Document Zjq2ZaZnKkgqLyQZwM6jq5k0

United States Environmental Protection Agency (EPA) Region 4 Air Enforcement Branch Inspection Report I. GENERAL INFORMATION Facility Name: Center Point Terminal Chickasaw Location (Address): 200 Viaduct Road Mobile, AL 36611 Inspection Date: April 22, 2021 Type of Inspection (Full or Partial Compliance Evaluation): Partial Compliance Evaluation ICIS-Air Number: 04000EPAALCENTERPT EPA Investigator(s)/Inspector(s): Steve Rieck, EPA Region 4 Environmental Scientist Scott Hamilton, EPA Region 5 Environmental Engineer Kate Haile, EPA Region 5 Environmental Engineer State/Local Investigator(s)/Inspector(s): Katie Smith, ADEM Environmental Scientist Person(s) Contacted at Facility (Name and Title): Report Prepared by: Steve Rieck Yojane Valera Operations Manager Project Name: Center Point Terminal Chickasaw ICIS/Project No.: 04000EPAALCENTERPT-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 1 of 9 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.). Bulk liquid storage Synthetic Minor Operating Permit Source Number #503-4007 3. Air permit issuance date. July 20, 2016 4. Air permit expiration date. No Expiration 5. Facility classification (Major, Synthetic Minor/Conditional Major, Minor). 6. Major source pollutants (if Synthetic Minor N/A 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.). NSPS Subpart K and Ka The primary focus of this inspection were asphalt storage tanks. Storage tanks were equipped with fixed and internal floating roofs. B. Process Description (provide narrative or attach description provided by the company or excerpts from the permit) Center Point Terminal Chickasaw is a bulk liquid storage and transfer terminal for asphalt and related petroleum products. The facility receives asphalt by ship for storage. The received product is tested to ensure hydrogen sulfide in material does not exceed 10 parts per million. The Project Name: Center Point Terminal Chickasaw ICIS/Project No.: 04000EPAALCENTERPT-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 2 of 9 asphalt is kept in heated tanks to maintain the liquid phase of the material. Asphalt is loaded into heated trailer trucks for transfer or sale. III. INSPECTION ACTIVITIES Activity Opening Meeting 1. Date and time entered the facility. 2. Credentials presented to facility personnel (include name and title). 3. Conducted an opening meeting to explain the purpose and objectives of the inspection. Yes Comment No NA Yes April 22, 2021, at 11:30 AM Yes All inspectors presented their credentials. Yes EPA inspectors arrived on site and discussed inspection objectives with Mr. Valera. The purpose of the inspection was to determine compliance with Clean Air Act regulations, as well as to obtain ambient emission data through use of the Geospatial Measurement of Air Pollution (GMAP) mobile monitoring unit. The GMAP is a mobile air monitoring vehicle with analyzers for methane, benzene, toluene, ethylbenzene, xylene, and other VOCs. The GMAP allows for real-time monitoring and mapping of pollutants while the vehicle transverses the facility. 4. Discussed safety issues. Yes Inspectors discussed facility-specific safety and emergency procedures. 5. Discussed which records to be Yes EPA inspectors did not review any records reviewed. on-site. 6. Discussed the facility walk-through Yes The Region 4 inspector will use an Optical and the areas to be observed in the Gas Imaging (OGI) camera to survey storage facility. tanks. The Region 5 inspectors will operate the GMAP vehicle to measure ambient levels of various pollutants. 7. Discussed facility policy regarding Yes Inspectors indicated that videos may be taken photographs or video (if with the OGI camera and that copies of the applicable). video would be sent to the company. Project Name: Center Point Terminal Chickasaw ICIS/Project No.: 04000EPAALCENTERPT-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 3 of 9 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. Yes Inspectors discussed use of the OGI camera and the GMAP vehicle. Yes Inspectors discussed that copies of videos or pictures taken with the OGI camera will be provided to the facility to determine whether they contain CBI. No Records were not reviewed at the facility. Facility Walk-Through Observations 11. The process equipment observed Yes Inspectors used the OGI camera to survey and the associated operational rate storage tank operations and truck loading observed (e.g., Furnace 1 racks. The GMAP vehicle also measured production rate was 5 lbs/hr on concentrations of pollutants in the ambient 1/1/15, at 2:00 pm - permit requires air. A summary of the OGI camera survey is max rate at 6 lbs/hr). provided below. 