Document mBrzVj4mn042nv5mRqQ3nRZ5k

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6 1201 ELM STREET, SUITE 500 DALLAS, TEXAS 75270-2102 September 18, 2020 VIA EMAIL: jerry.stumbo@valero.com Mr. Jerry D. Stumbo Valero Refining - New Orleans, LLC P.O. Box 518 Norco, Louisiana 70079 RE: Emission Inventory Permit Consistency Review St. Charles Refinery, Valero Refining - New Orleans, LLC (AI# 26003) Dear Mr. Stumbo: The U.S. Environmental Protection Agency (EPA) Region 6 is working with the Louisiana Department of Environmental Quality (LDEQ) and has reviewed your facility's 2018 emission inventory for criteria pollutant and hazardous air pollutant (HAP) emission totals, as reported to LDEQ. Based upon this review, EPA has determined that your reported emissions for some Emission Points exceeded your permit authorization limits. EPA had also reviewed your Title V reports for 2018 and did not find that these permit exceedances were reported. A detail by Emission Point of the differences between the reported emissions and permitted limits is included in the attachment to this letter. EPA is providing you the opportunity to clarify or explain these differences, especially if any of the following conditions are present: Sources and associated emissions included in the emission inventories that are not represented in permits (e.g. de minimis sources); Criteria pollutants or individual HAPs reported in the facility's emission inventories that are not represented in LDEQ permits or authorizations; Reported or unreported upset or other excess emission events (e.g. startup/shutdown). If Valero Refining - New Orleans, LLC is interested in discussing or providing information about this matter, you have ten (10) working days from receipt of this letter to inform EPA by e-mail by contacting: Kevin Kim Enforcement Officer (ECDAT) Air Toxics Enforcement Section U.S. EPA, Region 6 email: kim.kevin@epa.gov Subsequent to the above-referenced due date, Kevin Kim will arrange to meet with Valero Refining - New Orleans, LLC via conference call. At that time, Valero Refining - New Orleans, LLC may provide additional information to address the potential violations and present evidence that contravenes EPA's evidence. The primary goal is to ensure compliance with the applicable environmental laws and regulations; however, settlements will be available where appropriate. Please direct questions to Kevin Kim of the Air Enforcement Branch at 214-665-8554 or at kim.kevin@epa.gov. Thank you for your attention to this matter. The EPA acknowledges that the COVID-19 pandemic may impact your business. If that is the case, please contact us regarding any specific issues you need to discuss. Sincerely, STEVEN THOMPSON Steve Thompson Chief Air Enforcement Digitally signed by STEVEN THOMPSON DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=STEVEN THOMPSON, 0.9.2342.19200300.100.1.1=68001003652657 Date: 2020.09.18 13:26:02 -05'00' Branch Attachment ECC: Celena Cage, Louisiana Department of Environmental Quality, celena.cage@la.gov Attachment A Valero Refining - New Orleans, LLC - St. Charles Refinery AI # Facility Name Permit Subject Item Subject Item Type Subject Item Desc Emission Type 26003 Valero Refining Co - New 2520-00027-V17 Orleans LLC - St Charles Refinery EQT00000000250 26003 Valero Refining Co - New 2520-00027-V17 Orleans LLC - St Charles Refinery EQT00000000250 Other Other 2005-58 - Coker No. 1 Steam Vent 2005-58 - Coker No. 1 Steam Vent Routine Routine Parameter Desc Toluene VOC, Total Permitted Limit (tpy) 0.3 ERIC Reported Emissions (tpy) 2.96 Reported Emissions Over Permited Limit (tpy) 2.66 4.29 30.12 25.83