Document 6RQ6MnJQLx1NLyBqpxxBw8Jb4
EPA Inspection Report - Page 1 of 26
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
03/24/2022 Air Louisiana SIP, NESHAP (40 CFR Part 63), NSPS (40 CFR Part 60)
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Phone Number Facility Contact:
BWC Harvey LLC BWC Harvey Terminals 81805 Fourth Street Harvey, LA 70058 81805 Fourth Street Harvey, LA 70058 Jefferson Parish (225) 331-4000 Jessica Sisto jsisto@bwcterminals.com
HSEQ Manager
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
110000448766 LDEQ Agency Interest (AI) Facility ID 2119, Air Permit 1340-00005-12 ICIS-Air LA0000002205100005 493190 Other Warehousing and Storage 4226 Special Warehousing and Storage, Not Elsewhere Classified
Personnel participating in inspection:
Prince Nfodzo
EPA Region 6 ECDAP
Aimee Boss
EPA Region 6 ECDAP
Brian Fontenot
LDEQ, New Orleans
Jodi Holewka
LDEQ, New Orleans
Jessica Sisto
BWC Harvey Terminal
Jack Fernandez
BWC Harvey Terminal
Blake Chatagnier
BWC Harvey Terminal
Environmental Engineer Physical Scientist Environmental Scientist Environmental Scientist HSEQ Manager Director of Operations Terminal Manager
EPA Lead Inspector Signature/Date
Branch Chief Signature/Date
PRINCE NFODZO
Digitally signed by PRINCE NFODZO DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=PRINCE NFODZO, 0.9.2342.19200300.100.1.1=68001003655862 Date: 2022.05.09 10:24:14 -05'00'
Prince Nfodzo
Digitally signed by STEVEN
STEVEN THOMPSON THOMPSON
Date: 2022.05.09 10:59:47 -05'00'
Steve Thompson
05/09/2022
Date
05/09/2022
Date
6ENFORM-019-R8.2 (02/12/2020)
1
EPA Inspection Report - Page 2 of 26
Section I - INTRODUCTION
BWC Harvey Terminals, Harvey, LA Date of Inspection: 03/24/2022
PURPOSE OF THE INSPECTION EPA Region 6 inspectors Prince Nfodzo and Aimee Boss, and LDEQ inspectors Brian Fontenot and Jodi Holewka arrived at the BWC Harvey Storage and Transfer Terminal ("BWC Harvey") at 8:30 am on March 24, 2022, for an unannounced inspection. We met with BWC Harvey representatives Jessica Sisto (HSEQ Manager), Blake Chatagnier (Terminal Manager), and Jack Fernandez (Director of Operations). I (Prince Nfodzo) presented my credentials to Jessica Sisto and informed them that this was an EPA inspection to determine compliance with the facility's Air Permit and the Clean Air Act. The facility is the subject of several citizen complaints regarding strong asphalt odors. The scope of the inspection is a full compliance evaluation (FCE) under applicable provisions of the CAA, and includes evaluation of the compliance of the facility with its operating permit.
FACILITY DESCRIPTION BWC Harvey is a bulk liquid storage and transfer facility located in Harvey, Louisiana. The facility is situated on the west bank of the Mississippi River in Jefferson Parish. The facility receives, and ships products by barge, vessels, rail cars, and trucks. Products handled by BWC Harvey include asphalt, slurry oil, pet tar, coal tar, low sulfur fuel, creosote, caustic soda, and other special branded products. The products are stored in above ground storage tanks until further distribution to end users. The facility's current permit includes an affected source under 40 CFR 60 Subpart JJJJ - NSPS for Stationary Spark Ignition Internal Combustion Engines and 40 CFR 63 Subpart ZZZZ - NESHAP for Stationary Reciprocating Internal Combustion Engines, and affected sources under 40 CFR 60 Subpart Dc - NSPS for Small Industrial-Commercial-Institutional Steam Generating Units.
The facility was previously operated as Chemtura Corporation - Gretna Facility ("Chemtura"). On December 17, 2009, Chemtura notified LDEQ that the facility had been shut down, decommissioned, demolished, and closed since 2008, and requested the closure of the site's air permit. BWC Harvey LLC, formerly Blackwater Harvey LLC, purchased the site from Chemtura on July 11, 2013, and applied for its initial permit to operate the facility as a for-hire bulk liquid terminal on August 19, 2013.
Section II - OBSERVATIONS Prior to making entry to the facility, EPA inspectors conducted fenceline and community surveillance on March 21, 2022, from 4:22 pm to 4:52 pm, March 23, 2022, from 2:35 pm to 3:30 pm, and March 24, 2022, from 7:50 am to 8:15 am. We did not observe any visible emissions, and did not observe any hydrocarbon emissions with a Forward Looking Infrared (FLIR) optical gas imaging (OGI) camera. We perceived an asphalt odor along Fourth Street, outside of BWC Harvey's boundary, at 4.50 pm on March 21, 2022, but we could not identify the source of the odor.
A. Generators BWC Harvey's air permit includes one emergency generator which has not been constructed/installed. There is no indication that BWC Harvey intends to install and operate the generator (see Area of Concern (AOC) #1).
