Document XzqEdN05Dq5p1GGqX06eyn3pw
EPA Inspection Report Page 1 of 9
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
02/06/2024 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:
Colonial Pipeline Company Port Arthur Products Station 5300 Old W. Port Arthur rd. Port Arthur, TX, 77640 5300 Old W. Port Arthur rd. Port Arthur, TX, 77640 Jefferson County 409-984-3576 Ryan Tedford RTedford@colpip.com
Environmental Specialist
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
110009773600 RN 106058878 Permit No. 94427 AFS # 48-245-00048 486910 4613
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
Paul Cox
Colonial Pipeline Company
Brian Willford
Colonial Pipeline Company
Ryan Tedford
Colonial Pipeline Company
Gary Revia
Colonial Pipeline Company
Curt Spell
Colonial Pipeline Company
Jody Lambright
Valero Energy Partners
Aaron Lyons
Valero Energy Partners
Dustin Harris
Valero Energy Partners
Brad Guidry
Valero Energy Partners
Environmental Engineer Life Scientist Environmental Engineer Environmental Engineer Physical Scientist Chemist Mechanical Engineer Senior Operator Safety Specialist Environmental Specialist Maintenance Supervisor
Operations Supervisor
Senior Area Manager Area Manager
Operations Manager
Regional HSE lead
EPA Lead Inspector Signature/Date
Benjamin Donaldson Date: 2024.04.12 07:51:10 -05'00' Digitally signed by Benjamin Donaldson
Benjamin Donaldson
Date
Supervisor Signature/Date
JAMES LEATHERS Date: 2024.04.12 13:07:06 -05'00' Digitally signed by JAMES LEATHERS
James Leathers
Date
6ENFORM-019-R8.2 (02/12/2020)
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Section I - INTRODUCTION
Colonial Pipeline Company /Port Arthur Products Station Inspection Date 02/06/2024
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 Colonial Pipeline Company ("Colonial") Port Arthur Products Station at 8:32 PM on February 6, 2024 for an unannounced inspection. We met with Paul Cox, Colonial senior operator, Brian Willford, Colonial safety specialist, Ryan Tedford, Colonial environmental specialist, Gary Revia, Colonial maintenance supervisor, Jody Lambright, Valero Energy Partners ("Valero") senior area manager, Aaron Lyons, Valero area manager, Dustin Harris, Valero operations manager, and Brad Guidry, Valero regional HSE lead. Credentials were presented to Ryan Tedford for Colonial and Jody Lambright for Valero and 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 Federal operating Air Permit and the Clean Air Act. The scope of the inspection is a partial evaluation ("PCE"). This inspection occurred as part of a multi-scale monitoring project in the Beaumont-Port Arthur area. Photographs and video taken during the inspection can be found in Appendix 1 and 2, respectively. The sign-in sheet for the opening and closing conference is attached as Appendix 3.
FACILITY DESCRIPTION
The Port Arthur Products station is a tank storage terminal operated by Colonial that operates under New Source Review Permit Number 94427 issued December 23, 2010. Valero is also co-located within the Port Arthur Products station and owns nine of the tanks.
Section II - OBSERVATIONS
The NEIC GMAP was driven by Mr. Helmich, the instruments were operated by Mr. Myers, and observed in the vehicle by Mr. Donaldson. Facility representatives Ryan Tedford, Jody Lambright, Brian Wilford and Dustin Harris escorted the GMAP. Conditions were sunny and windy with winds from the northnortheast. 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 of the GMAP measurements and observations will be issued by NEIC and shared with Colonial when the report is final.
Before making entry on a road outside of the facility, the GMAP detected elevated reading from a tank later identified as Tank 1466. Tank 1466 is an external floating roof tank owned by Colonial and contains
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Colonial Pipeline Company /Port Arthur Products Station Inspection Date 02/06/2024
gasoline. Mr. McPherson operated an Optical Gas Imaging Camera ("OGIC") and climbed to the observation platform of Tank 1466. Mr. McPherson observed emissions with the OGIC from the rim seal on the Northeast side of the tank (FLIR0007.mp4 & R0010092.jpg). [AOC1] The site GMAP survey ended at 11:15 am and we returned to the conference room. Section III - AREAS OF CONCERN Benjamin Donaldson conducted a closing conference at the Colonial Pipeline Company Port Arthur Products station at 11:15 am on February 6, 2024 for the inspection. Mr. Meyers and Mr. Donaldson summarized the facility tour and presented their emissions observations, including the following Area of Concern. The facility made no claims of confidential business information regarding the photographs or videos. The facility was informed that copies of the videos would be made available to the facility following the inspection. We departed the facility at 11:38am.
1) Emissions were observed from the rim seal of Tank 1466 with the OGIC. Section IV - FOLLOW UP No additional information was received by EPA after exiting the Facility on February 6, 2024.
Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 1 photos taken 2/06/2024 Appendix 2 - Video Log - 1 FLIR videos taken 2/06/2024 Appendix 3 - Opening and closing conference sign-in sheets
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Colonial Pipeline Company / Port Arthur Products Station Inspection Date 02/06/2024
Appendix 1 Photograph Log
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Colonial Pipeline Company Port Arthur Product Station
City: Port Arthur
County/Parish: Jefferson
State: TX
Photo File Name: R0010092.JPG Date of Photo: 02/06/2023 Time of Photo: 11:10 am Photographer: Kenneth McPherson Description: Roof of Tank 1466
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Colonial Pipeline Company / Port Arthur Products Station Inspection Date 02/06/2024
Appendix 2 Video Log
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Video Log
Appendix 2
Location: Colonial Pipeline Company / Port Arthur Products Station
City: Port Arthur
Jefferson County
State: TX
Video File Name: Date of Video: Time of Video: Videographer: Description:
FLIR0007.mp4 02/06/2024 10:50 am Kenneth McPherson Emissions observed from the seal of Tank 1466.
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Colonial Pipeline Company/ Port Arthur Products Station Inspection Date 02/06/2024
Appendix 3 Opening and Closing Conference Sign-in Sheets
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Colonial Pipeline Company/ Port Arthur Products Station Inspection Date 02/06/2024