APPENDIX F Pennsylvania Upset Rules and Data

Transcription

1 APPENDIX F Pennsylvania Upset Rules and Data Upset Rules: The Pennsylvania Department of Environmental Protection (PADEP) has rules that apply to most of the state. PADEP had delegated authority over air programs in certain areas to the Philadelphia Department of Public Health and the Allegheny County Health Department. Neither PADEP s rules, nor those of the Philadelphia Department of Public Heath or Allegheny County Health Department, contain a SIP exemption or affirmative defense for upset emissions. Reporting: Pennsylvania s Title V rules require the reporting of deviations, including those attributable to upset conditions, within the time required by the permit. Deviation reports are generally required to include the probable cause of the deviations and corrective actions or preventive measures taken. 1 The rules do not require that the reports include an estimation of excess emissions caused by the deviation. Philadelphia Air Management Services rules require the reporting of breakdowns, malfunctions or emergencies which may increase emissions immediately by telephone with a written confirmation within 24 hours. 2 In addition, the rules provide: where it is planned to take any approved installation, equipment, or device out of service for any reason, except for normal plant shutdowns, the Department shall be notified at least three days in advance. 3 Allegheny County Health District rules similarly require breakdowns of equipment causing excess emissions or emissions of toxics to be reported within one hour and to be followed by written notice within seven days. 4 The notice must specify the materials emitted and their estimated quantity. It must also include a statement regarding the toxic qualities of the emissions. 5 Planned shutdowns of control equipment must be reported at least 24 hours before the shutdown. 6 The reports must include the nature and quantity of likely emissions. 7 Any shutdown of control equipment without the shutdown of associated processes requires approval of the Department. 8 Data: We reviewed upset reports for the following two facilities: Facility Name Sunoco Philadelphia Refinery Sunoco Marcus Hook Refinery Facility Location Philadelphia, PA Marcus Hook, PA For Sunoco s Philadelphia refinery, we reviewed Philadelphia Air Management Services 24 hour Notifications and Release Incident Reports. For Sunoco s Marcus Hook facility, we reviewed Hazardous Material Release Notification Sarah Kurnes, Philadelphia PA, near Sunoco Refinery Once I was a healthy, robust person, but now after living near the Sunoco refinery I am unable to do normal every day things. To live in pain everyday is not what anyone should have to endure. When the facility has an upset, I can see the pollution cloud moving towards my home. The pollution forces me out of my own home and neighborhood, and has sent me to the hospital numerous times unable to breathe. I could sum up my experience in one sentence, It s a living hell. 113 Gaming the System

2 114 Reports and Incident Notifications in the files at the Pennsylvania Department of Environmental Protection. As can be seen from the attached Sunoco spreadsheet, it was not possible to determine from these files how much was being emitted by the Sunoco facilities during upsets. The 24 Hour Notification to Air Management Services reports filed by Sunoco s Philadelphia refinery include a section for the environmental impact of the event, but the response in this section rarely included emission estimates. The Release Reports and Incident Notifications filed by Sunoco s Marcus Hook facility did include some emissions estimates, but not a reliable estimate of Gaming the System total upset emissions. The reports did indicate, however, significant SO 2 emissions throughout 2002 due to repeated problems with the Ethylene Complex. NOTES 1 25 PA CODE (c)(2). 2 PAMS Reg. I, Section II.A.5. 3 Id. 4 ACHD (c). 5 Id. 6 ACHD (b). 7 Id. 8 Id.

3 SUNOCO REFINERY PHILADELPHIA, PA EMISSIONS DATA (LBS./EVENT): /13/ Reformer Flare ~possible high 12/13/ FCCU Flare 0.5 ethane, propane, butane 12/8/ Reformer 12/7/ & 866 Units H2 compressors shut down due to high level in KO drum 12/7/ & 866 Units of H2 12/2/ HF Unit Flare high for turnaround 11/18/ FCCU Flare after maintenance turnaround 10/26/02 13H1 Vaccum Tower Heater 10/26/02 #2 Boiler at 22 Boiler House 10/21/02 North Yard Propane Flare Burner Flare Fire of 600# steam boiler 10/21/ B & C 10/21/02 #2 Boiler at 22 Boiler House 10/16/ Reformer hydrocarbons Regenerating the 860 catalyst 10/12/ Unifiner 10/12/ Reformer 10/6/ B & C 10/6/ & 864 Units 10/3/ FCCU 9/28/ P-1B Charge Pump Pump 9/9/ FCCU Stack > catalyst fines 8/22/ Unit Fire Gaming the System 115