2
EPA Inspection Report - Page 3 of 26
BWC Harvey Terminals, Harvey, LA Date of Inspection: 03/24/2022
B. Process Heater and Boilers BWC Harvey operates two (2) process heaters and two (2) boilers with no emission control equipment. However, BWC Harvey's permit includes only one process heater (see AOC #2). We did not observe any visible emissions. I viewed the exhaust vents with a FLIR OGI camera and did not observe any hydrocarbon emissions. BWC Harvey is meeting emission limit requirements by using sweet natural gas as fuel. I reviewed fuel records and verified that BWC meets the fuel and recordkeeping requirements. BWC Harvey has also maintained the heater and boilers per manufacturer' specifications.
C. Storage Tanks and Loading Operations BWC Harvey's air permit includes 53 storage tanks. Specific Requirement (SR) 27 of the permit requires that products which are stored in the tanks must have a true vapor pressure not exceeding 0.75 pounds per square inch (psia). The storage tanks are equipped with temperature gauges, and BWC Harvey monitors the temperature of each tank's contents during each shift to ensure that maximum temperatures required to meet the vapor pressure limits are not exceeded. I reviewed the temperature monitoring records and noted that BWC Harvey maintained product temperatures below the design maximum. A sample of the temperature monitoring record (Shift Steam Report) is included as Appendix 3.
During the inspection, we observed loading of fuel oil from a marine vessel to Tanks 1003 and 5080. The temperature at the tanks at the time of the inspection was about 90 degrees Fahrenheit (F) and 100F, respectively. We did not perceive any unusual or disagreeable odors, and did not observe any visible emissions. I viewed the tanks and ancillary equipment with a FLIR OGI camera and did not observe any hydrocarbon emissions. I reviewed storage tank operation and maintenance records, and noted that BWC Harvey's permit included tanks that have been demolished, not constructed, or not in service (see AOC #3).
SR 28 and SR 31 of BWC Harvey's permit require that toxic air pollutants (TAPs) and volatile organic compounds (VOCs) emissions from the tanks shall not exceed 10.00 tons/year and 64.79 tons/year, respectively. I reviewed emissions records for calendar years 2019 to 2022 and noted that BWC Harvey did not exceed the annual TAP and VOC emission limits.
I reviewed records of the volumes and types of material loaded, and noted that BWC Harvey maintained records as required by SR 26. I also noted that records were maintained for contents and throughput of each storage vessel on a monthly basis in accordance with SR 25.
D. Other Observations In response to the several complaints regarding odor in the neighboring community, BWC Harvey, under no obligation by any statutory requirement, implemented corrective measures to address the community's concerns. BWC Harvey installed: two (2) odor neutralization systems on its asphalt holding tanks in October and November 2020; a 2000-pound capacity activated carbon adsorption system on the creosote tank in April 2021; and a 1000-pound capacity activated carbon adsorption system on its truck loading rack in March 2021. Photographs of the 2000-pound activated carbon adsorption system, and one of the odor neutralization systems are included as Photo No. 1 and Photo No. 2, respectively in
3
EPA Inspection Report - Page 4 of 26
BWC Harvey Terminals, Harvey, LA Date of Inspection: 03/24/2022
Appendix 1. BWC Harvey also engaged a third party to conduct an industrial hygiene assessment at the facility. The audit report, excluding Appendices, is included as Appendix 4.
E. Forward Looking Infrared (FLIR) Optical Gas Imaging Surveillance I used a FLIR OGI camera ("the camera") during the field inspection to look for the presence of hydrocarbon emissions. I used the camera to view specifically Tanks #s 16-2, 1003, 1204, 2505, 2507, 5052, 5055, 5057, and 5080 from ground level, and a broader view of all the tanks from the roof of Tank 5055. I used the camera to view loading of fuel oil from a ship to Tanks 1003 and 5080. I also used the camera to view process heater and boiler vents, compressors, and ancillary pipe works. I did not observe hydrocarbon emissions at any point during the field inspection.
Section III - AREAS OF CONCERN 1. BWC Harvey's air permit 1340-00005-12 includes a provision for the construction and installation of one (1) emergency generator, represented as EQT 0047. However, this generator has not been installed. Since BWC has not shown any intent to construct/install the generator, EQT 0047 with its associated emission representations should be removed from the permit. 2. BWC Harvey operates two (2) process heaters, but only one (1) heater (represented as EQT 0057) is included in the permit. BWC Harvey is potentially operating the second heater without appropriate emission authorization. 3. BWC Harvey's storage tank records show a total of 57 tanks, out of which five (5) have not been constructed or have been demolished, and two (2) which are out of service (i.e., constructed, but without associated lines to receive or transfer product). Tanks 26-1, 1207, and 2504 have not been constructed, and Tank 16-2 is not in service, but all three tanks are included in the permit. BWC Harvey should remove these tanks and associated emission representations from the permit since the facility has not shown the intent to construct and/or operate these tanks.
EPA Region 6 inspectors Prince Nfodzo and Aimee Boss conducted a closing conference for the inspection at BWC Harvey at 4:22 pm on March 24, 2022. During the closing conference, I presented preliminary findings of the inspection, and reviewed AOC #1, which was noted during the inspection. I informed the representatives of the review process that will follow the field inspection, and that the inspection report will be made public on EPA's web site. Additionally, AOC #s 2 and 3 were determined after the conclusion of the inspection, and were not included in the closing conference debriefing to BWC Harvey. The sign-in sheets for the opening and closing conferences are included as Appendix 2. Since no hydrocarbon emissions were observed with the FLIR OGI camera, there was no video recorded during the inspection, or included with this report.
