Document ykz2mJyEQ0KGdQXkEZ86GR7ZX

EPA Inspection Report - Page 1 of 254 Region 6 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 4/22-23/2019 Air SIP, Title V, NESHAP, NSPS Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) Parish: Facility Contact: LBC Baton Rouge LLC Sunshine Terminal 1725 Hwy 75 Sunshine, LA 70780-3412 2625 Bay Area Blvd. - Suite 200 Houston, TX 77058 Iberville Parish Danielle L. Bush d-bush@lbctt.com Regional Manager, Air & Env. Compliance (281) 291-3418 FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 1100 0957 7145 LDEQ AI # 3492; Title V Permit # 1280-00025-V9 issued 10/17/18 AFS 22-047-00025 493190 - Other Warehousing and Storage 4226 - Special Warehousing and Storage Personnel participating in inspection: Debbie Ford EPA R6 / ECDAT James Haynes EPA R6 / ECDAT Justin Chen EPA R6 / ECDAT Kevin Chimento LBC Baton Rouge Jody Kelley LBC Baton Rouge Darrel Heil LBC Baton Rouge T.J. Buffaloe LBC Houston Danielle Bush LBC Houston Env. Scientist Physical Scientist Env. Engineer Terminal Manager Operations Supervisor Maintenance Supervisor HSEQ Manager Env. Manager (Regional) (214) 665-7235 (214) 665-8546 (214) 665-2273 (225) 314-2188 (225) 314-2198 (225) 314-2194 (281) 291-3438 (281) 291-3418 EPA Lead Inspector Signature/Date Supervisor Signature/Date Debbie Ford Margaret Osbourne 6/20/2019 Date 6/20/2019 Date 6ENFORM-019-R7 (2/15/2017) 1 EPA Inspection Report - Page 2 of 254 Section I - INTRODUCTION LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 PURPOSE OF THE INSPECTION Environmental Protection Agency (EPA) Region 6 inspectors Debbie Ford, James Haynes, and Justin Chen arrived at the LBC Baton Rouge LLC (LBC)/Sunshine Terminal (facility or terminal) at 8:40 a.m. on April 22, 2019 for an unannounced inspection. We met with the following individuals for the opening conference: Kevin Chimento, Terminal Manager Jared Sweatman, EST Coordinator Jody Kelley, Operations Supervisor T.J. Buffaloe, HSEQ Manager (via video conferencing) Danielle Bush, Regional Environmental Manager (via video conferencing) All three EPA inspectors presented their credentials to Mr. Chimento, Mr. Kelley, and Mr. Sweatman. I 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), which is authorized under Section 114(a) of the CAA. The scope of the inspection is a partial compliance evaluation (PCE) and includes evaluation of the compliance of the facility with applicable New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAP), and Louisiana State Implementation Plan (SIP) regulations. During the inspection we took photographs using a Nikon COOLPIX AW120 digital camera and videos using a FLIR Systems GF320 infrared camera. The FLIR GF320 infrared camera is configured so it can visually detect chemicals in the infrared spectrum that are the typical hydrocarbons that can be emitted by facilities such as refineries, oil and gas sites, and other similar industries. FACILITY DESCRIPTION The Sunshine Terminal is owned by LBC Baton Rouge, LLC, which is owned by LBC Tank Terminals. It began operation in 1969 as Nordix, Inc. In 1978 Petro United Terminals, Inc. acquired the terminal, and in 2001 LBC took ownership. The facility is a bulk liquid for-hire, or contract, storage terminal. All of the tanks at the terminal are either vertical fixed roof (VFR) or internal floating roof (IFR) design. The facility leases storage tanks to store liquids on a short-term or long-term basis. The Sunshine Terminal is a major source of hazardous air pollutants (HAPs) as well as a major source for volatile organic compounds (VOCs). As a major source, it is required to operate under a CAA Title V operating permit. The current operating permit for the facility is Permit No. 1280-00025-V9 issued October 17, 2018. The terminal is located on the Mississippi River. Liquid products are moved into and out of the terminal via tank truck, railcar, barge, or ship. All of the tanks at the site have marine loading/unloading capability. The products can be petroleum products, VOCs, or various inorganic compounds. 2 EPA Inspection Report - Page 3 of 254 Section II - OBSERVATIONS LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 I provided a list of records (see Appendix 4) that we were requesting as part of the inspection. I explained that we would be reviewing the records later, but the primary purpose of the onsite visit was to observe the operation of the facility with the FLIR camera to see if there were any hydrocarbon emissions from equipment. Also, we wanted to discuss their procedures for operating, inspecting, and maintaining their tanks. Mr. Chimento provided the latest printout of the facility Tank Daily Gauge (see Appendix 5). He explained that they do not gauge the tank levels on a daily basis unless it is active (i.e. product moving into or out of the tank). The hand gauging is the official record of the amount of material in a tank. If there is no activity, then the tank is gauged monthly. Some customers request that tank gauging is verified by an independent third-party cargo inspector such as Inspectorate, Caleb Brett, or SGS. This verification is performed monthly. The specific cargo inspector company is determined by LBC's customer. Due to the nature of the types of products the facility can handle as well as the age of the various tanks, the facility is subject to a wide variety of regulations in the Code of Federal Regulations (C.F.R.): Tanks Transfer Racks Piping LDAR Vapor Processing Systems or Flares Regulation Description NSPS (40 C.F.R. Part 60) Subpart K Tanks constructed after 6/11/1973 and prior to X 5/19/1978 Subpart Ka Tanks constructed after 5/18/1978 and prior to X 7/23/1984 Subpart Kb Tanks constructed after 7/23/1984 X Subpart XX Bulk gasoline terminals loading gasoline into tank trucks X X NESHAP (40 C.F.R. Part 61) Subpart J Leak Detection and Repair (LDAR) program for benzene - X refers to Subpart V Subpart V LDAR for volatile hazardous air pollutants X Subpart Y Benzene Emissions from Benzene Storage Vessels X Subpart BB Benzene Transfer Operations X X NESHAP (40 C.F.R. Part 63) Subpart R Bulk Gasoline Terminals X X X X Subpart Y Marine Tank Vessel Loading Operations X X Subpart SS Closed Vent Systems - referencing subpart is NESHAP X Subpart EEEE Subpart TT LDAR - Referencing subpart is NESHAP Subpart EEEE X Subpart WW Referencing subpart is NESHAP Subpart EEEE X Subpart EEEE Organic Liquids Distribution (OLD MACT) X X X X 3 EPA Inspection Report - Page 4 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 We reviewed the Record Request with Ms. Bush and Mr. Buffaloe so they could begin compiling the records while we observed tanks at the terminal with the FLIR camera. During the inspection we used the Facility Site Plan (see Appendix 6) from the Title V permit application for the current permit, Permit No. 1280-00025-V9. Inspectors identified the internal floating roof (IFR) tanks using an orange highlighter, tanks in benzene service with a pink highlighter, and tanks in natural gasoline service with a yellow/green highlighter on both the Facility Site Plan and the Tank Daily Gauge. Once in the tank farm, inspectors noted that the tanks did not have eyebrow vents that would allow for observation with the FLIR camera from the ground level. Mr. Chimento stated that they had welded all of the vents shut (see Appendix 1 - Photo 1). Inspectors and facility personnel climbed the following tanks to view the fittings on the tank roofs with the FLIR camera: Roof Type / Approximate Tank # Contents Primary Seal (1o) / Secondary Seal (2o) Diameter (feet) Capacity (barrels) Tank Type Photo # 55-9 Octene-1 Aluminum pontoon / 100 55,000 IFR none 1o: Ultraflote US I with Teflon Video # none fabric 2o: n/a Observations: Tank 55-9 operates with a nitrogen blanket. No hydrocarbon emissions observed. 120-1 Raffinate Aluminum pontoon / 1o: Mechanical shoe with 134 120,000 IFR 13 none Ultraflote II sec. / 2o: Cast flexible wiper Observations: No hydrocarbon emissions observed. Floor was replaced approximate 1 year ago with a cone up design. 80-8 Hexene Aluminum pontoon / 120 55,000 IFR 9 - 12 1, 7 1o: Ultraflote I 2o: n/a Observations: Tank 80-8 operates with a nitrogen blanket. Hydrocarbon emissions observed from the conservation vent (see AOC #1). 80-2 Benzene Aluminum pontoon / 120 55,000 IFR 2 2 1o: Mechanical shoe / 2o: Cast flexible wiper Observations: Hydrocarbon emissions observed with the FLIR only in high sensitivity mode (HSM). Benzene odors noted by James Haynes and Justin Chen. Mr. Kelly and Mr. Sweatman also confirmed the odors at the time. 110-2 Benzene Carbon steel pan / 1o: Mechanical shoe with 140.5 110,000 IFR 3 none Teflon fabric 2o: Cast flexible wiper 4 EPA Inspection Report - Page 5 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Tank # Roof Type / Approximate Contents Primary Seal (1o) / Secondary Seal (2o) Diameter (feet) Capacity (barrels) Tank Type Observations: No hydrocarbon emissions observed. Photo # 110-1 Natural Carbon steel pan / 140.5 110,000 IFR 6 gasoline 1o: Mechanical shoe with Teflon fabric 2o: Cast flexible wiper Observations: Hydrocarbon emissions observed. Video # 4, 5 Also, inspectors observed each of the facility's flares* with the FLIR camera: Flare ID Description FL-1 Truck Loading Material Loaded Ethanol Photo # 7,8 (not operating) Video # 3 Observations Trailing unburned Flare (EQT 002) 17 (nameplate) hydrocarbons observed. 18 (crossover piping) 20 (crossover piping locked) 21 (crossover piping locked) FL-2 Marine Loading Hexene 10 (smoking) 8 No emissions observed. Flare (EQT 003) 22 (operating) FL-3 Railcar Loading Avgas 7,8 (operating) 6 Flare (EQT 042) (aviation 14 (railcars being loaded) gas) 15 (blower) 16 (nameplate) 18 (crossover piping) 19 (control panel) 20 (crossover piping locked) 21 (crossover piping locked) * Although the current operating permit describes each as a "flare," FL-2 at the Marine Dock is actually a vapor combustor. This is discussed below in the Operating Permits section. OPERATING PERMITS Operational and physical changes yet no increase in permitted emissions Petro United received Permit 1280-00025-03 on October 7, 1992 (see Appendix 7). With the permit, the marine vapor combustor was included in the permit along with associated fugitive emissions. Petro United also increased throughput and loading rates at the dock and truck rack along with an increase in 5 EPA Inspection Report - Page 6 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 permitted tankage throughput. The permit authorized 34 tanks having a total capacity of 1,873,000 bbl and throughput at the dock and truck rack were 25 MM gal/yr of benzene and 45.4 MM gal/yr of benzene, respectively. The permit authorized 290.7 tons/yr of VOC emissions. Between October 1992 (Permit 1280-00025-03) and October 2018 (current Title V Permit 1280-00025- V9) (see Appendix 8), LDEQ has granted twenty permitting actions (minor source, Title V, amendments) that have added railcar loading, railcar flare, additional railcar loading, new tanks, and increased throughput at the dock, truck loading, and tanks. The current Title V permit authorizes 48 tanks having a total capacity of 3,561,000 bbl. Older permits had details of maximum throughput across the dock and at the truck loading. The current permit doesn't provide an annual maximum operating rate, but it does provide an operating rate for a shorter period of time (e.g., bbl/hr or gal/min). An annual rate can then be calculated based upon the operating time specified for that emission point: Operating Rate Operating Time Operating Rate (annual) Permit 1280-00025-03 issued 10/7/1992 Dock Loading 105.0 MM gal/yr Truck Loading Flare 45.4 MM gal/yr (benzene) Permit 1280-00025-V9 issued 10/17/2018 MARINE RACK - Loading and Unloading Dock 5200 bbl/hr 8760 hr/yr 1,913 MM gal/yr (calculated) TRUCK RACK - Truck Loading Rack 700 gal/min 8760 hr/yr 367.9 MM gal/yr (calculated) Sunshine Terminal's applications state that the emissions will remain under the 290.7 tons/yr of VOC emissions and the permitted VOCs remain unchanged (see AOC #2). Annual report of chemicals stored, throughput, and calculated VOC emissions The current operating permit has Specific Requirement 541 that requires the facility demonstrate compliance with the 270.9 tons/yr VOC permit limit by recording monthly the chemicals stored, the throughput, and the total throughput for the last 12 months. Also, the permit requires the facility to submit an annual report by April 30 showing the chemicals stored, throughput, and the VOC emissions calculated based on the throughput for the preceding calendar year. This is a new requirement in the Title V Permit, and the first report should have been submitted by April 30, 2019 for the 2018 calendar year. I could not locate the report in LDEQ's Electronic Document Management System, or EDMS (see AOC #3). EQT 003 - FL-2 Marine Flare FL-2 is described in the current operating permit as a flare: Marine Dock Flare. The Title V Permit Specific Requirements 158 - 164 are the flare requirements at 40 C.F.R. 60.18 and Specific 6 EPA Inspection Report - Page 7 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Requirements 184 - 190 and 213 - 218 are the flare requirements at 40 C.F.R. 63.11. The device in the pre-Title V permits referred to the device accurately as a combustor. EPA notes that the definition of a flare is a combustion device lacking an enclosed combustion chamber that uses an uncontrolled volume of ambient air to burn gases (40 CFR 63.641). Because the MVCU does not meet this definition, it does not meet the definition of a flare (see AOC #4). Inaccuracies in the Permit LDEQ requires that construction must begin on new sources within 2 years of a permit issuance or the authorization of the source becomes invalid. During our inspection, LBC identified several projects that had been permitted but the projects were cancelled: In the February 24, 2011 permit (Permit 1280-00025-V2), LBC was authorized to construct several new tanks. The following 7 tanks were never constructed: 55-16, 55-17, 80-10, and 110- 5 through 110-8. In the December 30, 2014 permit (Permit 1280-00025-V7), LBC removed 5 of these tanks, but Tanks 80-10 and 110-5 remain in the current Title V Permit 1280-00025-V9. In the May 9, 2014 permit, LBC proposed a new railcar rack with 154 loading spots along with increased tank throughput (EQT 074). The current Title V permit shows that the facility is applicable to 40 C.F.R. 68 - Risk Management Program, but LBC registered a Risk Management Plan (RMP) on 4/8/11 and de-registered the plan 7/29/11 (see Appendix 9) due to cancellation of the proposed project. The RMP noted that the regulated substance was acrylonitrile and the current Title V permit still has permitted emissions of acrylonitrile. FL-3 Railcar Flare was authorized in 2001 by Small Source Permit 2761. The terminal constructed the flare and rail loading, but it was never used until the facility began Avgas loading in February 2017. Errors in the permit can cause confusion in assessing applicability of regulations and determining compliance for regulatory agencies (see AOC #5). LDEQ requires Title V permit applications to be prepared by or under the supervision of a person properly qualified to perform engineering work and certified by a professional engineer (PE) With the May 31, 2013 application for the Title V Permit 1280-00025-V4 (see Appendix 10), LBC began using the consultant Shawn Flannigan from Alliant Environmental, LLC located in Katy, TX. LBC has contracted the same consultant for their Title V permit applications since 2013, for a total of six (6) applications between 2013 and 2018. All applications were signed but none of the applications had a PE stamp under the signature. I searched for Mr. Flannigan's PE License 33081 on the Louisiana Professional Engineering and Land Surveying website and found that Mr. Flannigan's license has been expired since September 30, 2011 (see Appendix 11). According to the statement below the license, a licensee must maintain an active license to be able to provide or offer to provide engineering services in Louisiana or use the words "engineer" or "engineering" or any modification or derivative thereof in their name or in connection with their business or activities in Louisiana (see AOC #6). 7 EPA Inspection Report - Page 8 of 254 NESHAP Subpart EEEE (OLD MACT) LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Notice of Compliance Status (NOCS) LBC provided the initial NOCS dated August 13, 2007 (see Appendix 12) and identified fourteen (14) tanks (Tanks 55-4, 55-5, 55-6, 55-8, 55-9, 55-10, 55-11, 55-13, 80-6, 80-7, 80-8, 80-9, 120-1, and 120-2) subject to OLD MACT regulations. LBC also identified the total annual transfer of organic liquids out of the facility via the truck rack and rail rack to be less than 800,000 gal/yr. LBC provided two NOCS letters for new tanks 80-1 and 80-2 (see Appendix 12) that were constructed in 2013. I created a table of tank activity (see Appendix 13) using the tanks identified in the NOCS documents, then adding the tank landing information (see Appendix 14) (e.g., products, date range of the landings). Some of the records of the tank landings clearly indicated if the tank was cleaned, but in other records it wasn't clear. The shorter duration for a landing would indicate that the tank was likely not cleaned. Tank 110-2 in 2016 was switched from a product that did not require an IFR to benzene service. In this instance, the tank was cleaned, but the record is not clear when benzene was introduced to the tank, the duration of filling before the roof was refloated, or if emissions were controlled (see AOC #7). The names of some of the products are not clear about the constituents that are in the product. For example, tank products were DA120, DA135, alkylate, full range alkylate, and reformate. Under OLD MACT, the definition of organic liquid is (1) any non-crude liquid or liquid mixture that contains 5 percent by weight or greater of the organic HAP listed in Table 1 to this subpart, as determined using the procedures specified in 63.2354(c), (2) crude oils downstream of the first point of custody transfer, (3) organic liquids for purposes of this subpart do not include the following liquids: (i) gasoline (including aviation gasoline), kerosene (No. 1 distillate), diesel (No. 2 distillate oil), asphalt, and heavier distillate oils and fuel oils.... It appears that the constituents of naphtha, alkylate, and reformate have 5 percent by weight or greater of the organic HAP listed in Table 1. Tanks 110-2 and 110-4 were constructed in 2008 after the initial NOCS was submitted. LBC did not provide an NOCS for these tanks, yet they have stored naphtha, benzene, pygas, and reformate (see AOC #8). Overlapping Requirements - Tanks comply with NESHAP Subpart WW In the OLD MACT NOCS, LBC noted the overlapping requirements with other tank regulations. Specifically, the benzene storage vessels subject to 40 C.F.R. 61 Subpart Y were listed along with other tanks subject to Subpart EEEE, and LBC stated that compliance with NESHAP Subpart WW was the option selected. The IFR requirements in NESHAP Subpart WW provide three options for the seal configuration: 1) a liquid mounted seal, 2) a mechanical shoe seal, or 3) two seals mounted one above the other, the lower may be vapor-mounted. 8 EPA Inspection Report - Page 9 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 LBC provided a listing of their IFR tanks (see Appendix 15) that detailed the tank ID, floating roof type, primary seal type, and if applicable, the secondary seal type. According to Mr. Chimento, the IFRs identified as aluminum pontoon are all skin and pontoon design. Tanks 55-4, 55-6, 55-7, 55-10, 55-11, 55-13, and 80-9 all store or have stored organic liquids (benzene and full range alkylate), but they only have a single wiper (vapor-mounted) primary seal (see AOC #9). LBC identified the single wiper primary seal for the tanks in the previous paragraph as Ultraflote II, but the specification sheets (see Appendix 16) provided actually identify the roof design as Ultraflote and the seal design as Ultraseal II. According to Mr. Heil, LBC Maintenance Supervisor, the Ultraseal II is made from DuPont Surlyn. Although the Ultraflote documentation indicates the seal is good for benzene service, the DuPont Surlyn Technical Information: Chemical Resistance (see Appendix 17) states that in industrial applications, aromatic hydrocarbons have a strong plasticizing action. The aromatic hydrocarbons can be absorbed by the DuPont Surlyn causing swelling, weight gain, softening, and some loss of yield strength. Benzene is identified as a plasticizer and at 70oF is noted as resistant, but at 140oF is considered variable resistant. In 2017-2018 Tank 55-7, which also has only a primary seal identified as Ultraflote II by LBC, stored a toluene/xylene mixture. According to the Chemical Resistance chart, toluene and xylene are both plasticizers and toluene has a chemical resistance code of "U" which is described as "Not resistant. Not recommended for service applications under any conditions" (see AOC #10). LDAR The facility uses Eagle Environmental to perform the required monitoring. NESHAP Subpart EEEE Table 4 - Work Practice Standards for pumps, valves, and sampling connections that operate in organic liquid services at least 300 hours per year allows for compliance with NESHAP Subpart H, TT, or UU. LBC had elected to comply with NESHAP Subpart TT. In the records request I asked for the LDAR reports for the facility. Ms. Bush provided two reports for each semi-annual period: VTAP Fugitive Emissions Control Program Semi-Annual Report and NON-HON Fugitive Emissions Control Semi-Annual Report. Neither of these reports state what regulation or permit requirement the report is satisfying. Also, neither of these reports appear to be in the format that is required under NESHAP Subpart TT, so it is not clear if the contractor is monitoring using the proper regulations (see AOC #11). I reviewed the last LDEQ inspection of the facility (see Appendix 18) and noted that in 2015, a pump seal had leaked benzene on June 12, 2015. This was reported in the Title V Deviation Report (see Appendix 18). I reviewed the 2015 VTAP Semi-annual Report for the first half of 2015 (see Appendix 18) and I did not find a reference to reports of the leaking pump (see AOC #12). Compliance Reports NESHAP Subpart EEEE requires the submittal of semi-annual compliance reports. Table 11 of NESHAP Subpart EEEE details the information that is to be included in these reports, including information from referring subparts to NESHAP Subpart EEEE. As part of the NOCS, LBC identified NESHAP Subpart WW as 9 EPA Inspection Report - Page 10 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 