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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Marathon Petroleum Corporation, Garyville, Louisiana Constantinos Loukeris, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Marathon Petroleum Corporation (MPC) Facility Location: 4663 W. Airline Highway, Garyville, LA, 70051 Date of Inspection: April 14-15, 2022 EPA Inspector(s): 1. Constantinos Loukeris, Environmental Engineer 2. Jason Schenandoah, Environmental Engineer 3. James Haynes, Physical Scientist 4. Ben Rosenthal, Physical Scientist Other Attendees: 1. Kelly Hedges, MPC Environmental Supervisor 2. Haley Ilg, MPC Environmental Manager 3. Paula Bremmer, Environmental Professional 4. Jim Manning, MPC ESS Manager 5. Lance Traylor, MPC LDAR Coordinator 6. Mia Mosby, MPC Environmental Professional 7. Veo Mills, MPC Environmental Engineer 8. David Calebaugh, MPC Environmental Professional 9. Jason Bradford, MPC Environmental Professional 10. Marvin Alberto, Clean Harbors Contractor 11. Jonathan Brockhaus, Alliance Contractor 12. Lee Oncale, MPC Shift Supervisor Contact Email Address: kmhedges@marathonpetroleum.com Page 1 of 4 Purpose of Inspection: Inspect the benzene waste operations and volatile organic compounds (VOC) emissions from wastewater systems Facility Type: Petroleum Refinery Regulations Central to Inspection: Refinery wastewater subject to the New Source Performance Standards for VOC Emissions from Petroleum Refinery Wastewater Systems, at 40 C.F.R. Part 60, Subpart QQQ (Subpart QQQ), and the National Emissions Standards for Hazardous Air Pollutants for Benzene Waste Operations, at 40 C.F.R. Part 61, Subpart FF (Subpart FF) Arrival Time: April 13, 2022, 2:00 pm Departure Time: April 15, 2022, 1:20 pm Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided CBI warning to facility The following information was obtained verbally from MPC personnel unless otherwise noted. Process Description: MPC provided an overview of the overall flow of the benzene waste streams, including those that are controlled by Subpart FF and those that overlap with Subpart QQQ. MPC operates two desalter units, one installed in the late 1970's (desalter #10) and one installed in the late 2009 (desalter #210). Each of the desalters operate with a benzene flash column to remove any benzene prior to sending the streams for further treatment. Originally, MPC managed waste from each desalter to an American Petroleum Institute (API) designed oil/water separator (OWS) respective of installation timing. However, since 2009, MPC has modified its benzene waste operations a few times such that each desalter sends material primarily to tank #100-5 with a smaller stream being sent to either API oil water/separator #1 (for desalter 10). The wastewater from tank#100-5 is sent to two dissolved nitrogen floatation units (DNF) that operate in parallel. The DNF's were installed in late 2020. In addition to the two desalter streams, the refinery generates other waste streams that are sent to each of the API oil/water separators. Each API oil/water separator streams route the benzene emissions to a two-carbon bed system, that is operated in parallel. MPC indicated that the carbon was changed last on one of the beds for API oil/water separator #1 in 2017, and there has been no carbon bed change for API oil/water separator #2 since its installation in 2010. Page 2 of 4 Staff Interview: EPA had a brief interview with Mr. Marvin Alberto on April 15, 2022 regarding his oversight of the Subpart FF program. Mr. Alberto is responsible for conducting EPA Method 21 and visual inspections on the components that MPC has identified as needing that type of monitoring. In addition, Mr. Alberto conducts carbon canister sampling for breakthrough by sampling the outlet of the carbon beds for 5 parts per million (ppm) of benzene by using a benzene calibrated portable photo-ionization detector instrument. