Document X7MnxgonY4VZzVRqrZkw5ya9w

EPA Inspection Report - Page 1 of 8 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/08/2024 Air Title V, 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: Valero Energy Corp Valero Port Arthur Refinery 1801 South Gulfway Drive (Lat 29.868333, Long -93.968333) Port Arthur, TX 77640 1801 South Gulfway Drive Port Arthur, TX 77640 Jefferson County (409) 985-1000 Luke Holloway Environmental Manager Luke.holloway@valero.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000464006 RN102584026 / Title V - O1498; Title V - O3992 AFS 48-245-00004 324110 - Petroleum Refineries 2911- Petroleum Refining Personnel participating in inspection: Kenneth R. McPherson EPA Region 6 ECDAT Life Scientist Ben Donaldson EPA Region 6 ECDAT Environmental Engineer Dan Hoyt EPA OECA AED Environmental Engineer Nathan Hicks EPA OECA AED Physical Scientist Phil Myers, PhD EPA NEIC Mechanical Engineer Richard Helmich, PhD EPA NEIC Senior Chemist Luke Holloway Valero Port Arthur Environmental Manager Kristin Wescoat Valero Port Arthur Environmental Superintendent, Air Darrell Buckner Valero Port Arthur Environmental Superintendent, Waste Clint Mitchell Valero Port Arthur Environmental Safety Director EPA Lead Inspector Signature/Date EPA Lead Inspector Signature/Date KENNETH MCPHERSON Date: 2024.04.16 13:39:06 -05'00' Digitally signed by KENNETH MCPHERSON Date Supervisor Signature/Date Supervisor Signature/Date Kenneth R. McPherson JAMES LEATHERS Date: 2024.04.16 14:08:43 -05'00' Digitally signed by JAMES LEATHERS Date James Leathers 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 8 Section I - INTRODUCTION Valero Energy Corp / Valero Port Arthur Refinery Inspection Date 02/08/2024 PURPOSE OF THE INSPECTION EPA inspectors Kenneth McPherson (EPA Region 6, "Region 6"), Ben Donaldson (Region 6), Dan Hoyt and Nathan Hicks (EPA Office of Enforcement and Compliance Assurance, "OECA") accompanied by Philip Myers and Richard Helmich (National Enforcement Investigations Center, "NEIC") arrived at the Valero Port Arthur Refinery ("Facility") in Port Arthur, Texas at 14:12 on February 8, 2024, for an unannounced inspection. The EPA inspectors held an opening conference with Facility representatives Luke Holloway, Environmental Manager; Kristin Wescoat, Environmental Superintendent; and Darrell Buckner, Environmental Superintendent. Inspector Hoyt presented his credentials to Luke Holloway while Inspector McPherson informed him that we were conducting an EPA inspection of the Facility's marine dock area located near the West Basin of the Taylor Bayou to evaluate potential sources of excess emissions using EPA's Geospatial Measurement of Air Pollution ("GMAP") vehicle and to evaluate compliance with the Facility's Title V Air Permit and the Clean Air Act ("CAA"). Inspector McPherson informed Mr. Holloway that the unannounced inspection was the result of the GMAP detecting a benzene plume outside the Facility's fence line northwest of the Facility docks. Mr. Holloway stated that there was an automated environmental Gas Chromatograph ("eGC") near Berth 1 at the Facility dock that recorded a single 10 parts per billion ("ppb") alert for benzene (C6H6) sometime in the morning hours. The scope of the inspection was a partial compliance evaluation ("PCE"). This inspection occurred as part of a multi-scale monitoring project in the Beaumont-Port Arthur, Texas area. The sign-in sheet for the opening conference is attached as Appendix 1. FACILITY DESCRIPTION The Facility is a petroleum refinery that operates as a major source for emissions under CAA Title V Permit Number O1498 (Petroleum Refineries) issued on January 02, 2018; and CAA Title V Permit Number O3992 (DCU-844 Coker Complex) issued on August 21, 2019. Valero Energy Corp (Valero) operates a gasoline, diesel and jet fuel production complex located on a 4,000-acre site along the Port Arthur Ship Channel south of Port Arthur, Texas. Valero acquired the Facility in 2005. The Facility has a 425,000 barrels per day throughput capacity. Valero has 800 employees, including contractors, and operates the Facility 8,760 hours per year. The primary feedstock for the Facility is crude oil which it receives by rail, marine docks, and pipelines. Product is distributed to various customers by pipelines, ships, and barges. Section II - OBSERVATIONS At 14:55 on February 8, 2024, we