Document dOjkjZxEpq5pdR3Ozxm0pBQG

May 16, 2024 James Daniel Roberts Plant Manager, High Purity Solvents Plant Trecora Hydrocarbons, LLC 7752 FM 418 Silsbee, Texas 77656-8943 Sent via email: dan.roberts@trecora.com Re: Notice of Violation and Opportunity to Confer Dear Mr. Roberts: The United States Environmental Protection Agency, Region 6 ("EPA") has identified Trecora Hydrocarbons LLC ("Trecora") as having violated the Clean Air Act ("CAA"). This Notice of Violation and Opportunity to Confer ("NOVOC") is issued to Trecora1 for violations of the CAA, 42 U.S.C. 7401 et seq., at Trecora's High Purity Solvents Plant located at 7752 FM 418, Silsbee, TX 77656 (the "Facility"). Based on information currently available, EPA finds that Trecora has committed a violation of the federally-approved Texas State Implementation Plan (SIP). By this letter, EPA is extending to you an opportunity to advise the Agency, via a conference call or in writing, of any further information EPA should consider with respect to the alleged violations. This NOVOC is issued pursuant to Section 113(a)(1) of the CAA, 42 U.S.C. 7413(a)(1). Section 113(a)(1) of the CAA, 42 U.S.C. 7413(a)(1) requires the Administrator of the EPA to notify any person in violation of a SIP or permit of the violation, and this NOVOC serves as such notice. The authority to issue this NOVOC has been delegated to the Director of the Enforcement and Compliance Assurance Division, EPA Region 6. EPA contracted helicopter flyovers in the Beaumont-Port Arthur, Texas area from November 7 through November 9, 2023 to assess emission sources using Optical Gas Imaging ("OGI") technology. 1 Please be advised that some companies may qualify as a "small business" under the Small Business Regulatory Enforcement and Fairness Act ("SBREFA"). The U.S. Small Business Administration has established a Table of Small Business Size Standards, which can be found at: https://www.sba.gov/document/support-table-size-standards. The SBREFA Information Sheet provides information on compliance assistance to entities that may qualify as small businesses as well as to inform them of their right to comment to the SBREFA Ombudsman concerning EPA enforcement activities. The SBREFA Information Sheet can be found at: https://www.epa.gov/compliance/small-business-resources-information-sheet. Page 2 On December 1, 2023, EPA sent a letter informing Trecora of potentially unauthorized emissions from a facility that EPA believed was owned/operated by Trecora, along with OGI video captures for the facility. EPA asked Trecora to verify facility ownership, provide current site-specific permit information, and take any necessary corrective action to address unauthorized hydrocarbon emissions. EPA considered information provided by Trecora to determine whether violations occurred at the facility. CAA Violations We are sending this NOVOC to inform Trecora of the following violations at the Facility: Texas SIP Violations 1. Failure to implement the required volatile organic compounds (VOC) controls on a storage tank operating at equal to or greater than 11 pounds per square inch absolute (psia) in which VOC are placed, stored, or held, in violation of 30 Tex. Admin. Code 115.112(a)(1); and 2. Failure to properly close automatic bleeder vents for an external floating roof, in violation of 30 Tex. Admin. Code 115.112(a)(2)(B). Please review the specific violations and information we have provided in the Enclosure regarding the facility at issue. Opportunity to Confer This NOVOC provides you with the opportunity to confer with EPA. We request Trecora contact Justin Lannen, Assistant Regional Counsel, at lannen.justin@epa.gov or (214) 665-8130 within ten (10) business days to discuss this pending matter. Sincerely, Digitally signed by CHERYL SEAGER Date: 2024.05.16 14:21:54 -05'00' Cheryl T. Seager, Director Enforcement and Compliance Assurance Division Enclosure cc: Michael De La Cruz, TCEQ (michael.delacruz@tceq.texas.gov) Michael Miller, TCEQ (michael.miller@tceq.texas.gov) Patrick Sayles, Trecora Hydrocarbons, LLC (patrick.sayles@trecora.com) Douglas Wallace, Trecora Hydrocarbons, LLC (douglas.wallace@trecora.com) Enclosure Unit Tank 61 Tank 61 Page 3 TRECORA HYDROCARBONS, LLC - HIGH PURITY SOLVENTS PLANT, SILSBEE, TEXAS Flyover Date 11/9/2023 Flyover Video ID Pin096_F2 Permit NSR Permit No. 3295; Title V Permit No. 2776 EPA Team Observations of Flyover Video Capture Emissions from the tank's external floating roof. Information later obtained indicates the tank's size is larger than 25,000 gallons with a psia equal to or greater than 11 Violation Failure to utilize required VOC storage tank controls 11/9/2023 Pin096_F2 NSR Permit No. 3295; Title V Permit No. 2776 Emissions from the north bleeder vent on the tank's external floating roof Failure to properly close automatic bleeder vents