Document ppxoy09ERqoNdEeKDX2Ro13qE

EPA Inspection Report - Page 1 of 48 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 09/12/2022 to 09/16/2022 Air Title V, 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: TotalEnergies Petrochemicals & Refining USA, Inc. Port Arthur Refinery 7600 32nd Street Port Arthur, TX 77642 PO BOX 849 Port Arthur, TX 77641 Jefferson County 409-963-6611 Isaac Bankole Environmental Superintendent isaac.bankole@totalenergies.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000755200 RN102457520 AFS 48-245-00037 324110 2911 Personnel participating in inspection: Sarah Frey EPA Region 6, ECD-AT Nicholas Bobbs EPA OECA, AED Jeanette Morrell TCEQ, Region 10 Michael Miller TCEQ, OCE Alexia Scott ERG Elizabeth Hubbard ERG Isaac Bankole TotalEnergies Carl Boyd TotalEnergies Amy Geist TotalEnergies Connie Howard TotalEnergies Meredith Youngson TotalEnergies Anthony McLaughlin TotalEnergies Trisha Froemming TotalEnergies Inspector Inspector Environmental Investigator Air Program Liaison Investigator Investigator Environmental Superintendent OM&S Supervisor Corporate Environmental Manager Environmental Staff Environmental Staff Environmental Staff Environmental Staff EPA Lead Inspector Signature/Date 1/6/2023 Sarah Frey Date Supervisor Signature/Date JAMES LEATHERS Date: 2023.01.06 15:44:23 -06'00' Digitally signed by JAMES LEATHERS James Leathers Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 48 Section I - INTRODUCTION TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 PURPOSE OF THE INSPECTION EPA Region 6 inspector Dr. Sarah Frey and EPA OECA-AED inspector Mr. Nicholas Bobbs arrived at the TotalEnergies Petrochemicals & Refining USA, Inc. ("Total") Port Arthur Refinery (the "Facility" or "refinery") at 8:15 am on September 12, 2022 for an announced inspection. They were accompanied by Ms. Jeanette Morrel and Mr. Michael Miller from the Texas Commission on Environmental Quality ("TCEQ") and Ms. Alexia Scott and Ms. Elizabeth Hubbard from the Eastern Research Group ("ERG"), contractors for the EPA. We met with Mr. Hugh Campbell/HSSE Manager, Mr. Tom Chavez/General Manager, Mr. Isaac Bankole/Environmental Superintendent, Ms. Amy Geist/Corporate Environmental Manager, and other facility representatives at the Opening Conference. We presented our credentials to Mr. Chavez and Mr. Campbell and informed them that this was an EPA inspection to determine compliance with the facility's Title V Air Permit and the Clean Air Act ("CAA"). The scope of the inspection is a partial compliance evaluation ("PCE") and includes evaluation of the compliance of the facility with its Title V operating permit and the applicable CAA regulations, focusing particularly on the National Emissions Standards for Hazardous Air Pollutants ("NESHAP") Subpart CC Fenceline Monitoring regulations (40 CFR 63.658). The inspection was prompted by the Facility's reported benzene fenceline monitoring concentrations, in which the 12-month rolling average exceeded the action level of 9 g/m3 for at least 13 consecutive calendar quarters. Photographs and videos taken during the inspection can be found in Appendix 1 and 2, respectively. The sign-in sheet for the Opening Conference is attached as Appendix 3. FACILITY DESCRIPTION Total operates under Federal Operating Permit (FOP) O-1267, issued on August 13, 2010, under New Source Review (NSR) Permit 46396, last revised on October 24, 2022. The refinery also operates under several Permit By Rules. The refinery receives crude oil and condensate via pipeline and marine vessel. The crude is first split into various petroleum fractions via distillation. The refinery manufactures transportation fuels: gasoline, diesel, jet fuel, propane, butane, and bunker oil. The refinery also makes asphalt and recovers benzene, toluene, and xylene from its fuel products. Total is subject to 40 CFR part 63 subpart CC, which requires all refineries to implement a fenceline monitoring program for benzene emissions. The regulatory requirements of the program can be found in 40 CFR 63.658 and the reporting requirement can be found in in 40 CFR 63.655(h)(8). Fenceline monitoring is required to be performed in accordance with Methods 325A and 325B of 40 CFR part 63 Appendix A. To meet the requirements for benzene fenceline monitoring in 40 CFR 63.658, the Facility installed 23 passive sampling sites for biweekly analysis of benzene concentrations. The Facility also installed 22 temporary sampling sites for weekly analysis of benzene concentrations. Additionally, four real-time fenceline gas chromatograph analyzers were installed around May 2021 to collect benzene concentrations every 10 minutes. 2 EPA Inspection Report - Page 3 of 48 Section II - OBSERVATIONS TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 On September 12, 2022, after credentials and identification were presented to the responsible officials, the inspection team discussed our plans for the inspection, including the intent to deploy real-time benzene analyzers to investigate potential sources of benzene impacting the Facility's fenceline. Details about the ENMET environmental Gas Chromatographs ("eGCs") used and the resulting data can be found in Appendix 4. EPA and TCEQ also shared that we would conduct screenings using optical gas imaging ("OGI") cameras and photoionization detectors ("PID"). After discussions about safety, scheduling, photographs, videos, and confidential business information ("CBI"), we discussed the status of the records requested on August 25, 2022 (Appendix 5, Document Request). The inspection team began a review of the requested sampling data and Ms. Connie Howard described the Facility's Benzene Taskforce Root Cause Analysis team, which meets every two weeks to discuss sampling results and action items. Ms. Howard shared that the 22 temporary monitors are collected weekly, but the results are reviewed on a biweekly basis. Mr. Carl Boyd described past and current issues with the nitrogen gas regulator on Tank 926, which was having an impact on the associated thermal oxidizer. [AOC 10] Facility representatives described how they used data from their real-time analyzers, utilizing email and text alerts to potentially trigger further investigations using handheld monitors that have a lower detection limit of 10 parts per billion ("ppb") benzene. EPA requested additional documents and departed the conference room to set up the EPA eGC near tanks 807 and 808. At approximately 11:30am, the inspection team observed one of Total's real-time analyzers, passive sampler site PA-6.5, and the temporary thermal oxidizer. ERG assembled EPA's real-time analyzer, an ENMET eGC labeled "eGC EPA 2", and placed it near Tanks 810 and 808. After breaking for lunch, the inspection team broke into two groups. Inspector Bobbs was accompanied by ERG in the field, and Inspector Frey was accompanied by TCEQ in the conference room. Discussions related to exceedance events and corrective action plans continued with Mr. Bankole, Ms. Howard, and Ms. Trisha Froemming (see Section II-a). Mr. Bobbs adjusted the location of "eGC EPA 2" to be slightly closer to Tanks 809 and 810 and surveyed the benzene transfer pumps for tanks 809 and 810. The inspection team departed the facility at 5:00 pm. On September 13, 2022, the inspection team arrived at 8:05 am. The team reviewed eGC data collected from both Total and EPA's analyzers overnight. Inspector Bobbs and ERG returned to the field to relocate eGC EPA 2 to the west/southwest of Tank 807 and to assemble "eGC EPA 1", initially placed south of Dock 3A. Inspector Frey and TCEQ remained in