Document O39M9jb7edDDk1y1GZrgR32dp

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET SW ATLANTA, GEORGIA 30303-8960 SENT VIA ELECTRONIC MAIL Kevin Clark Terminal Operations Supervisor Shell Oil Products US 1717 61st Avenue North Nashville, Tennessee 37209 Kevin.Clark@shell.com Dear Mr. Clark: Enclosed is a copy of the final report generated by the U.S. Environmental Protection Agency's Region 4, North Air Enforcement Section, for the inspection conducted at the Shell Oil Products US facility, located in Nashville, Tennessee, on July 12, 2022. If you have any questions, please contact me at 404-562-8134, or by email at Zhong.Baichen@epa.gov. Sincerely, BAICHEN ZHONG Digitally signed by BAICHEN ZHONG Date: 2022.09.01 16:53:42 -04'00' Baichen Zhong Environmental Engineer North Air Enforcement Section Enclosure CC: John Finke, Nashville Metro Public Health Department ENCLOSURE A FINAL INSPECTION REPORT United States Environmental Protection Agency (EPA) Region 4 Air Enforcement Branch Inspection Report I. GENERAL INFORMATION Facility Name: Shell Oil Products US Location (Address): 1717 61st Avenue North, Nashville, TN Inspection Date: 7/12/2022 Type of Inspection (Full or Partial Compliance Evaluation): Partial Compliance Evaluation ICIS-Air Number: TNNDC0004703700065-2022 EPA Investigator(s)/Inspector(s): 1. Baichen Zhong, Environmental Engineer 2. Nicole Radford, Environmental Scientist State/Local Investigator(s)/Inspector(s): 1. Eric McCann, MPHD 2. Natalie Tooley, MPHD Person(s) Contacted at Facility (Name and Title): 1. Ben Graham, Lead Operator 2. Kevin Clark, Terminal Operations Supervisor Report Prepared by: Baichen Zhong Project Name: Shell Oil Products US ICIS/Project No.: TNNDC0004703700065-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 1 of 10 II. FACILITY INFORMATION A. Facility and Permit Information Facility and Permit Information Comments 1. Type of facility (e.g., chemical plant, refinery, cement manufacturer, etc.). 2. Air permit number(s) and type of permit (e.g., Title V, PSD, Synthetic Minor, etc.). 3. Air permit issuance date. 4. Air permit expiration date. 5. Facility classification (Major, Synthetic Minor/Conditional Major, Minor). 6. Major source pollutants (if Bulk petroleum distribution terminal. The Shell Oil Products US facility is operating under Synthetic Minor Operating Permit Nos. 65-1, 65-2, 65-3, 65-8, 65-9, 65-10 and 65-11. These permits are issued by the Metro Public Health Department of the Metropolitan Government of Nashville and Davidson County. Date of Issuance: July 1, 2022 Expiration Date: June 30, 2023 Shell Oil Products US is classified as a Synthetic Minor source. VOCs applicable). 7. Applicable regulations (e.g., State Implementation Plan, MACT Subpart FFFF, NSPS Subpart EEEE, etc.). 8. Types of air emission points (e.g., tanks, process vents, boilers, etc.). 9. Types of air pollution control equipment (e.g., baghouse, scrubber, afterburner, etc.). 40 C.F.R. Part 63 Subpart BBBBBB Tanks and truck loading racks A Vapor Recovery Unit (VRU) is used to control emissions at the loading rack. A Vapor Combustion Unit (VCU) serves as backup for the VRU. Project Name: Shell Oil Products US ICIS/Project No.: TNNDC0004703700065-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 2 of 10 B. Process Description (provide narrative or attach description provided by the company or excerpts from the permit) Shell Oil Products US is a bulk gasoline facility that handles gasoline, diesel fuel, ethanol, additives, and other volatile organic products. These products are delivered to the facility by pipeline, or trucks in the case of ethanol, and stored in internal floating roof and fixed roof storage tanks. The products are loaded into trailer trucks using loading racks at the facility. Hours of operation for truck fueling are 24 hours per day, 7 days per week. The terminal is manned Monday - Friday during the day. III. INSPECTION ACTIVITIES Activity Yes No NA Opening Meeting 1. Date and time entered the facility. Y 2. Credentials presented to facility Y personnel (include name and title). 3. Conducted an opening meeting to Y explain the purpose and objectives of the inspection. 4. Discussed safety issues. Y 5. Discussed which records to be Y reviewed. 6. Discussed the facility walk-through Y and the areas to be observed in the facility. Project Name: Shell Oil Products US ICIS/Project No.: TNNDC0004703700065-2022 Page 3 of 10 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Comment The EPA Region 4 (R4) inspectors conducted the inspection on July 12, 2022 and entered the facility at 8:00 am. Upon arrival on site, R4 inspectors presented credentials to Kevin Clark, the Terminal Operations Supervisor during the opening meeting. An opening meeting was conducted, which was led by Nicole Radford (R4). The purpose of the inspection was explained. The facility was also informed that the focus of the inspection would be on compliance with the NESHAP 6B, observing gasoline storage tanks, the loading racks, the vapor control units and the process contact water (PCW) systems. Inspectors discussed facility-specific safety and emergency procedures. Records that were needed for review were discussed during the opening meeting and during the closing meeting, where the facility committed to sending the records that were not produced during the time of the inspection. During the opening conference R4 inspectors informed the facility that the main areas of review would be the gasoline 7. Discussed facility policy regarding photographs or video (if applicable). 