Document N2yXOV0QN7GDgqvmKeykNgjzQ

EPA Inspection Report - Page 1 of 34 EPA ft ....,..., United States Environmental Protection ~II" Agency Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 09/14/2017 Air/RMP CAA Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Valero Energy Partners LP Valero Partners Houston, LLC 9701 Manchester Houston, Texas 77012 9701 Manchester Houston, Texas 77012 Harris County Matt Lindquist Matt.lindguist@valero.com I Environmental Engineering Manager FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110000460885 0-3784, 129444 324110/32411 2911 Personnel participating in inspection: Sherronda Phelps US EPA- 6EN-ASH James Gold US EPA- 6EN-ASH Prince Nfodzo US EPA- 6EN-AA James Haynes US EPA- 6EN-AT Jeff Hude Valero Houston Refinery Matt Lindquist Valero Houston Refinery Environmental Engineer Inspector Environmental Engineer Physical Scientist Environmental Director H&S Environmental Engineering Mgr. 281-983-2122 281-983-2105 214-665-7491 214-665-8546 713-923-3478 713-923-3378 EPA Lead Inspectors Signature/Date ~~~~. J '11 ~ Prince Nfodzo, Sherronda Phelps t\fd-fi:Lol7 Date Supervisor Signature/Date ~ ~ ' lJvWIV' Darrin Larson \\ /2t /~ n Date 6ENFORM-019-R7 (2/15/2017) 1 EPA Inspection Report - Page 2 of 34 Section I - INTRODUCTION PURPOSE OF THE INSPECTION Four United States Environmental Protection Agency (US EPA) Region 6 Air Enforcement staff ("the team") conducted an inspection at Valero Partners Houston, LLC (Valero) on September 14, 2017. The Valero facility is located at 9701 Manchester Road in Houston, Texas. We arrived at Valero at 9:30 hours, and completed Valero's safety orientation requirements. We met with Mr. Matt Lindquist, Environmental Engineering Manager, and Mr. Jeff Hude, Director, Environmental, Health and Safety 10:22 hours for introductions and a briefing on the purpose and overview of the inspection. We presented our credentials, and we informed the Valero representatives that the inspection was a partial compliance evaluation focused on Tank 228, a gasoline tank, and Tank 3, an atmospheric crude tank, to determine Valero's compliance with the Clean Air Act (CAA) regulations and the facility's Risk Management Plan (RMP). The sign-in sheet for the inspection is included as Appendix 2. EPA is investigating whether the two tanks were contributing sources of emissions in the adjacent community during and/or in the aftermath of Hurricane Harvey. The scope of the inspection included an evaluation of the facility's compliance with 40 CFR Part 63, National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart CC, CAA Section 112(r)(7), and 40 CFR Part 68, Chemical Accident Prevention Provisions. The inspection included an evaluation of compliance with emission limits, installation of emission control equipment, testing, monitoring, recordkeeping, and reporting requirements. FACILITY DESCRIPTION The Valero facility is a mid-sized plant with a total throughput capacity of 235,000 barrels per day. The refinery began operations in 1942 and has gone through numerous modifications and expansions including feedstock for a new ultra-low sulfur diesel (ULSD) unit, a fluidized catalytic cracking unit (FCCU). The facility, which covers approximately 250 acres, is located on the Houston ship channel, and primarily outside the Houston city limits. Valero operates a fully integrated refinery with crude distillation, FCCU, alkylation, hydrodesulphurization, sulfur recovery and fuel blending. Valero produces a wide range of petroleum products including gasoline, kerosene, jet fuel, ultra-low-sulfur diesel, liquefied petroleum gases, propylene, No. 6 fuel oil, and sulfur. Crude oil is obtained primarily by pipeline and/or ship/barge and transported to the refinery via pipelines. Products leave the refinery by pipelines, railcars, tanker trucks and marine shipping. Regulated substances are included in flammable mixtures within the tank farm and throughout the facility in several process units. There are no toxics maintained at greater than threshold quantities in any facility process. Miscellaneous flammable mixtures and pure component streams are maintained in storage tanks and contained