the conference room to further discuss evaluation of fenceline data, exceedance events, and corrective action plans (see Section II-a). After breaking for lunch, the inspection team returned to the field at 3:15pm. Dr. Frey, Mr. Miller, and Ms. Morrell were accompanied by Mr. Bankole, Ms. Howard, Ms. Froemming, and Ms. Youngson of Total to observe the Crude Unit heat exchangers and the cooling towers. Mr. Bobbs, Ms. Scott, and Ms. Hubbard were accompanied by Mr. Boyd, Ms. Geist, and other Total personnel to survey the benzene transfer pump 22P-809, benzene sales pump 22P-807 and the offspec pygas pump 22P-807. Mr. Bobbs observed 3 EPA Inspection Report - Page 4 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 that the seal pressure gauge for pump 22P-809A was pegged at the maximum of 100 psi. Mr. Boyd said that this was due to a faulty gauge. [AOC 10] The inspection team departed the facility around 5:30pm. On September 14, 2022 the inspection team arrived at 8:15 am. Dr. Frey reviewed cooling tower emission monitoring records. The team reviewed eGC data collected from both Total and EPA's analyzers overnight. The eGC EPA 1 was positioned to the south-southwest of Dock 3A overnight and there was a light wind coming from the north and north-northeast. The refinery was loading a barge at Dock 3A with benzene product from Tank 808 during this period. Mr. Bobbs requested the log for the barge loading on September 13 to 14 and used it to determine probable causes of benzene concentrations detected by eGC EPA 1. The eGC EPA 1 detected significant benzene concentrations between 2:26pm and 6:55 pm on September 13, 2022. There was a high reading of 60.8 ppb at 4:56 pm, was immediately before the transfer hose was connected to the barge. The barge disconnected from the transfer hose at 6:10 pm after being refused loading due to high pressure in the barge. There was a high reading of 48.92 ppb at 6:26 pm, which is when the barge left from dock 3A. The barge returned and started transferring benzene product overnight. The eGC EPA 1 detected significant benzene concentrations from 6:36 am to 8:36 am. The highest readings during this window were 195 ppb at 6:56 am and 173.8 ppb at 7:46 am. These readings occurred while the barge had finished receiving product and the transfer hose had been disconnected, but the barge was still at Dock 3A. [AOC 1] The eGC EPA 2 analyzer recorded elevated readings from the direction of Tanks 540, 541, 532 and 960. (See Appendix 4) Additional documents were requested. The inspection team reviewed the operator logs for responding to exceedances at the real-time analyzers and discussed the processes in place for notification and investigation. If a real-time analyzer records a concentration greater than 2.9 ppb, an email and text alert are sent to the area field supervisor. If the exceedance was greater than 10 ppb, operators have been instructed to use the handheld analyzer and attempt to locate the source. A summary report is typed in a shared word document. Depending on the person, notes range from just a statement of the time and concentration to details related to thermal oxidizer status, barge operations status, and/or actions taken. While we were onsite, it was discovered that the automated emails/texts are sent just once every 30 minutes and may exclude elevated concentrations that immediately follow the first triggering event. This could result in operators not initiating a field investigation if the initial concentration is between 2.9 and 10 ppb. [AOC 2] At approximately 10:30am, the inspection team went into the field to relocate eGC EPA 2 closer to the fenceline, east of Tank 807 and south of Tank 808. Mr. Bobbs and Ms. Morrell climbed to the top of Tanks 807, 808, and 809 and monitored for benzene using an UltraRae 3000 PID with a benzene separation sorbent tube. Mr. Bobbs discovered that the ball valves for the hermetic gauges on Tanks 808 and 809 were missing caps. Mr. Bobbs took a photo of the hermetic gauge for tank 808 (Photo 1). [AOC 3] Inspectors also detected benzene concentrations on top of tank 807 up to 3.7 ppm near the weighted manway (Component 22EV-1807). [AOC 5] 4 EPA Inspection Report - Page 5 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 At 3pm, Dr. Frey and Ms. Morrell met by phone with Hugh Campbell, HSSE Manager. Mr. Campbell has been with the facility for four months. We discussed the past and current processes related to the facility's fenceline monitoring program and root cause identifications. Mr. Campbell recognized that the facility has had difficulties in determining causes and appropriate follow-up actions. [AOC 4, AOC 8] (see Section II-a) He explained the changes that he is implementing, including the integration of Lean Management processes and how incidents are being investigated and communicated. After the meeting, document review continued, including a review of pump inspection records for 809A and 809B and of 1-week passive sampling data. In the field, Mr. Bobbs and ERG relocated eGC EPA 1 west of its previous position, in attempts to be downwind of a barge waiting to be loaded from Tank 926 at Dock 3A (See Appendix 4). Mr. Bobbs observed the top of Tank 926 and measured benzene concentrations up to 146 ppm using a PID with benzene separation tube emanating from the weighted manway (Component 22TEV-926). [AOC 5] Mr. Bobbs noted that at the time of measurement that the nitrogen blanket pressure in Tank 926 was 1 inch of water column ("inH2O"). Information related to vacuum breaker and weighted manway pop-off pressures and nitrogen blanket regulator settings was requested. Mr. Bobbs also observed that sample site PA-15 and PA-15.5 was not located where indicated on maps provided by Total. When the coordinates provided in Total's quarterly fenceline monitoring reports were reviewed, multiple inconsistencies were discovered. [AOC 6] The eGC EPA 2, which was located downwind of Tank 807, detected a benzene concentration of 5.9 ppb at 3:36 pm. Mr. Boyd described recent repairs that had been made to the nitrogen regulator on Tank 807. [AOC 10] The inspection team departed the facility around 5:40pm. On September 15, 2022 the inspection team arrived at 8:15 am. The team reviewed eGC data collected from both Total and EPA's analyzers overnight. The eGC EPA 1 detected elevated benzene concentrations, which are believed to be a result of connecting and disconnecting hoses from the barge at Dock 3A. The eGC EPA 1 was positioned downwind of Dock 3A, where a barge was loading benzene product from Tank 926 overnight. Mr. Bobbs requested and reviewed the log sheet for the barge loading and compared it to the eGC detections to find possible benzene sources. The eGC EPA 1 detected a benzene concentration of 78 ppb at 5:16 pm on September 14, 2022, which was when the barge disconnected from the transfer hose after being refused loading due to high pressure in the barge. The barge returned after depressurizing and reconnected the transfer hose at 9:10 pm. The eGC EPA 1 detected a benzene concentration of 128 ppb at 9:06 pm, which was right before the transfer hose was connected, and a benzene concentration of 19 ppb at 9:26 pm, which was after the transfer hose was connected but before product loading started. [AOC 1]. The eGC EPA 2 detected elevated benzene from the direction of Tank 807. Mr. Bobbs and ERG returned to the field and Dr. Frey and TCEQ remained in the conference room. Discussions related to past exceedance events continued, and site-specific meteorological data from April to June 2022 was requested (see Section II-a). It was also determined that the following benzene containing tanks are equipped with weighted manways and a nitrogen blanket: 926, 928, 929, 930 (out of service at time of inspection), 807, 808, 809, 810, 941, and 946. 