Document B865x2qQJvydaq1veYaOLmqLL

Office of Enforcement and Compliance Assurance, Air Enforcement Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/07/2024 Air Title V, NESHAP Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Natgasoline LLC Beaumont Gas to Gasoline Plant 2366 Sulfur Plant RD Beaumont, TX 77705 PO Box 20339 Beaumont, TX 77720 Jefferson County 409-344-4900, Ext.3300 Miguel Martinez Environmental Manager miguel.martinez@natgasoline.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110070183112 RN106586795/Title V Air Operating Permit 3963 ICIS-Air TX0000004824500747 325110 2869 Personnel participating in inspection: Daniel Hoyt EPA OECA AED Nate Hicks EPA OECA AED Philip Myers EPA OECA NEIC Richard Helmich EPA OECA NEIC Justin Chen EPA Region 6 ECDAT Ben Donaldson EPA Region 6 ECDAT Kenneth McPherson EPA Region 6 ECDAT Miguel Martinez Natgasoline LLC Representative Sarah Lee Natgasoline LLC Representative David Williamson Natgasoline LLC Representative Brendon Stout Natgasoline LLC Representative Scott Kolb Natgasoline LLC Representative Reid Guidry Natgasoline LLC Representative Environmental Engineer Physical Scientist Mechanical Engineer Chemist Environmental Engineer Environmental Engineer Life Scientist Environmental Manager Safety and Emergency Response Environmental Engineer Production Manager Environmental Engineer SSR EPA Lead Inspector Signature/Date DANIEL HOYT Digitally signed by DANIEL HOYT Date: 2024.04.03 12:33:32 -04'00' Daniel Hoyt Date Supervisor Signature/Date GREGORY FRIED Date: 2024.04.03 12:53:01 -04'00' Digitally signed by GREGORY FRIED Gregory Fried Date Section I - INTRODUCTION Natgasoline LLC/Beaumont Gas to Gasoline Plant 02/07/2024 PURPOSE OF THE INSPECTION EPA inspectors Daniel Hoyt and Nate Hicks (Air Enforcement Division, "AED") accompanied by Philip Myers and Richard Helmich (National Enforcement Investigations Center, "NEIC") arrived at the Natgasoline LLC/Beaumont Gas to Gasoline Plant at 1:15 pm CT on February 7, 2024, for an unannounced inspection. Region 6 EPA inspectors Ben Donaldson, Kenneth McPherson and Justin Chen arrived at the Natgasoline LLC/Beaumont Gas to Gasoline Plant at around 1:45 pm CT. The EPA team met Sarah Lee and Miguel Martinez and watched a safety video. Credentials were presented to Miguel Martinez and Daniel Hoyt informed Sarah Lee and Miguel Martinez that this was an EPA inspection to evaluate potential sources of excess emissions using EPA's Geospatial Measurement of Air Pollution ("GMAP") vehicle and evaluate compliance with the facility's Title V Air Permit and the Clean Air Act. The scope of the inspection is a partial evaluation ("PCE"). This inspection occurred as part of a multi-scale monitoring project in the Beaumont-Port Arthur area. Photographs and video taken during the inspection can be found in Appendix 1 and 2, respectively. FACILITY DESCRIPTION The Natgasoline LLC/Beaumont Gas to Gasoline Plant is a petrochemical manufacturing facility (NAICS Code 325110) that operates under Title V Air Operating Permit O3963, issued August 21, 2019. The facility produces methanol from natural gas, steam and oxygen, and includes equipment for separating the produced methanol by distillation, methanol storage tanks and equipment for loading methanol into trucks and rail cars. Section II - OBSERVATIONS The NEIC GMAP was driven by Richard Helmich and the instruments were operated by Philip Myers. Facility representatives, including Miguel Martinez, accompanied the GMAP. Conditions were partly cloudy, winds from the south-southeast at 15 to 20 mph. Daniel Hoyt, Nathan Hicks, Ben Donaldson, Kenneth McPherson and Justin Chen were escorted/followed the GMAP in two vehicles. The GMAP drove on all available facility roads measuring air pollutant concentrations downwind of each of the process areas, if possible. A full report from the GMAP will be issued by NEIC at a later date. Daniel Hoyt and Nathan Hicks operated a Data Acquisition in Real Time (DART) unit on their vehicle, equipped with a photoionization detector (PID) that measures VOC in the air, and a wind monitor that monitors wind speed, wind direction and geolocation. The DART unit had a 10.6ev PID installed. Philip Myers indicated that the GMAP detected methane downwind from the 20-inch natural gas plant inlet pipe at around 2:20 pm. Philip Myers used an optical gas imaging camera and indicated that he saw emissions coming from two valves associated with the natural gas inlet pipe. I used a FLIR GFx320 optical gas imaging camera. I observed emissions from the first valve, which were barely visible using in high sensitivity mode. I observed emissions from the second valve, noted that the emissions were visible using optical gas imaging in both high sensitivity mode and auto-mode, and observed that the second valve was located near equipment tag number 1707. I took one visible light/color photograph of valve 2 