within process unit equipment. The facility is subject to the provisions of 40 CFR Part 68. Valero employs about 340 full-time employees, and the facility operates 24 hours, 7 days a week. Section II - OBSERVATIONS 1. Incident Response [112(r)(7)] According to Valero, an incident occurred on August 27, 2017, at 8:30 hours as a result of unprecedented heavy rainfall associated with Hurricane Harvey. The weight of the rain rapidly accumulating on the external floating roof of Tank 3 caused the western side of the roof deck to deform EPA Inspection Report - Page 3 of 34 and breach the roof seal. Crude oil mixed with water on the roof deck was released into secondary containment via tank roof drains until the drain valve was closed. The spill was contained onsite, and no oil was discharged outside the secondary containment area. At the time of the inspection, Valero was in the process of recovering light crude from Tank 3. It was determined that light crude still existed in the pontoons of the floating roof. There are 19 of these pontoons on Tank 3, and Valero is cutting 10" - 12" diameter holes in the tank wall to access and open a cover on each of the pontoons in order to remove remaining crude. Valero was also cutting an 18' x 18' opening into the side of the tank wall in preparation for the demolition of the tank roof. According to the Valero representatives, due to safety concerns, the sludge and solids under the roof will be removed during the demolition operations. Valero expected a plan to be established by September 15, 2017, and to begin the demolition operations on September 16, 2017. We observed puddles of residual material on the roof of the tank. It was also noted that Valero will conduct an inspection evaluation to determine whether Tank 3 can be put back into service or if it will need to be replaced through the construction of a new tank. A pinhole leak developed in the drain line of Tank 228, and leaked contents of the tank (gasoline and naphtha mix) onto the surrounding area. Valero started degassing operations on Tank 228 and indicated that the tank will be completely emptied and opened up for inspection and cleaning on September 15, 2017. Photographs of the tanks are included as Appendix 1. 2. Risk Management Plan (RMP) Valero Partners Houston, LLC, has submitted a single RMP that reflects all covered processes. As a facility with a Program 3 process, Valero must develop and implement a management system, conduct a hazard assessment, implement the prevention requirements of 40 CFR 68.65 through 68.87, develop and implement an emergency response program, and submit the data elements from 40 CFR 68.175 in their RMP. Records were requested from the facility related to the August 27, 2017, incident. From the information provided, Tank 3 is not covered under the RMP. The substance held in the tank does not meet the criteria of the National Fire Protection Agency (NFPA) -4. Inspection records have been provided and a review of the records is on-going. Tank 228 is an atmospheric tank currently holding a gasoline/naphtha mix. During the visit, the material from the tank was being pumped out of the tank. During Hurricane Harvey, Valero had to pump naphtha into Tank 228. Naphtha is normally sent to the barges; however, it was pumped into Tank 228 due to barges not being available. This is not a part of daily operations, as explained by Mr. Hude. From the information provided, Tank 228 normally holds gasoline, and is not covered under the RMP. The substance held in the tank does not meet the criteria of the NFPA -4. Valero indicated that the tank will be evaluated for its return to service when all clean up measures have been completed. Inspection records have also been provided and a review of the records is on-going. Valero uses Guardian for tank seal gap inspections, and either HMT, Mistras, Team Qualspec, or Valero inspectors for the API 653 integrity inspections. Valero provided the two most recent Compliance Audits as required under the RMP. The last audit was conducted March 2015 and previously in June of 2012. A review of the records is on-going. EPA Inspection Report - Page 4 of 34 EPA requested Valero's Emergency Response Plan, Offsite Consequence Analysis documentation, Hurricane Plan, and Spill Prevention Control and Countermeasure Plan, which were provided. A review of the records is on-going. 