Ohio Refining failed to maintain nine flare flow meters in accordance with the requirements of Table 13 of MACT Subpart CC, perform a benzene analysis for a set of fenceline monitoring samples, accurately measure, calculate, and record volumetric flow rate of assist steam used for its West Flare, operate the West Flare to maintain an NHVcz at or above 270 Btu/scf, and record images a reasonable distance above the West Flare flame suitable for visual emissions observations, all in violation of MACT Subpart CC. Additionally, Ohio Refining failed to install, operate, and maintain a Fluid Catalytic Cracking Unit flow meter according to the requirements in Table 41 of MACT Subpart UUU. There is a concurrent CAFO with this ACO.
This ACO requires Ohio Refining to (1) replace a flow meter with one that will meet the regulatory accuracy requirements across the full range of operation; (2) review the logic for its flare control programming to ensure that it properly handles all normal operating conditions and common upset conditions; (3) review its procedures for replacing flare monitoring and control equipment to ensure correct settings are in place before new equipment starts operation; (4) implement a notification that is triggered by 4 NHVcz calculations using the same value for any given parameter; and (5) implement an alarm when a steam control valve is open but the flow meter is reading zero flow. Additionally, Ohio Refining already conducted an audit of the laboratory which