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Learn: ExxonMobil Out of Control

Specific Examples of Pollution and Enforcement Problems at Baytown

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  1. Operating major units with no backup Discussion of persistent problems (page 28 of report): The company has had repeated occurrences in which they've continued to operate theFCCU-3 unit at times when there is no backup boiler. Boilers B and C have each been primarily or secondarily implicated in 10 excess emission episodes each.

    Quick Facts:
    Problem: Company repeatedly operates unit without backup
    Unit: Fluidized Catalytic Cracker Unit-3(FCCU-3)
    # of episodes: 28 from '98-'00
    Time in episodes: 1,364 hours

    Only the three worst FCCU-3 incidents in length and total emissions drew a TNRCC Notice of Violation for repeated violations caused by design, maintenance and/or operational failure.

    The most frequent failures involve electrical outages, tube and/or refractory failure, air blower failure, low water condition and unit to unit interactions. There is not always a clear indication in the upset reports that ExxonMobil reduced the FCCU-3 production rate during these conditions.

    The most significant ExxonMobil culpability is their frequent practice of running their FCCU-3 process during times when no operable carbon monoxide boiler is available as a backup unit.

  2. Continued operation of unreliable units Discussion of persistent problems (page 29 of report): Poor reliability of BS-4 compressor C-904 is responsible for repeated and preventable incidents of flaring at the Baytown Refinery. There were at least 7 such incidents involving this equipment. Unreliability at BS-4 compressor C-901 is responsible for at least 4 additional incidents. At least 5 incidents didn't properly identify the specific compressor which caused a problem. Although C-901 has a backup, which is C-902, apparently there is no backup unit for C-904.

    Quick Facts:
    Problem: Unreliable gear, maintenance conducted with no backup ready
    Unit: Booster Station 4 (BS-4)
    # of episodes: 20 from '98-'00
    Time in episodes: 2,286 hours

  3. Maintenance without backups Discussion of persistent problems (page 29 of report): ExxonMobil had one maintenance episode in which it conducted "planned maintenance" on BS-4 compressors while the rest of the plant continued to operate. This incident caused flaring to go on for 26 days, releasing 485 tons of sulfur dioxide, 48 tons of volatile organic compounds and 5.56 tons of hydrogen sulfide. At the time, this incident apparently drew no TNRCC enforcement interest as TNRCC issued no violation.

    Repeated cases of running major maintenance while the facility continued to operate caused significant maintenance-releated emission episodes. Additional installations of backup equipment ought to be considered for these types of situations. Another 4 day "planned maintenance event" caused the release of 24 tons of volatile organic compounds.

  4. Planned maintenance results in high or extended emissions episodes Discussion of persistent problems (page 29 of report): ExxonMobil had 27 episodic emission events involving sulfur conversion unit SCU-2. This is the unit where hydrogen sulfide cleaned from refinery fuel gases is converted to elemental sulfur.

    On only 1 of these events, which always involve significant emissions of sulfur dioxide, did ExxonMobil admit that they could cut throughput through SCU-2 by stopping the processing of sour water and temporarily storing this waste stream. No mention of this emission reduction technique is mentioned for the 26 other incidents.

    One SCU-2 "planned maintenance" episode lasted 66 days and involved continual violation of the facility's air permit while a "pollution control project" was installed in one of the process units at SCU-2. There are repeated incidents of "planned maintenance" where the company burns sulfur out of catalyst beds. While sulfur in the beds can cause fires, the company never addressed any underlying design, operations or maintenance scheduling approaches to try to minimize these occurrences.

    Out of 27 SCU-2 episodic events, TNRCC issued Notices of Violation on only two.

  5. Extreme problems produce no enforcement action from TNRCC: ExxonMobil violated 72 TNRCC rules from 1984 through the present, but the TNRCC only issued 6 legally binding orders to abate those violations and only imposed $64,000 in penalties in total over that period. Despite dozens and dozens of events which could merit Notices of Violations and penalties for violations of the law, the TNRCC failed to act in most cases. These violations include actions that caused upsets that were avoidable, where there were reporting violations, failure to properly report upsets, and failures to identify the cause of upsets.

Case:
use not replaced after electrical work conducted. Human error in the Baytown Refinery electric utilities center caused one of the largest emission episodes May 26, 1999. Fuses were removed from a electric utilities station in order to perform some electrical work, but the fuses were not replaced when the work was completed.

When the refinery was put back on the electric grid, out of phase operation caused a complete power failure at the facility. During a 2.5 day period, this incident resulted emissions of 102 tons of volatile organic compounds, 20 tons of sulfur dioxide and over 1 ton of hydrogen sulfide.

TNRCC Action:
No TNRCC NOV was issued for this avoidable event with massive emissions.

Case:
Upset from low flow condition. The longest flaring incident at BS-4 was an upset caused by a low flow condition in a distillation unit. This flaring at a reduced rate went on for 53 days from August 30, 1998 until October 22, 1998 and released 5.3 tons of VOC, 168 tons of sulfur dioxide and 2 tons of hydrogen sulfide.

TNRCC Action:
TNRCC-Houston never issued any Notice of Violation on any of the incidents occurring at BS-4 during 1998-2000.

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