5 EPA Inspection Report - Page 6 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 In the field, eGC EPA 1 was moved to downwind of Tank 926. Mr. Bobbs observed the top of Tank 926 and detected a constant plume of benzene concentrations of up to 120 ppm emanating from the weighted manways. Mr. Bobbs was told that the tank pressure was 1 inH2O and that the pressure vacuum breakers are set to 3.75 inH2O. Weighted manway set pressures are intended to be greater than the pressure vacuum breakers. Benzene concentrations of up to 1.5 ppm were detected at the pressure vacuum breakers. [AOC 5] Mr. Bobbs also observed that the ball valve for the hermetic gauge on the tank was missing a cap. [AOC 3] The team returned to the conference room around 11:30 am. Around 1pm, TCEQ received notification from their mobile monitoring team that benzene had been detected off-site, near the west fenceline of Total with winds coming from the east. Concentrations ranged from 5 to 10 ppb. It was determined that the detections were near sample station PA-11. The inspection team requested to go in the field to observe tanks that could be impacting the fenceline and have off-site impacts. Tanks that could contain benzene in the area include Tanks 562, 563, 531, 530, and 902. At approximately 2:20pm, Dr. Frey, Ms. Morrell, Mr. Miller, Mr. Bankole, Ms. Youngson, Ms. Froemming, and contractor Mr. Kris Brown (Senior Project Manager for LDAR and BWON) arrived on the road between Tanks 902 and 562. Ms. Morrell observed strong odors and elevated background VOC concentrations on the PID (0.05 to 0.20 ppm VOC). At the top of Tank 902, VOC concentrations ranged from 12 to 153 ppm. The inspection team could audibly hear the vacuum breakers opening and closing. The tag on the breakers indicated that the set pressure was 10 inH2O. Benzene concentrations as high as 1.575 ppm were recorded. [AOC 5] Tank 902 contains diesel. Mr. Miller captured OGI videos showing hydrocarbons emitting from component 22TV902B and the vacuum breaker (Video 1). At approximately 2:45pm, the inspection team approached Tank 562. On the ground, a benzene concentration of 0.725 ppm was detected. The team observed the top of the tank, which is equipped with an external floating roof, and Mr. Bankole estimated it was at around 50% full. Benzene concentrations as high as 0.575 ppm were recorded. Mr. Miller captured an OGI video showing hydrocarbon emissions from pipes on the roof (Video 2). [AOC 7] At approximately 3:30 pm, the inspection team entered the saturated liquids unit. No emissions were detected with the PIDs. Mr. Miller identified one gauge valve leak using the OGI camera. At approximately 4pm, the inspection team arrived at benzene Tanks 928, 929, and 930. Tank 930 was out of service. Emissions of VOC and benzene were detected at multiple locations at Tanks 928 and 929, see Table 1. [AOC 5] 6 EPA Inspection Report - Page 7 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 Table 1. Highest detected concentrations of VOC and benzene at various tanks. Tank Component Highest VOC concentration Highest benzene concentration Number Number detected detected Tank 807 22EV-1807 NA 117 ppm Tank 808 22EV-1808 NA 0.45 ppm Tank 926 22TEV-926 NA 146 ppm Tank 928 22TV-928A 12 ppm 1.725 ppm Tank 928 22TV-928B 3.0 ppm 0.400 ppm Tank 929 22TV-929A NA 0.075 ppm Tank 929 22TV-929B 0 ppm 0 ppm Tank 929 22EV-929 9.026 ppm 0.300 ppm At approximately 2:50pm, Mr. Bobbs and ERG relocated eGC EPA 2 to an area southwest of Tank 541. Afterwards, Mr. Bobbs observed the top of Tanks 541, 807, 808, 810, and 909. Mr. Bobbs discovered that the ball valves for the hermetic gauges on Tanks 807 and 810 were missing caps. [AOC 3] Mr. Bobbs detected bezene as high as 117 ppm at the weighted manway at Tank 807. He was told that the tank pressure was 0.5 inH2O at the time, while the pressure setting of the manway was between 1.8 and 3.6 inH2O. Mr. Bobbs climbed on top of Tank 808, but was not able to access the weighted manway on top of Tank 808 due to the catwalk limitations. Benzene was detected as high as 0.45 ppm on top of Tank 808 approximately 10 feet downwind of the Tank 808 weighted manway (Component 22EV-1808). Upwind of Tank 810, no benzene was detected and Mr. Bobbs was told that the nitrogen pressure was set at 5 inH2O. [AOC 5] Tank 909 contains diesel, and no emissions were detected. Hydrocarbon emissions were observed emanating from Tank 541. The tank is equipped with an external floating roof (Videos 3 and 4). [AOC 7] The inspection team departed the facility around 5:20pm. On September 16, 2022 the inspection team arrived at 7:10 am. Mr. Bobbs and ERG entered the field to disassemble eGC EPA 1 and eGC EPA 2. Dr. Frey, Ms. Morrell, Mr. Miller requested to observe Tanks 941 and 946. However, Ms. Geist informed us that the weighted manway lid on Tank 941 had "blown off" overnight and that the area was unsafe to review. We remained in the conference room and continued document review. Mr. Bobbs and ERG returned at 9:30am. At 9:35am, Mr. Bankole provided an updated status on Tank 941. When EPA had requested to observe all benzene containing tanks on the afternoon of September 15, Total sent a contractor to observe the tanks. The missing weighted manway lid was discovered around 12:30pm on September 15 via visual inspection. The lid was replaced around 7:45am on September 16. Total stated that handheld benzene detectors were used at ground level, and no benzene concentrations were detected. The tank level was 9 feet and it appeared that the nitrogen regulator/gauge seemed to be broken, per Mr. Bankole. [AOC 10] 7 EPA Inspection Report - Page 8 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 It is unclear why the inspection team was denied access to the tank when we first arrived. Mr. Bankole did offer to take us to tanks 941 and 946 at 10am, however it was raining, and the inspection team needed to prepare for the closing conference. Follow-up documentation was requested. Section II-a - Analysis of Facility Submitted Corrective Action Plans At multiple times during the inspection, the inspection team discussed the facility's root cause analysis, initial corrective actions, and submitted Corrective Action Plans ("CAPs") with Mr. Bankole and Ms. Howard. Below is a summary of multiple topics related to Total's CAPs, especially the most recent "Root Causes Analysis Status Report" dated August 24, 2022 (Appendix 6). Inspectors reviewed exceedance events and actions taken by Total to reduce fenceline concentrations below the action level, as required by 40 CFR 63.658. Developing a Site-Specific Monitoring Plan as a Corrective Action Total's CAP dated August 24, 2022 (Appendix 6) states, "The Refinery is using a consultant to evaluate and prepare a Site-Specific Monitoring Plan (SSMP)..." with a tentative implementation date of December 31, 2022. Total also cites the development of a SSMP as a corrective action in their May 14, 2022, February 14, 2022, and November 12, 2021 CAPs (with completion dates of June 30, 2022). Total first mentioned the use of a contractor to develop a SSMP in their August 13, 2021 CAP. However, in discussions with Mr. Bankole, the statement the August 24, 2022 CAP was not accurate and Total was not planning on submitting a SSMP to EPA. [AOC 8] Vacuum Truck Procedures In CAPs dated July 3, 2019 and August 29, 2019, Total stated: "For PA-01.6, the individual sampler station results