Document n6Y3Vbe5Kk7D74gNnvLRjrZz

UNITED STATES Clean Air Act Compliance Inspection Report AGENCY United States Environmental Protection Agency ONMENTALPROTECTION Region 10 Seattle, WA Partial Compliance Evaluation Kinder Morgan Willbridge and Linnton Terminals 5880 NW Saint Helens Road,11400 NW Saint Helens Road, Portland, OR 97210Portland, OR 97231 Inspection Date: December 5, 2024 Digitally signed by ZACHARY HEDGPETH ZACHARY HEDGPETH Date: 2025.02.13 07: 51: 46-08'00 ' Report Author SignatureDate Zach Hedgpeth, PE Environmental Engineer EPA Region 10 BRENDAN WHYTE DigitalDlatye : s2i02g5n.0e2d.1 3b 0y8 :B 2R6E: N0D0-A0N8' 0W0 H'Y TE Peer Review SignatureDate Brendan Whyte CAA Inspector EPA Region 10 Digitally signed by ELIZABETH WALTERS ELIZABETH WALTERS Date: 2025.02.13 11: 40: 50-08'00 ' Manager SignatureDate Elly Walters Supervisor, Air Enforcement Section EPA Region 10 Table of Contents 1. Basic Facility and Inspection Information......3 2. Introduction4 3. Inspection Elements and Field Observations - December 5, 20244 4. Closing Conference - December 5, 2024.....6 Attachments Attachment 1 ..Photo and Video Log Attachment 2.............. EPA Region 10 FLIR GF320 SOP 2 1. Basic Facility and Inspection Information Facility:Kinder Morgan Willbridge Terminal Kinder Morgan Linnton Terminal 5880 NW Saint Helens Road,11400 NW Saint Helens Road, Portland, OR 97210Portland, OR 97231 AFS / FRS Number:AFS: OR0000004105102028FRS: 110048840735 Permit Number:26-2028-TV-01 Facility Contacts:Lane Karabaic Area Manager Kinder Morgan lane karabaic@kindermorgan.com Donny Homer Air Specialist Kinder Morgan donny homer@kindermorgan.com Agency Inspectors:Zach Hedgpeth, PE-EPA Region 10 206-553-1217, hedgpeth.zach@epa.gov Brendan Whyte - EPA Region 10 (b) (6) whyte.brendan@epa.gov Trey Peterson - EPA Region 10 Alex Liebert - EPA Region 10 Boris Barrera - Oregon DEQ Inspection Date:December 5, 2024 Inspection Notice:Limited notice Disclaimer This report is a summary of observations and information gathered from the facility at the time of the inspection. The information provided does not constitute a final decision regarding compliance with the Clean Air Act (CAA) and applicable regulations or permits, nor is it meant to be a comprehensive report of all activities and processes conducted at the facility. 3 2. Introduction a) This was a Clean Air Act (CAA) compliance inspection by the Environmental Protection Agency (EPA). The purpose of this inspection was to conduct a partial compliance evaluation (PCE) inspection of the facility. The inspection included general discussion of facility operations and a visual walk - through including observations using FLIR GF320 and Gx620 infrared gas imaging cameras in addition to the observations of the inspectors. b) Limited notice of this inspection was provided to the facility. 3. Inspection Elements and Field Observations - December 5, 2024 a) Around 08:15 I called Donny Homer and provided notice of the inspection. b) The EPA inspectors arrived onsite at the Linnton facility location at approximately 09:10. We met with Lane Karabaic, Area Manager, and Sean Gray, Operations Supervisor, in the facility parking lot. c) Opening Conference 1. A brief opening conference was held in the facility entrance with the four EPA staff, Mr. Karabaic, and Mr. Gray. Donny Homer arrived shortly after our arrival. The EPA inspectors presented our credentials to facility staff at this time. Mr. Karabaic explained that he and Mr. Homer would serve as EPA's points of contact for the inspection. 2. I began the opening conference by explaining that we (EPA inspectors) were onsite to conduct an inspection under the Federal Clean Air Act (CAA). The inspection will be a PCE centering around emissions observations using the FLIR cameras. I noted that EPA was following up based on data recently collected and submitted by the facility as part of the fenceline monitoring currently underway as required by the EPA Information Request. 