Document 2n3ygkYYrooZOG6jGEDMaXB6
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 6 1201 ELM STREET, SUITE 500 DALLAS, TEXAS 75270-2102
September 24, 2020
VIA EMAIL: bgrantham@targaresources.com
Mr. Bill Grantham Targa Midstream Services, LLC - Venice Gas Processing Plant 811 Louisiana Street, Suite 2100 Houston, Texas 77002
RE: Emission Inventory Permit Consistency Review Targa Midstream Services, LLC - Venice Gas Processing Plant (AI# 17897)
Dear Mr. Grantham:
The U.S. Environmental Protection Agency (EPA) Region 6 is working with the Louisiana Department of Environmental Quality (LDEQ) and has reviewed your facility's 2018 emission inventory for criteria pollutant and hazardous air pollutant (HAP) emission totals, as reported to LDEQ. Based upon this review, EPA has determined that your reported emissions for some Emission Points exceeded your permit authorization limits. EPA had also reviewed your Title V reports for 2018 and did not find that these permit exceedances were reported.
A detail by Emission Point of the differences between the reported emissions and permitted limits is included in the attachment to this letter. EPA is providing you the opportunity to clarify or explain these differences, especially if any of the following conditions are present:
Sources and associated emissions included in the emission inventories that are not represented in permits (e.g. de minimis sources);
Criteria pollutants or individual HAPs reported in the facility's emission inventories that are not represented in LDEQ permits or authorizations;
Reported or unreported upset or other excess emission events (e.g. startup/shutdown).
If Targa Midstream Services, LLC (Targa). is interested in discussing or providing information about this matter, you have ten (10) working days from receipt of this letter to inform EPA by e-mail by contacting:
Jack Telleck Enforcement Officer (ECDAT) Air Toxics Enforcement Section U.S. EPA, Region 6 email: telleck.jack@epa.gov
Subsequent to the above-referenced due date, Jack Telleck will arrange to meet with Targa via conference call. At that time, Targa may provide additional information to address the potential violations and present evidence that contravenes EPA's evidence.
The primary goal is to ensure compliance with the applicable environmental laws and regulations; however, settlements will be available where appropriate.
Please direct questions to Jack Telleck of the Air Enforcement Branch at 214-665-9732 or at telleck.jack@epa.gov. Thank you for your attention to this matter.
The EPA acknowledges that the COVID-19 pandemic may impact your business. If that is the case, please contact us regarding any specific issues you need to discuss.
Sincerely,
STEVEN THOMPSON
Digitally signed by STEVEN THOMPSON DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=STEVEN THOMPSON, 0.9.2342.19200300.100.1.1=68001003652657 Date: 2020.09.24 13:34:56 -05'00'
Steve Thompson Chief Air Enforcement Branch
Attachment ECC: Celena Cage, Louisiana Department of Environmental Quality, celena.cage@la.gov
Attachment A Targa Midstream Services LLC - Venice Gas Processing Plant
AI #
Facility Name
Permit
Subject Item
Subject Item Type
17897 VENICE GAS PROCESSING PLANT 2240-00015-V7 EQT00000000009 17897 VENICE GAS PROCESSING PLANT 2240-00015-V7 EQT00000000009
Flare Flare
Subject Item Desc
Process Flare Process Flare
Emission Type
Routine Routine
Parameter Desc
Carbon monoxide Nitrogen oxides
Permitted Limit (tpy)
2.91 0.64
ERIC Reported Emissions
(tpy)
10.29
4.961
Reported Emissions Over Permited Limit
(tpy)
7.38
4.32