Document VJbej6m8JKzMznjJ0Y8NL1xNp
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6
1201 ELM STREET, SUITE 500 DALLAS, TEXAS 75270-2102
September 18, 2020
VIA EMAIL: csanfilippo@txpetinv.com
Mr. Chris Sanfilippo Texas Petroleum Investment Company - West White Lake 540-B Facility 101 La Rue France Ste. 406 Lafayette, Louisiana 70508
RE: Emission Inventory Permit Consistency Review Texas Petroleum Investment Company - West White Lake 540-B Facility (AI# 33252)
Dear Mr. Sanfilippo:
The U.S. Environmental Protection Agency (EPA) Region 6 is working with the Louisiana Department of Environmental Quality (LDEQ) and has reviewed your facility's emission inventory for criteria pollutant and hazardous air pollutant (HAP) emission totals, as reported to LDEQ. Based upon this review, EPA has determined that your reported emissions for some Emission Points exceeded your permit authorization limits. EPA had also reviewed your Title V reports for 2018 and did not find that these permit exceedances were reported.
A detail by Emission Point of the differences between the reported emissions and permitted limits is included in the attachment to this letter. EPA is providing you the opportunity to clarify or explain these differences, especially if any of the following conditions are present:
Sources and associated emissions included in the emission inventories that are not represented in permits (e.g. de minimis sources);
Criteria pollutants or individual HAPs reported in the facility's emission inventories that are not represented in LDEQ permits or authorizations;
Reported or unreported upset or other excess emission events (e.g. startup/shutdown).
If Texas Petroleum Investment Company is interested in discussing or providing information about this matter, you have ten (10) working days from receipt of this letter to inform EPA by e-mail by contacting:
Jack Telleck Enforcement Officer (ECDAT) Air Toxics Enforcement Section email: telleck.jack@epa.gov
Subsequent to the above-referenced due date, Jack Telleck will arrange to meet with Texas Petroleum Investment Company via conference call. At that time, Texas Petroleum Investment Company may provide additional information to address the potential violations and present evidence that contravenes EPA's evidence. The primary goal is to ensure compliance with the applicable environmental laws and regulations; however, settlements will be available where appropriate.
The EPA acknowledges that the COVID-19 pandemic may impact your business. If that is the case, please contact us regarding any specific issues you need to discuss.
Please direct questions to Jack Telleck of the Air Enforcement Branch at 214-665-9732 or at telleck.jack@epa.gov. Thank you for your attention to this matter.
Sincerely,
STEVEN THOMPSON
Digitally signed by STEVEN THOMPSON DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=STEVEN THOMPSON, 0.9.2342.19200300.100.1.1=68001003652657 Date: 2020.09.18 13:30:30 -05'00'
Steve Thompson Chief Air Enforcement Branch
Attachment
ECC: Celena Cage, Louisiana Department of Environmental Quality, celena.cage@la.gov
Attachment A Texas Petroleum Investment Company - West White Lake 540-B Facility
AI #
Facility Name
Permit
Subject Item
Subject Item Type Subject Item Desc
33252
West White Lake 540-B Facility
2940-00100-V4
EQT00000000008 Internal combustion engine
Waukesha F1197G; Backup SWD Pump
33252
West White Lake 540-B Facility
2940-00100-V4
EQT00000000008 Internal combustion engine
Waukesha F1197G; Backup SWD Pump
Emission Type Parameter Desc
Routine
Carbon monoxide
Routine
Nitrogen oxides
Permitted Limit (tpy)
10.53
6.26
ERIC Reported Emissions
(tpy)
Reported Emissions Over Permited Limit
(tpy)
15.48
4.95
15.48
9.22