Section IV - FOLLOW UP After the EPA inspection team exited the Facility on March 24, 2022, BWC Harvey uploaded all the information requested during the inspection to an EPA shared OneDrive folder by April 1, 2022. On April 8, 2022, I had a follow-up call with BWC Harvey representatives to discuss some of the records provided, and also requested additional information regarding emissions records and safety data sheets (SDS) for each product BWC Harvey handles. The additional information regarding emissions records and SDS were uploaded to the shared folder by April 18, 2022. Additional information to supplement what was requested on site also was uploaded to the shared folder on April 18, 2022.
4
EPA Inspection Report - Page 5 of 26
Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 2 photos taken 3/24/2022 Appendix 2 - Opening and closing conference sign-in sheets Appendix 3 - Shift Steam Report Appendix 4 - Industrial Hygiene Audit Report
BWC Harvey Terminals, Harvey, LA Date of Inspection: 03/24/2022
5
EPA Inspection Report - Page 6 of 26
BWC Harvey Terminals 03/24/2022
Appendix 1 Photograph Log
EPA Inspection Report - Page 7 of 26
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: BWC Harvey Terminals City: Harvey
Photo No. 1 County/Parish: Jefferson
State: Louisiana
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0774.JPG March 24, 2022 2:25 pm Aimee Boss 2000 lb Activated Carbon Adsorption System
EPA Inspection Report - Page 8 of 26
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Location: BWC Harvey Terminals City: Harvey
Photo No. 2 County/Parish: Jefferson
State: Louisiana
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0772.JPG March 24, 2022 2:34 pm Aimee Boss Odor Neutralization System
EPA Inspection Report - Page 9 of 26
Appendix 2 Opening and closing conference sign-in sheets
EPA Inspection Report - Page 10 of 26 FRS: 110000448766 BWC Harvey, LLC - Storage & I ran!:> fCI I Ulltllllc..ll
11:,unJ ul
Opening/Pre-Inspection Meeting
Commence opening/pre-inspection meeting_____ ~.? .L~y_J _~-~~------Time: 8 . ?;/o Ct"Wl-
Name Prince Nfodzo Aimee Boss
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Title Environmental Engineer Physical Scientist
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EPA Inspection Report - Page 11 of 26 FRS: 110000448766 BWC Harvey, LLC - Storage & Transfer Terminal
Page 25 of 27
Exit interview I Out-briefing Meeting
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Name Prince Nfodzo Aimee Boss
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EPA Inspection Report - Page 12 of 26
Appendix 3 Shift Steam Report
EPA Inspection Report - Page 13 of 26
BW TERMINALS HARVEY DAILY SHIFT STEAM CHECK SHEET
Product Name
Time
Steam On or Steam Off
Tank Inventory Level
Current Temperature
Maximum Temperature per Customer
Tank Circulation or Sparging
Comments
Operator Initials
0700
Off
2501
XTOL 651
1500
Off
210
2300
Off 11-11-1/8 OUT
200
Off
A
0700
Off
2503
Liqrene D
1500
Off
210
2300
On 20-8-5/8 OUT
180
Off
A
0700
Off
1202
Morlife 5000
1500
Off
140
2300
Off 32-1-5/8 OUT
45
Off
A
0700
Off
1204
Morlife 5000
1500
Off
140
2300
Off 17-8-1/4 OUT
57
Off
A
0700
Off
1206
Morlife 5000
1500
Off
140
2300
Off T/T
86
Off
A
0700
Off
5066
Pitch
1500
Off
210
2300
Off 6-3-3/8 OUT
190
Off
A
0700
Off
2507
Petroleum Tar
1500
Off
160
2300
Off 32-4-1/2 OUT
135
Off
A
0700
Off
2508
Coal Tar
1500
Off
160
2300
Off 46-1-15/16 OUT
79
Off
A
0700
Off
5067
Creosote
1500
Off
160
2300
Off 19-3-0 OUT
138
Off
A
0700
Off
1501
Clarified Oil
1500
Off
210
2300
Off 15-3-1/2 OUT
78
Off
A
0700
Off
2402
Clarified Oil
1500
Off
210
2300
Off T/T
102
Off
A
0700
Off
2505
Slurry Oil
1500
Off
210
2300
Off 43-6-5/8 OUT
75
Off
A
0700
Off
2506
Slurry Oil
1500
Off
210
2300
Off 2-10-3/8 OUT
75
Off
A
0700
Off
2502
Asphalt
1500
Off
330
2300
On 23-2-3/8 OUT
325
Off
A
0700
Off
5053
Asphalt
1500
Off
330
2300
On 2-11-1/2 OUT
300
Off
A
0700
Off
5055
Asphalt
1500
Off
330
2300
On 9-1-0 OUT
325
Off
A
0700
Off
5057
Asphalt
1500
Off
330
2300
Off 9-9-3/4 out
250
Off
A
0700
Off
5058
Asphalt
1500
Off
330
2300
Off 32-6-3/4 OUT
155
Off
A
0700
Off
5068
Asphalt
1500
Off
330
2300
On 3-6-0 OUT
260
Off
A
0700
Off
5069
Asphalt
1500
Off
330
2300
Off 32-2-1/2 OUT
125
Off
A
0700
Off
5070
Asphalt
1500
Off
330
2300
Off 30-2-0 OUT
330
Off
A
EPA Inspection Report - Page 14 of 26
0700
Off
5065
Membrane Caustic
1500
Off
2300
Off 11-5-1/4 OUT
78
Off
A
0700
Off
5075
Fuel Oil
1500
Off
120
2300
Off 6-8-1/4 OUT
69
Off
A
0700
Off
5076
Fuel Oil
1500
Off
2300
Off 28-8-1/8 OUT
70
120
Off
A
0700
Off
5077
Ultra Low Sulfur Diesel 1500
Off
2300
Off 38-0-1/4 OUT
61
Off
A
0700
Off
5078
Fuel Oil
1500
Off
2300
Off 3-1-7/8 OUT
82
Off
A
0700
Off
5079
Fuel Oil
1500
Off
2300
Off 32-7-1/8 OUT
62
120
Off
A
0700
Off
5080
Fuel Oil
1500
Off
2300
Off 10-5-3/4 OUT
87
120
Off
A
0700
Off
5081
Fuel Oil
1500
Off
2300
Off 25-7-1/8 OUT
100
120
Off
A
0700
Off
5082
Fuel Oil
1500
Off
2300
Off 37-7-7/8 OUT
100
120
Off
A
0700
Off
10002
Fuel Oil
1500
Off
2300
Off 9-6-5/16 OUT
93
120
Off
A
0700
Off
10003
Fuel Oil
1500
Off
2300
Off 4-11-15/16 OUT
90
120
Off
A
0700
Off
10004
Fuel Oil
1500
Off
2300
Off 38-1-3/4 OUT
80
120
Off
A
0700
Off
10005
Fuel Oil
1500
Off
2300
Off 45-5-0 OUT
55
120
Off
A
EPA Inspection Report - Page 15 of 26
Appendix 4 Industrial Hygiene Audit Report
EPA Inspection Report - Page 16 of 26
CTEH
THE SCIENCE OF READY SM