3. Collection of photos, videos, and FLIR infrared videos were discussed, and facility personnel expressed their agreement. I also explained that copies of all recordings collected during the inspection would be transmitted to the facility along with the inspection report. 4. I noted that some of the EPA equipment is not intrinsically safe, and facility staff completed the necessary documentation in their hot work permit system. 5. Confidential business information (CBI) was discussed, and the EPA CBI forms were sent via email to Mr. Karabaic on 12/6/24. Facility personnel did not claim any information as CBI during the inspection. 6. The opening conference ended, and the group proceeded to the field at approximately 09:20. 1 Use of the cameras during this inspection followed U.S. EPA Region 10 Office of Environmental Assessment Standard Operating Procedure OEAFIELDSOP-111 entitled " Optical Gas Imaging with a FLIR GF320 Infrared Camera ", which is included as Attachment 2. 4 d) Field Observations - Linnton Facility 1. Fieldwork began with a walk - through survey of selected tanks and other areas using the FLIR cameras. Mr. Karabaic, Mr. Gray, and Mr. Homer accompanied the inspectors throughout the inspection. 2. Sorbent tube monitoring Station 4 was observed, and I took photos 487-489 (see Attachment 1) showing the installation of the sorbent tube monitoring equipment. 3. The groundwater treatment system installed at the facility was observed. The contractor who maintains the system was onsite at the time of the inspection, and noted that the carbon was last changed out in September 2024. 4. The oil - water separator at the facility was observed, see photo 491. The facility staff noted that the unit is rarely used. 5. The facility staff noted that painting was ongoing, and had been initiated on November 11, 2024. We observed hand painting of piping occurring. 6. Inspector Whyte climbed Tanks T-45028 and T-59029 and observed the tanks using the FLIR camera. No emissions were visible using the FLIR camera. 7. The group departed the Linnton facility around 10:15 and drove to the Willbridge facility. e) Field Observations - Willbridge Facility 1. The inspectors arrived at the Willbridge location around 10:30. We briefly entered the facility office and met with facility personnel in order to sign - in. We then proceeded to the field, accompanied by Mr. Karabaic, Mr. Gray and Mr. Homer. 2. Instead of walking through the facility, the inspectors drove to a gravel area outside the northwest portion of the site, near the truck scale. The facility staff opened a gate to allow us access to the facility through the security fence. 3. Sorbent tube monitoring Station 03 and the mobile meteorological station onsite were observed, and I took photos 492-495 showing the installation of the sorbent tube monitoring equipment and met station. 4. Mr. Gray explained that the facility truck rack and marine loading vapor collection are both routed to a bladder tank, which is upstream of the vapor recovery unit (VRU). The bladder tank was installed in / around 2015. 5. FLIR observations were conducted of Tank WB-123. VOC emissions were observed from the rim vents using the FLIR cameras, and Inspector Whyte recorded video 200 (see Attachment 1). 6. The group observed that trucks regularly idle near sorbent tube monitoring Station 03, as shown in photo 496. 5 10 4. Closing Conference - December 5, 2024 a) The closing conference was held in the field at the Willbridge facility. I led the discussion, including providing an overview of the EPA Region 10 compliance process. b) Attendees: 1. Kinder Morgan: Lane Karabaic, Sean Gray, Donny Homer 2. EPA: Zach Hedgpeth, Brendan Whyte, Alex Liebert, Trey Peterson c) No issues were identified as potential compliance concerns under the CAA. I clarified that this may not include any additional compliance concerns that are identified post- inspection. d) The closing conference ended around 11:00, and the inspectors departed the facility. 6