Document mq55pV1VM174ZKqjd7bjDEQkg

EPA Inspection Report - Page 1 of 19 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 06/22-23/2021, 6/30/2021 Air SIP, Title V, NSPS, NESHAP Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Motiva Enterprises, LLC Dallas Marketing Terminal 3900 Singleton Blvd Dallas, Texas 75212 3900 Singleton Blvd Dallas, Texas 75212 Dallas County 214-631-6193 Sandra Mena sandra.mena@motiva.com Terminal Superintendent FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000495027 TCEQ RN100519651 / Title V O-2713 AFS # 48-113-00046 424710 5171 Personnel participating in inspection: James Haynes EPA/Region 6 ECDAT Ben Rosenthal EPA/Region 6 ECDAT Austin Boehmer Motiva Spencer Fitzhenry Motiva Sandra Mena Motiva Donald Ferry Motiva Kevin Buchanan Motiva Naomi McElroy Motiva Kristine Pelt Motiva Physical Scientist Physical Scientist Operator Coordinator Terminal Superintendent Complex Manager Project Engineer Environmental Coordinator HSE Manager EPA Lead Inspector Signature/Date Supervisor Signature/Date Haynes, James Digitally signed by Haynes, James DN: cn=Haynes, James, email=haynes.james@epa.gov Date: 2021.08.26 14:45:18 -05'00' James Haynes Stucky, Marie Stucky Marie Digitally signed by Stucky, Marie DN: cn=Stucky, Marie, email=Stucky.Marie@epa.gov Date: 2021.08.26 14:59:09 -05'00' Date Date 6ENFORM-020-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 19 Section I - INTRODUCTION Motiva Enterprises, LLC / Dallas Marketing Terminal Inspection Date 06/22-23/2021, 06/30/2021 PURPOSE OF THE INSPECTION Two United States Environmental Protection Agency ("EPA") Region 6 inspectors, Mr. James Haynes and Mr. Ben Rosenthal, arrived at the at Motiva Enterprises, LLC's Dallas Marketing Terminal ("Motiva" or "the terminal") at approximately 11:15 on June 22, 2021 for an announced inspection. We met with Austin Boehmer, Motiva Operator. I, James Haynes, presented my credentials to Mr. Boehmer and informed him that this was an EPA inspection to determine compliance with the facility's permits and the Clean Air Act ("CAA"). Ms. Sandra Mena, Terminal Superintendent, Mr. Donald Ferry, Complex Manager, and Ms. Naomi McElroy, Environmental Coordinator, were unavailable and not at the terminal for the opening conference. The scope of the inspection is a partial compliance evaluation ("PCE") and includes evaluation of the compliance of the facility with its Title V Federal Operating Permit ("FOP"), New Source Review ("NSR") Permit, and Texas State Implementation Plan ("SIP") regulations. Additional federal regulations include New Source Performance Standards ("NSPS") and National Emission Standards for Hazardous Air Pollutants ("NESHAP") requirements. See Appendix 1 for a copy of the inspection's sign-in sheet. FACILITY DESCRIPTION Motiva owns and operates the Dallas Marketing Terminal, a petroleum storage and distribution terminal in Dallas, Texas. The site operates under NSR Permit No. 1285 and Title V FOP No. O-2713, both issued by the Texas Commission on Environmental Quality. Motiva's NSR is set to expire January 9, 2022, and the FOP is set to expire on August 16, 2022. These permits authorize Motiva's storage tanks, truck loading operations, and vapor control equipment. See Appendix 2 for a copy of the terminal's plot plan. The terminal receives, stores, and distributes diesel, jet fuel, two different grades of gasoline, and additives (such as ethanol). These products are received by the terminal via pipeline and truck. Motiva blends ethanol, butane, and gasoline at the loading racks to create the final product. Section II - OBSERVATIONS Mr. Rosenthal and I provided a Document Request to Mr. Boehmer prior to beginning any field activity. See Appendix 3 for a copy of this Document Request. We requested that Motiva start gathering documents so I could collect them at the end of the day. Following the discussion, Mr. Boehmer transmitted the Document Request to Ms. McElroy. For the inspection, I used a