were above 9.0 g/m3 for two sampling periods. The cause for the elevated benzene at PA-01.6 appears to be due to exceeding the VOC concentration at a vacuum truck's carbon absorption system (CAS) that was being used to abate hydrocarbon emissions while removing Dock 1 from service and while Dock 1 was being put back in service following planned maintenance and inspection." No specific corrective actions were proposed for this root cause. It does not appear that vacuum truck procedures were cited as a root cause in any following CAPs. However, in Total's CAP dated September 30, 2020, a corrective action was added to review vacuum truck procedures by October 31, 2020. Total wrote that this action was to ensure vacuum truck emissions will not impact the fenceline when used for clearing sumps, piping, and equipment near the fenceline. In Total's CAP dated December 8, 2020, the self-imposed deadline for this corrective action was extended to January 31, 2021. In Total's CAP dated February 12, 2021, the item was marked completed on January 31, 2021 with a statement, "The vacuum truck procedure will be revised and routed for authorization with the updates resulting from the review." The inspection team requested a copy of the updated vacuum truck procedures while onsite. The procedures stated that the last revision date was June 2, 2020. Dr. Frey inquired if that date was accurate, and Mr. Bankole stated that it was correct. It is unclear why reviewing the vacuum truck 8 EPA Inspection Report - Page 9 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 procedures was an appropriate corrective action and why it was deemed revised and completed in January 2021 when the document itself was last revised in June 2020. [AOC 8] Heat Exchanger Leak into Cooling Tower Total attributed 2nd quarter 2022 exceedances at sample sites PA-14 and PA-15 to heat exchanger leaks into the FPM cooling tower. Every month, the cooling tower water is tested for strippable fugitive VOC emissions using the El Paso Method. Per Total's permit, VOC concentrations of 0.08 ppm or greater must be repaired as soon as practical, but no later than the next shutdown. VOC concentrations of 0.8 ppm or greater requires immediate action. PA-14 is approximately 120 yards northwest from where cooling tower samples are collected (Photos 2 and 3). PA-15 is approximately 500 yards northeast from where cooling tower samples are collected (Photo 4). Table 2 shows the 2-week benzene concentrations at PA14 and PA-15. Table 3 is a timeline of heat exchanger repairs, sampling results, and facility actions. Table 2. Biweekly concentrations of benzene at sample sites PA-14 and PA-15. Sampling Period PA-14 Benzene PA-15 Benzene End Date Concentration (g/m3) Concentration (g/m3) 4/26/2022 10.8 19 5/9/2022 8.61 15.3 5/24/2022 9.55 4.23 6/6/2022 8.0 3.38 6/20/2022 1.34 2.88 7/5/2022 1.12 1.94 Ms. Morrel inquired if the excess emissions event due to a heat exchanger leak in May 2022 was reported to TCEQ. Ms. Howard confirmed no report had been submitted and Mr. Bankole stated that the calculations would be worked on by Total's engineering team. [AOC 9] EPA observed that concentrations of benzene at PA-15 were elevated prior to the discovery of the heat exchanger leak, and decreased from April to July. EPA observed that concentrations at PA-14 were the highest during the sample period ending April 26, 2022. Due to the lack of data correlation and the average daily wind direction, it is unlikely that a single event was the cause of elevated results at both sample sites. It is possible that a separate event occurred closer to PA-15 in April, that also impacted PA14, prior to the heat exchanger leak detected May 24, 2022. [AOC 4] Another heat exchanger leak was detected on August 22, 2022. It is unclear what is causing the heat exchangers to fail, and a "Mode of Failure" report is pending. Per Mr. Bankole, heat exchanger bundles are expected to last longer than 5 years. 9 EPA Inspection Report - Page 10 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 Table 3. Timeline of events related to heat exchanger leak impacting VOC concentrations at the FPM cooling tower, per Mr. Bankole. Date Action September 2021 Crude Unit shutdown October 2021 New heat exchanger bundles installed April 19, 2022 FPM Cooling Tower passed testing (0.01 ppm) May 23, 2022 FPM Cooling Tower failed testing (13.40 ppm) May 26, 2022 Environmental Department notified of elevated VOC emissions June 1 to 2, 2022 Water flow reversed at leaking heat exchangers June 3, 2022 FMP Cooling Tower passed testing (0.01 ppm) Sample periods ending 4/26/22 and 5/9/22 fenceline results received June 23, 2022 Heat exchangers removed from service June 25, 2022 New bundles installed, repairs complete, heat exchangers returned to service July 7, 2022 FMP Cooling Tower passed testing (0.01 ppm) August 22, 2022 FMP Cooling Tower failed testing (11.27 ppm) Water flow reversed at leaking heat exchangers August 23, 2022 FMP Cooling tower passed testing (0.01 ppm) 2022 Exceedance at Sampler Station PA-1.6 In the August 24, 2022 CAP, Total attributed the May 9 to May 24, 2022 exceedance at sample site PA1.6 to annual dock testing being conducted on May 11, 12, 16, and 17. [AOC 11] The laboratory results showing the exceedance were received on June 16, 2022. The sample result for PA-1.6 was 81 g/m3 for the two-week period. The corrective action was to "charter an investigation team" to review each phase of dock testing, to be completed by September 30, 2022, 106 days after receiving the sampler results. [AOC 8] Dr. Frey received a copy of a September 11, 2022 "Incident Investigation Status Report". The report references two real-time analyzers having exceedances on May 24, 2022 with values ranging from 64.6 g/m3 to 412 g/m3 during the time period of 2:26 pm and 4pm. The report states that the exceedance reflected in sample site PA-1.6 appears to be the result of maintenance activity occurring at Dock 1, when two sump header valves were replaced on May 24, 2022. [AOC 11] The preliminary findings include that sump head piping was not flushed with soap and water, further evaluation is needed to determine if the system has adequate bleeders, and that dock operators did not receive notifications of the real-time analyzer exceedances. [AOC 2] Dr. Frey requested the Standard Operating Procedures ("SOP") for this maintenance activity, but per Mr. Bankole, no SOP currently exists. Dr. Frey then reviewed the benzene fenceline Sample Report from the laboratory which shows that the 2-week sample at PA-1.6 was collected at 10:23am on May 24, 2022. This makes it impossible for the event occurring from 2:26pm to 4pm on May 24 to impact the sample period from May 9 to May 24, 2022. [AOC 4] 10 EPA Inspection Report - Page 11 of 48 Section III - AREAS OF CONCERN TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 EPA Region 6 inspector Sarah Frey and EPA AED inspector Nicholas Bobbs conducted a closing conference at TotalEnergies Petrochemicals & Refining USA, Inc. Port Arthur Refinery at 12:00 PM on September 16, 2022 for the inspection. During the closing conference, Dr. Frey and Mr. Bobbs reviewed following Areas of Concern ("AOC") noted during the inspection. The sign-in sheet for the closing conference is included as Appendix 7. Digital copies of all photographs and OGI videos were shared with the facility electronically during and after the inspection. The facility informed Dr. Frey of any photos or documents that they would be claiming as CBI. Mr. Bankole kept detailed receipts of documents taken offsite by inspectors. We departed the facility around 1:30 pm. 1) Elevated concentrations of benzene were recorded by the eGCs before, during, and after active barge loading. 