Document N2qMZQ2jV7D6dGpdg8RQBkvyD

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III Four Penn Center - 1600 John F Kennedy Blvd Philadelphia, Pennsylvania 19103-2852 Report Title: Inspection Date(s): Regulatory Program(s): Clean Air Act Inspection of PBF Logistics Products Terminal 03/28/2023 Title V, NESHAP, NSPS Company Name: Facility Name: Facility Location: Latitude: County/Parish: PBF Logistics Products PBF Logistics Products Terminal 6850 Essington Avenue Philadelphia, PA 19153 39.911701 Philadelphia Longitude: -75.218773 ICIS-Air Number: Permit Number: NAICS Code: Unique Project #: PAPAM0004210105013 Title V/ State Operating Permit No. V10-025 5171 SIC: 424710 3E23CA088A Facility Representatives: John Grisi, Terminal Manager Phone: 215-937-6410 Email: Todd Bretz, HSE Director Phone: 609-828-3435 Email: Point of Contact John.Grisi@pbflogistics Todd.Bretz@pbfenergy.com EPA Inspectors*: Paul Arnold, Environmental Engineer, 3ED21 Phone: 215-814-2194 Email: Arnold.Paul@epa.gov Alex Everhart Phone: 215-814-2114 Email: Everhart.Alex@EPA.gov *Additional inspectors identified in report body and on attached sign in sheet State/Local Inspectors: Adessalem Cherifi, Phial-AMS Phone: 267-312-8748 Email: Sam.cherifi@phila.gov Rashidi Butler, Phila AMS Phone: 215-219-7430 Email: Rashidi.Butler@phila.gov EPA Lead Inspector Digitally signed by PAUL PAUL ARNOLD ARNOLD Date: 2023.05.22 09:33:29 -04'00' Signature Paul Arnold 1600 John F Kennedy Blvd Philadelphia, PA 19103-2852 Supervisor Signature Digitally signed by KRISTEN KRISTEN HALL HALL Date: 2023.05.22 09:38:01 -04'00' Kristen Hall Date Date Table of Contents I. Introduction................................................................................................................................ 3 A. Summary of the Facility ...................................................................................................... 3 B. Inspection Opening Conference........................................................................................... 3 II. Site Activity/Process Description .....................................................................................................4 III. Observations .......................................................................................................................................4 IV. Records Review .................................................................................................................................4 V. Closing Conference.............................................................................................................................4 VI. List of Attachments ...........................................................................................................................5 Unique Project #: 3E23CA088A Page 2 of 5 I. Introduction The United States Environmental Protection Agency (EPA) conducted a Clean Air Act (CAA) inspection at PBF Logistics Products Terminal (PBF or Facility) to determine if elevated levels of compounds were present. The City of Philadelphia Air Management Services (AMS) was notified of the inspection on March 14, 2023, via email. On March 27, 2023, EPA notified the Facility of the planned inspection via phone. A. Summary of the Facility The Facility is located at 5860 Essington Avenue, Philadelphia, PA 19153. PBF is a petroleum terminal and serves solely as a petroleum liquids storage transfer facility. PBF receives petroleum products via pipeline that is then stored in tanks prior to loading on truck for delivery. The Facility received a Title V Operating Permit (V10-025) from the City of Philadelphia Department of Public Health Air Management Services issued on May 24, 2011. PBF is classified as major source for Volatile Organic Compounds(VOCs) and Hazardous Air Pollutants (HAPs). The Facility is subject to, or potentially subject to the following federal regulations: 40 CFR Part 60, Subpart XX: Standards of Performance for Bulk Gasoline Terminals; 40 CFR Part 60, Subpart Kb: Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced after July 23, 1984; 40 CFR Part 63, Subpart R: National Emission Standards for Gasoline Distribution Facilities (Bulk Gasoline Terminals and Pipeline Breakout Stations); 40 CFR Part 63, Subpart Y: National Emission Standards for Marine Tank Vessel Loading Operations. B. Inspection Opening Conference At 1:20 PM on March 28, 2023, EPA inspectors arrived at the Facility for a CAA Inspection and conducted a brief opening conference. PBF was represented by John Grisi and Tom Bretz. Also, Rashidi Butcher and Adessalem Cherifi Phial were present from AMS. EPA inspectors, Paul Arnold, Alex Everhart, Scott Yanos, Parmatma Adhikari, Nick Bobbs and Phil Meyers, presented their credentials and explained the purpose of the visit was to conduct Geospatial Measurement of Air Pollution monitoring (GMAP). Nick Bobbs explained that the GMAP vehicle has the capability to monitor Hydrogen Sulfide, volatile organic compounds, Methane, Sulfur Dioxide and Benzene. Todd Bretz indicated that approximately two years ago (2021) EPA conducted GMAP monitoring at PBF. Todd stated that there was only one pollutant (methane) detected at elevated levels in one area during the previous GMAP monitoring event. Todd stated that the detection was around the natural gas compressor station that was not part of PBF property or ownership. Additionally, EPA informed the facility representatives of their right to Unique Project #: 3E23CA088A Page 3 of 5 claim any confidential business information (CBI). At that time, PBF did not claim any photos or documentation as CBI. II. Site Activity/Process Description PBF terminal manager John Grisi stated that PBF Logistics servers solely as a storage transfer facility. John stated that gasoline, diesel, #2 fuel oil, and asphalt are delivered to the site via pipeline and stored in tanks prior to being loaded into tanker trucks. The opening conference concluded at 1:50 PM. III. Observations EPA inspectors were led on a drive through of the Facility at 1:55 PM by John Grisi and Todd Bretz of PBF. At 1:55 PM, EPA initiated GMAP monitoring. Rashidi Butcher and Adessalem Cherifi of Phial-AMS, and Paul Arnold, Alex Everhart, Scott Yanos, Parmatma Adhikari, Nick Bobbs and Phil Meyers, of EPA, were present during GMAP monitoring. The EPA GMAP vehicle was lead on the perimeter road that encircles the storage tanks. At approximately 2:05 PM methane was detected at elevated levels. It was noted that the methane detection was in the immediate vicinity, downwind to the south of the natural gas compressor station. On May 4, 2023, EPA emailed PBF to determine ownership of the natural gas compressor station. Photos received on May 4, 2023, in response to EPA's inquiry from PBF Terminal Manager John Grisi, indicate the natural gas compressor station is owned by Enbridge Inc. The GMAP monitoring concluded at 2:25 PM IV. Records Review No records were reviewed as part of the inspection. V. Closing Conference EPA inspectors, Rashidi Butcher and Adessalem Cherifi of Phial-AMS, John Grisi and Todd Bretz of PBF had a brief closing conference to ask additional questions and discuss observations. The EPA inspectors noted that the investigation is on-going, and any areas of concern identified in the final report do not necessarily reflect a violation or deviation, rather, they are areas that will require further investigation. EPA also noted that they would issue an inspection report within in 60 days, with a copy to Phila-AMS. The inspection concluded at 2:30 PM. The following has been identified as a potential issue during the inspection. The issue may require either further investigation by EPA or additional information or explanation by PBF. EPA observed elevated levels of methane downwind and in the immediate vicinity to the south of the natural gas compressor station owned and operated by Enbridge Inc. Unique Project #: 3E23CA088A Page 4 of 5 VI. List of Attachments Attachment 1: Opening Conference sign in sheet. Unique Project #: 3E23CA088A Page 5 of 5