Document rpxZy0nJnq1RKm5RDw6j4KM0V

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1 5 POST OFFICE SQUARE, SUITE 100 BOSTON, MASSACHUSETTS 02109-3912 Clean Air Act Inspection Report Report Date: Draft: October 18, 2024 Final: October 28, 2024 I. Background EPA Inspectors: Digitally signed by GRACE Grace Perry, Environmental Engineer, Air Compliance Section, Region 1 GRACE PERRY Date: 2024.10.28 09:37:59 PERRY -04'00' Steve Rapp, Environmental Engineer, Air Enforcement Division, Office of Enforcement and Compliance Assurance (OECA) EPA Reviewer: John Melcher, Senior Enforcement Coordinator, Air Compliance Section, Region 1 Inspection Date: October 8, 2024 Digitally signed by JOHN JOHN MELCHER Date: 2024.10.28 09:52:21 MELCHER -04'00' Facility Name: R. M. Packer Company, Inc. Facility Location: 188 Beach Road, Tisbury, MA 02568 Mailing Address: PO Box 308, Vineyard Haven, MA 02568 ICIS Air ID#: MA0000002512000397 Disclaimer: Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. Inspection Attendees Name Grace Perry Steve Rapp Joe Canzano Newt Tedder Margarita Chatterton Daniel Gavin Jenifer Carter Glenn DeBlase Susan Courtney Skip Bailey Title Environmental Engineer Environmental Engineer Environmental Engineer Physical Scientist Environmental Engineer Multimedia Inspector Multimedia Inspector Compliance Officer Safety Consultant Driver Organization U.S. EPA Region 1 U.S. EPA OECA U.S. EPA Region 1 U.S. EPA Region 1 U.S. EPA Region 1 MassDEP MassDEP R.M. Packer John W. Furrh Associates R.M. Packer Facility/Process Description: The R.M. Packer Company in Tisbury, Massachusetts, ("Packer," or "the facility") is a petroleum distribution and storage facility that provides services to businesses and residents of Martha's Vineyard. The facility stores and distributes diesel, gasoline, and fuel oil. The terminal is equipped with a vapor recovery unit ("VRU") to control emissions from the storage and distribution of gasoline. The facility is owned by Ralph Packer and was purchased in 1979 from Texaco. Potentially Applicable Federal Regulations: 40 CFR Part 60 Subpart XX: Standards of Performance for Bulk Gasoline Terminals That Commenced Construction, Modification, or Reconstruction After December 17, 1980, and On or Before June 10, 2022 40 CFR Part 63 Subpart BBBBBB: National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities R.M. Packer Company, Inc.: Court-Ordered Injunctive Relief, Filed 9/27/2019 State Air Regulations: 310 C.M.R. 7.24 (2): Bulk Terminals and Bulk Plants 2 II. Inspection A. Opening Conference: Inspectors from the United States Environmental Protection Agency ("EPA") and Massachusetts Department of Environmental Protection ("MassDEP"), i.e., "the inspectors," arrived at the facility office at approximately 9:15 A.M. on October 8, 2024. EPA had announced the inspection to the facility on September 23, 2024. The inspectors were greeted by Mr. DeBlase and Packer's consultant, Ms. Courtney. The inspectors presented their credentials to Mr. DeBlase and Ms. Courtney. The EPA Clean Water Act inspectors explained the purpose of their inspection. See separate inspection report for details. The EPA Clean Air Act inspectors, Inspector Rapp and Inspector Perry, explained that the purpose of their inspection was to inspect the gasoline loading equipment and VRU, as well as the recently installed lockout system. Inspector Rapp asked if it would be possible for Packer to demonstrate the conditions that result in the lockout of the gasoline loading from the storage tank to the delivery truck. Mr. DeBlase agreed and arranged for a truck to be loaded. The MassDEP inspectors, Mr. Gavin and Ms. Carter, explained that they were not at the site to inspect but to observe the equipment related to the vapor recovery system because Packer had recently submitted a permit application to MassDEP to change the system from VRU to a vapor control unit ("VCU"). B. Walk Through: Mr. DeBlase led the inspectors to the fuel loading area where they were met by Packer's fuel technician, Skip Bailey. The loading area includes four fuel storage tanks and equipment