Document byY5rmeyYDQd67103mr5n7jVk

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 November 10, 2021 CLEAN AIR ACT INSPECTION REPORT Citgo Petroleum Corporation (Citgo), Lemont, Illinois Constantinos Loukeris, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Chief AECAB (MI/WI) File BASIC INFORMATION Facility Name: Citgo Petroleum Corporation (Citgo) Facility Location: 135th Street & New Avenue, Lemont, Illinois, 60439 Date of Inspection: September 13-15, 2021 EPA Inspectors: 1. Constantinos Loukeris, Environmental Engineer 2. Veronica Fischer, Environmental Engineer 3. Daniel Heins, Environmental Scientist Other Attendees 1. Jim Lant, Environmental Manager 2. Matt Klickman, Senior Air Environmental Staff 3. Mike Mee, HSE Manager 4. Drew Bollinger, BWON Coordinator Contact Email Address: jlant@citgo.com Purpose of Inspection: to assess compliance with requirements of NESHAP Subpart FF, NSPS QQQ and Citgo's Consent Decree Facility Type: refinery Page 1 of 10 Regulations Central to Inspection: National Emission Standards for Hazardous Air Pollutants for Benzene Waste Operations (BWON), at 40 C.F.R. Part 61, Subpart FF, New Source Performance Standards for VOC Emissions from Petroleum Refinery Wastewater Systems (QQQ), at 40 C.F.R. Part 60, Subpart QQQ, and Citgo's Consent Decree Arrival Time: September 13, 2021 - 9:40 am Departure Time: September 15, 2021 - 4:55 pm Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Credentials Presented CBI warning to facility provided The following information was obtained verbally from Citgo representatives unless otherwise noted. Process Description: Citgo provided EPA a brief overview of how the benzene wastewater is controlled from the various parts of the refinery. In addition, Citgo provided information as to how QQQ is applicable to the individual drain systems at the refinery. A simplified process water diagram was used to explain how the plant is broken up, and also to provide details of the BWON controlled sewer section of the plant. Citgo operates a North and South Plant. In the North Plant, Citgo indicated there is no QQQ-applicable equipment due to the age of the existing individual drain systems and that no modifications, reconstruction, or construction has occurred to otherwise make them subject. In the South Plant, all the wastewater is hard piped to the South Plant effluent sump (SP PSO), which is the start of the wastewater treatment under BWON. In addition, Citgo operates a two-stage desalter system that includes a hydroclone and a flasher prior to being routed to the SP PSO effluent sump. The desalter is the primary benzene wastewater stream that is being controlled. Citgo also operates a sour water stripper to manage the sour water that is generated in the system. The BWON controlled system consists of four floating roof tanks used for separation, an induced gas flotation (IGF) tank, two slop oil tanks, and three aeration tanks. Citgo considers the effluent stream of the aeration tanks as controlled to the levels required by BWON (i.e. <10 parts per million by weight benzene), and thus Citgo considers subsequent equipment not part of the BWON controlled system. Subsequent equipment includes two clarifiers and a treated water basin. Slop oil from the four floating roof tanks and the IGF tank used for separation are routed to either slop oil Tank 433 or slop oil Tank 434. Tank 434 was demolished and actively being rebuilt at the time of EPA's inspection. Page 2 of 10 Citgo conducts monthly visual inspections for equipment subject to QQQ and quarterly EPA Reference Method 21 for equipment subject to BWON and QQQ drains. