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Motiva Enterprises (1406), Norco

Releases of Ethylbenzene

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

RCCU Flare (EPN #8-84)
Cause: No information given.

Followup: Yes

Notes: No listed remedial actions

DU-5 Unit
Cause: An atmospheric leak of light naphtha gasoline material was identified in Motiva's Distilling unit due to a piping failure on the crude column overhead line. Initially, operations personnel identified the line dripping in two locations, and vaporizing before reaching grade.

Followup: Yes

Notes: Operations developed a plan to safely remove insulation so that the leak could be stopped. Operations installed barricade tape around affected area and monitored the leak for benzene. A catch tray was fabricated and mounted directly to the crude overhead piping to contain atmospheric emissions while the associated insulation was removed from the crude overhead line. Once the insulation was removed, a pipe clamp was installed to permanently stoped the leak. The overhead piping will be replaced during the next unit turnaround in October 2006.
124.0 pounds

Wharf Berth 1: high sulfur light product line
Cause: LDEQ report states, "Motiva reported a leaking high sulfur light product line at the wharf that released approximately six barrels of naptha to the Mississippi River. Leak was caused by external corrosion, and two contributing factors were identified. First, the line was found to be in contact with the insulation of adjacent piping, causing water accumulation between the lines. Additionally, inadequate coating was discovered on the blistered section of piping." A total of 1,748 pounds of chemicals were released to the air.

Followup: No

Notes: RQ. LDEQ report states that "Motiva took the following measures to prevent reoccurrence of this incident: the blistered section of piping will be replaced so it does not contact near-by equipment and the new line will be adequately coated to protect from external corrosion. Motiva has determined that the release was preventable. This incident is an area of concern with regards to LAC 33:III.905 and LAC 33:IX.501.D."
28.0 pounds

FLARE: HCU elevated Flare (EPN-4-84)
Cause: "Motiva CR-2 recycle gas compressor (K-2057) tripped due to an expected high level in the CR-2 product separator vessel, which subsequently tripped the CR-2 process unit. A sudden increase in the level in the CR-2 product separator occurred while Motiva operators were placing exchangers (E-1243/44/45) back in service." This subsequently caused the HCU elevated Flare (EPN-4-84) to release naphtha-cyclohexane, ethylbenzene, napthalene,hydrotreated heavy naphtha, hexane, toluene, xylene. FLARE.

Followup: Yes

Notes: BRQ. The refinery letter states that no reportable quantities were exceeded during this incident.

Hose from the frac tank
Cause: At 10:01 on October 9, 2012 Motiva Site Supervisor received a call of an odor around the SBA area. After responding to the issue, it was discovered that the odor was coming from the VAT sump. A contractor was in the process of removing material from one of the four frac tanks that were staged in preparation for Hurricane Issac to collect excess oil and water during the storm. During the storm material containing high benzene was mistakenly put into the frac tank. When the contractor disconnected the hose from the frac tank that was labeled oil and water, the material remaining in the hose spilled onto the pavement. The contractor attempted to wash the area, which in turn washed the material into the VAT collection sump.

Followup: Yes

Notes: Industrial Hygiene (IH) and ERT were contacted due to an odor in the area and high levels of benzene were detected. The area were secured and under fresh air, clean up efforts were immediately implemented. To prevent any further release of hydrocarbons, the VAT collection sump was immediately blocked in and the material was pumped into a frac tank. The VAT collection sump was water washed, pumped to a frac tank and cleaned. Air testing was performed and the benzene levels were below the limit. Liquids were recovered and returned to the frac tank. No soils were contaminated. Material that evaporated during the release and recovery operation was released to atmosphere and dispersed naturally. The following requirements were adopted to prevent reoccurence: A MSDS is required before any material can be removed by contractors; Procedures have been updated and include a tracking sheet for all loads. Motiva has no current knowledge of pollution migration as free product was contained to the VAT collection sump and recovered to a frac tank. Motiva exceeded the reportable quantity for benzene.
0.1 pounds

Cause: Motiva Enterprises LLC, Norco Refinery is providing a preliminary report for a verbal notification on August 28, 2012 at 1854 hours of a release of 1,3 butadiene, benzene, carbon dioxide, ethylene, flammable gas, hexane, methane, nitrogen oxides, volatile organic compounds, propylene and sulfur dioxide from flaring and potential releases to atmosphere from the unexpected shutdown and restart of the site before and during inclement weather due to landfall of Hurricane Isaac. On August 28, 2012, Shell Chemical Norco Site operation was adversely affected by inclement weather due to the landfall of Hurricane Isaac. Several of Shell's Units were un-expectantly shutdown due to safety concerns associated with operating in the weather conditions brought on by the landfall of Hurricane Isaac. All materials were released lo the atmosphere from the associated flare's, and dispersed naturally.

