Document 2JoG8Ymv98RqE1Yvj56aMRovr
EPA Inspection Report - Page 1 of 5
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
04/18/2022 Air SIP, Title V
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) County/Parish: Facility Phone Number Facility Contact:
NuStar Energy L.P. St. James Terminal 7167 Koch Road St. James, LA, 70086 St. James Parish 225-746-2117 Brad Roig Brad.roig@nustarenergy.com
Health, Safety and Environmental (HSE)
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
110007278908 LDEQ Agency Interest Number 36538, Title V: 2560-00013-V9 AFS#: 22-093-00013 424710, Petroleum Bulk Stations and Terminals 5171, Petroleum Bulk Stations and Terminals
Personnel participating in inspection:
Christopher Williams
EPA-OECA-OCE-AED
Richard Helmich, Ph.D.
OECA-OCEFT-ONEIC-LB
David Mahoney
OECA-OCEFT-ONEIC-FB-CRSS
Ali Gitipour, Ph.D.
EPA-ORD-CEMM-AMCD
Cory Lormand
LDEQ-OEC-Surveillance Division
Chemical Engineer Senior Chemist Physical Scientist Technician Federal Postdoctoral Research Fellow/Chemical Engineer Environmental Scientist
EPA Lead Inspector Signature/Date
CHRISTOPHER WILLIAMS Date: 2022.07.12 10:07:54 -04'00' Digitally signed by CHRISTOPHER WILLIAMS
Christopher Williams
Date
Supervisor Signature/Date
JAMES LEATHERS Date: 2022.07.12 09:26:42 -05'00' Digitally signed by JAMES LEATHERS
{Supervisor name}
Date
6ENFORM-019-R8.2 (02/12/2020)
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EPA Inspection Report - Page 2 of 5
Section I - INTRODUCTION PURPOSE OF THE INSPECTION
NuStar / St. James Terminal Inspection Date 04/18/2022
On April 18, 2022, the Government Team consisting of Mr. Richard Helmich (EPA-NEIC), Mr. Ali Gitipour (EPA-ORD), Mr. David Mahone (EPA-NEIC), Mr. Christopher Williams (EPA-OECA) and Mr. Cory Lormand (LDEQ-OEC) arrived at the NuStar Energy L.P. ("Nustar") St. James Terminal in St. James Parish at around 1:30 P.M. local time to conduct an unannounced Clean Air Act ("CAA") inspection.
The Government Team signed in with security at the gate and were directed to a conference room in the main office building. In the conference room the Government Team was introduced to NuStar representatives Mr. Brad Roig, HSE Supervisor, Mr. Marcello Cornejo, Terminal Manager, and Mr. Jean Zeringue, General Manager of Operations. Mr. Williams presented his inspector credentials to Mr. Zerinque and notified him of the Government Team's intent to conduct a CAA Partial Compliance Evaluation ("PCE"). This inspection occurred as part of the Administrator's Multi-Scale Monitoring Project called the Pollution Accountability Team (PAT).
FACILITY DESCRIPTION
Petroleum products are transported to the St. James Terminal (LDEQ Agency Interest Number 36538) by barges, ships, pipelines, rail cars and truck where they are either stored until shipped out by barges, ships an pipelines or to other facilities or pipelines. The petroleum products transported to/from and stored at the St James Terminal include crude oil, no. 6 oil, distillate fuel oil no. 2, vacuum gas oil and marine diesel. The facility operated over 35 storage tanks with a combination of fixed roofs, external floating roofs ("EFRs"), and internal floating roofs ("IFRs").
