# Phillips 66

San Francisco Refinery
Rodeo, California

BAAQMD Plant 16



# Flare

Minimization

Plan (FMP)

Non-Confidential version

Bay Area Air Quality Management District (BAAQMD) Regulation 12, Rule 12

October 2013
, Revision 9

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 1

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# Contents

1.0 Flare Minimization Plan

........................................................................................................................... 1-3

1.1 Safety Statement

................................ ............................................................................................. 1-3

1.2 Executive Summary

................................ ......................................................................................... 1-3

1.3 Ce rtification

...................................................................................................................................... 1-5

2.0 Flare System Information

........................................................................................................................ 2-1

2.1 Background Information for Flare Systems

.................................................................................... 2-1

2.2 Technical Data – Description of Flaring Systems (401.1)

.............................................................. 2-3
2.2.1 Phillips 66, San Francisco Refinery Flare & Fuel Gas Recovery System Overview

....... 2-3
2.2.2 Detailed process flow diagram, PFD (401.1.1)

................................ ................................ . 2-3
2.2.3 Description of Monitoring and Control Equipment (401.1.2)

............................................ 2-4

3.0 Reductions & Planned Reductions

........................................................................................................ 3-1

3.1 Reductions Previously Realized (401.2)

......................................................................................... 3-1

3.2 Planned Reductions (401.3)

................................ .......................................................................... 3- 15

4.0 Prevention Measures (401.4)

.................................................................................................................. 4-1

4.1 “Major” Maintenance Activities (401.4.1)

........................................................................................ 4-1
4.1.1 Refinery Maintenance and Turnaround Activities

............................................................. 4-1
4.1.2 Measures to Minimize Flaring During Preplanned Maintenance

..................................... 4-8
4.1.3 Turnaround and Maintenance Flare Minimization Planning Tool

.................................. 4- 15
4.1.4 Measures to Minimize Flaring During Unplanned Maintenance

.................................... 4- 15

4.2 Gas Quality/Quantity Issues for Each Flare (401.4.2)

................................ .................................. 4- 16
4.2.1 When Flaring is Likely to Occur

...................................................................................... 4- 16
4.2.2 Vent Gas Recovery Systems

.......................................................................................... 4- 20

4.3 Recurrent failure (401.4.3)

................................ ............................................................................ 4- 26
4.3.1 Reportable Flaring Events Attributable to the Same Process or Equipment Item

........ 4- 26
4.3.2 Means to Prevent Recurrent Failure

............................................................................... 4- 26

5.0 Other Information Requested by APCO to Assure Compliance (401.5)

........................................... 5-1

5.1 New Equipment Installations (404.2)

.............................................................................................. 5-1

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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# Attachments

Attachment A San Francisco Refinery Simplified Flare System Overview

Attachment B San Francisco Refinery Detailed Flare Gas System Description

Attachment C San Francisco Refinery Flare System Process Flow Diagram

Attachment D Historical Startup / Shutdown Event Data (200 0 – 2006 ) BUSINESS CONFIDENTIAL

Attachment E San Francisco Refinery Unit List

Attachment F Flare Minimization Process Flowchart

Attachment G Typical Flare Gas Recovery System

Attachment H Flaring Event Overview, Recurring Failure Review, and Categorization

Attachment I Storage, Treatment, & Recovery Schematic

Attachment J DELETED – previous Attachment J now included in Attachment H

Attachment K Flare Construction BUSINESS CONFIDENTIAL portion

Attachment L Compressor Capacity & Monitoring Description BUSINESS CONFIDENTIAL portion

Attachment M Fuel Gas System Description BUSINESS CONFIDENTIAL portion

Attachment N Cost Effectiveness Calculation Background Material

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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# 1.0 Flare Minimization Plan

Regulation 12, Rule 12, was adopted by the BAAQMD in July, 2005, with the objective of reducing emissions from flares at petroleum refineries. This flare minimization plan for the Phillips 66, San Francisco Refinery (SFR) located in Rodeo, CA is consistent with progress toward that goal. It defines a series of measures that will lead to minimization of flaring without compromising refinery operations and practices with regard to safety. The key tools utilized are careful planning to minimize flaring, measuring and monitoring of flare events when they occur, coupled with evaluation of the cause of flaring events that do occur. Using this approach, an understanding of the events leading to the flaring event can then be incorporated into future planning and flare minimization efforts. The plan also examines the costs and benefits of potential equipment modifications to further increase flare gas recovery.


# 1.1 Safety Statement

This Flare Minimization plan outlines the approach that Phillips 66 , San Francisco Refinery has developed to manage and minimize flaring events, without compromising the critical safety function of the flare system. Flares are first and foremost devices to ensure the safety of refinery operations and personnel. Nothing in the BAAQMD 12-12 rule or in this Flare Minimization Plan (FMP) should be construed to compromise refinery operations and practices with regards to safety.



# 1.2 Executive Summary
Shown below are graphical representations of historical flare flow and emissions from the period of 2004 to June 30, 2013:

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 1

- 4 The Rodeo Refinery installed and has utilized a Flare Gas Recovery Compressor since the mid-70’s. Historic practices emphasized flare minimization. Some of the recent flaring reductions have occurred due to improved monitoring and tracking of flare volumes as well as attributing causes to all flaring as required by BAAQMD 12- 11 and 12-12 and internal policies for incident investigation. Other efforts to minimize flare emissions have occurred through communication and improved awareness. Flare Key Performance Indicators (KPIs) are shared throughout the organization.

High flare volumes in 2004 and 2009 were due to significant turnaround activities taking place. Key pressure vessels in the flare gas recovery system were removed from service for required 10 year vessel metallurgical inspections in 2009. In 2012 there was a large turnaround which contributed to higher than usual year to date flows. Following the turnaround, a relief valve leaking to the flare was discovered. An engineered solution was developed in order to isolate and provide an alternative relief path. In 2012 there were also a number of periods of fuel gas imbalance in which scrubbed fuel gas was sent to the flare.

In the second half of 2010 the facility experienced a number of flaring events due to the unplanned shutdowns of the 3 rd 

## party Hydrogen supplier. Phillips 66 worked closely with the 3 rd 

## party Hydrogen supplier to improve reliability at their facility. Work began in 2010 and continued up until mid-2011 when the supplier made significant equipment reliability upgrades during a planned shutdown.

In August 2009 three new, redundant liquid ring Flare Gas Recovery Compressors were installed and put in service. The purpose of the new compressors is to provide additional capacity on a consistent basis and to provide for backup compressor capacity. The new compressors are of a different design than the existing compressor and are designed to handle a wider range of composition and of flare gas. They are also less susceptible to liquid carryover impacts.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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# 2.0 Flare System Information

2 .1 Background Information for Flare Systems

Refineries process crude oil by separating it into a range of components, or fractions, and then rearranging those components to better match the yield of each fraction with market demand. Petroleum fractions include heavy oils and residual materials used to make asphalt or petroleum coke, mid range materials such as diesel (heating oil), jet fuel and gasoline, and lighter products such as butane, propane, and fuel gases.
The San Francisco Refinery is organized into groups of process units, with the general goal of maximizing the production of transportation fuels. Each unit takes in a set of feed streams and produces a set of product streams with the composition changed (or upgraded) as one step toward production of an optimal mix of refined products. Many of these processes operate at elevated temperatures and pressures, and a critical element of safe design is having the capability of releasing excess pressure via relieving devices to the flare header to manage excess materials in a controlled manner. These separation and rearrangement processes also produce and/or consume materials that are gases at atmospheric pressure. As a final step in processing, many units provide treatment to conform to environmental specifications such as reduced sulfur levels

. The refinery is designed and operated so that there will be a balance between the rates of gas production and consumption. Under normal operating conditions, essentially all gases that are produced are routed to the refinery fuel gas system, allowing them to be used for combustion in refinery heaters and boilers. Typical refinery fuel gas systems are configured so that the fuel gas header pressure is maintained by making up natural gas to meet the net fuel requirement. This provides a simple way to keep the system in balance so long as gas needs exceed the volume of gaseous products produced. Additional operational flexibility is typically maintained by having the ability to add butane and having the capability to adjust the rate of fuel gas consumption to a limited extent at the various refinery users (e.g. heaters, boilers, cogeneration units).
A header for collection of vapor streams is included as an essential element of nearly every refinery process unit. These are referred to as “flare headers”, as the ultimate destination for any net excess of gas is a refinery flare. One of the primary functions of the flare header is safety. It provides the process unit with a controlled outlet for any excess vapor flow, making it an essential safety feature of every refinery. The flare header also has connections for equipment depressurization and purging related to maintenance turnaround, startup, and shutdown, as well as pressure relief devices to handle upsets, malfunctions, and emergency releases.
Knockout drums are in place for separation of entrained liquid. This minimizes the possibility of liquid being carried forward to the flare or flare gas compressor. The vapor stream from the unit knockout drum is then routed to the refinery flare gas recovery system.
The refinery flare system consists of a series of branch lines from various unit collection systems which join a main flare header. The main flare header is in turn connected to both a flare gas recovery system and to the flares. Normally all vapor flow to the flare header is recovered by the flare gas recovery compressor, which increases the pressure of the flare gas allowing it to be routed to a gas treater for removal of contaminants such as sulfur and then to the refinery fuel gas system. Gases that cannot be recovered or used by the flare gas recovery compressor, the treater(s), and/or the fuel gas system end users flows to a refinery flare so it can be safely disposed of by combustion.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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- 2 A flare seal drum is located at the base of each flare to serve several functions. A level of water is maintained in the seal drum to create a barrier which the gas must cross in order to get to the flare stack. The depth of liquid maintained in the seal determines the pressure that the gas must reach in the flare header before it can enter the flare. This creates a positive barrier between the header and the flare, ensuring that so long as the flare gas recovery system can keep pace with net gas production, no gas from the flare header will flow to the flare. It also guarantees a positive pressure at all points along the flare header, eliminating the possibility of air leakage into the system. Finally it provides a positive seal to isolate the flare, which is an ignition source, from the flare gas header and the process units. The flare systems combine two flares with different water seal depths, effectively “staging” operation of the flares.
Gases exit the flare via a flare tip which is designed to promote proper combustion over a range of gas flowrates. Steam is used to improve mixing between air and hydrocarbon vapors at the flare tip, so as to improve the efficiency of combustion and reduce smoking. A continuous flow of gas to each flare is required for two reasons. Natural gas pilot flames are kept burning at all times at the flare tip to ignite any gas flowing to the flare. Additionally, a small purge gas flow is required to prevent air from flowing back into the flare stack.
The sources of normal or base level flow to the refinery flare gas collection system are varied, but in general result from many small sources such as leaking relief valves, instrument purges, and pressure control for refinery equipment items (e.g. overhead systems for distillation columns). Added to this base load are small spikes in flow from routine maintenance operations, such as clearing hydrocarbon from a pump or filter by displacing volatiles to the flare header with nitrogen or steam. Additional flare load results from routine process functions, such as drum depressurization at the delayed coking unit.
Flaring often occurs during unit startups and shutdowns or when pieces of equipment associated with units are taken out of service. Equipment maintenance results in the need for removal of hydrocarbon from process equipment and associated piping before opening, for both safety and environmental reasons including compliance with BAAQMD Regulation 8 Rule 10. Typical decommissioning procedures include multiple steps of depressurization, and purging with nitrogen or steam to the flare header. During these steps, the quality of the fuel gas is degraded and at times cannot be recovered. During startups, low quality gases may also be produced which are not desirable to be recovered. Additionally, when multiple units are shutdown, flaring can occur when gases are being produced at one unit and an interrelated unit which normally utilizes the gases

, such as hydrogen, have not yet been started up.

A lthough maintenance-related flows can be large, the design and sizing of refinery flare systems is without exception driven by the need for safe disposal of much larger quantities of gases during upsets and emergencies. A major emergency event, such as a total power failure, will require the safe disposal of a very large quantity of

gas and hydrocarbon materials during a very short period of time in order to prevent a catastrophic increase in system pressure. The flow that the flare system could be called upon to handle during an event of this type is several orders of magnitude greater than the normal or baseline flowrate.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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# 2.2 Technical Data

– Description of Flaring Systems (401.1)
This section contains the information required under 401.1 in regards to required Technical Data.



# 2.2.1 Phillips 66, San Francisco Refinery Flare & Fuel Gas Recovery System Overview
2.2.1.1 General Flare Gas System Overview
The Phillips 66 Rodeo Refinery has a flare gas recovery system in which liquids and gases are recovered the majority of the time, cleaned, and utilized as fuel gas in facility heaters and the co-generation plant. When gases cannot be recovered due to quality or quantity issues gases would be routed to the flare. There are two flares on site which function in a semi-cascading manner. The C-1 Main Flare (S-296) is the primary flare that is utilized. The MP-30 Flare (S-398) is used during significant events (i.e. major utilities failure) and during times in which the Main Flare is shut down for maintenance. The Refinery flare system consists of the following key components:

 Flare gas compressor recovery system;

 Liquid recovery system;

 Video monitoring system;

 Flare gas flow measurement system;

 Automated flare gas sampling system, and

 Smokeless flare installation.

See Attachment A for simplified diagram of the flare gas recovery system. Attachment B contains a detailed description of the refinery flare gas system. Attachments K and L contain information on the flares and compressors, respectively.



# 2.2.2 Detailed process flow diagram, PFD (401.1.1)

See Attachment C for PFD of SFR Flare System components. The PFD contains the information required under 401.1.1. The PFD contains the pipelines, process unit blowdown origins, flare gas recovery system equipment, water seals, surge drums, knock-out pots, and other equipment associated with the flare system. The drawing contains the dimensions and capacities of the flare gas recovery system, compressor, water seals, surge drums, and knockout pots.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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# 2.2.3 Description of Monitoring and Control Equipment (401.1.2)
Locations of flowmeters, temperature and pressure indicators are shown on the PFDs referenced in the section above. Locations of sample points and monitoring equipment are also shown on the PFDs. Listed below are the monitors and controls associated with the flare gas recovery system as required by 401.1.2.
2.2.3.1 C-1 Main Flare (S-296)

Flare System Flowmeters

Main Flare (S

- 296)

– Flare System Flowmeters
Tag Number Description Location Type (e.g. sonic) Range

(X

– Y scfd)

Flare Gas Flow:

RFLRE :19FI 0 520 Main Flare 42" Line 42" Line

- Upstream of Flare Stack Water Seal (C

- 1) Ultrasonic Flowmeter 0

- 60,000

RFLRE :19FI 0 520l. 42" Line

- low range 0

- 2,000

RFLRE :19FI 0 520h. 42" Line

- high range 0

- 60,000

RFLRE :19FI 0 513A

. Main Flare 42" Line 42" Line

- Upstream of Flare Stack Water Seal (C

- 1) Anemometer 1 

## 0

- 110,000

RFLRE :19FI 0 586 Main Flare 10" Line 10" Line

- From U200 & U267 Ultrasonic Flowmeter 0

- 20,000

RFLRE:19FI 0 586 l. 10" Line

- low range 0

- 2,000

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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- 5 Main Flare (S

-

296)

– Flare System Flowmeters
Tag Number Description Location Type (e.g. sonic) Range

(X

– Y scfd)

RFLRE :19FI 0 586 h. 10" Line

- high range 0

- 20,000

RFLRE :19FI 0 513. Main Flare 10" Line 10" Line

- From U200 & U267 Anemometer 1 

## 0

- 6000

Purge Gas Flow:

RFLRE:19FIC0 510. Natural Gas Purge Purge into Flare Stack (C

- 1) Orifice Plate 0

- 930 MSCFD

RFLRE:19FI0 521. Natural Gas Purge Purge into Flare Stack (C

- 1) Orifice Plate 0

- 25 MSCFD

1 

## Does not meet 12-11 accuracy requirements for all ranges. Utilized as a back up meter, when necessary.
Continuous Recording Instruments



# Main Flare (S

- 296)

– Continuous Recording Instruments

Tag Number Description Location Instrument Type

Pressure

RFLRE:19PIC0 530. 200:19F

- 1 PRESSURE Refinery Relief Blowdown Drum (F

- 1) Pressure Pressure Indicator

RFLRE:19PI0 520. 42" Line

- Upstream of Flare Stack Water Seal (C

- 1) (integrated with ultrasonic flowmeter) 

## 42" Line

- Upstream of Flare Stack Water Seal (C

- 1) Pressure Indicator

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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# Main Flare (S

-

296)

– Continuous Recording Instruments

Tag Number Description Location Instrument Type

RFLRE:19PI0 586. Main Flare 10" Line (integrated with ultrasonic flowmeter) 

## 10" Line

- From U200 & U267 Pressure Indicator

Level

RFLRE :19LIC0 512. 200:19F

- 3 Water Seal Level 19F

- 3 Water Seal Water Seal Level Indicator

RFLRE :19LI0508

. 200:19C

- 1 Flare Stack Water Seal Level 19C

- 1 Flare Stack Water Seal Level Indicator

Temperature

RFLRE :19TI0 520. 200: Flare Blowdown Line Temperature 42" Line

- Upstream of Flare Stack Water Seal (C

- 1) Temperature

RFLRE :19TI0 586. 200: 10” Line Flare Blowdown Line Temperature 10" Line

- From U200 & U267 Temperature

RFLRE :19TI0 528A. 200:19C

- 1 Flame Sensor Flare Tip Thermocouple

RFLRE :19TI0 528B. 200:19C

- 1 Flame Sensor Flare Tip Thermocouple

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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# Main Flare (S

-

296)

– Continuous Recording Instruments

Tag Number Description Location Instrument Type

RFLRE :19TI0 528C. 200:19C

- 1 Flame Sensor Flare Tip Thermocouple

RFLRE :19TI0 528D. 200:19C

- 1 Flame Sensor Flare Tip Thermocouple

Analyzers

RFLRE :19 A I 0 520. 42" Line

- Molecular Weight 42" Line

- Upstream of Flare Stack Water Seal (C

- 1) MW Indicator

RFLRE :19AI0 586. 10” Line

– Molecular Weight 10" Line

- From U200 & U267 MW Indicator

RFLRE :19AI0 501. 42" Line

- Oxygen 42" Line

- Upstream of Flare Stack Water Seal (C

- 1) Oxygen Content Indicator

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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- 8 2.2.3.2 MP -30 Flare (S-398)
Flare System Flowmeters



# MP

- 30 Flare (S

- 398)

– Flare System Flowmeters

Tag Number Description Location Type (e.g. sonic) Range (X

– Y scfd)

Flare Gas Flow:

RFLRE :19FI0 584. MP30 48" Line 48" Line

- Downstream of Water Seal (F

604) Ultrasonic Flowmeter

RFLRE :19FI0 584L. 48" Line

- low range 0

- 2,000

RFLRE :19FI0 584 H

. 48" Line

- high range 0

- 35,070

RFLRE :19FI0 585

. 36" Line 36" Line

- from Refinery Blowdown Line (F

2) Ultrasonic Flowmeter 0

- 12 0,000

RFLRE:19FI0585L. 36" Line

– low range

RFLRE:19FI0585H. 36" Line

– high range

Purge Gas Flow

RFLRE :19FIC0 511. 

## Natural Gas Purge Orifice Plate 0

- 930 MSCFD

1 

## Does not meet 12-11 accuracy requirements for all ranges. Utilized as a back up meter, when necessary.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 2

- 9 Continuous Recording Instruments



# MP

- 30 Flare (S

- 398)

– Continuous Recording Instruments

Tag Number Description Location Instrument Type

Pressure

R230:PI6014. 230F

- 600 Blowdown Drum Upstream of MP30 Relief Blowdown Drum (F

600) Pressure Indicator

RFLRE :19PI0 584. MP30 48" Line 48" Line

- Downstream of Water Seal (F

- 604) Pressure Indicator

Level

R230:LIC654A. 230:F

- 604 MP30 Flare System Water Seal Make Up H2O

Level F

- 604 Vessel

R230:LIC654B. 230F

- 604 MP30 Flare System Water Seal H2O Drain

Level F

- 604 Vessel

RFLRE :19LI0509

. 200: (C

- 602) Flare Stack Water Seal MP30 Flare Stack (C

- 602) Water Seal Water Seal Level Indicator

Temperature:

RFLRE :19TI0 584. 200:MP30 Flare Vapor Temperature 48" Line

- Downstream of Water Seal (F

- 604) Temperature

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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# MP

- 30 Flare (S

- 398)

– Continuous Recording Instruments

Tag Number Description Location Instrument Type

RFLRE :19TI0 529A. 200:(C

- 602) NW Flare Pilot Flare Tip Thermocouple

RFLRE :19TI0 529B. 200:(C

- 602) NE Flare Pilot Flare Tip Thermocouple

RFLRE :19TI0 529C. 200:(C

- 602) SE Flare Pilot Flare Tip Thermocouple

RFLRE :19TI0 529D. 200:(C

- 602) SW Flare Pilot Flare Tip Thermocouple

Analyzers

RFLRE :19AI0 584. 200:MP30 Flare Vapor Molecular Weight 48" Line

- Downstream of Water Seal (F

- 604) M olecular Weight Indicator

RFLRE :19AI0 502. 200:MP30 F lare Oxygen 48" Line

- Downstream of Water Seal (F

- 604) Oxygen Content Indicator

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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- 11 2.2.3.3 Unit 200 Flare Gas Recovery Compressor (G-503)
See Attachment C and L for diagrams showing locations of meters and analyzers.

Flowmeters



# Flare Gas Recovery Compressor (G

- 503) Flowmeters

Tag Number Description Location Type

(e.g. sonic) Range

(X

– Y MMSCFD)

Gas Flow:

R200:FI_506B. Flare Gas Recovery Compressor (G

- 503) Downstream of Salt Water Exchanger E

- 510 

## Orifice Plate 0

– 4.64

Monitors and Instruments
Note: All setpoints and alarms are subject to change. These values may change as operational or safety optimization opportunities are identified. This list contains the values at the time of publication. 

# Flare Gas Recovery Compressor (G-503) Monitors and Instruments

Flar e Gas Recovery Compressor (G

- 503) Monitors & Instruments

Tag Number Description Location Att Setpoint or Alarms

Pressure

R200:PI 0 509. 200:F

- 509 Separator Overhead F

- 509 Separator Overhead C 0.5 psig Alarm
0.0 psig

– Action automatic unloading of

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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# Flar e Gas Recovery Compressor (G

- 503) Monitors & Instruments

Tag Number Description Location Att Setpoint or Alarms
compressor cylinders

R200:PI 0 513. 200:G

- 503 1st Stage Downstream of 1 st 

## Stage C None

R200:PI 0 515. 200:G

- 503 2nd Stage Downstream of 2 nd 

## Stage C None

R200:PI 0 514. 200:G

- 503 Frame Oil Downstream of Frame Oil Filters L None

R200

– PAL 575 200: G

- 503 Frame Oil (Local Indication) Downstream of Frame Oil Filters L Shutdown Compressor

- < 16 psig
Temperature

R200:TI 0 509. 200:F

- 509 Separator Overhead F

- 509 Separator Overhead C Alarm

– 150 o 

## F

R200:TI 0 511. 200:G

- 503 Flare Gas Recovery Compressor

1st Stage Downstream of 1 st 

## Stage C None

R200:TI 0 513. 200:G

- 503 Flare Gas Recovery Compressor

2nd Stage Downstream of 2 nd 

## Stage C Alarm

– 300 o 

## F

Shutdown

- 350 o 

## F

R200:TI 0 510. 200:G

- 503 Tempered Water Upstream of Exchanger E

- 512 L None

R200:TI 0 512. 200:G

- 503 Frame Oil Downstream of Frame Oil Pump L None
Analyzer

R200:AI 0 504. 200:G

- 503 Discharge Specific Gravity (SG) Compressor Discharge L Alarm Low SG

– 0.60

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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# Flar e Gas Recovery Compressor (G

- 503) Monitors & Instruments

Tag Number Description Location Att Setpoint or Alarms
Alarm High SG

– 1.12

R200

- AE503. 200:G

- 503 Compressor Discharge Oxygen

Analyzer Compressor Discharge L Alarm

– 1.5% O 2



## Level Indicator

R200:L 509 200:F

- 509 Level Indicator (Local Indicator) F

- 509 Low Pressure Separator L Level is monitored by Operator.

R200

– LAH 510 200:F

- 509 Level Shutdown (Local Indicator) F

- 509 Low Pressure Separator L Shutdown Compressor

– 30% Level

R200

– LAH 537 200:F

- 503A Level Shutdown (Local

Indicator) F

- 503A G

- 503 First Stage Suction Pulsation Dampener L Shutdown Compressor

– 75% Level

R200

– LAH 538 200:F

- 503C Level Shutdown (Local

Indicator) F

- 503C: G

- 503 Second Station Suction Pulsation Dampener L Shutdown Compressor

– 75% Level

R200

– LAH 541 200:F

- 503E Level Shutdown (Local

Ind icator) F

- 503E: G

- 503 Second Stage Suction Knock Out Pot L Shutdown Compressor

– 90% Level

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



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- 14 2.2.3.4 Unit 200 Liquid Ring Flare Gas Recovery Compressors (G-540A/B/C)
Note: All data in this section is preliminary and subject to change. These values and meter numbers may change as operational or safety optimization opportunities are identified. The Compressor is undergoing a Process Hazard Analysis (PHA) at the time of the FMP update, which may result in additional changes. At this time all ranges and setpoints are being developed and thus are shown as pending.
See Attachment C and L for diagrams showing locations of meters and analyzers.

Flowmeters



# Liquid Ring Fla re Gas Recovery Compressor (G

- 540 A/B/C ) Flowmeters

Tag Number Description Location Type

(e.g. sonic) Range

(X

– Y MMSCFD)

Gas Flow:

FI

- 1573 Liquid Ring Flare Gas Recovery Compressor (G

- 540A, B, & C) Flow Downstream of F

- 540 Gas Separator Drum 

## Orifice 0

– 6,000 MSCFD

Service Liquid Flow:

FI

- 1544 (A)

FI

- 1545 (B)

FI

- 1546 (C) Compressor Service Liquid Flow Indication, Alarm, & Shutdown To Compressor 

## Orifice 0

- 200 gpm

Alarms: Low Low 100 (SD) Low 110 gpm High 150 gpm

Monitors and Instruments

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 2

- 15 Note: All data in this section is preliminary and subject to change. These values may change as operational or safety optimization opportunities are identified. The Compressor is undergoing a Process Hazard Analysis (PHA) at the time of the FMP update, which may result in additional changes. 

# Liquid Ring Flare Gas Recovery Compressor (G-540 A/B/C) Monitors and Instruments

Liquid Ring Fla re Gas Recovery Compressor (G

- 540 A/B/C ) Monitors & Instruments

Tag Number Description Location Att Setpoint or Alarms

Pressure

PI

- 1541 High Pressure Alarm and Shutdown Flare Gas to Compressor C Alarm High 115.3 psig
Alarm High High 125.3 psig (SD)

PI

- 1543 Low & High S uction Pressure Alarm Flare Gas to Compressor C Alarm High 18.5 psia

Alarm Low 14.7 psia

PI

- 1881 (A)

PI

- 1882 (B)

PI

- 1883 (C) Compressor Dual Seal Low Pressure Alarm Compressor Seal C Alarm Low 50 psig

Temperature

TI

- 1540 Suction Temperature Alarm and Shutdown Compressor Suction C Alarm High 150 o 

## F
Alarm High High 170 o 

## F (SD)

TI

– 1547 (A) Compressor Temperature Discharge Gas

Temperature Indication, Alarm, & Shutdown Discharge of Compressor C Alarm High 150 o 

## F

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 2

- 16 

# Liquid Ring Fla re Gas Recovery Compressor (G

- 540 A/B/C ) Monitors & Instruments

Tag Number Description Location Att Setpoint or Alarms

TI

- 1548 (B)

TI

- 1549 (C) Alarm High High 170 o 

## F (SD)

TAH

- 1545 Service Water Temperature Alarm Service Water to Compressor C Alarm High 150 o 

## F

Analyzer

VI

- 1541 (A)

VI

- 1542 (B)

VI

- 1543 (C) Compressor 

## Vibration Alarms Connected to compressor C High Alarm 0.4 in/second
High High Alarm 0.6 in/second (SD)

Level Indicator

LI

- 1881 (A)

LI

- 1882 (B)

LI

- 1883 (C) Compressor Dual Seal Low Level Alarm Compressor Seal C Alarm Low 35%

LAHH

- 1543 Compressor Suction Liquid Level Alarm and

Shutdown Compressor Suction C Alarm Low 32%

LAHH

- 1540 Gas Separator Drum Liquid Level Alarm & F

- 540 Gas Separat or Drum C Alarm High 85%

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 2

- 17 

# Liquid Ring Fla re Gas Recovery Compressor (G

- 540 A/B/C ) Monitors & Instruments

Tag Number Description Location Att Setpoint or Alarms

Shutdown Alarm High High 99% (SD)
Alarm Low 15.2% Alarm Low Low 4.3% (SD)

LAH

- 1542 Gas Separator High Level Alarm F

- 540 Gas Separator Drum Blowdown Side C Alarm Low 10%

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 1 

# 3.0 Reductions & Planned Reductions

3.1 Reductions Previously Realized (401.2)

Changes or Equipment in Place prior to 2003 which Prevent or Minimize Flaring

Due to economics and community concern, the refinery has a long history of flare minimization practices. The Flare Gas Recovery Compressor (G-503) was installed in the early 70’s. Up until 2000 the facility utilized a ground flare that was located near I-80. When the flare was utilized the flame was very visible from the highway. Prior to 2000 the Refinery Management had expectations for Operations to increase facility reliability to prevent upsets and to develop a means to conduct Startups & Shutdowns with minimal flaring. Those practices remain in place today.

Another item of note is the existing Sulfur Recovery Unit system. The facility has three Sulfur Recovery Units (U235, 236, & 238) which can provide for significant redundancy. This has allowed the facility to experience only one instance of acid gas flaring in the past five years from a complete refinery shutdown.

In 1999, the Unit 200 Wet Gas Compressor (G-501) seal was upgraded to a dry seal system. Previously, the seal would fail every 12 – 24 months which required a seal replacement. The seal replacement would take approximately 5 – 6 days and flaring would occur throughout this period. After the dry seals were installed, the on-line performance of the Compressor significantly improved. The compressor has not experienced a seal failure since the seal upgrade. The upgrade has resulted in a reduction of approximately 4 - 6 MMSCFD of gas flared for approximately 5 days every 12 – 24 months.

Starting in 2003 weekly updates and quarterly Key Performance Indicators (KPIs) are reported & distributed with Flaring History to all Refinery employees. The content and distribution of the KPIs is described in Environmental Services Department (ESD) Policy and Procedure 1.1 “Environmental KPIs”. The KPIs issued show trends and causes for flaring events and other reportable environmental events. The KPIs helps reduce flaring by showing all employees this is important in that it is tracked and communicated.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 2 Changes Made to Reduce Flare Emissions

May 30, 2003 to June 30, 2010
In accordance with 401.2, listed below are reductions that have been made to reduce flaring over the past 5 years. Many of the items listed are Management System improvements. Although some of these improvements are difficult to quantify, they have had a significant impact on minimizing flaring.
Changes Made to Reduce Flare Emissions ( May 30, 2003

– June 30, 2010 )

Year Installed

or Implemented Equipment Item Added, Process Changed or Procedure Implemented

Procedures:

3 rd 

## Qtr 2005

1 st 

## Qtr 201 3 (updated) Refinery Policy & Procedure (P&P) 6 .05

- 05 “Flare Monitoring & Reporting”

-

 Procedure created to communicate flare sampling, monitoring, & root cause analysis requirements. The co ntents of the procedure include Responsibilities for personnel at the refinery in respect to flare compliance activities.

 Sets standards for accountability in reg ards to monitoring, reporting, and preventing recurrence.

 Criteria for agency release reporting (i.e. CA OES, CCC HSD, BAAQMD, NRC, etc. ) for flare events.

 Summary of BAAQMD 12

- 11 flare monitoring requirements (e.g. video, flare flow, sampling)

,

 Summary of various regulatory reporting requ i rements.

 Criteria for incident investigation in respect to BAAQMD regulations and the Phillips 66 EPA Consent Decree.

 Means to track flare events with P66 Corporate incident tracking system. This procedure reduces flaring by demonstrating to employees that those who have defined roles must follow the steps outlined in the procedure and that these activities are important. It also mandates expectation for consistent evaluation of flaring eve nts & development of corrective actions to prevent recurrence.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 3 Changes Made to Reduce Flare Emissions ( May 30, 2003

– June 30, 2010 )

Year Installed

or Implemented Equipment Item Added, Process Changed or Procedure Implemented

2 nd 

## Qtr 2005

3 rd 

## Qtr 20 13 (updated)

4 th 

## Qtr 2009 &

on

- going (training) Refinery Policy & Procedure (P&P) 10.00

- 01 “Incident Investigation” & Incident Investigation Training

- P&P 10.00

- 01

establishes responsibilities, event triggers, and typical means for conducting incident investigations. The contents of the procedure include:

 Definition of the types of incidents that can occur (i.e. minor, serious, major)

.

 Responsibilities for employees that discover an incident and who must complete tasks in respect to incident investigations.

 Establishes accountability.

 Description of who m and when personnel should be notified of incidents.

 Defines w ho should participate in an incid ent investigation.

 Description of the investigation process.

 How the findings of an incident investigation are reviewed.

 How findings of an incident investigation should be communicated to employees and Phillips 66 sister refineries.

