Case Study Calcasieu Refining

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EPA/STATE and LOCAL 12th ANNUAL AIR INSPECTOR
WORKSHOPApril 16, 2009Dallas, Texas

• Case Study Calcasieu Refining
• Tank 312
• by Debbie Ford, EPA-R6

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Once upon a time.

• there was a small refinery in southwest Louisiana
  named Calcasieu Refining.
• Its capacity was 15,000 barrels of oil per day
  (bpd).

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It began to grow and expand..

• Soon it was operating with a capacity of 80,000
  bpd

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Then there was the HAWK Project
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EPA Grant to study emissions from barges along
Louisiana waterways

• Used a helicopter with a GasFindIR camera mounted
  externally
• A series of studies over 1 ½ years along the
  Mississippi River, the Intracoastal Waterway, and
  the Calcasieu Ship Channel (SWLA)
• Ground (actually water) support crews of LDEQ and
  Coast Guard to measure and confirm leaks found

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On Wednesday, July 11, 2007, the HAWK spotted
Calcasieu Refinery situated on the Calcasieu Ship
Channel.. and noticed something
Tank 311.wmv
Tank 312.wmv
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Youve got mail

• Calcasieu Refining
• Tank 311 and tank just east of Tank 313.
  
• Both leaking vapors.
• Bruce

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Tanks are identified

• Facilities throughout LA had been forewarned
  about the HAWK Project for Homeland Security
  purposes
• The Operations Manager at Calcasieu Refining was
  contacted and he reported that the facility had 3
  crude tanks
• TK-300 EFR 100,000 bbl (NSPS Subpart Ka)
• TK-311 EFR 200,000 bbl (NSPS Subpart Ka)
• TK-312 IFR 100,000 bbl (NSPS Subpart Kb)

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Facility Plot Plan
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DEQ Investigation

• At this point, LDEQ inspectors did not know
  where the leaks were occurring only that vapors
  had been observed
• Tank inspection records were requested
• Tank 311 (EFR) records revealed no obvious
  compliance issues. Last primary secondary seal
  gap measurement performed 4 months prior. No
  obvious compliance issues.
• Tank 312 (IFR) records were more complicated.

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Tank 312 (IFR) History

• Originally built as an IFR tank in 1980 (NSPS
  Subpart Ka)
• 134 diameter, 40 height
• Floating roof aluminum pontoon deck with 10
  pontoons
• Single, vapor-mounted seal
• Originally permitted for kerosene/diesel service

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2004 Permit Modification

• References to change to crude service
• EIQ sheet for Tank 312 indicated Crude Oil Tank
  and change in emissions
• No reference to change in permit briefing sheet
  or in Applicability Table
• Tanks 4.0.9 Emission Report in application
  indicated it was a Crude Oil Tank with IFR and a
  single vapor-mounted seal (no change from prior
  service)
• Reid Vapor Pressure 5 in Tanks Emission Report
  (typical for crude)
• Raised a compliance question Did Calcasieu
  Refining just switch the service from diesel to
  crude without any modification to the tank?
• Crude has a vapor pressure gt 1.5 psia. NSPS Kb
  requires either a liquid mounted seal, a
  mechanical shoe seal, or a double seal (primary
  and secondary).

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Tank 312 (IFR) history (contd)

• LDEQ inspection June 2005 - tank still in diesel
  service
• Internal inspection records October 2005
  indicated that the tank was storing diesel but
  was changing to crude service
• Permit modifications approved in 2007 indicated
  NSPS Subpart Kb applicability

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Other issues

• The company found some e-mails regarding work
  done on Tank 312. They began pulling the
  financial records and contracts to determine the
  scope of work.
• Conclusion facility had installed a double-seal
  system in Feb. 2006.
• Records indicated that crude was introduced to
  the tank in late Feb. 2006. No notification to
  LDEQ to observe inspection prior to tank refill.