Nikon COOLPIX AW120 digital camera to photograph observations and a FLIR Systems GF320 infrared camera to screen equipment that visually detects hydrocarbon emissions. See Appendix 4 for photographs taken during the inspection. On June 22, 2021, we began the field portion of the inspection with Mr. Boehmer. We walked to the location of the terminal where Motiva receives and takes custody of incoming product. We continued to walk around the facility and observed a second custody transfer location from a nearby terminal. Mr. 2 EPA Inspection Report - Page 3 of 19 Motiva Enterprises, LLC / Dallas Marketing Terminal Inspection Date 06/22-23/2021, 06/30/2021 Rosenthal and I continued walking around the terminal and observed Motiva's storage tanks. The following table summarizes the list of tanks we observed: Table 1. List of Tanks Observed by EPA Tank Number Tank Contents 30745 Commingled Product (gasoline, diesel, ethanol) 29515 Ethanol 29514 Out of Service 29537 Diesel 28538 Diesel 30967 Gasoline 31476 Gasoline NOTE: This list does not include tanks storing additives or butane. Tank Type Internal Floating Roof ("IFR") IFR IFR Fixed Roof IFR IFR IFR We climbed Tank 29537 (storing diesel) and observed light hydrocarbons emanating from the access hatch near the sample well. See Photo 1 for the location of the leak. Following additional observations of the storage tanks referenced in Table 1, we walked to the location where the terminal injects butane into the piping that feeds the loading racks. Motiva uses this butane to adjust the Reid vapor pressure ("RVP") of the gasoline for seasonal changes. We also observed the terminal's oil-water separator and other tanks storing additives blended into the gasoline and diesel. In this area of the terminal, I detected odors near an additive tank. Mr. Boehmer identified the likely source, the tape gauge of Tank 5457 (storing additive). I confirmed light hydrocarbons coming from the tape gauge with the FLIR camera. We later observed the devices the terminal uses to control emissions from loading operations. The backup control device is a John Zink vapor combustion unit ("VCU") that thermally destructs the loading vapors. See Photo 2. The primary control device is a vapor recovery unit ("VRU") that uses a carbon adsorption system to recover gasoline product that can be returned to the storage tanks. Mr. Boehmer stated that the VRU was currently out of service due to a defect with a valve; therefore, vapors from loading operations were being routed to the VCU at the time of the inspection. See Photo 3. Mr. Boehmer noted that Motiva had ordered a replacement valve for the VRU prior to the inspection. We observed the loading racks and loading operations at the terminal. Mr. Boehmer showed us the location where blending occurs at the racks, the MultiLoad II loading interface, and the Scully system. See Photo 4 for a photograph of the loading interface system. We returned to the office for a brief phone call with Ms. McElroy before departing the terminal at 15:15. On June 23, 2021, we returned to the terminal 11:35 and met with Ms. Mena and Mr. Ferry. We confirmed that the VRU was out of service until the terminal received a replacement valve. Additionally, we climbed Tank 29537 again to confirm any hydrocarbons with the FLIR camera; however, I did not observe any emissions with the FLIR camera at that time. We also returned to Tank 5457. Motiva staff indicated that the tape gauge was repaired, and I confirmed that there were no visible hydrocarbons with the FLIR camera. 