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: EPA conducted leak detection and repair monitoring using a Toxic Vapor Analyzer Model 2020 (TVA 2020) flame ionization detector on Citgo's BWON sewer system components that are required to be designed to operate with no detectable emissions (NDE), which is indicated by an instrument reading of less than 500 ppm. In addition, EPA visually inspected drain hubs and other QQQ affected equipment. EPA also used the TVA 2020 for the QQQ affected equipment when accessible. Photos and/or Videos: were taken during the inspection. Field Measurements: were taken during this inspection. The table below summarizes EPA's TVA 2020 monitoring results: Component ID 119HQ115 By D401 in SRU 102WWML-26 102WWML-23 103WWML-19 WW590-8 WW 113-3 119HQ31 119WWML-8 102WWML-22 112WWML-3 Equipment Type Drain Stormwater Drain (Grate) Manhole Manhole Manhole Cover Manhole Cleanout Manhole Manhole Manhole EPA's Reading (ppm) 825 64 25,000 >10,000 21,000 1,640 1,340 1,200 80,000 20,000 900 Citgo's Reading (ppm) 660 - 545 14,000 22,000 924 779 2,160 15,859 31,000 1,221 Additional Notes Sight Glass Blowdown to Drain Not QQQ, sludge liquid on top of drain - 2 bolts missing on manhole cover Cracked cover with missing metal seal. Emissions from all around the manhole Open hole on manhole cover Caulk on sample port in middle of manhole cover cracked and dry Page 3 of 10 111WWML-13 Manhole 119WWML-11 Manhole North of 119G-2B South of D3 in 119 Process Unit Tag# 844-SPSO LL 00049 844G-444B 844SPSO LL00018 Tag# 401247 Tag#401249 Tag#401243 Stormwater Drain (Grate) Stormwater Drain (Grate) PSO Sump Cover Drain Hatch/Cover PSO Sump Cover PSO Sump Cover PSO Sump Cover 1,180 3,900 21.7 38 - 8,300 16,107 Confirmed 28 12,240 3,000 30,000 12,079 14,000 9,600 Multiple cracks in concrete around the manhole Manhole cover has opening with no bolt/patch Not QQQ - - - - - - The table below summarizes the number of visual inspections completed by EPA by process unit: Process Unit/Equipment Type Crude Unit Drains Manholes Cleanouts Sulfur Recovery Unit Drains Manholes Cleanouts Gasoline Hydrotreater Drains Manholes Cleanouts Ultra-low Sulfur Diesel Drains Manholes Cleanouts Naphtha Hydrotreater Drains Manholes Number Visually Inspected 33 8 1 128 1 8 42 11 10 56 9 8 10 4 Page 4 of 10 Cleanouts 0 Coker Unit Drains 10 Manholes 4 Cleanouts 5 FCCU Drains 27 Manholes 3 Cleanouts 10 Purge Treatment Unit Drains 12 Manholes 0 Cleanouts 5 The table below summarizes the visual inspection observations identified by EPA: Component ID W111-3 111HQ25 111HQ57 111HQ51 111HQ32 Process Unit Crude Unit Crude Unit Crude Unit Crude Unit Crude Unit 111HQ28 WWML-13 Crude Unit Crude Unit 119ML-11 Sulfur Recovery Unit 119HQ8 119HQ5 119HQ15 119HQ16 119HQ18 119HQ11 119HQ20 Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit 119HQ22 Sulfur Recovery Unit Equipment Type Manhole Drain Drain Drain Drain Drain Manhole Manhole Drain Drain Drain Drain Drain Drain Drain Drain Observation Debris and hose on top of manhole Dry, no water seal Dry, no water seal Water seal appeared oily Drain appears wet on the sides, but no water seal Level is quite high and appeared oily Multiple cracks in concrete next to manhole cover Opening on the cover, and also minimal debris on top Dry, no water seal Dry, no water seal Dry, no water seal Dry, no water seal, sulfur odor present Dry, no water seal Dry, no water seal Drain appears wet on the sides, but no water seal Dry, no water seal Page 5 of 10 119HQ32 119HQ36 119HQ40 119HQ47 119HQ45 Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit 119HQ46 119HQ51 119HQ59 119HQ60 119HQ61 119HQ63 119HQ64 119HQ70 119HQ72 119HQ73 119HQ116 119HQ121 Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit 119HQ120 Sulfur Recovery Unit 119HQ135 119HQ130 Sulfur Recovery Unit Sulfur Recovery Unit 119HQ148 119HQ147 Near 119F36 Sulfur Recovery Unit Sulfur Recovery Unit Sulfur Recovery Unit 102HQ39 Gasoline Hydrotreater 102HQ42 Gasoline Hydrotreater 102HQ40 102HQ43 102HQ41 Gasoline Hydrotreater Gasoline Hydrotreater Gasoline Hydrotreater Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Page 6 of 10 Dry, no water seal Dry, no water seal Dry, no water seal Dry, no water seal Dry, no water seal, debris was present in the drain hub Dry, no water seal Dry, no water seal Water seal appeared oily Water seal appeared oily Water seal appeared oily Dry, no water seal Dry, no water seal Dry, no water seal Dry, no water seal Dry, no water seal Water seal appeared oily Dry, no water seal, debris was present in the drain hub Dry, no water seal, debris was present in the drain hub Dry, no water seal Dry, no water seal, debris was present in the drain hub Dry, no water seal Dry, no water seal Dry, no water seal, insulation was present in the drain hub Dry, no water seal, debris was present in the drain hub Dry, no water seal, debris was present in the drain hub Dry, no water seal, water bottle in drain Dry, no water seal Debris on the upper level of the drain, with a water seal below 102HQ22 102HQ25 102HQ5 Gasoline Hydrotreater Gasoline Hydrotreater Gasoline Hydrotreater 102WWML22 102WWML20 102HQ3 Gasoline Hydrotreater Gasoline Hydrotreater Gasoline Hydrotreater 102HQ1 Gasoline Hydrotreater 102ML23 Gasoline Hydrotreater Drain Drain Drain Manhole Manhole Drain Drain Manhole 103ML19 590HQ33 Naphtha Hydrotreater Ultra-Low Sulfur Diesel Manhole Drain 590HQ56 590HQ52 590HQ41 590HQ37 Ultra-Low Sulfur Diesel Ultra-Low Sulfur Diesel Ultra-Low Sulfur Diesel Ultra-Low Sulfur Diesel Drain Drain Drain Drain 590HQ35 Ultra-Low Sulfur Diesel Drain 590HQ45 Ultra-Low Sulfur Diesel Drain 590HQ05 590HQ06 590HQ44 590HQ08 590HQ09 590HQ32 Ultra-Low Sulfur Diesel Ultra-Low Sulfur Diesel Ultra-Low Sulfur Diesel Ultra-Low Sulfur Diesel Ultra-Low Sulfur Diesel Ultra-Low Sulfur Diesel Drain Drain Drain Drain Drain Drain Page 7 of 10 Dry, no water seal, water bottle in drain Dry, no water seal, tube in drain Dry, no water seal, debris was plugging the drain hub Manhole had an open hole in it Manhole had a cracked concrete seam Dry, no water seal, debris was plugging the drain hub Dry, no water seal, debris was present in the drain hub Manhole was half covered in dirt and rocks; seal visibly broken on cover Manhole almost entirely covered under dirt Dry, no water seal, debris was present in the drain hub Dry, no water seal Dry, no water seal, cobwebs were present Dry, no water seal, cobwebs were present Dry, no water seal, debris was present in the drain hub Dry, no water seal, debris was present in the drain hub Dry, no water seal, debris was plugging in the drain hub Dry, no water seal Dry, no water seal Dry, no water seal Dry, no water seal Dry, no water seal Dry, no water seal 590HQ23 590HQ60 Ultra-Low Sulfur Diesel Ultra-Low Sulfur Diesel 590HQ61 Ultra-Low Sulfur Diesel 590HQ17 Ultra-Low Sulfur Diesel 590HQ53 Ultra-Low Sulfur Diesel 590HQ22 590HQ55 590HQ39 Ultra-Low Sulfur Diesel Ultra-Low Sulfur Diesel Ultra-Low Sulfur Diesel 590HQ49 590HQ58 Ultra-Low Sulfur Diesel Ultra-Low Sulfur Diesel 590HQ48 590HQ11 Ultra-Low Sulfur Diesel Ultra-Low Sulfur Diesel 590HQ47 Ultra-Low Sulfur Diesel 