8. Discussed the use of the infrared camera, TVA, PID, and any other equipment. 9. Discussed CBI. Records Reviewed at the Facility 10. The types of records reviewed and the time period reviewed. storage tanks, the loading racks, the vapor control units and the PCW systems. Y Region 4 inspectors indicated a digital camera would be used during the inspection. The team discussed facility policy regarding photography and videography. Inspectors indicated that copies of any videos or photographs taken at the facility would be sent to the company. A log of photographs taken at the facility is included in this report. See Appendix A. Y R4 inspectors indicated that the infrared camera, TVA and 4-gas monitors were going to be used during the walk-through of the facility. Y EPA inspectors indicated that any documents claimed to be Confidential Business Information (CBI) would be treated in accordance with regulations. Y At the time of the inspection, the R4 inspectors received the following records: a) the site plans for each of the main areas of the facility; b) a tank inventory; c) Semi-annual monthly leak detection and repair report; d) Monthly thru the hatch inspection for internal floating roof (IFR) tanks; e) monthly tank throughputs; f) VCU and VRU preventative maintenance checklist; g) Testing and Continuous Emissions Monitoring (CEMS) records for the VRU; h) Initial Notification; i) Semi-annuals Report; and j) American Petroleum Institute (API) test summaries. Facility Walk-Through Observations 11. The process equipment observed Y and the associated operational rate Project Name: Shell Oil Products US ICIS/Project No.: TNNDC0004703700065-2022 Page 4 of 10 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 On July 12, 2022, at 10:49 am, the R4 inspectors began the facility walkthrough. observed (e.g., Furnace 1 production rate was 5 lbs/hr on 1/1/15, at 2:00 pm - permit requires max rate at 6 lbs/hr). Provide the date and time the information was recorded by the inspector. The inspectors observed the three-bay loading rack, the VRU, 5 IFR gasoline storage tanks (21061 (61), 23274 (74), 31567 (67),31565 (65) and 31566 (66)) and PCW tank. For the VRU observations, no emissions were detected. Identify the permit limit (if applicable). No emissions were noted for the pressure relief valve (PRV) with the infrared camera. An attachment may be used for a large amount of information. For loading rack observations, a leak (4% on TVA) was detected at the truck connection to the vapor return line on bay 3. For the tank observations, the TVA was used to measure the concentration of emissions from the hatch and gauge pole of Tank 65 (300 ppm on TVA). Additional emissions were detected at Tank 66's eyebrow vents, with the gauge pole reading 1600 ppm on the TVA. Emissions were also detected at eyebrow vents for Tank 61 and 67. The emissions were recorded in videos (See Attachment A for additional details). No emissions were noted for the PRV with the infrared camera. 12. The type of process parametric monitoring observed and the associated value observed (e.g., Furnace 1 flux injection rate was 200 lbs/batch at 1/1/15, at 2:00 pm - permit requires max rate at 225 lbs/batch). PCW Tank/Storage was observed. No detectable emissions were seen through the infrared camera. N/A Provide the date and time the information was recorded by the inspector. Project Name: Shell Oil Products US ICIS/Project No.: TNNDC0004703700065-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 5 of 10 Identify the permit limit (if applicable). An attachment may be used for a large amount of information. 13. If process equipment or parametric N/A monitoring equipment was not operating, state the reason by facility personnel why the equipment was not operating. 14. The type of air pollution control Y The loading rack PRV had a setpoint of 18 equipment, the process equipment it inches of water. is controlling, and the associated parametric monitoring value A VRU is used to control VOC emissions observed (e.g., baghouse pressure from the loading racks. A VCU is also drop, temperature, scrubber flow present in case the VRU is offline. rate, etc.). The VRU contains two carbon beds that (For example - RTO 1 controlling switches once one bed becomes saturated. furnace 1, 1,500 degrees F on 1/1/15, at 2:00 pm - permit requires 1,400 degree F or higher). Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. 15. Continuous emissions monitoring devices and values observed. (e.g., CEMS, COMs, etc.). Y The CEMS for the VRU was observed at 0.10% when V-2 (second carbon bed) was in operation and 0.20% when switching to V-1 (first carbon bed) Project Name: Shell Oil Products US ICIS/Project No.: TNNDC0004703700065-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 6 of 10 Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. 16. If air pollution control equipment N/A was not operating, state the reason by facility personnel why the equipment was not operating. 17. Capture and collection system N/A (enclosures and hoods) observations, if applicable (e.g., the magnitude and duration of emission escaping capture from the hood). 