4 8/16/ Sulfur Plant 1.0 Unit upset due to back pressure caused by blockage 8/15/ Sulfur Plant Flare Both N & S plants shut down, which caused exceeding limit on N flare 8/15/ Crude Unit 8/15/ Reformer 8/13/ Sulfur Plant Flare Both N & S plants shut down, which caused exceeding limit on N flare 8/12/ Unifiner 8/12/ Reformer 8/12/ Sulfur Plant Flare Both N & S plants shut down, which caused exceeding limit on N flare 8/10/ A & B Crude Units due to small leak in fuel gas drum 8/10/ N Sulfur Plant Flare Both N & S plants shut down, which caused exceeding limit on N flare 8/9/ N Sulfur Plant Flare Both N & S plants shut down, which caused exceeding limit on N flare 8/7/02 NE Refining Complex Flare ,200 8/7/ Sulfur Plant Flare 8/6/02 #2H9 Boiler at 860 Unit 8/6/ Gulfiner Unit 8/6/02 #2H9 Boiler at 860 Unit Test run to check instrumentation 7/30/ Unit after hot standby 7/25/ Sulfur Plant Stack 1.0 7/25/02 North Claus Unit 15.0 High backpressure Gaming the System 116

5 7/24/ Sulfur Plant Stack 7/11/ Sulfur Plant Burner 2.0 Leak malfunction 7/3/ Cumene 6/18/02 NE Refining Complex Flare 0.8 1,974 6/4/ Gulfiner Unit Tower for repairs 5/28/ FCCU Stack ~ >20% 0.1 5/23/ Udex Unit 4/21/ CO Boiler Tube Leak malfunction 4/21/ FCCU possible high emission 4/19/ Reformer Flare ~possible high Going to total combustion 4/17/ DIB Tower Flare 0.2 4/17/ Reformer Tower smoke Fire 4/17/ Unit Reboiler propane, butane dissipated with steam 4/14/ Sulfur Plant Line over reportable quantity DEA (exceeded as well) Leak malfunction Leak malfunction 4/8/02 #3 Boiler House Stack smoke 0.1 3/25/ FCCU Flare smoke 0.5 Instrumentation problem produced high 3/6/02 #3 Broiler Stack smoke 0.2 Steam load increase 3/3/02 868, 865 FCCU Flare high 2/24/ FCCU Flare ~possible 2/23/ FCCU Flare ~possible 2/22/ FCCU Flare ~possible Power Outage Gaming the System 117

6 2/21/ Unit Lost feed to unit, shutdown 2/13/ Reformer Flare 2/9/ CO Boiler ~possible 2/9/ Udex Unit Flare 2/7/ Cumene preparation after turnaround 2/4/ Gulfiner Unit Flare 2/4/02 Tank 884 crude 1/30/ FCCU Flare ~possible 1/27/02 #1 Boiler tubes : tubes damaged on restart 1/26/ Unit 0.0 PP mix Gauge malfunction 1/22/ FCCU Flare ~possible 1/19/ FCCU Flare ~possible 1/18/ FCCU to cool disengager 1/16/ FCCU Catalytic Cracker 12/23/ Crude Unit 12/23/01 #3 Boiler at 22 Boiler House 12/20/01 #4 Water Treatment Plant Flare, smoke 12/20/ FCCU Flare ~possible spikes 12/6/ FCCU ~possible Restart Tank lbs of Cl2 Accident Problems necessitating shutdown and restart 12/5/ Reformer 11/27/ Reformer to repair H2 leak 11/20/ Reformer Gaming the System 118