Natgasoline LLC/Beaumont Gas to Gasoline Plant 02/07/2024 1707 with a FLIR GFX320 camera (See Appendix 1 Photo Log, FLIR0002) and recorded one optical gas imaging video of the emissions from the second valve near tag 1707 using a FLIR GFX320 in standard mode (see Appendix 2 Video Log, FLIR0001). The site GMAP survey ended at 3:00 pm CT and we returned to the Natgasoline LLC conference room. Section III - AREAS OF CONCERN I, Daniel Hoyt, conducted a closing conference at the Natgasoline LLC/Beaumont Gas to Gasoline Plant at 3:00 pm CT on February 7, 2024, for the inspection (see sign-in sheet, included as Appendix 3). Philip Meyers and I summarized the facility tour and presented the emissions observations, including the following Area of Concern: GMAP detected elevated methane downwind from the 20-inch natural gas plant inlet pipe at around 2:20 pm CT. Philip Myers used an optical gas imaging camera and indicated that he saw emissions coming from two valves associated with the natural gas inlet pipe. Natgasoline LLC's Prevention of Significant Deterioration Permit (GHGPSDTX54, dated June 17, 2020), Special Permit Condition III.A.7.a., indicates the facility is subject to the Texas Commission on Environmental Quality (TCEQ) 28VHP leak detection and repair (LDAR) program for fugitive emissions of methane. The TCEQ 28VHP LDAR program requires "[d]amaged or leaking valves or connectors found to be emitting VOC in excess of 500 parts per million by volume (ppmv)" to be "tagged and replaced or repaired", and that a leaking component must "be repaired as soon as practicable, but no later than 15 days after the leak is found" unless "the repair of a component would require a unit shutdown that would create more emissions than the repair would eliminate". In response to the methane detected by GMAP during the facility survey, Miguel Martinez indicated during the Exit Briefing that Natgasoline LLC: Conducted initial leak detection and repair monitoring with a TVA, finding that: o The concentration of emissions around the first valve was 406 ppm. o The concentration of emissions around the second valve near tag 1707 caused the TVA instrument to "flame-out". Attempted to address emissions from the first valve by tightening the valve cap. Had not yet addressed emissions from the second valve near tag 1707 because a ladder was needed. The facility made no claims of confidential business regarding the photograph taken and optical gas imaging video recorded. The facility was informed that a copy of the video and photograph would be made available to the facility following the inspection. We departed the facility at 3:15 pm CT. Section IV - FOLLOW UP Miguel Martinez provided a follow up email on March 5, 2024, in response to an email dated February 29, 2024, from Daniel Hoyt (see Appendix 4). In that email, Miguel Martinez provided documentation, including calibration records, indicating Natgasoline LLC used EPA Method 21 in response to the 3 Natgasoline LLC/Beaumont Gas to Gasoline Plant 02/07/2024 methane detected by GMAP during the facility survey. The email response indicates Natgasoline LLC detected emissions coming from valves on the 20-inch natural gas pipeline interconnect on the pipeline section associated with a 24-inch receiver. The documentation provided by Miguel Martinez indicates the detected emissions were coming from two valves identified with tags 1706 and 1711, and provides the following results for initial EPA Method 21 monitoring: Tag 1706 18297 ppm February 7, 2024, at 2:46 pm CT Tag 1711 19040 ppm February 7, 2024, at 2:49 pm CT The documentation provided by email further indicates that after the respective valve hatches were tightened, the repairs were deemed successful based on the following EPA Method 21 monitoring results: Tag 1706 308 ppm February 7, 2024, at 4:00 pm CT Tag 1711 84.8 ppm February 7, 2024, at 4:05 pm CT Section V - LIST OF APPENDICES Appendix 1 - Photo Log - one photograph taken February 7, 2024 Appendix 2 - Video Log - one FLIR video recorded February 7, 2024 Appendix 3 - Closing conference sign-in sheet Appendix 4 - Email response and attachments from Miguel Martinez dated March 5, 2024 4 Natgasoline LLC/Beaumont Gas to Gasoline Plant Appendix 1 Photo Log - one photograph taken by Daniel Hoyt on February 7, 2024 Photo # 1 File Name FLIR002.jpg Date/Time (CST) 2024-02-07/2:30 pm Description Valve near Tag 1707 on 20-inch natural gas pipeline interconnect on the pipeline section associated with a 24-inch receiver, from which emissions were observed using optical gas imaging Page 1 of 1 Natgasoline LLC/Beaumont Gas to Gasoline Plant Appendix 2 Video Log - one FLIR video recorded by Daniel Hoyt on February 7, 2024 Photo # 1 File Name FLIR001.mp4 Date/Time (CST) 2024-02-07/2:30 pm Duration 00:00:16 Description VOC emissions observed using optical gas imaging from valve near Tag 1707 on 20inch natural gas pipeline interconnect on