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. Tank 10 Tank 10 stores liquid asphalt. The tank is kept heated at 300 degrees Fahrenheit to maintain the liquid phase. Visible emissions were observed from the central tank vent. Tank 7 Tank 7 stores liquid asphalt in a heated tank. Visible emissions were observed from the central tank vent. Tank 7 will be taken out of service next year for a 10-year inspection. Truck Loading Rack Two trucks were loading liquid asphalt at the time of inspection. One truck was smoking excessively outside the truck top hatch. When asked, Mr. Valera said it was likely due to adding a comparatively cool additive to the hot liquid asphalt. Project Name: Center Point Terminal Chickasaw ICIS/Project No.: 04000EPAALCENTERPT-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 4 of 9 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). 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. The GMAP vehicle was stationary near some tanks as well as the loading rack to take ambient measurements of concentrations. N/A 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 Yes Storage tanks observed on-site are equipped equipment, the process equipment it with fixed and internal floating roofs. The is controlling, and the associated EPA inspector evaluated the condition of the parametric monitoring value tanks using the OGI camera. observed (e.g., baghouse pressure drop, temperature, scrubber flow Facility staff indicated the tanks observed rate, etc.). during the inspection undergo regular in- service inspections as well as an out-of- (For example - RTO 1 controlling service full inspection every 10 years. furnace 1, 1,500 degrees F on 1/1/15, at 2:00 pm - permit requires 1,400 degree F or higher). Project Name: Center Point Terminal Chickasaw ICIS/Project No.: 04000EPAALCENTERPT-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 5 of 9 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 No devices and values observed. (e.g., CEMS, COMs, etc.). 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 N/A emissions to the air pollution control device observations, if applicable (e.g., the magnitude and duration of emission escaping from the ductwork, holes or deterioration Project Name: Center Point Terminal Chickasaw ICIS/Project No.: 04000EPAALCENTERPT-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 6 of 9 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 No observed? (if yes, identify the location and equipment). 21. Was a Method 9 reading No 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 No visible emissions? (if yes, identify the location and equipment). 24. Identify the cause of the visible emissions as explained by facility personnel, if applicable. 25. Was the infrared camera used? If so, attach the video log (which includes the equipment ID, and the date and time the video was recorded) and videos to this report. N/A Yes A video log is provided in Attachment A. A copy of the videos has been provided to the facility Project Name: Center Point Terminal Chickasaw ICIS/Project No.: 04000EPAALCENTERPT-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 7 of 9 26. Was the TVA used? If so, identify No 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. 27. Was the PID used? If so, identify No 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. 29. Summarize any additional information needed, if applicable? 30. Accept a declaration of CBI, if applicable? 31. Discussed observations. Yes The inspection team discussed findings with terminal staff in the parking lot including videos taken and next steps. The GMAP vehicle operators discussed preliminary observations of ambient pollutant data. The GMAP operators will make the data available following quality assurance and control review. Yes Facility staff will review OGI videos taken for any potential CBI. Yes Inspectors discussed equipment observed during the inspection and summarized what was observed with the OGI camera. Project Name: Center Point Terminal Chickasaw ICIS/Project No.: 04000EPAALCENTERPT-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 8 of 9 32. Discussed next steps, if applicable? Yes Inspectors discussed providing videos to the facility and a timeline for the inspection report. 33. Date and time inspection The inspection team left the facility around concluded. 1: 30 pm. Miscellaneous 34. Include any additional observations, if applicable. EPA Investigator/Inspector Signature: EPA Supervisor Signature & Title Date Report Finalized: Digitally signed by STEPHEN STEPHEN RIECK RIECK Date: 2021.06.16 10:33:29 -04'00' ___________________________________ JASON Digitally signed by JASON DRESSLER _D__R__E_S__S_L_E__R_______-0_4_'0_0_' ____________ Date: 2021.06.16 14:26:53 Chief, North Air Enforcement Section June 16, 2021 Project Name: Center Point Terminal Chickasaw ICIS/Project No.: 04000EPAALCENTERPT-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 9 of 9