Document b5XXbwM6GnLe4nmRj6G1gJyjo

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III Four Penn Center - 1600 John F Kennedy Blvd Philadelphia, Pennsylvania 19103-2852 Report Title: Geospatial Measurement of Air Pollution of Monroe Energy LLC Inspection Date(s): March 29, 2023 Regulatory Program(s): Title V, NSPS, NESHAP, MACT Company Name: Monroe Energy LLC - Trainer Refinery Facility Name: Monroe Energy LLC - Trainer Refinery Facility Location: 4101 Post Rd Trainer, PA 19061 Latitude: 39.826431 Longitude: - 75.405123 County/Parish: Delaware County AFS/Air-ICIS Number: PA000293037 Permit Number: 23-00003 NAICS Code: 324110 SIC: 2911 Unique Project #: 3E23CA091A Facility Representatives: Point of Contact Matt Torell, Environmental Leader Phone: 610-364-8399 Contact: matt.torell@monroe-energy.com Liz Clapp, Environmental Manager Phone: 610-364-8399 Contact: liz.clapp@monroe-energy.com Greg Merrill, Environmental Compliance Program Lead Phone: 610-364-8101 Contact: greg.merrill@monroe-energy.com EPA Inspectors: Parmatma Adhikari, Air Inspector, 3ED21 Phone: 215-814-2161 Contact: adhikari.parmatma@epa.gov Scott Yanos, Air Inspector, 3ED21 Phone: 215-814-2128 Contact: Yanos.scott@epa.gov Nicholas Bobbs, AED Phone: 202-564-0726 Contact: bobbs.nicholas@epa.gov Philip Myers, NEIC Phone: 303-462-9301 Contact: Myers.philip@epa.gov State/Local Inspectors: Heather Henry, Air Quality Specialist, PADEP Phone: 484-877-6092 Contact: hehenry@pa.gov Parmatma Digitally signed by Parmatma Adhikari EPA Lead Inspector Adhikari Date: 2023.05.17 06:19:24 -04'00' Signature Parmatma Adhikari Date Four Penn Center - 1600 John F Kennedy Blvd (3ED21) Philadelphia, PA 19103-2852 Supervisor Signature KRISTEN HALL Kristen Hall Digitally signed by KRISTEN HALL Date: 2023.05.17 08:40:48 -04'00' Date Section Table of Contents I Introduction............................................................................ A Summary of the Facility.................................................................................. B Inspection Opening Conference...................................................................... II Site Activity/Process Information.................................................................... III Observations.................................................................................................... IV Closing Conference......................................................................................... Page 3 3 4 4 4 5 Unique Project #: 3E23CA091A Page 2 of 5 I. Introduction The United States Environmental Protection Agency (EPA) conducted mobile monitoring using Geospatial Measurement of Air Pollution (GMAP) at Monroe Energy LLC - Trainer Refinery (Monroe Energy or Facility) to determine if elevated levels of detectable compounds were present. The Pennsylvania Department of Environmental Protection (PADEP) was notified of the inspection on March 15, 2023, via email. On March 28, 2023, EPA notified the Facility of the planned inspection, via phone. A. Summary of the Facility The Facility is located at 4101 Post Rd, Trainer, PA 119061. Monroe Energy is a petroleum refinery, and its products include jet fuel, diesel, gasoline, and LPGs (propane and butane). The Facility received Title V Operating Permit (23-00003) from PADEP, issued on June 25, 2014. Monroe Energy is classified as major source for Nitrogen Oxide (NOX), Volatile Organic Compounds (VOC), and Hazardous Air Pollutants (HAPs). The Facility is subject, or is potentially subject, to the following federal regulations: 40 CFR 60 Subpart Db - Standards of Performance for Industrial- CommercialInstitutional Steam Generating Units Operating permit terms and conditions. Emission monitoring for particulate matter and nitrogen oxides. 40 CFR 60 Subpart Ja - Standards of Performance for Petroleum Refineries for Which Construction, Reconstruction, or Modification Commenced After May 14, 2007 40 CFR 60 Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines 40 CFR 60 Subpart J - Standards of Performance for Petroleum Refineries 40 CFR 60 Subpart QQQ - Standards of Performance for VOC Emissions From Petroleum Refinery Wastewater Systems 40 CFR 60 Subpart GGG - Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries 40 CFR 60 Subpart GGGa - Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries for Which Construction, Reconstruction, or Modification Commenced After November 7, 2006 Standards. 