3 EPA Inspection Report - Page 4 of 19 Motiva Enterprises, LLC / Dallas Marketing Terminal Inspection Date 06/22-23/2021, 06/30/2021 We later observed a sample recovery tank at Skid FJB06 where I detected light hydrocarbons using the FLIR camera. See Photo 5 and 6 for the location of the skid and the leaking component. Using Motiva's 4-gas meter, we observed readings less than 500 ppm VOC with an estimated lower explosive limit ("LEL") of 3%. After viewing the sample recovery tank, we returned to the loading rack. At Bay 5, Mr. Rosenthal and I encountered odors at the back of a trailer loading gasoline. After using the FLIR camera, I observed emissions at Bay 5's flame arrestor. See Photo 7 for a photo of the flame arrestor. Displaced vapors from the truck travel through this arrestor during loading operations and then through additional piping to the downstream vapor processing system. We used Motiva's 4-gas meter again, and I observed a reading of about 1,200 ppm VOC with an estimated LEL of greater than 10%. The meter also noted that the LEL was outside the calibrated range. See Area of Concern (AOC) 1. On June 30, 2021, Mr. Rosenthal and I conducted a virtual meeting with Motiva staff, discussing the terminal's operations, procedures, and permitted sources. We also identified additional records we would need to continue evaluating the compliance of the terminal. At the end of the call, Mr. Rosenthal and I conducted the closing conference with Motiva staff available for the call. Following the closing conference, I transmitted a copy of the sign-in sheet, two notices regarding confidential business information, and copies of all photos from the inspection. Section III - AREAS OF CONCERN 1) Hydrocarbons Observed with the FLIR Camera at the Flame Arrestor EPA observed hydrocarbon vapors using the FLIR camera at Bay 5's flame arrestor. Motiva is required to equip the loading rack with a vapor collection system that transports displaced vapors from the cargo tanks to a control device that reduces total organic compounds. Additionally, Motiva's 4-gas meter documented elevated LEL and VOC readings that may indicate that Motiva is not operating and maintaining an affected source in a manner consistent with safety and good air pollution practices for minimizing emissions. Note: the LEL measurement did not factor in the meter's calibration gas and/or LEL correction factors that may be necessary to adjust for gasoline vapors. **2) Leak Inspections Occuring Outside the Monthly Requirements During a cursory review of Motiva's leak inspection log book, EPA observed several instances where leak inspections occurred outside the monthly requirements. Under NESHAP Subpart BBBBBB ("NESHAP 6B"), Motiva is required to conduct monthly inspections of all equipment in gasoline service. Additionally, under NESHAP 6B, EPA defines monthly as once per calendar month at regular intervals of no less than 28 days and no more than 35 days. For example, in 2020, Motiva conducted a leak inspection on September 16. The following monthly inspection occurred on October 6 - 20 days later. Under NESHAP 6B, these two leak inspections should be no less than 28 days apart. The next month, Motiva conducted the leak inspection on November 25 - 50 days later and 15 days beyond what is allowed under the regulation. 4 EPA Inspection Report - Page 5 of 19 Motiva Enterprises, LLC / Dallas Marketing Terminal Inspection Date 06/22-23/2021, 06/30/2021 **3) Vapor Combustor Compliance Options During a call on June 30, 2021, Motiva staff indicated that the VCU complies with the testing and monitoring requirements of NESHAP 6B by following 40 C.F.R. 63.11092(b)(1)(iii)(B). Upon further review, compliance with this section of the rule is only allowed after conducting a performance test under 40 C.F.R. 63.11092(a)(1); however, Motiva confirmed that they are complying with 40 C.F.R. 63.11092(a)(2) which allows the terminal to certify the compliance status of the loading rack in lieu of the performance test under paragraph (a)(1). Under NESHAP 6B, if Motiva has elected to comply with 40 C.F.R. 63.11092(a)(2), Motiva is required to follow the requirements outlined in 40 C.F.R. 63.11092(b)(5). **Not addressed with company during the inspection or at the closing conference. Note: The Areas of Concern referenced above are not comprehensive. It only reflects the concerns identified during this