On May 21, 2004, BP self disclosed the Refinery MACT violation. BP discovered a valve that vented from one drum to another had been shut off due to pipe corrosion. The drum contained enough 2,2,4 trimethylpentane to be subject to the MACT as a miscellaneous process vent. The drum's emissions needed to be controlled by a flare to be in compliance with the MACT. BP constructed new piping to another drum which is vented to a flare.
During the test, BP emitted lead into the atmosphere at a higher rate than the regulation in the HWC MACT. BP discovered the emissions were related to the testing conditions and re-tested the incinerator in May 2004. The follow up test showed compliance. This violation was not a self disclosure. Both violations are included in the same CAFO and the penalty amount is for both violations.