Section II - OBSERVATIONS
Opening Conference At around 1:55 P.M., the Government Team conducted an opening conference with NuStar representatives, Mr. Roig, Mr. Carnejo and Mr. Zerinque. Mr. Helmich explained that the compliance evaluation would include a mobile air monitoring survey of the facility using Geospatial Measurement of Air Pollution ("GMAP") and provided an overview of the vehicle and equipment. Mr. Williams explained that he would be using a FLIR GF320 optical gas imaging ("OGI") camera and a handheld photoionization detector ("PID") to locate any hydrocarbon emission sources upwind of detections made by GMAP. Mr. Helmich and Mr. Williams asked the NuStar representatives to begin processing any hot work permits required by the company to gain full access to the facility using the described equipment. Mr. Williams asked the company to let the Government Team know if any Confidential Business Information is obtained during the PCE, so that the information could be treated by the custodians as such. Mr. Carnejo confirmed that the facility was operating as normal and that EFR Tank 9 was the only tank being loaded at this time. At around 2:20 P.M. the opening conference concluded, and the Government Team prepared the vehicles and equipment for entry into the tanks' operations area.
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EPA Inspection Report - Page 3 of 5
NuStar / St. James Terminal Inspection Date 04/18/2022
Site Tour At around 2:25 P.M., Mr. Williams took a photo of the NuStar entry sign (DC_171.jpg) and the Government Team began the site tour. Conditions were sunny with some cloud cover, and with moderate winds coming from the north to northwest. In the mobile air monitoring vehicle, Mr. Helmich, Mr. Gitipour and Mr Mahone were escorted by Mr. Roig. In a company vehicle following, Mr. Williams and Mr. Lormand were escorted by Aaron Martinez, Maintenance. The mobile air monitoring vehicle drove on all available roads in the tanks' operations area.
At around 3:00 P.M. downwind of IFR Tank 25, GMAP detected elevated concentrations of VOC (at around 2,500 ppb) at ground-level. Mr. Williams and Mr. Lormand exited the vehicle to inspect Tank 25. Using OGI, Mr. Williams recorded video MOV_172 of emissions emanating from the downwind brow vents and video MOV_173 of emissions emanating from the upwind brow vents on Tank 25. Mr. Roig confirmed that Tank 25 was not loading at the time of the emissions observations.
At around 3:40 P.M. downwind of the EFR Tank 6, GMAP detected elevated concentrations of VOC (at around 1,200 ppb) at ground-level. Mr. Williams, and Mr. Lormand exited the vehicle to inspect Tank 6. Using OGI, Mr. Williams recorded video MOV_174 of emissions coming out of the top rim of Tank 6. Mr. Roig confirmed that Tank 6 was not loading at the time of the emissions observations.
At around 3:50 P.M., the Government Team exited the tanks' operations area and returned to the conference room.
Section III - AREAS OF CONCERN
At around 4:00 P.M., the Government Team conducted a closing conference with NuStar representatives Mr. Roig, Mr. Carnejo and Mr. Zerinque. Mr. Helmich and Mr. Williams provided a summary of the areas of concern, which include the observations of emissions coming from Tank 25 and Tank 6 as described above. Mr. Williams was designated as the EPA contact for any potential followup. The closing meeting concluded at around 4:30 P.M. and the Government Team exited NuStar's facility.
Section IV - FOLLOW UP
No additional information was received by EPA after exiting the NuStar's facility on April 18, 2022.
Section V - LIST OF APPENDICES
Appendix 1 - Photo and Video Log - 1 photo and 3 OGI videos taken April 18, 2022.
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NuStar / St. James Terminal Inspection Date 04/18/2022
Appendix 1 Photo and Video Log
EPA Inspection Report - Page 5 of 5
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photo and Video Log
Appendix 1
Location: NuStar St. James Parish
City: St. James
St. James Parish
State: Louisiana
File Name: Date taken: Time taken: Videographer: Description:
DC_171.jpg 04/18/2022 2:26 pm Christopher Williams Photo of the NuStar entry sign.
File Name: Date taken: Time taken: Videographer: Description:
MOV_172.mp4 04/18/2022 3:09 pm Christopher Williams OGI video of emissions emanating from downwind brow vents on Tank 25.
File Name: Date taken: Time taken: Videographer: Description:
MOV_173.mp4 04/18/2022 3:28 pm Christopher Williams OGI video of emissions emanating from upwind brow vents on Tank 25.
File Name: Date taken: Time taken: Videographer: Description:
MOV_174.mp4 04/18/2022 3:41 pm Christopher Williams OGI video of emissions from the top circumference of Tank 6.
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