 How corrective actio ns should be addressed.
The existing procedure was updated to denote environmental related events requiring incident investigation. Flaring event s are identified in the procedure. P&P 6

- 7 cross references P&P 5

- 1. This procedure reduces flaring by demonstrating to employees that those who have defined roles must follow the steps outlined in the procedure and that these activities are important. Withou t this procedure incidents which occur would not necessarily be investigated and addressed in a co nsistent fashion. The main value in flaring reduction is that this procedure requires that corrective actions be developed and addressed for incidents.
To ensure good quality investigations are conducted the facility identified key personnel to receive incident investigation training. Training ensured that first reporting (basic who, what, when, where) captures critical initial information. The training also ensures that investigations receive the necessary level of investigation and get to defined ro ot causes. Additional work is on

- going to improve and maintain the quality of the investigations conducted.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 4 Changes Made to Reduce Flare Emissions ( May 30, 2003

– June 30, 2010 )

Year Installed

or Implemented Equipment Item Added, Process Changed or Procedure Implemented

Procedures:

2 nd 

## Qtr 2003 (approx.)

2 nd 

## Qtr 201 3 (updated) Emergency Operating Procedure EOP

- 1 “Guidelines for Standard Public Address System Announcements”

- Enhanced

Communication within the Facility when Flare Gas Recovery System Load Increases

– For example, the facility Public Announcement system is currently used if an increase in the compressor load occurs. This requires process units to review th eir operations in order to find the cause of the increase and take actions to mitigate. This prevents some flaring events from occurring in that discretionary gases , such as nitrogen purges and hydrogen, sent to the flare gas recovery system can be scheduled around peak loading periods to maximize gases recovered. Coordination of these activities is done through Operators at various units and Shift Supervisors working together to coordinate their activities in respect to use of the flare gas blowdown system. This minimizes flaring by consciously identify periods in which the blowdown system can be utilized without overloading the flare gas recovery compressor. This results in less periods of flaring due to brief peak loading of the compressor

. In addition to this process, the Public Announcement system is utilized during pla nned and emergency events as specified in some of the Unit 200 procedures (ESOP & NSOP

- various

- 200) to improve equipment use and switching. For example, if the Flare Gas Recovery Compressor (G

503) is put into Wet Gas or Odor Abatement service the public announcement system will be utilized to notify plant personnel of the change in operation. Listed below is a partial list of some of the key procedures where the public announcement system use i s referenced:

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 5 Changes Made to Reduce Flare Emissions ( May 30, 2003

– June 30, 2010 )

Year Installed

or Implemented Equipment Item Added, Process Changed or Procedure Implemented

Normal Operating Procedures

 NSOP

- 001

- 200 Relief “U200 Table of Safe Operating Limits”

 NSOP

- 306

- 200 “Light Ends Shutdown, Unit Running”

 NSOP

- 704

- 200 “G

- 501 Compressor Shutdown & Clean

- up”

 NSOP

- 707

- 200 “G

- 503 Flare Compressor Planned Shutdown”

 NSOP

- 709

- 200 G

- 503 Flare Compressor Start

- up

 NSOP

- 710

- 2 00 “Switching G

- 503 to Wet Gas Service”

 NSOP

- 711

- 200 “Switching G

- 503 from Wet Gas to Flare Service”

 NSOP

- 716

- 200 “Switching G

- 503 to Odor Abatement Service”



##  NSOP 717

- 200 “G

- 503 Flare Compressor Circulation” 

## Emergency Operating Procedures

 ESOP

- 700

- 200 “Loss of G

- 501 Compressor”

 ESOP

- 701

- 200 “G

- 503 Compressor Failure”



## 1 st 

## Qtr 2006 Normal Safe Operating Procedure (NSOP) NSOP

- 900

- 200

- 1 “Drum Switching” Operational Improvement

Flaring can occur during Unit 200 Coker drum cooling due to brief peak loading to the flare gas recovery compressor. Changes have been made which reduced the instances of this flaring. The procedure associated with drum cooling has been revised. The process of Drum Switching involves numerous steps

. The procedure was revised to clearly indicate the sequencing of steps involving cooling of the drum and the details surrounding each step. This ensures consistency and repeatability of this activity. In the past the steps were not as clearly defined. Th is resulted in periods of flaring with some Shifts and no flaring while other Shifts were conducting the same activity. By establishing specific steps this eliminates variability and prevents flaring. Additionally, communication around flare gas compress or loading has been enhanced. This has minimized the amount of instances that flaring occurs during drum cooling

.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 6 Changes Made to Reduce Flare Emissions ( May 30, 2003

– June 30, 2010 )

Year Installed

or Implemented Equipment Item Added, Process Changed or Procedure Implemented

4 th 

## Qtr 2006 & On

- Going Turnaround Planning Flare Minimization

- as part of the FMP, a formal process is utilized for turnarounds. This process had

been performed in a consistent manner and lessons learned captured and includes the following:

 Establishing Personnel Responsibilities for Various Planning Steps

 Conductin g Review of Potential Flare Minimization Techniques Prior to Turnaround

 Documenting Flare Minimization Turnaround Planning Review

 Conducting a Post Turnaround Review of Comparison of expected and actual flaring. Discussion of lessons learned and opportuni ties for improvement

 Documenting lessons learned and opportunities for improvement.

 Incorporating elements regarding flare minimization and communication of flaring in operating procedures.
Identifying corrective actions and taking action to minimize flari ng in future turnarounds.

3 rd 

## Qtr 200 3 (approx.) Maintenance Startup / Shutdown Coordination

– Coordinated the shutdown and startup of units and major pieces of equipment

during periods of high flare gas compressor loading in order to minimize total period of flaring. This coordination includes examining the periods when flaring is expected to occur and targets accomplishing shutdown and startup work in similar fashion while minimizing flaring. Some examples include emphasis on communication with Unit 200 operators when going to blowdown to work around drum switching, conducting G

- 503 Flare Ga s Recovery Compressor maintenance when major gas producers are shutdown, staging of nitrogen purging of vessels to minimize the total volume of nitrogen going to blowdown.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 7 Changes Made to Reduce Flare Emissions ( May 30, 2003

– June 30, 2010 )

Year Installed

or Implemented Equipment Item Added, Process Changed or Procedure Implemented

3 rd 

## Qtr 2013 Loss of Emergency Gas Flow to Air Liquide (REOP

- 25

- OPS)

- A n ew Refinery Emergency Operating Procedure (REOP) was

developed in response to the June 10, 2013 flaring event after loss of RFG

- A to Air Liquide. This procedure will help to reduce the flaring of sour flare gas by improved management of the RFG

- A gas at Unit 240 Plant 3 and it should also reduce the overall flaring time for this type of event with improved management of the Flare Gas recovery compressors.

Equipment

3 rd 

## Qtr 2003

4 th 

## Qtr 2010 Flow Meter Installation on Main & MP30 Flares

– Flow meter installation per BAAQMD Regulation 12

- 11

- 501. The installation of

the flow meters provides for enhanced recognition of flaring events. The flow meters help reduce flaring by providing an acc urate means to measure and provide ind ication as to when flaring is occurring. The flow meters are especially useful for small flaring events which may not be detectable from visual flare stack monitoring only. The meters help to track and record all instance s of flaring as well as giving Un it Operators immediate indication that flaring is occurring so that they can take action to reduce flaring.
Added an additional ultrasonic meter to a line that was previously only put in service every 5

- 10 years. This meter (RFLRE:FI0585) went into ser

vice December 2010.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 8 Changes Made to Reduce Flare Emissions ( May 30, 2003

– June 30, 2010 )

Year Installed

or Implemented Equipment Item Added, Process Changed or Procedure Implemented

2 nd 

## Qtr 2005 Unit 250 Diesel Hydrotreater Design

– This unit was designed with a Zero Power Failure Relief Load. This unit operates under

pressure. Typically, hydrotreaters would automatically relieve to a refinery flare blow down system in the event of a power failure to protect equipment from overpressuring. This unit was designed in a manner that prevents the need for the unit to vent to the flare during a power failure or other loss of utilities. Listed below are the pri mary means this design was accomplished. .

 High design pressure of reaction system equipment to contain settle out pressure in event of a power failure.

 No automatic reaction system depressuring.

 Designed with a manually activated depressuring system.

 Product stripper was designed as a steam stripper, eliminating a fired heater and reducing power failure relief load.

 Hot Separator was designed with the capacity to contain all oil from the reactors, minimizing impact on the Product Stripper in a power f ailure.

Dec. 2006 Completed Addition of Unit 110 Atmospheric Vent for Hydrogen

- Benefit is to vent hydrogen during startup, shutdown, and/or during

hydrogen supply imbalances to the atmosphere rather than sending it to the flare. When hydrogen is sent to the flare this re sults in the shutdown of the flare compressor & flaring of all materials that have been sent to the blowdown system.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 9 Changes Made to Reduce Flare Emissions ( May 30, 2003

– June 30, 2010 )

Year Installed

or Implemented Equipment Item Added, Process Changed or Procedure Implemented

Milestones (approximate)

 October
2008

– Construction Start



##  August 2009 Startup (actual) Installation of Additional Flare Gas Recovery Compressors G

- 540A/B/C

- – The Clean Fuels Expansion Project (CFEP)

determined a new Odor Abatement (OA) Compressor would be required to maintain reliability of the OA system during peak loadin g periods. Initially, the new compressor was to be designed in order to serve in both OA and Flare Gas Recovery Compressor service in order to leverage the use of the new OA compressor. After detailed engineering evaluation and analysis it was determined to install separate compressors in each service. The main benefits will be to allow for additional Flare Gas Recovery Comp ressor capacity on a consistent basis and to provide for backup compressor capacity. The new Flare Gas Recovery Compressor was also designed to handle the varying composition of flare gas. The Liquid Ring compressor installed is actuall y a set of 3 compr essors that can be used in conjunction with each other or separately. Some of the identified benefits of the Liquid Ring compressor are reliability and it can handle gas quality variations and liquid carryover much more readily than other ty pes of
compres sors. The total capacity of the three liquid ring compressors is 4.8 MMSCF/D. The new compressors will eliminate the majority of flaring associated with brief peak loading and eliminate flaring that occurs when the G

- 503 Flare Gas Recovery Compressor is taken out of service for routine maintenance. The compressor and associated fuel gas system will still be limited by gas quality and heating value requirements of the downstream fuel gas combustion sources.

The G

- 503 compressor and one of the Liquid Rin g Compressors will be operated at all times with the exception of planned maintenance periods. This will allow for increased capacity in the flare gas recovery compressor system and will be able to pick up swings that occur during brief peak loading on th e existing compressor. The 3 new Liquid Ring Flare Gas Compressors will be operated simultaneously when the G

- 503 compressor is shutdown for planned maintenance. The operational philosophy of this system of compressors will incorporate measures to minimi ze periods of no flare gas recovery. That will be done by optimizing up time of flare gas recovery by developing operating and maintenance procedures which focus on compressor up time

. The system operatio n may change as operating procedures are developed and actual operation experience is gained.
As stated above, a separate Odo r Abatement Compressor was installed . The new odor abatement compressor will add an additional compressor to the three currently available.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 10 Changes Made to Reduce Flare Emissions ( May 30, 2003

– June 30, 2010 )

Year Installed

or Implemented Equipment Item Added, Process Changed or Procedure Implemented

2 nd 

## Qtr 2015 target Propane Recovery Project

– permit application No. 25199 has been submitted to BAAQMD and is undergoing review. The

purpose of the project is to recovery propane and butane from the refinery fuel gas (RFG). Another aspect of the project is to remove a portion of the sulf ur com pounds from the remaining Refinery Fuel Gas (RFG). From a flaring standpoint, this project is beneficial in reducing overall volume of Refinery Fuel Gas. The propane and butane will be replaced by natural gas provided by PG&E. Because it is relative ly easy to reduce the amount of natural gas being imported, the likelihood of flaring due to fuel gas imbalance will be reduced. In addition, by reducing the concentration of sulfur in fuel gas this removes some of the restrictions on where fuel gas can b e routed which further helps to minimize and reduce periods of potential fuel gas imbalance.

Processes:

3 rd 

## Qtr 2003 Monthly Flare Event Reporting

- BAAQMD Regulation 12

- 11

- 401 requires reporting of all flaring. The requirement to report all

events has required enhanced recognition for all flaring events and establishes the history of all flaring events. Reporting of flaring events requires the refinery to recognize all flaring events and track them. These records are used to monitor trends of flaring events as described in the reference to monthly Key Performance Indicator (KPI) tracking: ESD Policy & Procedure 1.1 “Monthl y Environmental KPIs” The data is also used for root cause analysis and to identify ways to take action to prevent re current flaring.

4 th 

## Qtr 2003 Flare Root Cause Analysis Reporting for Land Use Permit

– Under the facility Land Use Permit (LP02

- 2095) an agreement was

made and a condition (S7) was imposed that required the facility to conduct a root cause analysis of any flaring event at the refinery that exceeded 500,000 SCF. The analysis was required to be provided to a Non

- Governmental Organization (NGO) and a copy submitted to the BAAQMD. This reporting reduces flaring by requiring the facility to identify causes of flaring which brings focus to potential failures, repetitive activities, and potential trends. This requirement was in place for Rodeo prior to the 12

- 12 root cause requirement. This condition has now expired. This reporting required the refinery t o focus on the cause of events 1

- 1/2 years prior to the adoption of 12

- 12. It also caused the facility to start examining causes of flaring events in order to take action to prevent

recurrence.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 11 Changes Made to Reduce Flare Emissions ( May 30, 2003

– June 30, 2010 )

Year Installed

or Implemented Equipment Item Added, Process Changed or Procedure Implemented

3 rd 

## Qtr 2005

3 rd 

## Qtr 2007 (Land Use Permit addition) Flare Root Cause Analysis Reporting BAAQMD

– Reporting of root cause of flaring events which exceeded a volume of 500,000

SCF/D or 500 lbs SO2 (4/06) as required by BAAQMD Regulation 12

- 12

- 406. Reporting of root cause required the facility to take a closer loo k at flaring events and ensure that corrective actions had been appropriately identified to prevent recurrence. This reporting reduces flaring by requiring the facility to identify causes of flaring which brings focus to potential failures, r epetitive acti vities, and potential trends. Prevention measures identified to prevent recurrent flaring must also be identified and report ed to the BAAQMD. As part of the root cause analysis, actions are defined and taken to prevent recurrence.

Under the Clean Fuels Expansion Project (CFEP) Land Use Permit 05

- 2048 Community Working Group (CWG) agreement the flare Root Cause Analysis reports are required to be provided to the CWG. The RCAs are provided to the CWG when the report i s transmitted to BAAQMD.

1 st 

## Qtr 2 004 Operational Improvement

– Monitoring :

Flare System Diagnostic Tools

– Developed tools for better flare flow & monitoring capability.

 PI Process Book Flare System Overviews

– tool was developed to provide Supervision & Operations Engineers an overview of the flare system operation. This is useful when load to the flare increases or following a flaring event to better understa nd triggers for flaring.

 Flare Flow Spreadsheet

– spreadsheet was developed to be used by Shift Superintendent to monitor flow to the flare in relation to Federal and BAAQMD reporting requirements. The spreadsheet is referenced in Refinery P&P 6

- 7 “Flare Monitoring & Reporting”
The use of this tool helps reduce flaring by letting parties who are responsible for flare reporting an d incident investigation management know the magnitude and characteristics of a particular flaring event. It also provides a good snapshot as to when there is a change in the baseline load to the compressor which, if continuing to rise can result in flari ng. In some cases, where the cause is not immediately known this can help give insight to the cause which can result in quicker flare minimization.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 12 Changes Made to Reduce Flare Emissions ( May 30, 2003

– June 30, 2010 )

Year Installed

or Implemented Equipment Item Added, Process Changed or Procedure Implemented

3 rd 

## Qtr 2005

3 rd 

## Qtr 2009 (update) Operational Improvement

– Drum Cooling

Flaring can occur during Unit 200 Coker drum cooling due to brief peak loading to the flare gas recovery compressor. Changes have been made which reduced the instances of this flaring.

Communication Enhancements

– Increased inter and intra departmental communication during regular p eriods of high flare gas recovery compressor loading association with Unit 200 Coker drum cooling. This reduces flaring in cases where activities in which discretionary gasses (i.e. small volumes of nitrogen, hydrogen, etc.) are being sent to blowdown can be coordinated. For example, if one unit needs to purge equipment with small amounts of nitrogen which can be absorbed by flare gas recovery this activity could potentially be delayed during Coker drum cooling. Rather then two activities which add incre ased volume to the flare gas recovery compressor occurring at one time they can be staggered to prevent exceeding the capacity of the flare gas recovery compressor

. Since the Coker drum cooling process has a routine schedule, this communication occurs whe n the unit that needs to send discretionary gasses to blowdown contacts the Operators at Unit 200 in order to coordinate their activities. This communicati on is important since Operators from various units are currently housed in separate control rooms. A s referenced in the Central Control Room item listed under Planned Reductions, this communication will more easily occur when Operators are housed in a central location.
Equipment installation

– the addition of the new, redundant flare gas recovery compr essor G

- 540 A/B/C increases the capacity of the flare gas recovery system during most operating periods. This has further prevent ed and minimize d the number and volume of small flaring events that occur during drum cools.

1 sr 

## 2007

2 nd 

## Qtr 2009 (update) Improved Incident Investigation

– Smaller Flare Activity (<500,000 SCFD and/or <500 lbs SO2)

Personnel from the Environmental Department and Operations meet on a periodic basis to review all flaring activity to determi ne potential cause of all flaring even ts. These regular meetings reinforce that identifying and minimizing all flaring events is important. For example, the PI Process Book Flare System Overview tool that was listed in this section under Operational Improvement

- Monitoring has been improved over time in order to more quickly identify the source of smaller flaring events in different flare headers systems. See Attachment H for analysis of smaller flare events. A detailed analysis w as initially performed as part of the 2008 FMP u pdate. The results showed small events account for on average 5

- 10 % total annual flow. The new Flare Gas Recovery Compressor G

- 540 A/B/C has mitigate d some of the smaller events.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 13 Changes Made to Reduce Flare Emissions ( May 30, 2003

– June 30, 2010 )

Year Installed

or Implemented Equipment Item Added, Process Changed or Procedure Implemented

3 rd 

## Qtr 2010 Unicracker Plant 4 Hydrogen Plant Shutdown Procedure

– a ne w procedure for shutting down the Plant 4 Hydrogen Plant was

implemented in order to reduce flaring. The revised procedure was successful an d no flaring occurred during a recent shutdown. Based on past experience it was estimated this reduced 4

- 6 hours o f flaring of gasses

. This procedure was successfully implemented in 2011 as well. This Hydrogen Plant is now shutdown.

3 rd 

## Qtr 2010 Installation of Backup Lube Mist System for the G

- 540 Flare Gas Compressors

– a backup lube oil mist system was installed

for the new Flare Gas Recovery Compressors. The purpose of this system is to ensure that continuous lubrication is available to each of the compressors. If an oil mist system alarm sounds or failure occurs the backup compressor can be utilized without compressor operation loss.

3 rd 

## Qtr 2010 Operational Improvement

– Monitoring :

Fuel System Diagnostic Tools

– Developed tools for better fuel flow monitoring & optimization capability.

 PI Process Book Fuel Flow System Overviews

– tool was developed to provide Supervision & Operations En gineers an overview of the fuel system operation with key parameters displayed

. The key parameters shown include fuel gas produced, natural gas imported, sulfur levels in fuel, f uel consumer demand.

 PI Process Book Fuel Imbalance Optimization Tool

– a n online tool was developed which provide recommended steps for mitigating fuel gas imbalance. The tool lists the steps and limitations for each step which need to be optimized. ”
The use of this tool helps to reduce flaring caused due to fuel gas imbalance by providing tools & a multi unit overview of key parameters. Users of the tool can plot trends of key parameters.

1 st 

## Qtr 2011 & On

- Going Unit 110 Hydrogen Plant Startups and Shutdowns

– changes have been made in how Unit 110 startups and shutdowns, when

conditions warrant, to minimize flaring. For example, a shutdown takes place and human entry is not required, the unit may b e purged with plant Nitrogen rather than hot, pumped Nitrogen. This allows for the Nitrogen to slowly be swept into the blowdown system, allowing for the Fuel Gas Recovery Compressor to remain operating. For some shutdowns the amount of flaring has been eliminated vs. a previous average period of of 5

- 1/2 hours. Unit startups have also been reduced from a period of approximately 2

- 1/2 hours in comparison to the previous duration of 5 hours. Throughout 2011 and 2012 efforts to minimize Unit 110 related flaring has con tinued by examining steps related to startup and shutdown activities.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 14 Changes Made to Reduce Flare Emissions ( May 30, 2003

– June 30, 2010 )

Year Installed

or Implemented Equipment Item Added, Process Changed or Procedure Implemented

4 th 

## Quarter 2012 Flare System Rundown List (R

- 065)

– A checklist was developed for looking for possible sources (lines and monitoring tags) at

operating units which may be contributing high base load to the flare compressors and/or directly to the flare. This checklist is to be used by Shift Superintendents, Head Operators, and Unit Supervisors to pinpoint and locate higher than normal flows.

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BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 15 

# 3.2 Planned Reductions (401.3)

The table below summarizes the actions currently planned to effect further reductions in refinery flaring.

Planned Actions for Reducing Flaring
Planned Actions for Reducing Flaring

Planned Date of Installation/ Implementation Equipment Item to be Added, Process to be Changed or Procedure to be Implemented

Procedure:

Equipment

Phased 2006

– 201 3

 2006

– MP30 (complete)

 200 9

– Sulfur Plant (complete)

 2009

– UK (complete)

 2011

– U200/ U267/U250 (complete)

 201 4

- U110 & SPP

 201 5

– U100 & Bulk


## (completion dates listed) 

## Construction & Operation of Central Control Room (CCR) The CCR has been built and is currently contains the controls for the MP30 Complex, the Sulfur Plant, the Unicracker Complex, Unit 200 and Units 215/233/250/267. The CCR now houses all of the process unit Boardmen. The Boardmen for the utility and bulk movement units will be moved into the CCR by 2015. The Boardmen are the Operators that oversee the unit operation and provide direction to Outside Operators. The Boardmen were housed in Control Ro oms at their individual units The CCR brings all the Boardmen together in one large control room. There is an inherent value in having the Boardmen housed in one Control Room that will minimize flaring. Improved communication will occur and better awareness of each unit’s impact upon another unit’s operation will occur. In addition, optimization by Operations Supervision will be simplified when the unit controls are housed in one Control Room. An example of this benefit is that if one unit is nitrogen purging a vessel which will add loading to the U200 G

- 503 Flare Gas Recovery Compressor the Boardman can immediately talk to the Unit 200 Boardman about whether or not additional loading can be handled. As the purging is taking place the two B oardmen can work closely together to monitor the impact of purging and provide immediate feedback as to the impact of the activity on the Compressor. Adjustments can be made much more quickly to manage the activity. This enhanced coordination will reduce in flaring.

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BAAQMD Plant 16 October 2013, Rev. 9



## 3

- 16 Planned Actions for Reducing Flaring

Planned Date of Installation/ Implementation Equipment Item to be Added, Process to be Changed or Procedure to be Implemented

Phased 2006

– 201 3

 2006

– MP30 (Complete)

 2009

– Sulfur Plant (complete)

 2009

– UK (complete)

 2011

– U200/ U267/U250 (complete)

 201 4

– U110 & SPP

 201 5

– U100 & Bulk


## (completion dates listed) 

## Controls Modernization

– a series of controls modernization projects are underway and scheduled to be completed in phases. One major phase, MP

- 30 Controls Modernization, is c omplete . Listed below are the benefits of the modernization projects in respect to flare minimization.

 Provides for enhanced diagnostic tools (i.e. graphics of unit operation are much more visible and easy to follow) in units where Distributed Control Systems (DCS) are not currently in place (MP30 & Sulfur Recovery Units ).

 Reduction of control system instrumentation fa ilures due to upgrade from old, pneumatic technology. This will result in much better reliability of the controls.

 Increases unit stability and minimizes unit upsets.

 Improves operator performance by incorporating Abnormal Situation Management practice s such as alarm management and graphic guidelines. Alarm management is a philosophy which prioritizes alarms and minimizes the amount of alarms an operator must respond to in an abnormal situation. This prevents an operator from being overloaded with ala rms and helps the operator focus on the immediate issues which must be remedied.

 Use of human factors in information processing in order to communicate information in a proven, consistent, simplified, meaningful way. Early event detection to reduce abnormal situations which might cause an upset.
Installation of state of the art Safety Instrumented Systems (SIS) that will minimize spurious trips. Overall, the Controls Modernization will reduce flaring by minimizing u psets that can occur with the current controls in place. Improving the way that operators interface with controls allows them to prioritize their response to abnormal situations. This can result in more rapidly mitigating an unusual situation and minimiz ing overall impacts. One example would be by upgrading field tags (which are monitoring devices for operating parameters such as pressure or temperature, currently only visible in the field) to a tag which can be monitored in the control room. For exampl e , if an equipment shutdown occurs and the parameter which shut the equipment down is a field tag

, the modernized control system will more rapidly pinpoint the cause of the shutdown . The upgraded field tag would now be able to be seen rapidly by the Board Operator which will assist in restarting the piece of equipment more rapidly. This will reduce flaring.

Processes:

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## 3

- 17 Planned Actions for Reducing Flaring

Planned Date of Installation/ Implementation Equipment Item to be Added, Process to be Changed or Procedure to be Implemented

On

- going Improved Incident Analysis Investigation

– Continue to complete required 12

- 12 Root Cause analysis and analysis

triggered by internal incident investigation drivers. Investigations and corrective actions identified will continue to addr ess issues that may result in flaring if not otherwise addr essed. The root cause analysis requires that the facility find the actual cause of flaring, down to a single part that may have failed in some instances. The 12

- 12 analysis also requires the facility to identify changes that can be made to prevent flarin g and list those in the root cause analysis submittal to BAAQMD. This results in the facility taking action to prevent recurrence of flaring events. For example, some of the recent root cause analysis have identified equipment upgrades that should be mad e, additional training to be conducted, equipment repairs, etc.

Permit Application Submitted 12/2011
Target Completion 4 th 

## Qtr 201 3 Fuel Gas Combustion Sulfur Dioxide Emissions

– A permit application was submitted to BAAQMD to obtain new Sulfur Dioxide (SO2) limits for the Steam Power Plant (SPP) via permit modification . This would allow greater percentage of refinery fuel gas to natural gas to be fired in the turbines. By revising the SPP emission limits it is possible that a large portion of flaring during periods of fuel gas imbalance could be minimized while reducing overall combustion emissions. Historically fuel gas imbalance occurred during major Unicracker turnarounds when 30% of fired duty sources are shutdown. Discussion s were previously held with BAAQMD permit engineers in 2007 to review the benefits and potential permitting m echanisms for repermitting SPP. Numerous discussions and responses have been provided to BAAQMD in respect to the permit application and permit re visions BAAQMD has been provide d the necessary supporting information and must approve and finalize the permit in order for the facility to implement this item.

.
Target 4 th 

## Qtr 2012 Flare Activity Review

– Soon after a reportable flaring event occurs an overview of the event is communicated between site management.

Maintenance:

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## 3

- 18 Planned Actions for Reducing Flaring

Planned Date of Installation/ Implementation Equipment Item to be Added, Process to be Changed or Procedure to be Implemented

On

- going G

- 503 /G

- 540 Flare Gas Recovery Compressor s

- this practice began more than 5 years ago and continues to date.

Approximately every 18 months, in association with a major unit turnaround, the G

- 503 Flare Gas Recovery Compressor is taken out of service for a major overhaul. The purpose is to maintai n critical equipment associated with the compressor in order to prevent unplanned failures. This practice minimizes overall downtime for the compressor. The work is scheduled with a major turnaround since gasses produced at the facility are at reduced ra tes and many fuel gas consumers are out of service. Without this maintenance it is more likely that the compressor would experience unplanned failures during periods when high gas volumes are being produced. The unplanned failure repair is of longer dura tion because the personnel and equipment must be assembled without advanced planning. In many cases, diagnosis must be performed to determine the failure and this can take considerable time. Whereas, planned maintenance prevents many of these types of fa ilures from occurring. As with regular maintenance on a vehicle, this maintenance performs a similar
purpose.

Now that the new Liquid Ring Flare Gas Recovery Compressor has been installed all flare gas recovery compressors will be maintained on a routin e basis yet it will be done when the spare compressor(s) are in operation which will further reduce overall flare emissions.

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BAAQMD Plant 16 October 2013, Rev. 9



## 4

- 1 

# 4.0 Prevention Measures (401.4)

4.1 “Major” Maintenance Activities (401.4.1)

This section discusses refinery maintenance and turnaround activities, outlines measures to minimize flaring during both preplanned and unplanned maintenance activities. A description of flaring that occurs during major maintenance activities is included in this section and in the section titled “Wh en Flaring is Likely to Occur” in accordance to 401.4.1. As required by 401.4.1 a review of flaring associated with major maintenance has been conducted and is referenced below. The measures taken to prevent flaring during portions of major maintenance activities are included in the section titled “Measures to Minimize Flaring During Preplanned Maintenance”.



# 4.1.1 Refinery Maintenance and Turnaround Activities
Maintenance activities often result in a higher than normal flow of material to the flare gas recovery system. In order to maintain process equipment, the first step is to clear the process equipment and associated piping of hydrocarbons, before the system is opened to the atmosphere, for both safety and environmental reasons, including compliance with BAAQMD Regulation 8 Rule 10, (Process Vessel Depressurization). How this is accomplished depends on the physical properties of the hydrocarbons to be removed (vapor pressure, viscosity) and on the process details of the equipment that is to be maintained.

The first step is to recover as much of the hydrocarbon as is possible by transferring it to a process unit that is not in the part of the refinery that is being prepared for maintenance. For example, liquid hydrocarbons can be pumped to tankage or another process system; gases under pressure may be depressurized to another process unit. Heavy hydrocarbons that are viscous at ambient temperatures are often displaced from the equipment to be maintained using lighter hydrocarbons, e.g. diesel type material. This material can then be pumped from the equipment.

Although depressurization and pump-out can be used to remove the bulk of the hydrocarbon from the equipment, they leave some residual material. Following pump-out or depressurization to other process equipment, the next step in decommissioning typically requires a low-pressure location that has the ability to accept a wide range of hydrocarbon materials in order to avoid putting these materials to the atmosphere. The flare gas header is the only location within the refinery that meets these criteria. Equipment items containing materials that are gases at ambient temperature and pressure are often vented to the flare gas recovery system so that the hydrocarbon can be recovered as fuel gas. To free the equipment of hydrocarbons following depressurization, they can be purged using an inert gas such as nitrogen. Alternatively nitrogen can be added to the equipment increasing the internal pressure. The resulting mixture of nitrogen and hydrocarbon can then be released to the flare header, reducing the pressure in the equipment. Steam can be substituted for nitrogen in some cases, but not for processes that need to be kept dry in order to avoid corrosion or catalyst damage, or for some other reason.

For equipment containing liquids, often steam or nitrogen are used to “blow” the liquid to the flare header. The liquid hydrocarbon and condensed steam are separated from the vapor phase and returned to the refinery’s recovered oil system and to wastewater treatment either at the unit knockout drum or at the flare knockout drum. Nitrogen with hydrocarbon vapor continues on to flare gas recovery. Once the bulk of the liquid hydrocarbon has been displaced, the flow of steam or nitrogen is continued to remove any residual hydrocarbon by vaporization. Steam can be more effective for heavier materials as it increases their volatility by increasing temperature. Proprietary solvents such

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## 4

- 2 as “Zyme-flow” are sometimes used in aqueous solution for removal of residual hydrocarbons. When aqueous solvents are used, they are typically circulated in the equipment and then treated.
Although these procedures eliminate hydrocarbon emissions related to equipment opening, they require a high volumetric, high velocity, steam or nitrogen flowrate in order to be effective. This high flowrate of inert gas can create several sets of circumstances where flare gas recovery is not feasible. These problems relate either to the change in fuel gas composition (increased molecular weight or temperature) or to the increase in volumetric flowrate.
In addition to an increase in flare gas average molecular weight from higher than normal nitrogen flowrate, there is also the potential for much lower than average molecular weight gas from increased flow of hydrogen. There are many process and reactor systems within a refinery that contain gases with a high hydrogen content. When this equipment is decommissioned by depressurization to the flare gas header, there can be a sharp decrease in the flare gas average molecular weight.

Effect of Flare Gas on Downstream Equipment
Gas composition affects the equipment in the flare gas recovery system. Specifically:

 High nitrogen content can impact heaters, boilers and the flare gas compressor.

 Hydrogen and other low molecular weight gases impact flare gas compressor performance.

 Steam impacts knock out drums and compressors.
High flows of nitrogen from equipment purging leads to a much higher than normal inert content in the recovered flare gas, greatly reducing its fuel value (measured as Btu/scf) and increasing its molecular weight. Reciprocating compressor (G -503) increase the pressure of a constant inlet volumetric flowrate of gas. For a given volume of gas, an increase in molecular weight creates an increase in its mass. This increases the work that the compressor has to do to compress the gas, overloading and potentially damaging the machine.

For a reciprocating compressor, the compression ratio (ratio of outlet pressure to inlet pressure) is high enough that more than one stage of compression is needed. The temperature of the gas increases as it is compressed. The gas is cooled between stages in order to control the temperature increase. Operation of a reciprocating compressor with a feed stream that has a molecular weight outside of the range for which it was designed (e.g. high hydrogen content) can lead to a temperature increase exceeding the design limitations of the machine. Flare Ga s Compressor (G

- 503) is shutdown in order to protect it from failure that could be caused by a decrease in molecular weight.
The Liquid Ring compressors are expected to have a wider range of operating conditions. The compressors and associated control system will have enhanced monitoring in comparison with the existing Reciprocating Compressor. There will still be limitations on the type of gases that should be recovered and utilized in the fuel gas system (i.e. high volumes of hydrogen potentially impacting Btu values).
Additionally, if low Btu flare gas is transferred to the fuel gas header, the lower fuel value can have the effect of reducing combustion efficiency, as the combustion device burners are designed to operate with fuels that have higher heat content per cubic foot. In extreme cases, the heating value of the gas can be reduced by dilution with nitrogen to the point of extinguishing the burner flame. This creates the potential for unburned fuel to accumulate in the heater or boiler, potentially leading to an explosion when it is re-ignited. NFPA 85 – Boiler and Combustion Systems Hazards Code and NFPA 86 Standards for Ovens and Furnaces warn against this possibility.