BWC TERMINALS
'
IH ASSESSMENT
Harvey, Louisiana Rroject Date May 7, 13, and 25, 2021
Project #114368
Report Submitted on June 16, 2021
EPA Inspection Report - Page 17 of 26
Table of Contents
1.0
2.0 3.0 3 .1 3.1.1 3 .1.2 3.1.3 4.0 5.0 5.1 6.0 6.1 6.1.1 6.1.2 7.0 8.0 9.0 10.0
Summary .... ....... .... .......... ........ ........ ............ ..... .......... .. ....... ... ..... .... .. .. ... ...... ........ .. ...... ... ...... ... ..... 1
Background .............. ......... ... ............ ......... .. .. ....... ...... ...... ............ .. ..... ....... .. ........ .. ........ ............... 1 CTEH Activities ....... .... .... ............................. ............. .... ..... ....... ............. .. .. ... ... .. ... .. ........ ...... .. ........ 1 Observations .. ..... ... ... ...... ........................ .... ........ .... ........ ........ .... .......... ...................... .... .............. 2 Engineering Controls ..... .. ... .... ... ...... .. ......... ..... .. .. ... .. .. ... ... ........ .... ........ .. ........ ... ... ... ............. .. ..... .. 2 Personal Protective Equipment .... ... ......... ............... .... ........ ... ... .. .... ..... ..... .. ....... ......... .................. 3 Environmental Conditions ................. ...... .... .. .. .. ... ........ ... ......... ..... .............. ...... .. ... ..... .................. 3 Exposure Standards and Guidelines ... ..... ..... ................... .. ........ ... ... .. .. .... ............................ ..... .. .. . 5 Methods ........... .. .. .. .. ...... ......... .. .. ................ ..... ...... ......... .. ..... .. ....... .. .. .... ...... .. .... .... .. .. ..... .. ... .... .... 6 Personal and Area Air Sampling .... ........ .............. .. ... ... ...... .. ...... .. .. .................. .... ............ .. ... .... ..... 6 Results and Discussion .......................... .... .. ............. .. ....... ...... .. .... ...... .... .... ........ ............... ............ 7 Air Sampling Discussion ... .. ........ .......... ... .... .. ..... .. ........... .... ... ................ ........... .......... ... ..... ... .... .... 7 Personal Air Sampling Discussion .. .. ..... .... .... ... ..... ...... ............. .......... ... ... ... ..... ..... ...... ................... 7 Area Air Sampling Discussion ............................................................ ... .... ...... .............. .... ...... ....... 7 Representativeness ...... ... .. .... ..... ....... ... ... .... ...... ...... ....... .... .... ... .... .... ....... ....... .. .. .. ... .. .. .. .. ... ... .. ..... 8 Conclusion ..... .. ...... .. .. .. .. .. .... ........ ... ... .. ........... ................ ............. ... .... ... ... .. .. ..... .... .... ...... ..... ......... 8 Recommendations .. ..... ...... .. .. ... ..... .. ....... ...... .......................... ... ..... .. ....... ... ... .... .......... .. ... .... ........ 8 References .. ..... .. ... ... ... ... .. .... .. ...... ................. .... .... ....... ....... .. ............ ...... ... ...... ...... ......... ... .. .. ..... ... 8
IH Assessment BWC Terminals May 2021
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CTEH
THE SCIENCE OF READVM
EPA Inspection Report - Page 18 of 26
List of Tables
Table 1
Table 2 Table 3
Summary of Personal Air Samples and Noise Monitoring .................. .............. .... ........... ....... ... 2 Summary of STEL Sample Activities .... ........ ... ..... .. ... .. ............ .. .. ...... ........ .............. .................... 2 Summary of Air Sampling Methods .................... ........................................... .. .. ..... ........... ........ 6
List of Appendices
Appendix A .. .. ................................ .... ... ........................ ... .. ........................... Personal Air Sampling Summary Appendix B ..................................... ........................... ... .. ....... ..............................Area Air Sampling Summary Appendix C ....................................................................... Area EPA T0-15 Air Sampling Detection Summary Appendix D ....... .. .. .. ............................... .. ....................... ..... ............... .. ............................ Laboratory Reports Appendix E.................................................. .... .. ..... .. ...... ... .............................. . Employee Notification Letters
IH Assessment BWC Terminals May 2021
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I CTEH
THE SCIENCE OF READr
EPA Inspection Report - Page 19 of 26
1.0 SUMMARY
On May 7, 13, and 25, 2021, an industrial hygienist from CTEH, LLC (CTEH) conducted an industrial hygiene assessment at the BWC Terminals facility in Harvey, Louisiana. As part of the assessment, the industrial hygienist collected both personal and area air samples for benzene, toluene, ethyl benzene, and xylenes (BTEX) and total hydrocarbons as hexane, asphalt fumes as benzene-soluble fraction with total dust, coal tar pitch, and petroleum distillates in the breathing zones of workers while they performed routine job tasks. The industrial hygienist also collected area air samples for volatile organic compounds (VOCs) via EPA T0-15 around the perimeter of the facility for a twelve-hour period.