the compliance method for the tanks which had overlapping requirements with other regulations. Similarly, for equipment leak components (i.e., pumps, valves, sampling connections), LBC identified compliance with NESHAP Subpart TT as its compliance method for overlapping requirements. I reviewed the Compliance Reports (see Appendix 19 for the 2018 reports) and LBC did not include all of the required information in the Compliance Reports (see AOC #13). TANK REQUIREMENTS NSPS Subpart Kb The terminal has tanks that are regulated by varying regulations due to their age (i.e., NSPS K, Ka, Kb). When a new tank is constructed, reconstructed, or modified, it will be subject to NSPS Subpart Kb and is required to meet the control requirements depending on the maximum true vapor pressure of the product stored in the tank. Under NSPS Subpart A requirements, the owner/operator is required to submit a Notification of Initial Startup within 15 days of actual startup. For internal floating roof tanks, the owner/operator is required to submit a report that describes the control equipment and certifies that the control equipment meets the NSPS Subpart Kb specifications for IFR tanks. This report shall be attached to the Notification of Initial Startup. The four newest tanks at LBC are Tanks 80-1, 80-2, 55-14, and 55-15. I located the startup notifications for all the tanks but Tank 55-14 (see Appendix 20) which according to the Tank Landings for 2017 (see Appendix 14), was put into service on February 18, 2017 (see AOC #14). LBC did not provide the IFR tank certification report for all four of the new tanks (see AOC #15). NSPS requires for new tanks that the IFR, the primary seal, and if applicable, the secondary seal is visually inspected for holes, tears, or other openings in the seals or seal fabric or defects in the IFR. The facility is required to provide 30-day notice in writing prior to the filling of the tank to afford the opportunity to have an observer present. The following table was compiled from several notifications and records (see Appendix 21) related to new tanks 55-14 and 55-15 (see AOC #16): Completion of construction Inspection Notification Actual inspection Initial Startup Tank 55-14 11/9/16 (est startup: 11/18/16) 7-day notice dated 11/3/16 (received by LDEQ 11/10/16) (anticipates 11/9/16) 11/8/16 2/18/17 (no notification) (from Tank Landings 2017) Tank 55-15 11/9/16 7-day notice dated 11/3/16 (received by LDEQ 11/10/16) (anticipates 11/9/16) No record provided 12/2/16 (letter dated 12/14/16) Every time the IFR tank is emptied and degassed and at least every 10 years, the facility is required to perform an internal inspection. If the inspection is planned, the facility is required to provide a 30-day notice in writing prior to the filling of the tank to afford the opportunity to have an observer present. If the inspection was unplanned and the owner/operator could not have known about the inspection 30 days in advance of refilling the tank, the owner/operator shall notify by telephone at least 7 days prior to refilling of the tank. Immediately following the telephone notification, the owner/operator shall 10 EPA Inspection Report - Page 11 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 provide written documentation demonstrating why the inspection was unplanned. Alternatively, the notification and written documentation may be made in writing and sent by express mail so that it is received at least 7 days prior to the refilling. In 2017 LBC provided 7-day notifications of inspections for Tank 15-2, 120-1, and 120-2 (see Appendix 22): Tank 15-2 - Notice was dated January 4, 2017 which stated that the anticipated inspection would be on or after January 10, 2017. It was received by LDEQ on January 11, 2017. From the Tank Landings records, Tank 15-2 was landed from December 29, 2016 to July 2, 2017. Tank 120-1 - Notice was dated November 10, 2017 which stated that the anticipated inspection would be on or after November 16, 2017. From the Tank Landings records, Tank 120-1 was landed from May 27, 2017 to December 21, 2017. Tank 120-2 - Notice was dated April 18, 2017 which stated that the anticipated inspection would be on or after April 24, 2017. It was received by LDEQ on April 24, 2017. From the Tank Landings records, Tank 120-2 was landed from April 21, 2017 to December 30, 2017. All of the notifications of inspections that I have reviewed were 7-day notices, yet it is clear that the tanks had more than 30 days for inspection notifications. None of these notifications follow the requirements in NSPS Subpart Kb (see AOC #17). NSPS Subpart Kb requires tanks to have annual visual inspections of the floating roof and the primary or secondary seal (if one is in service) through the manholes and roof hatches on the fixed roof. These rooftop inspections are to look for the following inspection failures: IFR is not resting on the surface of the liquid product Liquids accumulated on the roof Seal is detached Holes or tears in the seal fabric Every time a tank is emptied and degassed, NSPS Subpart Kb requires an internal inspection of the IFR, seals, seal fabric, and deck fittings to ensure they are meeting Subpart Kb requirements. The regulations state that the owner/operator shall keep a record of each inspection identifying the tank, the date of the inspection, and the observed condition of each component of the control equipment (seals, IFR, and fittings). LBC uses the same form for both the annual visual inspection (see Appendix 23), referred to as an external inspection by LBC, and the internal inspection (see Appendix 24). None of the internal inspections have "Internal Inspection" circled on the forms, but one form had both circled. Also, Tanks 15-2, 20-1, and 55-8 all state that the IFR is not floating on the liquid, yet the Tank Landings records do not indicate that these tanks were landed at the time of the inspection. The forms provided as external inspections also include tanks that "Internal Inspection" is circled on some forms or circled and crossed out on others. The external inspections are performed by the operations personnel at LBC. The internal inspections are performed by the maintenance personnel. 11 EPA Inspection Report - Page 12 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 I asked about the procedures for the external inspections at LBC. Mr. Chimento said that he has his personnel perform external inspections monthly. He explained that they perform the inspection from the gauging hatch, which is approximately 8 inches, and the manways, which are approximately 18-20 inches. I asked if they break the plane of the opening to see better, and he told me they do not. I asked how they can see the entire roof if they do not break the plane. He told me that they are looking for liquids on the roof, and they have limited view beyond the area directly below the opening. For tanks that are in organic liquid service, they would be subject to NESHAP Subpart WW. Many of the NSPS Subpart Kb requirements are similar in NESHAP Subpart WW with one notable exception: instead of looking for visible gaps, NESHAP Subpart WW requires the testing for gaps greater than 1/8 inch (see AOC #18). We noted that Tank 110-1 through 110-4 were constructed in 2008. The American Petroleum Institute requires an initial API 653 inspection at 10 years to establish a corrosion rate. Thus, LBC should have emptied and degassed the tanks in 2018 for the required inspection. At the time of the inspection, I observed hoses around Tanks 110-1 and 110-4. Mr. Chimento explained that they were preparing to be emptied and degassed for the API inspection. Mr. Chimento also stated that the other two tanks would be inspected next year (see AOC # 19). Mr. Chimento explained that when a tank is emptied and degassed, the facility brings in a portable unit to combust the vapors from the tank. The companies they hire are from Texas. To date they have used three companies: O-Zone Industrial Services, LLC, Gen Mobile, and Pro-Act. I explained that they need to ensure that the companies have a unit that is permitted to operate in Louisiana as a portable source. Once permitted, when it is moved from location to location, they only need approval from LDEQ to relocate it (see AOC #20). Mr. Buffaloe and Ms. Bush were not aware that the terminal was bringing in a portable unit. The permit has separate emission points identified as Tank Cleaning and Tank Degas. I asked how these emission points were used since the emission point name sounded like they would be describing similar emissions, but I did not get an answer. FL-3 RAILCAR FLARE (EQT 042) The Railcar Flare is an air-assisted flare that LBC constructed in 2001. On March 29, 2005, Emission Testing Services tested the flare pursuant to 40 C.F.R. 60.18. According to Mr. Chimento, they never operated the railcar loading until 2017 when they received a contract to load Avgas. We observed trailing unburned hydrocarbons from the flare with the FLIR camera. We noted that the control panel for the flare had a BTU reading. LBC confirmed that they installed a calorimeter to measure BTU content at the flare. We also noted on the control panel that a low BTU alarm had occurred recently (see AOC #21). We observed a crossover line between the truck loading flare header and the railcar loading flare header (see Appendix 1 - Photo 18). The valve was closed but it was not locked. If the valve were opened, this would allow emissions to divert to the other device. If the other flare were not lit at the time, this would allow a bypass of the control device and vent the emissions to the atmosphere (see AOC #21). While we were onsite, operators placed a lock on the bypass line (see Appendix 2 - Photos 20 and 22). 12 EPA Inspection Report - Page 13 of 254 Section III - AREAS OF CONCERN LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 AOC #1- EPA observed hydrocarbon emissions using the FLIR camera from Tank 80-8 in hexene service although the tank operated with a nitrogen blanket. AOC #2 - Over a 20-year period, LBC has permitted significant increases in operational throughput at the truck loading, marine loading, and tank emission points. LBC has also constructed new storage tanks and a new railcar loading operation. With all of the changes, the permitted VOCs have not changed from 290.7 tons/yr. The original limit was prior to the Title V permitting program, and even though the permitting guidelines for Tile V permits states that permits are based upon potential to emit, the permitted VOCs did not increase. AOC #3 - LBC did not submit the annual report of chemicals stored, throughput, and calculated VOC emissions for 2018 by April 30, 2019. AOC #4 - The vapor combustor at the Marine Dock is inaccurately identified in the Title V permit as a flare. The identification of the control device as a flare may be bypassing testing requirements in LDEQ regulations. AOC #5 - The current Title V permit doesn't reflect equipment and operations at the site. AOC #6 - LBC has submitted six Title V permit applications since 2013 that were prepared by an individual who was not qualified to provide engineering services in Louisiana. AOC #7 - LBC did not keep clear records of when a tank had landed, if the tank was cleaned and degassed, and when the cleaning was complete, which would end any emissions from the roof being landed. AOC #8 - LBC did not provide a NESHAP Subpart EEEE NOCS for Tanks 110-2 and 110-4 that have stored organic liquids. AOC #9 - Tanks 55-4, 55-6, 55-7, 55-10, 55-11, 55-13, and 80-9 all store or have stored organic liquids (benzene and full range alkylate), but do not meet the seal requirements of NESHAP Subpart WW. AOC #10 - LBC may be using a seal material that is incompatible with the product stored in the tank. AOC #11 - The LDAR contractor may not be monitoring using the proper regulations. AOC #12 - The LDAR report for First Half of 2015 did not report the leaking benzene pump. AOC #13 - NESHAP Subpart EEEE Compliance Reports do not contain all of the required information. 