18. Ductwork transferring the emissions N/A to the air pollution control device observations, if applicable (e.g., the magnitude and duration of emission escaping from the ductwork, holes or deterioration in ductwork, no deterioration observed, etc.). 19. Any existing unpermitted emission N/A points, new unpermitted emission points, or non-permitted construction activities observed. (if yes, describe in the comments field). 20. Were any visible emissions N/A observed? (if yes, identify the location and equipment). Project Name: Shell Oil Products US ICIS/Project No.: TNNDC0004703700065-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 7 of 10 21. Was a Method 9 reading N/A performed? (if yes, identify the location and equipment). 22. Was the cause of the visible N/A emissions investigated and the information documented? 23. Was a Method 22 performed for N/A visible emissions? (if yes, identify the location and equipment). 24. Identify the cause of the visible N/A emissions as explained by facility personnel, if applicable. 25. Was the infrared camera used? If so, Y See Attachment A for the video log. attach the video log (which includes the equipment ID, and the date and time the video was recorded) and videos to this report. 26. Was the TVA used? If so, identify Y the equipment monitored and the results. Provide the date and time the information was recorded by the inspector. Include actual instrument readings for each piece of equipment monitored above the leak definition and/or where the infrared camera identified a release. An attachment may be used for a large amount of information. Project Name: Shell Oil Products US ICIS/Project No.: TNNDC0004703700065-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 8 of 10 A TVA was used to monitor the loading racks and tank hatches and gauge poles. For loading rack observations, a leak (4% on TVA) was detected at the truck connection to the vapor return line on bay 3. For tanks, TVA readings of around 300ppm were observed on the hatch and gauge pole of Tank 65 and around 350ppm on the Jvent of Tank 65. A TVA reading of around 1600ppm was observed on Tank 66's gauge pole. All hatches and gauge poles are in the Normally Closed position and ppm measurement(s) were taken after gauge hatch/gauge pole(s) were opened. 27. Was the PID used? If so, identify N how the PID was used and the results. Provide the date and time the information was recorded by the inspector. An attachment may be used for a large amount of information. Closing Meeting 28. Conducted a closing meeting. Y A close out meeting was conducted at approximately 12:25 pm CST. The inspection team discussed findings with terminal staff. 29. Summarize any additional Y The pre-fill roof inspection report for tank information needed, if applicable? 61 was sent to R4 inspectors after the inspection via email. 30. Accept a declaration of CBI, if N Facility personnel did not declare or claim applicable? any documents as CBI. 31. Discussed observations. Y The R4 inspectors discussed what was seen and observed during the inspection at the closing meeting. It was noted that a copy of the infrared camera videos would be sent to the facility for their review. 32. Discussed next steps, if applicable? Y The R4 inspectors stated that both the infrared camera videos and inspection report will be sent to the company for the facility's review for CBI. Following this step, R4 would proceed to finalize and issue a final report. 33. Date and time inspection concluded. The inspection concluded on July 12, 2022, at 12:57 pm. Miscellaneous 34. Include any additional observations, if applicable. Project Name: Shell Oil Products US ICIS/Project No.: TNNDC0004703700065-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 9 of 10 EPA Investigator/Inspector Signature: EPA Supervisor Signature & Title Date Report Finalized: BAICHEN ZHONG Date: 2022.09.01 16:54:42 -04'00' Digitally signed by BAICHEN ZHONG ___________________________________________ JASON Digitally signed by JASON DRESSLER Date: 2022.09.02 08:10:56 __D__R__E_S__S_L__E_R__________-0_4_'0_0_' ________________ Jason Dressler, Chief, North Air Enforcement Section September 2, 2022____________________________ Project Name: Shell Oil Products US ICIS/Project No.: TNNDC0004703700065-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 10 of 10 Attachment A - List of Videos During the July 12, 2022, inspection, EPA Region 4 staff used an infrared camera to record equipment at the Shell Oil Products US facility located in Nashville, Tennessee. Below is a list and description of the footage. Table 1: Videos taken during the July 12, 2022, inspection Image Number File Name Date and Time 1 MOV_0437.mp4 7/12/2022 11:14 AM 2 MOV_0438.mp4 7/12/2022 11:30 AM 3 MOV_0439.mp4 7/12/2022 11:30 AM 4 MOV_0440.mp4 7/12/2022 11:36 AM 5 MOV_0441.mp4 7/12/2022 11:47 AM 6 MOV_0442.mp4 7/12/2022 11:53 AM 7 MOV_0443.mp4 7/12/2022 11:56 AM Description of Image Loading Rack Bay 3 vapor return line Northwest eyebrow vent of Tank 66 (high sensitivity) Additional video of northwest eyebrow vent of Tank 66 (normal view) Southeast eyebrow vent of Tank 67 Northwest eyebrow vent of Tank 66 (normal view from bottom of tank) Northwest eyebrow vent of Tank 61 Southeast eyebrow vent of Tank 61