7 11/18/01 HDS 866 Flare ~possible Heating up unit for start-up 11/12/ Reformer 10/19/01 HDS /19/ FCCU 10/16/ Gulfiner Unit 10/14/ FCCU Flare heavy 10/13/ FCCU Stack exceeded 10/13/ FCCU spike Valve start-up catalyst fines 10/13/ Gulfiner Unit 9/27/ Unit 1232 absorber off gas pipe 9/12/ Incinerator Stack higher levels will be in the fuel gas system as a result Stack 1.0 SO2 excursion 8/30/ Unit Tower hydrocarbons 8/26/ Regenerator ~possible spikes 8/25/ CO Boiler high 8/23/ FCCU C-101B Blower 8/10/ Reformer, 864 Unifiner catalyst fines Maintenance Stack catalyst fines 8/5/ FCCU 8/1/ FCCU 7.0 7/31/01 #40 Boiler at #3 Boilerhouse 7/21/ Reformer, 864 Unifiner 6/29/01 #2 Boiler at 22 Boiler House Stack smoke 0.1 Maintenance smoke 0.3 and restart 6/27/ Reformer 6/22/ Reformer Gaming the System 119

8 6/20/ Sour Water Stripper 6/18/01 NE Refining Complex Sulfur recovery unit 6/18/ CO Boiler #4 soot blower ~71% 6/18/ Sour Water Stripper Tower 6/18/ CO Boiler #4 soot blower high 6/18/ Crude Unit Heater smoke (heavy) 6/11/01 NE Refining Complex Sulfur recovery unit 0.8 1, catalyst fines 1.0 catalyst fines ,593 6/11/ Sulfur Plant Tail gas unit 6/11/ Sulfur Plant Tail gas unit 6/11/ Reformer 6/6/ Reformer Cooling tower hydrocarbons 5/27/ Light Ends Unit 5/26/ Light Ends Unit Flare Flare 5/22/01 This is a drill hydroflouric acid, <50 gal 5/20/01 Depropanizer Reflux Pump Flare some smoke, high 5/20/ FCCU Stack exceeded 5/18/ FCCU Stack spikes; exceeded Repairs to depropanizer put tower back in service Deprop reflux pump shut down due to malfunction Failed pump with no backup caused emissions Spikes during shutdown, 5 hrs during start-up 5/17/ FCCU Flare 5/17/ Alkylation Unit 5/16/ Alkylation Unit 5/13/ Unit Gaming the System 120

9 5/12/ Reformer, 864 Unifiner, & 866 Unit 5/11/ Reformer 5/10/ FCCU exceeded 60%, 20% 0.1 5/10/ Unit 0.0 H2 4/20/ CO Boiler Sootblower soot #3 sootblower operated after repair 4/15/ Reformer smoke 1.0 Fire 4/15/01 Exchangers 2E5C 1,2,3 4/3/ FCCU ~possible high 4/2/01 Flue Gas Boilers elevated NaPh Fire Round of power off mapping to improve performance Injected walnut shells into flue gas boilers to improve efficiency 3/31/ FCCU 3/30/ FCCU 3-5 BBLS of fresh feed 3/29/ Unit Tower ethane, methane 3/29/ FCCU 3/28/ CO Boiler Flare ~possible 3/27/ Gulfiner Unit 3/21/ Crude Unit for decoking 3/7/ CO Boiler Stack catalyst fines Maintenance 3/4/01 Belmont Terminal: Air to City Sewer 2/27/ Light Ends Unit Fan light ; flames controlled with steam Car accident damaged pollution control device for turnaround Gaming the System 121

10 2/27/01 HF 433 for repairs 2/26/ Unit Valve hydrocarbons Safety valve release 2/25/ Alkylation Unit 2/5/ Unit Flare high, no smoke 1/30/01 Tank SR73 Valve iso-butane Crack in valve 1/23/01 SRTF Butane Spheres Sphere Compressor malfunction 1/19/ Alkylation Unit Flare unit out of service 1/17/ FCCU Stack Some 1/17/ FCCU >20% 11.0 >200 PPA (?) for 2 hrs 1/16/ FCCU ~possible exceeding 1/16/ Alkylation Unit Flare high Depressurizing in prep for turnaround 1/9/01 CRU 1332 Prefract column Pressure surge led to release 1/7/ Reformer 1/1/ Alkylation Unit Flare high 1/1/ Alkylation Unit Gaming the System 122