13 EPA Inspection Report - Page 14 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 AOC #14 - LBC did not provide a Notification of Initial Startup within 15 days after such date for new tanks 55-14. AOC #15 - LBC did not provide a report that describes the control equipment for Tanks 80-1, 80-2, 55- 14, and 55-15 and certifies that the control equipment meets the NSPS Subpart Kb specifications for internal floating roofs. AOC #16 - LBC did not provide a 30-day notice of internal inspection for new IFR tanks 55-14 and 55-15. AOC #17 - LBC is not providing proper notification of inspections when a tank is inspected after emptying and degassing the tank. AOC #18 - LBC is not performing and documenting external and internal inspections of IFR tanks as required. AOC #19 - LBC failed to perform API 653 inspections on Tanks 110-1 through 110-4 at an initial 10-year interval. AOC #20 - LBC may be operating a portable unit to destroy degassing vapors that has not been permitted to operate in Louisiana. AOC #21 - FL-3 Railcar Flare has unburned hydrocarbons and may be having low BTU issues. AOC #22 - Bypasses to flares operated without a car seal or flow meter to indicate if the control device was bypassed. Section IV - FOLLOW UP On May 2, 2019 I received additional information requested during the inspection. These records included the OLD MACT Notice of Compliance Status dated August 13, 2007. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 22 photos taken 4/22-23/2019 Appendix 2 - Video Log - 8 FLIR videos taken 4/22-23/2019 Appendix 3 - Inspection sign-in sheet Appendix 4 - Record Request Appendix 5 - Tank Daily Gauge as of 4/18/2019 Appendix 6 - Facility Site Plan Appendix 7 - Permit 1280-00025-03 issued 10/7/1992, selected pages Appendix 8 - Current Title V Permit 1280-00025-V9 issued 10/17/2018, selected pages Appendix 9 - RMP registration and de-registration dates for the Sunshine Terminal 14 EPA Inspection Report - Page 15 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 10 - Title V Permit 1280-00025-V4 application, selected pages Appendix 11 - Shawn Flannigan Louisiana PE License 0033081 - expired 9/30/2011 Appendix 12 - NESHAP Subpart EEEE NOCS - Initial and Tanks 80-1 and 80-2 Appendix 13 - Tank Activity 2015-2018 Appendix 14 - Tank Landings 2015-2018 Appendix 15 - Sunshine Terminal Tank Table Appendix 16 - Ultraflote and Ultraseal Specification Sheets Appendix 17 - DuPont Surlyn Technical Information: Chemical Resistance Appendix 18 - 2017 LDEQ Inspection Report, selected pages, Title V Deviation Report 1H 2015, and VTAP LDAR Report 1H 2015 Appendix 19 - NESHAP Subpart EEEE Semi-annual Compliance Reports for 2018 Appendix 20 - NSPS Notification of Initial Startup - Tanks 80-1, 80-2, 55-15 Appendix 21 - Tanks 55-14 and 55-15 Appendix 22 -7-day Inspection Notifications for Tanks 15-2, 120-1, 120-2 in 2017 Appendix 23 - External Inspection Forms 2016 Appendix 24 - Internal Inspection Forms 2018 15 EPA Inspection Report - Page 16 of 254 LBC Baton Rouge, LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 1 Photograph Log 6ENFORM-019-R3 (11/14/2013) EPA Inspection Report - Page 17 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0367-00.JPG 4/22/2019 10:54 AM (corrected) Debbie Ford Welded eyebrow vent on EQT 036 - Tank 80-6. This is an example of the other tanks at the facility that have had eyebrow vents wended closed. Page 1 of 22 EPA Inspection Report - Page 18 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0368-00.JPG 4/22/2019 11:26 AM (corrected) James Haynes EQT 072 - Tank 80-2 roof - conservation vents. Page 2 of 22 EPA Inspection Report - Page 19 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0369-00.JPG 4/22/2019 3:24 PM (corrected) Justin Chen EQT 058 - Tank 110-2 nameplate. Page 3 of 22 EPA Inspection Report - Page 20 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0370-00.JPG 4/22/2019 3:27 PM (corrected) Justin Chen EQT 060 - Tank 110-4 nameplate. Page 4 of 22 EPA Inspection Report - Page 21 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0371-00.JPG 4/22/2019 3:30 PM (corrected) Justin Chen EQT 059 - Tank 110-3 nameplate. Page 5 of 22 EPA Inspection Report - Page 22 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0372-00.JPG 4/22/2019 3:30 PM (corrected) Justin Chen EQT 057 - Tank 110-1 nameplate. Page 6 of 22 EPA Inspection Report - Page 23 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0373-00.JPG 4/23/2019 8:29 AM (corrected) Debbie Ford EQT 001 - FL-1 Truck Loading Flare (right): not operating EQT 042 - RAIL FL-3 Railcar Loading Flare (left): operating to control emissions from Avgas (aviation gas) loading. Page 7 of 22 EPA Inspection Report - Page 24 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0375-00.JPG 4/23/2019 8:36 AM (corrected) Debbie Ford EQT 001 - FL-1 Truck Loading Flare (left): not operating EQT 042 - RAIL FL-3 Railcar Loading Flare (right): operating to control emissions from Avgas loading. Page 8 of 22 EPA Inspection Report - Page 25 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0376-00.JPG 4/23/2019 8:49 AM (corrected) Debbie Ford EQT 038 - Tank 80-8 - tank gauging using electronic gauge by LBC employee with concurrence by third party contractor SGS. Page 9 of 22 EPA Inspection Report - Page 26 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0378-00.JPG 4/23/2019 8:55 AM (corrected) Debbie Ford View towards dock area from roof of EQT 038 - Tank 80-8. Note light smoke from EQT 003 - MARINE FL-2 Marine Loading Flare. Prior to photo, James Haynes observed flames. Photographer Debbie Ford observed heavy smoke when she turned around to observe the vapor combustor unit. Page 10 of 22 EPA Inspection Report - Page 27 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0379-00.JPG 4/23/2019 9:00 AM (corrected) Debbie Ford EQT 038 - Tank 80-8 - nitrogen blanket control system. Page 11 of 22 EPA Inspection Report - Page 28 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0380-00.JPG 4/23/2019 9:01 AM (corrected) Debbie Ford EQT 038 - Tank 80-8 - nameplate. Page 12 of 22 EPA Inspection Report - Page 29 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0381-00.JPG 4/23/2019 9:06 AM (corrected) Debbie Ford EQT 047 - Tank 120-1 - stripping line. Note oil staining on valve. Solvent-like odors noted on 4/22/2019 and 4/23/2019. Page 13 of 22 EPA Inspection Report - Page 30 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0382-00.JPG 4/23/2019 9:19 AM (corrected) Debbie Ford Railcar loading of Avgas Page 14 of 22 EPA Inspection Report - Page 31 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0383-00.JPG 4/23/2019 9:30 AM (corrected) Debbie Ford EQT 042 - FL-3 Railcar Loading Flare - blower. Page 15 of 22 EPA Inspection Report - Page 32 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0384-00.JPG 4/23/2019 9:32 AM (corrected) Debbie Ford EQT 042 - FL-3 Railcar Loading Flare - nameplate indicating 2001 construction date. Page 16 of 22 EPA Inspection Report - Page 33 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 17 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0385-00.JPG 4/23/2019 9:34 AM (corrected) Debbie Ford EQT 002 - FL-1 Truck Loading Flare - nameplate indicating 1985 construction. Page 17 of 22 EPA Inspection Report - Page 34 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 18 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0386-01.JPG 4/23/2019 9:38 AM (corrected) Debbie Ford Crossover line between EQT 002 - FL-1 Truck Loading Flare and EQT 042 - FL-3 Railcar Loading Flare. Closed position. No lock to prevent bypass of control device. Page 18 of 22 EPA Inspection Report - Page 35 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 19 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0387-00.JPG 4/23/2019 9:42 AM (corrected) Debbie Ford EQT 042 - FL-3 Railcar Loading Flare - control panel. At the top of the panel (in the red area) is a display of a low BTU alarm on 4/20/2019 at 1:44. Page 19 of 22 EPA Inspection Report - Page 36 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 20 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0388-00.JPG 4/23/2019 9:45 AM (corrected) Debbie Ford Crossover line between EQT 002 - FL-1 Truck Loading Flare and EQT 042 - FL-3 Railcar Loading Flare. Lockout tag added after discussion with EPA inspectors. Page 20 of 22 EPA Inspection Report - Page 37 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 21 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0389-00.JPG 4/23/2019 9:45 AM (corrected) Debbie Ford Crossover line between EQT 002 - FL-1 Truck Loading Flare and EQT 042 - FL-3 Railcar Loading Flare. Lockout tag added after discussion with EPA inspectors. Page 21 of 22 EPA Inspection Report - Page 38 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 22 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Appendix 1 Photo File Name: Date/Time of Photo: Photographer: Description: DSCN0390-00.JPG 4/23/2019 1:45 PM (corrected) Debbie Ford EQT 003 - MARINE FL-2 - Marine Loading Flare at dock area on the Mississippi River. Operating to control emissions of hexene loading from Tank 80-8. Page 22 of 22 EPA Inspection Report - Page 39 of 254 LBC Baton Rouge, LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 2 Video Log EPA Inspection Report - Page 40 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 2 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Video No: File Name: Date/Time: Videographer: Description: 1 MOV_0154-01.mp4 4/22/2019 10:57 AM (corrected) Justin Chen Tank 80-8 - conservation vent with visible hydrocarbon emissions. Tank is nitrogen blanketed and in hexene service. Video No: File Name: Date/Time: Videographer: Description: 2 MOV_0155-01.mp4 4/22/2019 11:26 AM (corrected) James Haynes Tank 80-2 - conservation vent. Tank is in benzene service. Odors noted by James Haynes & Justin Chen. Hydrocarbon emissions observed in HSM, but not easily seen in normal mode. Video No: File Name: Date/Time: Videographer: Description: 3 MOV_0157-01.mp4 4/22/2019 11:46 AM (corrected) James Haynes FL-1 - Truck Loading Flare (right): operating with trailing unburned hydrocarbons during loading of ethanol. RAIL FL-3 - Railcar Loading Flare (left): not operating. Video No: File Name: Date/Time: Videographer: Description: 4 MOV_0158-00.mp4 4/22/2019 3:38 PM (corrected) James Haynes Tank 110-1 - conservation vent with visible hydrocarbon emissions. Tank is in natural gasoline service. Page 1 of 2 EPA Inspection Report - Page 41 of 254 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 2 Location: LBC Baton Rouge, LLC - Sunshine Terminal City: Sunshine Iberville Parish State: LA Video No: File Name: Date/Time: Videographer: Description: 5 MOV_0159-00.mp4 4/22/2019 3:40 PM (corrected) James Haynes