Two types of personal air samples were collected during the assessment: 8-hour Time-Weighted Average (TWA) samples and 15-minute Short-Term Exposure Limit (STEL) samples. All TWA personal air sampling results were below the Occupational Safety and Health Administration (OSHA) Action Level (AL), OSHA Permissible Exposure Limit-Time-Weighted Average (PEL-TWA), and the American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value-Time-Weighted Average (TLV-TWA) where applicable. Additionally, all STEL personal air sampling results were below the OSHA PEL-STEL, OSHAL PEL-Ceiling, and the ACGIH TLV-STEL where applicable.
Results of the area air samples for asphalt fumes as benzene-soluble fraction with total dust, coal tar pitch, and petroleum distillates were below the occupational exposure values (OEVs) set by OSHA and the ACGIH for an 8-hour TWA were established except for one sample for total dust taken along the North fence line on 5/25/21. Results for the MinicanTM evacuated canister samples for voes were below OSHA and ACGIH OEVs and the Agency for Toxic Substances and Disease Registry (ATSDR) Minimal Risk Levels (MRLs) where established.
2.0 BACKGROUND
BWC Terminals contacted CTEH and requested that an industrial hygienist perform an IH assessment, including both personal and area air sampling, at the BWC Terminals facility located in Harvey, Louisiana. The goal of this assessment was to evaluate potential employee and community exposures related to terminal operations. The terminal stores and ships petroleum products including asphalt, pitch, and slurry by means of tanker truck and rail car.
3.0 CTEH ACTIVITIES
On May 7, 13, and 25, 2021, a CTEH industrial hygienist conducted personal and area air sampling. During the assessment, 10 employees had air samples collected in their breathing zones. Additionally, area air samples were taken at four locations around the facility. Table 1 identifies the number of personal and area air samples collected during the assessment.
IH Assessment BWC Terminal s May 2021
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CTEH
THESCIENCE OF READY
EPA Inspection Report - Page 20 of 26
Table 1 Summary of Personal Air Samples and Noise Monitoring
Analyte(s) BTEX and total hydrocarbons as hexane BTEX and total hydrocarbons as hexane Asphalt fumes as benzene-soluble fraction with total dust Petroleum distillates Coal tar pitch Asphalt fumes as benzene-soluble fraction with total dust Petroleum distillates Coal tar pitch
voes via EPA T0-15
Sample Type TWA STEL TWA TWA TWA Area Area Area Area
Number Collected 4 2 4 4 4 12 12 12 12
3.1 Observations
During the industrial hygiene assessment, the CTEH industrial hygienist observed the work activities of the area operators. Tasks observed by the industrial hygienist included operator rounds, tank gauging, and truck loading. Two STEL samples were obtained for BTEX and total Hydrocarbons on two operators performing truck loading and tank gauging operations. These tasks were selected by site management. Historical weather data was obtained for each day of sampling to reference environmental conditions that may impact the sampling events. Wind direction, temperature, and humidity may dictate the concentrations of potential contaminants at each sample point. Table 2 provides a summary of tasks associated with each STEL sample.
Name
Table 2 Summary of STEL Sample Activities
Job Title
Task
-r-- ---
3.1.1 Engineering Controls
Operators utilized a vapor recovery system located on the truck loading rack that recovered vapors emitted during the product loading process which controls the potential buildup of chemical vapors.
IH Assessment BW C Terminals May 2021
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CTEH
THE SCIENCE OF READYu
EPA Inspection Report - Page 21 of 26
3.1.2 Personal Protective Equipment
Operators wore personal protective equipment including flame-resistant clothing, safety glasses, ha rd
hats, ear plugs, and personal hydrogen sulfide monitors. Operators also utilized face shields for certain tasks with potential splash hazards.