inspection. The inspection team will continue to evaluate Motiva's records and engage with terminal staff to determine compliance with the CAA as part of a more detailed investigation. Section IV - FOLLOW UP EPA received initial responses from Motiva on June 25, 2021. EPA received additional information on July 28 and August 5, 2021, after ending the inspection on June 30, 2021. Section V - LIST OF APPENDICES Appendix 1 - Sign-in Sheet Appendix 2 - Terminal Plot Plan Appendix 3 - Document Request Appendix 4 - Photograph Log 5 EPA Inspection Report - Page 6 of 19 Motiva Enterprises, LLC / Dallas Marketing Terminal Inspection Date 06/22-23/2021, 06/30/2021 Appendix 1 Sign-in Sheet EPA Inspection Report - Page 7 of 19 EPA Inspection Report - Page 8 of 19 Motiva Enterprises, LLC / Dallas Marketing Terminal Inspection Date 06/22-23/2021, 06/30/2021 Appendix 2 Terminal Plot Plan EPA Inspection Report - Page 9 of 19 WAREHOUSE 7487 TRUCTRANS 6 K LA LO PA ORT NES DING ASPHALT PARKING NORWICH STREET ENTERPRISE CONCRETE PRODUCTS PUMP HOUSE MAGELLAN PIPELINE Co. SINGLETON BLVD. GRAVEL GRAVEL WHSE. TRUCK WASH GARAGE GRASS FOAM HOUSE BUTANE TANK 1 VALVE #1 VALVE #2 VALVE #3 VRU SECONDARY CONTAINMENT AVG. HT 2' (79,647 gal) EQUIP. STAGING AREA 1096 1075 221 3 1083 1 ADDITIVE TANK UST OWS 5457 1091 VRU GRASS 30967 SECONDARY CONTAINMENT AVG. HT 6' (5,476,842 gal) ANODE BED 31476 ELEC. BLDG. METERS & VALVES OFFICE ANAYLZER BLDG. LOCATION OF COMMUNICATION & ESD EQUIP. EQUIP. STAGING AREA GRASS RECTIFIER CAP. 70 GALLONS 30746 31485 TRAINING/CONFERENCE WAREHOUSE BLDG. GRASS PIPING 29538 29537 30745 29515 29514 EXPLORER PIPELINE TO TANKS EXPLORER PIPELINE CO. BUILDING CIFIC RAILROAD UNION PA 0' 90' 180' 360' SCALE 3ORW3ODQ Motiva Enterprises LLC Dallas Terminal 3900 Singleton Blvd 0//201 J15910 AS NOTED S0 MOT000646 EPA Inspection Report - Page 10 of 19 Motiva Enterprises, LLC / Dallas Marketing Terminal Inspection Date 06/22-23/2021, 06/30/2021 Appendix 3 Document Request EPA Inspection Report - Page 11 of 19 Motiva Enterprises LLC, Dallas Marketing Terminal EPA Record Request - 6/22/2021 Description Current state and federal operating permit(s) and application(s) Current plot plan with each tank ID Listing of all tanks, year constructed, material stored, capacity, diameter, height, tank type (cone roof, IFR, EFR, CVS w/ control), applicable regulations. If floating roof, type of floating roof, type of primary seal, and type of secondary seal (if applicable) Vapor pressure analysis/documentation of each material stored with ASTM test method Strapping table for each tank including levels when the vacuum breaker opens and the level when the tank rests on it legs (if adjustible, high and low settings) To what standards (e.g. API, ASTM) are/were each tank built? To what standards are they maintained? Procedures for inspection, maintenance of tanks Any policy, guidance, or interpretation of regulations and what that means for the operation of the tank or controls Spreadsheet or database used to track inspections/repairs (e.g., API schedules, repair history) Individual product throughput records (gasoline, ethanol, diesel, biodiesel, avjet, additives) for the site and individual product throughputs at the loading racks. Provide average and maxiumum loading rates for the tanks and loading racks. Provide truck loading data. How are tank levels recorded? Are roof landings included in the facility permit(s)? Are tank cleanings included in the facility permit(s)? Provide a listing of tanks that have been landed, when they were landed, and the duration of the landing. Provide tank cleaning records. How are roof landings tracked/documented? Are different emission factors used for Emission Inventory reporting? Annual Emissions Inventory Reports Title V reports (ACC, Semi-annual Monitoring and Deviation Reports) Period 2 years 5 years 5 years 5 years Provide all notifications and/or record of communication for fill/refill of IFR storage vessels to TCEQ 5 years