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: MPC indicated that the covers of API #1 OWS, API #2 OWS, the stormwater sump, AIS3 Sump, and the ISBL sump are not monitored with Method 21 to verify that there no detectable emissions above 500 ppm; however, a seal gap measurement is performed semi-annually for the API's. EPA observed a pressure relief valve to have a bypass to atmosphere near associated with the benzene stripper supporting the area 10 desalter system. EPA observed a vacuum truck with personnel cleaning an oil float on both days that we were onsite on top of API #1 OWS. MPC operations indicated that this is routine during any rain events and at other times. EPA observed no sealant at multiple spots, cracked seals, and a warped-open cover on the stormwater sump located next to API #1 OWS. Two carbon canisters controlling emissions from API #1 OWS and API #1 OWS effluent sump are used in parallel. MPC indicated that the effluent from the sour water strippers is routed to API #1 OWS effluent sump, and the temperature of that stream is between 160-200F. Photos and/or Videos: were taken during the inspection. EPA imaged hydrocarbon emissions using a FLIR optical gas imaging camera, Model GFx-320. In addition, this camera was also used to take digital pictures and videos as well. See Appendix 1 for the summary of the videos and pictures taken. Field Measurements: were taken during this inspection. See Appendix B for a summary EPA's field measurements. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: 1. 2019-2022 Annual No Detectable Emission Inspections 2. 2019-2022 Quarterly BWON Visual Inspections 3. End of Line Sampling Plan 4. 2019-2021 Semi-Annual Subpart QQQ Reports Page 3 of 4 5. 2019-2021 Semi-Annual Subpart FF Reports 6. 2019-2021 Total Annual Benzene Reports 7. Subpart FF Carbon Canister Changeout Report for 2019-2022 8. Carbon Adsorption System Design Basis For the API Vent (July 11, 2008) - Confidential Business Information (CBI) 9. API Separator General Plan and Drawing - CBI 10. API Separator Panel and Seal Layout - CBI 11. API Welded Panel Assembly - (1 of 2) - CBI 12. API Welded Panel Assembly - (1 of 2) - CBI 13. API Separator Main Bay Seal Details - CBI 14. API Separator Forebays Panel and Seal Details - CBI 15. API Separator Forebay Panel Fabrication Details - CBI 16. API Separator Primary and Secondary Seal Details - CBI 17. OWS - J-Bolt Installation - CBI 18. 2019-2022 Instrument Calibration Records 19. WWTP Flow Diagram (dated 4/29/2022) 20. Flash Column Performance Certification (March 30, 2005) 21. Revised MPC 6 BQ RY21 (dated 4/29/2022) 22. Garyville Carbon Canister Calculation with ASTM Final Spreadsheet 23. CBI Notice (dated 4/29/2022) Concerns: EPA identified the follow areas of concern: 1. MPC has not maintained a wastewater drawing reflecting the benzene waste operations, and unable to provide how compliance with the 6 Megagram control option is maintained for Subpart FF; 2. MPC has never conducted no detectable emission (NDE) monitoring on the API OWS's, and other sump covers that are part of the controlled system for Subpart FF. 3. Routine oil float on top of API #1 OWS indicative of the floating roof not creating a seal or designed to NDE under Subparts QQQ and FF. 4. MPC may not be meeting the 6 Megagram control option based on the several of the waste managements being considered controlled but not operated as controlled. 