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Facility visit 7/17/06 (Tues)

• Met with the new Environmental Manager
• While at the facility, we received the video of
  the helicopter flyover with the visible emissions
  from the crude tanks. This was the first time we
  knew the exact location of the reported
  emissions.
• Reviewed the crude assays from barge deliveries
  from 7/3/07 7/15/07 RVP was 7.6, 5.6, 5.0, 4.8,
  and 7.9.
• RVP records for Tank 312 since put into service
  revealed a max RVP of 11 and an average RVP of
  7.98.
• Environmental technician had monitored the tanks
  on 7/12/07 (the date the emissions were observed)
  using a TVA-1000.
• 8 of 16 roof vents on Crude Tank 300 (EFR) gt
  10,000 ppm. Maximum concentration was 161,400
  ppm.
• 9 of 23 roof vents on Crude Tank 311 (EFR) gt
  10,000 ppm. Maximum concentration was 147,800 ppm
  (this was the leaking vacuum breaker observed on
  the video).
• These roof vents described by the Env.
  Technician were later found to be the roof legs
  and vacuum breakers.

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Visual inspection of roof

• Company had not performed an annual
  through-the-hatch visual inspection in Feb. 2007.
  
• Due to the visual observation of emissions by the
  GasFindIR and a concentration of 4000 ppm with
  the TVA-1000, we arranged for the facility to
  perform a visual inspection.
• Company said the level would be kept at a low
  level.
• 2 days later at the inspection, it was full. Only
  saw about 5-6 feet of the seal. It was a gray,
  closed-cell extruded foam material.

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Seal Material

• Softlite Ionomer Periphery Wedge Seal made of
  Dupont Surlyn by Gilman Corp.
• Life expectancy of 5-8 years.
• Technical info from Dupont
• Highly resistant to permeation by liquids.
  However, some aromatic, cyclic, and higher
  aromatic hydrocarbon solvents do cause swelling
  permeate through the ionomer should be used
  with caution.
• Aromatics are plasticizers causing swelling,
  weight gain, softening, and some loss of
  strength.
• Ethylbenzene Toluene were listed as not
  resistant and were not recommended for service
  under any conditions.

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Double seal installation details

• Upgrade of tank undertaken by prior Plant Manager
  and prior Environmental Manager
• Company bought the materials (seal, framework)
  from different suppliers and contracted with a
  third company to install.
• The additional weight of a mechanical shoe seal
  would have likely required replacement of the 10
  pontoons with 12 inch pontoons, thus much higher
  cost.

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Seal Material

• Softlite Ionomer Periphery Wedge Seal made of
  Dupont Surlyn by Gilman Corp.

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Seal Material (contd)

• Life expectancy of 5-8 years.
• Technical info from Dupont
• Highly resistant to permeation by liquids.
  However, some aromatic, cyclic, and higher
  aromatic hydrocarbon solvents do cause swelling
  permeate through the ionomer should be used
  with caution.
• Aromatics are plasticizers causing swelling,
  weight gain, softening, and some loss of
  strength.
• Ethylbenzene Toluene were listed as not
  resistant and were not recommended for service
  under any conditions.

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Other issue

• Company was nearing conclusion of negotiations
  for Refinery Consent Decree.
• Wanted to exclude any compliance issues prior to
  July 31, 2007 (thus the issues with Tank 312).
• LDEQ denied request the company agreed to empty
  degas the tank by Feb. 2011. A mechanical shoe
  seal will be installed.
• Until then, a semi-annual through-the-hatch
  visual inspection with LDEQ observation will be
  implemented.

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Use of Dupont Surlyn seals (aka Softlite Seals
by Gilman Corp)

• If you find a tank with this material, send me
  (ford.debbie_at_epa.gov) information about the tank
• Facility name/location
• Tank ID
• Tank size
• turnovers/year
• Material stored
• Date of seal installation
• Any info on issues with emissions/odors

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Resources

• If it doesnt look right, ask questions.
• There are always new things to learn.
• Use all of the tools of your agency
• Check your agencys library for reference
  materials

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Questions?