Tank 110-1 - conservation vent with intermittent visible hydrocarbon emissions. Tank is in natural gasoline service. Video No: File Name: Date/Time: Videographer: Description: 6 MOV_0161-00.mp4 4/23/2019 8:39 AM (corrected) James Haynes RAIL FL-3 - Railcar Loading Flare - loading Avgas from Tank 55-14. Visible hydrocarbon emissions trailing after heat dissipation from flame. Video No: File Name: Date/Time: Videographer: Description: 7 MOV_0163-01.mp4 4/23/2019 8:50 AM (corrected) Justin Chen Tank 80-8 - conservation tank with visible hydrocarbon emissions. Tank is nitrogen blanketed and in hexene service. Video No: File Name: Date/Time: Videographer: Description: 8 MOV_0165-00.mp4 4/23/2019 1:51 PM (corrected) Justin Chen MARINE FL-2 - Marine Loading Flare - loading hexene from Tank 80-8. No trailing emissions observed. Page 2 of 2 EPA Inspection Report - Page 42 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 3 Inspection Sign-In Sheet EPA Inspection Report - Page 43 of 254 EPA Inspection Report - Page 44 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 4 Record Request EPA Inspection Report - Page 45 of 254 LBC Baton Rouge LLC - Sunshine Terminal EPA Record Request - 4/22/2019 Description Current operating permit(s) and application(s). Plot plan (current) with each tank ID Listing of all tanks, year constructed, material stored, capacity, diameter, height, tank type (cone roof, IFR, EFR, CVS w/ control), applicable regulations. If floating roof, type of floating roof, type of primary seal, and type of secondary seal (if applicable) Vapor pressure analysis/documentation of each material stored Strapping table for each tank including levels when the vacuum breaker opens and the level when the tank rests on it legs (if adjustible, high and low settings) To what standards (e.g. API, ASTM) were each tank built and maintained? Procedures for inspection, maintenance of tanks Any policy, guidance, or interpretation of regulations and what that means for the operation of the tank or controls. Spreadsheet or database used to track inspections/repairs Current inventory for each tank - material stored, level How are tank levels recorded? Are roof landings included in the facility permit(s)? Provide a listing of tanks that have been landed, when they were landed, and the duration of the landing. How are roof landings tracked/documented? Are different emission factors used for Emission Inventory reporting? Title V reports (ACC, Semi-annual Monitoring and Deviation Reports Period 5 years 5 years Provide all notifications and/or record of communication for fill/refill of IFR storage vessels to LDEQ 5 years Provide copies of records of inspection (i.e. prior to filling the tank, roof top inspections, internal inspections each time emptied/degasses). If no internal inspection w/in 5 years, provide records of the last internal inspection. Include: Storage vessel ID, date of inspection, observed condition of each component of the control eqt (seals, IFR, and fittings) Provide all reports to LDEQ of failed roof top visual inspections Provide all reports to LDEQ of failed internal inspections Provide certif rpt to LDEQ for all new IFR tanks NESHAP Subpart EEEE (OLD MACT) Notice of Compliance Status OLD MACT Semi-annual Compliance Reports Compliance method for each tank subject ot EEEE Last performance test record for each flare. Leak Detection and Repair (LDAR) reports 5 years 5 years 5 years since 2014 5 years 5 years EPA Inspection Report - Page 46 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 5 Tank Daily Gauge as of 4/18/2019 EPA Inspection Report - Page 47 of 254 EPA Inspection Report - Page 48 of 254 EPA Inspection Report - Page 49 of 254 EPA Inspection Report - Page 50 of 254 EPA Inspection Report - Page 51 of 254 EPA Inspection Report - Page 52 of 254 EPA Inspection Report - Page 53 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 6 Facility Site Plan EPA Inspection Report - Page 54 of 254 IFR Tank Tanks in benzene service Tanks in natural gasoline service EPA Inspection Report - Page 55 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 7 Permit 1280-00025-03 issued 10/7/1992, selected pages EPA Inspection Report - Page 56 of 254 EPA Inspection Report - Page 57 of 254 EPA Inspection Report - Page 58 of 254 EPA Inspection Report - Page 59 of 254 EPA Inspection Report - Page 60 of 254 EPA Inspection Report - Page 61 of 254 EPA Inspection Report - Page 62 of 254 EPA Inspection Report - Page 63 of 254 EPA Inspection Report - Page 64 of 254 EPA Inspection Report - Page 65 of 254 EPA Inspection Report - Page 66 of 254 EPA Inspection Report - Page 67 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 8 Current Title V Permit 1280-00025-V9 issued 10/17/2018, selected pages EPA Inspection Report - Page 68 of 254 EPA Inspection Report - Page 69 of 254 EPA Inspection Report - Page 70 of 254 EPA Inspection Report - Page 71 of 254 EPA Inspection Report - Page 72 of 254 EPA Inspection Report - Page 73 of 254 EPA Inspection Report - Page 74 of 254 EPA Inspection Report - Page 75 of 254 EPA Inspection Report - Page 76 of 254 EPA Inspection Report - Page 77 of 254 EPA Inspection Report - Page 78 of 254 EPA Inspection Report - Page 79 of 254 EPA Inspection Report - Page 80 of 254 EPA Inspection Report - Page 81 of 254 EPA Inspection Report - Page 82 of 254 EPA Inspection Report - Page 83 of 254 EPA Inspection Report - Page 84 of 254 EPA Inspection Report - Page 85 of 254 EPA Inspection Report - Page 86 of 254 EPA Inspection Report - Page 87 of 254 EPA Inspection Report - Page 88 of 254 EPA Inspection Report - Page 89 of 254 EPA Inspection Report - Page 90 of 254 EPA Inspection Report - Page 91 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 9 RMP Registration and De-Registration EPA Inspection Report - Page 92 of 254 Facility Name: LBC Baton Rouge, LLC EPA Facility Identifier: 1000 0021 3002 Plan Sequence Number: 1000018680 Section 1. Registration Information Source Identification - Facility Name: LBC Baton Rouge, LLC Parent Company #1 Name: LBC Houston, LP Parent Company #2 Name: - Submission and Acceptance - Submission Type: First-time submission Subsequent RMP Submission Reason: Description: Receipt Date: 08-Apr-2011 Postmark Date: 08-Apr-2011 Next Due Date: 08-Apr-2016 Completeness Check Date: 08-Apr-2011 Complete RMP: Yes De-Registration / Closed Reason: 04 De-Registration / Closed Reason Other Text: Project cancelled, product never handled at Facility De-Registered / Closed Date: 03-Aug-2011 De-Registered / Closed Effective Date: 29-Jul-2011 Certification Received: Yes - Facility Identification - EPA Facility Identifier: 1000 0021 3002 Other EPA Systems Facility ID: LAD096040712 Facility Registry System ID: - Dun and Bradstreet Numbers (DUNS) - Facility DUNS: 92487172 Parent Company #1 DUNS: Parent Company #2 DUNS: - Facility Location Address - Street 1: 1725 Hwy 75 Street 2: City: Sunshine State: LOUISIANA ZIP: 70780 ZIP4: County: IBERVILLE - Facility Latitude and Longitude - Latitude (decimal): 30.284444 Longitude (decimal): -091.134833 Lat/Long Method: Interpolation - Map Lat/Long Description: Plant Entrance (General) Horizontal Accuracy Measure: 25 Horizontal Reference Datum Name: North American Datum of 1983 Source Map Scale Number: 24000 Data displayed is accurate as of 12:00 AM (EDT) Friday, June 07, 2019 Page 1 of 17 EPA Inspection Report - Page 93 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 10 Title V Permit 1280-00025-V4 application, selected pages EPA Inspection Report - Page 94 of 254 EPA Inspection Report - Page 95 of 254 EPA Inspection Report - Page 96 of 254 EPA Inspection Report - Page 97 of 254 EPA Inspection Report - Page 98 of 254 EPA Inspection Report - Page 99 of 254 EPA Inspection Report - Page 100 of 254 EPA Inspection Report - Page 101 of 254 EPA Inspection Report - Page 102 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 11 Shawn Flannigan Louisiana PE License 0033081 expired 9/30/2011 EPA Inspection Report - Page 103 of 254 LOUISIANA PROFESSIONAL ENGINEERING AND LAND SURVEYING BOARD As of 12/06/2018 , the Louisiana Professional Engineering and Land Surveying Board (LAPELS) has the following information on file: Mr. Steven Shawnacey Flannigan 21811 Ann Circle Magnolia, TX 77355-4591 Fold Here LOUISIANA PROFESSIONAL ENGINEERING & LAND SURVEYING BOARD (LAPELS) 9643 Brookline Avenue, Suite 121 Baton Rouge, LA 70809 Phone (225) 925-6291 www.lapels.com Mr. Steven Shawnacey Flannigan License/Certificate Type - Number PE.0033081 Expiration Date 09/30/2011 Status: Expired Please be advised that your license must be in "Active" status in order for you to (a) provide or offer to provide engineering or land surveying services in Louisiana or (b) use the words "engineer", "engineering", "land surveyor", "land surveying" or any modification or derivative thereof in your name or in connection with your business or activities in Louisiana. Licensees whose licenses are in "Retired", "Inactive", or "Expired" status are prohibited from engaging in the activities described above in items (a) and (b). LA R. S. 37:689 requires firms practicing or offering to practice engineering or land surveying in the state of Louisiana to be licensed by the Board prior to offering such services. Cut Here Print and keep the following information for your record or verification. The pocket card may also be printed on card stock or laminated to keep with you as license/certificate verification. Disclaimer All information provided by LAPELS on this web page, and on its other web pages and internet sites, is made available to provide immediate access for the convenience of interested persons. While LAPELS believes the information to be reliable, human or mechanical error remains a possibility, as does delay in the posting or updating of information. Therefore, LAPELS makes no guarantee as to the accuracy, completeness, timeliness, currency, or correct sequencing of the information. Neither LAPELS, nor any of the sources of the information, shall be responsible for any errors or omissions, or for the use or results obtained from the use of this information. Other specific cautionary notices may be included on other web pages maintained by LAPELS. EPA Inspection Report - Page 104 of 254 If you need to make changes to your contact information, please choose one of the following options below: Contact update for Individuals Contact update for Firms License/Certificate Types: EF = Engineering Firm VF = Land Surveying Firm CPD = Continuing Professional Development Sponsor/Provider *PE = Professional Engineer *EI = Engineer Intern *PLS = Professional Land Surveyor *LSI = Land Surveyor Intern *PE Discipline Codes AG Agricultural ME Mechanical AR Architectural MI Mining or Mineral CH Chemical MT Metallurgical CE Civil MU Manufacturing CS Control Systems NV Naval Architecture & Marine EE Electrical & Computer NU Nuclear EV Environmental ST Structural * FP Fire Protection PT Petroleum IE Industrial * An engineer that has passed the Structural I exam is listed as a Civil Engineer. An engineer that has passed both the Structural I and II exams is listed as Structural (ST) and a Civil (CE) Engineer. EPA Inspection Report - Page 105 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 12 NESHAP Subpart EEEE NOCS - Initial and Tanks 80-1 and 80-2 EPA Inspection Report - Page 106 of 254 EPA Inspection Report - Page 107 of 254 EPA Inspection Report - Page 108 of 254 EPA Inspection Report - Page 109 of 254 EPA Inspection Report - Page 110 of 254 EPA Inspection Report - Page 111 of 254 EPA Inspection Report - Page 112 of 254 EPA Inspection Report - Page 113 of 254 EPA Inspection Report - Page 114 of 254 EPA Inspection Report - Page 115 of 254 EPA Inspection Report - Page 116 of 254 EPA Inspection Report - Page 117 of 254 EPA Inspection Report - Page 118 of 254 EPA Inspection Report - Page 119 of 254 EPA Inspection Report - Page 120 of 254 EPA Inspection Report - Page 121 of 254 EPA Inspection Report - Page 122 of 254 EPA Inspection Report - Page 123 of 254 EPA Inspection Report - Page 124 of 254 EPA Inspection Report - Page 125 of 254 EPA Inspection Report - Page 126 of 254 EPA Inspection Report - Page 127 of 254 EPA Inspection Report - Page 128 of 254 EPA Inspection Report - Page 129 of 254 EPA Inspection Report - Page 130 of 254 EPA Inspection Report - Page 131 of 254 EPA Inspection Report - Page 132 of 254 EPA Inspection Report - Page 133 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 13 Tank Activity 2015-2018 EPA Inspection Report - Page 134 of 254 Tank 15-2 55-4 55-5 55-6 55-7 55-8 55-9 55-10 55-11 55-13 55-14 55-15 80-1 80-2 80-6 80-7 80-8 80-9 110-2 110-3 Construction Date (if after Initial NOCS) Initial NOCS 2007 OLD MACT Updated Updated NOCS 2013 NOCS 2014 Landed? 