5. Pressure relief valves subject to Subpart FF having an atmospheric bypass. DIGITAL SIGNATURES CONSTANTIN CONSTANTINOS LOUKERIS Digitally signed by Date: 2022.05.23 15:48:03 Report Author: _____O_S__L_O__U_K_E_R__IS__-05_'0_0' _____________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL Date: 2022.05.23 ______M_A__R_S__H_A__L_L__1_5_:53_:0_5_-0_5'0_0_' ________ Page 4 of 4 Facility Name: Marathon Petroleum Corporation Facility Location: 4663 W. Airline Highway, Garyville, LA, 70051 Date of Inspection: April 13-15, 2022 APPENDIX A: DIGITAL IMAGE/VIDEO LOG 1. Inspector Name: James Haynes 2. Archival Record Location: C:\Users\cloukeri\OneDrive - Environmental Protection Agency (EPA)\EPAWork\Marathon Ashland Petroleum\Garyville Refinery\MPC Garyville - April 2022 Inspection\EPA FLIR Video and Pics Image Number 1 2 3 4 File Name MOV_0186.mp4 MOV_0189.mp4 MOV_0190.mp4 MOV_0195.mp4 5 MOV_0196.mp4 6 MOV_0209.mp4 7 MOV_0211.mp4 8 MOV_0212.mp4 9 MOV_0213.mp4 10 MOV_0216.mp4 11 MOV_0217.mp4 12 DC_0176.jpg 13 DC_0177.jpg 14 DC_0178.jpg 15 DC_0179.jpg 16 DC_0180.jpg 17 DC_0181.jpg 18 DC_0182.jpg Date 4/14/2022 4/14/2022 4/14/2022 4/14/2022 4/14/2022 4/14/2022 4/14/2022 4/14/2022 4/14/2022 4/14/2022 4/14/2022 4/14/2022 4/14/2022 4/14/2022 4/14/2022 4/14/2022 4/14/2022 4/14/2022 Description of Image Hydrocarbon emissions imaged from Stormwater Sump - Gooseneck Vent Video of a portion of the Stormwater Sump, flame arrestor, and gooseneck vent Brief video of the Stormwater Sump cover Video of API #1 OWS portion of the floating roof, with visible oil stains on parts of the seal Video of API #1 OWS - Oil-water float on roof Video of a grated manhole cover, digital and infrared Hydrocarbon emissions imaged from API #1 OWS Effluent Sump Hydrocarbon emissions imaged from Stormwater Sump - Cover Warped Open Hydrocarbon emissions imaged from Stormwater Sump - Gooseneck Vent, Process Heaters in background Infrared video, showing a reflection on an external floating roof tank from flare located nearby Hydrocarbon emissions imaged from steam- assisted flare nearby wastewater tanks Stormwater Sump Cover Stormwater Sump Cover - Warped Cover, Open Seam Stormwater Sump Cover - Seam by Pump Stormwater Sump Cover - Seam by Pump, Sealant Missing on Cover Plate Stormwater Sump Cover - Seam by Pump Stormwater Sump Cover _ Seam by Pump, Dry Caulk, Gap Stormwater Sump Cover - Seam Appendices Page 1 of 4 Facility Name: Marathon Petroleum Corporation Facility Location: 4663 W. Airline Highway, Garyville, LA, 70051 Date of Inspection: April 13-15, 2022 19 DC_0183.jpg 4/14/2022 Stormwater Sump Cover 20 DC_0184.jpg 4/14/2022 Stormwater Sump Cover 21 DC_0187.jpg 4/14/2022 Stormwater Sump Cover 22 DC_0188.jpg 4/14/2022 Stormwater Sump Cover - Gooseneck Vent 23 DC_0191.jpg 4/14/2022 Stormwater Sump Cover 24 DC_0192.jpg 4/14/2022 Stormwater Sump Cover 25 DC_0193.jpg 4/14/2022 API #1 OWS - Oil-water float on roof 26 DC_0194.jpg 4/14/2022 API #1 OWS - Oil-water float on roof 27 DC_0197.jpg 4/14/2022 API #1 OWS vent off back bay 28 DC_0198.jpg 4/14/2022 API #1 OWS vent off back bay 29 DC_0199.jpg 4/14/2022 API #1 OWS Effluent Sump 30 DC_0200.jpg 4/14/2022 API #1 OWS Effluent Sump 31 DC_0201.jpg 4/14/2022 API #1 OWS Effluent Sump 32 DC_0202.jpg 4/14/2022 API #1 OWS Effluent Sump 33 DC_0203.jpg 4/14/2022 API #1 OWS Effluent Sump - Staining and Cracks in Cover lining 34 DC_0204.jpg 4/14/2022 API #1 OWS Effluent Sump - Staining and Cracks in Cover