A major advantage of using steam to clear hydrocarbons from equipment is its elevated temperature; however this can be a disadvantage with respect to flare gas recovery. When the distance the gas must travel to reach the flare gas compressor is large, (the flare header is long), the gas will cool, and

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## 4

- 3 much of the steam will condense and be removed as water at the knock-out drum. However; with a shorter flare line or a long-duration steam out event, the temperature of the flare gas at the flare gas compressor can be elevated significantly. If the temperature of the flare gas stream at the inlet to the flare gas compressor exceeds machine limits, the gas must be diverted away from the compressor inlet in order to avoid mechanical damage.
Summary
Each of the situations described above potentially leads to the need to divert gas produced during refinery maintenance away from the flare gas recovery compressor and to a flare. This is a necessary result of maintenance procedures which have been adopted to minimize the release of hydrocarbons to the atmosphere during equipment opening. The need to divert gas is driven by the quantity and composition of the gases produced during equipment shutdown and startup.
Major maintenance activities can result in flaring, as discussed above. A review of maintenancerelated flaring from 2000 to 2006 at the Phillips 66 San Francisco refinery in Rodeo has been completed. See Attachment D for list of flaring due to planned and unplanned unit shutdowns or startups during that time frame. Attachment D has been marked Business Confidential . Due to the requirement to install flowmeters and report flare emissions to BAAQMD the data from September 2003 to date is the most accurate for this review. Subsequent flaring taking place during equipment startups and shutdowns are being examined as part of the Turnaround Planning Flare Minimization Process and causal analysis being conducted.
Based on the review there were means of further reducing and/or eliminating flaring that were identified. Included below is a summary of the measures identified and rationale for the acceptance or rejection of the concept:

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## 4

- 4 

# Major Maintenance
Prevention Measure Evaluation

Th is is a list of prevention measures that were identified based on the 5-year look back of Major Maintenance activities. Attachment D (Confidential) contains a list of the Major Maintenance events. Attachment H is a summary of all flaring events and is grouped by category. Based on the 5-year look back the following types of flaring were identified for elimination:

 Flaring associated with Hydrogen Unit Startups/Shutdowns (H2 SU/SD)

 Flaring due to G-503 Flare Gas Recovery Compressor Planned Maintenance (G -503 PM)

 General Flaring Associated with Major Maintenance (.e.g. nitrogen purging, steaming, etc.) (General)

Major Maintenance

– Prevention Measure Evaluation

Measure Description Schedule for

Implementation Rationale to Support Schedule Type of Flaring that woul d be Reduced or Eliminated Rationale for

Rejecting Measure Section Reference

(for more details)



## Addition of Unit 110 Hydrogen Vent  Dec. 2006

 I nstall ation of a vent which will allow a small stream of purified hydrogen to be vented. H2 SU/SD n/a 

## 3.2

Odor Abatement/Flare Gas Recovery System Optimization  October 2008

– Construction Start

 August 2009 (completed) A set of 3 Liquid Ring Compressors were installed in order to provide redundant and extra capacity for the Flare Gas Recovery compressor

. This will eliminate some flaring events that have historically occurred by having additional flare gas recovery
service. A separate odor abatement compressor was installed which will provide further reliability for the odor abatement system. G

- 503 SU/SD

G

- 503 Brief Peak Loading Completed 

## 3.2

Turnaround (T/A) Planning Procedure 4 th 

## Qtr 2006 Being coordinated with submittal of Flare
Minimization Plan. H2 SU/SD

G

- 503 PM

General n/a 

## 4.1.3

Shutdown & Startup Activity Extension 4 th 

## Qtr 2006 This will be included as part of the T/A Planning
Procedure. In some cases flaring may be General To be included as part of T/A Planning Procedure 

## 4.1.3

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## 4

- 5 Major Maintenance

– Prevention Measure Evaluation

Measure Description Schedule for

Implementation Rationale to Support Schedule Type of Flaring that woul d be Reduced or Eliminated Rationale for

Rejecting Measure Section Reference

(for more details)



## eliminated or minimized by extending the period that a unit is going through shutdown or startup. An example would be to nitrogen (N 2 

## ) purge equipment at a lower ra te so the G

- 503 Flare Gas Recovery Compressor c an handle the excess N 2



## . More importantly , the safest operating conditions for a unit are when it is out of service or when it is running at normal conditions. The transition period, which occurs during star tup and shutdown, require s special attention and procedures. Equipment placed under these conditions experienc e temperature and pressure changes
whic h can result in hydrocarbon leaks . Due to
these factors it is necessary to minimize the duration of tran sition periods. process.

This will not be utilized in
each case due to transitional activity

concerns.

Rate Reduction / Unit Shutdowns 4 th 

## Qtr 2006 This will be included as part of the T/A Planning Procedure process. In some cases flaring may be eliminated or minimized through reducing rates or shutting down units. The implications of shutting down a unit must be examined for each case. For

exam ple, shutting down additional units may result in more fuel gas imbalance (i.e. production of more gas then can be consumed). The refinery units are interrelated so shutting down one or two units will result in impacts to other units. In some

cases a num ber of units must be shutdown in association with a particular unit. In order to properly shutdown units they must be General To be included as part of T/A Planning Procedure

process.

It is not beneficial to use this for all sit uations as described in the previous
column. 

## 4.1.3

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## 4

- 6 Major Maintenance

– Prevention Measure Evaluation

Measure Description Schedule for

Implementation Rationale to Support Schedule Type of Flaring that woul d be Reduced or Eliminated Rationale for

Rejecting Measure Section Reference

(for more details)



## depressured and purged. This typically results in flaring. So, the shutdown of associated units doesn’t reduce flaring in all cases and must be evaluated for the overall benefit on a case by case
basis.

Rate reduction is typically only of potential value if refinery is out of fuel gas balance. See Section 4.1.2 for the steps taken to mitigate fuel gas imbalances, including rate reducti on. Some units may be an overall fuel consumer so reducing rate may not be helpful. The benefits need to be examined on a case by case basis.

Implementation of
Prevention Measures Identified during Causal Analysis Reporting 3 rd 

## Qtr 2005 Prevention Measures are identified during the required BAAQMD flare event Causal Analysis reporting . These measures are then implemented to reduce flaring.

Note: General programmatic prevention measures identified will be listed in this section during Annual updates. Equipment specific prevention measures hav e been added to
Attachment H

. Various n/a 

## 3.1

Identification of Cause of Small (<500,000 SCFD or <500 lb SO2) Flaring Activity 1 st 

## Qtr 2007 Conduct regular meetings with Operation personnel who are responsible for the flare operation to identify causes of all flare activities. Various n/a 

## 3.1

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## 4

- 7 Major Maintenance

– Prevention Measure Evaluation

Measure Description Schedule for

Implementation Rationale to Support Schedule Type of Flaring that woul d be Reduced or Eliminated Rationale for

Rejecting Measure Section Reference

(for more details)



## Storage, Treatment, Recovery Scenario 1

– Addition of New 1.5 MMSCF/D Compressor n/a n/a G

- 503 PM (portion)

General Determined not to be cost

effective. 

## 4.2.2.1

Storage, Treatment, Recovery Scenario 2

– Addition of New 6.0 MMSCF/D Compressor n/a n/a G

- 503 PM

General Determined not to be cost

effective . However, a set of three new Flare Gas Recovery Compressor s

are being installed in conjunction with the Clean Fuels Expansion Project. 

## 4.2.2.1

Storage, Treatment, Recovery Scenario 3 & 4

– Addition of New High Pressure Storage Sphere, Compressor, & Amine
Treater n/a n/a H2 SU/SD

G

- 503 PM

General Determined not to be cost

effective. Technological, operability, and safety feasibility not yet determined. It is likely that upon further st udy cost effectiveness will be further diminished. Operability and feasibility of safe operation of such a system may also pose a challenge. 

## 4.2.2.1

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## 4

- 8 Section 4.1.2 contains a list of measures that are currently in practice for reducing flaring.
From this review it is clear that one of the greatest potentials for achieving further cost-effective reductions in flaring lie in maintenance planning with flare minimization as a goal coupled with the existing goals of safety and minimizing production impacts due to extended downtimes. The essential component of any plan that satisfies maintenance needs while minimizing flaring is that it must mitigate or eliminate the conditions described in the sections above that make recovery of flare gas impossible. In practical terms this means taking a series of actions specific to the unit being decommissioned to limit the rate at which flare gas is generated and maintain its temperature and composition within a range acceptable for transfer via a flare gas compressor and for use in the fuel gas system. Concepts for accomplishing this are discussed in the section following.



# 4.1.2 Measures to Minimize Flaring During Preplanned Maintenance
In accordance with 401.4.1 in regards to feasible prevention measures that can be used to minimize future flaring: (including that related to scheduled process unit turnarounds and immediate near-term shutdowns) are listed below. Numerous prevention measures are utilized to prevent flaring from occurring during portions of major maintenance events. The information is organized by process unit and by topic. There are also some general measures listed that are used at most units, when applicable. Refer to Attachment E for list of unit names and numbers. It is noted that although prevention measures are routinely employed, as explained in the previous section, all flaring cannot be eliminated due to gas quality and quantity issues associated with major maintenance activities.
Hydroprocessing (U228, U229, U230, U231, U240-2, U244, U248, U250)

Hydroprocessing units are depressurized to hydrogen recovery, or other lower pressure locations , and only after this are they depressurized to flare gas recovery, reducing the load on the flare gas recovery system. This prevents flaring by minimizing load on the flare gas recovery system and decreases the period of time in which flaring occurs during venting activities.

Following depressurization, the remaining hydrocarbon is removed by increasing the pressure in the equipment with nitrogen and then depressurizing it to flare gas recovery multiple times. Doing this quickly helps with mixing, which improves removal of hydrocarbon from the vessel so that fewer cycles are needed. This minimizes the volume of low quality gasses that are sent to the flare.

Depressurization of the unit to the flare gas recovery system is staged in order to minimize exceeding the capacity or quality parameters of the system in order to maximize the time in which the flare gas recovery compressor is on-line. The longer the flare gas recovery compressor is online the less flaring that occurs.

G ases are recirculated using the hydrogen recycle compressors as the reactors cool. When the equipment is cooled and at low pressure, nitrogen pressurization and release steps are used to clear hydrocarbons. Hydrogen-containing streams are directed to the hydrogen plant. Use of hydrogen recycle for cooling and cleaning minimizes the need for nitrogen which, when utilized, typically results in flaring.

U250 - A high pressure hydrotreater design is used to avoid flow to the flare by containing the process during loss of utilities. Without this design, additional volume of materials would be sent to the flare during loss of utilities. See Section 3.1 for more details on elements of this design.

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## 4

- 9

Reformer (U231, U244)

The timing of the steps involved in the regeneration cycle are controlled and the venting / depressuring rate limited to be within the capacity of the compressors. This minimizes the total vent stream that must be sent to the flare.

Delayed Coker (U200)

The delayed coker drum cooling cycle time is coordinated with other activities to prevent exceeding the Flare Gas Recovery Compressor capacity.

Fractionation Units (Various units, throughout refinery)

Vents from depressurization of fractionation units are recovered using the flare gas compressor system rather than being routed to the flare, when capacity is available or gas quality allows. This minimizes flaring by reducing the volume of gasses that must be sent to the flare.

Compressor (U200 Flare & Blowdown System)
Compressor Maintenance In some instances, the flare gas recovery compressor (G

- 503) is placed in wet gas recovery compressor service (G -501) if the wet gas compressor is expected to be offline. This minimizes the total amount of gas flared

. A greater volume of gas can be recovered by placing G-503 directly in Wet Gas service rather than directing the Wet Gas into the blowdown system. Recovering higher rates of gas reduces the volume recovered.

Flare gas compressors are maintained during planned unit shutdowns, to improve reliability during periods of normal operation. A planned shutdown provides an opportunity to do maintenance while flare system load is lower.

In the future, when the redundant new Liquid Ring Flare Gas Recovery Compressors are operational planned maintenance scheduling will be optimized and staggered to minimize and/or prevent flare gas recovery outages for compressor maintenance.

Regular preventative maintenance of flare gas compressors, as described further in Section 3.2, is used to improve their reliability.

Maintenance is also conducted on compressors based on critical monitoring (i.e. vibration, temperature, load) results.

Flare System Monitoring

Fl are Gas Recovery Compressor load is monitored to identify & mitigate higher than normal baseline load. High loads are mitigated by identifying the source and making reductions. For example, if a PRV is venting to blowdown then the responsible unit will be identified and directed to make adjustments to prevent the PRV from venting.
The flare gas recovery compressor is monitored when maintenance is being conducted at other units that will cause the compressor to be taken off-line. The purpose is to minimize the amount of compressor downtime in order to protect the compressor and minimize the total time the compressor is shutdown and reduce overall flaring.

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## 4

- 10

Plant personnel who oversee flare gas recovery systems have been instilled with an improved understanding. The operators monitor flare gas compressor load to check for high load or load changes, record instances of flaring and potential causes, take action to minimize flaring, and notify Shift Superintendents when flaring occurs. This results in conscious management of the flare system to minimize flaring.
Flow and/or temperature measurement as a means of indicating flow in each flare header is used to identify and eliminate sources of flow to the flare gas header. Indication of flow during periods when flow is not expected is a direct indication of flaring

. As described above, operators respond to flaring events by attempting to track the source and working with the Shift Superintendent to take action to make reductions or eliminate flaring.
The monitoring parameters available for the Liquid Ring Compressors will be more robust and provide more on-line indication of changes in flare gas quality. This enhanced monitoring will likely assist in the optimization of compressor on-line performance.

On -line diagnostic tools are utilized to monitor flows to the flare in order to minimize flaring duration. See Section 3.1 “Operational Improvement – Monitoring” for more details on how these tools reduce flaring.
When higher than normal flare gas recovery compressor loads are detected announcements are made throughout the refinery in order to proactively identify and address the source of
gases. See Section 3.1 Emergency Operating Procedure EOP-1 “Guidelines for Standard Public Address System Announcements” for more details.
Fuel Gas Scrubbing
Gases collected by the flare gas compressor are scrubbed whenever possible. This includes periods of fuel gas imbalance and periods when the compressor capacity is exceeded but the compressor is still operational. This results in reduced sulfur dioxide emissions from the flare.

Sulfur Recovery Units (U235, 236, & 238)
The refinery has three sulfur recovery units operating in parallel. During periods of maintenance the load is shifted from one unit to the others. Thus, no flaring is necessary during unit startups or shutdowns. Additionally, sulfur load can readily be reduced by decreasing sour water stripping. The Refinery has not historically experienced acid gas flaring during sulfur plant startups & shutdowns or upsets.

General Measures (used at various units, as applicable)

Liquid Vessel Cleanup

Chemical cleaning is used to so that cleanup is faster, minimizing the time needed for steam out. Chemical cleaning works similar to using dish soap on greasy dishes in that cleaning time and rinse water is minimized. Thus, in practice overall time in which steaming must occur is minimized, thus minimizing flaring. Chemical cleaning is primarily used in units where there is a high volume of residual oil and solids in equipment and piping. Chemical cleaning must be balanced with wastewater treatment plant capabilities.

Depressurization

Separate flare gas headers are in place at the Unicracker Complex for the Reactor section and Hydrogen Plant so that some gases produced during maintenance, startup, and

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shutdown can be directly routed to the flare. This minimizes the volume of gases sent to the flare during maintenance activities since it provides a separate system from the refinery blowdown system. This allows a portion of the refinery gasses to be recovered while only those from the Unicracker are sent to the flare.

Pressure Relief

Routine maintenance of PRDs, consistent with API 510, is used to minimize “routine” flow to the flare gas header. The purpose of the maintenance is to ensure the PRDs are operating properly at the appropriate set points and not relieving prior to the intended set point. Proper operation of PRDs provides a safe operation

, reduc es the base load and allows the system to better able to handle flow peaks during maintenance or other periods where there is additional flow in the blowdown system.

Source Reduction

If there are indications of increased base load to the flare gas compressor efforts are taken to identify and mitigate or minimize the source of gasses. This is done by identifying the flare header affected by use of monitoring parameters, as available, such as flare header flow meters, pressure and temperature indicators.

Shutdown/Startup Planning & Scheduling

A specific plan will be developed to minimize flaring during each turnaround, as each is unique. Specific actions depend on which parts of the unit are being brought down and which other units are down at the same time. Note: Historically this has taken place for major turnarounds, this will be expanded to minor turnarounds as well.
Specific “flare planning” has been conducted in respect to major turnarounds.
Plans have been prepared to insure there will be a viable fuel balance during each time period during the shutdown.
The length of the shutdown has been extended in some cases to allow equipment to be purged at lower rates that can be handled by the flare gas recovery system. Extension of shutdown length will be considered as part of the turnaround planning procedure referenced in Section 2. There are limitations to this activity. The safest operating condition for a unit is either when it is out of service or when it is running at normal conditions. The transition period, which occurs during startup and shutdown, requires special attention and procedures. Equipment placed under these conditions experience temperature and pressure changes during the transition period which can result in hydrocarbon loss. Due to these factors it is necessary to minimize the duration of transition periods.

Rate Reductions and Unit Shutdowns at interrelated units occur to balance inventory. This will be included as part of the T/A Planning Procedure process referenced in Section 2. The implications of shutting down a unit must be examined for each case. For example, shutting down additional units may result in more fuel gas imbalance (i.e. production of more gas then can be consumed). The refinery units are interrelated so shutting down one or two units will result in impacts to other units. In some cases a number of units must be shutdown in association with a particular unit. In order to properly shutdown units they must be depressured and purged. This typically results in flaring. So, the shutdown of associated units doesn’t reduce flaring in all cases and must be evaluated for the overall benefit on a case by case basis.

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Rate reduction is typically only of potential value if refinery is out of fuel gas balance. Again, the big picture needs to be examined. Some units may be an overall fuel consumer so reducing rate may not be helpful. The benefits need to be examined on a case by case basis.
Load shed planning is used to keep the fuel gas system in balance as units come up/down. Following the turnaround, any flaring that did occur is reviewed and a list of lessons learned is developed in order to minimize flaring during future turnaround events. Note: This is a minimization effort that is being instituted in a more rigorous manner as part of this FMP. This consistently applied review will help establish successful flare minimization practices that can be utilized in the future.
Shutdown activities are staged to keep the rate to the flare gas compressor low. This will be considered on a case by case basis as part of the turnaround planning procedure referenced in Section 2 which addresses flare minimization.

Turnarounds are scheduled so as to bring some units down every year, so that not all units are down at any one time

.
Turnarounds are scheduled to minimize downtime associated with the unit and to provide a window for conducting preventative maintenance in order to promote equipment reliability. Conducting turnarounds on a regular basis prevents unplanned shutdowns that can lead to long periods of flaring if the necessary equipment is not available to quickly remedy a failure.

The duration between turnarounds is being extended over time as technology improves in order to minimize production impacts. This also results in minimizing flaring over long periods of time (i.e. 5 – 10 year windows). The reason this reduces flaring is that the number of turnarounds in a 10 year period is reduced if the duration between turnarounds is extended. Eliminating one or two turnarounds in a 10 year period will eliminate the flaring associated with the startup and shutdown activities. The duration between turnarounds is being extended due to improvements such as longer catalyst life, better unit monitoring, better metallurgy, enhanced inspection technology and procedures.

Shutdown and Startup Execution

Equipment is purged slowly to avoid overloading flare gas recovery system capacity. The minimum purge rate that can be achieved is limited by the need to prepare the equipment for maintenanc e. This will be evaluated as part of the turnaround planning procedure referenced in Section 2.
Cleanup activities are cascaded so that large amounts of nitrogen are not routed to the flare at any one time. If all equipment was purged with nitrogen simultaneously this would likely overwhelm the flare gas recovery compressor. By cascading the purging, this allows the flare gas recovery compressor to recove ry gasses to blowdown during a longer period of time, thus minimizing overall flaring since the compressor has been kept on-line for a longer period of time.
Steam is used instead of nitrogen for equipment clearing, as much of the steam condenses reducing the load on the flare recovery system. Steam is typically used in cases where there are not equipment vacuum limitations (e.g. piping, small equipment). Vessels typically have vacuum limitations. During steamout the peak flow to the flare gas recovery system is minimized by monitoring the steam rate and cutting back if the rate is too high. This does not eliminate all flaring associated with steamout procedures but minimizes the total amount of flaring.

The molecular weight of the flare gas is monitored, so that it is diverted away from the flare gas compressor when approaching outside of parameters that it can handle or that is suitable for

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combustion in unit heaters and boilers. This minimizes flaring by optimizing the period in which the compressor is on-line while also protecting the compressor from an equipment failure. Feed and product compressors are used to recycle material during startup until product specifications are met, allowing flaring to be avoided. The alternative would be to send gasses that have run once-through the reactors directly to blowdown. This minimizes the load to the flare gas recovery system and eliminates the potential for flaring.

Communication Measures
There is coordination from operator to operator and coordination within the shift organization so that the flare gas compressor load is not exceeded. The operators call to check on compressor operation before initiating actions that increase vent load.

Fuel Gas Balance

The fuel balance is adjusted to avoid flaring. This is done by examining the fuel gas balance which contains fuel producers and consumers. Depending on the environmental, safety and process constraints, operational changes are made dependent on which units have the most impact to the balance and the most flexibility. Reductions in fuel consumption or increases in consumption are att empted at numerous locations in order to get the facility back into fuel gas balance.
Steps taken to prevent fuel gas imbalances include and are generally included in the order of potential impact are:

 Minimize or cease butane vaporization to fuel gas.

 In creasing fuel consumption at operating heaters.

 Increasing production (i.e. fuel consumption) at Co-Generation plant.

 Operating steam turbines rather than electric drivers for pumps and compressors.

 Adjust the fuel supply at the Co-Generation plant to back out purchased natural gas and use more refinery fuel gas.

 Adjusting the severity of unit operations to affect the rate of gas production.

 Reducing process unit rates to decrease fuel gas generation.
The Refinery is also reviewing an application of a permit modification to address the short term SO 2 

## limit at the Co-Generation plant that restricts fuels gas consumption. Removing that restrictive limit will significantly reduce flaring from a fuel gas imbalance.
If a fuel gas imbalance does occur gasses are typically scrubbed for hydrogen sulfide removal. Excess clean gasses are then flared while additional measures are taken to mitigate the imbalance.

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Reliability
The reliabilities of ancillary systems which can lead to flaring if they trip have been improved, reducing flaring. See the “Maintenance Excellence Philosophy” portion of Section 4.3.2.1 for more details of the facilities reliability practices.
Incident investigations, as further described in Section 3.1 and 3.2, are utilized to determine root cause of failures and determine appropriate corrective actions to prevent recurrence.
Maintenance is conducted on compressors based on critical monitoring (i.e. vibration, temperature, load) results.
Preventative maintenance is conducted on critical pieces of equipment (pumps, compressors, etc) throughout the refinery to prevent failures. The benefits described for Flare Gas Recovery Compressors in Section 3.2, preventative maintenance conducted on critical equipment serves a similar purpose. Planned maintenance prevents failures. Equipment failures can often lead to flaring if a unit experiences an upset or must be shutdown. By conducting preventative maintenance, failures can be prevented which reduces flaring.

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# 4.1.3 Turnaround and Maintenance Flare Minimization Planning Tool
A planning tool has been developed and will be used to minimize flaring associated with planned turnaround and maintenance events, incorporating the minimization concepts outlined above. The means in which it will be utilized is presented in Attachment F. Listed below is an overview of the elements contained in the procedure:

 Establishing a timeline for conducting the initial evaluation of when flaring may occur prior to the turnaround;

 Scoping of the flaring that is expected to occur;

 Checklist which has a list of elements which should be considered in respect to flare minimization techniques;

 Post turnaround review of flaring which occurred.

 Documentation of lessons learned during the turnaround & successful minimization techniques utilized.

 Incorporation of lessons learned into appropriate shutdown, operating procedures, facility documents.

This process will minimize flaring by requiring more planning to address flaring that may occur during

a unit shutdown and tur naround. It will also cause personnel associated with turnaround activities to develop means to alter their work in order to take action to minimize flaring. Lessons learned will be captured and used for future turnarounds in order to continue efforts to minimize and/or eliminate flaring. See Section 3 Turnaround Planning Flare Minimization Procedure discussion for more detail.



# 4.1.4 Measures to Minimize Flaring During Unplanned Maintenance
There are occasions, primarily as a result of equipment malfunction, where a relatively immediate decision is made to shut down a block of the refinery, typically within a period of hours, allowing very little time for specific planning. In these cases, although the maintenance planning tool can still be used, it is often not possible to make the adjustments necessary to minimize flaring to the same extent as is possible when the shutdown is planned in advance. Despite this, there are many actions that can be taken to minimize flaring even when there is very little advance notice. For these cases, the refinery utilizes general procedures that have been developed to minimize flaring during all maintenance events, as shown in the attached flowchart. Although there is less of an opportunity for scheduling turnaround activities so as to insure that there will be a home for all of the gas generated at each step of the process, many of the same general principles apply when the decision to bring the unit down is immediate.

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# 4.2 Gas Quality/Quantity Issues for Each Flare (401.4.2)
This section discusses when flaring is likely to occur due to gas quality/quantity issues, systems for recovery of vent gas, and options for recovery, treatment and use of flare gas in accordance with 401.4.2



# 4.2.1 When Flaring is Likely to Occur

Re leases of vent gas to the flare result from an imbalance between the quantity of vent gas produced by the refinery and the rate at which it can be compressed, treated to remove contaminants (sulfur compounds) and utilized as fuel gas. Situations that can lead to flaring can be grouped together based on similarity of cause. These general categories, including specific examples of events which fit into each category, are outlined and discussed below as required by 401.4.2 in respect to flaring that may reasonably be expected to occur due to issues of gas quantity and quality:

4.2.1.1 Maintenance, Turnaround, Startup, and Shutdown
Generally, in order to maintain either an individual equipment item or a block of refinery equipment, it is necessary to remove it from operation and clear it of process fluids. Examples include:

 Unit shutdown

 Working on equipment

 Catalyst change

 Plant leak repairs

 Compressor system repairs (planned and unplanned)

 Unit Startup
Fuel and Hydrogen Gas Balance
All of these activities of necessity impact refinery operations in a variety of ways. In order to minimize the risk of flaring, there must, at all times, be a balance between producers and consumers of fuel gas. When either a block of equipment or an individual equipment item is removed from service, if it either produces or consumes gases, then the balance of the fuel gas system is changed and adjustments are necessary to bring the system back into balance. If the net change in gas production/consumptio n is large and adjustments in the rate at which gas is produced/consumed by other units cannot be made quickly enough, then flaring results.

F laring also occurs during Hydrogen Plant startups, shutdowns, or when a downstream hydrogen user experiences a sudden outage. As previously described, flare gas recovery compressors cannot handle high volumes of hydrogen in the system. When a hydrogen plant has been shutdown it typically is shutdown with a hydrogen consumer. In order to properly startup the consumer unit the hydrogen must first be available. Therefore, hydrogen plants are started up initially and may not have an outlet for all the hydrogen being produced. If a vent is not available, the hydrogen is sent to the flare gas recovery system if the system can handle minor volumes, otherwise it is sent to the flare. Hydrogen is also utilized for downstream equipment sweeping, thus the hydrogen plant is typically shutdown after the downstream unit. Thus, for similar reasons to startup there can be hydrogen containing streams sent to the flare system. If a hydrogen consumer suddenly shuts down, in order to minimize overall facility impacts, the hydrogen plant is typically kept running, rates may be reduced, but excess hydrogen flared until the downstream unit is restarted. Specific examples of this effect and fuel gas balance issues are listed below:

 Fewer locations that can accept the gas due to equipment/units out of service

 Hydrogen plant startup/shutdown

o Including Excess Hydrogen production following startup or unit shutdown

o Temporary flaring of off-spec hydrogen during startup

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o Planned & Unplanned shutdowns can result in flaring

o Planned & Unplanned shutdowns of the third party plant can result in flaring.

 Unicracker Complex turnaround (i.e. numerous combustion devices shutdown)

Equipment Preparation for Maintenance
Additionally, in order to clear hydrocarbons from equipment in a safe and orderly fashion so as to allow it to be maintained, a variety of procedures must be used. Many of these necessary procedures result in changes in the quantity and quality of fuel gas produced. For example:

 Depressurization of equipment

 Pressurization of equipment with nitrogen to remove hydrocarbon resulting in low fuel value (high nitrogen content) gas which cannot be used with burners designed for “normal” fuel
gas , as there can be NOx production and flameout concerns with low Btu gas.

 Steaming provides an efficient means for removing hydrocarbon clingage from equipment but the effects of steam (high temperature, condensation production) can result in the need to shutdown flare gas recovery compressors.

See the “Refinery Maintenance and Turnaround Activities ” section for more details in regards to the reasons for flaring during equipment preparation for maintenance.

Preventative Maintenance

, On -Line Planned Maintenance, Equipment Upgrades, Changes

In order to prevent unplanned failures preventative maintenance (PM) is conducted at varying schedules. Typically, PM is conducted to minimize production and/or environmental impacts by grouping PM activities together. Additionally, equipment upgrades occur periodically or changes may be made to improve existing systems. During equipment upgrades/changes pieces of equipment may be required to be taken out of service for brief periods of time to ensure worker safety and/or allow for equipment access.
Flare Gas Recovery Compressor Maintenance

–

Major Maintenance - typically conducted in conjunction with the Unicracker Complex turnaround in order to minimize environmental impact (i.e. less gas being produced while the Unicracker Complex is shutdown). The purpose of the PM is to maintain the compressor in order to minimize unplanned failures. This results in better on-line efficiency. Unplanned failures typically require more downtime due to time needed to diagnose the failure and then acquiring the necessary parts to make repairs.

Minor Maintenance – Based on on-going monitoring conducted on the compressor, see Recurring Failure section for more details, minor maintenance is conducted to replace parts or equipment which may fail or is not operating per the design. Purpose of the maintenance is to minimize and control downtime by preventing an unplanned, uncontrolled failure which may result in increased downtime. Additionally, the maintenance also can restore the compressor capacity and prevent flaring if the compressor is not functioning up to the equipment design.
Refinery Relief and Blowdown System Maintenance

– Periodic maintenance is required on sections of the relief and blowdown systems (e.g. process vessels, drums, flare water seals, flare tips, etc.). This maintenance can include periodic, required metallurgical equipment inspections as well as preventative maintenance cleaning and replacement of components.

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These activities are required to prevent unplanned shutdowns which might incur long repair periods of not performed proactively.
Miscellaneous PM, Equipment Upgrades, Changes
Flare Gas Recovery System Maintenance - Construction tie-ins to the flare system, instrument changes, electrical upgrades, new equipment installations could require equipment to be taken out of service. This might result in flaring in order to isolate equipment and then also during equipment startup.

Equipment Upgrades / Changes - are made periodically to improve existing systems. This may require various pieces of equipment to be temporarily taken out of service. Portions of operating units or individual pieces of equipment may be taken off line for preventative maintenance or repairs. This can result in flaring during the clearing of equipment and flaring when equipment is put back in service.

On -Line Maintenance - Water washing of U244 D-506 and U231 D-105 Reformate Stabilizer is conducted periodically. The procedure is managed in order to minimize loading to the flare gas recovery system but there are periods when flaring may occur during this procedure.

4.2.1.2 High Base/Continuous Load
Although flaring is often the result of a sudden, short-term imbalance in the flare/fuel gas system, it is made more likely when the gap between the capacity of the flare gas recovery system and long term average flow to the flare header is reduced. Examples of base load to the flare header includ e:

 Leakage of relief valves

 Low pressure equipment vented to flare header, e.g. tower overhead systems

 Delayed coker depressurization

 Low pressure tankage or odor sources vented to flare header via blower or compressor

 Hydrocrackers and reformers at end of run with elevated gas production rates

 Accumulation of small actions each of which results in production of flare gas

 Seasonal issues with cooling water temperature resulting in increased rates to flare head er

 Temporary re-rerouting of gases from other systems such as odor abatement to fuel gas recovery in order to prevent system overpressure

.

 Feed quality issue resulting in temporary increased base load.

In cases of this type of flaring when the flare gas compressor is still operating the gasses recovered by the compressor will continue to be scrubbed for hydrogen sulfide removal at Unit 233

.

4.2.1.3 Reduced Consumption of Fuel Gas
Treated flare gas may be flared during supply/demand imbalance. If flaring is to be minimized, it is necessary to balance fuel gas producers and consumers in the refinery. Refinery modifications that can change the fuel gas balance so as to make flaring more likely include:

 Energy efficiency projects that reduce fuel gas consumption

 Fuel gas imbalances can occur when fuel consumers (e.g. heaters, turbines) are shutdown and more gas is being produced then can be consumed.

 Fuel gas imbalances can occur when the third party Hydrogen Plant conducts planned or unplanned maintenance on feed filters and knock out drums.

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An imbalance in the flare gas system can also result from any of a series of upsets or equipment malfunctions that either increase the volume of flare gas produced or decrease the ability of the fuel gas handling system to accommodate it. Examples include:

 Leaking relief valves, PRV malfunction

 Relieving relief valves

 Equipment plugging

 Loss of a major compressor (e.g. Wet gas compressor)

 Loss of flare gas compressors, including but not limited to:

o Reciprocating compressor seats overheating from high nitrogen or hydrogen content

o Fuel gas with low specific gravity (due to Hydrogen), or high heat of compression resulting in overheating

o High inlet temperature to flare gas compressor

o Monitored safety/protective parameter (e.g. vibration) triggered shutdown.

o General mechanical problems inherent in the operation of rotating equipment.

o High liquid level.

o Equipment failure resulting in loss of compressor efficiency.

 Loss of other compressors (e.g. odor abatement, recycle hydrogen)

 Loss of a utility (steam, air, cooling water, power)

 Loss of air fins or condensers

 Failure of instrumentation, valve, pump, compressor, etc. to function as designed.

 Fuel quality upsets

 Hydrogen plant Pressure Swing Adsorption (PSA) operational changes (e.g. switching from 10 bed to 8 bed operation).

 Hydrogen plant PSA valve leaks resulting in a unit upset.

 Hydrogen may be sent to the flare system when there is a supply/demand imbalance

.

 Unplanned/sudden shutdown of 3 rd 

## party Hydrogen Plant.

 Equipment failure which results in an immediate or controlled unit shutdown (e.g. charge pump failure)

 Feed quality issue resulting in unit upset. (e.g. wet feed, lighter than typical feed)

 Control system failures resulting in either unit shutdowns or unit not operating as efficiently in manual operating mode.

 The unit Hazard and Operability (HAZOP) studies contain more specific listings of potential causes of equipment malfunctions and upsets which may lead to flaring.