2015 Products Empty/ degas? Y Y Y 2016 Dates Landed? Products Y Nat Gas DA120 + DA135 Y Nas Gas Benzene VTAP LDAR? 1H - n/a 2H - n/a 1H 2H 1H 2H 1H - n/a 2H - n/a Empty/ degas? Y Dates 12/29/16 - 7/2/17 Y 4/11/16 - 4/21/16 Y 6/23/16 - 7/11/16 Y Y Y Y Y 2016 2016 2013 Y 2013 Y Y Y Y 2008 2008 y Toluene Benzene Y 3/27/15 - 4/12/15 1H 2H 1H - n/a 2H - n/a 1H 2H 1H 2H 1H 2H Y Fuel Ethanol new svc 12/3/2016 Y Benzene 1H Pygas 2H Y Y Benzene 1H Ethylbenzene 2H 1H 2H 1H 2H 1H - n/a 2H - n/a y Pygas Y 11/9/15 - 1H Benzene 12/4/15 2H (new cust) Y (non-IFR product) 1H Benzene 2H Y ??? - 5/19/16 Landed? Products Y Toluene/ Xylene mix Y Avgas Y Ethylbenzene Benzene Y Benzene Pygas Aklylate Y Benzene Reformate 2017 VTAP LDAR? Empty/ degas? Dates Landed? Products 2H - n/a 1H 2H 1H 2H 2H - n/a 1H 2H 2H - n/a 1H 2H 1H 2H 1H 2H 1H 2H 1H 2H 1H 2H 1H 2H 2H - n/a 1H 2H * 1H 2H Y 12/2/16 - 12/17/17 Y Toluene/ Xylene mix Mixed Xylene Reformate No tank landings yet 1Q and 4Q 2017 stored benzene new svc 2/18/2017 N y Pygas Benzene N Y 8/6/17 - 12/15/17 N 11/12/17 - 11/13/17 Y Full Range Alkylate Toluene/ Xylene mix Mixed Xylene Y Pygas** Benzene 2018 VTAP LDAR? 2H - n/a 1H 2H 1H 2H 2H - n/a 1H 2H 2H - n/a 1H 2H 1H 2H 1H 2H 1H 2H 1H 2H 1H 2H 1H 2H 2H - n/a 2H*** 1H 2H Empty/ degas? Dates y? 5/5/18 - 5/5/18 Y? 8/8/18 - 8/9/18 Y 8/5/18 - 9/18/18 Y? 4/21/18 - 4/22/18 Y? 5/5/18 - 5/6/18 Y 1/28/18 - 2/22/18 110-4 2008 Y Naphtha 1H 1H 2H - not 2H listed 2H*** 2H*** EPA Inspection Report - Page 135 of 254 Tank 120-1 Construction Date (if after Initial NOCS) Initial NOCS 2007 Y OLD MACT Updated Updated NOCS 2013 NOCS 2014 Landed? 2015 Products Empty/ degas? Dates Landed? Products Y Nat Gas Alkylate 2016 VTAP LDAR? Empty/ degas? Y Dates 5/20/16 - 12/12/16 Landed? Products Y Alkylate Reformate 120-2 Y Y Naphtha Reformate * 2H 2017 VTAP - Tank 80-9 states it contained benzene in 3Q and 4Q 2017 yet landing rpt states alkylate. ** Tank 110-2: 2018 Landing Rpt shows change from Pygas to Benzene, but 2017 had benzene to reformate. *** tanks are storing "Xylene (Naphtha) 1H 2H - not listed Y 5/16/16 - 12/14/16 Y Reformate Alkylate 2017 2018 VTAP LDAR? Empty/ degas? Y? Dates 5/27/17 - 12/21/17 Landed? Products Y Reformate Full Range Alkylate Mixed Xylene Reformate 1H 2H - n/a Y? 4/21/17 - 12/30/17 Y Full Range Alkylate Mixed Xylene Reformate VTAP LDAR? 2H 2H Empty/ degas? Y? Y? Y? Y? Y? Dates 2/10/18 - 2/11/18 2/22/18 - 2/23/18 8/4/18 - 8/5/18 4/20/18 - 4/22/18 8/7/18 - 8/8/18 EPA Inspection Report - Page 136 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 14 Tank Landings 2015-2018 EPA Inspection Report - Page 137 of 254 INTERNAL FLOATING ROOF LANDING FORM TANK # 20-1 DATE 3/14/14 TIME 0900 L L TEMP 5' 4" 60 PRODUCT Heptene LANDED FLOATED CUSTOMER X VESSEL K 10014 55-8 3/27/15 0500 5' 2" 65.8 Toluene TX X 55-8 4/12/15 1130 5' 2" 67.7 Benzene X 80-9 11/9/15 0001 5' 2" 69.8 80-9 12/4/15 1830 5' 2" 73.2 Pygas Benzene X X 110-4 11/20/15 1400 4' 1" 68.5 110-4 11/20/15 2140 4' 1" 66.2 Naphtha Naphtha X X CHEM 3714 BOW HERON K 24703 Bow Trajectory FMT 3104 FMT 3124 2015 COMMENTS Customer cleaned tank Customer cleaned tank and changed products New product for customer Customer getting out of tank New Customer/New Product Varec gauge off - missed stop gauge Unloaded product from barge to float roof EPA Inspection Report - Page 138 of 254 EPA Inspection Report - Page 139 of 254 Notes: Tanks with IFRs but product doesn't require one: 55-4 Renewable Diesel 55-9 Octene 110-2 EHC 110 EPA Inspection Report - Page 140 of 254 INTERNAL FLOATING ROOF LANDING FORM TANK # 20-1 DATE 3/14/14 TIME 0900 L L TEMP 5' 4" 60 PRODUCT Heptene LANDED FLOATED CUSTOMER X VESSEL K 10014 55-5 4/11/16 1913 6' 2" 65 55-5 4/21/16 6' 2" 71 X X Nat. Gas Benzene Trans to 15-2 Trans from 55-6 110-2 5/19/2016 1700 4' 1" 78.9 120-2 5/16/16 1815 3' 10" 73 120-2 12/14/16 0932 3' 10" 60.1 120-1 5/20/16 1100 4' 2" 72.6 120-1 12/12/16 1140 4' 2" 62.4 55-5 6/23/16 1400 6' 2" 81.4 55-5 7/11/16 1730 6' 2" 84.3 80-1 9/6/16 03:30 4' 7" 81.3 80-1 9/29/16 10:00 4' 7" 79.8 80-2 11/3/16 01:15 4' 7" 74.1 80-2 11/4/16 05:30 4' 7" 80.3 15-2 12/29/16 0900 5' 3" 60 X Benzene Trans from 80-1 X Naphtha Trans to 110-4 X Reformate WEB 352/353 X Nat. Gas. Trans to 110-3 X Alkylate HTCO 3098/3099 X X Benzene Benzene Trans to 55-8 Navig8 Aragonite X X Benzene Pygas Trans to 110-2 K 10077 X Benzene Transfer to 80-6 X Ethylbenzene K 28059 X Nat Gas Trucks 55-7 12/2/16 1600 5' 0" 62.6 X Fuel Ethanol Trans to 55-15 2016 COMMENTS Customer cleaned tank Customer getting out of tank-Tk cleaned New Customer - New Product Prior Customer AC 600 - IFR not required. New Customer - New Product Customer giving up tank New customer - new service Customer giving up tank New customer - new service Off Spec Product - Stripped - Cleaned Rec'd new product Customer giving up tank New customer - New product Customer changing product New Product - No cleaning prior Customer giving up tank Customer changing tanks 55-15 12/3/16 2232 4' 10" 61.2 X Fuel Ethanol Trans from 55-7 New Service EPA Inspection Report - Page 141 of 254 EPA Inspection Report - Page 142 of 254 Notes: Tanks with IFRs but product doesn't require one: 55-4 Renewable Diesel 55-9 Octene EPA Inspection Report - Page 143 of 254 INTERNAL FLOATING ROOF LANDING FORM TANK # 20-1 DATE 3/14/14 TIME 0900 L L TEMP 5' 4" 60 PRODUCT Heptene LANDED FLOATED CUSTOMER X VESSEL K 10014 15-2 12/29/16 0900 5' 3" 60 15-2 7/2/17 5' 3" 55-7 12/2/16 1600 5' 0" 62.6 55-7 12/17/17 2200 5' 2" 68.3 X Nat Gas Trucks DA 120 + DA135 X Fuel Ethanol Trans to 55-15 X Toluene/Xylene Mix K 15001D 55-15 12/3/16 2232 4' 10" 61.2 80-2 1/23/17 0700 4' 7" 62.9 80-2 1/24/17 0900 4' 7" 61.9 X Fuel Ethanol Trans from 55-7 X Ethylbenzene K 30501B X Benzene Trans from 110-2 55-14 2/18/17 2334 4' 9" 60.5 80-9 4/11/17 0315 5' 2" 68.4 80-9 4/12/17 1830 5' 2" 89 120-2 4/21/17 1815 3' 10" 71.9 120-2 12/30/17 1345 3' 10" 58 120-1 5/27/17 2045 4' 2" 76.9 120-1 12/21/17 1900 4' 10" 61 80-9 8/6/17 1200 5' 2" 77.6 80-9 12/15/17 0200 5' 2" 55 110-2 11/12/17 2100 4' 1" 65.4 110-2 11/13/17 0530 4' 1" 66.5 80-2 11/22/17 1600 4' 7" 65.8 80-2 11/22/17 1620 4' 7" 65.8 X Avgas K 29118 X X Benzene Pygas Transfer to 55-8 Bow Flora X Reformate CBC 370 X Alkylate Transfer from 80-9 X Alkylate G 403 X Reformate GBL 4630/4730 X X Pygas Alkylate Trans to 80-1 EMS 394/343 X Benzene X Reformate CCL 416T K 10078 X X Benzene Benzene FMT 3266 FMT 3266 2017 COMMENTS Customer cleaned tank Customer giving up tank Customer changing tanks New Customer-New product New Service Customer changing products New product - no prior cleaning New Service Customer changing product New Product - no prior cleaning Customer giving up tank New customer-New Product Customer giving up tank New Customer-new product Customer giving up tank New Customer-New Product Customer changing products New product-no prior cleaning Missed stop gauge Float roof again EPA Inspection Report - Page 144 of 254 EPA Inspection Report - Page 145 of 254 Notes: Tanks with IFRs but product doesn't require one: 55-4 Renewable Diesel 55-9 Octene 15-2 EPA Inspection Report - Page 146 of 254 EPA Inspection Report - Page 147 of 254 INTERNAL FLOATING ROOF LANDING FORM TANK # 20-1 DATE 3/14/14 TIME 0900 L L TEMP 5' 4" 60 PRODUCT Heptene LANDED FLOATED CUSTOMER X VESSEL K 10014 110-2 1/28/18 1300 4' 1" 46.8 110-2 2/22/18 1530 4' 1" 69 Pygas Benzene X X 120-1 2/10/18 1915 4' 1" 55.6 Reformate X 120-1 2/11/18 2000 4' 1" 59.8 Full Range Alkylate X 120-1 2/22/18 1500 4' 10" 65.5 Full Range Alkylate X 120-1 2/23/18 2045 4' 10" 68.7 Mixed Xylene X 80-9 4/21/18 0115 5' 2" 64.2 Full Range Alkylate X 80-9 4/22/18 1400 5' 2" 64.5 Toluene Xylene Mix X 120-2 4/20/18 2345 3' 10" 65.3 Full Range Alkylate X 120-2 4/22/18 445 3' 10" 66.4 Mixed Xylene X 80-9 5/5/18 2300 5' 2" 72.2 Toluene/Xylene Mix X 80-9 5/6/18 1100 5' 2" 75.5 Mixed Xylene X 55-7 5/5/18 0100 5' 2" 69.8 Toluene/Xynlene Mix X 55-7 5/5/18 0840 5' 2" 71.7 Mixed Xylene X 80-1 8/5/18 1300 4' 7" 81 80-1 9/18/18 0800 4' 7" 84 Pygas Benzene X X 120-1 8/4/18 1745 4' 10" 82 Mixed Xylene X 120-1 8/5/18 1130 4' 10" 88.4 Reformate X 120-2 8/7/18 0415 3' 10" 88 Mixed Xylene X 120-2 8/8/18 1000 3' 10" 86.4 Reformate X 55-7 8/8/18 0010 5' 2" 81.6 Mixed Xylene X 55-7 8/9/18 1230 5' 2" 87.1 Reformate X Chem 3708 CHEM 3231 GBL 2330/830 Transfer from 80-9 Transfer to 80-9 K 30002/30040 K 30074/30083 Transfer from 55-7 K 30074/30083 Transfer from 120-1 MMLP 325 Transfer from 120-1 MMLP 325 Transfer from 120-1 K 28163 Transfer from 110-2 Transfer to 80-9 G 403/410 Transfer to 80-9 Transfer from 120-1 Transfer to 80-9 Transfer from 120-1 2018 COMMENTS Customer cleaned tank Cleaning tank - changing product New Product Customer changing product New product Customer changed product New Product Customer changed product New Product Customer changed products New Product Customer Changed Product New Product Customer Changed Product New Product Customer giving up tank New Customer/New Product Customer Changed Product New Product Customer Changed Product New Product Customer Changed Product New Product EPA Inspection Report - Page 148 of 254 55-7 9/21/18 2222 5' 2" 79.8 Reformate 55-7 9/22/18 0430 5' 2" 88.1 Alkylate X X 55-8 9/24/18 1330 5' 2" 80.2 55-8 10/17/18 0645 5'2" 72.6 Benzene Benzene X X 80-9 10/2/18 1000 5' 2" 80.9 Mixed Xylene X 80-9 10/3/18 2300 5' 2" 83.4 Reformate X 80-9 11/1/18 1830 5' 2" 69.9 Reformate X 80-9 11/2/18 1240 5' 2" 74.1 Full Range Alkylate X 55-4 12/22/18 1715 5' 2" 50.9 Benzene X Transfer to 120-2 HTCO 3114/3117 Transfer to 55-6 Transfer from 80-1 CHEM 3254/3216 Transfer from 120-1 Transfer to 120-1 FMT 3030/3032 HFL 405 Customer Changed Product New Product Customer contracted ended New Customer/New Product Customer Changed Product Customer Changed Product Customer Changed Product Customer Changed Product Prior Cargo didn't require IFR New Customer/Product EPA Inspection Report - Page 149 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 15 Sunshine Terminal Tank Table EPA Inspection Report - Page 150 of 254 EPA Inspection Report - Page 151 