Followup: Yes

Notes: Recovery and preparations for a safe re-start of the site is ongoing (Notification on September 4th). Data gathering to perform calculations and investigation are ongoing. Motiva will provide an update within 60 days as required by LAC 33:1 3925.A.3. The updates were each a word for word copy of the original written notification letter from Motiva. There were also duplicate letters printed on the Shell Chemical letterhead that contained all of the same details from the Motiva reports. At this time (May 22 2013) LDEQ is still processing the update that they claim will have final calculations from their investigation. February 20, 2013 is the most recent follow-up that LABB was able to find (Update May 2013 - we requested the final summary report from LDEQ and received this final report that was published April 25th, 2013). The final report lists completely different pollutants than the list that was being reported in prior written notifications. These inconsistencies are not addressed in the report. Final summary report from Shell chemical 4/25/2013: Shell Chemical operations look the necessary steps to safely shut units down and minimize emissions resulting from the weather associated with Hurricane Isaac. Operations assessed damages, made repairs to equipment and safely return process units to normal operating conditions. RCCU at Motiva Enterprises (from final summary letter dated april 25 2012) On August 29, 2012, Motiva's Residual Catalytic Cracking Unit (RCCU) initiated a shutdown of the process unit due to inclement weather associated with Hurricane Isaac making landfall. During this time, the RCCU experienced an unexpected loss of flare pilot indication at the RCCU Elevated Flare, and a loss of pilot indication on the RCCU CO Heater due to hurricane force winds. An inadvertent catalyst leak developed during this time on level indicator Ll1548. Subsequently, the pH control on the circulation water for the RCCU Flue Gas Scrubber was lost at this time. The reportable quantities for volatile organic compounds and particulate matter were exceeded during this time. Additional details on reportable quantity and permit limit exceedences are listed in the following tables of this report. (also from April 25th report) Shell Chemical Venting to Motiva West Operations Ground Flare On August 29, 2012, Shell Chemical's G0-1 Process Unit flared at Motiva's West Operations Ground Flare due to shutdown and startup activities due to adverse weather conditions associated with the landfall of Hurricane Isaac. Details of the flaring by Shell Chemical are addressed in a separate letter from Shell. A total of the VOCs is given, but report states certain VOCs (carbon dioxide, ethylene, flammable gas, methane, propylene) that do not have breakdown of individual amounts released anywhere. This event did not result in an emergency condition. There were no fatalities, injuries or road closures. Planning and review meetings were held, learning's will be executed in future weather related occurrences as appropriate.
153.8 pounds

OL-5 Elevated Flare, FE-101 (EPN 6-84); OL-5 Ground Flare, FG-101 (EPN 7-84)
RCCU CO Heater and Flue Gas Scrubber (EPN 2-91)
RCCU CO Heater and Flue Gas Scrubber (EPN 2-91); OL-5 Elevated Flare, FE-101 (EPN 6-84); OL-5 Ground Flare, FG-101 (EPN 7-84)
Cause: On May 8, 2012, the Motiva Enterprise's Residual Catalytic Cracking Unit (RCCU) was struck by lightning during a heavy rainstorm event resulting in an unforeseen shutdown of the RCCU CO Heater and Flue Gas Scrubber (EPN 2-91). Consequently, an Instrument Protective Function (IPF) associated with the CO Heater's force draft fans automatically tripped the system's main fuel gas burners to safely secure the heater as per design. Motiva operations then worked to stablize the RCCU process unit and assess the damages to the RCCU CO Heater resulting from the lightning strike. The causal analysis generated from the investigation of this incident revealed simultaneous alarms and IPF shutdowns for multiple pieces of equipment associated with the RCCU CO Heater during the time of the incident. A time stamp taken from the RCCU alarm summary noted that several pieces of equipment simultaneously shutdown at 5/8/2012 17:24:34. The pieces of equipment affected from this incident are listed below: CO Heater Forced Draft Fan Electric; CO Heater Forced Draft Fan Turbine; CO Heater Pilot Gas; RCCU Refrigeration Compressor Lube Oil; RCCU Main Air Blower Flow to Fluffing Rings; RCCU Cooling Water Pump Lube Oil Systems. The data proved that the signals initiating the multiple trips were not generated by the processes themselves, but by a non-process related influence. The investigation team determined that a bolt of lightning struck somewhere in close proximity of the junction boxes for the different pieces of equipment near the RCCU CO Heater. Consequently, this caused an inadvertent energy pulse to either stop current on the analog systems, or provide enough voltage to energize the trip signal and shutdown the equipment listed above. On May 8, 2012, Shell Chemical's OL-5 Process Unit experienced an unexpected shutdown of the OL-5 Process Gas Compressor (PGC) due to weather conditions which led to flaring at the OL-5 Elevated and Ground Flares. Weather conditions in the area caused issues in a Motiva Unit leading to a curtailment of the sites steam supply. As per site load shedding policies OL-5 was instructed to shut down the PGC which is a consumer of steam.