4.2.1.5 Emergencies
Equipment failures and operational issues that result in equipment overpressure, typically leading to relief valves opening to the flare system, are classed as emergencies. Emergency flaring events are severe instances of upsets or malfunction. Emergencies are further defined in BAAQMD 12-12.

 Line leak, fires due to leaking flanges, etc. can result in emergency unit shutdowns in which material from units is quickly sent to the flare.

 Unit Hazards and Operability Studies (HAZOPs) and Process Hazards Analysis (PHA) also reference emergency conditions which may lead to flaring. These studies are a systematic evaluation of the hazards involved in the process. PHAs are required for initiation of a process

, for major equipment/operating changes, and at least once every five years after that. One of the values of PHA’s is to identify potential hazardous and develop means for mitigating hazards before they occur. For example, one of the ways to conduct this evaluation is to take unit piping and instrument diagram (P&ID). The consequences of failure of pieces of equipment (e.g. on a

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pump if flow is lost, flow is increased, flow is decreased) are discussed and the mitigation in place is reviewed. Where improvements should be made they are identified and tracked to completion. See Section 4.3.2.1 for more details about PHAs.

4.2.1.6 Miscellaneous

 Undetermined Cause - in some cases the cause of flaring cannot be determined. Typically, this is during minor flaring events (<500,000 scfd). Systems have been setup to try and pinpoint the cause of all flaring events, most events are traced back to a source but there are instances when a direct cause cannot be determined.

 Natural Gas Purge – flaring can occur if there is a spike in the natural gas purge flow. One of the ways this may occur is if the natural gas purge valve is opened too quickly or at a rate greater then typical flow. This results in the brief flaring of excess purge gas

.

 False Flow Meter Reading – as previously described to BAAQMD, many parameters (e.g. water seal level, flare line pressure, flare tip cameras) are utilized to determine whether or not flaring has actually occurred. In some cases flow may be detected by the meter, for example due to thermal expansion, but not all other parameters indicate that flaring has occurred. This is a common issue due to the sensitivity of the ultrasonic flow meters.

4.2.1.7 Other Causes
There are many potential causes of flaring, some of which are exceedingly difficult to totally eliminate, despite careful planning and system design.



# 4.2.2 Vent Gas Recovery Systems
As required by 401.4.2 the following sections contain an audit of the vent gas recovery, storage, and treatment capacity. In addition, an evaluation for installing additional recovery, storage, or treatment equipment to recover portions of gases periodically sent to the flare.
Refinery unit operations both produce and consume light hydrocarbons. Most of these hydrocarbons are routed directly from one refinery process unit to another. Refineries are constructed with a network of flare headers running throughout each of the process units in order to allow collection and safe handling of any hydrocarbon vapors that cannot be routed directly to another process unit. The hydrocarbon vapors are collected at low pressures in these flare headers. These gases are recovered for reuse by increasing their pressure using a flare gas compressor system. The compressed gases are typically returned to the refinery fuel gas system for use in fired equipment within the refinery. Any gas not compressed and sent to the fuel gas system is routed to a flare so it can be disposed of safely by combustion under controlled conditions. A typical flare gas system is shown in :

See Attachment G . In order to recover flare gas for use in the fuel gas system, three criteria must be met. First, there must be sufficient flare gas compressor capacity. Second, there must be sufficient gas treating capacity. Finally there must either be available storage volume or a user (e.g. fired heater) with a need for the gas. If any of these conditions are not met, then the gas cannot be recovered into the fuel gas header.

Existing Systems for Vent Gas Recovery

Within the Phillips 66 San Francisco Refinery at Rodeo, CA , the systems that currently exist for recovery of vent gas are described by the table below.

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Capacity (MM scf) Scrubbing

Capacity for Vent Gas (MM scfd) Total Gas

Scrubbing Capacity (MM scfd)

Main Flare & MP30 Flare 4.75 None None 35 1

1 

## The facility does not have a scrubber for gases sent directly to the flare. The flare gas recovery system typically sends gases to U233 for H 2 

## S removal and then sends these gases to fired sources. The capacity listed above includes the total capacity of the scrubbing system.



## The Phillips 66, San Francisco Refinery vent gas recovery system does not include any dedicated capacity for storage of fuel gas or vent gas. However, on a continuous basis the refinery optimizes the refinery fuel gas system of producers and consumers to maximize the capacity available for treatment and reuse of recovered gases by employing the following strategies:

 adjusting the sources of fuel that are made up to the fuel gas system including imported natural gas, and butane;

 adjusting the operations of units that produce fuel gas range materials including at times reducing severity of operations to reduce fuel gas production if it would put the refinery in a flaring situation;

 adjusting the refinery profile for consumption of fuel gas by ensuring the cogeneration unit is at its maximum capacity (within constraints on exporting power), shifting rotating equipment to turbine drivers (which operate with steam generated in the fuel gas fired boilers), and at times reducing the throughput of processing units to minimize gas production. There are limitations to this activity. For example, the cogeneration unit has a sulfur dioxide (lb/hr) limit. The cogeneration unit utilizes a fuel mixture of refinery fuel gas (sulfur containing) and natural gas (nearly nil sulfur). As the ratio of refinery fuel gas is increased the units start approaching their sulfur dioxide limits. The amount of fuel gas burned in facility heaters is limited by permit conditions and energy efficiency constraints.

 When possible, the usage of fuel gas can be increased for brief periods of time to mitigate or prevent flaring.

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- 22 The total gas scrubbing capacity that is indicated is an integral part of the refinery fuel gas management system. This capacity is closely matched with the fuel gas consumers’ (heaters, boilers, etc.) usage requirements. The capacity indicated as being available for recovered vent gas scrubbing will vary depending on the balance between fuel gas production and consumption; it will vary both on a seasonal basis and during the course of the day. With this system for flare gas recovery in place, the Phillips 66 San Francisco refinery at Rodeo, CA has recovered the following daily and annual average flow volumes:

Year Daily Average

Flare Gas Recovered
(MMSCF/d) Daily Average

Flare Gas Flared (MMSCF/d) % of Material

Recovered Annual Volume

Flare Gas Recovered (MMSCF/Yr) Annual Volume

Flare Gas Flared (MMSCF/Yr)

2006 to date prorated 2.35 0.06 99% 858 22

2005 1.97 0.16 92% 722 58

2004 2.30 0.64 78% 850 234

Note: The amount of material flared and % of material recovered can be very dependent on the turnaround schedule. Major turnarounds are typically conducted less frequently than once per year. For example, a major turnaround of the flare system occurred in 2004

. 

## 4.2.2.1 Options for Recovery, Treatment and Use
To address the requirements of Regulation 12 Rule 12 (401.4), the Phillips 66, San Francisco refinery at Rodeo, CA

has considered the feasibility of further reducing flaring through additional recovery, treatment, and/or storage of flare header gases, or to use the recovered gases through other means. This evaluation considers the impact these additional systems would have on the volume of flared gases remaining in excess of what has already been recovered (as noted in the previous section), and the associated mass flow of hydrocarbons emitted after combustion in the flare control device.
A typical flare header is connected to both a flare gas recovery system and to one or more flares. Normally all vapor flow to the flare header is recovered by a flare gas recovery compressor, which increases the pressure of the flare gas allowing it to be routed to a gas treater for removal of contaminants such as sulfur and then to the refinery fuel gas system. Gas in excess of what can be handled by the flare gas recovery compressor(s), the treater(s), and/or the fuel gas system end users flows to a refinery flare so it can be safely disposed of by combustion. Therefore, in order to reduce the volume of gas flared, three essential infrastructure elements are required: sufficient compressor capacity to increase the pressure of the gas to the point where it can be used in the refinery fuel system, sufficient storage volume to dampen out the variation in volumetric flowrate to the flare gas header, and sufficient capacity in treating systems to condition the gas (primarily by removal of sulfur) for use in the fuel gas system.
Options for storage of flare gas are analogous to those for storage of other process gases. Gases can be stored at low pressure in expandable gas-holders with either liquid (water) or dry (fabric diaphragm) seals. The volumes of these systems expand and contract as gas is added or removed from the container. Very large vessels, containing up to 10,000,000 cubic feet of gas can be constructed by using multiple “lifts”, or stages. Gases can also be stored at higher pressures, and correspondingly lower volumes, in steel bullets or spheres. The optimal pressure vessel configuration depends on system design pressure and total required storage volume.

For any type of gas storage facility, selection of an acceptable site and obtaining the permits necessary for construction both present difficulties. Despite the refinery’s demonstrated commitment and strong track record with respect to safe handling of hazardous materials, the surrounding community can be expected to have

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## 4

- 23 concerns about any plan to store large volumes of flammable gas containing hydrogen sulfide and other sulfur compounds. Safety concerns are expected to impact site selection as well, with a relatively remote location preferred. Modifications to the recovery, storage and treating of refinery flare gases are subject to the provisions and approval of federal and local regulations including Process Safety Management (PSM), Contra Costa County Industrial Safety Ordinance (ISO), and California Accidental Release Prevention Program (CalARP). Although the objective of the project would be a reduction in flaring, there are expected to be multiple hurdles along the path to a construction/land use permit.

Flare gas treating is used to condition flare gas for use as fuel in the refinery fuel gas system. Treatment is focused on removal of sulfur compounds, with some systems improving fuel value by removing carbon dioxide as well. A range of technology options exist, most of which are based on absorption of acid gases into a “lean” amine solution (MEA, DEA, MDEA, DGA) with regeneration of the resulting “rich” solution by stripping at lower pressure. In order to recover additional fuel gas it is necessary to have sufficient capacity to match the capacity of gas treating systems to the peak flowrate of the flare gas requiring treatment.

In order to assess the potential effect of additional flare gas recovery, a hypothetical design for an upgraded system was developed. The impact that this system would be expected to have on hydrocarbon emissions, based on the refinery’s recent flaring history, was then evaluated. Results of this evaluation are provided for three system capacities corresponding to the rate of flow of additional flared gases that could be recovered, the modifications required to achieve that recovery, and the estimated total installed cost for the additional equipment needed for the increase in recovery. The budgetary level (order of magnitude) cost information provided in this section has been developed based on total installed cost data from similar installations where available, otherwise vendor quotes in combination with standard industry cost estimation procedures have been used to estimate system cost.

An evaluation was conducted for the Phillips 66, San Francisco Refinery in Rodeo, CA. In order to conduct the analysis a summary of historical flaring was prepared. Flaring events were categorized in order to determine feasible means for reducing flaring through storage, recovery, and treatment. See Attachment H for summary of categorized, historical flaring. The period of 2004 – 2006 was utilized to determine general trends. The data for 2005 was utilized to quantify potential costs and benefits of additional storage, recovery, and/or treatment.

Based on the data review it was determined that four cases should be examined. The cases include the following scenarios:

 Case 1 – Installation of Small Compressor (1.5 MMSCF/day) to enhance existing compressor recovery during peak loading.

 Case 2 – Installation of Large Compressor (6.0 MMSCF/day) to eliminate minor compressor loading events and some flaring events which occur during brief Flare Gas Recovery Compressor (G-503) preventative maintenance periods.

 Case 3 – Installation of high pressure storage sphere, installation of large compressor, and addition of amine treater. Value of this case would be to eliminate all events listed in Case 2 as well as some events which are quality driven (e.g. high Nitrogen & Hydrogen) due to equipment purging.

 Case 4 – Similar to Case 3 with a higher percentage of the volume generated during the quality driven flaring events would be eliminated.

See Attachment I for example schematic of the equipment installations that would be involved in Case 3 and 4

.

L isted below is a summary of the overview of the analysis performed and the results of the analysis.

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## 4

- 24 Storage, Treatment, & Recovery Scenario

- Emission Reduction & Cost Effective Analysis

Estimated Potential Reductions (tons/yr) Cost Effective Basis (tons) Cost of

Control ($MM) Annualized

Cost of Abatement System ($ MM ) Cost

Effectiveness Basis ($/ton)

Case VOC SO2 Nox CO PM

1

- 0.15

- 0.62

- 0.02

- 0.19 negligible

- 0.98 $ 3.25 $ 1

. 06 $ (1,08 4

, 092 )

2

- 1.12

- 4.51

- 0.13

- 1.38

- 0.01

- 7.1 6 $ 7.50 $ 2

. 5 1 $ (350, 420 )

3

- 1.57

- 6.35

- 0.19

- 1.94

- 0.02

- 10.0 7 $ 23.40 $ 6

. 19 $ (61 5 ,4 76 )

4

- 2.02

- 8.18

- 0.24

- 2.51

- 0.02

- 12.9 7 $ 23.40 $ 6

. 19 $ (47 7,509 )

1 

## Basis is BAAQMD Guidelines for calculation of cost- effectiveness for BACT using the “levilized cash flow method” . Costs for equipment were based on cost curves developed by a third-party.



## It should be noted that the cost basis did not include the consideration of infrastructure adequacy and did not include all potential equipment and instrumentation necessary. It is expected that once a more rigorous evaluation is performed the costs will significantly be impacted. For example, the cost of infrastructure needs for equipment utilizing electricity and air is expected to be significant. Attachment N contains data utilized to calculate the cost effectiveness of the four cases described above. The storage sphere costs were based on quotes provided by Chicago Bridge and Iron and are contained in the Attachment. A cost curve was prepared by a third-party for the compressor costs. The costs were based on data points of actual costs provided by WSPA membership.

For Case 3 and 4, the evaluation is based on the need for installation of new major systems in order to increase recovery of flare gases from current levels:

 Additional flare gas recovery compressor capacity - the estimated cost to provide additional compressor capacity to recover vent gas flowing in the flare header in excess of current compressor capacity, for transfer to storage and / or treatment. Costs provided are for one unspared compressor system to be added to one existing flare header. The estimate is for a reciprocating compressor with all necessary appurtenances for operation, including knock out pots, coolers, and instrumentation for a fully functional system.

 Addition of surge volume storage capacity – the estimated cost to provide temporary surge storage for a portion of the gases routed to the flare header in excess of the volumes currently being recovered, treated, and consumed. The addition of temporary surge storage volume is necessary for any further increase in flare gas recovery to allow flare gas flow (which is highly variable) to be matched to the demand for fuel gas. The cost used is based on a storage volume equal to the total volume of gas accumulated over one day, and is based on recovery in a high pressure sphere system with discharge at a controlled rate back to the flare gas header. Other lower pressure approaches were considered (low pressure gas holder, medium pressure sphere), but for the sizes analyzed a high pressure sphere was identified as the preferred approach based on operational, safety and economic considerations.

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- 25  Additional recovered gas treatment capacity – the cost of additional amine-based treating capacity to process recovered gases for sulfur removal so that they can be burned by existing fuel gas consumers without exceeding environmental or equipment operational limits. The assumption is that for small increases in treating capacity the existing treater(s) will be modified / upgraded to allow for the increase. No additional cost has been included for expansion of sulfur recovery system capacity.
Based on this review the Phillips 66, San Francisco Refinery has concluded that further expansion of systems for the recovery, treatment and use of flared gases is not the most effective approach to reducing these emissions. The refinery has concluded that the major source of flared gases on a volume basis can be attributed to large flow rate, low quality flaring events, especially those of extended duration such as may occur during emergency events or prolonged shutdowns where systems within the refinery are out of fuel gas (and / or hydrogen) balance. Additionally, a synergy was identified that the Refinery will leverage to install additional capacity of 3.3 MMSCFD.

The refinery has allocated significant resources to the development of procedures to plan for, manage, and minimize large flow and duration flaring events. Further resources have also been allocated effectively to ongoing preventive maintenance programs, and even to adjust refinery operations on a severity and throughput basis. These approaches have been identified to be more effective than providing additional flare gas recovery system capacity. Additionally, it is expected that the practices discussed in this plan, specifically the development of a formal turnaround flare management procedure

, continuation of incident investigations, and management system programs will result in further reductions of flaring events. These will likely prove to be most cost effective and meaningful.

4.2.2.2 Preventing Production of Low-Quality Flare Gas
Measures to help prevent production of low-quality flare gas, e.g. sour gas, low Btu gas, high nitrogen content are further investigated in this section. The discussion is integrated with the discussion of turnaround and maintenance events as gas quantity (insufficient demand) and gas quality (unscrubbed durin g upset/malfunction and nitrogen/steam during turnaround) are the primary drivers for flaring during these events. It is for this reason that the measures used to minimize production of low quality fuel gas are closely related to those that can be applied to reduce flaring during maintenance and turnaround events.

Preventing production of sour flare gas is accomplished by making sure that recovered flare gas is routed to the fuel gas system via a gas treating system. It is preventing the production of sour fuel gas that drives the need to match the capacity of treating systems to accept flare gas to flare gas recovery capacity.

High fuel gas nitrogen levels are primarily caused by the nitrogen used to purge hydrocarbons from equipment in preparation for equipment opening. High nitrogen fuel gas content is controlled by limiting the rate at which nitrogen is introduced to equipment and ultimately the flare gas system during nitrogen purging operations. There can be a trade-off between nitrogen flowrate and the effectiveness with which the nitrogen mixes withinthe contents of the vessel from which hydrocarbons are being removed. These must be balanced on a caseby -case basis to determine the purge rate that represents the best compromise among competing process needs. Scheduling decommissioning activities to minimize overlapping nitrogen purge events is one of the best ways to control the nitrogen content of flare gas.

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## 4

- 26 4.3 

# Recurrent failure (401.4.3)

 of Pollution Control Equipment

 Process Equipment, or

 A process to operate in a normal or usual manner:



# 4.3.1 Reportable Flaring Events Attributable to the Same Process or Equipment Item

For the Period from June 30, 2006 to June 30, 2013
A discussion and analysis of each event, including actions taken to avoid future flaring as a result of the same cause and the adequacy of maintenance schedules and protocols. Flaring as the result of malfunctions and upsets is included in the analysis.

Reportable Flaring Events Attributable to the Same Process or Equipment Item

Date Process or Equipment Item Flaring Event Description


## There have been no recurrent failures that occurred at the refinery in which the root cause was associated with a refinery equipment failure. There have been third

- party supplier outages that have resulted in flaring reportable events. Attachment H conta ins a listing of the reportable events and the associated corrective actions.



# 4.3.2 Means to Prevent Recurrent Failure

There are many programs in place in order to prevent recurrent failures. The programs fall into two major categories; proactive and reactive. The purpose of the proactive programs is to have systems in place based on potential failures that could occur in order to prevent failures from occurring. The reactive programs examine failures that have occurred in order to learn from the failure and develop stronger proactive programs to prevent recurrence. The facility employs many levels of proactive and reactive programs.

4.3.2.1 Proactive Programs
BAAQMD Regulation references “the adequacy of existing maintenance schedules and protocols” for air pollution control and process equipment in respect to recurrent failures. There are major programs in place which support the prevention of failures. Additionally, these programs facilitate continuous improvement to prevent failures. Key programs in place are described below.

Phillips 66 HSE Management System
Phillips 66 Corporation requires each refinery to implement a standard Health, Safety, and Environmental (HSE) Management System. This is achieved through providing organization structure, programs, procedures, processes, and resources to manage business activities safely and with respect and care for the environment. The HSE Management System seeks to:

 Demonstrate management commitment to health, safety, & environmental stewardship.

 Ensure that all reasonably practicable steps are taken to identify the hazards and risks arising from business activities.

 Establish adequate control over business activities with the aim of achieving safe, incident, and injury free working conditions. A review of flaring events caused by failures was examined from the period of July 20, 2005 to date. There were events of flaring caused by failures that

were identified. There were no cases in which recurrent failures were identified. Thus, this sectio n has been left blank.

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- 27  Maximize the operational integrity, reliability, and efficiency.

 Ensure regulatory compliance.

 Promote high standards and the continuous improvement of HSE performance.

Process Safety Management (PSM)
The refinery must comply with EPA’s PSM. Major elements of PSM are also incorporated in California’s Accidental Release Prevention Program (CalARP), the Contra Costa County (CCC) Industrial Safety Ordinance (ISO) and EPA’s Risk Management Program. There are fourteen elements of PSM, each of these elements is included in some fashion with the programs listed above. In addition, the CCC ISO and CAL ARP program have some additional elements. Although all the elements directly or indirectly prevent failures or minimize the impact of a failure if it occurs, listed below are some of the programs that most directly support failure prevention.
Employee Participation – Employees at all levels must be involved with the elements of PSM. This encourages ownership, participation and buy-in of incident investigation results and means for improvement, and promotes a better safety and operating culture.

Process Safety Information (PSI)

– the refinery is required to maintain accurate Process Safety Information. PSI includes chemical inventory, accurate drawings, operating procedures, etc.

Process Hazards Analysis (PHA) - A PHA is a systematic evaluation of the hazards involved in the process. PHAs are required for initiation of a process and at least once every five years after that. The PHA team should be multi-disciplinary, including maintenance, operations, and engineering. The facilitator of the PHA must be trained in the methodology being used. For proper conduct of a PHA, the PSI must be as complete as possible. One of the values of PHA’s is to identify potential hazardous and develop means for mitigating hazardous before they occur.
Operating Procedures - Operating procedures include not only the steps for normal operations, but for upset conditions, temporary operations, start-up, and shutdown. Very important safety information must also be included in operating procedures. Contained in the procedures are basic hazards of exceeding operational limits, appropriate response to upset conditions, safety and health information, and emergency operations. The procedures are required to be up to date and reliable. They are also a critical element in training of personnel.
Training - Training is required for all employees new to a process before they become involved in that process. The training must include the hazards of the chemicals and process and what is necessary to protect themselves, their fellow employees, and their surrounding communities. Training should be both written/classroom and hands-on. Employers must evaluate the effectiveness of training and make adjustments to content and frequency of training based on those evaluations.
Pre-Startup Safety Review (PSS R) - The Pre-Startup Safety Review is done before startup of a new operation or startup following a change in the process (see Management of Change, below). It is a means for ensuring that all essential action items and recommendations from the PHA have been completed prior to beginning operations. It is also the point at which the design parameters and standards used for construction are verified. If training or modifications to Process Safety Information (PSI) are necessary, completion of these items is also verified during the PSSR. Startup should not be allowed to occur until all safety-critical PSSR items have been completed.
Mechanical Integrity

- Employers are required to have a program to ensure the integrity of processes and equipment. Aspects include listing applicable equipment, training of maintenance personnel, inspection and testing, and maintenance of such systems as controls, vessels, piping, safety systems,

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- 28 and emergency systems. Development and modifications to the mechanical integrity program should be made based on operational experience, relevant codes, and industry standards.
Management of Change (MOC) - “Change” includes anything that would require a change in Process Safety Information. This includes changes to equipment, processes, and instrumentation. A proper MOC system requires that any change be evaluated prior to its implementation. The level of evaluation can depend on the degree of change and its criticality to the safety of the operation. In addition to the evaluation and approval of a change, MOC requires that suitable training be conducted (if necessary) and the relevant PSI be updated.
Compliance Audits - Per OSHA, compliance audits must be conducted at least once every three years. The purpose of the audits is to determine whether the practices and procedures developed under the provisions of the PSM standard are being followed and are effective. The auditor(s) must be knowledgeable in PSM and should be impartial to the facility being audited. An audit report must be developed and the employer must promptly respond to each of the findings. Once deficiencies are corrected, the corrective action must also be documented.
Maintenance Excellence Philosophy

Predictive Maintenance - The Rodeo Refinery utilizes predictive maintenance tools for both rotating equipment (pumps, blowers, fans, motors) and fixed equipment (pressure vessels, piping, storage tanks). These tools can be used to predict equipment condition and failures so that appropriate preventive measures can be taken, or so repairs can be scheduled prior to a failure. The Rotating Equipment/Reliability Department is responsible for ensuring that rotating equipment is in good condition and the Metallurgical Engineering and Inspection (ME&I) department is responsible for inspecting fixed equipment in the facility.

R OTATING 

## E QUIPMENT 

## The following is a list of tools and techniques used for maintaining the rotating equipment:

 

## Operator Inspections/Seal Integrity

 

## Equipment Deficiencies

 

## Vibration Analysis

 

## Lube Oil Testing

 

## Overhaul Testing

Operator Inspections / Seal Integrity

Operators visually inspect the equipment case and seal/packing area for signs of leakage. Mechanical seals are the number one failure mode in centrifugal pumps. Operations and maintenance personnel include visual monitoring of seals in their shift rounds. In some cases, for example where dual seals are installed, instrumentation (level, pressure, etc.) is available to alert operations that action is required. Seals subject to LDAR (Leak Detection and Repair) regulations are monitored for hydrocarbon emissions on a regular basis.

Operators listen to and observe the equipment operation to detect any unusual noises and/or vibrations that may indicate damage or wear.

Equipment Deficiencies

If a potential deficiency is observed, the operator contacts the Operations Supervisor to request consultation by the appropriate craft or by the Rotating Equipment Group. If it is determined that repair is required, the operator submits a Work Request via the Computerized Maintenance

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- 29

Management System and initiates the steps necessary to make the equipment available for repair. The Work Request documents the deficiencies noted during the operator inspection.

Vibration Analysis

Vibration analysis can be a useful predictive maintenance activity to identify potential equipment failures so that proper maintenance can be scheduled before a failure occurs.

Vibration readings are taken using hand-held piezoelectric accelerometers. Readings are normally taken on all bearing planes (horizontal, vertical, axial). Local panel readings for vibration and temperature, where applicable, are also entered into the data collector. The data is then typically uploaded into the vibration analysis computer, which can be compared to historical data, industry guidelines, or vendor data to assist in scheduling maintenance or indicating the need for additional detailed analysis. Rodeo Refinery personnel participate on a Phillips 66 Rotating Equipment Best Practices Network to facilitate learning in this area.

Lube Oil Testing

Several pieces of rotating equipment are classified as critical. A sample of lube oil is drawn from the appropriate critical equipment, or other machinery of interest, quarterly or as warranted. Thi s sample is sent to a certified laboratory for a standard set of analyses. The results are transmitted to the Machinery Specialist. The results of each analysis are entered into a computer database as a single record. The data included in the record are:

 Equipment tag number

 Date of sample

 Analysis results

Sample test results are trended and compared to established limits of operation for each specific piece of equipment. If a deficiency is noted, the Machinery Specialist initiates an appropriate corrective action. These could include continued monitoring, oil replacement, filtration, or a repair of the equipment.

Overhaul Inspections

Equipment that has been removed to the shop for repair undergoes a detailed internal inspection to identify wear or damage that could affect performance or mechanical integrity. Machinists perform visual inspections and measure clearances for comparison to manufacturer's specifications. If necessary, the Inspection Group can perform more sophisticated tests (radiographs, ultrasonic, magnetic particle, liquid penetrant and materials analysis) if requested by the Rotating Equipment Group or Maintenance.

F IXED 

## E QUIPMENT 

## The Rodeo Refinery utilizes the following techniques to ensure fixed equipment is in good condition:

 External Visual Inspection,

 Internal Visual Inspections, and

 Thickness Surveys.

External Visual Inspection

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The primary reasons for performing external visual inspections of pressure vessels, piping and storage tanks are to determine the type, rate and causes of any deterioration present that may negatively affect their mechanical integrity and/or service performance and to determine if any maintenance work is required to maintain the equipment in a safe operating condition.

External visual inspections are performed by qualified Phillips 66 or contract inspectors. The external visual inspection results are documented in an external inspection report. The report is completed and dated by the inspector(s) performing the external visual inspection. It is reviewed by the plant’s Inspection Supervisor or authorized representative. The completed report is filed in the equipment inspection history file located in the plant’s Inspection Department.

Internal Visual Inspection The primary reasons for performing an internal visual inspection are:

1. to determine if the essential sections of the vessel are safe to operate until the next inspection; 2. to determine the type, rate and causes of any deterioration present which may negatively affect its mechanical integrity; and, 3. to determine if any maintenance work is required to maintain the pressure vessel in a safe operating condition.

The internal visual inspections are performed by qualified Phillips 66 or contract inspectors.

Pressure vessels are typically visually inspected internally at least once every 10 years, in accordance with API standards. Non-fired boilers are inspected every 6 years maximum and fired boilers are inspected every 3 years maximum, in accordance with State of California requirements. In practice, many vessels and heaters in sulfur plants are visually inspected internally during a boiler inspection period, at a 3, 6, or 9 year interval and therefore, well within the 10 year maximum interval allowed by API industry standards.

The inspection results are documented in an internal inspection report. The report is completed and dated by the inspector(s) performing the internal visual inspection. It is reviewed by the plant’s Phillips 66 Inspection Supervisor or authorized representative. The completed report is filed in the equipment inspection history file located in the plant’s Inspection Department.

Thickness Survey A representative number of thickness measurements are taken on pressure vessels via ultrasonic and/or radiographic thickness techniques for remaining wall thickness at intervals pre-established by the industry. Thickness surveys are also performed on most process piping runs. The thickness survey is prompted by the plant’s Inspection Department to meet all requirements for thickness surveys as outlined in the applicable API standard.

The thickness surveys are performed by qualified Phillips 66 or contract inspectors who have the appropriate education, experience and qualifications.

The general area of each thickness monitoring location (TML) is ultrasonically scanned and/or radiographed and the lowest reading is recorded. When using ultrasonics, scanning the general area rather than monitoring the same exact location increases the chance of finding local corrosion and typically yields a larger (more conservative) general corrosion rate.

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The thickness survey results are completed and dated by the inspector(s) performing the thickness survey. It is reviewed by the Phillips 66 site Inspection Coordinator or authorized representative. The completed report is filed in the appropriate equipment file and all data is recorded in an electronic database (PCMS System).

Preventive Maintenance - Preventive maintenance activities ensure that equipment and instrumentation function properly through their design life. Examples of these activities are outlined below. Deficiencies are corrected at the time of the inspection where possible or work orders are written to facilitate cleaning or repair.

Instrumentation Ins truments that are critical to unit operations are reviewed and calibrated and cleaned as needed. Examples include flow meters, fire eyes, temperature monitoring devices and analyzers used for performance monitoring and control. Plant performance testing, through pressure surveys, temperature indicators, efficiency calculations or other data collection is used to resolve discrepancies in measurement devices.

Rotating Equipment To ensure reliable operation of rotating equipment, spare equipment can be operated, where installed, to facilitate repair. Seals and bearings are replaced based on inspections or predictive maintenance activities.

Preventive maintenance tasks include cleaning, adjustment, and lubrication. Operators replace lubricating oil and grease on a frequency set by a master schedule for the Refinery. Appropriate lubricants are specified in a written plan. Steam turbine drivers’ over-speed trip protection devices are tested at an established frequency. Fans and mixers are cleaned, lubricated and tested.

Fixed equipment Thickness measurements and corrosion monitoring (probes, coupons, external UT, and critical process variables) are used to schedule preventive maintenance on vessels. Refurbishment of steel through weld buildup, plate replacement, coatings, or vessel replacement is used to ensure the mechanical integrity of pressure vessels. Refractory is replaced based on inspections, monitoring skin temperatures and thickness in fired equipment and based on internal visual inspections of refractory condition.

Jacketing/Tracing Integrity of steam and electric tracing used in sulfur processing units is verified through regular plant walkthroughs/checklists by plant operations and maintenance personnel.

Catalyst & Chemicals Unit catalyst and chemical activity is monitored by unit engineers and operators through pressure surveys and temperature indicators. Lab testing is conducted on intermediate and products to monitor quality. When quality is compromised, operational parameters or other means are employed to ensure continued performance.

Turnaround Inspection And Repair - Major maintenance turnarounds of the process and utility units are planned based on predictive/preventative maintenance activities. Prior to each planned shutdown, a work scope is developed for detailed inspection, repair, replacement and testing of equipment, catalyst and chemicals to ensure the unit will operate properly until the next planned shutdown.

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- 32 The exact activities for each planned shutdown are determined by Operations, ME&I, Engineering

, Reliability and Maintenance personnel prior to each shutdown. A criticality ranking process is used to determine which proposed work activities are included in the turnaround inspections and repairs.

Where practical, maintenance is performed on the equipment while the unit is still in operation. Typical turnaround activities include cleaning equipment, replacing/rejuvenating catalyst and chemicals and inspecting/repairing/replacing equipment as-needed.

Critical Instruments & Safety Instrumented Syst em The facility has a list of critical devices and has a procedure for handling Safety Instrumented Systems. Safety Instrumented Systems (SIS) take processes to a safe state when predetermined conditions are exceeded. This includes set points such as pressure, temperature, level, etc. These programs maintain the reliability of such devices and systems in order to ensure that shutdown systems have been appropriately established and are reliable.

Near Miss/Good Catch Program
A process is in place that encourages all employees to identify and report potential near misses. Near misses are undesired events which, under different circumstances, could have resulted in harm to people, damage to property or the environment, or production/business loss. Near misses may also include unsafe practices, acts or conditions. The value of this program is that it facilitates:

 Identifying and addressing safety, procedural, environmental impact, design or equipment issues in a proactive, non-threatening manner.

 Identifies learning or training opportunities.

 Sharing of “lessons learned” and best practices with other employees and facilities.

Solomon Refining Comparative Analysis
The refinery participates in periodic comparative analysis. Flare volumes are one of the parameters included. Flare volumes are included in the metric to examine materials that could have been recovered from an economic standpoint. The purpose of the analysis is to determine how facilities compare with their peers in critical parameters.

4.3.2.2 Reactive Programs
When a failure has occurred, depending on the magnitude of a failure, the event will be examined in further detail. Listed below is an overview of the major elements of the programs in place to prevent recurrence of failures.

Incident Investigation

An internal procedure is in place which identifies the type of failures which require incident investigation. This process is a key part of our Health, Safety, and Environmental Management System. Failures captured by this process typically include accidents, injuries, events with potential off-site impact, some levels of flaring events, upsets which result in business loss. The procedure requires that an investigation be conducted and corrective actions identified. The regulatory drivers for this program include, but are not limited to; EPA’s PSM, EPA Risk Management Program, Contra Costa County (CCC) Industrial Safety Ordinance (ISO),

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- 33 California’s Accidental Release Prevention Program (CalARP). Additionally, there are strong business case drivers for completing incident investigation and preventing recurrence.

Root Cause Reporting

In addition to the incident investigations described above, root cause is required to be reported for higher level events based on various regulatory drivers. Regulatory drivers include but are not limited to; BAAQMD regulations 12-11 & 12-12, EPA SARA/CERCLA reporting requirements, Phillips 66 EPA Consent Decree requirements, Contra Costa County ISO.