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 16 Ultraflote and Ultraseal Specification Sheets EPA Inspection Report - Page 152 of 254 EPA Inspection Report - Page 153 of 254 EPA Inspection Report - Page 154 of 254 EPA Inspection Report - Page 155 of 254 EPA Inspection Report - Page 156 of 254 EPA Inspection Report - Page 157 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 17 DuPont Surlyn Technical Information: Chemical Resistance EPA Inspection Report - Page 158 of 254 DuPontTM Surlyn IONOMER RESINS TECHNICAL INFORMATION: CHEMICAL RESISTANCE DuPontTM Surlyn resins have outstanding resistance to both physical and chemical attack. They are also highly resistant to permeation by liquids. However, some aromatic, cyclic, and high eraliphatic hydrocarbon solvents cause swelling and permeate through the resin; therefore, they should be used with caution. The permeation rate of any liquid will vary depending upon the particular grade of resin and wall thickness, as well as the molecular weight and polarity of the liquid. Note: This report applies to industrial applications for Surlyn resins and not for flexible packaging applications. Generally, industrial applications involve material thicknesses greater than 20 mil. Flexible packaging applications, by comparison, typically involve thin films and/or thin coatings or laminations to other substrates. The chemical resistance performance of Surlyn for these thin, flexible packaging applications may be different than indicated in this report. Chemical environmental effects on Surlyn resins may be divided into three categories: oxidation, stress cracking, and plasticization. Only oxidation is a chemical degradation; the other two involve the physical properties of the polymer. Oxidizers Oxidizers are capable of chemically degrading Surlyn. The chemical effects of even a strong oxidizer may be gradual and may not be measurable over the short term. However, they may be significant over the long term and should be evaluated if continuous exposure is expected. The following materials are examples of strong oxidizers that are unsuitable for long-term exposure to Surlyn resin: Nitric acid, fuming Sulfuric acid, fuming (oleum) Aqua regia Chlorine (wet gas) Bromine (liquid) Stress Crack Agents Certain surface-active materials, although they have no chemical effect, can accelerate the cracking of Surlyn resins when under stress. This accelerated form of stress failure is called environmental stress cracking (ESC). Although all resins are subject to stress cracking, some are more susceptible to it than others. Certain Surlyn grades are specially designed to be more resistant to this type of failure. ESC failure depends on the amount of stress in the resin and, therefore, thermal history and design factors are very important. When designing for known or possible stress crack agents, Surlyn grade selection and optimum fabrication techniques (i.e., for minimum internal stress) must be considered. The following materials are examples of stress crack agents that are unsuitable for long-term exposure to Surlyn resin: Methyl alcohol Ethyl alcohol n-Propyl alcohol Isopropyl alcohol Ethylene glycol Plasticizers Certain types of nonaqueous chemicals are absorbed to varying degrees by Surlyn resins causing swelling, weight gain, softening, and some loss of yield strength. These plasticizing materials cause no actual chemical degradation of the resin. Some organic solvents such as aliphatic hydrocarbons, chlorinated hydrocarbons, aromatics, and heterocyclic compounds have a strong plasticizing action (10--20% solubility in the polymer). However, most of these solvents are sufficiently volatile, so that if they are removed from contact with the resin, the part will" dry out" and return to its original condition with no impairment of properties. Sodium-type resins absorb less of these solvents than zinc types. Conversely, aqueous solutions will plasticize sodium-type resins more than zinc types. If the end product is unsupported, absorption of either aqueous or nonaqueous product will reduce the product stiffness and may change color and increase internal haze. EPA Inspection Report - Page 159 of 254 Testing Is Important It cannot be expected that one chemical resistance data chart will include the effects of all chemicals. Furthermore, the suitability of Surlyn depends not only on the nature of the chemical environment, but also on the expected service temperature and stress, the duration of exposure, and whether it is intermittent or continuous. Because so many variables are involved, it must be recognized that standard laboratory tests can give only a general guide as to whether a resin may resist exposure to a specific environment. Therefore, the feasibility of any chemical environment must be determined by extensive laboratory tests carried out under conditions that approximate as closely as possible those expected in service. The following procedure is recommended to determine the suitability of Surlyn to resist a specific chemical exposure: 1. Immerse a sample of the Surlyn resin in the chemical under study. The sample should be preweighed and immersed at the expected service temperature for a reasonable time. Note: Many of the chemicals under study may be toxic, corrosive, flammable, and/or irritants. In addition, many of the chemicals under study should not be inhaled, ingested, or come in contact with human skin. Therefore, accepted industrial standards should be used when involved with these chemicals. 2. At the end of the test period, the sample should be reweighed to determine if there is a weight gain or loss. In addition, any change in surface hardness should be noted. 3. Check for chemical degradation of the resin by observing any surface crazing, cracking, or discoloration. 4. Tensile properties should be checked by measuring ultimate tensile strength and elongation. Tensile properties will change with percent plasticization. If chemical attack has occurred, a remarkable decrease in ultimate tensile strength should be evident. 5. Environmental stress cracking characteristics of the chemical understudy can be determined using ASTM test procedure D1693 by substituting the chemical of interest for the test liquid specified in this procedure. Guide to Chemical Resistance The chemical resistance data presented in the following table originated in part from tests conducted at DuPont laboratories and, in part, from reliable published sources. This table is intended only as a preliminary, general guide to the resistance of Surlyn to various chemicals. It should not be used by the industry as the basis for final decisions because the specific end-use application, design, and/or conditions of use may have added effects on performance in a particular chemical environment. It is recommended that laboratory testing of the specific end-use application be conducted under expected service conditions. Resistance Code R Resistant; no indication that serviceability would be impaired. Caution Code O Oxidizer P Plasticizer V Variable resistance, depending on conditions of use.* A Known stress crack agentb U Not resistant. Not recommended for service applications under any conditions B Possible stress crack agentb aThe classification "variable resistance" is very broad. Depending on the nature of the chemical, its concentration, the service temperature and pressure, and the time of exposure, Surlyn resin can be either very resistant or very susceptible to attack. Therefore, where Surlyn is said to have variable resistance to a chemical, it is critical that extensive pretesting be conducted. b A system using Surlyn in exposure to a chemical to which it is designated resistant, but which carries a stress crack identifier (A or B), may be serviceable over a useful lifetime providing the following precautions are observed: A stress crack resistant grade of Surlyn resin should be used. Stresses in the fabricated Surlyn must be minimized by design and processing. Conditions and limitations of the application should be carefully observed (avoidance of high temperature, etc.) EPA Inspection Report - Page 160 of 254 Caution Code B B Chemical Acetaldehyde (100%) Acetic Acid (10%) Acetic Acid (60%) Acetic Anhydride Acetone Acrylic Emulsions Chemical Resistance Data - Surlyn Resin Chemical Resistance Code 21C 60C Cautio (70F) (140F) n Code Chemical V U Beer R R B Beet Sugar Liquors R V B Benzaldehyde R R P Benzene R * P Benzene Sulfonic Acid (10%) R R Benzoic Acid Chemical Resistance Code 21C 60C (70F) (140F) R R R R V U R V R R R R Adipic Acid R R Air R R B,P Allyl Chloride U U Aluminum Chloride R R Aluminum Fluoride R R Aluminum Hydroxide R R Aluminum Nitrate R R Aluminum Oxychloride R R Aluminum Sulfate R R Alums (all types) R R Ammonia (100% dry gas) R R Ammonia, Liquid R R Ammonium Acetate R R Ammonium Carbonate R R Ammonium Chloride R R Bismuth Carbonate R R Black Liquor R R Bleach Lye (10%) R R Borax R R Boric Acid R R Brine R R Bromic Acid R V O Bromine, Liquid U U O Bromine, Vapor (25%) U U O Bromine, Water U U P Butadiene V * P Butane R * A Butanediol R V Butter R R P n-Butyl Acetate (100%) R V Ammonium Fluoride Ammonium Hydroxide (10-28%) R R R R A n-Butyl Alcohol (100%) V U Butyric Acid U U Ammonium Metaphosphate R R Ammonium Nitrate R R Ammonium Persulfate R R Ammonium Phosphate, R R Ammoniacal and Neutral Ammonium Sulfide R R Ammonium Sulfate R R Cadmium Cyanide Calcium Bisulfite Calcium Bisulfide Calcium Carbonate Calcium Chlorate Calcium Chloride R R R R R R R R R R R R Ammonium Thiocyanate R R B,P Amyl Acetate (100%) U U A,P Amyl Alcohol (100%) P Amyl Chloride (100%) P Aniline (100%) V V U U R U Calcium Hydroxide R R B Calcium Hydroxide V V (bleach solution) Calcium Nitrate (50%) R R Calcium Oxide R R Calcium Sulfate R R P Aniline Hydrochloride U U B,P Camphor Oil U U Anthraquinone R R Carbon (slurry) R R Anthraquinone Sulfonic Acid R R Carbon Dioxide R R Antimony Trichloride R R Carbon Disulfide U U O Aqua Regia U U Carbon Monoxide R R P Aromatic Hydrocarbons R V P Carbon Tetrachloride U U Arsenic Acid R R Carbonic Acid R R Ascorbic Acid (10%) R R Castor Oil R R Barium Carbonate R R Caustic Potash R R Barium Chloride R R Caustic Soda R R Barium Hydroxide R R P Cellosolve R U Barium Sulfate R R P Chloralhydrate U U Barium Sulfide R R O Chlorine (100% dry gas) U U O Chlorine (wet gas) U U O Chlorine Liquid U U V -- Variable resistance U - Not resistant * -- Insufficient data Refer to text for explanation of Resistance and Caution Codes. EPA Inspection Report - Page 161 of 254 Caution Code B Chemical Chlorine Water (2%) Chemical Resistance Data - Surlyn Resin Chemical Resistance Code 21C 60C Caution (70F) (140F) Code Chemical R V Ferric Chloride P Chlorobenzene U P Chloroform U Chlorosulfonic Acid (100%) U Chromic Acid (10%) R O Chromic Acid (30--50%) R Cider R Citric Acid R A Coconut Oil Alcohols R Coffee R Cola Concentrates R Copper Carbonate R Copper Chloride R Copper Cyanide R Copper Fluoride (2%) R Copper Nitrate R Copper Sulfate R Corn Oil R Corn Syrup R P Cottonseed Oil R P Cresol U Crude Oil R Cupric Fluoride R Cupric Sulfate R Cuprous Chloride R B Cyclohexanol R P Cyclohexanone R B Detergents, Synthetic R Developers, Photographic R Dextrin R Dextrose R Diazo Salts R Dibutylphthalate R B,P Dichlorobenzene (o & p) U B Diethyl Ketone V A Diethylene Glycol R A Diglycolic Acid R Dimethylamine U P Dioctylphthalate R Disodium Phosphate