Provide records of inspection (i.e. prior to filling the tank, roof top inspections, internal inspections each time emptied/degasses). If no internal inspection w/in 5 years, provide records of the last internal inspection. Include: Storage vessel ID, date of inspection, observed condition of each component (seals, IFR, and fittings) Provide copies of the previous two internal and external API inspections at each tank Provide all reports to TCEQ of failed roof top visual inspections Provide all reports to TCEQ of failed internal inspections Provide the certification report to TCEQ for all new floating roof tanks NESHAP Subpart 6B Notificiation of Compliance Status/Initial Notification NESHAP Subpart 6B Semi-annual Compliance Reports All engineering assessments and performance test records for the VCU CEMS records for the VRU Annual certification test for gasoline cargo tanks and/or documentation showing vapor-tight testing for each tank truck loaded at the facility Equipment leak log book records documenting inspection, leaks, and repairs 5 years 5 years 5 years since 2016 5 years 5 years 2 years 2 years EPA Inspection Report - Page 12 of 19 Motiva Enterprises, LLC / Dallas Marketing Terminal Inspection Date 06/22-23/2021, 06/30/2021 Appendix 4 Photograph Log EPA Inspection Report - Page 13 of 19 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Motiva Enterprises, LLC - Dallas Marketing Terminal City: Dallas County: Dallas State: TX Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0502.JPG 06/22/2021 12:21 Ben Rosenthal Access hatch of Tank 39537; arrow notes the location at which EPA observed hydrocarbon emissions using the FLIR camera. Page 1 of 7 EPA Inspection Report - Page 14 of 19 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Motiva Enterprises, LLC - Dallas Marketing Terminal City: Dallas County: Dallas State: TX Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0505.JPG 06/22/2021 12:50 Ben Rosenthal Vapor combustion unit at terminal to control emissions from loading operations. Page 2 of 7 EPA Inspection Report - Page 15 of 19 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Motiva Enterprises, LLC - Dallas Marketing Terminal City: Dallas County: Dallas State: TX Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0506.JPG 06/22/2021 13:02 Ben Rosenthal Sight glass into VCU showing flames; VCU was controlling emissions from loading operations at the time of the inspection. Page 3 of 7 EPA Inspection Report - Page 16 of 19 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Motiva Enterprises, LLC - Dallas Marketing Terminal City: Dallas County: Dallas State: TX Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0514.JPG 06/22/2021 13:51 Ben Rosenthal Loading interface system used by truckers prior to loading; a loading interface system is located at each bay. Page 4 of 7 EPA Inspection Report - Page 17 of 19 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Motiva Enterprises, LLC - Dallas Marketing Terminal City: Dallas County: Dallas State: TX Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0517.JPG 06/23/2021 13:50 Ben Rosenthal FJB06 skid used for sampling gasoline. Page 5 of 7 EPA Inspection Report - Page 18 of 19 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Motiva Enterprises, LLC - Dallas Marketing Terminal City: Dallas County: Dallas State: TX Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0518.JPG 06/23/2021 13:50 Ben Rosenthal Rear of FJB06 skid with gasoline tank; arrow notes the location at which EPA observed hydrocarbon emissions using the FLIR camera. Page 6 of 7 EPA Inspection Report - Page 19 of 19 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Motiva Enterprises, LLC - Dallas Marketing Terminal City: Dallas County: Dallas State: TX Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0519.JPG 06/23/2021 14:26 James Haynes Bay 5 flame arrestor; arrow notes the location at which EPA observed hydrocarbon emissions using the FLIR camera. Page 7 of 7