3. 1.3 Environmental Conditions
May 7, 2021
Time 12:53 AM 1:53AM 2:53 AM 3:53 AM 4:53 AM 5:53 AM 6:53 AM 7:53 AM 8:53 AM 9: 53AM 10:53 AM 11:53 AM 12:53 PM 1:53 PM 2: 53PM 3:53PM 4:53 PM 5:53PM 6:53 PM 7:46 PM 7:53PM 8:53 PM 9:53PM 10:53 PM 11:53 PM
Temperature 73 ' F 65 "F 64 ' F 63 ' F 63 ' F 63 'F 63 ' F 71 ' F 76 ' F 76 ' F 78 'F 81 ' F 82 ' F 83 ' F 85 'F 85' F S5 ' F 84 ' F 82 ' F 79 ' F 79 'F 79' F 76 'F 77 ' F 76 ' F
DewPoint 56 ' F 59 ' F 59 F 59 ' F 59 ' F
S ~' F
59 ' F 62'F
57 ' F 57 ' f 57 ' f SS ' F
53 ' F 52'F 50'F 51 ' F 51 ' F 51 F 53 'F SS ' f SS ' F 57 ' F 58 ' F 56 'F 55 'F
Humidity 55 % 81 %
87 % 87 %
87 % 73% 52 % 52 %
41 % 37 9~
31 %
3 n~
32 % 37% 48 % 40 % 47% 54 % 48 %
Wind N CALM CALM
w
CALM CALM
w
WNW
NW VAR NNW NW NNW N NW NW fl!NW NNW NNW
NE ENE
WmdSpeed 3 mpn Ompll Om ph 3 mpll Omph Ompll l mpll .3 mph 7mpll 12 mph 10 mph 6mpn ' l m ph & mph 10 mph 9 mpll 9 mph Smpll 7 mpll 3 mph :S mph Smpll 2 mpt. 5mpl\ l mph
Wind Gust Om ph Omph Omph Omph Omph
Omph Omph Om ph Omph
O m p ~.
Omph Omph Omph -Omph Omph Omph Omph Omph Omph Qmph Omph Omph Omph
Pressure 30.13 In 3D-1 2 1n 30.10 In 30.l Oin 30 10 1n 3QJ1 in 30 13 in
30 . 1 6 i ~
3Q.1 8 In JQ.1 9 in 3Q.20 In 30 l 8 1n 30 15 in 30.14 in 30 l2 in 30.1 0 in 30.08 in 30.07 in 30.07 In 30,07 In 3007 In 30.08 in 30.09 in 30.08 in 30.08 In
Plecip. 0.0 In 0.0 In O.Oin O.Oin O.Oln O.Oir. O.Ol r. O.Oin O.Oln O.Oin 0.0 In 0.0 In 0.0 in O.Oln O.Oln O.Oln O.Oin O.Oi n 0.0 in 0.0 in 0.0 In O.Oin 0.0 In O.Oin O.Oln
Condition Fair Fail Fair Fai r Fai r Fair Fait Fair Fair Fair Fair Fair Fair Fair
Fair Fair Fair Fair Fair Fair Fair Fair Fai r Fair Fair
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EPA Inspection Report - Page 22 of 26
May 13, 2021
Time 12:53 AM U3AM 2:53AM 3:53AM 4:53AM 5:53AM 6:51 AM 6:53AM J:OSAM 7:53AM S:OOAM 8:53AM 9:53AM 10:53 AM 11:53 AM 12:53 PM 1:53PM 2:53PM 3:53PM 4:53PM 5:53PM 6:53PM 7:53PM 8:53PM 9:53PM 10:53 PM 11:53PM
Temperature 71 f 70F 69 'f 70 F 70 f 69 f 70 'F 69 'F 69 f 70 'f 70'F 71 f 73 f 75 f 75 f 76 f 77 'F 77 'f 77 f 77 'F 77 f 76 f 75 'f 74 f 74 'F 73 f 72 f
Dew Point 62'F 62.F 62'F 62 'F 61 f
61 r
63'f 62,'F 62f 62'F 62.F 61 f 61 'f 61 f 61 f
6or
58 f 59'F 58'f 58'f 58 ' f 57 f
sa r
58'F
57'f 57'F
Hwnklity
73 % 76 3 78 % 7.6 %
73~
75% 7BC;o 78 % 78% 76'1;, 76% 70%
65 ~
62% 62% 58% 52 % 54 11 52 % 52 % 52 % 52 % 55 %
57~
55% 57 % 59%
Wlnel NE NE NE NE NE Nr-!E NNE NE NE NE NE NE NNE NE NNE NNE NE NE NNE NNE NNE VAR Nf.IE N
NNE NE
E
Wind Speed 12mph 9mpb 7 mpll 10mph 9mph 6mpb lOmph 9mpb HI mph Hlmph lOmph 9mpll lOmph 9mpll 12mph 12mpn 13mph 10mph 10mph 12mp:1 8mpb 7mpn Smph 3mph Smpb 6mpb Smph
Wind Gust Omph Omph omph Omph Omph Omph Omph Omph Omph Omph Omph Omph Omph Gmph Omph 21 mph Omph Omph Gmph Omph Omph Omph Omph Omph Omph Omph ()mph
Pressure 30.15 ~ 30.13 in 30.1 2 ill 30.13 in 30.1 3 in 30.1 3 in 30.l 5 1n 30.151n 30.1 6 1n 30.17 in 30.17 in 30.18 1n 30.19 1n 30.20in 30.20 in 30.19 in 30.18 in :30.17 in 30.16 111 30.1 5 !0 30. IS in 30.14 in 30.li in 30.l S in 30.19 in 30.21 In 30.20 1n
Precip. O.Oin C.Oin O.Gln O.Oin C.Oin O.Oin G.Oin G.Oin O.Oin O.Oin
O.Oin 0.0 in O.Oin 0.0 in 0.0 in o.o in G.Oin O.Oin 0.0 in O.Gin 0.0 in 0.0 in o.ain O.Oin 0.0 in O.Oin