590HQ02 Ultra-Low Sulfur Diesel Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain Drain 590HQ62 Ultra-Low Sulfur Diesel Drain 103HQ12 103HQ04 103HQ11 103HQ10 Naphtha Hydrotreater Naphtha Hydrotreater Naphtha Hydrotreater Naphtha Hydrotreater Drain Drain Drain Drain 103HQ07 103HQ03 Naphtha Hydrotreater Naphtha Hydrotreater Drain Drain Page 8 of 10 Dry, no water seal Dry, no water seal, debris was present in the drain hub Dry, no water seal, debris was present in the drain hub Dry, no water seal, debris was present in the drain hub Dry, no water seal, debris was present in the drain hub Dry, no water seal Dry, no water seal Dry, no water seal, debris was present in the drain hub Dry, no water seal Dry, no water seal, debris was present in the drain hub Dry, no water seal Water seal present; however, spray paint can in drain Dry, no water seal, debris was present in the drain hub Dry, no water seal, and buried under almost 1 foot of dirt. Citgo indicated was cleaned out a few years ago. Dry, no water seal, debris was present in the drain hub High level present in drain Dry, no water seal Dry, no water seal Dry, no water seal, debris was present in the drain hub Dry, no water seal Dry, no water seal 103HQ02 113HQ22 113HQ25 113CQ29 WW113-1 Naphtha Hydrotreater Coker Unit Coker Unit Coker Unit Coker Unit HQ01 Purge Treatment Unit 113HQ61 Coker Unit 113HQ26 Coker Unit 113 CQ31 Coker Unit 112HQ15 FCCU Drain Drain Drain Cleanout Manhole Drain Drain Drain Drain Drain Dry, no water seal Dry, no water seal Dry, no water seal Located under a trailer Center hold of manhole cover with pipe running through it to backflush/segregate sewer. Dry, no water seal, filled with dirt to the top of hub Dry, no water seal, debris was present in the drain hub Dry, no water seal, debris was present in the drain hub Cleanout drain dry with debris present and not sealed. Dry, no water seal CLOSING CONFERENCE Requested documents: EPA requested the following documents: Quarterly BWON reports for 2019 and 2020; Total Annual Benzene Report for 2019 and 2020; End-of-Line Sampling Reports from 1st quarter 2020 through 1st quarter 2021; Semi-annual QQQ reports for 2019 and 2020; Procedure for Preparing H2S-containign pumps for Maintenance; Leak Detection and Repair Database for BWON and QQQ; PSO Design Documentation; Internal and External Inspection Reports for Tanks 433, 439, 485. 486, and 487; Tank Information on September 15, 2021: approximate level, roof seal type, and average temperature (Tanks 433, 439, 485, 486, and 487); 22 pictures provided by Citgo indicating various repairs from the visual observations and 21 monitoring. Method Citgo provided responses to the requested documents via a Microsoft Onedrive link provided by EPA to Citgo. Concerns: 1. EPA identified concerns that numerous QQQ drains were found without a water seal and in several instances, with debris present/plugging the drain hub. Page 9 of 10 2. EPA identified concerns that the visual inspections for QQQ are not being completed properly or at all, since the presence of some of the debris indicated a significant pileup. 3. EPA observed the Alky flare smoking the entire time EPA was on top of Tank 433. 4. EPA identified the concern that BWON and QQQ manhole covers are not being sealed properly and also found manhole covers covered in dirt in a few instances with broken seals. 