3. Permits Both tanks are incorporated in Valero's Title V permit, O3784, which was last issued June 30, 2016. The tanks are subject to the requirements of NESHAP Subpart CC. Tank 3 and Tank 228 are operated under Texas Commission on Environmental Quality (TCEQ) permit by rule (PBR), 30 TAC 106.261 and New Source Review (NSR) permit number 129444, respectively. Valero indicated that Tank 3 will be incorporated in NSR permit 129444 when due for renewal. Excerpts of the permits are included as Appendix 3. 4. EPA Air Monitoring We conducted air monitoring using a photoionization detector (PID) and forward looking infrared (FLIR) camera. Tank 228: We conducted monitoring at the top, ground-level, and both upwind and downwind of the tank. We observed readings below 1 ppmv of volatile organic chemicals (VOC) with the PID. We observed very light emissions of VOC with the FLIR camera from the drain. Tank 3: We conducted monitoring at the top, ground-level, and both upwind and downwind of the tank. We observed readings below 1 ppmv of VOC at the ground level, up to 102 ppmv of VOC at one of the westerly-facing holes to access the pontoon, up to 44 ppmv VOC at the top of the tank, and up to 45 ppmv VOC at a hole cut on the east side of the tank. We observed moderate emissions from the covers to the pontoons with the FLIR camera. 5. Valero Onsite Air Monitoring We reviewed records of onsite monitoring conducted by Valero staff for the period of August 29, 2017 through September 6, 2017. The records show few isolated instances of elevated emissions of benzene (150 part per billion [ppb] - 1250 ppb). Section III - AREAS OF CONCERN Other than the issues that have been mentioned above, we did not observe any areas of concern during the onsite inspection regarding Tank 228 and Tank 3. Section IV - FOLLOW UP No additional information was requested from Valero. EPA will conduct an offsite detailed and comprehensive review of the documents received from Valero during the inspection as a follow-up to the onsite inspection. Section V - LIST OF APPENDICES Appendix 1 - Photograph log Appendix 2 - Inspection sign-in sheet Appendix 3 - Pages from permits EPA Inspection Report - Page 5 of 34 Appendix 1 Photograph Log EPA Inspection Report - Page 6 of 34 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0193.JPG 09/14/2017 1:06 pm Sherronda Phelps Tank 228 (from ground level) EPA Inspection Report - Page 7 of 34 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0194.JPG 09/14/2017 1:12 pm Sherronda Phelps Tank 228 Roof (from top of tank) EPA Inspection Report - Page 8 of 34 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0198.JPG 09/14/2017 1:13 pm Sherronda Phelps Tank 228 Roof (from top of tank) EPA Inspection Report - Page 9 of 34 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0199.JPG 09/14/2017 2:37 pm Sherronda Phelps Tank 3 (from ground level) EPA Inspection Report - Page 10 of 34 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0201.JPG 09/14/2017 2:37 pm Sherronda Phelps Tank 3 (from ground level) EPA Inspection Report - Page 11 of 34 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0205.JPG 09/14/2017 2:42 pm Sherronda Phelps Tank 3 (from ground level) EPA Inspection Report - Page 12 of 34 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0205.JPG 09/14/2017 2:45 pm Sherronda Phelps Tank 3 Monitoring from cut out hole EPA Inspection Report - Page 13 of 34 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0207.JPG 09/14/2017 2:45 pm Sherronda Phelps Tank 3 roof (from top of tank) EPA Inspection Report - Page 14 of 34 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0208.JPG 09/14/2017 2:46 pm Sherronda Phelps Tank 3 Monitoring from cut out hole EPA Inspection Report - Page 15 of 34 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0207.JPG 09/14/2017 2:45 pm Sherronda Phelps Tank 3 roof (from top of tank) EPA Inspection Report - Page 16 of 34 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0216.JPG 09/14/2017 2:50 