condition Cloudy Cloudy Mostly Cioudy C!oU:tf Cloudy Mostly C!oudy Mostly Cloudy Mostly CloU<ly Mostly C!ou:!y MostlyC!ou:ly IAostly Cloudy Mostly Cloudy Partly Cloudy IAostly Cloudy f'artly Clow!y Partly Cloudy Mostly C<cmay Cloudy Mostly Cloudy Mostly c~ouoy Mostly Cloudy Partly Cloudy
Fa~ Fa~
Fa'r
Fair
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EPA Inspection Report - Page 23 of 26
May 25, 2021
Time 12:53 AM 1:53AM 2:53 AM 3:53 AM 4:53AM 5:53AM 6:51 AM 6:53AM 7:05AM 7:53AM S:OOAM 8:53AM 9:53AM 10:53 AM 11:53 AM 12:53 PM 1:53PM 2:53PM 3:53PM 4:53 PM 5:53PM 6:53PM 7:53 PM 8:53PM 9:53PM 10:53 PM 11:53 PM
Temperature 71 ' F 70 'f 69 f 70 "F 70 'F 69 ' f 70 ' F 69 "F 69 "F 70'F 70 'F 71 ' f 73 ' F 75 ' f 75 ' f 76 'F 77'F 77 'F 77 'F 77 ' f 77'f 76'F 75 'f 74 ' F 74 ' f 73 ' f 72 'F
Dew Point 62 ' F 62'F 62 ' F 62'F 61 'F 61 'F 63 ' F 62 'F 62 ' F 62 ' F
62 r
61 'f 61 ' F 61 ' f 61 ' f 60 ' F 58 'F 59 ' F SB 'f 58 'F 58'F 57'F 58 ' F 58'F 57'f 57'F 57 ' F
Humidity 73 '%
76 ~
73 % 75 o/o 78 5',
78 % 76 '% 76 % 7-0 % 66,, 6.2 % 62 % 58 % 52 % 54 % 52 % 52 '% 52% 52 % 55 %
55 % 57 % 59 %
Wind NE NE NE NE NE NNE NNE NE NE NE NE NE NNE NE NNE NNE NE NE NNE NNE Nl>!E VAR NNE
NNE NE
E
WinclSpeed 12mph
9mph 7mpll 10 mpli 9mpll 6mpll lOmph 9mpn lOmpn 10mph lOmph 9 m p ll lOmpn 9mph 12mph 12mph 13mph 10mph 1Clm ph 12mpll 8mph 7mpll 5mph 3mpll Smpll 6 m p ll Smph
Wind Gust Omph Omph Omph Omph Omph Omph Omph Omph Omph Omph Omph O mph Omph Om)lh Omph 21 mph O mph Omph Om]lh Omph Omph Omph Omph Gmph Omp!J Omph Omph
Pressure 3Cl 15 in 30.13 1n 30.1 2 In 30.13 in W.13 in 30.13 in 30.1 5 In 30 15 In 30.1 6 in 3Cl.17 in 301 7 In 30.18 in 30.19 In 30.20 in 30.20 in 30.19in 3018 ir. 30.17 in 30 16 in 30.15 !n 30.15 in 3!l.14 in 30.li In 30.18 in 30 1 9 i n 30.21 in 30.20 In
Preclp. O.Oin O.Oin O.Oin C.Gtn O.O!n O.O in O.Oin O.Oin O.Oin O.Otn O.Gin O.C in C.Oin O.Oin O.Oin 0.0in O.Oin O.Oin O.Oin O.Oln O.Oin O.Oin O.Oin O.Oin O.Oin O.Oin
O.Oin
Condition Ck>udy Cloudy Mostly Cooudy Cloudy C!oudy Mostly C!oll<ly Mostly Cloudy Mostl y C!oudy Mostly Cloooy Mostly Cicudy Mostly Clcu~y Mostly C!Oudy Partly Crou:Jy Mostly C!Cooy Partly C!-OUdy Partly C!oudy Mostly C1audy Cloudy Mostly Ctoooy MostlyC\oooy Mostly C:ou~y Partly Cloudy Fal Fair Falr
Fa!r
4.0 EXPOSURE STANDARDS AND GUIDELINES
OSHA has promulgated standards designed to protect the health and safety of workers from occupational exposure to air contaminants, including benzene (OSHA 29 CFR 1910.1000; 29 CFR 1910.1028;). Additionally, the ACGIH has developed guidelines to assist in the control of health hazards (ACGIH 2021a) (ACGIH 2021b). Although the ACGIH values are not enforceable, they are included for reference.
Results of personal samples collected during this assessment were compared to applicable occupational exposure values (OEVs) including the OSHA AL, OSHA PEL-TWA, OSHA PEL-STEL, OSHA PEL-Ceiling, ACGIH
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TLV-TWA, and ACGIH TLV-STEL where established. Evacuated canister air samples for voes were compared to the OSHA PEL-TWA, ACGIH TLV-TWA, and ATSDR MRLs where established.
5.0 METHODS
5.1 Personal and Area Air Sampling
Personal and area air samples for BTEX and total hydrocarbons, EPA T0-15 analytes, and asphalt fumes as benzene-soluble fraction with total dust, coal tar pitch, and petroleum distillates were analyzed using the sampling methods outlined in Table 3.