for loading fuel products into trucks. Tank 4 storing gasoline has a volume of approximately 100,000 gallons. The tanks storing ultra-low sulfur diesel fuel ("ULSD") and heating fuel, Tanks 2 and 3, respectively, each have volumes of approximately 60,000 gallons. Tank 1 storing distillate fuel oil ("#2 oil") has a volume of approximately 100,000 gallons. See photos DSCN1742.JPG and DSCN1743.JPG. Packer also has a barge docked at the site with a volume of approximately 120,000 gallons. See photos DSCN1768.JPG and DSCN1769.JPG. Mr. Bailey explained that the loading rack includes different colored loading pipes associated with specific types of fuels: green for diesel fuel, red for dyed heating oil, yellow for #2 oil, and white for gasoline. See photo DSCN1745.JPG. In the loading area, the inspectors observed thermal expansion valves and tanks for the diesel/fuel oils and 3 gasoline. See photos DSCN1751.JPG, DSCN1752.JPG, and DSCN1758.JPG. Mr. Bailey explained that the diesel/fuel oils expansion tank is disconnected and the valves plugged but Packer is waiting for an electrician to decommission them before they remove them. He said the new system released pressure directly back to the storage tanks. He said the gasoline thermal expansion system was still in service and would not be changed. Inspector Rapp asked Mr. Bailey to explain how the gasoline loading system worked, including the VRU, and for a demonstration of the recently installed lockout system ("Scully system"). Mr. Bailey showed the inspectors the facility's new "Toptech EXl" fuel loading control system which requires the operator to log in with a key card and PIN. He said it was similar to the type of system used at the larger gasoline distribution terminals, such as the Motiva terminal in Providence. Mr. Bailey showed the inspectors that the VRU was operational which was indicated by a green light above the equipment. See photo DSCN1748.JPG. He said that if the VRU was not fully operational, the red light next to the green would turn on. Mr. Bailey inserted a key card and logged into the Toptech system. He set the system to load 3,000 gallons of gasoline from the storage tanks to the truck. He showed the inspectors that the screen indicated an alarm, "MTR ALARM," because the truck was not connected to the control system. Mr. Bailey showed the inspectors the vapor return line which must be connected from the rack to the truck for the fuel to flow. Because the line was not connected, the screen indicated that the vapor return line was not connected ("CHECK VR"). See photo DSCN1749.JPG. Mr. Bailey showed the inspectors the tank truck's computer system which also must be connected to the fuel loading rack's control system for gasoline to flow from the storage tank to the truck. See photo DSCN1755.JPG. He explained that given the vapor return line and electronic probe were not connected to the control system, gasoline could not be loaded into the truck, i.e., it was locked out. Mr. Bailey said there were three steps to loading a gasoline truck: vent; ground; and load. He proceeded to vent the truck by removing the cap on the opening the vapor return valve on the side of the truck. The inspectors smelled a rush of gasoline vapors exiting the truck and asked if any of Packer's trucks had any kind of valve to prevent venting directly to the atmosphere when the vent cap was removed and before the vapor return line was connected. Mr. Bailey said he did not believe any of Packer's trucks had such a valve. He then attached the vapor return line to valve from the loading rack to the truck vent. See photo DSCN1753.JPG. Mr. Bailey explained the vapor return system was a passive system relying on the liquid entering the truck's tank to push the vapors out into the line. Next, Mr. Bailey connected the electronics probe from the system to the truck. See photo DSCN1755.JPG. Mr. Bailey then attached the gasoline transfer pipe to the truck. See photos DSCN1756.JPG and DSCN1757.JPG. Mr. Bailey pointed out the two green 4 lights in the front of the Scully system panel indicating that the required