Document Od7Ypkv5OQ41NoEn1zbN26JX

EPA Inspection Report Page 1 of 7 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/07/2024 Air NESHAP Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Phillips 66 Spindletop Compressor Station 6175 Highland Ave Beaumont, Texas, 77705 6175 Highland Ave Beaumont, Texas, 77705 Jefferson County 409-332-3443 Ruben Herrera Ruben.Herrera@p66.com Environmental Specialist FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110015744523 RN100211424 - Permit no. 02507 48-245-00169 211111, 486210 1311 Personnel participating in inspection: Benjamin Donaldson Region 6 ECDAT Kenneth McPherson Region 6 ECDAT Justin Chen Region 6 ECDAT Daniel Hoyt OECA AED Nathan Hicks OECA AED Richard Helmich NEIC Philip Myers NEIC Bryan Mason Phillips 66 Justin Goss Phillips 66 Ruben Herrera (via phone) Phillips 66 Environmental Engineer Life Scientist Environmental Engineer Environmental Engineer Physical Scientist Chemist Mechanical Engineer Operator Supervisor Environmental Specialist EPA Lead Inspector Signature/Date Supervisor Signature/Date Digitally signed by Benjamin Benjamin Donaldson Donaldson Date: 2024.04.12 14:22:09 -05'00' Benjamin Donaldson Date JAMES LEATHERS Date: 2024.04.12 14:48:30 -05'00' Digitally signed by JAMES LEATHERS James Leathers Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report Page 2 of 7 Section I - INTRODUCTION Phillips 66 / Spindletop Compressor Station Inspection Date 02/07/2024 PURPOSE OF THE INSPECTION EPA inspectors Benjamin Donaldson (R6 ECDAT), Justin Chen (R6 ECDAT), Kenneth McPherson (R6 ECDAT), Daniel Hoyt (OECA AED), and Nathan Hicks (OECA AED) accompanied by Philip Myers and Richard Helmich (National Enforcement Investigations Center, "NEIC") arrived at the Phillips 66 Spindletop Compressor Station ("Spindletop") at 8:50AM on February 7, 2024, for an unannounced inspection. We met with Bryan Mason, a Phillips 66 operator, Justin Goss, a Phillips 66 site supervisor, and with a Phillips 66 environmental specialist, Ruben Herrera on the phone. Credentials were presented to Justin Goss, and we informed them that this was an EPA inspection to evaluate potential sources of excess emissions using EPA's Geospatial Measurement of Air Pollution ("GMAP") vehicle and evaluate compliance with the facility's Title V Air Permit and the Clean Air Act. The scope of the inspection is a partial compliance evaluation ("PCE"). This inspection occurred as part of a multi-scale monitoring project in the Beaumont-Port Arthur area. Video taken during the inspection can be found in Appendix 1. The sign-in sheet for the opening conference is attached as Appendix 2. FACILITY DESCRIPTION Spindletop is a natural gas compressor station that operates under Permit Number 02570 issued January 15, 2021. The gas storage facility consists of eight compressor engines that are powered by natural gas, four glycol dehydration units with reboilers, line heaters, filter separators, gas scrubbers, an emergency generator engine, and metering equipment. Section II - OBSERVATIONS The NEIC GMAP vehicle was driven by Mr. Helmich, the instruments were operated by Mr. Myers, and observed by Mr. Donaldson. Facility representatives, Bryan Mason and Justin Goss, accompanied the GMAP, and we were later met in the field by Heather Low, Phillips 66 environmental specialist. Conditions were sunny. Inspectors Justin Chen, Kenneth McPherson, Daniel Hoyt, and Nathan Hicks followed the GMAP in secondary vehicles. Daniel Hoyt and Nathan Hicks operated a Data Acquisition in Real Time ("DART") unit on their vehicle, equipped with a photoionization detector ("PID") that measures volatile organic compounds ("VOC") in the air, and a wind monitor that monitors wind speed, wind direction and geolocation. The DART unit had a 10.6ev PID installed. The GMAP drove on all available facility roads measuring air pollutant concentrations downwind of each of the process areas, if possible. A full report from the GMAP will be issued by NEIC at a later date. At 10:30AM, the GMAP detected an approximately 500 parts per million ("ppm") elevated reading of methane downwind of the inlet/outlet area of the compressor station. This spike was outside of the calibration range of >20 ppm. Elevated readings of total VOC were also measured by the DART and noted for follow up with the Optical Gas Imaging Camera ("OGIC"). 2 EPA Inspection Report Page 3 of 7 Phillips 66 / Spindletop Compressor Station Inspection Date 02/07/2024 I used the OGIC to observe emissions from the slop oil tank's pressure release valve (FLIR0016.mp4). At 11:00AM, Mr. McPherson used a PID with a Draeger tube and observed a reading of 3.965 parts per million ("ppm") of benzene. [AOC 1] We moved to the decommissioned flare where I observed emissions from the top of the flare with the OGIC (FLIR0017.mp4). Mr. Goss explained a third-party contractor recently removed some sludge from the bottom of the base of the decommissioned flare. Mr. Chen requested that a valve at the base of the flare be opened. Spindletop staff opened the valve and captured some water that had accumulated inside as a sample. We placed a PID over the water sample and measured a reading of 5.372 ppm of total VOC. [AOC2] The site GMAP survey ended at 12:00PM and we returned to the parking lot. At 12:04PM on February 7, 2024, EPA inspectors Benjamin Donaldson, Justin Chen, and Kenneth McPherson returned to the inlet/outlet area with the OGIC, but no emissions were observed. The inspection team returned to the conference room at 12:30PM. Section III - AREAS OF CONCERN Benjamin Donaldson conducted an inspection closing conference at Phillips 66 Spindletop Compressor Station at 12:27PM on February 7, 2024. Mr. Meyers and Mr. Donaldson summarized the facility tour and presented their observations, including the following Areas of Concern: 1) Inspectors observed emissions from the slop oil tank with the OGIC. A PID with a Draeger tube measured emissions of 3.965 ppm benzene, which is not typically present in slop oil. 2) Inspectors observed emissions from the decommissioned flare with the OGIC and obtained a PID reading of 5.372 ppm of total VOC from the flare's base. The facility made no claims of confidential business information regarding the videos provided. The facility was informed that copies of the videos would be made available to the facility following the inspection. We departed the facility at 12:51PM. Section IV - FOLLOW UP No additional information was received by EPA after exiting the Facility on February 7, 2024. Section V - LIST OF APPENDICES Appendix 1 - Video Log - 2 FLIR videos taken 02/07/2024 Appendix 2 - Opening and closing conference sign-in sheets 3 EPA Inspection Report Page 4 of 7 Phillips 66 / Spindletop Compressor Station Inspection Date 02/07/2024 Appendix 1 Video Log EPA Inspection Report Page 5 of 7 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 1 Location: Phillips 66 / Spindletop Compressor Station City: Beaumont Jefferson County State: Texas Video File Name: Date of Video: Time of Video: Videographer: Description: FLIR0016.mp4 02/07/2024 10:45 AM Benjamin Donaldson Emissions observed from the pressure release valve of the slop oil tank. Video File Name: Date of Video: Time of Video: Videographer: Description: FLIR0017.mp4 02/07/2024 11:30 AM Benjamin Donaldson Emissions from the decommissioned flare Page 1 of 1 EPA Inspection Report Page 6 of 7 Phillips 66 / Spindletop Compressor Station Inspection Date 02/07/2024 Appendix 2 Opening and Closing Conference Sign-In Sheets EPA Inspection Report Page 7 of 7 Phillips 66 / Spindletop Compressor Station Inspection Date 02/07/2024