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|LDEQ Accident Number
|Point Source(s)||Notes||Amount of Release|
|NIG||Cause: Several title V operating permit compliance matters and potential RQ exceedances resulting from upset conditions caused by Hurricane Isaac:
During a post-hurricane Isaac storm survey, the PV vent on Tank 867 was discovered leaking. Emissions from the PV vent were approximately 49 pounds of flammable vapor.
During a post-hurricane Isaac storm survey, socks on floating roof tank 783 were found missing and/or torn as a result of high winds. The missing/torn socks were replaced on September 19, 2012. Emissions from the missing/torn tank socks were approximately 1.9 pounds of VOC.
During a post-hurricane Isaac storm survey, multiple tank hatches were discovered either missing or open as a result of high winds.
Due to Hurricane Isaac, the Continuous Emissions Monitoring System (CEMS) analyzers may have experienced less than 90% data availability. Also the data calibration drift check on the analyzers may have been missed.
The HFU TTU was bypassed for approximately 1 hour due to failure to maintain TTU temperature of 1600 degrees Fahrenheit. This bypass resulted in approximately 0.08 tons of hexane being released.|
Notes: There were several compliance matters and potential RQ exceedances resulting from upset conditions caused by Hurricane Isaac. The PV vent on Tank 867 was repaired and returned to service on September 5,2012. The missing socks on tank 783 were replaced on Septermber 19, 2012. The tank hatches that were discovered missing were replaced as soon as possible to prevent any further emissions to the atmosphere. The tank that were found open were closed and remonitored using the HAWK camera. In attachment 1 of the written notification you will find a summary of the emissions from the tank hatches that were discovered missing or open. remediation of Continuous Emissions Monitoring System (CEMS) - EMCP is working to determine the extent to which the CEMS analyzers may have malfunctioned before, during, and after the storm. This information will be included in the CEMS quarterly report. HFU TTU was bypassed for approximately 1 hour resulting in a hexane release. The letter from EMCP asks that LDEQ exercise enforcement discretion and no such penalties be issued for actions and events related to Hurricane Isaac response and recovery efforts. LABB has the 30 day follow up report, as well as the subsequent LDEQ verbal report, but no subsequent written notifications that serve as a follow up to clarify the total pollutants released from the tank hatches that still needed to be repaired as of the October 4th written notification.
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