Document mmp8NGX1r2YJRR8oNyDo5pjpZ

Enclosure A United States Environmental Protection Agency (EPA) Region 4 Air Enforcement Branch Final Inspection Report I. GENERAL INFORMATION Facility Name: CITGO Birmingham Terminal Location (Address): 2200 25th Street SW Birmingham, AL 35211 Inspection Date: July 29, 2021 Type of Inspection (Full or Partial Compliance Evaluation): Partial Compliance Evaluation ICIS-Air Number: ALJEF0000107300074 EPA Investigator(s)/Inspector(s): Steve Rieck EPA Region 4 Environmental Scientist Richard Helmich EPA National Enforcement Investigations Center (NEIC) Chemist Nicolas Bobbs EPA Office of Enforcement and Compliance Assurance (OECA) Environmental Engineer State/Local Investigator(s)/Inspector(s): Jason Howanitz, Jefferson County Department of Health Senior Air Pollution Control Engineer Person(s) Contacted at Facility (Name and Title): Report Prepared by: Steve Rieck Ryan Browne Assistant Terminal Manager Enclosure A - Final Inspection Report 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.). 3. Air permit issuance date. Bulk gasoline terminal Synthetic Minor Operating Permit #4-07-0074-03 September 29, 2008 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.). 40 C.F.R. Part 63, Subpart BBBBBB Truck loading rack and associated equipment, Storage tanks and associated equipment Vapors collected at the loading rack are sent to a Vapor Combustion Unit (VCU). Storage tanks are equipped with Internal and External Floating Roofs (IFRs/EFRS). B. Process Description (provide narrative or attach description provided by the company or excerpts from the permit) The CITGO Birmingham Terminal is a bulk gasoline facility that handles gasoline, diesel fuel, ethanol, additives, and other volatile organic products. These products are delivered to the facility by pipeline Project Name: CITGO Birmingham Terminal ICIS/Project No.: ALJEF0000107300074-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 2 of 9 Enclosure A - Final Inspection Report and trailer truck and stored in internal floating roof storage tanks. The products are loaded into trailer trucks using loading racks at the facility. 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 July 29, 2021, at approximately 8:30 am Yes All inspectors presented their credentials. Yes EPA inspectors arrived on site and discussed inspection objectives with Mr. Browne. 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 NEIC and EPA OECA 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. 8. Discussed the use of the infrared Yes Inspectors discussed use of the OGI camera and camera, TVA, PID, and any other the GMAP vehicle. equipment. Project Name: CITGO Birmingham Terminal ICIS/Project No.: ALJEF0000107300074-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 3 of 9 Enclosure A - Final Inspection Report 9. Discussed CBI. Records Reviewed at the Facility 10. The types of records reviewed and the time period reviewed. 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 The Region 4 inspector used the OGI camera and the associated operational rate to survey facility operations. The GMAP observed (e.g., Furnace 1 vehicle also measured concentrations of production rate was 5 lbs/hr on pollutants in the ambient air. A summary of 1/1/15, at 2:00 pm - permit requires the OGI camera survey is provided below. max rate at 6 lbs/hr). Loading Rack and VCU Provide the date and time the The loading rack and VCU were evaluated information was recorded by the wth the OGI camera while two trailer trucks inspector. loaded fuel. No emissions were observed at the loading rack or associated pressure relief Identify the permit limit (if device. applicable). The VCU receives and combusts vapors An attachment may be used for a collected during loading operation. The large amount of information. Region 4 inspector observed the VCU with the OGI camera. A plume of VOC emissions was observed at the VCU stack, indicating non-combusted vapors. Tank 1 Tank 1 is an EFR storage tank containing regular gasoline. The Region 4 inspector ascended Tank 1 and observed the floating roof with the OGI camera. No emissions were observed. Tank 2 Tank 2 is an EFR storage tank containing regular gasoline. The Region 4 inspector ascended Tank 2 and observed the floating roof with the OGI camera. VOC Emissions Project Name: CITGO Birmingham Terminal ICIS/Project No.: ALJEF0000107300074-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 4 of 9 Enclosure A - Final Inspection Report 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. were observed from the rim seals around the circumference of the floating roof. 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 The loading rack is connected to a VCU to equipment, the process equipment it control VOC vapors collected during truck is controlling, and the associated loading operation. The pressure in the loading parametric monitoring value rack must be kept under 18 inches of water. observed (e.g., baghouse pressure Two trucks were loading simultaneously drop, temperature, scrubber flow during the inspection. Pressure did not exceed rate, etc.). 5 inches of water. (For example - RTO 1 controlling furnace 1, 1,500 degrees F on 1/1/15, at 2:00 pm - permit requires 1,400 degree F or higher). Provide the date and time the information was recorded by the inspector. Project Name: CITGO Birmingham Terminal ICIS/Project No.: ALJEF0000107300074-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 5 of 9 Enclosure A - Final Inspection Report 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 in ductwork, no deterioration observed, etc.). Project Name: CITGO Birmingham Terminal ICIS/Project No.: ALJEF0000107300074-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 6 of 9 Enclosure A - Final Inspection Report 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. 26. Was the TVA used? If so, identify the equipment monitored and the results. N/A Yes A video log is provided in Enclosure B. No Project Name: CITGO Birmingham Terminal ICIS/Project No.: ALJEF0000107300074-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 7 of 9 Enclosure A - Final Inspection Report 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 returned to the office to conduct a closing conference. Yes Facility staff will review OGI videos taken for any potential CBI. Yes The team provided an overview of the day's inspection and observations. The GMAP vehicle operator discussed preliminary observations of ambient pollutant data. The data will be provided to Region 4 for review and distribution to the facility, separate from this report. 32. Discussed next steps, if applicable? 33. Date and time inspection concluded. Yes Inspectors discussed providing videos to the facility and a timeline for the inspection report. The inspection team left the facility at 9:45 am. Project Name: CITGO Birmingham Terminal ICIS/Project No.: ALJEF0000107300074-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 8 of 9 Enclosure A - Final Inspection Report Miscellaneous 34. Include any additional observations, if applicable. EPA Investigator/Inspector Signature: EPA Supervisor Signature & Title STEPHEN Digitally signed by STEPHEN RIECK _R_I_E_C__K___________-0_4'_00_' _______________ Date: 2021.10.01 15:15:39 JASON Digitally signed by JASON DRESSLER _D__R__E_S_S__L_E__R_______-0_4_'0_0'_____________ Date: 2021.10.01 15:42:35 Chief, North Air Enforcement Section Project Name: CITGO Birmingham Terminal ICIS/Project No.: ALJEF0000107300074-2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Template Effective Date: May 1, 2019 Page 9 of 9