pm Sherronda Phelps Tank 3 roof (from top of tank) EPA Inspection Report - Page 17 of 34 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0219.JPG 09/14/2017 2:51 pm Sherronda Phelps Tank 3 roof (from cut out hole) EPA Inspection Report - Page 18 of 34 Appendix 2 Inspection sign-in sheet EPA Inspection Report - Page 19 of 34 EPA Inspection Report - Page 20 of 34 Appendix 3 Pages from Permits EPA Inspection Report - Page 21 of 34 FEDERAL OPERATING PERMIT A FEDERAL OPERATING PERMIT IS HEREBY ISSUED TO Valero Energy Partners LP AUTHORIZING THE OPERATION OF Valero Partners Houston Petroleum Refining LOCATED AT Harris County, Texas Latitude 29 43' 20" Longitude 95 15' 18" Regulated Entity Number: RN100219310 This permit is issued in accordance with and subject to the Texas Clean Air Act (TCAA), Chapter 382 of the Texas Health and Safety Code and Title 30 Texas Administrative Code Chapter 122 (30 TAC Chapter 122), Federal Operating Permits. Under 30 TAC Chapter 122, this permit constitutes the permit holder's authority to operate the site and emission units listed in this permit. Operations of the site and emission units listed in this permit are subject to all additional rules or amended rules and orders of the Commission pursuant to the TCAA. This permit does not relieve the permit holder from the responsibility of obtaining New Source Review authorization for new, modified, or existing facilities in accordance with 30 TAC Chapter 116, Control of Air Pollution by Permits for New Construction or Modification. The site and emission units authorized by this permit shall be operated in accordance with 30 TAC Chapter 122, the general terms and conditions, special terms and conditions, and attachments contained herein. This permit shall expire five years from the date of issuance. The renewal requirements specified in 30 TAC 122.241 must be satisfied in order to renew the authorization to operate the site and emission units. Permit No: O3784 Issuance Date: June 30, 2016 For the Commission EPA Inspection Report - Page 22 of 34 (xiv) Title 30 TAC 115.546(a)(2) and (a)(2)(A) - (J) (relating to Recordkeeping and Notification Requirements), for recordkeeping (as appropriate to the control device) (xv) Title 30 TAC 115.546(a)(4) (relating to Recordkeeping and Notification Requirements), for recordkeeping of testing of control devices used to comply with 30 TAC 115.542(a)(1) (xvi) Title 30 TAC 115.546(b) (relating to Recordkeeping and Notification Requirements), for notification (xvii) Title 30 TAC 115.547(4) (relating to Exemptions) 7. The permit holder shall comply with the following requirements for units subject to any subpart of 40 CFR Part 60, unless otherwise stated in the applicable subpart: A. Title 40 CFR 60.7 (relating to Notification and Recordkeeping) B. Title 40 CFR 60.8 (relating to Performance Tests) C. Title 40 CFR 60.11 (relating to Compliance with Standards and Maintenance Requirements) D. Title 40 CFR 60.12 (relating to Circumvention) E. Title 40 CFR 60.13 (relating to Monitoring Requirements) F. Title 40 CFR 60.14 (relating to Modification) G. Title 40 CFR 60.15 (relating to Reconstruction) H. Title 40 CFR 60.19 (relating to General Notification and Reporting Requirements) 8. The permit holder shall comply with the requirements of 30 TAC Chapter 113, Subchapter C, 113.100 for units subject to any subpart of 40 CFR Part 63, unless otherwise stated in the applicable subpart. 9. For sources subject to emission standards in 40 CFR Part 63, Subpart CC, the permit holder shall comply with the following requirements (Title 30 TAC Chapter 113, Subchapter C, 113.340 incorporated by reference): A. Title 40 CFR 63.640(l)(3) - (4) (relating to Applicability and Designation of Affected Source), for units and equipment added to an existing source B. Title 40 CFR 63.640(m)(1) - (2) (relating to Applicability and Designation of Affected Source), for units and emission points changing from Group 2 to Group 1 status EPA Inspection Report - Page 23 of 34 Attachments Applicable Requirements Summary Permit Shield New Source Review Authorization References EPA Inspection Report - Page 24 of 34 Applicable Requirements Summary Unit Summary .......................................................................................... 