Flare Monitoring & Reporting Procedure

The procedure documents the BAAQMD monitoring and reporting requirements. Additionally, it contains levels in which flare incident investigations must be conducted. The levels correspond to those required by BAAQMD and in the Phillips 66 Consent Decree. See Attachment E for general overview of the process for reviewing flaring events.

Use of Incident Investigation Documentation Software

Phillips 66 requires use of a Corporate wide software tool in which certain risk levels of incidents must be tracked. An overview of the incident is included in the software as well as the corrective actions. Depending on the level of the incident, the overview of the incident is immediately shared with Vice President level staff electronically via the software.

High Learning Value Event (HLVE)

If an event occurs in which a lesson learned might have value to sister refineries within Phillips 66 a system has been established for quickly sharing lessons learned so that other facilities may not experience a similar incident.

Corporate Incident Notification Requirements

Higher level events, such as off-site impacts, require immediate notification to the Corporation.
Corporate Health, Safety, and Environmental Reporting Requirements
Flaring volumes are required to be reported and are tracked refinery by refinery to the Corporation on a regular basis.
Key Performance Indicators (KPIs) - KPIs are reported internally throughout the facility on a periodic basis. The KPIs include the number and cause of flaring events. The purpose is to inform plant personnel of occurrences of these events and to encourage continuous improvement by tracking cause and number.
Regulatory Notifications
There are various regulatory drivers which require notification of various levels of flaring events. Drivers include; BAAQMD 12-12, EPA’s SARA/CERCLA, CCC Community Warning System requirements, etc.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 October 2013, Rev. 9



## 5

- 1 

# 5.0 Other Information Requested by APCO to Assure Compliance (401.5)

5.1 New Equipment Installations (404.2)

A new source review application was submitted to BAAQMD for the installation of new equipment associated with the Clean Fuels Expansion Project (CFEP). The BAAQMD application number is 13424

, the permit to construct was issued on March 13, 2007

. Both the BAAQMD permit and Environmental Impact Report (EIR) included an evaluation of potential flaring that may occur as part of the project. Minimization techniques utilized for comparable equipment will be utilized for the new equipment/units. No routine flaring is planned or expected to occur with the new equipment/units. Anticipated flaring includes that associated with equipment maintenance, startups, shutdowns, major turnarounds, and during potential emergencies. The types of flaring expected for the new installation comparable to those that have been categorized for existing refinery operations in the section titled “When Flaring is Likely to Occur”. Listed below is an overview of the tie-ins and changes to be made to the flare system:

 Installation of three (3) new Liquid Ring Flare Gas Recovery Compressors to increase overall flare gas recovery compressor capacity and provide redundant capacity during maintenance activities.

 Tie-ins from the units listed below for non-routine flaring activities as described above:

o Unit 246-8 New Heavy Oil Hydrocracker

o Unit 235 Sulfur Recovery Plant including new Sour Water Stripper and new Amine Regeneration

o Unit 120 3 rd 

## Party Hydrogen Plant – for upstream (i.e. relief valve venting of feed streams)

 Debottlenecking of steam piping to flare to allow for wider smokeless range for both flares. Resulting in an increase from 50,000 lb/hr per flare to 75,000 lbs/hr to each flare with a maximum combined flow of 110,000 lb/hr for both flares..

The major tie-ins, new units, and new compressors are reflected in Attachments C, E, L, and M.

The third-party Hydrogen Plant application was currently processed under BAAQMD Number 13679. The permit application and EIR contemplated flaring that could occur in association with the Hydrogen Plant. The third party plant has a flare on-site. Flaring that could occur at the Rodeo Refinery and is associated with the third party Hydrogen Plant can potentially from feed streams upstream of the new Methane Steam Reformer. Downstream flaring off the Methane Steam Reformer would take place at the third part plant flare.

### Flare Minimization Plan, BAAQMD 12-12
Sa n Francisco Refinery
BAAQMD Plant 16



# ATTACHMENT A

SAN FRANCISCO REFINERY

SIMPLIFIED FLARE SYSTEM OVERVIEWProcess Gas From MP-30ComplexProcess Gasfrom MP-30Purge (Natural Gas)Purge (Natural Gas)42'' Line Flow MeterPurge (Natural Gas)48" Line Flow MeterMain FlareC-1MP-30 FlareC-602Process GasFrom RefineryBlowdownAI 586AI 520AI 584U-233TreatedFuel GasUnitHeaters& CogenF-3UnicrackerBlowdownU200/267BlowdownAttachment ASan Francisco RefinerySimplified Flare System OverviewPurge (Natural Gas)WaterSealWaterSealFuel GasCenter(H2S Removal)U 200 Wet Gas (G-501)CompressorOdor AbatementCompressorsUK / MP30 Sour Gas10'' Line Flow MeterG-540 Liquid Ring Flare GasRecovery Compressor (New 2009)ABCG-503 Flare GasRecovery CompressorWaterSealAI 58536" Line Flow MeterJ. Ahlskog, 07/2008Flare System Overview...vsd

# ATTACHMENT B

San Francisco Refinery, Rodeo, CA

Flare Gas System Detailed Description

Listed below is a detailed overview of the facili ty flare system. Although some parameters are contained in this description they are subject to change as operational or safety enhancements are identified.

The Refinery Relief and Blowdown Systems provide a m eans for recovery or safe disposal of gases and liquids, which may be generated by the process units. Typical sources of normal flow include coke drum steam-out and switching, sampling, acti vation of relief valves, distillation tower overhead vapors, and purging of equipment for maintenance or startup. During emergencies, major flow may occur from heater or unit depressuring and the liftin g of pressure relief valves. Gases and liquids flow through relief and blowdown lines to blowdown accumulators and knockout drums. Gases and vapors pass overhead to be recovered or flared. The liquids are generally reprocessed through appropriate operating units.

There are two flares in the refinery – the Main Fl are and MP-30 Flare. There are three relief and blowdown systems; the Refinery, the Hot Coker Bl owdown, and the MP-30 system. Typically the gases sent to the blowdown systems are recovered, tr eated, and then utilized for fuel in the facility heaters and co-generation equipment. During periods when gases are not recovered, the flare gases are typically sent to the Main Flare. The Refinery and Hot Coker Blowdown system gases are routed to the Main Flare. The units lo cated in the MP30 Complex relieve to the MP-30 Blowdown system. Typically, the gases sent to the MP-30 Blowdown System are recovered in conjunction with the gases from the Refinery and Hot Coker Blowdown system due to interconnecting piping. This interconnecting piping also accommodates minor flaring so that gases from the MP-30 Blowdown System are typically sent to the Main Flare. During major releases from MP-30, the gases would be flared at the MP-30 flare.

There are periods in which the Main Flare is sh utdown in association with the Unicracker Complex shutdown. During these periods, the Refinery Bl owdown system can be diverted to the MP-30 Flare. The Hot Coker Blowdown system would also be diverted to the MP-30 Flare while the Main Flare is shutdown.

Refinery Relief and Blowdown System

The Main Relief and Blowdown system handles relief and blowdown from the Coking Unit 200, Crude Unit 267, Gasoline Fractionation, Caustic Treating and Deisobutanizer Unit 215, Diesel Hydrotreating Unit 250, Steam Power Plant, Hydrogen Plant Unit 110, Fuel Gas Center Unit 233,the Unicracker Complex including Reforming Unit 244, Unit 246 Heavy Oil Hydrocracker (mid2009), and Unisar Unit 248, Sulfur Units, Isomerization Unit 228, the Unit 120 3 rd 

## Party Hydrogen Plant (mid-2009), and minor MP-30 releases.

During normal conditions, vapor in the flare headers upstream of 19F-3 Water Seal Drum is diverted to the Refinery Flare Compressor G-503 at Unit 200. G-503 compresses this vapor to the refinery gas system at the Fuel Gas Center Un it 233. Flare Gas Recovery Compressors G-540 A/B/C can be used as a total spare for the G-503 co mpressor. If all of the Flare gas compressors shutdown or the release is too large for the compressor system, the gasses flow through the Refinery Flare Drum 19F-1 and Water Seal 19F-3 - breaking the water seal and are burned in the Refinery Flare.

## F-1 Blowdown Drum

Vapor and liquid releases from the units list ed above flow through various blowdown headers to Refinery Blowdown Drum F-1. The Unicracker complex has its own separate Blowdown Drum F-45 upstream of F-1 to limit the liqui d releases to F-1. Vapor and li quid release from the Unicracker Complex discharge into F-45. Liquids are knock ed out and the vapor flows from F-45 through a 36- 42 ′′ header to F-1. Not all relief valves from the Unicracker Complex discharge to F-45. Relief valves from D-305 Fractionator di scharge directly into the 36-42 ′′ header from F-45.

The Steam Power Plant and Unit 110 also hav e separate Blowdown Drums upstream of F-1 – Blowdown Drum F-35 and Flare Knock Out Drum V-18 , respectively. The sites of the Steam Power Plant and Unit 110 have low points in their relief headers. Liquids condensing in the SPP and Unit 110 flare headers to F-1 flow back down the flare header to their respective blowdown drums.

Entrained liquids are knocked out in F-1. At a high liquid level in F-1, blowdown pumps G-1A/1B automatically start and pump the collected liquid through Cooling Water Exchanger E-1 to the foul water tank. The foul water tank has a water phase and hydrocarbon liquid phase. The water phase is fed to the Phenolic Water Stripper D-901. The hydrocarbon liquid phase becomes feed to Coking Unit 200 or to Naphtha Hydrotreater Unit 230.

F-3 Water Seal Drum and Flare Vapor Recovery Compressor Water Seal Drum F-3, located between drum F-1 and the Main Flare, permits th e use of the blowdown system and its drums as suction surge for the G-503 Flare Vapor Recovery Compressor during normal releases. F-3 usually contains about an eight foot water seal that diverts the gas in Blowdown Drum F-1 down the main 36 ′′ Unicracker blowdown header to the F-509 Knock Out Drum for G-503. The G-503 compressor, located in the Coker Light Ends area, returns the compressed gases to the refinery fuel gas system. The compressor design flowrate is 200,000 scf/hr of 23 MW gas. If more than 4.8 MMSCF/D gas is released to the blowdown system, usually during th e steamout of a Coke Drum, one of the G-504 compressors can also take suction on the flare header and can discharge an additional 1.6 MMSCF/D to the refinery make gas system for a to tal of 6.4 MMSCF/D vapor recovery. When the vapor flowrate is higher than 200,000 scf/hr, vapor s released to the refinery blowdown system break through the F-3 water seal and flow to the Main Flare. If the vapors released are from the MP-30 blowdown system, the vapors may also break thr ough the F-604 water seal and flow to the MP-30 Flare. G-503 may also spare the Unit 200 Coker Wet Gas Compressor G-501 or the Unit 200 Odor Abatement Compressors G-60A/B/C. When G-503 is in G-501 or G-60A/B/C se rvice, or G-503 is down, all three G-540 compressors can be placed in fl are gas recovery service. Total gas recovery is then limited to 4.8 MMSCF/D. If no flare gas recovery compressors are available, the F-3 water seal is removed, and vapors flow directly to the Main Flare. The F-604 water seal is not removed when G-503 is down, so that flaring of the normal releases only occurs at one flare stack.

Main Flare Header

Flare gas from D-7 Blowdown Drum and Unit 240 reactor depressuring gas release downstream of Water Seal Drum F-3. The Unit 240 reactor depressuring line bypasses drum F-1 and Water Seal Drum F-3 to accommodate depressuring of the reactors at a 300 psi/min rate. The Hot Coker Blowdown bypasses the F-3 Water Seal Drum to minimize back pressure on the Hot Coker Blowdown Drum D-7.

Any gas breaking through the F-3 water seal, vapor from D-7, and/or Unit 240 depressuring gas enter the Main Flare Stack C-1 through a water seal at the base of the flare. This seal is one of the flashback protections for the Main Flare - prevents the backflow of gas or air into the flare lines, which could create explosive mixtures. Additional flashback protections are the molecular seal and continuous purge of the flare stack. An on-li ne oxygen analyzer is located between F-3 and 19C-1 and sounds an alarm on high oxygen content in the Unit 200 DCS.

## Vacuum Protection for Refinery Blowdown System

After a hot vapor release through F-3, the water seal in F-3 will be automatically re-established on level control. To ensure flashback from the flar e cannot occur, natural gas is added to F-1 on pressure control (PIC-530) at low pressures. The pressure indicator controller PIC-530 indicates and alarms in the Unit 200 DCS.

Main Flare Purge Gas Requirements

Natural gas supplies purge gas to prevent flashback. The purge gas enters the Main Flare above the water seal at the base of the flare. The mole cular seal prevents both co nvective and diffusional backflow of air into the stack. The proprietary seal design allows some of the rising flare and purge gases to be trapped in the seal. This creates a zone, which is higher than atmospheric pressure and lower in molecular weight than air (lighter t han air). Air cannot backflow through such a zone.

Main Flare Pilots

The stack tip has four electronic spark ignited pilots , each with its own igni tion system. The pilots utilize electronic spark ignition for an automati c re-light function. When the thermocouple on the pilot senses a pilot outage (low thermocouple readi ng), the spark igniter immediately reacts to relight the pilot. After a set period of time, the loss of pilot indication will alarm in the DCS in the Unit 200 control room. Each pilot is equipped with tw o thermocouples, but only one thermocouple is connected to the DCS for control of the electroni c spark system. The other thermocouple is a
spare.

As a back-up system to this aut omatic electronic spark ignition system, each pilot has a manual flame front generator line.

Temperature indicators for each pilot also alarm on low temperature in the Unit 200 DCS to alert the operators that pilot flame-out has possibly occurr ed. If the low temperature alarm remains on because the automatic spark ignition system has not been successful to re-ignite the pilot, an operator is then dispatched to the field to manually operate the flame front generator to re-ignite the pilot.

Smokeless Flaring at Main Flare

A small continuous flow of steam to the flare is provided to prevent a condensate build-up in the steam line and provide cooling to the flare tip. Du ring a flaring event, additional steam is injected at the tip to aspirate air into the flame and ensure smokeless burning of the flare gases. Flow indicators, located on the two flare headers - 10 ′′ header from D-1 and 42 ′′ header from F-1-to the Main Flare stack- detect releases to the flare. These flow indica tors also alarm in the Unit 200 DCS, so that the Unit 200 operators are aware that gas is being released to the flare. A monitor of the flare is located in the Unit 200 control room ; so that the Unit 200 operators can continuously view the flare operation.

## MP-30 Relief and Blowdown System

When the Main Flare is in service, normally only th e MP-30 Complex major releases flow to the MP30 Flare. However, the MP-30 Relief and Blow down System can also handle releases from Coking Unit 200, Crude Unit 267, Gasoline Fractionation, Caustic Treating and Deisobutanizer Unit 215, Diesel Hydrotreating Unit 250, Steam Power Plan t, Hydrogen Plant Unit 110, Fuel Gas Center Unit 233, Sulfur Units, and Isomerization Unit 228, when the Main Flare is down for maintenance. During this maintenance period, the blowdown header s for Units 267, 200, 215, 250, 110, 233, 228, Steam Power Plant, and Sulfur Plant Complex header s can be diverted to Blowdown Drum F-2. Releases to F-2 will flow dire ctly to the MP-30 Flare Stack

Diverting the blowdown headers to F-2 is only done , when Blowdown Drum F-1 and/or Water Seal Drum F-3 must also be inspected or repaired with the Main Flare. If F-1 and F-3 do not have to be inspected when Main Flare is down, a 26 ′′ interconnecting line downstream of F-3 is opened to the 36 ′′ header from F-2. This allows the refinery to keep G-503 Flare Compressor in service during the maintenance of the Main Flare and minimize flaring. Only major releases will break the F-3 water seal and flow through the 26 ′′ interconnecting line to the MP-30 Flare.

MP-30 Complex Blowdown Drum F-600

Releases from the Hydrotreating Units 229 and 230 and Reforming Unit 231 flow to Blowdown Drum F-600. Any liquid releases or entrained liq uid will drop out in F-600. Liquid in F-600 gravitates to F-603 Drain Pot. On high level in F-603, blowdown pumps G-600/601 automatically start. The liquids are pumped by level control through Blowdown Slops C ooler E-600 to the foul water tank, the same foul water tank for the Re finery Relief and Blowdown System. When level in F-603 has dropped to the preset level, the pumps automatically stop.

Minor vapor releases up to 200,000 scf/hr are di verted from F-600 to the Refinery Blowdown System by a fifteen foot water seal in F-604 Wa ter Seal Drum downstream of F-600. These minor releases flow to the Refinery Blowdown System through a 12 ′′ cross-connecting line to the Sulfur Plant/Isomerization Unit common blowdown header. Major vapor releases break the water seal in F-604 and flow through a 42 ′′ /48 ′′ flare header to the MP-30 Flare.

Vacuum Protection for F-600 and F-604

To prevent a vacuum, PIC-601 on F-600 adds natural gas to the MP-30 Blowdown on low pressure. In addition, the pipe entering the F-604 seal leg rise s 19 feet above the top of the 15 foot water seal. Therefore, if a vacuum or partial vacuum occurs in the MP-30 blowdown syst em, water in F-604 will back flow up the seal pipe, but the seal will not be broken.

On low pressure in the flare header, separate pressure controller PIC-658 adds natural gas to the flare line to prevent flashback. A small continuous flow of natural gas through a restriction orifice sweeps the flare line to ensure th e line does not contain any H 2 

## S, NH 3 

## , or other heavier hydrocarbons after flaring ceases.

MP-30 Flare F-2 Blowdown Drum (Partial spare for F-1)

When blowdown headers are lined up to F-2, any ent rained liquids in the vapor releases or any liquid releases to F-2 are knocked out in F-2. F-2 is also a low point in the system. Any liquid that condenses in the 36 ′′ header will flow back to F-2. At a hi gh level in F-2, blowdown pumps G-2A/B automatically start and pump the collected liquid through Cooling Water Exchanger E-2 to the foul water tank. The foul water tank is the same foul water tank as listed for the Refinery Relief and Blowdown System. When a low level in F-2 is aga in reached, the blowdown pumps automatically stop.

## Even when no Unit blowdown headers are lined up to F-2, F-2 must remain in service when the MP-30 Flare is in service. Any high level at the base of the MP-30 flare is gravity drained to F-2. The continuous purge required for the MP-30 Flare Stack to prevent flashback also flows through F2.

MP-30 Flare Operation

The MP-30 flare operates similarly to the Main Flar e. The MP-30 Flare also has four electronic spark ignited pilots. Pilot operation is basically the same as the Main Flare.

The MP-30 Flare also has a molecular seal. The flare tip is 48 ′′ diameter. Natural gas is also used as the purge gas for to prevent flashback. The co ntinuous purge gas requirement of 0.01 ft/sec to the MP-30 Flare Stack is supplied through pressu re regulator PCV-565 and flow restriction orifice FO-523 to 19F-2. The purge gas flows from 19F-2 through the 36 ′′ flare header to the MP-30 Flare. (The minimum purge requirement of 445 SCF/hr for th is flare stack is set by the manufacturer’s molecular seal and flare tip design.)

In addition to the molecular seal and continuous purge, a water seal exists at the base of the flare stack to prevent flashback. The seal is designed to have a continuous water purge of 0.5 gpm. A continuous water purge ensures that any condens ed hydrocarbon vapor that may accumulate is removed from the base of the flare. The continuous water purge and/or any condensed hydrocarbon gravitate from to F-2 fo r removal to the foul water tank.

An on-line oxygen analyzer is located on the main 48 ′′ flare header downstream of the 36 ′′ F-2 flare header and 12 ′′ D-7 header connections. The analyzer s ounds an alarm on high oxygen content in the Unit 200 DCS to warn operators of potentially explosive mixtures in the MP-30 flare system.

Smokeless Flaring at MP-30 Flare

A small continuous flow of steam is provided to t he flare tip to prevent a condensate build-up in the steam line and provide cooling to the flare tip. When flaring occurs, additional steam is injected at the tip to aspirate air into the flame and ensure smokeless burning of the flare gases. Flow indicators, located on the 48 ′′ header from MP-30, the 36 ′′ header from F-2, and the 12 ′′ header from D-7 detect releases to the flare. These flow indicators alarm on high flowrates in the Unit 200 DCS. A monitor of the flare is also located in the Unit 200 control room; so that the Unit 200 boardman can continuously view the MP-30 flare. If there is a flow to the flare or the flare is smoking, the steam to the flare tip is manually increased by the boardman from the Unit 200 DCS.

Hot Coker Blowdown System

The Hot Coker Blowdown system was built with th e Unicracker Complex in 1970. Releases to the hot Coker Blowdown System flow through a 16 ′′ blowdown header to Blowdown Accumulator F-6. Even though the system is described as the Hot Coker Blowdown system, not all releases are hot nor are all releases from Unit 200 Co king Section. Originally, most of the releases to the blowdown system were from relief valves on heater outlets, blowdown lines from heater outlets, and the relief valves on the Unit 200 Coke Drums (hot releases in excess of 650 ° F). However, other factors such as type of material released from a relief valv e (i.e. crude) will also c ause the relief valve to be connected to the Hot Coker Blowdown System. Other Unit 200 connections include Unit 200 Vacuum Tower relief valve, crude feed pump relief valve, various thermal relief valves for heat exchangers, and pump clean-out/ blowdown lines at Unit 200. The Unit 267 Desalter, crude pump relief valves, and Diesel Filter reli ef valves discharge to the Hot Coker Blowdown System as well. Although Unit 233 can relieve to either F-6 or F-3 the primary route is through F-6. This is manually controlled. During periods of fuel gas imbalance the excess clean fuel gas is vented to F-6 through the 10” line.

## Liquid releases to the Hot Coker Blowdown system dr op out in F-6. A high liquid alarm on F-6 that sounds on the DCS alerts the Unit 200 Operators that liquid is flowing to F-6. Operators manually start blowdown drum pump G-61 to pump the liquid to the recoverable oil tank. If the liquid is a hot release, the Operators will divert cooler gas oi l from Unit 200 to the Hot Coker Blowdown header to cool the liquid release before pumping to tankage.

Any vapor that is released from F-6 flows to Blow down Drum D-7. On high temperature in the D-7 overhead line (150 ° F), a water deluge control valve automatically opens to flood water into D-7. A high temperature alarm sounds in the Unit 200 c ontrol room on the DCS and a valve positioner alarm from this control valve sounds on the Un it 200 alarm panel when the deluge valve opens. This alerts operators that a hot release has occurred and additional operator intervention may be required for D-7. Water gravitates through the water deluge control valve from Tank 286 to D-7 and condenses most of the vapor released to D-7 by c ontact with the vapor by flowing over the disc and donut baffles inside D-7. Any vapor not condensed will flow overhead from D-7 to one of the flares for combustion. D-7 overhead is normall y lined up to the Main Flare.

The water and any entrained hydrocarbon liquid will discharge from D-7 through a water seal leg to the process sewer. During any release at the flares or to the Hot Coker Blowdown System, the pressure in D-7 will not exceed 15 psig. This water seal leg ensures that the water seal is not blown during any potential release.

Some of the condensed hydrocarbon in D-7 will separate from the wate r at the base of D-7. The operators manually line up D-7 bottom to the Blowdown Drum Pump G-61 to pump the hydrocarbon liquids from D-7 to the recoverable oil tank.

Gasses from the Hot Coker Blowdown system are recovered if the pressure in the blowdown does not exceed the pressure necessary to blow the water seal in the C-1 Flare Stack Water Seal Drum. Gasses are periodically sent to the flare from th e Hot Coker Blowdown system. This 10” line is monitored with a separate ultrasonic meter.

Capacity of the Relief and Blowdown Systems

The Refinery and MP-30 flare systems are sized to handle releases during refinery-wide utility failures -refinery-wide power failure, total saltwater co oling system failure, or 150 psig steam failure. The maximum design relief case for both these fl are systems is currently a refinery-wide power failure. The design of an individual unit blowdown header may be based on other failures. For example the DIB blowdown header design is based on a refinery-wide salt water failure. The Unit 267 blowdown header design is based on a 150 psig steam failure.

The MP-30 blowdown system (cons isting of F-600, F-604, and MP-30 blowdown header) is sized to handle releases from common utilit y failures for the MP-30 Complex - Units 229, 230, and 231. The two major utility failures, causing the highest relief loads, are power failure and cooling water failure. Power failure creates the highest radiation releas e concern in the flare area, because a refinerywide power failure can cause both the MP-30 Flare and the Main Flare to have large releases. An MP-30 cooling water failure creates the highest back pr essure in the system for certain MP-30 relief valves.

Interrelated Systems

Wet Gas Stream, process units, and compressor - The light ends section of Unit 200, Crude/Coking Unit, processes the bubble tower wet gas and bubble tower raw naphtha stream to produce a stabilized naphtha. Wet gas (high C3 – C5 content) from the bubble tower reflux drum is compressed by the G-501 Wet Gas Compressor, a multi-stage centrifugal compressor. The compressed gas is mixed with the bubble tower raw naphtha. In exchanger E-511, salt water cools

## the combined stream before the stream discharges into the F-502 High-Pressure Separator. Vapor from the high-pressure separator flows to the D-503 Absorber. In D-503, the vapor is contacted with a stripped lean oil which removes the heavier components from the vapor. The scrubbed off-gas from D-503 is then pressure controlled to the light ends sour fuel gas header. The combined sour fuel gas stream from the light ends section fl ows to Unit 233, the Refinery Fuel Gas Center.

The Flare Gas Recovery Compressor (G-503) can be put into Wet Gas Compressor (G-501) service, if needed. This is done on a planned and emergency basis. The value of this is to minimize overall flaring. The “Wet Gas” Compressor runs at a rate much higher than the Flare Gas Recovery Compressor. The Flare Gas Recovery Compressor typically runs at about 50% of the maximum flow on an annual average basis. When the Flare Gas Recovery Compressor is put into Wet Gas Compressor service the entire capacity of th e Flare Gas Recovery Compressor is utilized. Although flaring will likely occur, the total rate of flaring has been minimized by approximately 2.3 MMSCFD by placing the Flare Gas Recovery Comp ressor into Wet Gas Compressor service.

Odor Abatement: stream, process units, and compressor – There is a group of compressors and a closed vent system referred to as the “Odor Abatement” (OA) system. The OA System is a Refinery wide collection system that includes tank blanketing, vacuum towers non-condensable vapor, de-gassing vapors from various processe s, butane tanks vents, and the iso-pentane tank vents. Seasonal ambient temperature incr eases will impact variou s processes causing an increase in flow of material to the OA System. The purpose of the system is to collect and control vapors from the sources lis ted above. Natural gas is purged into the system based on certain set points. Natural Gas as Blanketing Gas for tanks has been used due to low H2S/Sulfur content, nil oxygen content, consistent quality, and low molecular weight. Low molecular weight and low H 2 

## S/Sulfur are only critical to finished low sulfur products. Nil oxygen content is critical for finished product and intermediate products to prevent formation of materials that foul preheat exchangers.

The compressors help maintain pressure in the system and maintain movement of the vapors. The vapors are routed, via the odor abatement compressors directly to Unit 233 Fuel Gas Center. The vapors are co-mingled with other recovered str eams, such as the U200 Wet Gas & Flare Gas Recovery vapors, for sulfur removal.

There are 4 odor abatement compressors. Typicall y, one or two compressors are operating with a third one as backup. A 4th compressor was install ed in 2009. Following the installation of the 4 th 

## compressor, 2 to 3 compressors will typically be oper ated with 1 to 2 spare compressors. The Flare Gas Recovery Compressor can be put into Odor Abatement service, if needed. By utilizing the Flare Gas Recovery Compressor in Odor Abatement service, emissions directly to the atmosphere are mitigated but flaring wi ll likely take place.

F-502 - F-502 which is shown on the PFD shown in At tachment B is related to the Wet Gas Compressor system described above. Gasses collected and compressed in the G-501 Wet Gas Compressor are then sent to the Unit 200 F-502 High Pressure Separator. If the Flare Gas Recovery Compressor (G-503) is utilized in Wet Gas Compressor service then the Flare Gas Recovery Compressor would discharge to the F-502 separator.

### Flare Minimization Plan, BAAQMD 12-12 San Francisco Refinery
BAAQMD Plant 16



# ATTACHMENT C

SAN FRANCISCO REFINERY

FLARE SYSTEM PROCESS FLOW DIAGRAMMAIN FLARE GAS SAMPLER 10" LINE ULTRASONIC FLOWMETER & INDICATORS

42" LINE ULTRASONIC FLOWMETER & INDICATORS MP30 FLARE GAS SAMPLER

MP30 ULTRASONIC FLOWMETER & INDICATORS

36" LINE ULTRASONIC FLOWMETER & INDICATORS

### Flare Minimization Plan, BAAQMD 12-12 San Francisco Refinery
BAAQMD Plant 16



# ATTACHMENT D

SAN FRANCISCO REFINERY

HISTORICAL STARTUP / SHUTDOWN EVENT DATA (2001 – 2006)

Note: This was a one time review. This review was performed as required by 12-12 during the initial submittal. Following the submittal of the init ial FMP Flare RCA’s and turnaround flare planning was conducted to address flare minimization for startup / shutdown activities.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16 

## ATTACHMENT E

Phillips 66

San Francisco Refinery, Rodeo, CA

Unit List

Unit Number Unit Description
40 Raw Materials Receiving Unit
76 Gasoline Blending Unit
80 Refined Oil Shipping Un it
100 Process Water Unit 110 Hydrogen Plant 120 Hydrogen Plant (new in 2009, 3 rd 

## party operated by Air Liquide) 200 Coking Unit 200 Relief and Blowdown System 215 Gasoline Fractionation and Deisobutanizer, and Caustic Treating Unit
228 Isomerization Unit 229 Mid-Barrel Unionfining Unit 230 Naphtha Unionfining Unit 231 Magnaforming Unit
233 Fuel Gas Center 235 Sulfur Unit (new in 2009)
236 Sulfur Unit
238 Sulfur Unit 240 Unicracking Unit 244 Reforming Unit 246 Heavy Oil Hydrocracker (new in 2009)
248 Unisar Unit 250 Diesel Hydrotreating Unit
267 Crude Distillation Unit MTC Marine Terminal Complex
SPP Steam Power Plant

--- Relief and Blowdown System

### Flare Minimization Plan, BAAQMD 12-12 San Francisco Refinery
BAAQMD Plant 16



# ATTACHMENT F

SAN FRANCISCO REFINERY

FLARE MINIMIZATION PROCESS FLOWCHART

### Flare Minimization Plan, BAAQMD 12-12 San Francisco Refinery
BAAQMD Plant 16



# ATTACHMENT G

TYPICAL FLARE GAS RECOVERY SYSTEM

### Flare Minimization Plan, BAAQMD 12-12 San Francisco Refinery
BAAQMD Plant 16



# ATTACHMENT H

SAN FRANCISCO REFINERY

FLARING EVENT OVERVIEW & CATEGORIZATION

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc 

# Prevention Measures Listed in Causal Analysis Submitted to BAAQMD

& Recurrent Failure Analysis

Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? 6/13/2006 Loss of Salt Water

Cooling, G

- 503 Shutdown The G

- 503 Flare Gas Recovery Compressor shutdown due to high gas temperatures from lack of adequate cooling water due to loss of salt wa ter cooling at the refinery. Hydroblast screen cleaning was not done frequently enough and/or not coordinated with low tide cycles. 1. Develop low tide operating plan.

2. Clean intake structure and screens to remove biological growth.

3. Clean mud and debris from pump bays.

4. Schedule Spring/Fall hydroblast cleanings before low tide cycles. 1. COMPLETED 7/21/06

2. COMPLETED 6/13/06

3. COMPLETED 4/1/2007

4. COMPLETED 8/06 Duration: 4 hours

Flow: 551 MSCFD

Emissions:

SO2

– 1,700 lbs (H2S = 1.9%) NMHC

– 220 lbs Methane

– 90 lbs n/a

– FMP not yet in effect 341

- 06

N

Blow back air burst cleaning equipment was not working properly on several intake

screens. Review benefits of higher maintenance frequency for multiple blow valve failures. COMPLETED 10/1/06

Routine operations screen washing is insufficient to manage marine growth on intake screens. Evaluate alternative options for operations screen cleaning, including anti

- foulant coatings. COMPLETED 10/1/06

7/10/06 Unit 228 Shutdown The G

- 503 Flare G as Compressor was shutdown when Unit 228 was shutdown. Unit 228 was shutdown due to the GB

- 520 Hydrogen Compressor shutting down when the electrical circuit tripped, causing the lube/seal oil pumps on the compressor to shutdown. The coil of fiber optic ca ble springing loose and moving the breaker on GB

- 520. 1. Install switch covers.

2. Discuss with contractor the need to secure the fiber optic cable. 1. COMPLETED 7/11/06

2. COMPLETED 7/12/2006 Duration: 7.5 hours

Flow: 990 MSCFD

Emissions:

SO2

– 2,100 lbs (H 2S = 1.3%) NMHC

– 550 lbs Methane

– 315 lbs n/a

– FMP not yet in effect 348

- 06

N

7/23

- 24/06 Unit 228 Startup &

Shutdown The G

- 503 Flare Gas Compressor was shutdown when Unit 228 was shutdown. Unit 228 was shutdown due to the GB

- 520 Hydrogen Compress or shutting down during a PG&E voltage sag. The protective relay at at GB

- 520 interpreted the voltage sag as a reverse power situation and triggered the shutdown. In addition, PSV

- 890 lifted and sent PG&E voltage sag Disabled option that shuts down the compressor during a reverse power situation. COMPLETED 7/23/06 Duration: 17 hours

Flow: 1,340 MSCFD

Emissions:

SO2

– 870 lbs (H2S = 0.38%) NMHC

– 700 lbs Methane

– 350 lbs n/a

– FMP not yet in effect. 376

- 06

N

PSV

- 890 lifted PSV

- 890 was s erviced and the back pressure controller tuned. COMPLETED 7/31/06

10/26

- 11/1/06, 11/7/06, 11/17

- 18/06, & Unicracker

Shutdown, G

- 503 Shutdown, Fuel The main cause of flaring was due to the planned shutdown of the Unicracker C omplex. During this Fuel Gas Out of Balance 1. Use of IERC’s to allow for tem porary higher firing during “fuel gas out of balance period”. 1. COMPLETED

– approx. Jan 2007. Duration: 223 hours

Flow: 46,145 MSCFD n/a

– FMP not yet in effect. 479

- 06

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? 11/22/06 Gas Out of Balance period there were numerous units shutting down, reducing system pressure, purging equipment with steam and nitrogen. In addition, there was a Plant 4 unit upset following startup. Higher firing would result in an increase of the NOx Bubble level. 2. Evaluate permitting options for increasing SPP Turbine SO2 limit during fuel gas out of balance periods in order to minimize or prevent flaring. 2. See Section 3.2 Planned Reductions, Emissions:

SO2

– 8,600 lbs (H2S = 0.3 %) NMHC

– 7,500 lbs Methane

– 8,720 lbs

Plant 4 Repairs Repairs required to be made to complete unit startup & prevent

recurrence. COMPLETED 11/18/06

12/7/06 G

- 503 Maintenance The G

- 503 compressor was shutdown for planned maintenance. In the course of performing routine equipment ch ecks the Reliability group identified a potential issue via an auditory observation. It was believed the issue was with the loader valve positioner so a shutdown was scheduled. Loader Valve Failure 1. Repair valve.

