Document EqMOR0Ka7QmoGmJzRXKoEQxOR

EPA Inspection Report - Page 1 of 5 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/12/2024 Air Title V, NSPS, SIP Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Motiva Enterprises LLC Port Neches Terminal 100 E Port Neches Ave Port Neches, TX 77651 100 E Port Neches Ave Port Neches, TX 77651 Jefferson County 409-835-5381 Blake Yarbrough blake.yarbrough@motiva.com Complex Manager FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000599576 RN100210103 / FOP O3277 AFS # 48-245-00013 424710 5171 Personnel participating in inspection: James Haynes EPA Region 6 ECDAT Ben Rosenthal EPA Region 6 ECDAT Blake Yarbrough Motiva Enterprises LLC Michael Brinkley Motiva Enterprises LLC Arles Zelayn Motiva Enterprises LLC Physical Scientist Physical Scientist Complex Manager Terminal Manager Operator EPA Lead Inspector Signature/Date Haynes, James Date: 2024.03.28 13:13:27 -05'00' Digitally signed by Haynes, James James Haynes Date Supervisor Signature/Date Digitally signed by JAMES JAMES LEATHERS LEATHERS Date: 2024.04.15 17:44:20 -05'00' James Leathers Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 5 Section I - INTRODUCTION Motiva Enterprises LLC / Port Neches Terminal Inspection Date 02/12/2024 PURPOSE OF THE INSPECTION I, James Haynes, with Ben Rosenthal, EPA Region 6 inspectors, arrived at Motiva Enterprises LLC's Port Neches Terminal (the "Facility") at 16:00 on February 12, 2024, for an unannounced inspection. We met with Mr. Michael Brinkley, Terminal Manager, and Mr. Blake Yarbrough, Complex Manager. I presented my inspector credentials to Mr. Brinkley and informed him that this was an EPA inspection to evaluate the Facility's compliance with the Clean Air Act ("CAA"). The scope of the inspection is a partial evaluation ("PCE"). This inspection occurred as part of a multi-scale monitoring project in the BeaumontPort Arthur area. Photographs taken during the inspection can be found in Appendix 1. FACILITY DESCRIPTION The Port Neches Terminal is used for the storage and distribution of crude oil and other petroleum products. Section II - OBSERVATIONS During the opening conference, we discussed the Facility's in-service internal floating roof ("IFR") and external floating roof ("EFR") storage vessels and marine loading operations. We informed the Facility that we would use a FLIR GF620, an optical gas imaging ("OGI") camera, and TVA 2020, a flame ionization detector ("FID"), as part of the inspection. We met with Arles Zelayn, an operator at the Facility, to begin our site tour. The following table is a summary of our observations: Tank # 280 34030 1815 Tank Contents Design Notes and Observations Stormwater IFR No hydrocarbons emission observed with the OGI camera. Debutanized Aromatic EFR EPA inspectors noted hydrocarbon odors at Concentrate the tank's platform and along the circumference of the tank's shell. EPA inspectors noted visual defects of gasket material of the tank's guidepole hatch (Photo 1) and measured a concentration of 3,300 parts per million using the FID. [AOC 1] Light hydrocarbon emission observed with the OGI camera at the base of the secondary rim seal. [AOC 2] Cyclohexane IFR No liquids on the floating roof. No hydrocarbon emissions observed with the OGI camera. 2 EPA Inspection Report - Page 3 of 5 1835 1834 275 Crude Oil Crude Oil Crude Oil Section III - AREAS OF CONCERN Motiva Enterprises LLC / Port Neches Terminal Inspection Date 02/12/2024 EFR Hydrocarbon emission observed with the OGI camera along the rim seal. [AOC 2] EFR No hydrocarbon emissions observed with the OGI camera. EFR Hydrocarbon emissions observed with the OGI camera along the rim seal. [AOC 2] I conducted a closing conference at 18:45 for the inspection with Mr. Yarborough and Mr. Brinkley. We summarized the observations, including the following Areas of Concern: 1) At Tank 34030, upon detecting hydrocarbon odors at the tank's platform, we observed the gasket material at the guidepole hatch was torn. Mr. Rosenthal also measured emissions with the FID and confirmed that emissions were emanating from the hatch near the torn gasket. 2) At Tanks 34030, 1835, and 275, we observed hydrocarbon emissions with the OGI camera along the rim seals indicating that the secondary seals may not be controlling emissions as required. Section IV - FOLLOW UP EPA requested additional information following the inspection. On March 11, 2024, Motiva Enterprises LLC submitted responses to my request. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log 3 EPA Inspection Report - Page 4 of 5 Motiva Enterprises LLC / Port Neches Terminal Inspection Date 02/12/2024 Appendix 1 Photograph Log EPA Inspection Report - Page 5 of 5 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Motiva Enterprises LLC / Port Neches Terminal City: Port Neches County: Jefferson State: TX Photo File Name: Date of Photo: Time of Photo: Photographer: Description: FLIR0033.jpg 02/12/2024 17:21 James Haynes Torn gasket material at hatch on Tank 34030. EPA recorded approximately 3,300 parts per million VOC, as methane, with the FID.