NOTE: This case is important as it is based on the simple fact that the facility did not follow it’s own internal procedures regarding changes and construction. This incident also occurred via a “TEMPORARY CHANGE” where the MOC called for a check-valve, the spec’s called for a check-valve; yet a check-valve was NOT installed. This construction error was not captured before the change was put into service and this allowed for the discharge to occur.
Respondent owns and operates a petroleum refinery where Respondent operates the Number 12 Pipestill (No. 12PS), which Respondent began operating in June of 2013. No. 12PS fractionates crude oil into various products and sends these products to other refinery units for further processing. Respondent operates a “Once Through Cooling Water (OTCW)” system at the Facility. The OTCW system is used as non-contact cooling water throughout the Facility. The OTCW system flows through a piping system to Six Separator for treatment. Six Separator is open to the ambient air and works by allowing time for oil, if any, to float to the surface based on the difference in density between oil and water. The OTCW flow ranges from 55 to 85 million gallons per day and the residence time varies from 50 to 90 minutes.
On March 24, 2014, a discharge of crude oil from the Facility to Lake Michigan occurred from the Facility’s OTCW system outfall located at Six Separator. Respondent conducted an investigation of the March 24, 2014 crude oil discharge to Lake Michigan and issued an “Incident Investigation Report” (“Report”) dated August 20, 2014, that described the findings and recommendations from the investigation.