Document xzrqGM0RyOBmNX86MNMO07j5y

EPA Inspection Report - Page 1 of 5 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/14/2024 Air SIP, Title V, NSPS, 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: TPC Group LLC Port Neches Operations 2102 TX-136 Spur Port Neches, TX 77651 2102 TX-136 Spur Port Neches, TX 77651 Jefferson County 409-724-4700 Brad Wilkins brad.wilkins@tpcgrp.com Senior Environmental Engineer FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000504801 RN104964267 / FOP O1327 AFS # 48-245-00715 424710 5171 Personnel participating in inspection: James Haynes EPA Region 6 ECDAT Ben Rosenthal EPA Region 6 ECDAT Nicholas Bobbs EPA OECA/OCE/AED Dan Heins EPA OECA/OCE/AED Philip Myers EPA OECA/OCEFT/NEIC Conor Goulding EPA OECA/OCEFT/NEIC Brad Wilkins TPC Group LLC Scott Hanks TPC Group LLC Physical Scientist Physical Scientist Environmental Engineer Environmental Scientist Mechanical Engineer Physical Scientist Senior Environmental Engineer Safety Facilitator EPA Lead Inspector Signature/Date JAMES HAYNES Date: 2024.04.17 19:07:41 -05'00' Digitally signed by JAMES HAYNES James Haynes Date Supervisor Signature/Date JAMES LEATHERS Date: 2024.04.17 20:57:01 -05'00' Digitally signed by JAMES LEATHERS James Leathers Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 5 Section I - INTRODUCTION TPC Group LLC / Port Neches Operations Inspection Date 02/14/2024 PURPOSE OF THE INSPECTION EPA inspectors Nicholas Bobbs and Dan Heins, accompanied by Philip Myers and Conor Goulding with EPA's National Enforcement Investigations Center ("NEIC") staff arrived at TPC Group LLC's Port Neches Operations (the "Facility") at 12:45 on February 13, 2024 for an unannounced inspection. Upon arrival, the EPA inspectors and NEIC, met with Mr. Scott Hanks, Safety Facilitator. The EPA inspectors presented their credentials to Mr. Hanks and informed them that this was an EPA inspection to evaluate potential sources of excess emissions using EPA's Geospatial Measurement of Air Pollution ("GMAP") vehicle and evaluate compliance with the Clean Air Act and the Facility's Title V Air Permit. The scope of the inspection is a partial compliance evaluation. This inspection occurred as part of a multi-scale monitoring project in the Beaumont-Port Arthur area. FACILITY DESCRIPTION The Facility operates as a terminal that transfers various liquid material, including but not limited to methanol, butadiene, and raffinate, from rail, pipeline, and barges into storage tanks and out to various clients. Section II - OBSERVATIONS GMAP Inspection Mr. Goulding drove the GMAP and Mr. Myers operated the GMAP's instruments. The EPA inspectors followed the GMAP in a secondary vehicle. The GMAP drove on all available facility roads to measure air pollutant concentrations downwind of each process area. A full report from the GMAP will be issued by NEIC at a later date. EPA inspectors noted a plume of hydrocarbon emissions using an optical gas imaging ("OGI") camera from a perimeter vent on Tank 55, an internal floating roof ("IFR") storage vessel containing methanol. The site GMAP survey ended at 13:50. Region 6 Follow-up Inspection I, James Haynes, with Ben Rosenthal, EPA Region 6 inspectors, arrived at the Facility at 09:30 on February 14, 2024 for an unannounced follow-up inspection. I presented my credentials to Mr. Hanks and Mr. Brad Wilkins, Senior Environmental Engineer. We began the follow-up inspection by returning to Tank 55, an IFR storage vessel containing methanol. Mr. Rosenthal observed hydrocarbon emissions with the OGI camera from the western perimeter vents. 2 EPA Inspection Report - Page 3 of 5 TPC Group LLC / Port Neches Operations Inspection Date 02/14/2024 A leak detection and repair ("LDAR") technician with HPC Industrial separately confirmed emissions from Tank 55's perimeter vents. Mr. Wilkins informed us that the most recent inspection of the IFR was completed in the previous month. [AOC 1] After obtaining the necessary permits, we observed several tanks and process equipment in Block 7. No hydrocarbon emissions were observed from any of the tanks in this Block. Following the activity in Block 7, we visited the control room and spoke with a Facility operator who described the control equipment and monitoring data collected for the #1 and #2 vapor combustion units ("VCU1" and "VCU2"). The VCU2 is the primary unit that controls emissions from the tanks, some of which are vented automatically while others are vented manually. The Facility operator showed us the temperature alarms set on the VCU1/VCU2. I noted that the Facility did not set a low temperature alarm for VCU2, and that there may not be any feedback to the control room operators when temperatures drop below a limit established during a performance test to ensure compliance. [AOC 2] We exited the control room and viewed the area of the Facility where VCU1/VCU2 are located. See Photo No. 1. We visited Dock No. 3 to observe the loading equipment and the associated dock flare. While we were in this area of the Facility, we discussed any wastewater from the loading process and other general wastewater flows for the site. The inspection team departed the facility at 15:25. Section III - AREAS OF CONCERN I conducted a closing conference at 14:50 for the inspection with Mr. Hanks and Mr. Wilkins We summarized the observations, including the following Areas of Concern: 1) At Tank 55, EPA inspectors observed hydrocarbon emissions with the OGI camera, indicating that the floating roof and seals of the IFR may not be controlling emissions as required. 2) At VCU2, the control board did not display low temperature alarms that are consistent with performance test data to ensure adequate combustion temperatures are maintained for the proper destruction of waste gas. Section IV - FOLLOW UP EPA requested additional information following the inspection. On March 8, 2024, I received a partial response to my request. The remaining responses were submitted April 5, 2024. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log 3 EPA Inspection Report - Page 4 of 5 TPC Group LLC / Port Neches Operations Inspection Date 02/14/2024 Appendix 1 Photograph Log EPA Inspection Report - Page 5 of 5 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: TPC Group LLC / Port Neches Operations City: Port Neches County: Jefferson State: TX Photo File Name: Date of Photo: Time of Photo: Photographer: Description: FLIR0058.jpg 02/14/2024 14:13 James Haynes VCU1 and VCU2