14 Applicable Requirements Summary ......................................................... 22 Note: A "none" entry may be noted for some emission sources in this permit's "Applicable Requirements Summary" under the heading of "Monitoring and Testing Requirements" and/or "Recordkeeping Requirements" and/or "Reporting Requirements." Such a notation indicates that there are no requirements for the indicated emission source as identified under the respective column heading(s) for the stated portion of the regulation when the emission source is operating under the conditions of the specified SOP Index Number. However, other relevant requirements pursuant to 30 TAC Chapter 122 including Recordkeeping Terms and Conditions (30 TAC 122.144), Reporting Terms and Conditions (30 TAC 122.145), and Compliance Certification Terms and Conditions (30 TAC 122.146) continue to apply. EPA Inspection Report - Page 25 of 34 Unit/Group/ Process ID No. Unit Type 90FB001 STORAGE TANKS/ VESSELS 90FB001 STORAGE TANKS/ VESSELS 90FB001 STORAGE TANKS/ VESSELS 90FB002 STORAGE TANKS/ VESSELS 90FB002 STORAGE TANKS/ VESSELS 90FB002 STORAGE TANKS/ VESSELS 90FB003 STORAGE TANKS/ VESSELS 90FB003 STORAGE TANKS/ VESSELS 90FB004 STORAGE TANKS/ VESSELS 90FB004 STORAGE TANKS/ VESSELS 90FB004 STORAGE TANKS/ VESSELS 90FB005 STORAGE TANKS/ VESSELS Unit Summary Group/Inclusive SOP Index No. Units Regulation N/A R5112-5 30 TAC Chapter 115, Storage of VOCs N/A 60Kb-5 40 CFR Part 60, Subpart Kb Requirement Driver No changing attributes. No changing attributes. N/A 63CC-2 40 CFR Part 63, Subpart CC No changing attributes. N/A R5112-4 30 TAC Chapter 115, Storage No changing attributes. of VOCs N/A 60Kb-4 40 CFR Part 60, Subpart Kb No changing attributes. N/A 63CC-1 40 CFR Part 63, Subpart CC No changing attributes. N/A R5112-2 30 TAC Chapter 115, Storage No changing attributes. of VOCs N/A 63CC-1 40 CFR Part 63, Subpart CC No changing attributes. N/A R5112-4 30 TAC Chapter 115, Storage No changing attributes. of VOCs N/A 60Kb-4 40 CFR Part 60, Subpart Kb No changing attributes. N/A 63CC-1 40 CFR Part 63, Subpart CC No changing attributes. N/A R5112-2 30 TAC Chapter 115, Storage No changing attributes. of VOCs EPA Inspection Report - Page 26 of 34 Unit/Group/ Process ID No. Unit Type 90FB226 STORAGE TANKS/ VESSELS 90FB227 STORAGE TANKS/ VESSELS 90FB227 STORAGE TANKS/ VESSELS 90FB227 STORAGE TANKS/ VESSELS 90FB228 STORAGE TANKS/ VESSELS 90FB228 STORAGE TANKS/ VESSELS 90FB230 STORAGE TANKS/ VESSELS 90FB230 STORAGE TANKS/ VESSELS 90FB230 STORAGE TANKS/ VESSELS 90FB231 STORAGE TANKS/ VESSELS 90FB232 STORAGE TANKS/ VESSELS 90FB233 STORAGE TANKS/ VESSELS Unit Summary Group/Inclusive SOP Index No. Units Regulation N/A 63CC-1 40 CFR Part 63, Subpart CC Requirement Driver No changing attributes. N/A R5112-5 30 TAC Chapter 115, Storage No changing attributes. of VOCs N/A 60Kb-6 40 CFR Part 60, Subpart Kb No changing attributes. N/A 63CC-1 40 CFR Part 63, Subpart CC No changing attributes. N/A R5112-2 30 TAC Chapter 115, Storage No changing attributes. of VOCs N/A 63CC-1 40 CFR Part 63, Subpart CC No changing attributes. N/A R5112-2 30 TAC Chapter 115, Storage No changing attributes. of VOCs N/A 60Kb-3 40 CFR Part 60, Subpart Kb No changing attributes. N/A 63CC-1 40 CFR Part 63, Subpart CC No changing attributes. N/A R5112-1 30 TAC Chapter 115, Storage No changing attributes. of VOCs N/A R5117-1 30 TAC Chapter 115, Storage No changing attributes. of VOCs N/A R5117-1 30 TAC Chapter 115, Storage No changing attributes. of VOCs EPA Inspection Report - Page 27 of 34 Applicable Requirements Summary Unit Group Process ID No. 90FB003 90FB003 Unit Group Process Type SOP Index No. EU R5112-2 EU 63CC-1 Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements VOC 30 TAC Chapter 115, Storage of VOCs 115.112(e)(1) 115.112(e)(2) 115.112(e)(2)(A) 115.112(e)(2)(B) 115.112(e)(2)(C) 115.112(e)(2)(E) 115.112(e)(2)(F) 115.112(e)(2)(G) [G] 115.112(e)(2)(H) [G] 115.112(e)(2)(I) 115.114(a)(2)(A) 115.114(a)(4)(A) No person shall place, store, or hold VOC in any storage tank unless the storage tank is capable of maintaining working pressure sufficient at all times to prevent any vapor or gas loss to the atmosphere or is in compliance with the control requirements specified in Table 1 of this paragraph for VOC other than crude oil and condensate or Table 2 of subsection (a)(1) of this paragraph for crude oil and condensate. 