Document rxjj5bDwq8yyzYaNe8pwwrQG7

EPA Inspection Report - Page 1 of 8 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 11/07/2024 Air NESHAP, SIP Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: HPC Industrial Services LLC Norco Oil Recovery Facility 15536 River Road Norco, LA 70079 15536 River Road Norco, LA 70079 St. Charles Parish 225-681-0878 Jeremy Leonick Director jeremy.leonick@hpc-industrial.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110044317691 Agency Interest # 160461 / Permit # 2520-00164-01 AFS # 22-089-00164 562213 (Solid Waste Combustors and Incinerators) 1389 (Oil and Gas Field Services) Personnel participating in inspection: James Haynes EPA Region 6 ECDAT Ben Rosenthal EPA Region 6 ECDAT Sophia Ong EPA Region 6 ECDAT Jeremy Leonick HPC Industrial Services, LLC Robert Basl EHS Technology Group, LLC Physical Scientist Physical Scientist Physical Scientist Director Consultant EPA Lead Inspector Signature/Date JAMES HAYNES Date: 2025.02.10 14:51:27 -06'00' Digitally signed by JAMES HAYNES James Haynes Date Supervisor Signature/Date Leathers, James Date: 2025.02.10 15:34:25 -06'00' Digitally signed by Leathers, James James Leathers Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 8 HPC Industrial Services LLC / Norco Oil Recovery Facility Inspection Date 11/07/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION I, James Haynes, with Ben Rosenthal and Sophia Ong, EPA inspectors, arrived at HPC Industrial Services LLC's Norco Oil Recovery Facility (the "Facility" or "NORF") at 13:30 on November 7, 2024, for an unannounced inspection. We met with Mr. Jeremy Leonick, Director with HPC Industrial Services, and Mr. Robert Basl, consultant for the Facility. I presented my inspector credentials to Mr. Leonick and informed him that this was an EPA inspection to evaluate compliance with the Clean Air Act ("CAA"), implementing regulations of the CAA such as 40 C.F.R. Part 61 Subpart FF ("Benzene Waste Operations NESHAP" or "BWON"), and the Facility's air permit. The scope of the inspection is a partial compliance evaluation ("PCE"). FACILITY DESCRIPTION The Norco Oil Recovery Facility treats oily sludges and cake waste materials by dewatering, drying, and recovering oil through the application of centrifuge and thermal desorption processes. The centrifuge process dewaters the sludge and recovers much of the oil, and the thermal desorption process utilizes an indirect-fired anaerobic thermal desorption unit ("ATDU") that dries the dewatered cake into ash and includes a vapor recovery system to recover the remaining oil. Vapors from the ATDU are routed to and controlled by a thermal oxidizer. The dried ash is transported off-site for disposal. Section II - OBSERVATIONS Following the opening conference, I informed Mr. Leonick that the focus of the inspection was on BWON, and we would focus on controlled benzene wastes received from refineries and chemical plants across the U.S. NORF receives waste in roll-off boxes, vacuum trucks, vacuum boxes, and other mobile shipping containers. For controlled benzene wastes, NORF must comply with the standards in 40 C.F.R. 61.343 through 61.347 at each waste management unit. A waste management unit is a piece of equipment, structure, or transport mechanism used in handling, storage, treatment, or disposal of waste. Examples of a waste management unit include a tank, surface impoundment, container, oil-water separator, individual drain system, steam stripping unit, thin-film evaporation unit, waste incinerator, and landfill. As part of the inspection, we conducted Method 21 monitoring using Thermo Environmental Instruments' Toxic Vapor Analyzer ("TVA") Model 2020 and conducted observations of the process equipment with a Teledyne FLIR Gx620, an intrinsically safe optical gas imaging ("OGI") camera. We began our field activity near the thermal oxidizer, ATDU, quench scrubber, and oil water separator. In this area of the Facility, we observed significant hydrocarbon odors near the quench scrubber and oil water separator. Our monitoring at the oil water separator caused the TVA instrument to flame out after the detector was overwhelmed by the rich vapors coming from an access hatch, in excess of 10,000 parts per million (Appendix 1 - Photo No. 1). NORF later collected a Summa canister sample on December 4, 2024, that was analyzed using EPA Method TO-15. The result indicated a benzene concentration of 250 micrograms per cubic meter, or approximately 78 parts per billion. 