2) Inspectors observed barriers to timely responses to real-time analyzer data. Creating standard operating procedures, documenting actions taken, and conducting a barrier analysis could improve response timeliness and effectiveness. 3) Inspectors observed open-ended lines, or missing caps, on the ball valves for hermetic gauges on Tanks 807, 808, 809, 810, and 926. 40 CFR 61.242-6(a)(1) requires that all open-ended lines be equipped with a cap, blind flange, plug, or a second valve. 40 CFR 61.242-6(a)(2) requires that the cap, blind flange, plug, or second valve shall seal the open end at all times except during operations requiring process fluid flow through the open-ended valve or line. 4) Inspectors observed inaccurate and ineffective root cause analyses for exceedance events. 40 CFR 63.658 requires the Facility to initiate a root cause analyses to determine the causes of exceedances and to determine appropriate corrective actions. 5) Inspectors observed and detected elevated concentrations of VOC and benzene from multiple vacuum breakers and weighted manways at Tanks 902, 926, 928, 929, 807, 808, and 810. This may be a potential source of benzene impacting the fenceline. 6) Inspectors observed that the actual coordinates of the passive samplers do not match the coordinates in Total's quarterly reports required by 40 CFR 63.655(h)(8)(iii). 7) Inspectors observed hydrocarbon emissions at Tanks 541 and 562, which are equipped with external floating roofs. Videos 2, 3, and 4. 8) Inspectors observed that Corrective Action Plans, as required by 40 CFR 63.658(h) and submitted to TCEQ, contain inaccurate information and inadequate actions to reduce fenceline concentrations below the action level. 9) The heat exchanger leak detected on May 23, 2022 was not reported until September 13, 2022, 113 days after the incident and 1 day after EPA began their inspection. The calculations submitted on September 13, 2022 revealed a release of 134 lbs of benzene, over 13 times higher than the reportable quantity of 10 lbs. This may be a violation of The Emergency Planning and Community Right-to-Know Act ("EPCRA") Section 304. Further, 30 TAC 101.201 requires that companies must submit an initial notification in the State of Texas Environmental Electronic 11 EPA Inspection Report - Page 12 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 Reporting System ("STEERS") within 24 hours of discovery of the emissions event if a reportable quantity will be exceeded and a final report is due two weeks from the end of the event after the entity has fully evaluated the incident. 10) Inspectors observed reoccurring issues related to the nitrogen gas regulators, pressure gauges, and associated set pressures for Tanks 926 and 807. Tank 941 may have similar problems occurring. 11) Inspectors observed the attribution of routine maintenance activities to elevated benzene concentrations at the fenceline. Procedures should be implemented in order to reduce emissions associated with regular activities. Section IV - FOLLOW UP The following information was received by EPA after exiting the Facility on September 16, 2022: September 22, 2022 - EPA and Total had a conference call to discuss the document request status and details relating to Tank 926. EPA requested additional documents. Total provided a summary of actions taken since EPA departed the facility on September 16. This included the decision to hire a third-party to evaluate and respond to benzene emissions detected by real-time analyzers, as well as evaluating all tanks at the refinery for fugitive emissions. Additionally, steps are being taken to alter the automated alerts sent in response to benzene emissions detected at the real-time analyzers. Discussions have been held with neighboring facilities and barge companies to address fenceline benzene impacts from off-site sources. October 12, 2022 - EPA and Total had a conference call to discuss the document request status and facility's emissions inventory process. Total shared that all caps of open-ended lines had been replaced and that the gauging company will be instructed to notify facility personnel if caps are missing. October 27, 2022 - Total provided stack test procedures to TCEQ with a tentative test date the week of December 12, 2022 for two of the three thermal oxidizers. November 10, 2022 - EPA and Total had a conference call to discuss additional corrective actions taken to date. Total shared that repairs had been made at Tanks 902 and 562. The pressure settings and weights of vacuum breakers and weighted manways on tanks are being evaluated by engineers. However, problems with the nitrogen regulator on Tank 926 persists. Total stated that the tank and its associated thermal oxidizer are being closely monitored to prevent excess emissions. Additionally, Total contracted a third party to review the barge loading process and identify engineering solutions to reduce emissions. Total also stated that improvements and training are being implemented for the investigation of exceedances detected by the real-time analyzers. 12 EPA Inspection Report - Page 13 of 48 Section V - LIST OF APPENDICES TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 Appendix 1 - Photograph Log - 4 photos Appendix 2 - Video Log - 4 OGI videos Appendix 3 - Opening conference sign-in sheet Appendix 4 - ERG eGC Report to EPA Appendix 5 - Document Request Appendix 6 - CAP, "Root Causes Analysis Status Report" dated August 24, 2022 Appendix 7 - Closing conference sign-in sheet 13 EPA Inspection Report - Page 14 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 Appendix 1 Photograph Log EPA Inspection Report - Page 15 of 48 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: TotalEnergies Petrochemicals & Refining USA, Inc. - Port Arthur Refinery City: Port Arthur County/Parish: Jefferson State: Texas Photo File Name: DC_0201.jpg Date of Photo: 9/14/2022 Time of Photo: 11:48 am Photographer: Bobbs Description: Tank 808 ball valve for the hermetic gauge missing a cap. Open-ended line. EPA Inspection Report - Page 16 of 48 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: TotalEnergies Petrochemicals & Refining USA, Inc. - Port Arthur Refinery City: Port Arthur County/Parish: Jefferson State: Texas Photo File Name: DSCN0590.jpg Date of Photo: 9/13/2022 Time of Photo: 4:24 pm Photographer: Frey Description: Passive benzene sampling station PA-14, taken from location that cooling tower water samples are collected. Between two cooling towers. Arrow and text box added for clarity. EPA Inspection Report - Page 17 of 48 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: TotalEnergies Petrochemicals & Refining USA, Inc. - Port Arthur Refinery City: Port Arthur County/Parish: Jefferson State: Texas Photo File Name: DSCN0591.jpg Date of Photo: 9/13/2022 Time of Photo: 4:24 pm Photographer: Frey Description: Zoomed in view of passive benzene sampling station PA-14, taken from location that cooling tower water samples are collected. Between two cooling towers. Arrow and text box added for clarity. EPA Inspection Report - Page 18 of 48 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: TotalEnergies Petrochemicals & Refining USA, Inc. - Port Arthur Refinery City: Port Arthur County/Parish: Jefferson State: Texas Photo File Name: DSCN0593.jpg Date of Photo: 9/13/2022 Time of Photo: 4:47 pm Photographer: Frey Description: Passive benzene sampling station PA-15 with cooling towers in the background. Arrows and text boxes added for clarity. EPA Inspection Report - Page 19 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 Appendix 2 Video Log EPA Inspection Report - Page 20 of 48 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 2 Location: TotalEnergies Petrochemicals & Refining USA, Inc. - Port Arthur Refinery City: Port Arthur County: Jefferson State: Texas Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_0062.mp4 9/15/2022 2:42 pm Miller Infrafed OGI video of emissions from emergency weighted manway located on top of diesel Tank 902 where elevated readings were recorded with handheld monitoring equipment. Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_0064.mp4 9/15/2022 2:56 pm Miller Infrared OGI video of emissions from an external floating roof, Tank 562. Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_0214.mp4 9/15/2022 2:56 pm Bobbs Infrared OGI video of emissions from Tank 541, observed emanating from the rim seal on the north side. Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_0217.mp4 9/15/2022 3:16 pm Bobbs Infrared OGI video of emissions from Tank 541, observed from ground level. Page 1 of 1 EPA Inspection Report - Page 21 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 Appendix 3 Opening Conference Sign-In Sheet EPA Inspection Report - Page 22 of 48 EPA Inspection Report - Page 23 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 Appendix 4 ERG eGC Report to EPA EPA Inspection Report - Page 24 of 48 Inspection Date(s): Name ERG Staff Alexia Scott Liz Hubbard EPA Staff Nick Bobbs Sarah Frey eGC Air Monitoring TARGETING/INSPECTION REPORT September 12, 2022 - September 16, 2022 Inspection Announced: {Yes} Email Alexia.Scott@erg,com Elizabeth.Hubbard@erg.com Bobbs.Nicholas@epa.gov Frey.Sarah@epa.gov Facilities Inspected: Name Address TotalEnergies Petrochemical and Refining USA, INC 7600 32nd St, Port Arthur, TX 77642 On Site? Yes eGC Target Compound Benzene eGC No. EPA 1, EPA 2 Canister Sample Collected No 1 EPA Inspection Report - Page 25 of 48 SECTION I - INTRODUCTION Background Information From September 12, 2022 through September 16, 2022, Alexia Scott and Liz Hubbard of ERG performed mobile air monitoring using the ENMET environmental Gas Chromatograph (eGC) at TotalEnergies Petrochemical and Refining, Inc. in Port Arthur, TX. ERG was joined by several staff from the EPA and TCEQ who provided direction on eGC placement. The purpose of the inspection was to investigate high levels of fence-line Benzene and identify possible sources. The eGCs were deployed to aid in source detection. ERG deployed eGC EPA 2 in the TotalEnergies facility on September 12th and deployed eGC EPA 1 on September 13th. Both eGCs were left in the facility over-night and were moved to several different locations within the facility during the inspection. SECTION II - OBSERVATIONS Quality Assurance The eGCs are capable of detecting Benzene through a semi-continuous 10-minute sample cycle. Enmet advertises the analysis range of the eGCs to be between 0.3 - 200 ppb. A pre-deployment calibration curve was independently generated by ERG to verify the eGCs performance. Both eGCs were independently tested and verified at a range of 0.5 - 50 ppb. The results of this pre-deployment testing are available as Appendix 2. The eGCs are also equipped with a one-point auto calibration feature, which is produces a calibration factor (CalFactor). The eGCs were calibrated with this feature upon initial set up at the site and when they were moved from site to site. All calibrations performed during the inspection are collated in the "Calibration" tab in the data sheet which is available as Appendix 1. The calibrations were also judged for quality based on the QAPP criteria. The QAPP criteria for calibrations stated that calibrations must have a relative precent difference (RPD) of within 15% when compared to the calibration cylinder concentration. Calibration quality fell into three categories: Good - Good calibrations satisfied the QAPP criteria, and the subsequent data was not flagged; Tentative - tentative calibrations did not satisfy the QAPP criteria but the CalFactors produced were reasonable therefore data was flagged but not corrected. Data flagged after a tentative calibration have their corresponding CalFactors flagged with a yellow highlight. Bad - bad calibrations did not satisfy the QAPP criteria and the CalFactor produced was unreasonable therefore data was flagged and post-corrected. Data flagged from a bad calibration was corrected using the nearest reasonable CalFactor. The corrected data's CalFactors have been flagged in the dataset with an orange highlight. The data was corrected using a Concentration Calculator provided by Enmet which is Appendix 3. 2 EPA Inspection Report - Page 26 of 48 The eGCs are also equipped with wind sensors, these sensors must be directionally oriented to provide accurate data. The wind sensors were appropriately oriented at the initial eGC sites and reoriented whenever the eGCs were moved. eGC Site Observations Figure 1. Total eGC Sites EPA 1 - Loading Docks Table 1. Summary of EPA 1 Sites Site Code GPS Location Start Date/Time End Date/Time EPA 1A 29.9802, -93.8804 09/13/22 12:36 AM 09/14/22 3:16 PM EPA 1B 29.98025, -93.88085 09/14/22 3:30 PM 09/15/22 9:34 AM EPA 1C 29.9785, -93.88275 09/15/22 10:00 AM 09/16/22 8:46 AM Highest Reading 173.8 ppb 128.1 ppb 23.85 ppb 3 EPA Inspection Report - Page 27 of 48 Figure 2. EPA 1 eGC Site Overview EPA 1A Site EPA 1A was the first site that EPA 1 was positioned at; the site is located southeast of Dock 3A which is downwind of the dock. EPA 1 was set up at approximately 12:36 pm on September 13, 2022 and ran at site EPA 1A until 3:16 pm on September 14, 2022. The wind during this time frame came predominantly from the northeast and east and was slow, averaging at approximately 0.5 mph. Notable eGC Activity Significant benzene readings were reported from EPA 1 between 2:26 pm - 6:65 pm on September 13, 2022. The highest reading during this window was 48.92 ppb at 6:26 pm. Wind during this period was predominantly coming from the north and north-northeast with wind speed at approximately 1.0 - 1.5 mph. Significant benzene readings were reported from EPA 1 between 6:36 am - 8:36 am on September 14, 2022. The highest reading during this window was 173.8 ppb at 7:46 am. Wind during this period was predominantly coming from the north and north-northeast with wind speed at approximately 0 - 1 mph. 4 EPA Inspection Report - Page 28 of 48 EPA 1B Figure 3. EPA 1B Site EPA 1B was the second site of EPA 1, this site was located several yards east of site EPA 1A and was still downwind of Dock 3A. EPA 1 was set up at this site at approximately 3:30 pm on September 14, 2022 and stayed there until 9:34 am on September 15, 2022. During this time the wind came from the east-northeast and east, wind speed averaged at around 1.0 - 1.5 mph. Notable eGC Activity A single benzene reading of 78.56 ppb was reported at 5:16 pm on September 14, 2022. Wind was from the east at approximately 1.25 mph. Significant benzene readings were reported between 8:26 pm - 10:15 pm on September 14, 2022. The highest reading during this time period was 128.1 ppb at 9:06 pm. Winds during this window were coming from the east-northeast at a strength of approximately 1.0 - 1.5 mph. 5 EPA Inspection Report - Page 29 of 48 EPA 1C Figure 4. Site EPA 1C Site EPA 1C was the third site where EPA 1 was positioned, this site was established downwind of T 926. EPA 1 was set up on an access road southeast of T 926 at approximately 10:00 am on September 15, 2022. EPA 1 stayed at this site until 8:46 am on