2. Upgrade loader valves which are impacted most significantly by gravitational forces. 1. COMPLETED

– 12/7/06.

2. COMPLETED

- February/March 2007 during G

- 503 overhaul. See Section 4.3.1 in the FMP for additional details. Duration: 86 hours

Flow: 10,264 MSCFD

Emissions:

SO2

– 18,339 lbs (H2S = 1. 14 %) NMHC

– 4421 lbs Methane

– 31 1 5 lbs 4.2.1.1 Flare Gas Recovery Compressor Maintenance

– Minor Maintenance 025

- 07

N

Tarry Substance 1. Investigate source of tarry material through analytical testing. 1. COMPLETED Approx. 12/15/06

– no unusual ma terials discovered. Source indeterminate. Actuator Cylinder Piston Failure 1. Replace failed seal. 2. Conduct regularly scheduled compressor overhaul. Purpose is to perform inspection of equipment and make repairs, as needed. 1. COMPLETED 12/12/06 2. COMPLETED

- February/March 2007. See Section 4.3.1 in the FMP for additional details.

2/24/07 Unit 200

Turnaround & G

503 Shutdown The primary cause for flaring is due to the planned shutdown of Unit 200 Coker & scheduled overhaul of G

- 503 Flare Gas Recovery Compressor. No equipment specific prevention measures identified since these were planned activities.

Turnaround pre & post planning was conducted to review expected flaring & minimization techniques to be implemented. n/a n/a Duration: 257 h ours

Flow: 17,024 MSCFD

Emissions:

SO2

– 34,220 lbs (H2S = 1. 08 %) NMHC

– 10,800 lbs Methane

– 3,000 lbs FMP 4.2.1 Equipment Preparation for Maintenance (Rev 3, p. 4

- 17)

FMP 4.2.1 Preventative Maintenance

– Flare Gas Recovery Compressor Mainten ance (Rev 3, p. 4

- 17) 127

- 07

N

3/18/2007 Failure in Electrical

Power Supply Power Supply Failure at SRUs Ground Fault Relay Failure Replace the faulty relay. COMPLETED Duration: 3.75 hours

Flow: 1,606 MSCFD

Emissions:

SO2

– 12,000 lbs (H2S = 4.45%) NMHC

– 1,200 lbs Methane

– 525 lbs FMP 4.2.1.4 Equipment Failure which Results in an Immediate or Controlled Unit Shutdown (Rev 3, p. 4

- 19) 160

- 07

N

The Refinery MOC/PHA policy does not encompass 1. Eval uate and modify as needed the PHA/MOC process to include 1. COMPLETED 10/3/2007 & on

- going. As part of the EUPHA process loss of

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? electrical design basis reliability electrical power distribution adequacy, redundancy, and reliability.

2. Operations & Engineering to conduct joint process reliability reviews of the Sulfur Plant Complex electrical power distribut ion system. electrical power is considered. MOCs also consider electrical changes.

2. COMPLETED 9/30/08

The Ground Fault Relay did not get tested Identify and provide a p lan to test or replace protective relays that are not normally accessible online or during single unit turnarounds. Review results of all relay testing and respond according to results. COMPLETED 6/30/08. List of inaccessible protective relays & plan for replacement developed.

8/20/2007 Pressure Safety

Valve (PSV) 7 on Raw Hydrogen Line Opened Prematurely Unit 110 Hydrogen Plant PRV Lift and Subsequent Flaring PSV 7 failed and opened prematurely. Replaced with a new valve. 1. COMPLETED

– 8/23/07. D uration: 73.62 hours

Flow: 23,166 MSCFD

Emissions:

SO2

– 21,563 lbs

NMHC

– 10,110 lbs Methane

– 4,840 lbs FMP 4.2.1.4 Upset/Malfunction

– Leaking Relief Valves, PRV Malfunction (Rev. 3, p. 4

- 20)

FMP 4.2.1.4 Other Causes

– i.e. Metallurgical F ailure (Rev 3, p. 4

- 21)

FMP 4.2.1.4 Maintenance, Turnaround, Startup, Shutdown

– Hydrogen Plant Startups (Rev 3, p. 4

- 17) 353

- 07

N

PV 4 Bypass Valve Failed 1. PV 4 bypass was replaced along with a similar type valve in similar service as a precaution

. 2. PV 4 bypass was sent out for metallurgical examination. 1. COMPLETED 8/23/2007

2. COMPLETED 9/25/07 (report received)

– No further actions based on report findings. Venting of H2 to Flare during U110 Startup As described in the Flare Minimization Plan a review will be completed as to the potential benefit of installing a H2 process vent. Global Prevention Measure

- see Prevention Measure section of FMP for current status and plan.

2/22/2008 Unit 110 Shutdown Unit 110 was scheduled for a planned turnaround. During the shutdown Hydrogen is sent to the flare blowdown system. The G

- 503 Flare Gas Recovery Compressor is shutdown when high volumes of Hydrogen are sent to blowdown. No equipment specific prevention measures identified sin ce these were planned activities.

Turnaround pre & post planning was conducted to review expected flaring & minimization techniques to be implemented. n/a n/a Duration: 9.82 hours

Flow: 2,908 MSCFD

Emissions:

SO2

– 11,600 lbs (H2S = 2.40%) NMH C

– 231 lbs Methane

– 1,583 lbs FMP 4.2 Maintenance, Turnaround, Startup, & Shutdown

– Hydrogen Plant Startups (Rev 3 131

- 08

N

8

- Mar

- 08 U231 High Liquid

Volume U231 Startup and High Liquid Volume Shutting down G

- 503 Flare Gas Recovery Compressor New Ad ditional Flare Gas Recovery Compressor

– as part of the CFEP and Flare Minimization Plan (FMP) commitments a redundant flare gas recovery compressor is being installed. The compressor will be able to operate under a wider range of gas composition then th e existing COMPLETED

– August 2009. Duration: 5.25 hours

Flow: 318 MSCFD

Emissions:

SO2

– 1,306 lbs (H2S = 2.5%) FMP 4.2 Maintenance, Turnaround, Startup, & Shutdown

– Unit Startu p (Rev 3, p. 4

- 17)

FMP 4.2 Upset/Malfunction

– Loss of Flare Gas Compressor: High Liquid Level (Rev 3, p. 4

- 20) 227

- 08

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? the existing G

- 503 Compressor. NMHC

– 324 lbs Methane

– 114 lbs 3/9/2008 Unit 110 Startup Unit 110 was scheduled for a planned turnaround. During the shutdown Hydrogen is sent to the flare blowd own system. The G

- 503 Flare Gas Recovery Compressor is shutdown when high volumes of Hydrogen are sent to blowdown. No equipment specific prevention measures identified since these were planned activities.

Turnaround pre & post planning was conducted to review expected flaring & minimization techniques to be implemented. n/a n/a Duration: 4.85 hours

Flow: 1,642 MSCFD

Emissions:

SO2

– 1,960 lbs (H2S = 0.72%) NMHC

– 1,540 lbs Methane

– 600 lbs FMP 4.2 Maintenance, Turnaround, Startup, Shutdown

– Hydrogen Plant Startups (Rev 3, p. 4

- 17) 151

- 08

N

20

- Mar

- 08 U250 LIC359

Improperly Ranged Unplanned Odor Abatement (OA) Compressor Shutdown Switching G

- 503 Flare Gas Compressor into Odor Abatement Service New Additional Flare Gas Recovery Compressor

– as part of the CFEP and Flare Minimization Plan (FMP) commitments a redundant flare gas recovery compressor is being installed. 1. COMPLETED

– August 2009. Duration: 6.83 hours

Flow: 850 MSCFD

Emissions:

SO2

– 3,500 lbs (H2S = 2.66 %) NMHC

– 452 lb s Methane

– 345 lbs FMP 4.2.1.4 Upset/Malfunction

– Loss of other compressors (e.g. odor abatement, etc.) (Rev 3, p. 4

- 20) 225

- 08

N

Faulty Level Indication on LIC359 & LIC360 1. Re

- range level indications on D

- 711 vessel so that full scale is seen in t he DCS. Obtain proper records of calibration offset. 2. Confirm specific gravity on level indications for D

- 711 Vessel. Consider re

- calibration with water to ensure proper configuration parameters are used. 3. Confirm and document any calibration offset pla ced in all level displacer indications at Unit 250. Verify correct specific gravity has been used for each level indication. 4. Evaluate a software alarm with logic verifying if both diesel production meters, FIC378 & FIC388 are reading zero. 1. COMPLETED 3/2 0/08

2. COMPLETED 3/20/08

3. COMPLETED 3 RD Qtr 2009

4. Target 10/1/08 1 st Qtr 2010

Not Identified as a Finding

– Prevention Measure New Odor Abatement Compressor

– as part of the Clean Fuels Expansion Project (CFEP) an additional compressor is being added to provide more capacity. COMPLETED 3 RD Qtr 2009.

14

- Apr

- 08 G

- 503 Flare Gas

Recovery Compressor Constant Voltage G

- 503 Unplanned Shutdown Constant Voltage Transformer (CVT) failure on G

- 503 Flare Compressor

. Replace CVT COMPLETED 4/14/2008 Duration: 7.85 hours

Flow: 618 MSCFD FMP 4.2.1.4 Upset/Malfunction

– Loss of Flare Gas Compressor (Rev 3, p. 4

- 20)

FMP 4.2.1.4 Upset/Ma lfunction

– Equipment 283

- 08

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? Transformer (CVT) Failure Emissions:

SO2

– 2,183 lbs (H2S = 2.13%) NMHC

– 373 lbs Methane

– 258 lbs Failure (Rev 3, p. 4

- 20)

Unplanned Shutdown of the G

- 503 Flare Gas Compressor due to equipment failure New Additional Flare Gas Recovery Compressor

– as part of the CFEP and Flare Minimization Plan (FMP) commitments a re dundant flare gas recovery compressor is being installed. COMPLETED

– August 2009

5/16/2008 Unicracker & Unit

200 Planned Shutdown A planned shutdown was conducted on the Unit 200 Coker/Crude Complex & the Unicracker Complex. During the unit shutdowns there were periods where gas quality and/or quantity could not be recovered by the G

- 503 Flare Gas Recovery compressor. Thus, the Compressor was shutdown at various times when gas quality and/or quantity issues were occurring. No equipment specific
preve ntion measures identified since these were planned activities.

Turnaround pre & post planning was conducted to review expected flaring & minimization techniques to be implemented. n/a n/a Duration: 45.18 hours

Flow: 6,493 MSCFD

Emissions:

SO2

– 24,9 00 lbs (H2S = 2.16 %) NMHC

– 2,201 lbs Methane

– 2,524 lbs FMP 4.2.1.1 Equipment Preparation for Maintenance (Rev 3, p. 4

- 17) 344

- 08

N

5/28/2008 & 6/2/2008 G

- 503 Unplanned

Shutdown The G

- 503 Flare Gas Recovery Compressor (G

- 503) shutdown unexpected ly due to a high liquid level. A G

- 503 shutdown occurred again on June 2, 2008 for the same reason. In each case the compressor was re

started as soon as possible once liquids had been removed from the flare gas recovery system. The primary cause was ex cess butane in the flare gas recovery system. Removed liquids from flare gas recovery system. Made process and equipment adjustments to remove liquids from flare gas recovery systems. COMPLETED 6/2/2008 Duration: 8.75 hours

Flow: 719 MSCFD

Emissions:

SO2

– 3,980 lbs (H2S = 3.0%) NMHC

– 690 lbs Methane

– 218 lbs FMP 4.2.1.4 Loss of Flare Gas Compressor

– High Liquid Level (Rev 3, p. 4

- 20) 345

- 08

N

8/19/2008 G

- 503 Unplanned

Shutdown The G

- 503 Flare Gas Recovery Compressor (G

- 503) shutdown

un expectedly due to a high liquid level in the instrument air system. Flaring occurred while the compressor was down. High liquid level in the instrument air system. 1. Replacement of filters which removes moisture in air system.

2. Updated Operator ro utine rounds form (R

- 049) to include draining air system filters every shift. 1. COMPLETED 9/5/08

2. COMPLETED 8/27/08 Duration: 8.88 hours

Flow: 1,515 MSCFD

Emissions:

SO2

– 4,700 lbs (H2S = 1.3%) NMHC

– 770 lbs Methane

– 780 lbs  Loss of F lare Gas Compressor

– Monitored Safety/Protective Parameter (p. 4

- 20 Rev. 3)

 Loss of Flare Gas Compressor

– High Liquid Level (p. 4

- 20 Rev. 3)

 Loss of Utility

– Air (p. 4

- 20 Rev. 3) 472

- 08

N

10/3/2008 G

- 503 Unplanned

Shutdown for Poor Gas Quality (U11 0 Upset) The G

- 503 Flare Gas Recovery Compressor (G

- 503) was shutdown due to an upset at the U

- 110 Hydrogen Plant (S

- 437). Water in PV

- 92 Valve Positioner 1. Operators are manually blowing down the instrument air header and checking for water daily.

2. Calibration was checked for both PV

- 92 and PV

- 93 and no issues were found. 1. COMPLETED 10/08

2. COMPLETED 10/4/08 Duration: 7 hours

Flow: 1,092 MSCFD

Emissions:

SO2

– 1,570 lbs (H2S = 0.86%) NMHC

– 340 lbs Methane

– 440 lbs Hydrogen Plant PSA operational changes

– Switching from 10 bed to 8 and 5 bed operation 516

- 08

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? 10/22/08 G

- 503 Unplanned

Shutdown for Poor Gas Quality (U110 Upset) The G

- 503 Flare Gas Recovery Compressor (G

- 503) was shutdown due to an upset at the U

- 110 Hydrog en Plant (S

- 437) pressure swing adsorber (PSA). During the upset at U

- 110, gases sent to the flare gas recovery system could not be recovered by the G

- 503 compressor. PV

- 93 stuck in closed position when the valve over

stroked. 1. Maintenance improved t he engineering design and modified the mechanical stops on PV

- 92 and PV

93 to prevent the valves from over

stroking. 1. COMPLETED 10/24/08 Duration: 4.33 hours

Flow: 2,120 MSCFD

Emissions:

SO2

– 320 lbs (H2S = 0.09%) NMHC

– 400 lbs Methane

– 6 50 lbs Hydrogen Plant PSA operational changes

– Shutdown of PSA 523

- 08

N

11/1/2008 G

- 503 Unplanned

Shutdown The G

- 503 Flare Gas Recovery Compressor (G

- 503) was shutdown due to plugging of the compressor discharge line. During the period when the compr essor was shutdown, gases sent to the flare gas recovery system could not be recovered and flaring occurred. G

- 503 discharge valve failed to open 1. Steam out of discharge piping scheduled for every 6

– 8 months to prevent material buildup

2. Addition of new Flare Gas Recovery Compressor (item noted after RCA submitted & once it was determined periodic steaming cannot be performed

on

- line) 1. COMPLETED initially 11/2/08. Later determined this piping can only be steamed out while G

- 503 is down.

2. COMPLETED Augu st 2009. Duration: 27.5 hours

Flow: 3,744 MSCFD

Emissions:

SO2

– 18,900 lbs (H2S = 3.05%) NMHC

– 2,480 lbs Methane

– 1,380 lbs Loss of flare gas compressor

– monitored protective parameter triggered shutdown 579

- 08

N

1/14/2009 G

- 503 Un planned

Shutdown for Poor Gas Quality (U110 Upset) The G

- 503 Flare Gas Recovery Compressor (G

- 503) was shutdown due to the unscheduled shutdown of the U110 Hydrogen Plant. Excess hydrogen in the flare gas recovery system can damage the G

- 503 compressor. Du ring the period when the compressor was shutdown, gases sent to the flare gas recovery system could not be recovered and flaring occurred. Lack of motor bearing lubrication 1. Review and Update the Oil Condition check procedure for limits on oil quantit ies removed while equipment is in service.

2. Update Reliability Activities Requiring Work Order Procedure for situations where significant oil is to be removed from bearings while equipment is in service.

3. Provide refresher training on these procedu res. 1. COMPLETED Aug 2009

2. COMPLETED July 2009

3. COMPLETED Aug 2009 Duration: 9.92 hours

Flow: 1,459 MSCFD

Emissions:

SO2

– 4,280 lbs (H2S = 1.77%) NMHC

– 150 lbs Methane

– 1,020 lbs  Maintenance, Turnaround, Startup, Shutdown

– Hydrogen Pla nt Shutdown (Section 4.2.1.1)

 Upset/Malfunction

– Equipment failure which results in a unit shutdown (Section 4.2.1.4) 089

- 09

N

1/17/2009 U110 Startup / G

503 Shutdown The Unit 110 Hydrogen Production Plant was down for a turnaround. During the sta rt up of the Hydrogen Reformer Plant hydrogen is vented to the blowdown system. Unit 200 began recirculating the G

- 503 Flare Gas Recovery Compressor due to the high volume of hydrogen being sent to the recovery system. This results in flaring of all gase s typically recovered through the G

- 503 compressor as well as the excess raw Hydrogen. No equipment specific prevention measures identified since these were planned activities.

Turnaround planning was conducted to review expected flaring & minimizatio n techniques to be implemented. n/a n/a Duration: 3.6 hours

Flow: 1,433 MSCFD

Emissions:

SO2

– 1,550 lbs (H2S = 0.65%) NMHC

– 180 lbs Methane

– 960 lbs  Section 4.2

- Maintenance, Turnaround, Startup, Shutdown

– Hydrogen Plant Startups (p. 4

- 17) 92

- 09

N

1/26/09 G

- 503 Shutdown

(low quality gas) The G

- 503 Flare Gas Recovery Compressor (G

- 503) was shutdown due to planned nitrogen purging of drum, D

- 403C, at the U240 Hydrogen No equipment specific prevention measures identified since the se were planned activities. n/a n/a Duration: 7.12 hours

Flow: 1,441 MSCFD  Section 4.2.1.4 Maintenance, Turnaround, Startup, Shutdown

– Equipment Preparation for Maintenance (Section 4.2.1.1) 094

- 09

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? Plant. Turnaround planning was conducted to review expected flaring & minimization techniques to be implemented. Emissions:

SO2

– 2,220 lbs (H2S = 0.9%) NMHC

– 370 lbs Methane

– 830 lbs March 2

– 9, 2009 Major Unicracker

Turnaround A planned shutdown was conducted at the Unit 240 Unicracker Complex in order to perform scheduled maintenance on several units. During this shutdown, there were periods where flare gas quality and/or quantity could not be recovered by the G

- 503 Flare Gas Recovery Compressor. No equipment specific prevention measures identif ied since these were planned activities.

Turnaround planning was conducted to review expected flaring & minimization techniques to be implemented. n/a

– turnaround related n/a Duration: 100 hours

Flow: 29,488 MSCFD

Emissions:

SO2

– 66,500 lbs (H2 S = 1.33%) NMHC

– 13,994 lbs Methane

– 10,645 lbs  Section 4.2.1.1 Maintenance, Turnaround, Startup, Shutdown

– Equipment Preparation for Maintenance (Section 4.2.1.1) 139

- 09

N

March 14

– 28, 2009 Flare System

Maintenance A planned shutdown was conducte d on the Main Flare (S

- 296) and equipment associated with the flare. The purpose of the shutdown was to conduct preventative maintenance work on the Main Flare and to conduct a required vessel inspection on the F

- 3 Water Seal drum on the Main Flare system

. No equipment specific prevention measures identified since these were planned activities.

Turnaround planning was conducted to review expected flaring & minimization techniques to be implemented. n/a

– turnaround related n/a Duration: 298.25 hours

Flow: 77,470 MSCFD

Emissions:

SO2

– 218,512 l bs NMHC

– 29,092 lbs Methane

– 36,183 lbs  Maintenance, Turnaround, Startup, Shutdown

– Equipment Preparation for Maintenance & Working on Equipment (Section 4.2.1.1)

 Reduced Consumption of Fuel Gas

– Fue l Gas Imbalance (Section 4.2.1.3) 197

- 09

N

March 27

– 28, 2009 Odor Abatement

Compressor Upset One of three odor abatement compressors, G

- 60C, shut down. Unit 200 operators and maintenance personnel attempted to re

- start the compressor a number of time s during the evening shift. The G

- 60A compressor was already down for planned maintenance. This left only one of the three odor abatement compressors, G

- 60B, in operation. The facility Standard Operating Procedure (SOP) to switch the G

- 503 Flare Gas Rec overy Compressor from Flare Gas Recovery service to Odor Abatement service was implemented. Switching G

- 503 Flare Gas Compressor into Odor Abatement Service 1. A New redundant Flare Gas Recovery compressor is being installed as part of the CFEP and Fla re Minimization Plan (FMP) commitments. 2. Addition of a new 4 th Odor Abatement Compressor 1. COMPLETED August 2009

2. COMPLETED August 2009 Duration: 43 hours

Flow: 6,428 MSCFD

Emissions:

SO2

– 1,359 lbs (H2S = 0.18%) NMHC

– 3,135 lb s Methane

– 2,629 lbs  Upset/Malfunction

– Loss of other compressors (e.g. odor abtement, etc.) (Section 4.2.1.1)

 Reduced Consumption of Fuel Gas

– Fuel Gas Imbalance (Section 4.2.1.3) 196

- 09

N

E

- 11A

- 2 Leak 1. Replace shell of E

- 111A

- 2. 2. Upgrade metallur gy of the E

111A

- 2 exchanger. 3. Condenser system maintenance such as anode replacement for each exchanger and downcomer piping replacement. 3 COMPLETED mid

- April 2009 3 COMPLETED mid

- April 2009

. 3 COMPLETED mid

- April 2009.

3/29/09 Fuel Gas Imbalance A planned shutdown was conducted at the Unicracker Complex to perform scheduled maintenance on several No equipment specific prevention measures identified since these were n/a

– turnaround related n/a Duration: 162 hours

F low: 8,836 MSCFD  Reduced Comsumption of fuel gas

– Fuel Gas Imbalance (Section 4.2.1.3) 198

- 09

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? units. During this turnaround, approximately 30% of the refinery fuel gas consumers were out of service. This resulted in periods of fuel gas imbalanc e. planned activities.

Turnaround planning was conducted to review expected flaring & minimization techniques to be implemented. Emissions:

SO2

– 147 lbs (H2S = 0.01%) NMHC

– 6,791 lbs Methane

– 2,375 lbs 4/19/09 Major Unicracker

Turnaround A planned shutdown was conducted at the Unicracker Complex to perform scheduled maintenance on several units. On April 19, 2009 from 3:50 PM until 9:10 PM there was flaring due to high gas quantity during the Unicracker unit startup. i the turnaround. Exceeding G

- 503 Flare Gas Compress or capacity. 1. New redundant Flare Gas Recovery compressor, as part of the CFEP and Flare Minimization Plan (FMP) commitments, a redundant flare gas recovery compressor is being installed. The compressor will provide additional capacity during most pe riods of operation. Duration: 5.42 hours

Flow: 751 MSCFD

Emissions:

SO2

– 318 lbs (H2S = 0.25%) NMHC

– 194 lbs Methane

– 411 lbs  High base/continuous load (Section 4.2.1.2)

 Reduced consumption of fuel gas

– fuel gas imbalance (Section 4.2.1.3) 211

- 09

N

5/6/09 Unplanned

Shutdown of Plant 2 The Unicracker Plant 2 experienced an unplanned shutdown due to the auto initiation of a safety system shutdown. The safety shutdown triggered the release of pressure from the reaction section of Plant 2 to the flare. Catalyst bed collapse 1. Dump, screen, and reload catalyst. COMPLETED approximately May 20, 2009 Duration: 5 hours

Flow: 1,674 MSCFD

Emissions:

SO2

– 30 lbs (H2S = 0. 01 %) NMHC

– 975 lbs Methane

– 490 lbs  Upset/Malfunction

– Equ ipment Failure which Results in a Controlled Unit Shutdown (Section 4.2.1.4) 270

- 09

N

5/10/09 Plant 2 Shutdown Flaring occurred in association with maintenance being performed at the Unicracker Plant 2. The maintenance scheduled was to address the fai lure which occurred May 6 th

. Same as 5/6/09 event Duration: 44 hours

Flow: 16,809 MSCFD

Emissions:

SO2

– 453 lbs (H2S = 0.01%) NMHC

– 8,658 lbs Methane

– 3,386 lbs  Equipment Preparation for Maintenance

– Depressurization of Equipment & Pressurization of Equipment with Nitrogen (Section 4.2.1.1)

 Reduced Consumption of Fuel Gas (Section 4.2.1.3) 278

- 09

N

5/23/09 Fuel Gas Imbalance On May 23, 2009 there was a period of fuel gas imbalance in which treated fuel gas was vented to the flare. No equipment specific prevention measures identified since these were planned activities.

Turnaround planning was conducted to review expected flaring & minimization techniques to be implemented. n/a

– turnaround related n/a Duration: 6.5 hours

Flow: 1,092 MSCFD

Emissions:

SO2

– 20 lbs (H2S = 0.01%) NMHC

– 1,000 lbs Methane

– 350 lbs Reduced Comsumption of fuel gas

– Fuel Gas Imbalance (Section 4.2.1.3) 279

- 09

N

8/10/09 .Fuel Gas

Imbalance On 8/10/09 there was a fuel gas system upset that resulted in high levels of Hydrogen Sulfide (H2S) in the refinery fuel gas. The Federal limit for H2S in fuel gas is 162 ppm (3

- hr rolling average). The recorded levels of H2S Implementation of EOP

- 15 ‘High H2S Content in the Refinery Fuel Gas System”. High sulfur fuel gas was temporarily flared and offset with natural gas. Replace orifice plate on D

- 803 Amine Regenerator. COMPLETED 8/11/09 Duration: 4.5 hours

Flow: 600 MSCFD

Emissions: Reduced Consumption of Fuel Gas

– Fuel Gas Imbalance (Section 4.2.1.3) 359

- 09

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? during this period ranged from 170

- 240 ppm (3

- hr rolling average), during which time Emergency Operating Procedure EOP

- 15 was implemented. Wrong type Orifice plate in the new D

- 803 Amine Regenerator Steam Supply to the Reboiler. SO2

– 160 lbs (H2S = 0.16%) NMHC

– 290 lbs Methane

– 140 lbs

9/25/09 Unit 246 G

- 803

Make

- Up Compressor Relief Valve Lift On 9/25/09 at approximately 8:25am, the G

- 503 Flare Gas Recovery Compressor began to load up & the unit operators noticed that the sp ecific gravity of the gas was very low. In addition, the molecular weight of the flare gas dropped considerably. The G

- 503 Flare Gas Compressor was taken off

- line to protect the
compressor. Unit 246 G

- 803 Make

- Up Compressor Relief Valve lifted due to inc orrect valve seat material Replaced relief valve seating material in valve which relieved and those in similar service. COMPLETED 9/29/09 (all relief valves) Duration: 8 hours

Flow: 1,020 MSCFD

Emissions:

SO2

– 1,600 lbs (H2S = 0.97%) NMHC

– 230 lbs Methane

– 180 lbs Upset/malfunction

- PRV malfunction (Section 4.2.1.4)

Upset/malfunction

- Fuel Quality Upset (4.2.1.4) 441

- 09

N

09/29/09 Unplanned Unit 110

Shutdown & Startup The Unit 110 Hydrogen Production Plant shutdown unexpectedly on 9/28/10. The unit was started up the same day. When the Hydrogen Plant is started up there is a period of time in which the raw Hydrogen is sent to the blowdown system until the Hydrogen meets the necessary purity to be routed to the Hydrogen header. The fuel g as quality is not sufficient for recovery when there is Hydrogen in the blowdown system. The No. 152 relay on the C

- 1 Feed Gas Compressor failed. The failure of the relay resulted in a safety shutdown of the unit being triggered. Replacement of the No. 15 2 relay. COMPLETED 9/28/09 Duration: 4.3 hours

Flow: 1,520 MSCFD

Emissions:

SO2

– 2,855 lbs (H2S = 1.13%) NMHC

– 194 lbs Methane

– 317 lbs Maintenance, Turnaround, Startup, Shutdown

– Hydrogen Plant Startups 414

- 09

N

10/05/09 Unit 246 Relief

Valve Lift During the early morning of 10/5/09 it was discovered that the relief valve on top of the Unit 246 Cold High Pressure Separator, F

- 801, was leaking to the MP

- 30 Flare. The leaking relief valve is PSV

- 05A/ PSV 05A Lifting. Remove from service, perform maintenance, seat lapped. COMPLETED 10/6/09 Duration: 3.3 hours

Flow: 300 MSCFD

Emissions:

SO2

– 115 lbs (H2S = 0.23%) NMHC

– 16 lbs Methane

– 3 lbs Leaking relief valves, PRV malfunction

– Upset/Malfunction (Section 4.2.1.4) 473

- 09

N

11/16/09 Unplanned Unit 244

shutdown. During the morning of 11/16/09 a small flange fire occurred at the Unit 244 Reformer. The unit pressure was dumped to the flare for a unit shutdown, which resulted in flaring. E

- 501B Exchanger Leak. While the unit wa s down the exchanger flange was tightened & a chemical sealant was applied. COMPLETED 11/19/09 Duration: 5.5 hours

Flow: 830 MSCFD

Emissions:

SO2

– 615 lbs (H2S = 0.4%) NMHC

– 435 lbs Methane

– 140 lbs Equipment failure which results in the unp lanned shutdown of a unit

– Upset/Malfunction (4.2.1.4) 050

- 10

N

02/23/10 Unit 110 Hydrogen

Plant Scheduled shutdown On 2/23/10, steps were taken to shutdown Unit 110 Hydrogen Production Plant for a scheduled shutdown. Unit 110 communicated to Unit 200, responsible for the flare, that n/a

- Planned Shutdown No equipment specific prevention

measures identified since these were planned activities. n/a

– planned turnaround Duration: 4 .5 hours

Flow: 1,060 MSCFD

Emissions: Maintenance, Turnaround, Startup, Shutdown

– Hydrogen Plant Startups. 136

- 10

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? Hydrogen would be sent to the fuel gas recovery system so that the amt of time the fuel gas recovery compressors were put on circulation would be minimized. SO2

– 6 50 lbs (H2S = 0.4%) NMHC

– 180 lbs Methane

– 470 lbs 03/11/10 Unit 240 Plant 2

Planned Shutdown with Upset On 3/11/10 Unit 240 Plant 2 Hydrocracker was starting up after a brief planned shutdown. During the startup, approx 2 hrs after feed had been introduced, the recycle compressor shu tdown. This resulted in the unit depressuring to the flare. 2F

- 201 High Pressure Separator level indicator is calibrated for normal operating feed, not feed used during startup. Turnaround startup procedure updated to require visual monitoring of sight gl ass level. COMPLETED 3/15/10 Duration: 0.3 hours

Flow: 485 MSCFD

Emissions:

SO2

– 1,050 lbs (H2S = 1.3%) NMHC

– 170 lbs Methane

– 250 lbs Upset/Malfunction

– Loss of a Major Compressor (4.2.1.4) 185

- 10

N

3/20/10 Unit 110 Startup

and U 200 High Flow Conditions On 3/20/10 Unit 110 Hydrogen Plant was scheduled to be started up. Prior to the startup there was high flow to the G

- 503 and G

- 540 compressors. The Comrpessors were shutdown due to high flow and poor gas quality. The Unit 110 st artup subsequently occurred which resulted in off

- spec hydrogen being sent to blowdown. The high flow prior to the Unit 110 shutdown was due to a Unit 200 D

- 203 Drum Wedge Plug Valve which was found to be cracked
open. Reinforce and review Wedge Plug Ope ration with Drum Switcher qualified operators. COMPLETED 5/15/10 Duration: 5.5 hours

Flow: 1,569 MSCFD

Emissions:

SO2

– 2,605 lbs (H2S = 1.0%) NMHC

– 322 lbs Methane

– 845 lbs High Base/Continuous Load (4.2.1.2) Maintenance, Turnaround, Startup , Shutdown

– Hydrogen Plant Startups (4.2.1.1) 198

- 10

N

4/27/10 Unplanned

Shutdown of 3 rd Party Hydrogen Supplier On 4/27/10 the 3 rd party Hydrogen Plant that provides a significant portion of hydrogen to the refinery experienced an unplanned shutdown. This resulted in intermittent flaring. As reported by the 3 rd party Hydrogen Supplier, the shutdown was due to a technician performing LDAR monitoring pulling a tag off of a control valve. The tag was attached to the actuator tubing for the control valv e and when pulled the tubing came unattached, which resulted in the control valve assuming the fail safe position and shutting down hydrogen production. The 3 rd party Hydrogen supplier trained their employees and their LDAR contractor on proper location s to hang tags. They also trained them on proper ways for tag removal (cutting, not pulling) COMPLETED approx. 5/30 Duration: 29.75 hours

Flow: 2,656 MSCFD

Emissions:

SO2

– 1,354 lbs (H2S = 1.59

- 0.01%) NMHC

– 1,455 lbs Methane

– 985 lbs Fuel a nd Hydrogen Gas Balance (4.2.1.1)

– unplanned Huydrogen supplier shutdowns. 223

- 10

N

6/7/2010 Unit 110 Planned

Shutdown Unit 110 was scheduled for a planned turnaround. During the shutdown Hydrogen is sent to the flare blowdown system. The G

- 503/540 Fl are Gas Recovery Compressors are shutdown when high volumes of Hydrogen are sent to blowdown. n/a

– Planned Shutdown No equipment specific prevention measures identified since these were planned activities. n/a Duration: 6.83 hours

Flow: 2,520 MSCFD

E missions:

SO2

– 1,140 lbs (H2S = 0.3%) NMHC

– 340 lbs Methane

– 970 lbs Maintenance, Turnaround, Startup, Shutdown

– Hydrogen Plant Startups & Shutdowns 249

- 10

N

7/20/10 PG&E Voltage Sag A voltage sag occurred in the third

party power supply. This resulted in flaring due to the loss of the flare The third

- party supplier has been unable to identify the root cause of the voltage No specific prevention measures were identified by ConocoPhillips because the primary cause was the voltage sag n/a Duration: 21.63 hours

Flow: 1,220 MSCFD Upset/Malfunction

– Loss of a Utility 349

- 10

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? compressors and some other major pieces of equipment. In addition, a number of units had to be shutdown following the voltage sag. This resulted in the flaring of unscrubbed
gas. sag. in the electricity supplied by the third

party utility supplier.