lining 35 DC_0205.jpg 4/14/2022 API #1 OWS Effluent Sump - Staining and Cracks in Cover lining 36 DC_0206.jpg 4/14/2022 API #2 - Cover manway 37 DC_0207.jpg 4/14/2022 Expansion Sump 38 DC_0208.jpg 4/14/2022 View of Sumps Leading into API #1 OWS 39 DC_0210.jpg 4/14/2022 Pressure Relief Valve with Atmospheric Bypass off Benzene Stripper in Area 10 40 DC_0214.jpg 4/14/2022 API #1 OWS - Oil-water float on roof 41 DC_0215.jpg 4/14/2022 API #1 OWS - Oil-water float on roof 42 IR_00185.jpg 4/14/2022 Stormwater Sump Cover - Gooseneck Vent (infared) Appendices Page 2 of 4 Facility Name: Marathon Petroleum Corporation Facility Location: 4663 W. Airline Highway, Garyville, LA, 70051 Date of Inspection: April 13-15, 2022 APPENDIX B: FIELD MEASUREMENT DATA The table below summarizes the field measurements by EPA conducting Method 21 with a Thermo Toxic Vapor Analyzer, Model 2020, and when available confirmed by MPC. Where MPC did not have an instrument available to confirm, EPA confirmed with a 2nd instrument. Component ID Equipment Type EPA's MPC's Additional Notes Reading Reading (ppm) (ppm)* API #1 OWS Drain hood, East 562 - None Side, Southwest Corner API #1 OWS Floating roof seal - 2,148 - None East Side, Northeast corner API #1 OWS NW Cover on oil 2,908 - No sealant around the skim, and pump to area. MPC indicated hazardous waste maintenance work tank completed several days prior, and expect to seal soon API #1 OWS SW Cover on oil 2,997 - No sealant around the skim, and pump to area. MPC indicated hazardous waste maintenance work tank completed several days prior, and expect to seal soon API #1 OWS NW Cover on oil 2,025 - No sealant around the skim, and pump to area. MPC indicated hazardous waste maintenance work tank completed several days prior, and expect to seal soon API #1 OWS NW Cover on next 680 - No sealant or gasket on to back bay the cover plate to the valve Stormwater Cover plate #1 for 600 - None Sump pump within the main cover of the sump Stormwater Cover plate #2 1,900 - No sealant around the Sump within the main area around cover plate. cover the sump Stormwater Cover plate #3 600 - No sealant around the Sump within the main area around cover plate. cover the sump Appendices Page 3 of 4 Facility Name: Marathon Petroleum Corporation Facility Location: 4663 W. Airline Highway, Garyville, LA, 70051 Date of Inspection: April 13-15, 2022 Stormwater Sump Stormwater Sump Stormwater Sump Stormwater Sump API #2 OWS API #2 OWS API #2 OWS API #2 OWS AIS3 Sump API #1 OWS Effluent Sump API #1 OWS Effluent Sump API #1 OWS Effluent Sump API #1 OWS Effluent Sump PH-60-38 Cover plate seam Cover plate at the 3rd seam from the west side of the sump Cover plate #4 within the main cover the sump Cover plate at the 1st seam from the east side of the sump Access manway (inner ring) on the west end (Nearest Tag # 60-2239-01) Access manway (outer ring) on the west end (Nearest Tag # 60-2239-01) Access manway on east side Access manway on east side Cover of pump within the main cover of the sump Cover, middle of east end of sump Cover, middle of sump Cover, middle of sump Cover, middle of sump Drain 800 10,000 1,964 1,591 1,600 700 3,021 1,306 729 1,600 10,000 1,800 650 - - Caulk cracked on seam. - Cover warped open with no caulk or seal intact. - None - None - None 800 None - On handle not closed to the access door - On seal to manway - Opening to atmosphere from a pinhole - None - Cover was warped open and visible steam coming out. - Cover was actively bubbling. - Middle of the sump near pump #2 - Oil present, MPC added water upon identification Appendices Page 4 of 4