September 16, 2022. This was the last site EPA 1 was set up at during this inspection. Winds came predominantly from the east to southeast with a wind speed of approximately 0.5 - 2.5 mph. Notable eGC Activity Significant benzene readings were reported between 1:16 am - 1:56 am on September 16, 2022. The highest reading was 23.85 ppb at 1:46 am. The wind was coming from the eastsoutheast at approximately 0.5 mph. Significant benzene readings were reported between 2:56 am - 3:16 am on September 16, 2022. The highest reading was 19.87 ppb at 1:46 am. The wind was coming from the eastsoutheast at approximately 0.75 mph. Significant benzene readings were reported between 4:06 am - 4:36 am on September 16, 2022. The highest reading was 8.66 ppb at 4:06 am. The wind was coming from the east at approximately 0.75 - 1.5 mph. 6 EPA Inspection Report - Page 30 of 48 Significant benzene readings were reported between 5:56 am - 6:16 am on September 16, 2022. The highest reading was 7.64 ppb at 6:06 am. The wind was coming from the east at approximately 1.0 - 1.5 mph. EPA 2 - Benzene Storage Table 2. Summary of EPA 2 Sites Site Code GPS Location Start Date/Time End Date/Time Highest Reading EPA 2A 29.95895, -93.8844 09/12/2022 1:30 PM 09/13/2022 10:49 AM 6.72 ppb EPA 2B 29.9587, -93.8853 09/13/2022 11:02 AM 09/14/2022 10:56 AM 9.72 ppb EPA 2C 29.9583, -93.88475 09/14/2022 11:14 AM 09/15/2022 2:16 PM 8.75 ppb EPA 2D 29.96078, -93.8837 09/15/2022 2:30 PM 09/16/2022 7:57 AM 1.74 ppb Figure 5. EPA 2 eGC Site Overview 7 EPA Inspection Report - Page 31 of 48 EPA 2A Site EPA 2A is the first location EPA 2 was deployed at during the inspection. The site was located in between several tanks including T807, T808, T809, T810. Two thermal oxidizers (TO) were also in this area and the BASF fence line is southeast of the site. EPA 2 was set up at approximately 11:00 am on September 12, 2022 and stayed at this site until approximately 10:49 am on September 13, 2022. The wind was coming from between the east-southeast and east-northeast at a speed of approximately 0.75 to 1.5 mph. Notable eGC Activity Significant benzene readings were reported between 8:56 am - 9:46 am on September 13, 2022. The highest reading in this window was 6.72 ppb at 9:46 am. The wind was coming from the northeast at a speed of approximately 1.0 mph. This data was post-corrected to adjust for poor eGC calibrations in the field. EPA 2B Site EPA 2B is located southeast of EPA 2A and the benzene tanks on a service road, the site was also northwest of the BASF fence line. EPA 2 was set up at this site at approximately 11:02 am on September 13, 2022 and stayed there until 10:56 am on September 14, 2022. The wind during this time was coming from the north and northeast at a speed of 1.0 - 2.5 mph. Notable eGC Events Significant benzene readings occurred between 12:36 pm - 2:06 pm on September 13, 2022. The highest reading in the window was 5.46 ppb at 1:36 pm. The wind during this period was coming from the northeast and east at a strength of 1.5 - 2.5 mph. A significant benzene event occurred between 10:26 pm - 11:06 pm on September 13, 2022. The highest reading in the window was 9.72 ppb at 11:06 pm. The wind during this period was coming from the north-northeast at a strength of 0.5 - 1.0 mph. EPA 2C Site EPA 2C was located further southeast on the same service road as EPA 2B. EPA 2C is located south of the benzene tanks and thermal oxidizers and northwest of the BASF fence line. EPA 2 was set up at approximately 11:14 AM on September 14, 2022 and stayed at EPA 2C until 2:16 PM on September 15, 2022. The wind during this timeframe was coming from the north-northeast at a speed of 0.5 - 2.5 mph. Notable eGC Events A single benzene reading of 5.94 ppb was reported at 3:36 pm on September 14, 2022. Wind was from the northeast at approximately 2.0 mph. Significant benzene readings were reported between 11:26 pm on September 14, 2022 and 12:26 am on September 15, 2022. The highest reading in this window was 5.59 ppb at 11:36 pm. The wind was coming from the north at a speed of 1.0 - 1.5 mph. 8 EPA Inspection Report - Page 32 of 48 Significant benzene readings were reported between 5:36 am and 6:16 am on September 15, 2022. The highest reading in that window was 8.75 ppb at 5:36. The wind was from the northnortheast at approximately 1.5 mph. EPA 2D Figure 6. EPA 2D Site EPA 2D was located downwind of T 541 and T 960 at the corner of a service road. This site was further north than the other EPA 2 sites. EPA 2 was moved to this site at approximately 2:30 pm on September 15, 2022 and stayed there until approximately 7:56 am on September 16, 2022. This was the last site that EPA 2 was stationed at during this inspection. The wind came from the north-northeast and the east during this time and had a strength of 0.5 - 2.0 mph. Notable eGC Events The EPA 2 did not have any notable events at this site. Calibration Discussion By default, the eGCs calibrate every 6 hours and the 15% RDP QA requirement was designed for that calibration schedule. That calibration schedule was, however, turned off for this deployment and eGCs were calibrated manually. eGCs were calibrated upon setup and when they were moved from site 9 EPA Inspection Report - Page 33 of 48 to site, this means they were calibrated less frequently than every 6 hours. This caused more drift to occur in the data and increased the amount of "tentative" graded calibrations. EPA 2 also experienced an issue which caused the device to fail several calibrations, which is why several "bad" calibrations are present in the data and several subsequent "tentative" calibrations followed. Tentative calibrations followed bad calibrations because eGCs can take several calibrations before they produce "good" calibrations after a bad calibration is performed. Calibration runs display the concentration based off the last previous CalFactor but display the newly generated CalFactor, this means tentative calibrations can look erroneous because of a previously bad calibration even if that tentative calibration generates a good CalFactor. The generated CalFactor is what the subsequent data will be calculated with so if the CalFactor is reasonable then the subsequent data is also reasonable. SECTION III - Results The data collected by EPA 1 and EPA 2 are included as Appendix 1. The data was downloaded from the Enmet eGC webserver and has been divided into tabs based on site. There are also tabs for the collated calibrations and for the raw corrected data. Table 3 provides a description of each column of the data. Column DATESTAMP TIMESTAMP RECORD RunType Vapor Concentration Table 3. Summary of Data Column Labels Description Universal Time Zone Date and Time Central Time Zone Date and Time - This time marks the end of the analytical cycle of the device. The sample time starts at the top of every 10-minute mark. Ex: TIMESTAMP 05:26:16 am means a sample was collected starting at 05:20:00 am and the analytical period ended at 05:26:16 am. Number label assigned to that specific data point "MEAS" - data point represents a measurement made by the eGC. "CAL" - data point represents a calibration made by the eGC Describes the target compound of that eGC This is the calculated concentration produced from the eGC integration results. This value is based off peak height, the pre-programed linearization coefficients and the r-factor. Reports in part-per-billion, ppb. Orange cells signify corrected data. 10 EPA Inspection Report - Page 34 of 48 PeakHeight PeakLocation CalFactor ColTemp Baseline Ver RunCount Status Latitude Longitude WS_ms WS_avg WindDir WS10avg