the pipeline section associated with a 24inch receiver, recorded in standard mode Page 1 of 1 Closing Conference Sign-in Sheet Natgasoline LLC/Beaumont Gas to Gasoline Plant Appendix 3 Page 1 of 1 From: To: Cc: Subject: Date: Attachments: Natgasoline LLC/Beaumont Gas to Gasoline Plant Appendix 4 Miguel Martinez Hoyt, Daniel Robert Wiess; Larry Richard RE: Natgasoline Follow-up Tuesday, March 5, 2024 4:57:12 PM NATG-X-1005 (03) Natgas TETCO Interconnect - 20{6} Pipeline - Receiver Area - P&ID (ID 79664).pdf Calibration.pdf Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Good Afternoon, Mr. Hoyt: As requested in your email below, Natgasoline is providing a narrative and the corrective actions associated with your team's visit. Requested Information EPA visited the Natgasoline-Beaumont Methanol facility on February 7, 2024, at approximately 13:00. The EPA was represented by: Daniel W. Hoyt Nathaniel C. Hicks Richard J. Helmich Phillip Meyers Justin Chen Ben Donaldson Ken McPherson The Natgasoline Environmental team was represented by: Miguel A. Martinez Scott Kolb David Williamson EPA used its Geospatial Measurement of Air Pollution (GMAP) vehicle to monitor the process state. The GMAP detected a methane emission from the 20" Natural Gas pipeline interconnect on the section associated with the 24" Receiver. Optical gas imaging (OGI) indicated the emissions were coming from valves 1707 and 1711. The initial Method 21 readings for the associated LDAR tags were: Tag 1706 18297 ppm 02/07/2024 14:46 Page 1 of 5 Tag 1711 19040 ppm 02/07/2024 14:49 Natgasoline LLC/Beaumont Gas to Gasoline Plant Appendix 4 Both the EPA OGI and the Natgasoline Method 21 TVA narrowed the location of the methane leaks to the valve hatches for V-1706 and V-1711. Corrective Action Natgasoline Environmental called ECHO, the rapid response mechanical contractor, to inspect the valve hatches. ECHO determined the repair requirements, identified possible safety risks, and tightened the valve hatches. The first attempt repair was successful where the leak measurement readings were: Tag 1706 308 ppm 02/07/2024 16:00 Tag 1711 84.8 ppm 02/07/2024 16:05 If you have any questions, please call me at 713-419-8935 or email me at miguel. martinez@natgasoline.com . Thank you, sir. Regards, Miguel A. Martinez Environmental Manager PO Box 20339 Beaumont, TX 77720 2366 Sulphur Plant Road Beaumont, TX 77705 Cell: 713-419-8935 miguel.martinez@natgasoline.com From: Hoyt, Daniel <Hoyt.Daniel@epa.gov> Sent: Thursday, February 29, 2024 1:39 PM To: Miguel Martinez <Miguel.Martinez@natgasoline.com> Subject: Natgasoline Follow-up Page 2 of 5 Natgasoline LLC/Beaumont Gas to Gasoline Plant Appendix 4 You don't often get email from hoyt.daniel@epa.gov. Learn why this is important CAUTION: This is an external email. Please take care when clicking links or opening unexpected attachments. Contact IT at helpdesk@natgasoline.com if you require assistance. Hello Miguel Martinez, Thank you again for your time and attention during our EPA site visit at the Natgasoline-Beaumont Gas to Gasoline Plant on February 7, 2024, with EPA's Geospatial Measurement of Air Pollution (GMAP) vehicle. As we discussed during the site visit, methane emissions were detected by the GMAP and wind direction/optical gas imaging indicated the emissions were coming from valve 1707 on Natgasoline's plant inlet natural gas pipe. You indicated during the exit briefing that Natgasoline had not yet addressed the emissions detected, coming from valve 1707 on the plant inlet natural gas pipe, because a ladder was needed. I want to document in my report if Natgasoline did take action to address the detected emissions. Please send me by email, by March 7, 2024, documentation of any corrective action taken to address the emissions detected during the site visit, coming from valve 1707 on the plant inlet natural gas pipe. Please include with the documentation a description of corrective actions taken, the dates and times of corrective actions taken, and the dates, times and results of any EPA Method 21 instrument monitoring (or optical gas imaging) conducted to confirm emissions or verify that corrective actions addressed the detected emissions. Feel free to give me a call or send me an email if you have any questions. Regards, -Dan Hoyt Daniel Hoyt, Environmental Engineer US Environmental Protection Agency Office of Enforcement and Compliance Assurance Office of Civil Enforcement - Air Enforcement Division (202) 564-7898 1200 Pennsylvania Ave, NW WJC-S, MC 2242A Washington, DC 20460 (mail) or 20004 (courier) Page 3 of 5 IU =- 11 f-'.JkAf-(" (f J IIJc'- \ - 1 :: 11 '; CD 1n I CJ (_) c fk(::I :.ui::H--c :ii f w r: :I,L.T:: - -1 :1c:4 L:l C, c, I c::, I . <l LL CJ u ,:n c;, ,c 0 ,- (j 0 ,fl c__:, F'FF=-='Flli-F D\/:C; I\E r ::4c f-:,:.; r, ') I' A <! CUp,;1q JLCJ F1 C.:\/ r-- ]! 3151 IS"::' C" c:-IIC. 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