entered the Facility through Gate 19 to conduct GMAP surveillance and to identify and observe emission sources. The NEIC GMAP vehicle was driven by Inspector Helmich, and the instruments were operated by Inspector Myers. Facility representatives Luke Holloway and Darrell Buckner were present in a lead company vehicle, guiding the GMAP vehicle. The meteorological conditions during the inspection consisted of a partly cloudy sky, winds from the south/southeast at 2 EPA Inspection Report - Page 3 of 8 Valero Energy Corp / Valero Port Arthur Refinery Inspection Date 02/08/2024 10.5 miles per hour (mph), temperature of 72o F, and a relative humidity of 77%. Inspectors Hoyt and Hicks followed the GMAP in a Data Acquisition in Real Time ("DART") mobile air monitoring system equipped vehicle. Inspector Donaldson and I followed the DART equipped vehicle in a support vehicle. The GMAP vehicle, followed by the DART equipped vehicle and support vehicle, drove on all available Facility roads near the Facility marine docks measuring air pollutant concentrations downwind of each of the process areas, if possible. A full report from the GMAP will be issued by NEIC on a later date. The GMAP survey of the Facility ended at 16:20 on February 8, 2024, and we returned to the Facility conference room. No significant levels of ambient pollution were detected. Section III - AREAS OF CONCERN Inspectors McPherson, Donaldson, Hoyt, Hicks, Helmich, and Myers conducted an inspection closing conference at the Facility conference room at 16:20 on February 8, 2024. Inspectors McPherson and Myers summarized the facility survey and presented their emissions observations, including the following Area of Concern ("AOC"). Facility representative Clint Mitchell stated the eGC next to Berth 1 at the north end of the Facility's marine dock recorded an 11.61 ppb for benzene at 08:26 on February 8, 2024. No other recordings were generated by the eGC for that date. The facility made no claims of confidential business information regarding the videos or documents provided. We departed the Facility at 16:51, February 8, 2024. AOC 1) EPA inspectors recorded volatile organic compounds (VOC), including benzene in the ambient air outside the Facility's fence line downwind of the Facility's marine docks while loading and off-loading operations were occuring at the Facility. This indicated that benzene and other VOCs were emitted from either the Facility's process units at or near the marine docks, or from marine vessels moored at the Facility's marine docks. 40 CFR 63.6(e)(1)(i) requires air pollution control equipment to be operated in a manner consistent with safety and good air pollution control practices for minimizing emissions. 30 TAC 116.115(b)(2)(G) states that permitted facilities shall not be operated unless all air pollution emission capture and abatement equipment is maintained in good working order and operating properly during normal facility operations. Section IV - FOLLOW UP No additional records or information was requested from the Facility. Section V - LIST OF APPENDICES Appendix 1 - Opening and closing conference sign-in sheets. Appendix 2 - Federal Operating Permit Number: O1498 (Signature Page). 3 EPA Inspection Report - Page 4 of 8 Valero Energy Corp / Valero Port Arthur Refinery Inspection Date 02/08/2024 Appendix - 1 OPENING AND CLOSING CONFERENCE SIGN-IN SHEETS 1 EPA Inspection Report - Page 5 of 8 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Opening and Closing Conference Sign-in Sheets Location: Valero Energy Corp / Valero Port Arthur Refinery City: Port Arthur County: Jefferson County State: Texas Appendix 1 Page 1 of 2 EPA Inspection Report - Page 6 of 8 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Opening and Closing Conference Sign-in Sheets Location: Valero Energy Corp / Valero Port Arthur Refinery City: Port Arthur County: Jefferson County State: Texas Appendix 1 Page 2 of 2 EPA Inspection Report - Page 7 of 8 Valero Energy Corp / Valero Port Arthur Refinery Inspection Date 02/08/2024 Appendix - 2 FEDERAL OPERATING PERMIT NUMBER: O1498 Date 01/02/2018 (Signature Page) EPA Inspection Report - Page 8 of 8 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Federal Operating Permit Number: O1498 Location: Valero Port Arthur Refinery / Petroleum Refineries City: Port Arthur County: Jefferson County State: Texas Appendix 2 Page 1 of 1