5. EPA identified the concern that Citgo did not identify any modifications, reconstruction or construction to the North Plant that would have triggered QQQ. 6. EPA identified the concern of significant peeling and pitting of caulk on the SP PSO sump with detectable emissions above 500 ppm. 7. EPA identified detectable emissions above 500 ppm at drain hubs, plates, and hatches on the South Plant PSO system leading to the induced gas flotation system. 8. EPA identified the concern that the controlled sewer at certain points may not be designed to operate below NDE as required by the BWON. 9. EPA observed that gauge hatches and sample valves on top of the Tanks 433, 439, 485, 486, and 487 were not part of the BWON leak detection and repair program. SIGNATURES CONSTANTIN Digitally signed by CONSTANTINOS LOUKERIS Report Author: _____O_S__L_O_U__K_E_R_I_S_D-_0a6_t'e0:0_2' 0_21_.1_1.1_0 1_1:_42_:16______ SARAH Digitally signed by SARAH MARSHALL Section Chief: _____M__A_R__S_H__A_L_L___D11_a:t5_e8:_:2502_2-1_0.61_'10.0_1'0_________ Page 10 of 10 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Constantinos Loukeris 3. Company/Facility Name: Citgo Petroleum Corporation (Citgo) 5. Number of Images: 33 Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 File Name MOV_0079.mp4 MOV_0080.mp4 MOV_0082.mp4 MOV_0083.mp4 MOV_0084.mp4 MOV_0085.mp4 MOV_0087.mp4 MOV_0088.mp4 MOV_0089.mp4 MOV_0096.mp4 MOV_0097.mp4 MOV_0106.mp4 MOV_0107.mp4 2. Date(s) of Inspection: September 13-15, 2021 4. Street Address, City, State: Lemont, IL 6. Archival Record Location: OneDrive: EPAWork\Citgo\Inspection\Citgo Lemont September 2021 BWON Inspection\FLIR Images and Video Date 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 Description of Image VOC emissions imaged from the manway skimmer line on top of Tank 486 VOC emissions imaged center vent on top of Tank 439 VOC emissions imaged from PSO sump effluent hatch VOC emissions imaged from PSO sump effluent hatch located west of previous one listed. VOC emissions from Drain: 844G-444B VOC emissions from PSO sump effluent hatch VOC emissions imaged from the plate top of the PSO sump, Tag# 401247 VOC emissions imaged from the plate top of the PSO sump, Tag# 401249 VOC imaged from flange on east end of the PSO sump VOC emissions imaged from Tag# 844-SPSO LL 00049 Digital video of hatches by the PSO sump VOC emissions imaged from the external floating roof of Tank 433 VOC emissions imaged from the external floating roof of Tank 433 Appendices Page 1 of 2 MOV_0108.mp4 14 MOV_0109.mp4 15 MOV_0111.mp4 16 17 DC90.jpg 18 DC91.jpg 19 DC92.jpg 20 DC93.jpg 21 DC94.jpg 22 DC95.jpg DC98.jpg 23 DC99.jpg 24 DC100.jpg 25 DC101.jpg 26 DC102.jpg 27 DC103.jpg 28 DC104.jpg 29 DC105.jpg 30 DC106.jpg 31 DC107.jpg 32 DC108.jpg 33 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 9/15/2021 VOC emissions imaged from the external floating roof legs of Tank 433 VOC emissions imaged from the gauge hatch on top of Tank 433 VOC emissions imaged from the external floating roof legs of Tank 433 Digital picture tank at PSO sump Digital picture tank at PSO sump Digital picture tank at PSO sump Digital picture tank at PSO sump Digital picture tank at PSO sump Digital picture tank at PSO sump Digital picture tank of the rest of the PSO system Digital picture tank of the rest of the PSO system Digital picture tank of the rest of the PSO system Digital picture tank of the rest of the PSO system Digital picture tank of the rest of the PSO system Digital picture tank of the rest of the PSO system Digital picture tank of the rest of the PSO system Digital picture tank of the rest of the PSO system Digital picture tank of the rest of the PSO system Digital picture tank of the rest of the PSO system Digital picture tank of the rest of the PSO system Appendices Page 2 of 2