas system. FCCU NOx, S02, CO, PM, and Opacity Permitted Emission Limits: During shutdown and subsequent start-up operations, the refinery exceeded the emission concentration limit for CO for 14 hours and the differential pressure parameter for 32 hours at the FCCU. There were no Title V permit limit lb/hr exceedences during these times. SRU Permitted Emission Limits (lbs/hr & concentration): During the shutdown and subsequent start-up operations, the refinery exceeded the permitted emission limit of 95 lbs/hr for S02 for three (3) hours at the Sulfur Recovery Unit. The 250 ppm concentration limit was exceeded for approximately 48 hours. It is important to note that these exceedances occurred during the period when CRLLC was starting up and lining out operations. These excess emissions are covered under the start-up/shutdown provisions provided in NSR CD Paragraph 23 and 29. Flare Pilot Outages: During the shutdown due to the higher than normal rain and wind volumes, flare pilots experienced temporary outages. Data Availability from Continuous Emission Monitoring Systems (CEMS): The CEMS analyzers at the CRLLC may be adversely affected by nitrogen constraints. Some selected CEMS may have reduced data availability during the time period of storm landfall, recovery, and start-up activities. The specific duration of reduced data availability will be provided in the 30- day follow-up report. Missing LDAR Monitoring: CRLLC is subject to several Louisiana & Federal Regulations requiring Leak Detection and Repair (LDAR) as noted below. Hurricane Isaac and its aftermath have not allowed completion of some of the timing obligations, and will prevent us from meeting all the timing obligations of the required August monitoring. Approximately 250 components will receive delayed monitoring, but will be monitored in September. Details of the number of components subject to delay will be provided in the 30-day follow-up report. Consistent with USEPA's decision for Hurricane Gustav, CRLLC requests that the delayed monitoring and repair be exempted from enforcement under the applicable Force Majeure provisions. Approximately 255 monthly LDAR components received delayed monitoring, but were monitored in September. In addition, 7 leaks that missed the 5 day attempt and 6 leaks that missed the 15 day attempt due to Hurricane Isaac. Isolated Areas of Standing Stormwater: There were isolated pockets of stormwater in the refinery which contained some sheen material and potential hydrocarbon. All of these areas were contained within the refinery boundaries and no material migrated offsite. Areas include tank firewall areas, overflow of sumps, and low-lying areas. There is the potential to exceed more than one (1) barrel of total oil accumulative across the complex from all the isolated areas. All hydrocarbon and sheen material was removed and properly disposed/treated. Any contaminated soil has been remediated. This information is reported in accordance with the site waste management plan. Coke Conveyor Facilities: The coke conveyor facilities sustained some minor damage which resulted in loss of covers over portions of the conveyor belt system. There are also minor amounts of coke material on the ground which is being collected. Some small particulate emissions may result from recovery and re-start Operations. Covers will be repaired/replaced as soon as possible. The 30-day follow-up report will describe the specific repairs and dates of completion. The conveyor covers that were damaged during the hurricane have been repaired/replaced. This accident is linked to Bypass of Wastewater Treatment Unit (LSP incident # 12-05781; NRC Incident # 102-2486). Actual storm rainfall was 30". In consideration of personnel safety and increasing weather severity, the refinery initiated the emergency discharge bypass for Outfall 004 from wastewater treatment facilities to MS River on August 28, 2012. It is important to note that the refinery process operations were shutdown previously which mitigated wastewater hydrocarbon content. Water discharge was essentially storm water. Samples were collected to document wastewater quality. On August 29, 2012 all parameters were within current permit limits with the exception of Total Suspended Solids. Preliminary analysis indicates a potential exceedance of 4,444 lbs/day versus permitted limit of 3,180 lbs.