Document n95zmVMoa9p83QvLejEY8w4B2

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 6TH AVENUE SEATTLE, WASHINGTON 98101 DATE: SUBJECT: FROM: THRU: TO: See date of Section Chief signature CLEAN AIR ACT INSPECTION REPORT McCall Companies, Portland, Oregon Daniel Heins, Environmental Scientist Air Toxics Enforcement Section, EPA Region 10 Derrick Terada, Acting Section Chief Air Toxics Enforcement Section, EPA Region 10 File BASIC INFORMATION Facility Name: McCall Companies Facility Location: 5480 NW Front Avenue, Portland, OR 97210 Date of Inspection: June 21, 2022 EPA Inspector(s): 1. Daniel Heins, Environmental Scientist Other Attendees: 1. Steve Kenyon, Operator - McCall Companies 2. Dustin Wilson,* Director of Terminal Operations - McCall Companies 3. George Yun, Air Quality Inspector - Oregon Department of Environmental Quality (DEQ) 4. Chris Moore, Air Quality Inspector - DEQ * Daniel Heins called Dustin Wilson via cell phone during the opening conference, and he arrived on site during the site tour. Contact Email Address: Dustin@McCallTerminals.com Purpose of Inspection: Tanks inspection Facility Type: Bulk fuels and asphalt terminal Page 1 of 5 Arrival Time: 15:45 Departure Time: 17:30 Inspection Type: Unannounced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet (via email after inspection) Provided CBI warning to facility The following information was obtained verbally from McCall Companies ("McCall") representatives unless otherwise noted. Process Description: McCall operates a bulk fuels and asphalt terminal in Portland ("The Facility"). The Facility receives, stores, and distributes biodiesel, diesel, and asphalt products. The Facility does not currently handle heating oil or tug fuel. The Facility receives asphalt by ship and rail, and distributes asphalt by truck. The Facility receives diesel and biodiesel by truck and ship, and could receive by rail. The Facility distributes diesel and biodiesel by truck and barge. The Facility's dock is occasionally used to receive renewable diesel (and no other products) for Zenith. The Facility has the capability of doing the same for Phillips 66 but does not in practice. The Facility's largest tanks are on the northeastern portion of the site. Here the Facility has three large asphalt storage tanks with maximum capacities of 9 to 12 million gallons, typically heated to around 240 degrees Fahrenheit. There are also large tanks of diesel and biodiesel on this side of the Facility. By near the truck loading is a tank farm with smaller tanks of asphalt and asphalt additives, which are blended for loading. The three largest tanks here have approximately 406 thousand gallon capacities and store asphalt products heated to approximately 350 degrees Fahrenheit. All other tanks in this area have capacities below 100 thousand gallons. The Facility has vapor recovery/control for loading asphalt and diesel. The tanks are all directly venting, though some of the diesel and biodiesel tanks have internal floating roofs. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: Daniel Heins used a Thermofisher TVA2020 flame ionization device ("the TVA") to measure the total hydrocarbon concentration in parts per million as methane (ppm) from sample ports at the tops of heated asphalt tanks. See Appendix A for a Facility map with selected tanks labeled. Page 2 of 5 Daniel Heins took readings at the tops of Tank 4 and 1 (the two largest asphalt tanks, both heated to approximately 245 degrees Fahrenheit and containing 58-28 and 64-22 grade asphalt, respectively). Tank 2 was empty during the inspection to facilitate maintenance. Daniel Heins then took readings at tanks 20 and 19 (heated to 327 and 346 degrees Fahrenheit and containing pitch and 58-28 asphalt, respectively). Tanks 19, 20, and 21 are the largest tanks in the loading area of the Facility. Tank 21 contained 62-22 asphalt and was not monitored. The pitch tank is the only one at the Facility. Steve Kenyon accompanied Daniel Heins up the tanks and observed the readings. Photos and/or Videos: were not taken during the inspection. Field Measurements: were taken during this inspection. See Appendix B. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Daniel Heins informed the Facility that research and investigations over the past decade had identified that default AP-42 emission factors/vapor pressures for heated asphalt underestimate actual volatile organic compound (VOC) emissions, and that many facilities with heated asphalt tanks are likely underestimating their emissions. Daniel Heins referenced a November 2020 EPA Enforcement Alert regarding this. McCall stated they would have to defer to the engineers that calculate the annual emissions estimates. Requested documents: EPA requested the following during the closing conference and confirmed via email: Site map with tank IDs Emissions calculations workbook for most recent submitted annual report List of tanks on site with: o Size/capacity o Product o Emissions controls (if applicable) o Typical heating temperature (if applicable) o Product max true vapor pressures DIGITAL SIGNATURES _________________________________ Daniel Heins, Report Author __________________________________ Derrick Terada, Acting Section Chief Page 3 of 5