connections were in place to allow gasoline to flow into the truck. See photo DSCN1754.JPG. Mr. Bailey said that prior to the installation of the Toptech and Scully equipment, gasoline could be loaded into a truck even if the vapor return line was not connected or the VRU was not operational. He said that the Toptech system allowed them to track the flow of gasoline to the trucks more accurately than previously which allowed them to fill the trucks closer to the maximum without risk of overflow. Inspector Rapp asked to see the VRU system. Mr. Bailey explained the VRU includes two carbon adsorption beds (Carbon Beds A and B) designed to adsorb and collect gasoline vapors generated during transfer from the storage tanks to the trucks. See photos DSCN1760.JPG, DSCN1761.JPG, and DSCN1762.JPG. He said vapors are sent to one of the carbon beds where the vapors are adsorbed onto activated carbon. He said while one carbon bed is adsorbing vapors, the second carbon bed is offline and is regenerated. He said the vapors trapped in the closed carbon bed are pulled by vacuum pump and sent to an absorption tower which uses liquid gasoline taken as the absorption liquid. See photos DSCN1759.JPG, DSCN1763.JPG, DSCN1764.JPG, and DSCN1765.JPG. He explained that the carbon beds switch to active or off-line based on a timer rather than by process parameters but the process can be controlled manually from the control panel. See photo DSCN1766.JPG. Mr. Bailey said that Packer often leaves the VRU system running after loading is completed in order for the beds to cycle through a few times which helps keep the carbon performing well. Mr. Bailey said that the facility currently has a lower throughput compared to historical volumes. He said that currently the typical throughput during the summer months is 50,000 gallons per week and in winter it is 30,000 gallons per week. He said the lower throughput also allows the carbon beds to regenerate more thoroughly, leading to lower emissions to the atmosphere. Inspector Rapp asked Mr. Bailey how often the carbon material in the VRU beds is exchanged. He said the carbon was not changed on a schedule but rather based on when vapor removal performance shows it is needed. Inspector Rapp asked Mr. Bailey about the "electrical problems" indicated in the October 2023 semi-annual report from Packer. Mr. Bailey said that the VRU is an old system and there were several solenoids and valves that needed repair or replacement but the system is now working well. Inspector Rapp asked Mr. DeBlase about the VRU's program logic controller ("PLC") issues noted in the Spring 2024 semi-annual report, specifically if the PLC had needed to be replaced in order for the lockout system to work. Mr. DeBlase said that they resolved the issues and were able to continue using the original PLC. 5 Mr. DeBlase noted that although the VRU is functioning well currently, Packer has applied for a permit at MassDEP to allow the replacement of the VRU with a vapor control unit ("VCU"). He said they are waiting for a response from MassDEP. C. Closing Conference: The inspectors, Mr. DeBlase and Ms. Courtney returned to Mr. DeBlase's office for a closing conference. The inspectors thanked Mr. DeBlase and the other facility representatives for their time and the information they shared, particularly for the demonstration of the VRU, gasoline loading, and lockout systems. The inspectors explained they will write an inspection report documenting their observations which they will share within 70 days from the inspection. They said they will contact Mr. DeBlase and Packer if they have any additional questions. The inspectors left the facility at approximately 12:15 P.M. 6 Appendix: Photo Log: R.M. Packer, Co., Inc. October 8, 2024 All photographs taken by Steve Rapp, EPA Number 1 2 3 Image Identification DSCN1742.JPG DSCN1743.JPG DSCN1744.JPG Description R.M. Packer facility from the water Fuel storage tanks (from left to right: 1, 2, 3, 4) Gasoline storage tank 4 DSCN1745.JPG Storage tanks, piping, and loading equipment 5 DSCN1746.JPG Delivery truck 6 DSCN1747.JPG Facility