2 EPA Inspection Report - Page 3 of 8 HPC Industrial Services LLC / Norco Oil Recovery Facility Inspection Date 11/07/2024 We walked to the southern portion of the Facility where waste is received at the Facility. Pumpable liquids, sludges, and slurries received in vacuum trucks are pumped into mix tanks for holding before they can be processed in the centrifuge. Other wastes that cannot be pumped are placed in the Facility's "3-Sided Box" where it can be loaded into the solids hopper that feeds a conveyer system to the ADTU (Appendix 1 - Photo No. 3). We observed the backup control device to the thermal oxidizer, the shaker screen, the centrifuge and separator box, the "3-Sided Box" and solids hopper, and a sump that operates as a final oil water separator before discharging the Facility's wastewater to the co-located refinery. In this area, we observed significant oil staining below the centrifuge at the separator box (Appendix 1 - Photo No. 2). We also noted that the "3-Sided Box" and solids hopper are open to the atmosphere. See AOC 1. While in the southern portion of the Facility, I observed the thermal oxidizer using the OGI camera and noted a plume of hydrocarbons trailing from the stack (Appendix 1 - Photo No. 4). See AOC 2. We ended the field activity and returned to the office module. I conducted a closing conference at 17:00. We summarized the observations from our field activity. Section III - AREAS OF CONCERN The following Areas of Concern were developed after the on-site inspection: 1) I reviewed a subset of records documenting the types of waste NORF receives (i.e., bills of lading). During the third quarter of 2024, NORF received wastes from 22 sites. Some of these wastes are identified as BWON-controlled wastes; therefore, NORF must manage each of these wastes pursuant to 40 C.F.R. 61.343 through 61.347 at each waste management unit. Based on the visual defects at the separator box below the centrifuge, because the "3-Sided Box" and solids hopper were open to the atmosphere, and the detectable emissions at the oil water separator, NORF may not be managing controlled BWON wastes in accordance with the requirements of the rule. 2) I reviewed the OGI video of hydrocarbons trailing from the thermal oxidizer. The plume may indicate that the combustion unit is not achieving the required efficiency. The thermal oxidizer is the control device for waste management units at the Facility. Section IV - FOLLOW UP EPA requested additional information following the inspection on November 19, 2024. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log 3 EPA Inspection Report - Page 4 of 8 HPC Industrial Services LLC / Norco Oil Recovery Facility Inspection Date 11/07/2024 Appendix 1 Photograph Log EPA Inspection Report - Page 5 of 8 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: HPC Industrial Services LLC / Norco Oil Recovery Facility City: Norco Parish: St. Charles Parish State: LA Photo File Name: Date of Photo: Time of Photo: Photographer: Description: FLIR0081-snip.jpg 11/07/2024 15:23 James Haynes Still image from FLIR0081.mp4 video Circled in Red: location of flameout on hatch of oil water separator downstream of quench scrubber EPA Inspection Report - Page 6 of 8 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: HPC Industrial Services LLC / Norco Oil Recovery Facility City: Norco Parish: St. Charles Parish State: LA Photo File Name: Date of Photo: Time of Photo: Photographer: Description: FLIR0085.jpg 11/07/2024 16:12 James Haynes Photograph in southern portion of the Facility Circled in Red: significant oil staining at the separator box below the centrifuge EPA Inspection Report - Page 7 of 8 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: HPC Industrial Services LLC / Norco Oil Recovery Facility City: Norco Parish: St. Charles Parish State: LA Photo File Name: Date of Photo: Time of Photo: Photographer: Description: FLIR0086.jpg 11/07/2024 16:13 James Haynes Photograph in southern portion of the Facility Circled in Red: open solids hopper used to feed a conveyer system into the ADTU Circled in Yellow: open "3-Sided Box" used to store solids prior to loading into the hopper EPA Inspection Report - Page 8 of 8 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: HPC Industrial Services LLC / Norco Oil Recovery Facility City: Norco Parish: St. Charles Parish State: LA Photo File Name: Date of Photo: Time of Photo: Photographer: Description: FLIR0083-snip.jpg 11/07/2024 15:47 James Haynes Still image from FLIR0083.mp4 video Circled in Red: hydrocarbon plume trailing from NORF's thermal oxidizer