Con ocoPhillips did meet with PG&E about the potential cause of the failure and power dips. PG&E reported they are undertaking a Modular Protection Automation & Control (MPAC) upgrade. This will replace all of the existing 115kV solid state relays with the latest microprocessor based relay standard to provide more line reliability and quick diagnostic tools. During a meeting with PG&E COP Business Manager also requested PGE to perform additional surveillance and increase the frequency of the preventative maintenance programs to the Oleum

Martinez and Oleum

- Christy line Emissions:

SO2

– 3,540 lbs (H2S = 2.27%) NMHC

– 880 lbs Methane

– 270 lbs

8/13/10 Un it 110 Startup &

F

- 3 Work The Unit 110 Hydrogen Production Plant started up after a shutdown period on August 13, 2010. Per the Unit 110 start

- up SOP, Unit 200 began

re

- circulating the Flare Gas Recovery Compressors due to the high volume of hydrogen bei ng sent to the recovery system, which can damage the compressor and decrease the Btu content of recovered gas. Re

circulating the compressors results in flaring of all gases typically recovered through the compressors as well as the excess raw Hydrogen. This resulted in the flaring of unscrubbed
gas. n/a

- Planned Shutdown No equipment specific prevention measures identified since these were planned activities. n/a

– planned turnaround Duration: 6.32 hours

Flow: 2,610 MSCFD

Emissions:

SO2

– 4,870 lbs (H2S = 1.1%) NMHC

– 1,320 lbs Methane

– 940 lbs Maintenance, Turnaround, Startup, Shutdown

– Hydrogen Plant Startups. 393

- 10

N

9/3/10 Unit 110 Startup &

F

- 3 Work During this flaring event, two separate work activities were coordinated in order to minimize flaring. This resulted in one flaring event of unscrubbed gas instead of two different events had the activities been completed at different times and decreased the amount and duration of flaring that otherwise would have occurred.

The Unit 110 Hydrogen Production Plant started up on September 3, 2010 after a brief shutdown period. Prior to the startup of Unit 110, it was determined that maintenance was n/a

- Planned Shutdown No equipment specific prevention measures identified since these were planned activities. n/a

– planned turnaround Duration: 5 hours

Flow: 1,619 MSCFD

Emissions:

SO2

– 2,650 lbs (H2S = 1%) NMHC

– 750 lbs Methane

– 340 lbs Maintenance, Turnaround, Startup, Shutdown

– Hydrogen Plant Startups. 430

- 10

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? required on the F

- 3 Water Seal Drum, which is an integral vessel in the Fuel Gas Recover y System. This work, which involved replacing the F

- 3 drain piping, was conducted during the Unit 110 startup to minimize flaring at the refinery. Had the F

- 3 work been conducted on its own, it would have resulted in flaring due to the need to shutdown t he Fuel Gas Recovery Compressors. The coordination of these two activities minimized flaring from the refinery.

9/13/10 AL Unplanned

Shutdown The Refinery’s third

- party Hydrogen Plant, Air Liquide, experienced an unplanned shutdown. As reported by Air Liquide, the cause of the shutdown was due to a faulty thermocouple on an Induced Draft (ID) fan bearing which resulted in loss of hydrogen production from this source. T he Refinery had one of its two hydrogen plants in operation at the time. The Refinery’s larger hydrogen plant was down for maintenance. The loss of Hydrogen from Air Liquide resulted in multiple refinery upsets. Unit 246, Unit 250 and Unit 240 Plant 2 S econd Stage Charge were shutdown. Due to the loss of hydrogen and subsequent shutdown of units and rate reductions, the fuel gas system pressured up, which resulted in flaring. The flaring was of a combination of scrubbed and unscrubbed gas. Third part y unplanned shutdown

The third party supplier provided cause and corrective action:

The Multilin controller for the ID Fan motor shutdown on a high temperature indication at the bearing. The plant was operating normally at 67% capacity. When the Multil in motor protection relay indicated a high termpature on temperature probe No. 7 (motor bearing) the relay stopped the motor, per design.

The root casue was determined to be an installation issue where a larger gauge wire was installed on a smaller guag e terminal block connectior. When the ID Fan and motor was replaced in 12/09, the new wire was not equal to the original installation and it was not well secured by the knife blade terminal block connector. No specific prevention measures were identifie d by ConocoPhillips because the primary cause was the voltage sag in the electricity supplied by the third

party utility supplier.

Third party corrective actions:

1. Terminal block incorrect size for installed wiring on C

- 102 motor. Replace terminal bloc k with one that accepts installed wiring size.

2. Verify wiring terminal block on C

101 motor is correct. Replace terminal block with one that accepts installed wiring size.

3. Wiring may become loose. Epoxy seal new wiring terminal block to prevent term inals from coming loose.

4. Installed instrument cable was not sized correctly for motor RTD terminals. Develop QA inspection procedure for acceptance of newly installed or replaced instrumentation.

5. Personnel with limited access to the Mulitlin software and training to support plant personnel. Identify sufficient personnel resources and have them trained to access Multilin software. See the corrective actions associated with the 10/22/2010 event. After repeated events with the shutdown of the 3 rd Pa rty H2 Plant measures were put in place to minimize impact of recurrence.

Third party corrective action status. 1. COMPLETED 9/13/2010

2. COMPLETED 9/13/2010

3. COMPLETED 9/13/2010

4. COMPLETED 6/13/2011

5. COMPLETED 12/31/2010 Duration: 3.22 hours

Flow: 600 MSCFD

Emissions:

SO2

– 2,340 lbs (H2S = 2.34%) NMHC

– 430 lbs Methane

– 180 lbs Fuel and Hydrogen Gas Balance (4.2.1.1)

– included unplanned Hydrogen supplier shutdowns 436

- 10

N (3 rd party)

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ?

9/25/10 Unit 240 G

- 425

Level Indicator Failure On September 25, 2010 at approximately 3:14 P.M. an increase in fuel gas system pressure led to flaring of treated fuel gas. At approximately 4:30 P.M. the G

- 503 Fuel Gas Recovery Compressor was circulated due to high liquid level. Alt hough the G

- 540 Compressors were in operation, the circulation of the G

- 503 Compressor resulted in flaring of unscrubbed gas. Unit 240 Plant 4 LIC 429 Level Controller Malfunction 1, Operate the F

- 429 Knock Out Drum in manual (i.e. take 4 LIC 429 out of service) COMPLETED 9/25/10 Duration: 4.32 hours

Flow: 354 MSCFD

Emissions:

SO2

– 791 lbs (H2S = 1.35%) NMHC

– 200 lbs Methane

– 100 lbs

 Upset/Malfunction

– Failure of Instrumentation

 Upset/Malfunction

– Loss of Fuel Gas Recovery Compressor / High Liquid Level 431

- 10

N

10/6/10 3 rd Party Hydrogen

Plant Unexpected Shutdown At approximately 4:40 PM the Refinery’s third

- party Hydrogen Plant, Air Liquide, experienced a sudden shutdown. As reported by Air Liquide, the cause of the shutdown was due to a valve issue on their Pressure Swing Adsorber (PSA). When the PSA valve stuck it led to a shutdown of their Reformer Heater due to high firebox pressure. The Refinery had one of its two hydrogen plants in operation at the time. The Refinery’s la rger hydrogen plant was down for maintenance. The loss of Hydrogen from Air Liquide resulted in multiple refinery upsets. Feed was removed from Unit 246, Unit 250 and Unit 240 Plant 2 Second Stage Charge. Due to the loss of hydrogen and subsequent shutd own of units and rate reductions, the fuel gas system pressured up, which resulted in flaring of scrubbed and unscrubbed
gas.

Following the Air Liquide Hydrogen Plant shutdown, approximately 20 MMSCFD of fuel and feed gas that is normally supplied by th e refinery to Air Liquide was diverted to the refinery fuel gas system. This excess gas caused the refinery fuel gas system to pressure up which resulted in approximately 674 MSCF of sweet fuel gas being sent to the flare from October 6 to 8, 2010. Durin g the upset a relief valve (PSV 069) at Unit 240 Plant 2 relieved prematurely. Its setpoint is 290 psig, it relieved at approximately 250 psig. This resulted The primary root cause was due to the sudden shutdown of the third

- party Hydrogen Plant. As described above, ConocoPhillips did implement measures to minimize flaring during the upset. Listed below is a prevention measure completed in respect the the relief valve which lifted following the upset.

The third party H2 Plant supplier did provide root cause and corrective actions.

The Steam Methane Reformer tripped on high box pressure when the PSA went from 12

- bed to 10

- bed operation. The root cause of the trip was inadequate PV

1611 response. The response resulted in a feedback mismatch of greater than 20% that exceeded 7 seconds. This feedback mismatch caused the PSA to go from 12 to 10

- bed. The consequential disturbance in off

- gas flow as the PSA adju sted to the new operating mode then caused an upset in the furnace pressure control ultimately leading to a plant trip. Inspect and repair PSV069.

See the corrective actions associated with the 10/22/2010 event. After repeated events with the shutd own of the 3 rd Party H2 Plant shutdown, measures were put in place to minimize impact of recurrence.

The third party supplier provided the following prevention measures.

1. Operators have to reduce PC

412A (off gas flare relief) from 6 psi to 4 psi to ac count for high off gas pressure. Investigate feasibility and implement a DCS response based on PSA signal of bed switch over event. 2. C

- 102 damper actuator responds slowly.

a. Tune PC

- 402 damper system. b. C

- 102 damper inspection/discovery is scheduled. 3. Initiat ing event for PSA beds tripping off, not logged. Ensure alarm logger is running while plant is up. 4. No means of monitoring valve

on

- line performance. Investigate feasibility of AMS. 5. PSA UOP specifications do not match valve specifications. Investigate ch anging valve COMPLETED , approximately during the week of 10/6/2010

Status of corrective actions provided by Third party

1. COMPLETED 6/15/2011

2.

a. COMPLETED 6/15/2011

b. COMPLETED 6/15/2011

3. COMPLETED 10/8/10

4. COMPLETED 12/31/10

5. COMPLETED 6/15/2011 Duration: 31.5 hours

Flow: 1,815 MSCFD

Emissions:

SO2

– 4,650 lbs (H2S = 1.56%) NMHC

– 1,110 lbs Methane

– 535 lbs Fuel and Hydrogen Gas Balance

– including unplanned Hydrogen supplier shutdowns 473

- 10

N (3 rd party)

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? in additional flow, primarily Hydrogen, to the flare from 6:00 PM until 8:00 PM on October 6, 20 10. Prior to the Air Liquide shutdown the G

- 503 Fuel Gas Recovery Compressor was down for maintenance. The G

- 540 Fuel Gas Recovery spare compressors were in service. During the upset the G

- 540 Fuel Gas Recovery compressors remained operational. specifications to match UOP and monitoring valve local alarms. 6. Possible contamination. Inspection of IA header scheduled for turnaround. 7. PSA has not been tuned at higher rates. Tune PSA bed at higher rates. 6. COMPLET ED 6/15/2010

7. COMPLETED 11/15/2010

10/22/10 3 rd Party Hydrogen

Plant Unexpected Shutdown, Cogen and Refinery Shutdown The Refinery’s third

- party Hydrogen Plant, Air Liquide, that provides a significant portion of hydrogen to the refinery, experienced a sudden shutdown. The shutdown of the Hydrogen Plant led to the shutdown of several process units and the refinery Steam Power Plant (SPP). Without steam, the majority of the refinery units were required to shutdown. These shutdowns resulted in flaring of scrubbed and unscrub bed gas on October 22, 2010 which then continued intermittently until October 23, 2010. Air Liquide Shutdown 1. COP intends to operate Plant 4 Hydrogen Plant until Air Liquide completes actions to improve reliability. 2. COP has teamed with Air Liquide in an eng ineering study to improve reliability. 1. COMPLETED.

2. COMPLETED during 2011 2 nd Qtr 2011 t/a. Duration: 29 hours

Flow: 12,657 MSCFD

Emissions:

SO2

– 17,422 lbs (H2S = 0.66%) NMHC

– 4,330 Methane

– 2,745 Fuel and Hydrogen Gas Balance including

u nplanned Hydrogen supplier shutdowns

Upset/Malfunction Loss of Utility (steam, air, cooling water, power) 475

- 10

N (3 rd party)

Fuel Gas System Pressure Increased 1. Identify and implement solutions for fuel gas system pressure increase when AL shutdow n. 2. Revise the Refinery Emergency Operating Procedure (EOP

- 21) to better address AL shutdowns. 1. COMPLETED

– PRV added during June 2011 t/a to divert fuel gas to flare during upset. 2. COMPLETED 3/1/2011

Condensate blowin into GT23C by air purge 1. Revised the SPP Turbine emergency shutdown procedure to block in the steam injection for all operating turbines if the steam injection is lost for any

reason. 2. Evaluate changing the air purge drop out to include a manual reset before it can be activated after a dr op

- out event. 1. COMPLETED.

2. COMPLETED 11/1/2010. An alternative to the manual reset was identified to be an improved mitigation. EOP

- 501

- SPP was updated to reflect a procedural change step. Loss of SPP instrument air 1. Revise the SPP Turbine
emerg ency shutdown procedure to block in the instrument air to a a shutdown turbine to prevent loss of instrument air. 2. Repair the PCV

- 905 pressure regulator to ensure that it will fully open when the SPP instrument air drops below 80 psig. 3. Inspect the SPP instr ument air 1. COMPLETED

2. COMPLETED

3. COMPLETED during 2011 t/a’s.

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? system for leaks at next t/a. 10/27/10 Unit 240 DIB

Overhead Hydrate Line Plug On October 27, 2010 at approximately 1:30 A.M. flaring of unscrubbed gas commenced at a relatively low vo lume. At that time ConocoPhillips also discovered a hydrate plug in the Unit 240 Plant 3 D

- 301 overhead system. The rate of flaring increased over time. At 5:18 AM the G

- 503 Fuel Gas Recovery Compressor was shutdown which resulted in additional flaring. ConocoPhillips cleared the hydrate plug around 6:10 AM. The G

- 540 and G

- 503 Fuel Gas Recovery Compressors were put in service at 7:10 AM and 7:45 AM respectively, once ConocoPhillips determined the plugging issue had been resolved. D

- 301 Overhead T emperature dropped below 65 F during startup. Update Unit 240 Plant 2/3 startup procedures to specify that overhead temperature should not be below when 65 F when feed from Plant 2 is introduced.

TOP

- PL2

- 202

- Section 1 Startup TOP

- PLT2

- 202

- Section 2 S tartup COMPLETED Duration: 7 hours

Flow: 2,997 MSCFD

Emissions:

SO2

– 11,420 lbs (H2S = 2.29%) NMHC

– 1,650 lbs Methane

– 860 lbs Upset/Malfunction

– Equipment Plugging 472

- 10

N

1/22

- 27/2011 Fuel Gas Balance Turnarounds were taking place at units that included large combustion sources during January 2011. Due to the number of process units in turnaround, there were periods where all of the fuel gas produced could not be consumed. Due to the imbalance in the fuel gas system, the additional f uel gas that could not be consumed by the refinery process heaters was flared. Periods of fuel gas imbalance where the flow exceeded the BAAQMD reporting threshold of 500,000 standard cubic feet per day (scfd) occurred from January 22 until January 27, 2 011. During this period, only excess treated (scrubbed) fuel gas was flared. In addition, a large volume of nitrogen was used to depressure and purge one of the units as part of its shutdown. This nitrogen was sent directly to the flare. No specific pre vention measures were implemented but measures were taken to minimize the quantity of material flared. n/a n/a Duration: 128.42 hours

Flow: 16,802 MSCF

SO2

– 415 lbs (H2S = 0.01%) NMHC

– 9,620 lbs Methane

– 3,186 lbs Reduced Consumption of Fu el Gas

– Fuel Gas Imbalance (Section 4.2.1.3) 137

- 11

N

2/15/2011 Unit 110 Startup The Unit 110 Hydrogen Production Plant started up on February 15, 2011 after a planned shutdown. Per the Unit 110 start

- up SOP, Unit 200 began

re

- circulating the G

- 503 Flare Gas Recovery Compressor due to the high volume of hydrogen being sent to the recovery system, which can damage this compressor. During this period each of the G

- 540 Flare Gas Compressors were put in service. They No new prevention measures or corrective actions were identified. The Unit 110 startup is a plann ed activity that will re

- occur in the future.

Due to the unplanned shutdown with the third

- party H2 Plants as detailed in the 10/22/10 event the Plant 4 n/a n/a Duration: 2.16 hours

Flow: 641 MSCFD

Emissions:

SO2

– 700 lbs (H2S = 0.67%) NMHC

– 127 lbs Methane

– 128 lbs Maintenan ce, Turnaround, Startup, Shutdown

– Hydrogen Plant Startups 138

- 11

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? can handle more varied gas quality

an d the fuel gas was not negatively impacted by the excess hydrogen being added. The flaring of unscrubbed gas and hydrogen occurred during this flare event. H2 plant was kept in operation for reliability purposes. This resulted in additional Unit 110 S tartups and Shutdowns when the plant is long on Hydrogen production in association with other unit shutdowns. 2/21/2011 Unit 240 DGA

Upset, Fuel Gas balance & Plant 4 Shutdown An electrical outage at the Diethylene Glycol Amine (DGA) pumps, located at Powerhouse No. 3 in the Unicracker Complex , resulted in higher than normal concentrations of H 2 S in the fuel gas system. This resulted in a fuel gas upset which started in the Refinery Fuel Gas A (RFG A) and later migrated to the Unit 233 fuel gas system. RFG A that normally would be fed to the third party Hydrogen Plant was dropped out to prevent unit damage. Since RFG A is used as feed and fuel this upset resulted in a sudden fuel gas imbalance. The G

- 503 and G

- 540 Flare Gas Recovery Compressors were circulated as part of implementing Emergen cy Operating Procedure (EOP) 12 “Total Loss of DGA Circulation”. Following the upset there was a period of fuel gas imbalance the following day since the large Unit 240 B401 Hydrogen Plant remained shutdown. This flare event resulted in the flaring of un scrubbed and scrubbed gas. High resistance due to connection issue. 1. Properly clean and inspect Bus connections during maintenance periods.

2. Consider performing ultrasonic testing preventative maintenance of powerhouses and substaions. 1. Ongoing with u nit turnarounds.

2. Ongoing with unit turnarounds. Duration: 37.5 hours

Flow: 7,652 MSCF

Emissions:

SO2

– 8,614 lbs (H2S = 1.38%) NMHC

– 5,559 lbs Methane

– 1,988 lbs Upset / Malfunction

– Loss of a Utility 192

- 11

n

Equipment Problem s related to this upset. 1. Replace aluminum Bus Bars with copper Bus Bars. 2. Consider relocating 4GM

415A starter to the Plant 31 MCC. 1. COMPLETED 11/4/11

2. COMPLETED 6/29/ 12

4/4/2011 Voltage Sag

resulting in Fuel Gas Overpressure On April 20, 2010 a voltag e sag occurred in the third

- part power supply. This resulted in flaring of unscrubbed gas due to the loss of two fuel gas compressors and some major pieces of equipment. A number of units were temporarily impacted by the voltage
sag. No specific p revention measures were identified by ConocoPhillips because the primary cause was the voltage sag in the electricity supplied by the third party supplier.

The third party electricity supplier did report that they found a flashed inulator approximately 3 miles from n/a n/a Duration: 15.75 hours

Fl ow: 820 MSCF

Emissions:

SO2

– 163 lbs (H2S = 0.15%) NMHC

– 607 lbs Methane

– 195 lbs Upset/Malfunction (4.2.1.4)

– Loss of a Utility 338

- 11

N (3 rd party)

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? the Christie substation nearest to Oleum

– North Tower

– Martinez Junction. Although they did not know the exact cause of the flash the third party scheduled it for replacement during the following month.

5/13

– 14/11 Unit 200 Steaming

for Shutdown and G

- 540 Fuel Gas Compressor Shutdown Th e Unit 200 Coker/Crude unit was beginning a major turnaround. Steaming was being conducted at the unit to allow for entry and maintenance work to begin. Due to the high temperatures which occur during steaming the G

- 540 Flare Gas Recovery Compressors cou ld not remain in operation. The G

- 503 Flare Gas Recovery Compressor had been shutdown prior to the turnaround for control system upgrades. Flaring of unscrubbed gas occurred. No new prevention measures or corrective actions were identified. The Uni t 200 turnaround and associated steaming is a planned activity that will re

- occur in the future. n/a n/a Duration: 39.5 hours

Flow: 6,503 MSCF

Emissions:

SO2

– 11,510 lbs (H2S = 1.72%) NMHC

– 960 lbs Methane

– 1,144 lbs Maintenance, Tur naround, Startup, and Shutdown

– Equipment Preparation for Maintenance, Equipment Steaming 377

- 11

N

5/21/2011 MP30 & Unit 200

Shutdown Steaming and Maintenance Preparation On May 21, 2011 flaring occurred in association with steaming being conducted as part of the Unit 200 Crude/Coker turnaround. The majority of the flow was through the Main Flare 10” line which vents directly to the flare. This resulted in the flaring of unscrubbed gas. No new prevention measures or corrective actions were identifi ed. The Unit 200 turnaround and associated steaming is a planned activity that will re

- occur in the future n/a n/a Duration: 8 hours

Flow: 665 MSCF

Emissions:

SO2

– 473 lbs (H2S = 0.43 %) NMHC

– 630 lbs Methane

– 38 lbs Maintenance, Turna round, Startup, and Shutdown (4.2.1.1)

– Equipment Preparation for Maintenance, Equipment Steaming 378

- 11

N

6/2/2011 Unit 110 Startup The Unit 110 Hydrogen Production Plant started up on June 2, 2011 after a planned shutdown. Per the Unit 110 start

- u p SOP, Unit 200 began re

circulating the G

- 540 Flare Gas Recovery Compressors due to the high volume of hydrogen being sent to the recovery system, which can damage this compressor. The G

- 503 Flare Gas Compressor had been shutdown prior to this activity a nd would not have minimized flaring emissions had it been in operation. Flaring of unscrubbed gas occurred during this event. No new prevention measures or corrective actions were identified. The Unit 110 startup is a planned activity that will re

- occ ur in the future.

Due to the unplanned shutdown with the third

- party H2 Plants as detailed in the 10/22/10 event the Plant 4 H2 plant was kept in operation for reliability purposes. This resulted in additional Unit 110 Startups and Shutdowns when the
p lant is long on Hydrogen production in association with other unit shutdowns. n/a n/a Duration: 2.75 hours

Flow: 1,060 MSCF

Emissions:

SO2

– 1,408 lbs (H2S = 0.80%) NMHC

– 144 lbs Methane

– 105 lbs Maintenance, Turnaround, Startup, Shu tdown

– Hydrogen Plant Startups 422

- 11

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? 6/5/2011 Unit 110 Unplanned

Shutdown due to SPP Upset On June 5, 2011 an unplanned shutdown of the Unit 110 Hydrogen Plant occurred. This occurred due to low refinery air pressure which shutdown the Unit 110 Pre ssure Swing Adsorber. Flaring of unscrubbed gas occurred immediately following the shutdown and then during the startup which was initiated approximately three hours following the shutdown. Unit operator inadvertently closed the B boiler feed water val ves. Consider conducting an alarm rationalization review and DCS/Display changes to highlight SOLs and allow operators to more readily distinguish between turnins on the DCS displays. COMPLETED 12/15/2011 Duration: 5 hours

Flow: 1,681 SCFD

Emissions:

SO2

– 1,033 lbs (H2S = 0.37%) NMHC

– 274 lbs Methane

– 221 lbs Maintenance, Turnaround, Startup, Shutdown (4.2.1.1)

– Hydrogen Plant Startup/Shutdowns 428

- 11

N

6/8

– 9/2011 Unit 246

Depressuring to MP30 Flare due to Planned Shutdown & Steami ng of E

301 and Unit 240 Plant 2 On June 8, 2011 Unit 246 was shutting down for maintenance work. As part of the unit shutdown and in order to prepare for maintenance and entry the unit is depressured and purged. The unscrubbed material is vented direct ly to the MP

- 30 Flare. In addition to the Unit 246 shutdown work the Unicracker E

- 301 exchanger was being steamed to restore its heat transfer rate. When this exchanger is steamed the discharge is vented to blowdown and then to the flare. No new preven tion measures or corrective actions were identified. These two activities were planned maintenance activities that will

re

- occur in the future. n/a n/a Main and MP30 Flare Totals

Duration: 26.50 hours

Flow: 1,288 SCFD

Emissions:

SO2

– 3,833 lb s (H2S = 1.86%) NMHC

– 166 lbs Methane

– 119 lbs Maintenance, Turnaround, Startup, and Shutdown

– Equipment Preparation for Maintenance, Equipment Steaming Maintenance, Turnaround, Startup, and Shutdown

– Equipment Preparation for Maintenance, De pressuring and Purging 424

- 11

N

6/20

– 21/2011 Unit 246 and

Unicracker Startup Associated Flaring and G

- 540 Startup Issue On June 20, 2011 Unit 246 was starting up after being shutdown for maintenance work. During the startup materials from the unit ar e sent to blowdown until they are on

- grade. There were numerous other units startups taking place on this day including the Unit 200 Coker/Crude Complex and MP

- 30 Complex. During these unit startups and while the Unit 246 materials were sent to blowdown flaring of unscrubbed gas occurred G

- 540 common discharge pressure setpoint change. Return setpoint from 70 to 80 psig. COMPLETED Duration: 23.25 hours

Flow: 830 MSCF

Emissions:

SO2

– 4,981 lbs (H2S = 3.6%) NMHC

– 406 lbs Methane

– 146 l bs Maintenance, Turnaround, Startup, and Shutdown

– High Base Load Upset/Malfunction

– Loss of a Compressor 429

- 11

N

7/8/2011 Unit 110 Planned

Startup Unit 110 was shutdown on June 19, 2011 without any significant flaring. The Unit was shutdown since o ne of the primary unit’s which utilizes its high purity Hydrogen was shutdown for maintenance. The Unit 110 Hydrogen Production Plant started up on July 8, 2011 after the planned shutdown. Flaring of unscrubbed gasses occurred during the startup. The pr imary cause for flaring was due to the startup of Unit 110. No new prevention measures or corrective actions were identified. The Unit 110 startup is a planned activity that will re

- occur in the future. Turnaround pre

- planning is conducted to minimize em issions associated with the startup. n/a Duration: 3:10 hours

Flow: 1,282 MSCF

Emissions

SO2

– 2,160 lbs (H2S = 1.01%) NMHC

– 770 lbs Methane

– 315 lbs Maintenance, Turnaround, Startup, and Shutdown

– Hydrogen Plant Startups 423

- 11

N

7/23/2011 3 rd Party Electricity

Supplier Voltage Sag On July 23, 2011 a voltage sag occurred in the refinery's third

- party power supply. The G

- 503 Flare Gas Recovery Compressor and other major pieces of equipment were impacted by A voltage sag occurred in the electricity delivered by the refinery's third

- party supplier. The third

- party supplier reported that a transfo rmer No specific prevention measures were identified by ConocoPhillips because the primary cause was the voltage sag in the electricity provided by the refinery's third

- party supplier. The n/a Duration: 4:04 hours

Flow: 422 MSCF

Emissions Upset/Malfunction

– Los s of a Utility 462

- 11

N (3 rd party)

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? the voltage sag which resulted in flari ng. Several process units were also impacted by the voltage sag. The flaring of unscrubbed gasses occurred. relay opened unexpectedly on the Oleum/Martinez line. third

- part y electricity supplier was able to re

- close the relay that unexpectedly opened, which restored voltage to the line. SO2

– 3,671 lbs (H2S = 5.24%) NMHC

– 249 lbs Methane

– 32 lbs

9/12/11 G

- 501 Wet Gas

Compressor Failure The Unit 200 Crude/Coker unit was being started up on Sunday, September 11, 2012. As part of the unit startup the G

- 501 Wet Gas Compressor, which is the compressor for the Cok er’s main fractionator, was in the process of starting up. On September 12, 2012, the second day of the unit startup, the G

- 501 Wet Gas Compressor shutdown. The flaring of unscrubbed gasses occurred. Top Tower Temperature Too Low 1. Clarify and chan ge start

- up procedure to ensure the top tower temperature reaches a clearly defined temperature prior to starting crude charge. 2. Ensure that refresher training for the Coking section start

- up procedure includes an emphasis regarding the critical nature of removing water from the tower, and following the procedure regarding when to introduce the wedge valve body steam. 1. COMPLETED February 21, 2012

2. COMPLETED February 21, 2012 Duration: 37:43 hours

Flow: 1,547 MSCF

Emissions

SO2

– 5,543 lbs (H2S = 2 .42%) NMHC

– 717 lbs Methane

– 297 lbs Upset/Malfunction

– Loss of a Major Compressor 547

- 11

N

Liquid Carryover 1. Review the setting for the High

High Level trip for the G

- 501 Wet Gas Compressor and assure that there is enough time to protect the compre ssor from liquid carry

- over. Ensure adequate wind down time for the compressor is included in alarm set points. 2. Establish a Safety Operating Limit for th e Wet Gas Compressor KO Drum. 1. Evaluation COMPLETED 4/25/13. Determination that existing trips were adequate.

2. COMPLETED 4/25/13

Liquid Removal Issues 1. Ensure the turbine driven reflux pump (G

- 215A) is considered a critical pump in the G

- 501 Compresso r startup procedure.

- 1. COMPLETED

9/25/11 G

- 501 Wet Gas

Compressor Startup The Unit 200 Crude/Coker unit was being started up on Sunday, September 11, 2012. On September 12, 2012, the second day of the unit startup, the G

- 501 Wet Gas Compressor failed. (See ConocoPhillips flaring root cause analysis for September 12, 2011 which provide s details regarding the Wet Gas Compressor failure.) After repairs had been made to the G

- 501 compressor it was put back into Wet Gas Service on September 25, 2011. During the Planned startup of the G

- 501 Wet Gas Compressor No new prevention measures or corrective actions were identified. The switch from G

- 503 from Wet Gas service to Fuel Gas Recovery service was a planned activity to restore the G

- 501 and G

- 503 to normal operation. The G

- 503 Fuel Gas Compressor is designed to be put into Wet Gas Compressor service to optimize the amount of gases routed back to fuel gas during peri ods of time when the G

- 501 Wet Gas Compressor is out of service. During n/a Duration: 1:12 hours

Flow: 120 MSCF

Emissions

SO2

– 770 lbs (H2S = 3.9%) NMHC

– 70 lbs Methane

– 40 lbs Maintenance, Turnaround, Startup, & Shutdown

– Compressor System Repairs 548

- 11

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? startup of the compressor and transition of the G

- 503 compressor out of Wet Ga s Compressor service there was a period of flaring of unscrubbed gas for a little over one hour. the switching process refinery personnel followed a detailed Operating Procedure to perform this activity. This ensures the necessary steps to perform the compressor switch and start up are performed in a safe and efficient manner. This minimizes the period of time in which flaring occurs.

9/29/11 Unit 110 Planned

Startup Unit 110 was shutdown on September 8, 2011. The Unit 110 Hydrogen Production Plant was re

- started up on September 29, 2011 after the shutdown. During the startup of Unit 110 there was flaring of unscrubbed
gasses. The primary cause for flaring was due to the startup of Unit 110. No new prevention measures or corrective actions were identified. The Unit 110 startup is a planned activity that will re

- occur in the future. Turnaround pre

- planning is conducted to determine means for reducing flaring. n/a Duration: 3:07 hours

Flow: 1,299 MSCF

Emissions

SO2

– 1,640 lbs (H2S = 0.76%) NMHC

– 326 lbs Methane

– 240 lbs Maintenance, Turnaround, Startup, and Shutdown

– Hydrogen Plant Startups 546

- 11

N

11/29/11 G

- 503 Flare Gas

Compressor Maintenance The G

- 503 Flare Gas Recovery Compressor was scheduled for Planned Maintenance in December and was shutdown in preparation for the maintenance. To provide flare gas
recovery while G

- 503 was out of service, the G

- 540 Flare Gas Recovery Compressors were put in service. However, the volume of gas in the blowdown system was at a level where all the gases could not be recovered with the G

- 540 compressors at all times throughout t he day. This resulted in the flaring of unscrubbed gases that were not treated for sulfur removal. The volume of gas in the blowdown system was more than the G

- 540 Flare Gas Compressor capacity. The G

- 540 Fuel Gas Recovery Compressors were installed in 20 09 to allow for unplanned and planned maintenance to take place on the G

503 Compressor while reducing flaring. Prior to the installation of the G

- 540 Compressors all gas would have been sent to the flare during periods of maintenance. n/a Duration: 1 0:13 hours

Flow: 764 MSCF

Emissions

SO2

– 1,347 lbs (H2S = 1.16%) NMHC

– 254 lbs Methane

– 163 lbs

 Maintenance, Turnaround, Startup, and

Shutdown

– Compressor Maintenance 063

- 12

N

12/5/11 Unplanned 3 rd Party

Hydrogen Plant Shutdown On December 5, 2011 the Refinery’s third

- party Hydrogen Plant that provides a significant portion of hydrogen to the refinery experienced an unplanned shutdown. This resulted in flaring of unscrubbed gases intermittently on December 5, 2011 from units that shutdown due to t he loss of hydrogen or experienced unit upsets.