115.114(a)(2) 115.114(a)(4) 115.114(a)(4)(A) [G] 115.117 112(B) HAPS 40 CFR Part 63, Subpart CC 63.646(a) 63.119(a)(1) 63.119(c)(1) 63.119(c)(1)(i) 63.119(c)(1)(ii) 63.119(c)(1)(iii) [G] 63.119(c)(3) 63.119(c)(4) 63.120(b)(10)(i) 63.120(b)(5)(i) 63.120(b)(5)(ii) 63.120(b)(6)(i) 63.120(b)(6)(ii) [G] 63.120(b)(7) 63.120(b)(8) [G] 63.646(f) 63.646(g) Each owner or operator of a Group 1 storage vessel subject to this subpart shall comply with the requirements of 63.119 63.121 except as provided in 63.646(b)-(l). 63.120(b)(1)(i) 63.120(b)(1)(iii) 63.120(b)(1)(iv) 63.120(b)(10) 63.120(b)(2)(i) 63.120(b)(2)(ii) 63.120(b)(2)(iii) 63.120(b)(3) 63.120(b)(4) 63.646(b)(1) 63.646(e) Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.118(a)(3) 115.118(a)(5) 115.118(a)(6)(C) 115.118(a)(7) 115.114(a)(2)(B) 115.114(a)(4)(B) 115.118(a)(3) [G] 63.120(b)(7) 63.120(b)(8) 63.642(e) 63.646(b)(1) 63.655(h)(1) [G] 63.655(i)(1) 63.655(i)(5) 63.120(b)(10)(ii) 63.120(b)(10)(iii) 63.120(b)(9) 63.642(f) 63.655(f) [G] 63.655(f)(1)(i)(B) 63.655(f)(6) 63.655(g) [G] 63.655(g)(3) 63.655(h) 63.655(h)(1) 63.655(h)(2)(i) 63.655(h)(2)(i)(A) 63.655(h)(2)(i)(B) 63.655(h)(2)(i)(C) 63.655(h)(2)(ii) [G] 63.655(h)(6) EPA Inspection Report - Page 28 of 34 Applicable Requirements Summary Unit Group Process ID No. 90FB228 90FB230 Unit Group Process Type SOP Index No. EU 63CC-1 EU R5112-2 Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements 112(B) HAPS 40 CFR Part 63, Subpart CC 63.646(a) 63.119(a)(1) 63.119(c)(1) 63.119(c)(1)(i) 63.119(c)(1)(ii) 63.119(c)(1)(iii) [G] 63.119(c)(3) 63.119(c)(4) 63.120(b)(10)(i) 63.120(b)(5)(i) 63.120(b)(5)(ii) 63.120(b)(6)(i) 63.120(b)(6)(ii) [G] 63.120(b)(7) 63.120(b)(8) [G] 63.646(f) 63.646(g) Each owner or operator of a Group 1 storage vessel subject to this subpart shall comply with the requirements of 63.119 63.121 except as provided in 63.646(b)-(l). 63.120(b)(1)(i) 63.120(b)(1)(iii) 63.120(b)(1)(iv) 63.120(b)(10) 63.120(b)(2)(i) 63.120(b)(2)(ii) 63.120(b)(2)(iii) 63.120(b)(3) 63.120(b)(4) 63.646(b)(1) 63.646(e) VOC 30 TAC Chapter 115, Storage of VOCs 115.112(e)(1) 115.112(e)(2) 115.112(e)(2)(A) 115.112(e)(2)(B) 115.112(e)(2)(C) 115.112(e)(2)(E) 115.112(e)(2)(F) 115.112(e)(2)(G) [G] 115.112(e)(2)(H) [G] 115.112(e)(2)(I) 115.114(a)(2)(A) 115.114(a)(4)(A) No person shall place, store, or hold VOC in any storage tank unless the storage tank is capable of maintaining working pressure sufficient at all times to prevent any vapor or gas loss to the atmosphere or is in compliance with the control requirements specified in Table 1 of this paragraph for VOC other than crude oil and condensate or Table 2 of subsection (a)(1) of this paragraph for crude oil and condensate. 115.114(a)(2) 115.114(a)(3) 115.114(a)(4) 115.114(a)(4)(A) [G] 115.117 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) [G] 63.120(b)(7) 63.120(b)(8) 63.642(e) 63.646(b)(1) 63.655(h)(1) [G] 63.655(i)(1) 63.655(i)(5) 115.118(a)(3) 115.118(a)(5) 115.118(a)(6)(C) 115.118(a)(7) 63.120(b)(10)(ii) 63.120(b)(10)(iii) 63.120(b)(9) 63.642(f) 63.655(f) [G] 63.655(f)(1)(i)(B) 63.655(f)(6) 63.655(g) [G] 63.655(g)(3) 63.655(h) 63.655(h)(1) 63.655(h)(2)(i) 63.655(h)(2)(i)(A) 63.655(h)(2)(i)(B) 63.655(h)(2)(i)(C) 63.655(h)(2)(ii) [G] 63.655(h)(6) 115.114(a)(2)(B) 115.114(a)(4)(B) 115.118(a)(3) EPA Inspection Report - Page 29 of 34 Permit Shield The Executive Director of the TCEQ has determined that the permit holder is not required to comply with the specific regulation(s) identified for each emission unit, group, or process in this table. Unit/Group/Process ID No. Group/Inclusive Units 90FB003 N/A 90FB006 N/A Regulation 40 CFR Part 60, Subpart K 40 CFR Part 60, Subpart Kb 90FB211 N/A 40 CFR Part 60, Subpart Kb 90FB212 N/A 40 CFR Part 60, Subpart Kb 90FB216 N/A 90FB224 N/A 90FB225 N/A 90FB226 N/A 90FB228 N/A 90FB231 N/A 40 CFR Part 60, Subpart K 40 CFR Part 60, Subpart K 40 