sign 7 DSCN1748.JPG Vapor recovery unit indicator light 8 DSCN1749.JPG Toptech EXl fuel loading control system screen 9 DSCN1750.JPG Toptech EXl fuel loading control system screen 10 DSCN1751.JPG Thermal expansion tank for diesel and fuel oils 11 DSCN1752.JPG Thermal expansion tank for gasoline 12 DSCN1753.JPG Vapor return line on truck 13 DSCN1754.JPG Control panel of Scully lockout system 14 DSCN1755.JPG Truck computer and electronic hookup 15 DSCN1756.JPG Gasoline line connected to truck 16 DSCN1757.JPG Gasoline loading rack (white) 17 DSCN1758.JPG Valve on thermal expansion line 18 DSCN1759.JPG Gasoline lines from Tank 4 19 DSCN1760.JPG Carbon adsorber beds (A on left, B on right) 20 DSCN1761.JPG Carbon bed A 21 DSCN1762.JPG Carbon bed B 22 DSCN1763.JPG Absorption tower (center) 23 DSCN1764.JPG Vacuum pump (yellow) 24 DSCN1765.JPG Absorption tower 25 DSCN1766.JPG VRU control panel 26 DSCN1767.JPG Gasoline storage tank behind berm wall 27 DSCN1768.JPG Fuel barge parked at dock 28 DSCN1769.JPG Fuel barge parked at dock Time (A.M.) 8:48 9:19 9:19 9:24 9:24 9:27 9:41 9:48 9:48 9:50 9:50 9:52 9:52 9:53 9:57 9:57 10:00 10:06 10:09 10:10 10:10 10:10 10:12 10:13 10:15 10:38 10:39 10:59 Number 1 Image Identification DSCN1742.JPG Description R.M. Packer facility from the water Time (A.M.) 8:48 Number 2 Image Identification DSCN1743.JPG Description Fuel storage tanks (left to right: 1, 2, 3, 4) Time (A.M.) 9:19 Number 3 Image Identification DSCN1744.JPG Description Gasoline storage tank (Tank 4) Time (A.M.) 9:19 Number 4 Image Identification DSCN1745.JPG Description Storage tanks, piping, and loading equipment Time (A.M.) 9:24 Number 5 Image Identification DSCN1746.JPG Description Delivery truck Time (A.M.) 9:24 Number 6 Image Identification DSCN1747.JPG Description Facility sign Time (A.M.) 9:27 Number 7 Image Identification DSCN1748.JPG Description Vapor recovery unit indicator light Time (A.M.) 9:41 Number 8 Image Identification DSCN1749.JPG Description Toptech EXl fuel loading control system screen Time (A.M.) 9:48 Number 9 Image Identification DSCN1750.JPG Description Toptech EXl fuel loading control system screen Time (A.M.) 9:48 Number 10 Image Identification DSCN1751.JPG Description Thermal expansion tank for diesel and fuel oils Time (A.M.) 9:50 Number 11 Image Identification DSCN1752.JPG Description Thermal expansion tank for gasoline Time (A.M.) 9:50 Number 12 Image Identification DSCN1753.JPG Description Vapor return line on truck Time (A.M.) 9:52 Number 13 Image Identification DSCN1754.JPG Description Control panel of Scully lockout system Time (A.M.) 9:52 Number 14 Image Identification DSCN1755.JPG Description Truck computer and electronic hookup Time (A.M.) 9:53 Number 15 Image Identification DSCN1756.JPG Description Gasoline line connected to truck Time (A.M.) 9:57 Number 16 Image Identification DSCN1757.JPG Description Gasoline loading rack (white) Time (A.M.) 9:57 Number 17 Image Identification DSCN1758.JPG Description Valve on thermal expansion line Time (A.M.) 10:00 Number 18 Image Identification DSCN1759.JPG Description Gasoline lines from Tank 4 Time (A.M.) 10:06 Number 19 Image Identification DSCN1760.JPG Description Carbon adsorber beds (A on left, B on right) Time (A.M.) 10:09 Number 20 Image Identification DSCN1761.JPG Description Carbon bed A Time (A.M.) 10:10 Number 21 Image Identification DSCN1762.JPG Description Carbon bed B Time (A.M.) 10:10 Number 22 Image Identification DSCN1763.JPG Description Absorption tower (center) Time (A.M.) 10:10 Number 23 Image Identification DSCN1764.JPG Description Vacuum pump (yellow) Time (A.M.) 10:12 Number 24 Image Identification DSCN1765.JPG Description Absorption tower Time (A.M.) 10:13 Number 25 Image Identification DSCN1766.JPG Description VRU control panel Time (A.M.) 10:15 Number 26 Image Identification DSCN1767.JPG Description Gasoline storage tank behind berm wall Time (A.M.) 10:38 Number 27 Image Identification DSCN1768.JPG Description Fuel barge parked at dock Time (A.M.) 10:39 Number 28 Image Identification DSCN1769.JPG Description Fuel barge parked at dock Time (A.M.) 10:59