. 3 rd Party Root Action Item : Broken weld on ID Fan Jack Shaft No specific prevention measures were identified by ConocoPhillips to prevent the loss of Hydrogen because the primary root cause was due to the unplanned shutdown of the third

- party Hydrogen Plant.

Repair ID Fan Jack Shaft COMPLETED 12/5/11 Duration: 5:35 hours

Flow: 230 MSCF

Emissions

SO2

– 1,025 lbs (H2S = 2.71%) NMHC

– 140 lbs Methane

– 30 lbs Fuel and Hydrogen Gas Bal ance

– Including unplanned Hydrogen supplier shutdowns 108

- 12

N (3 rd Party)

1/16/12 Unit 110 Startup

Following Unplanned Shutdown Unit 110 experienced an unplanned shutdown on January 15, 2012. During the process of Unit 110 startup there is flaring of unscrubbed gases. The cause of the shutdown was due to the failure of the Process Logic Controller (PLC) at Unit 110. The PLC failed due to a hardware Replace CPU COMPLETED 1/1 6/12 Duration: 4:45 hours

Flow: 1,628 MSCF

Emissions Unset/Malfunction

– Control System Failure Maintenance, Turnaround, Startup, and Shutdown

– Hydrogen Plant Startups 157

- 12

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? failure of the Central Processing Unit (CPU) which is the PLC processor. SO2

– 2,870 lbs (H2S = 1.06%) NMHC

– 840 lbs Methane

– 370 lbs 1/18

– 1 /20 Fuel Gas Balance

–

3 rd Party H2 Plant not taking RFG A Gas On January 18, 2012 the third

- party Hydrogen Plant took their feed gas coalescer out of service for a filter replacement. Due to the observation of higher than anticipated liquids in the feed gas the Air Liquide Plant blocked out the RFG A feed gas as a precautionary measure. The RFG A is a feed gas generated by the refinery and sent to Air Liquide. This resulted in a fuel gas imbalance at the refinery and the flaring of scrubbed gases. Liquids in RFG A 1. Evaluate the effectiveness of the piping installed at the RFG A/RFG B boundary and determine if the installation should be modified and upgraded. 2. Third party Hydrogen Plant to evaluate the need to increase water removal capabilities. A tie in to be provided for potential future additional water filter. 1. COMPLETED 3/31/2012

2. COMPLETED tie

- in 3 rd Qtr 2012 Duration: 55:20 hours

Flow: 11,939 MSCF

Emissions

SO2

– 198 lbs (H2S = 0.01%) NMHC

– 11,501 lbs Methane

– 2,808 lbs  Reduced C onsumption of Fuel Gas (4.2.1.3)

 Upset/Malfunction (4.2.1.4)

– fuel gas quality upsets 158

- 12

N

E

- 424 temperature outlet too low. Provide a temperature controller on the E

- 424 compressor discharge cooler. This project will allow the discharge tempe rature to be controlled so that during cool ambient conditions and reduced flowrates, the RFG A gas temperature can be maximized to prevent condensation of water. COMPLETED 10/18/12

2/16/12 U110 and U250

Planned Shutdown On February 16, 2012, steps w ere taken to shut down Unit 110 Hydrogen Production Plant for a scheduled shutdown to conduct major maintenance. Unit 250 was also conducting a turnaround during this period. Nitrogen purging of a Unit 250 compressor took place during this period. These activities resulted in the flaring of unscrubbed gases. The primary cause for flaring was the scheduled shutdown of Unit 110 Hydrogen Plant and Unit 250 for a major turnaround to conduct planned maintenance. Equipment and process vessels had to be cleared in order to provide a safe environment for personnel entry. No new prevention measures or corrective actions were identified. The turnaround activities are planned activities that will re

- occur in the future. Turnaround pre

- planning was conduc ted in order to identify means for reducing flaring that may occur. n/a Duration: 5:07 hours

Flow: 1,642 MSCF

Emissions

SO2

– 2,800 lbs (H2S = 1.37%) NMHC

– 670 lbs Methane

– 260 lbs  Maintenance, Turnaround, Startup, Shutdown

– Hydrogen Plant Startups and Shutdowns

 Equipment Preparation for Maintenance 159

- 12

N

3/1

– 3/5/12 Fuel Gas Imbalance Maintenance turnarounds were taking place at units that included large combustion sources during March, 2012. Due to the turnaround, there were periods where a ll of the fuel gas produced could not be consumed. Due to the imbalance in the fuel gas system, the additional fuel gas that could not be consumed by the refinery process heaters was flared. During this period, only excess scrubbed fuel gas was flared. The primary cause of the flaring was the shutdown of refinery fuel gas consumers for planned maintenance. This resulted in a fuel gas imbalance. More refinery fuel gas was being produced than could be consumed while maintaining compliance with other env ironmental limits, such as the Sulfur Dioxide limit at the Steam Power Plant. Turnaround pre

- planning was conducted that identified the potential for fuel gas imbalance. No specific prevention measures were implemented but measures were taken to minimi ze the quantity of material flared. n/a Duration: 99 hours

Flow: 8,752 MSCF

Emissions

SO2

– 140 lbs (H2S = 0.01%) NMHC

– 4,600 lbs Methane

– 4,350 lbs Reduced Consumption of Fuel Gas

– Fuel Gas Imbalance 242

- 12

N

3/14/2012 Unit 110 Startup

after Planned Unit 110 underwent a planned startup on March 14, 2012 following a planned V

- 4 leaking relief valve 1. Reseated and re

- lapped the 1. COMPLETED 3/15/12 Duration: 10:48 hours  Mainten ance, Turnaround, Startup, Shutdown

– Hydrogen Plant Startups 259

- 12

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? Shutdown unit turnaround. This resulted in the flaring of unscrubbed gases.

The primary cause for flaring was due to the startup of Unit 110. There was some additional f laring associated with the unplanned Unit 110 shutdown due to the leaking V

- 4 relief valve and a leaking gasket at the relief valve. relief valve.

2. Replace the gasket to one with different dimensions. Update documentation to ensure new model gasket will be utilized in the future. 2. COMPLETED 3/15/12 Flow: 2,170 MSCF

Emissions

SO2

– 2,080 lbs (H2S = 0.6%) NMHC

– 940 lbs Methane

– 390 lbs  Upset/Malfunction

– Leaking Relief Valves N

3/16/2012 Unit 110 Startup Unit 110 underwent a planned startup on March 14, 2012 following a planned unit turnaround. As described in the Flare RCA for March 14, 2012, a leaking steam relief valve was discovered. This required Unit 110 to be shutdown, the relief valve repair made, and the unit restarted. Unit 110 restarted on March 16, 2012. The compressor recirculation results in flaring of unscrubbed gas. See 3/14/2012 for root cause and corrective actions. n/a n/a Duration: 3:28 hours

Flow: 883 MSCF

Emissions

SO2

– 1,330 lbs (H2S = 0.9%) NMHC

– 350 lbs Methane

– 170 lbs Maintenance, Turnaround, Startup, Shutdown

– Hydrogen Plant St artups 260

- 12

N

3/19/2012 Fuel Gas Balance

–

SPP Turnaround Maintenance turnarounds were taking place at units that included large combustion sources during March, 2012. Due to the turnaround, there were periods where all of the fuel gas produced could not be consumed. Due to the imbalance in the fuel gas system, the additional fuel gas that could not be consumed by the refinery process heaters was flared. Periods of fuel gas imbalance where the flare flow exceeded the BAAQMD reporting threshold of 50 0,000 standard cubic feet per calendar day (scfd) occurred from March 19 until March 21, 2012. During this period, only excess scrubbed fuel gas was flared. The primary cause of the flaring was the shutdown of refinery fuel gas consumers for planned mai ntenance. This resulted in a fuel gas imbalance. More refinery fuel gas was being produced than could be consumed while maintaining compliance with other environmental limits, such as the Sulfur Dioxide limit at the Steam Power Plant. Turnaround pre

- planning was conducted that identified the potential for fuel gas imbalance. No specific prevention measures were implemented but measures were taken to minimize the quantity of material flared. n/a Duration: 48.5 hours

Flow: 3,428 MSCF

Emissions

SO 2

– 57 lbs (H2S = 0.01%) NMHC

– 2,920 lbs Methane

– 1,020 lbs Reduced Consumption of Fuel Gas

– Fuel Gas Imbalance (Section 4.2.1.3) 243

- 12

N

3/26/2012 Fuel Gas Balance

–

AL stopped taking A Gas On March 26, 2012 the third

- party Air Liquide Hydrogen P lant took their feed gas coalescer out of service for a filter replacement. The filter required replacement due to an increase in back pressure on the filter. In order to prevent potential liquids in the feed gas, the Air Liquide Plant blocked out the RFG A feed gas as a precautionary measure. The RFG A is a feed gas generated by the refinery and sent to Air Liquide. This resulted in a fuel gas Liquids in RFG A 1. Evaluate the effectiveness of the piping installed at the RFG A/RFG B boundary and determine if the installation should be modified and upgraded.

2. Third party Hydrogen Plant to evaluate the need to increase water removal capabilities. A tie in to be provided for potential 1.Temporary piping to blow down was added for the bleed at the low point in the RFG A gas line prior to going to Air Liquide COMPLETED 3/31/12

2. COMPLETED tie

- in 3 RD Qtr 2012.

. Duration: 33 hours

Flow: 4,028 MSCF

Emissions

SO2

– 67 lbs (H2S = 0.01%) NMHC

– 3,260 lbs Methane

– 1,045 lbs  Reduced Consumption of Fuel Gas (4.2.1.3)

 Upset/Malfunction (4.2.1.4)

– fuel gas quality upsets 253

- 12

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? imbalance at the refinery and the flaring of scrubbed gases. future additional water filter.

E

- 424 temperature outlet too low Provide a temperature controller on the E

- 424 compressor discharge cooler. This project will allow the discharge temperature to be controlled so that during cool ambient conditions and reduced flowrates, the RFG A gas temperature can be maximized to prevent condensation of water. COMPLETED 10/2012

4/25/2012 RFG A out of Air

Liquide and Fuel Gas Balance On April 24, 2012 the RFG A feed gas to the third

- party Air Liquide Hydrogen Plant was blocked out as a precautionary measure in preparation for planned turnaround activity. This resulted in a fue l gas imbalance at the refinery and the flaring of scrubbed gases. As the pressure built up in the fuel gas system on April 25, the amount of gas and increase in pressure caused water in the D

- 7 Hot Coker Blowdown drum to overflow. The water contained H 2 S and caused local H 2 S alarms to trigger. In order to maintain the liquid level in the D

- 7 drum and prevent the H 2 S alarms, the G

- 503 flare gas recovery compressor was put into circulation to relieve the pressure on the fuel gas system and the D

- 7 Drum. This resulted in the flaring of unscrubbed gases. Sour seal water from D

- 7 was automatically flushed to an open process sewer that caused H 2 S alarm. 1. Relocate the D

- 7 level transmitter to increase pressure activation from 2.2 psig to 4.5 psig. Thi s will prevent pressure fluctuations from tripping the quench water valve.

2. Reduce H 2 S in seal water by increasing minimum seal water flow and/or setting up routine quench water flushes. 1. COMPLETED 6/1/12

2. COMPLETED 9/26/12 Duration: 19 hours

Fl ow: 2,795 MSCF

Emissions

SO2

– 5,600 lbs (H2S = 1.2%) NMHC

– 1,470 lbs Methane

– 550 lbs  Maintenance, Turnaround, Startup, and Shutdown (4.2.1.1)

 Reduced Consumption of Fuel Gas (4.2.1.3)

 Upset/Malfunction (4.2.1.4)

– fuel gas quality upsets

 Emergency ( 4.2.1.5)

– Local H 2 S alarms near D

- 7 drum 297

- 12

N

Location of Unit 233 pressure control valve tie in to flare system at D

- 7. Evaluate a project to re

- route the Unit 233 pressure control valve flare system tie

- in location. Consider a tie

in location directly to the flare line downstream of 19F

- 3. Target 12/15/15 which corresponds to necessary equipment outage.

4/26

– 5/1/12 Fuel Gas Imbalance

During UK T/A In late April, 2012, a planned shutdown was conducted at the Unicracker Complex to perform scheduled maintenance on several units. Flaring occurred on May 19, 2012 while the G

540 Flare Gas Recovery Compressors were shutdown. The Flare Gas Compressors were shutdown during the Unit 244 Reformer Catalyst Activation startup procedure which led t o flaring of unscrubbed gas. The primary cause of flaring was the shutdown of the G

540 Flare Gas Recovery Compressors during hydrogen and nitrogen purge steps. Preplanning was conducted to identify periods of expected flaring to identify means for minim izing flaring. Communication between the Unit 200 Operator that operates the Flare Gas Recovery Compressors and Unit 244 takes place in advance of this work occurring. This ensures that the activity is planned and the period in which the flare gas recove ry compressor is shutdown is minimized. n/a Duration: 114 hours

Flow: 18,000 MSCF

Emissions

SO2

– 623 lbs (H2S = 0.01 %) NMHC

– 10,050 lbs Methane

– 3,700 lbs Reduced consumption of fuel gas

– fuel gas imbalance (4.2.1.3) 306

- 12

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? 5/19/12 Unit 244 Cat alyst

Reactivation and Nitrogen Purging A planned shutdown was conducted at the Unicracker Complex to perform scheduled maintenance on several units. Flaring occurred on May 19, 2012 while the G

- 540 Flare Gas Recovery Compressors were shutdown. The Flare Gas Compressors were shutdown during the Unit 244 Reformer Catalyst Activation startup procedure which led to flaring of unscrubbed gas. Preplanning was conducted to identify periods of expected flaring to identify means for minimizing flaring. Commun ication between the Unit 200 Operator that operates the Flare Gas Recovery Compressors and Unit 244 takes place in advance of this work occurring. This ensures that the activity is planned and the period in which the flare gas recovery compressor is shutd own is minimized. n/a n/a Duration: 12.83 hours

Flow: 4,300 MSCF

Emissions

SO2

– 2,260 lbs (H2S = 0.32%) NMHC

– 2,130 lbs Methane

– 800 lbs  Maintenance, Turnaround, Startup, Shutdown

– Unit startup (Section 4.2.1.1) 303

- 12

N

5/23

- 5/29/12 Unit 240 Plant 3

Unscheduled SD and Unit 246 D

- 803 Overhead to Flare T he Unit 246 Hydrocracker D

- 803 stripper overhead was routed to the flare gas recovery system as a result of the unscheduled shutdown of Unit 240 Plant 3. The addition of the D

- 803 stripper overhe ad gases to the flare gas recovery system led to periods where the refinery’s flare gas recovery compressors could not compress all of the gas in the system due to gas quantity. During these periods unscrubbed gas was flared due to the addition of the D

- 80 3 overhead.

The D

- 803 stripper overhead normally goes to Plant 3 in the Unit 240 UK. When the UK Plant 3 is shutdown, however, the D

- 803 stripper overhead is routed to the flare gas recovery system. On May 23, 2012, UK Plant 3 needed to be shut down to re pair a leak that was found in the E

- 316 fin fan cooler. The E

- 316 fin fan cools the UK Plant 3 D

- 305 Fractionator bottoms stream. E

- 316 Fin Fan Leak repair E

- 316 Fin Fan Leak repair

- Re

rolling of 320 tubes in areas where the E

- 316 leaks occurred followe d by the re

- start of UK Plant 3. Plant 3 COMPLETED 5/27/12 Duration: 111.5 hours

Flow: 8,970 MSCF

Emissions

SO2

– 7,815 lbs (H2S = 0.38%) NMHC

– 6,790 lbs Methane

– 1,665 lbs  Upset/Malfunction

- Loss of Air Fin (4.2.1.4)

 Reduced Consumption of Fu el Gas (4.2.1.3)

 Upset/Malfunction (4.2.1.4)

– fuel gas quality upsets

 Maintenance, Turnaround, Startup, and Shutdown (4.2.1.1) 320

- 12

N

E

- 316 Design Review the process in Plant 3 to determine if the E

- 316 fin fan unit can be replaced with shell and tube heat exchanger. Target 6/7/2015

5/31

- 6/1/12 Unit 110 Planned

Startup following Shutdown Unit 110 underwent a planned shutdown on May 3, 2012 due to lower hydrogen demand related to planned turnaround activity at the Unicracker complex. Flar ing of unscrubbed gases occurred in association with the Unit 110 startup. None, this was a planned startup with anticipated flaring. n/a n/a Duration:3.58 hours

Flow: 448 MSCF

Emissions

SO2

– 2,220 lbs  Maintenance, Turnaround, Startup, Shutdown

– Hydrogen Plant Startups 311

- 12

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? (H2S = 2.9%) NMHC

– 280 lbs Methane

– 80 lbs 7/24/12 UK Relief Valve

Leak following T/A

After the start

- up of the Unicracker (UK) Complex following a turnaround, Phillips 66 detected a low rate of flare flow at the M ain Flare (in the range of 300,000 to 400,000 scf per day of unscrubbed gas). Upon investigation it was determined the UK Plant 2 100 lb. relief valve (2HV023) on the 2F

- 201 High Pressure (HP) Separator was the source of the flow to the flare.

During th is period, there were three instances (7/24/12 to 7/27/12, 8/1/12 and 8/4/12 to 8/6/12) where H 2 S in the flare samples indicated that more than 500 pounds of SO 2 had been emitted and/or more than 500,000 scf of vent gas were flared during a calendar day. A ll three instances were caused by the UK 2HV023 relief valve leaking to the Main Flare which resulted in the flaring of unscrubbed gas. UK Plant 2 100 lb Relief Valve (2HV023) Leaking to Flare Block in existing 2HV023 relief valve and install new one in alternate location. COMPLETED 8/12/12 Duration:72 hours

Flow: 1,308 MSCF

Emissions

SO2

– 1,580 lbs (H2S = 0.74 %) NMHC

– 790 lbs Methane

– 330 lbs  High Base/Continuous Load

– Leaking Relief Valve (4.2.1.2)

 Upset/Malfunction

– Leaking Relief Valves (4.2. 1.4) 435

- 12

N

8/1/12 UK Relief Valve

Leak following T/A “ “ “ Duration:24 hours

Flow: 545 MSCF

Emissions

SO2

– 300 lbs (H2S = 0.33 %) NMHC

– 340 lbs Methane

– 100 lbs “ 437

- 12

N (on

- going)

8/4/12 UK Relief Valve

Leak following T/A “ “ “ Duration:7 2 hours

Flow: 1,212 MSCF

Emissions

SO2

– 1,677 lbs (H2S = 0.83 %) NMHC

– 704 lbs Methane

– 336 lbs “ 441

- 12

N (on

- going)

8/24/12 UK Unplanned

Shutdown On August 24, 2012 at approximately 1:00 PM, Unit 240 Plant 2 had an unscheduled shutdown. During t he shutdown, the unit de

- pressured directly to the main flare, bypassing the flare gas recovery compressors. Gases were also vented to the flare during the subsequent startup. The shutdown and startup resulted in the flaring of unscrubbed gases.

The Unit 240 Plant 2 shutdown and subsequent startup caused the pressure to build up in the fuel gas system, which led to periodic flaring of scrubbed gases. The increase in fuel gas flow to the flare can cause water in the D

- 7 blowdown drum to overflow. The w ater can contain H 2 S and cause local H 2 S sensors to alarm. To Lack of policy for process trip systems to be placed in Bypass while maintenance work is being performed on the tripped software. “ “ Develop a task safety analysis form specific to Process Contr ol work tasks. COMPLETED 5/28/1 2 Duration:61 hours

Flow: 18,470 MSCF

Emissions

SO2

– 98,680 lbs (H2S = 3.81 %) NMHC

– 13,229 lbs Methane

– 1,922 lbs  Reduced Consumption of Fuel Gas (4.2.1.3)

 Upset/Malfunction (4.2.1.4)

– control system failure

 Upset/ Malfunction (4.2.1.4)

– fuel gas quality upsets

 Maintenance, Turnaround, Startup, and Shutdown (4.2.1.1) 474

- 12

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? maintain the liquid level in the D

- 7 drum and prevent the H 2 S alarms, the G

- 503 flare gas recovery compressor was put into circulation to reduce the pressure on the fuel gas system and the D

- 7 D rum. This resulted in the flaring of unscrubbed gases.

Sour seal water from D

- 7 automatically flushes to an open process sewer that causes an H2S alarm 1. Relocate the D

- 7 level transmitter to increase pressure activation from 2.2 psig to 4.5 psig. This will prevent pressure fluctuations from tripping the quench water valve. 2. Reduce H2S in seal water by increasing minimum seal water flow and/or setting up routine quench water flushes. 1. COMPLET ED 6/1/12 as part of a previous Flare Event (4/25/12). This corrective action may have reduced the severity of this flare activity.

2. COMPLETED 9/26/12

Location of U233 pressure control valve tie

- in to flare system at D

- 7 Evaluate a project to re

- route the Unit 233 pressure control vavle flare system tie

- in location. Consider a tie

in location directly to the flar e line downstream of 19F

- 3. Target 12/15/15 which is linked with equipment /flare system outage.

8/27 /12 RFG A Backed out

of AL due to Higher than Normal Sulfur Content Portions of the Unicracker Complex were in startup on August 27, 2012 following an unplanned shutdown (see ESDR

- 474

- 12). At approximately 11:27 PM, flaring began when the third party Hydrogen Plant blocked out feed gas (RFG A) from Phillips 66 due to unexpectedly higher than normal sulfur content. Flaring of scrubbed fuel gas occurred until the following day at approximately 5:17 PM due to high fuel gas system pressure. Natural Gas was added to RFG A upstream of D402 rather than downstream. 1. Natural gas should be added downstream of D

- 402.

2. Add a tag on the D

- 402 upstream natural gas l ine to indicate this should not be utilized. 1. COMPLETED approx. 10/17/2012.

2. COMPLETED 11/27/12 Duration: 17.9 hours

Flow: 2,266 MSCF

Emissions

SO2

– 100 lbs (H2S = 0.01 %) NMHC

– 8,650 lbs Methane

– 458 lbs  Reduced Consumption of Fuel Gas

– Fuel Ga s Imbalance (Section 4.2.1.3)

 Upset/Malfunction (4.2.1.4)

– fuel gas quality upsets 503

- 12

N

9/10/12 Unit 110 Hydrogen

Vent Fire On September 10, 2012 at approximately 7:00 AM, the G

- 503 flare gas recovery compressor was circulated due to a large amount of hydrogen being sent to the flare gas recovery system. In some cases, too much hydrogen can cause the heating value of the fuel gas to be too low, which requires the compressor to be shut down. At the time the compressor was being circulated, there was excess hydrogen being produced at the refinery during the startup of the third party Air Liquide Hydrogen Plant (Air Liquide). The excess hydrogen being produced by the Unit 110 Hydrogen Plant was sent to the flare gas The Unit 110 operating procedure (REOP

- 21) does not adequately address Unit 110 atmospheric vent operating parameters. 1. Revise REOP

- 21 "Emergency Loss of Hydrogen," to inc lude a note regarding the Unit 110 atmospheric hydrogen vent operating limitations.

2. Review creation of a new normal operating procedure (NOP) for operation of the Unit 110 atmospheric hydrogen vent and how to respond to high flow. COMPLETED 12/20/2012 COMPLETED 1/9/2013

COMPLETED 1/9/2013 Duration:10.25 hours

Flow: 5,628 MSCF

Emissions

SO2

– 11,587 lbs (H2S = 1.24 %) NMHC

– 1,760 lbs Methane

– 620 lbs  Emergency, flame at Unit 110 atmospheric hydrogen vent (4.2.1.5)

 Hydrogen Gas Balance

– excess hydrogen production following startup or shutdown(4.2.1.1) 499

- 12

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? recovery system. Circulation of the G

503 flare gas recovery compressor resulted in the flaring of unscrubbed
gases.

10/3/12 U246

Depressurization to Flare and Planned SD On October 3, 2012 Unit 246 was being shut down for maintenance work. As part of the unit shutdown, and to prepare for main tenance and entry, the unit was depressured and purged. The purged material was vented directly to the MP

- 30 Flare and resulted in the flaring of unscrubbed
gases. No new prevention measures or corrective actions were identified. These activities

were planned maintenance activities that will re

- occur in the future. n/a n/a Duration:28.5 hours

Flow: 5,265 MSCF

Emissions

SO2

– 87 lbs (H2S = 0.01%) NMHC

– 150 lbs Methane

– 986 lbs Maintenance, Turnaround, Startup, and Shutdown

– Equipment Preparati on for Maintenance, Depressuring and Purging 537

- 12

N

10/4/12 U240 Plant 2

Unplanned SD due to failure of G

- 203B H2 Make Up Compressor On October 04, 2012, Unit 240 Plant 2 had an unscheduled shutdown at approximately 9:05 PM caused, in part, by the fai lure of the 3 rd stage of the G

203B Hydrogen Makeup Compressor. Prior to the shutdown at approximately 5:50 PM, the G

- 203B Hydrogen Makeup Compressor at Unit 240 developed a mechanical issue that resulted in one of the relief valves lifting and releasing h ydrogen to the flare. Gases were also vented to the flare during the subsequent startup after repairs of the G

- 203B Compressor were complete. The shutdown and startup resulted in the flaring of unscrubbed gases. 1. D

- 203 Catalyst Bed 4 had temperature
gr adient prior to the incident a. Expand the Unit 240 Plant 2 Reactor Operating Guidelines to improve temperature gradient management and actions to take to minimiz e gradients. b. Improve reactor temperature alarming. Consider installing alarms on the DCS and OIS T arget board.

d. c. Provide refresher training on The Plant 2 Reactor Operating Guidelines and training on

emer gency events. a. COMPLETED 3/25/13

b. COMPLETED 3/25/13 Upon detailed review it was determined that existing monitoring was consistent with industry best practices and per P66 ’ s internal recommendations. Thus, no additional monitoring was added.

c. COMPLETED 8/29/13 Duration:22.6 hours

Flow: 7,111 MSCF

Emissions

SO2

– 22,10 0 lbs (H2S = 2.25 %) NMHC

– 2,479 lbs Methane

– 941 lbs  Reduced Consumption of Fuel Gas (4.2.1.3)

 Maintenance, Turnaround, Startup, and Shutdown (4.2.1.1)

 Upset/Malfunction

– Loss of other compressors (G

- 203B) (4.2.1.4) 577

- 12

N

2. G

- 203B shutdown becau se of lube oil injection system failure. Complete the Failure Analysis Summary Report and implement recommended actions. COMPLETED report 12/17/12, Associated action items 1/31/13.

3. Initiation of a project to

re

- route the Unit 233 pressure contr ol valve flare system tie

- in location. Install a tie

- in location directly to the flare line downstream of 19F

- 3. Target 12/1 5/15 which is linked with key equipment outage.

1/18/13 U246 Unplanned

Shutdown due to failure of 8G

- 826B Forced Draft Fan On January 8, 2013, the Unit 246 Heavy Gas Oil Hydrocracker had an unscheduled shutdown. During the shutdown, the refinery’s G

- 503 flare gas recovery compressor was taken offline due to gas quality concerns due to the large amount of hydrogen being sent to the flare gas recovery system. The G

- 503 flare gas recovery VFD Cabinet High Temperature Install exhaust fans in the enclosure to direct hot air out of the enclosure. COMPLETED 4/10/13 Duration:9 hours

Flow: 227 MSCF

Emissions

SO2

– 970 lb s (H2S = 2.64 %) NMHC

– 183 lbs  Upset/Malfunction

- Loss of Forced Draft Fan, 8G

- 826B (4.2.1.4)

 Maintenance, Turnaround, Startup, and Shutdown (4.2.1.1) 071

- 13

N

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? compressor does not operate properly with high amounts of hydrogen and can be permanently damaged. Two of the liquid ring compressors were in operation, but could not compress all of the gas bein g sent to the flare. This resulted in the flaring of unscrubbed
gas. Methane

– 46 lbs

D

- 803 Overhead Offgrade to blowdown during Startup 1. Revise startup procedure to notify Unit 200 when D

803 is going to blowdown. Unit 200 may be able to delay drum switches and work to optimize flow to the fla re gas system. 2. Revise startup procedure to include increased D

803 Overhead sampling frequency to once per hour. This will allow the on grade determination to be made more quickly and reduce the time the material goe s to blowdown. 

## 3. Revise startup procedure to increase maximum D

803 Overhead on

- grade specification to 5 ppm total sulfur from 2 ppm to minimize the tim e the material goes to blowdown. COMPLETED 2/4/13

COMPLETED 2/4/13

COMPLETED 2/4/13

4/11/13 U246 Unplanned

Shutdown due to G801 Charge Pump Failure On April 10, 2013, the Unit 246 Heavy Gas Oil Hydrocracker had an unscheduled shutdow n. As part of the unit shutdown the unit was depressured. The depressured material was vented directly to the MP

30 Flare and resulted in the flaring of unscrubbed gases. 1. Routine equipment rounds did not include explicit instructions regarding G

- 801 motor oil levels and related parameters Update the Operator Rounds sheets to include explicit instructions to check the G

- 801 motor oil level gauges, temperature of oil supply tubing at each branch from the header pipe, levels in constant level oiler, oil ret urn flow rate and bearing housing air

- purged seal air pressure each shift. COMPLETED 5/2/13 Duration:7 hours

Flow: 1,167 MSCF

Emissions

SO2

– 814 lbs (H2S = 0.42 %) NMHC

– 127 lbs Methane

– 210 lbs  Upset/Malfunction

– Equipment failure which result s in an immediate or controlled unit shutdown (e.g. charge pump failure) (4.2.1.4)

 Maintenance, Turnaround, Startup, and Shutdown

– Equipment Preparation for Maintenance, Depressuring and Purging 162

- 13

N

2. No back up oil supply in the event the su pply orifice becomes blocked. Install an additional level gauge and a constant level oiler on the G

- 801 motor’s bearing housings to allow changes in oil level to be more apparent to Operators, and to provide a back up supply of oil in the event the flood lube supply orifice is COMPLETED 4/20/13

# Attachment H

ESDR No.

–

Internal document tracking number. Recurrent Failure

– Flaring caused by the recurrent failure of air pollution control equipment, process equipment, or a process to operating in a normal or usual manner. Recurrent is two times or more in a 5 year period. (BAAQMD 12- 12 -401.4.3)

Att H Rev 2 Prevention Measures June 2006 – Present FMP.doc Date Process or

Equipment Item Flaring Event Description Root Cause Finding Action Item(s) Proposed Dates/Status Duration, Flow & Emissions Consistency with Fl are Minimization Plan (12

- 12

- 406.3) ESDR No.

Recurrent Failure ? blocked. 6/10/13 Removal of RFG A

Feed to Air Liquide due to Presence of Atomized Oil On June 10, 2013, the Air Liquide Hydrogen Plant located next to the refinery experienced a sudden increase in differential pressure in its coalescer filter. Feed gas referred to as RFG A flows through the coalescer from the Phillips 66 Rodeo Refinery to the Air Liquide Hydrogen Plant and then on to its Hydrogen Reformer. At approximately 11:00 AM RFG A was shutout by Air Li quide. This resulted in flaring of scrubbed gases. During the upset, flow from the Unicracker D

- 301 Debutanizer triggered an alarm. Flow was diverted from the Unit 233 Fuel Gas System to the flare to respond to the alarm and to minimize additional unit impacts. This resulted in the flaring of unscrubbed gases. Flaring occurred intermittently from June 10 through June 11, 2013 at 9:25 PM. 1. 4

- PIC

- 176 Incorrect Calibration and Erroneous Pressure Indication 1. Re

- calibrate 4

- PIC

- 176. 2. Update 4

- PIC

- 176

c alibration documentation to reflect necessary
pressure offset adjustment for glycol filled leg.

. 3. Consider adding a 4

- PIC

176 low pressure alarm set at 145 psig. 1. COMPLETED 6/28/13 2. COMPLETED 8/26/13

3. COMPLETED 9/6/13

. Low pressure alarm was added as original ly premised. Duration:22 hours

Flow : 1,818 MSCF

Emissions

SO2

– 786 lbs (H2S = 0.27 %) NMHC

– 1,516 lbs Methane

– 348 lbs  Reduced Consumption of Fuel Gas (4.2.1.3)

 Upset/Malfunction (4.2.1.4)

- Failure of Instrumentation

 Upset/Malfunction (4.2.1.4)

– fuel gas quality upsets 227

- 13

N

3. 5

- FIC

- 015 Conservative High Flow Alarm Set Point

- Adjust 3 FIC 015 High Flow Alarm Set Point from 2.5 MMSCFD to 5 MMSCFD to allow for more sour gas to be vented to U233 fuel gas system rather than to blowdown. COMPLETED 7/30/13

4. Air Liquide Coalescer Location

- Meet with Air Liquide to discuss possibility of relocating existing coalescer on RFG A to upstream of 120

- FIC

- 115 control valve or to provide a new Knock Out vessel upstream of 120

- FIC

- 115. COMPLETED 8/15/13. On

- going discussions are continuing about feasibility of this project.

### Flare Minimization Plan, BAAQMD 12- 12

Phillips 66, San Francisco Refinery
BAAQMD Plant 16

### Flare Minimization Plan, BAAQMD 12-12 San Francisco Refinery
BAAQMD Plant 16



# ATTACHMENT I

STORAGE, TREATMENT, & RECOVERY SCHEMATIC

### Flare Minimization Plan, BAAQMD 12-12 San Francisco Refinery
BAAQMD Plant 16



# ATTACHMENT J

(Reserved)

### Flare Minimization Plan, BAAQMD 12-12 San Francisco Refinery
BAAQMD Plant 16



# Attachment N

Cost Effectiveness Calculation Background Material

### Flare Minimization Plan, BAAQMD 12-12 San Francisco Refinery
BAAQMD Plant 16



# Cost Curves for Major Equipment

### Flare Minimization Plan, BAAQMD 12-12 San Francisco Refinery
BAAQMD Plant 16



# Cost Effective & Emission Calculations for

Storage, Treatment, and Recovery Cases 1 - 4