CFR Part 60, Subpart K 40 CFR Part 60, Subpart K 40 CFR Part 60, Subpart K 40 CFR Part 60, Subpart Kb 90FB232 N/A 40 CFR Part 60, Subpart Kb 90FB233 N/A 40 CFR Part 60, Subpart Kb Basis of Determination Capacity > 65,000 gallons and constructed prior to 6/11/73. Vessel stores a VOL with a maximum true vapor pressure less than 0.5 psia. Tank stores a VOL with a maximum true vapor pressure less than 0.5 psia. Tank stores a VOL with a maximum true vapor pressure less than 0.5 psia. Capacity > 65,000 gallons and constructed prior to 6/11/73. Capacity > 65,000 gallons and constructed prior to 6/11/73. Capacity > 65,000 gallons and constructed prior to 6/11/73. Capacity > 65,000 gallons and constructed prior to 6/11/73. MACT CC supersedes NSPS K for Group 1 tanks. Vessel stores a VOL with a maximum true vapor pressure less than 0.5 psia. Vessel stores a VOL with a maximum true vapor pressure less than 0.5 psia. Vessel stores a VOL with a maximum true vapor pressure less than 0.5 psia. EPA Inspection Report - Page 30 of 34 New Source Review Authorization References by Emissions Unit The following is a list of New Source Review (NSR) authorizations for emission units listed elsewhere in this operating permit. The NSR authorizations are applicable requirements under 30 TAC Chapter 122 and enforceable under this operating permit. Unit/Group/Process ID No. 90FB001 90FB002 90FB003 90FB004 90FB005 90FB006 90FB204 90FB205 90FB210 90FB211 90FB212 90FB215 90FB216 90FB224 90FB225 90FB226 90FB227 90FB228 Emission Unit Name/Description STORAGE TANK 90FB001 STORAGE TANK 90FB002 STORAGE TANK 90FB003 STORAGE TANK 90FB004 STORAGE TANK 90FB005 STORAGE TANK 90FB006 STORAGE TANK 90FB204 STORAGE TANK 90FB205 STORAGE TANK 90FB210 STORAGE TANK 90FB211 STORAGE TANK 90FB212 STORAGE TANK 90FB215 STORAGE TANK 90FB216 STORAGE TANK 90FB224 STORAGE TANK 90FB225 STORAGE TANK 90FB226 STORAGE TANK 90FB227 STORAGE TANK 90FB228 New Source Review Authorization 129444, 86142, 106.261/11/01/2003 106.261/11/01/2003, 106.263/11/01/2001, 106.478/09/04/2000 106.261/11/01/2003, 106.261/12/24/1998 106.261/11/01/2003, 106.478/09/04/2000 129444 129444 106.478/09/04/2000 106.478/09/04/2000 129444 129444 129444 129444 129444 129444 102/01/08/1980 129444 106.478/09/04/2000 129444 o EPA Inspection Report - Page 31 of 34 () BryanW. Shaw, Ph.D., P.E., Chairman Toby Bal<er, Comrnissioner Jon Niermann, Commissioner Richard d Hyde, P.L, Hecutive Director Trxns CoiwnssroN oN EUUnoNMENTAL Quarrrv Protecting Texas by Reducing and Preventing Pollution MR ROBERT E MOORE VICE PRESIDENT AND GENERAL MANAGER VALERO REFINING TEXAS LP 9701 MANC}IESTER ST HOUSTON TX 77012-2408 December 19,2016 Re: Permit Alteration Permit Number: 129444 Expiration Date: February L7,2O2O Valero Energy Partners LP Valero Houston Refinery Houston, Harris County Regulated Entity Number: RN109290692 Customer Reference Number: CN604780486 Dear Mr. Moore: This is in response to a letter from Mr. Matthew I jndquist, received September 12,20L6, requesting alteration of the conditions and Maximum Allowable Fmission Rates Table (MAERT) of the above-referenced permit. We understand that you are requesting to administratively transfer fugitive components and associated emissions from New Source Review (NSR) Permit No. 2501A to NSR Permit No.129444. In accordance with Title 30 Texas Administrative Code $116.116(c) and based on our review, Permit Number L29444 is altered. Endosed are the new general conditions (permit face), altered special conditions, and altered MAERT. Please attach these to your permit. You are reminded that these facilities must be in compliance with all rules and regr:lations of the Texas Commission on Environmental Quality (TCEQ) and of the U.S. Environmental hotection Agency at all times. If you need further information or have any questions, please contact Mr. Kevin Oram at (512) 239-0158 or write to the Texas Commission on Environmental Quality, Office of Air, Air Permits Division, MC-l63, P.O. Box 13087, Austin, Texas 787LL-3087. P.O. Box 13087 . Austin, Texas 78711-3087 512-239-1000 tceq.texas.gov How is our customer seMce? tceq.texas.gov/customersuwey prlDted on rccyded papq o EPA Inspection Report - Page 32 of 34 ) Mr. Robert E Moore Page 2 December 19, 2016 Re: Permit Number: 129444 This action is taken under authority delegated by the Executive Director of TCEQ. @a Sincerely, Mchael Wilson, P.E., Director Air Permits Division Office of Air Texas Commission on Environmental Quality Endosure cc: Senior Project Manager, Houston Department of Health and Human Services, Bureau of Pollution Control & hevention, Houston Director, Harris County, Pollution Control Services, Pasadena Air Section Manager, Region 12 - Houston Project Numbers: 258387 EPA Inspection Report - Page 33 of 34 () /\ SPECIAL CONDMIONS Pemit Number 129444 1. This permit covers only those sources of emissions listed in the attached table entitled "F.mission Sources - Maximum Allowable Emis,sion Rates" (MAERT), and those sources are Iimited to the emission limits and other conditions specified in that table. 2. This permit authorizes Planned Maintenance, Startup, and Shutdown emissions from the activities listed in attachment A and only from those points ]isted in the attached table entitled "Emission Sources - Maximum Allowable Fmission Rates." The facilities covered by this permit are authorized to emit subject to the emissi6ll rate limits on that table and other operating conditions specified in this permit. Federal Applicability 3. These facilities shall comply with all applicable requirements of the U.S. Environmental hotection Agency (EPA) regulations on Standards of Performance for New Stationary Sources promulgated in Title 40 Code of Federal Regulations Part 60 (40 CFR Part 60): A Subpart A, General hovisions. B. Subpart Kb, Volatile Organic Liquid Storage Vessels. 4. These facilities shall comply with all applicable requirements of the U.S. Environmental Protection Agency (EPA) regulations on National Emission Standards for Hazardous Air Pollutants for Source Categories in 40 CFR Part 63: A Subpart A, General hovisions. B. Subpart CC, Petroleum Refineries, Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units- Emi ssion Standards and Operational Specifications 5. Storage tanks are Iimited to the following services: Tank Number Service(s) 90F8001 90FB005 90FB006 90F8205 90F8211 90F8212 Tank Number Catfeed/Crude Crude oil Catfeed Gasoline components and cat gasoline Kerosene/Jet Fuel/Diesel Kerosene/Jet FueyDiesel Service(s) 90FB215 90FB216 90F9224 90FB226 90F8228 90F8230 90FB232 (Diesel/Kerosene) No. 2 fud oil (Coker Distillate) No. 2 fuel oil Slurry oil Gasoline sgmponents and cat gasoline Gasoline components and cat gasoline Alkylate No. 2 fuel oil and kerosene A EPA Inspection Report - Page 34 of 34 ' ,- __/ -\- Emissiga Sources - trlorilnum Allowable Fmission Rates Permit Number L29444 This table ]jsts the maximum allowable emission rates and a]l sources of air contaminants on the applicant's property covered by this permit. The emission rates shown are those derived from information submitted as part of the application for permit and are the maximum rates allowed for these facilities, sources, and related activities. Any proposed increase in emission rates may require an application for a modification of the facilities covered by this permit. rlii'.: l:ir'" "Xi.l .. :i -'.'.:t.l.,:t:l...:::':W::!P: .:lrii,iiri .';.1 i j 11 ,.:,14fti,*-*l rit}4l$*"tp,,R;#g,l rAiiriffifriffii[qi( ]*,i Air Conteminants Data fnii;ili:iiE;ffii T'l,irl:: I:;'i*.:JAfl ; -;i i , i':rl ffi#I[y tel,: 9oFB005 9oFB001 9oFB006 90FB001,90FB006 91FBg17 90F8230 90F8205 Storage Tank 90FB005 Storage Tank 90FB001 Storage Tank 90FB006 Storage Tank Cap Storage Tank 91F8917 Storage Tank 90FB230 Storage Tank 90FB205 VOC VOC VOC VOC VOC VOC VOC 4.7L 0.80 0.80 1.80 3.10 3.s0 3.82 0.63 2.22 9.41 Benzene 0.20 90FB226 Storage Tank 90FB226 voc 3.50 9oFB228 Storage Tank 90FB228 Benzene VOC 0.20 3.s0 9oFB505 Storage Tank 90FB505 Benzene 0.20 voc 3.50 Benzene 0.20 9oFB506 Storage Tank 90FB506 VOC 3.s0 90FB507 Storage Tank 90FB507 Benzene 0.20 voc 2.27 90FB205, 90F8226, 90E8228, 90F8505, 90F8506, 90F8507, 91FB918 91F8920 91FB921 Storage Tank Cap Storage Tank 91F8918 Storage Tank 91F8920 Storage Tank 91F8921 Benzene voc Benzene VOC voc voc 0.03 60.78 3.37 0.50 0.40 0.40 Project Number: 258387