Followup: Yes

Notes: Motiva: The RCCU initiated a unit shutdown in a controlled manner following all operating and safety procedures in order to minimize excess emissions to the atmosphere. As part of the initial shutdown procedure, operating rates were reduced significantly leading up the unit showdown. Simultaneously, a maintenance work plan was developed and executed in a effort to re-establish normal operations of the RCCU CO Heater. At this time electrical inspectors were called in to visually inspect the associated junction boxes for this shutdown system. Additionally, enhanced monitoring of the shutdown system was performed to assure that no damage had occurred as a result of the lightning strike. Once the maintenance work was complete, the RCCU CO Heater was returned to service. Operations then worked to stabilize the CO Heater operations, and began to reverse the shutdown process following all operating and safety procedures. Motiva completed IPF checks to confirm that the instrument protective functions for this system are functioning as needed. Shell Chemical LP.-East: Furnaces in OL-5 were taken off feed after the PGC was shutdown to minimize flaring. The OL-5 process unit was secured until the steam supply was restored to normal conditions to allow for a safe restart of the PGC. In their original final report, Shell Chemical LP - East Site indicated that the permit level for benzene was exceeded; they sent a corrected final report on August 9, 2012 explaining that the permit level for benzene was not exceeded as indicated in the earlier report. As seen on first table Date/Time: 5/8/12 17:25 - 5/9/12 17:25 for section V.a. carbon monoxide was released about reportable quantities. In addition to carbon monoxide being above reportable quantity, benzene was as well although it was not reported as such. The reportable quantity for benzene is 10 lbs with the total amount of benzene being released from Shell Chemical LP - East Site being 967.9 lbs. The LDEQ sent out an emergency responder, Nicole Hardy, who took atmospheric samples from May 8, 2012 at 17:40 to 5/9/12 at 23:30 for a total of 1 day, 5 hours and 50 minutes; all of the samples came back as being below the Permissible Exposure Limits. Although they do not report the pollutant as exceeding reportable quantity - the facility released quantities that exceeded reportable quantities for benzene during the 2 days of this event. The initial verbal notification was made on May 8, 2012. There was an initial written notification (follow up report to verbal notification) made by both Shell chemical and Motiva on July 3, 2012. The first written notification was not made in a timely manner as per state regulations. Since the July 3rd report was their first written notification following the initial verbal notification, therefore they missed the 7 day deadline to make written notification (the deadline would have been May 15, 2013; it would be 48 days late as it was written 55 days after the accident). Another follow up report termed the "final release report" was made by both Shell chemical and Motiva on August 2, 2012. A final follow up report termed the "corrected final release report" was made by by Shell chemical on August 9, 2012 - there was no corrected final report made by Motiva.
88.0 pounds

De-watering sump west of Tank F-501
Cause: On January 22, 2013 at 16:33 the de-watering sump west of Tank F-501 overflowed onto the ground. The check valve failed open with some of the material contained withing the concrete pump pad. Approximately 3 barrels of Crude oil spilled to the ground, with additional oil overflow into nearby surface drains. Follow-up Report: Operations determined that the source of the spill was the result of the check valve of the sump pumps failing open allowing crude oil to flow backwards into the sump and eventually overflowing with some of the material contained within the concrete pump pad.

Followup: Yes

Notes: Clean up efforts were implemented. A pumper truck was staged at the pump pad to remove the oil from the concrete pump pad, sump, drains, and ground. Once the oil was removed from the concrete pump pad the area and drains were water washed to a pumper truck to remove all residual oil. Follow-up report: Immediately after discovering the source, operations personnel closed the discharge block valve of the sump pump to isolate the leak source. Temporary small dikes were quickly set up to stop additional oil flow from entering the storm water drainage. Vacuum trucks were called out to begin picking up free liquid. The underground storm water system was flushed with water and all oil vacuumed up for recovery into the refinery slop system until oil could no longer be detected. The remediation began on January 24, 2013 once all free liquid was collected. This work continued through the weekend until all contaminated soil was removed for inspection. After a final inspection, fresh soil was brought in to restore the area back to its original condition. Liquids were recovered and returned to the site slop oil system. Contaminated soils were excavated and properly disposed of. Material that evaporated during the release and recovery operation was released to atmosphere and dispersed naturally. The following measures will be implemented to prevent this incident from reoccurring: the sump pump discharge block valve was tagged closed to stop such an incident from reoccurring; vacuum trucks are being utilized to remove any water from the pump pads in the short term; operator surveillance in this area has been increased; the pump discharge check valve will be replaced and any deficiencies repaired in the pump pad secondary containment. All impacted soils were excavated and properly disposed of. Motiva has no current knowledge of pollution migration as free product was contained near Tank F-501 and has been recovered. The amount of crude oil initially reported as (3 barrels or 126 gallons), but they actually released 9646.68 gallons (229.68) of crude oil. Motiva also exceeded reportable quantities for benzene, napthalene, PAH, xylene, and toluene.
103.4 pounds