WD10avg WD10sd Battery_Voltage EnclosureTemp Yellow cells signify data which follows a Tentative calibration run. Reports the height of the target peak for that run Reports retention time of the target peak for that run For MEAS runs, reports the calibration factor used when calculating the concentration for that run, For CAL, reports the new calibration factor generated from the calibration run. Report the column temperature at the time of reporting Reports the baseline for that run Reports the eGC software version Reports the number label of that run Reports the status of the run, if OK the run was acceptable. Reports the latitude of the eGC at the time of reporting Reports the longitude of the eGC at the time of reporting WS_ms is a snapshot of the wind speed m/sec when the analysis is complete and is sent to the data logger. The end of the analysis run may vary depending on the application. WS_avg is the average wind speed during the "sampling" time of the GC. It is during the first two minutes of the cycle. WindDir is in degrees, data is collected every one second for 120 seconds, and the average is displayed example (ENE 76) WS10avg is the average wind speed during 5 to 15 minutes of the analysis cycle. Units are m/sec WD10avg is the average wind direction during 5 to 15 minutes of the analysis cycle. Units are Degrees WD10sd is the deviation during the 10 minutes average of both the Wind Speed and Wind Direction during the measured 10-minute period. Reports battery voltage at the time of reporting Reports enclosure temperature in Celsius at the time of reporting 11 EPA Inspection Report - Page 35 of 48 EngineTemp AlarmLevel Reports engine temperature in Celsius at the time of reporting Reports the alarm level based on the reported concentration. SECTION IV - Conclusions As of the completion of this report, ERG was not aware of any follow-up activities from the EPA pertaining to any of these facilities. All conclusions and decisions to follow-up on the findings presented here will be solely at the determination of the U.S. EPA. SECTION V - Appendix Attachment 1 - Total eGC Data (.xlsx file) Attachment 2 - Pre-deployment eGC Benzene Curves (.xlsx file) Attachment 3 - eGC Benzene Concentration Calculator (.xlsx file) 12 EPA Inspection Report - Page 36 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 Appendix 5 Document Request EPA Inspection Report - Page 37 of 48 TotalEnergies Petrochemicals and Refining USA, Inc., Port Arthur Refinery PORT ARTHUR, TEXAS EPA REGION 6 RECORDS/DOCUMENTS REQUEST GENERAL PROCEDURE During the Clean Air Act (CAA) compliance investigation at TotalEnergies Petrochemicals and Refining USA, Inc., Port Arthur Refinery ("Refinery") inspectors will be reviewing records kept for your facility. To expedite this portion of the investigation, EPA is providing you advanced notification of the records that will likely be reviewed on-site. For most documents, EPA will review the records on-site and request copies, as needed. In certain cases, document copies, either electronic or paper, will be requested for later review by EPA. In preparation for this compliance investigation, EPA has divided this record and document request into two sections. The first section consists of documents that EPA would like available, and copies prepared (as noted) on September 6, 2022. The second section consists of documents that EPA would like available electronically (through a shared FTP website) no later than September 8, 2022. Other documents may also be requested that are not listed. During the investigation, EPA will work with the Refinery to develop a schedule to review these documents. PART 1 - Please have these documents available on September 6, 2022 1. Provide all benzene air monitoring data in an electronic searchable and editable spreadsheet, for samples taken within and outside the Total Port Arthur Refinery between October 21, 2021 and receipt of this Request, from both permanent and temporary air monitoring locations, including, but not limited to: a. The twenty-two (22) additional temporary samplers, installed in July 2019. b. The four real-time analyzers purchased and installed between July and August 2021. 2. Provide barge loading and unloading schedule for week of September 5 including a. Type of product being loaded or unloaded b. The dock location of the barge loading/unloading, if known c. The tanks being filled/drawn from. 3. Provide all documents pertaining to root cause analyses initiated between February 14, 2022 through the receipt of this letter to determine the cause of any exceedances of the benzene action level (9 g/m3) established in 40 C.F.R. Part 63, Subpart CC (hereinafter, "MACT CC"). 4. Provide an inventory of all tanks, including tank contents, located at the Total Port Arthur Refinery. 5. Provide a detailed map of the facility layout, including tank numbers, process vent IDs, fenceline monitoring locations (both permanent and temporary), and real-time analyzers. 6. Provide a current status update of the project to permanently route emissions from Tank 807 (and Tank 805) to an emission control device. 7. Provide a current status update of the investigation into the fenceline monitoring spikes for PA1.6 from May 9, 2022 to May 24, 2022, including but not limited to: a. Barge loading and unloading EPA Inspection Report - Page 38 of 48 b. Vacuum truck operations in the refinery dock area c. Marine loading vapor control device operating parameters d. Any relief valve maintenance PART 2 - Please have these documents available by September 8, 2022 1. Provide temperature records for the thermal oxidizers since installation of temperature indicators. 2. Provide the SOP for vacuum truck operations, including updates due to the review of vacuum truck procedures referenced in the root cause analysis submitted on February 14, 2022. 3. Provide a description of the corporate hierarchy and relationship between TotalEnergies Petrochemicals & Refining, USA, Inc. and BTP, including a description of which facility owns and operates tanks 807, 808, 809, 810 and TO 22BZNTHFLR. 4. Provide the following information for Tanks 926, 454, 530, 589, 522, 908, 482, 807, 808, 809, 810: a. Contents of tank (If swing tank, list current contents as of week of September 5, 2022 as well as other contents stored since January 1, 2019 and any planned changes to contents) b. Type of tank (internal floating roof, fixed roof, etc.) c. Type of rim seals (primary and secondary) if applicable d. Tank dimensions e. Date of last tank visual inspection, rim-seal inspection, and 10-year inspection 5. Provide test protocol for upcoming stack test of Thermal Oxidizers for Tank 808. 809, 810 and the Thermal Oxidizer for Tank 926. 6. Provide temperature records for the thermal oxidizers since installation of temperature indicators. EPA Inspection Report - Page 39 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 Appendix 6 Facility Submitted Corrective Action Plan "Root Causes Analysis Status Report" dated August 24, 2022 EPA Inspection Report - Page 40 of 48 EPA2-TEPRI002902 EPA Inspection Report - Page 41 of 48 EPA2-TEPRI002903 EPA Inspection Report - Page 42 of 48 EPA2-TEPRI002904 EPA Inspection Report - Page 43 of 48 EPA2-TEPRI002905 EPA Inspection Report - Page 44 of 48 EPA2-TEPRI002906 EPA Inspection Report - Page 45 of 48 EPA2-TEPRI002907 EPA Inspection Report - Page 46 of 48 EPA2-TEPRI002908 EPA Inspection Report - Page 47 of 48 TotalEnergies Petrochemicals & Refining USA, Inc. / Port Arthur Refinery Inspection Date 09/12/2022 Appendix 7 Closing Conference Sign-In Sheet EPA Inspection Report - Page 48 of 48