40 CFR 60 Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced after July 23, 1984 40 CFR Part 63 Subpart CC - National Emission Standards for Hazardous Air Pollutants From Petroleum Refineries 40 CFR Part 63 Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial and Institutional Boilers and Process Heaters 40 CFR Part 63 Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Unique Project #: 3E23CA091A Page 3 of 5  40 CFR Part 63 Subpart UUU - National Emission Standards for Hazardous Air Pollutants for Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming Units, and Sulfur Recovery Units 40 CFR Part 63 Subpart Y - National Emission Standards for Marine Tank Vessel Tank Loading Operations 40 CFR Part 63 Subpart G - National Emission Standards for Organic Hazardous Air Pollutants From the Synthetic Organic Chemical Manufacturing Industry for Process Vents, Storage Vessels, Transfer Operations, and Wastewater 40 CFR Part 61, Subpart FF - National Emission Standard for Benzene Waste Operations B. Inspection Opening Conference At 10:00 AM on March 29, 2023, EPA inspectors arrived at the Facility for GMAP monitoring and conducted a brief opening conference. Monroe Energy was represented by Matt Torell (Environmental Leader), Liz Clapp (Environmental Manager) and Greg Merrill (Environmental Compliance Program Lead). Heather Henry, of PADEP, was also present. EPA inspectors, Parmatma Adhikari, Scott Yanos, Nicholas Bobbs and Philip Myers presented their credentials and explained the purpose of the visit was to conduct mobile monitoring using Geospatial Measurement of Air Pollution. Matt Torell asked about the technology and principle using in the GMAP system and Nicholas Bobbs explained that the GMAP vehicle has the capability to monitor Hydrogen Sulfide (H2S), Volatile Organic Compounds (VOCs), Methane (CH4), Sulfur Dioxide (SO2) and Benzene (C6H6). II. Site Activity/Process Description Monroe Energy manufactures jet fuel, gasoline, diesel, and home heating oil. The trainer refinery has two storage areas: the north tank farm and the south tank farm. At the time of the GMAP Survey, Liz Clapp, environmental manager of the Facility, mentioned that turnaround work is starting, such as replacing Fluid Catalytic Cracking (FCC) unit, but nothing is currently offline. The opening conference concluded at 10:40 AM. III. Observations EPA inspectors were led on a drive through the Facility at 10:48 AM by Matt Torell, Liz Clapp and Greg Merrill of Monroe Energy. At 10:50 AM, EPA initiated GMAP monitoring. Heather Henry, of PADEP, and Parmatma Adhikari, Scott Yanos, Nicholas Bobbs and Philip Myers, of EPA, were present during GMAP monitoring. The EPA GMAP vehicle was lead through various interior roads of the Facility. EPA observed GMAP readings which are represented in Table 1. A designation of "elevated" means elevated concentrations of the listed pollutant were measured above background levels using GMAP. Unique Project #: 3E23CA091A Page 4 of 5 Actual numeric concentration readings observed during the monitoring event were not yet verified at the time of this report, but can be shared, with the Facility, once the data becomes verified and available. Time 11:17 am 12:18 am 12:25 pm VOC (ppb) Elevated Elevated Elevated TABLE 1 Benzene H2S (ppb) (ppb) SO2 (ppb) Approximate Location Near Tank # 335 South of the Alkylation unit South of the Alkylation unit, nearby HF acid unit. The GMAP monitoring concluded at 12:50 PM. IV. Closing Conference EPA inspectors, Heather Henry, of PADEP, and Matt Torell, Liz Clapp and Greg Merrill of Monroe Energy, had a brief closing conference to ask additional questions and discuss observations. The EPA inspectors noted that the investigation is on-going, and any areas of concern identified in the final reports do not necessarily reflect a violation or deviation, rather, they are areas that will require further investigation. EPA also noted that they would issue an inspection report within in 60 days, with a copy to the State. Simultaneously, EPA will perform a detailed review of records and may have additional questions. The inspection concluded at 1:02 PM. The following have been identified as potential issues during the inspection. These are issues that require either further investigation by EPA, or additional information or explanation by Monroe Energy. Elevated VOC emissions near Tank # 335 and South of the Alkylation Unit. Unique Project #: 3E23CA091A Page 5 of 5