Table 3 Summary of Air Sampling Methods
Method
Analyte
Sample Type1 Sampling Media
NIOSH 1501/1501M
BTEX and total hydrocarbons as hexane
Passive Active
NIOSH 5042
Asphalt fumes as benzene-soluble fraction with total dust
Active
NIOSH 1550 Petroleum distillates
Active
OSHA 58
Coal tar pitch
OSHA
PV2120/EPA T0-15
voes
'TWA= Time-Weighted Average; STEL =Short-Term Exposure Limit 2L/min = liters per minute 'LOQ = Limit of Quantitation determined by the laboratory
g = micrograms; L/min = liters per minute
Active Active
525 assay badges
226-01 sorbent tubes Pre-weighted PTFE Cassette 226-01 sorbent tubes
GFF Cassette
MinicanTM evacuated canister
Flow Rate2
LOQs
Passive Varies
0.2 L/min
Varies
1-4
30
O.Gl0.2 50
2.0
60
NA
NA
Active samples for BTEX and total hydrocarbons as hexane, asphalt fumes as benzene-soluble fraction with total dust, petroleum distillates, and coal tar pitch were collected using sampling pumps attached to media specified in each respective sampling method. Before and after each use, the volumetric airflow rate for each pump was calibrated using a BIOS DryCal Defender primary flow meter. After connecting the sampling media to the flow meter, the pump was activated, the flow rate was allowed to stabilize, and three consecutive airflow measurements were taken. The average of these measurements was recorded as the flow rate. Each pump was calibrated in the flow rate range specified in the sampling method. The active air samples for voes via EPA T0-15 were conducted using evacuated canisters and an air intake regulator.
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Both active and passive personal air samples were collected in the workers' breathing zones to best represent their exposure . The breathing zone is defined by OSHA in its Technical Manual as a hemisphere forward of the shoulders within a radius of approximately six to nine inches from the nose or mouth. Analytical air samples were obtained utilizing a sample collection tripod to collect air approximately four feet above the ground.
As a quality control measure, field blanks were also collected, and all air samples and field blanks were sent to Analytics Corporation and Pace Analytical Laboratory, which are an American Industrial Hygiene Association-accredited laboratory under a chain of custody.
6.0 RES ULTS AND DISCUSSION
A summary of personal air sampling results compared to applicable OEVs is provided in Appendix A. Area
air monitoring results and OEVs are provided in Appendix B, and evacuated canister voe sampling results
are provided in Appendix C. The laboratory reports are provided in Appendix D, and employee notification letters are provided in Appendix E.
6.1 Air Sampling Discussion
6.1 .1 Personal Air Sampling Discussion All personal air sampling results were below OSHA and ACGIH OEVs where established.
6.1.2 Area Air Sampling Discussion
Results of the area air samples for asphalt fumes as benzene benzene-soluble fraction with total dust, coal tar pitch, and petroleum distillates were below the occupational exposure values set by OSHA TLV-TWA, ACGIH TLV-TWA where applicable except for one total dust sample taken along the North fence line on 5/25/21 which was over the OSHA and ACGIH OEL. Detectable levels of asphalt fumes as benzene-soluble fraction were detected along the West, South, and East fence line samples on 5/7/21 and North fence line sample on 5/25/21 but were below the OEL established by the ACGIH . The sample along the North fence line on 5/25/21 was greater than ~ the OEL established by the ACGIH for asphalt fumes as benzenesoluble fraction. Currently, there are no defined 24-hour OSHA or ACGIH OELs to compare the MinicanTM evacuated canister sa mpies to. Because of th is, the M inicanTM evacuated canister sa mpies were com pa red to available 8-hour OELs set by OSHA and ACGIH. Results for the MinicanTM evacuated canister samples for the EPA T0-15 analytes were below the OSHA and ACGIH 8-hour TWA and the ATSDR MRLs where app licable.
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7.0 REPRESENTATIVENESS
The tasks performed on May 7, 13, and 25, 2021, are considered representative of normal activities and work practices associated with BWC Terminals based upon conversations with management and other employees.
8.0 CONCLUSION
Results of the personal and area air sampling conducted at BWC Terminals in Harvey, Louisiana, on May
7, 13, and 25, 2021, were below OEVs established by OSHA, ACGIH, and the ATSDR where established with
the exception of one sample along the North Fence line on 5/25/21 for total dust.
9.0 RECOMMENDATIONS
The following recommendations are based on the sampling and monitoring conducted at BWC Terminals in Harvey, Louisiana.
Notify wo rkers of their individual air sampling results within 15 days of receipt of the final report.
Routine area and personal monitoring for asphalt fumes as benzene-soluble fraction and total dust.
The workplace may need to be re-evaluated if the following occur: o If the conditions in the facility change, o If new processes are added, and/or o If significant changes are made to existing processes.
10.0 REFERENCES
ACGIH (2021a) Documentation of Threshold Limit Values and Biological Exposure Indices. Cincinnati, Ohio: American Conference of Governmental Industrial Hygienists.
ACGIH (2021b) Guide to Occupational Exposure Values. Cincinnati, Ohio: American Conference of Governmental Industrial Hygienists.
Andrews, R. and O'Connor, P. F. (eds.) (2020) NIOSH Manual of Analytical methods (NMAM). 5th edn: NIOSH. Available at : https://www.cdc. gov/niosh/ nmam/ pdf/ NM AM SthEd EBook-508-fi nal.pdf
OSHA. Air contaminant--permissible exposure limits 29CFR1910.1000. Available at: https://www.osha.gov/pls/oshaweb/owadisp.show document?p table- STAN DARDS&p id=999
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