R Distilled Water R P Esters R P Ethers R P Ethyl Acetate (100%) R P Ethyl Acrylate R A Ethyl Alcohol V B,P Ethyl Benzene U P Ethyl Chloride U P Ethyl Ether U B,P Ethylene Bromide U B,P Ethylene Chloride U B,P Ehtylene Chlorohydrin U B,P Ethylene Dichloride U A Ethylene Glycol V Ethylene Oxide R V -- Variable resistance U - Not resistant * -- Insufficient data U Ferric Hydroxide U Ferric Nitrate U Ferric Sulfate * Ferrous Chloride * Ferrous Sulfate R Fish Solubles R Fluoboric Acid V O Fluorine, Gas, Wet R Fluosilicic Acid (conc.) R Fluosilicic Acid (32%) R B Formaldehyde R Formic Acid R Fructose R B Fruit Pulp R P Furfural (100%) R B,P Furfuryl Alcohol R B Gallic Acid R P Gas, Natural, Dry and Wet R P Gasoline U P Gasoline, High Octane R P Genetron, 11, 12 & 22 R Glucose R R B Glycerine R A Glycol V A Glycolic Acid (30%) U Grape Sugar (sat. aq.) R P n-Heptane R Hexachlorobenzene R P Hexane R B Hexanol, Tertiary R * Hydrobromic Acid (50%) V Hydrochloric Acid U Hydrocyanic Acid U * Hydrofluoric Acid (40-- 60%) V Hydrogen (100%) R Hydrogen Chloride (dry gas) U Hydrogen Peroxide (3%) U Hydrogen Sulfide R Hydroquinone R Hydroxylamine Sulfate V Hypochlorous Acid V B Inks U O Iodine (in Kl solution) V A Isopropyl Alcohol U P Jet Fuels, JP4 and JP5 U P Kerosene U Kraft Liquors U Lactic Acid (25%) U Lard Oil U Latex U Lauric Acid U P Lauryl Chloride U V Refer to text for explanation of Resistance and Caution Codes. Chemical Resistance Code 21C 60C (70F) (140F) R R R R R R R R R R R R R R R R U U R V R R R V R R R R R R U U U U R R R * R V R V R * R R R R V U R R R R R V R R R V R R R R R R R R R R R R R R R V R R R R R R R R R R U U V U V U V U R R R R R R R R R V V * EPA Inspection Report - Page 162 of 254 Caution Code P P P P A P P P B,P P P B O O P P P P O O O P P P P Chemical Resistance Data - Surlyn Resin Chemical Resistance Code 21C 60C Caution Chemical (70F) (140F) Code Chemical Lead Acetate R R Phosphoric Acid Lead Chloride R R Photographic Solutions Lead Nitrate R R O Picric Acid Lead Sulfate R R Plating Solutions Brass Linseed Oil V U Cadmium Lithium Bromide R R Copper Lubricating Oil, ASTM R V Gold #1, #2, #3 Machine Oil R V Lead Magnesium Carbonate R R Nickel Magnesium Chloride R R Silver Magnesium Citrate R R Tin Magnesium Hydroxide R R Zinc Magnesium Nitrate R R Potassium Bicarbonate Magnesium Sulfate R R Potassium Bichromate Maleic Acid R R Potassium Borate Mercuric Chloride R R Potassium Bromate Mercuric Cyanide R R Potassium Bromide Mercurous Nitrate R R Potassium Carbonate Mercury Potassium Chlorate Methane R * Potassium Chloride Methyl Alcohol V U Potassium Chromate (40%) Methyl Chloride U U Potassium Cyanide Methyl Ethyl Ketone R V Potassium Dichromate (40%) Methyl Isobutyl Ketone R V Potassium Ferri/ Ferro Cyanide Methyl Sulfate R R Potassium Fluoride Methyl Sulfuric Acid R R Potassium Hydroxide Methylene Chloride U U Potassium Nitrate (100%) Milk R R Potassium Perborate Mineral Oils R V Potassium Perchlorate (10%) Molasses R R Potassium Permanganate (20%) Naptha V U Potassium Persulfate Napthalene U U Potassium Sulfate Nickel Chloride R R Potassium Sulfide Nickel Nitrate R R Potassium Sulfite Nickel Sulfate R R P Propane Nicotine (dilute) R R A Propargyl Alcohol Nitric Acid (0--10%) R V A n-Propyl Alcohol Nitric Acid (10--98%) U U P Propylene Dichloride (100%) Nitric Acid, fuming U U A Propylene Glycol Nitrobenzene (100%) U U Pyridine Nitrous Oxide R * Resorcinol n-Octane R R Salicylic Acid Oleic Acid U U Sea Water Oxalic Acid R R Selenic Acid Oxygen R V Sewage Ozone R * Shortening Perchloric Acid (10--70%) U U Silicic Acid Perchloroethylene R U Silver Cyanide Phenol U U Silver Nitrate Solution Phenylhydrazine U U Silver Sulfate Phenylhydrazine U U Soap Solution Hydrochloride V -- Variable resistance U - Not resistant * -- Insufficient data Refer to text for explanation of Resistance and Caution Codes. Chemical Resistance Code 21C 60C (70F) (140F) R R R R U U R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R R U U R V V U U U R V R U R R R R R R R R R R R R R R R R R R R R R R EPA Inspection Report - Page 163 of 254 Caution Code B O P P O O P P Chemical Resistance Data - Surlyn Resin Chemical Resistance Code 21C 60C Caution Chemical (70F) (140F) Code Sodium Acetate R R P Sodium Benzoate (35%) R R Sodium Bicarbonate R R P Sodium Bisulfate R R P Sodium Bisulfite R R P Sodium Borate R R B Sodium Bromide (dilute) R R Sodium Carbonate R R P Sodium Chlorate R R Sodium Chloride R R Sodium Cyanide R R A Sodium Dichromate R R Sodium Ferri/Ferro Cyanide R R P Sodium Fluoride R R Sodium Hydroxide R R Sodium Hypochlorite R V Sodium Nitrate R R Sodium Nitrite R R A Sodium Peroxide R * B Sodium Sulfate R R P Sodium Sulfide R R Sodium Sulfite R R Sour Crude Oil R V Stannic Chloride R R Stannous Chloride R R Starch Solution R R Stearic Acid (100%) R R Stoddards Solvent R V Sulfur R R Sulfur Dioxide, Dry or Wet R V Sulfuric Acid (0--30%) R R Sulfuric Acid (30--98%) U U Sulfuric Acid, fuming U U (oleum) Sulfurous Acid R R Tallow R V Tannic Acid R R Tanning Liquors R R Tartaric Acid R R Tetrahydrofuran U U Chemical Thionyl Chloride Titanium Tetrachloride Toluene Tributylphosphate Trichloroethylene Triethylene Glycol Trisodium Phosphate Turpentine Urea (0--30%) Urine Vanilla Extract Vinegar Vinyl Acetate Water Water, Acid Mine Water, Salt and Sea Wetting Agents Whiskey Wines Xylene Yeast Zinc Bromide Zinc Carbonate Zinc Chloride Zinc Nitrate Zinc Oxide Zinc Stearate Zinc Sulfate Chemical Resistance Code 21C 60C (70F) (140F) U U U U U U V V U U R V R R V U R R R R R V R R V * R R R R R R R R R V R V R V R R R R R R R R R R R R R R R R V -- Variable resistance U - Not resistant * -- Insufficient data Refer to text for explanation of Resistance and Caution Codes. EPA Inspection Report - Page 164 of 254 EPA Inspection Report - Page 165 of 254 DuPont Worldwide: Americas DuPont Packaging & Industrial Polymers Chesnut Run Plaza 730 974 Centre Road Wilmington, DE 19805 Tel: +1 302 774 1000 Tel: +1 800 628 6208 ext. 6 Fax: +1 302 355 4056 Asia Pacific DuPont China Holding Co., Ltd. Shanghai Branch 399 Keyuan Road, Bldg. 11 Zhangjiang Hi-Tech Park Pudong New District, Shanghai P.R. china (Postcode: 201203) Tel: +86 21 3862 2888 Fax: +86 21 3862 2889 Europe/Middle East/Africa DuPont de Nemours Int'l S.A. 2, Chemin du Pavillon P.O. Box 50 CH-1218 Le Grand Saconnex Geneva, Switzerland Tel: +41 22 717 51 11 Fax: +41 22 717 55 00 DuPont do Brasil, S.A. Alameda Itapecuru, 506 06454-080 Barueri, SP Brasil Tel: +55 11 4166 8000 Fax: +55 11 4166 8736 www.surlyn.dupont.com The technical data contained herein are guides to the use of DuPont resins. The advice contained herein is based upon tests and information believed to be reliable, but users should not rely upon it absolutely for specific applications because performance properties will vary with processing conditions. It is given and accepted at user's risk and confirmation of its validity and suitability in particular cases should be obtained independently. The DuPont Company makes no guarantees of results and assumes no obligations or liability in connection with its advice. This publication is not to be taken as a license to operate under, or recommendation to infringe any patents. CAUTION: Do not use in medical applications involving permanent implantation in the human body. For other medical applications, see DuPont Medical Caution Statement, H-50102. The DuPont Oval Logo, DuPontTM, The miracles of science and Surlyn are trademarks or registered trademarks of E.I. du Pont de Nemours and Company. (10/00) Printed in U.S.A. (Replaces: E-78676-2) Reorder No.: E-78676-3 EPA Inspection Report - Page 166 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 18 2017 LDEQ Inspection Report, selected pages Title V Deviation Report 1H 2015 VTAP LDAR Report 1H 2015 EPA Inspection Report - Page 167 of 254 EPA Inspection Report - Page 168 of 254 EPA Inspection Report - Page 169 of 254 EPA Inspection Report - Page 170 of 254 EPA Inspection Report - Page 171 of 254 EPA Inspection Report - Page 172 of 254 EPA Inspection Report - Page 173 of 254 EPA Inspection Report - Page 174 of 254 EPA Inspection Report - Page 175 of 254 EPA Inspection Report - Page 176 of 254 EPA Inspection Report - Page 177 of 254 EPA Inspection Report - Page 178 of 254 EPA Inspection Report - Page 179 of 254 EPA Inspection Report - Page 180 of 254 EPA Inspection Report - Page 181 of 254 EPA Inspection Report - Page 182 of 254 EPA Inspection Report - Page 183 of 254 EPA Inspection Report - Page 184 of 254 EPA Inspection Report - Page 185 of 254 EPA Inspection Report - Page 186 of 254 EPA Inspection Report - Page 187 of 254 EPA Inspection Report - Page 188 of 254 EPA Inspection Report - Page 189 of 254 EPA Inspection Report - Page 190 of 254 EPA Inspection Report - Page 191 of 254 EPA Inspection Report - Page 192 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 19 NESHAP Subpart EEEE Semi-annual Compliance Reports for 2018 EPA Inspection Report - Page 193 of 254 EPA Inspection Report - Page 194 of 254 EPA Inspection Report - Page 195 of 254 EPA Inspection Report - Page 196 of 254 EPA Inspection Report - Page 197 of 254 EPA Inspection Report - Page 198 of 254 EPA Inspection Report - Page 199 of 254 EPA Inspection Report - Page 200 of 254 EPA Inspection Report - Page 201 of 254 EPA Inspection Report - Page 202 of 254 EPA Inspection Report - Page 203 of 254 EPA Inspection Report - Page 204 of 254 EPA Inspection Report - Page 205 of 254 EPA Inspection Report - Page 206 of 254 EPA Inspection Report - Page 207 of 254 EPA Inspection Report - Page 208 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 20 NSPS Notification of Initial Startup - Tanks 80-1, 80-2, 55-15 EPA Inspection Report - Page 209 of 254 EPA Inspection Report - Page 210 of 254 EPA Inspection Report - Page 211 of 254 EPA Inspection Report - Page 212 of 254 EPA Inspection Report - Page 213 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 21 Tanks 55-14 and 55-15 EPA Inspection Report - Page 214 of 254 EPA Inspection Report - Page 215 of 254 EPA Inspection Report - Page 216 of 254 EPA Inspection Report - Page 217 of 254 EPA Inspection Report - Page 218 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 22 7-day Inspection Notification for Tanks 15-2, 120-1, 120-2 in 2017 EPA Inspection Report - Page 219 of 254 EPA Inspection Report - Page 220 of 254 EPA Inspection Report - Page 221 of 254 EPA Inspection Report - Page 222 of 254 EPA Inspection Report - Page 223 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 23 External Inspection Forms 2016 EPA Inspection Report - Page 224 of 254 EPA Inspection Report - Page 225 of 254 EPA Inspection Report - Page 226 of 254 EPA Inspection Report - Page 227 of 254 EPA Inspection Report - Page 228 of 254 EPA Inspection Report - Page 229 of 254 EPA Inspection Report - Page 230 of 254 EPA Inspection Report - Page 231 of 254 EPA Inspection Report - Page 232 of 254 EPA Inspection Report - Page 233 of 254 EPA Inspection Report - Page 234 of 254 EPA Inspection Report - Page 235 of 254 EPA Inspection Report - Page 236 of 254 EPA Inspection Report - Page 237 of 254 EPA Inspection Report - Page 238 of 254 EPA Inspection Report - Page 239 of 254 EPA Inspection Report - Page 240 of 254 EPA Inspection Report - Page 241 of 254 EPA Inspection Report - Page 242 of 254 EPA Inspection Report - Page 243 of 254 EPA Inspection Report - Page 244 of 254 EPA Inspection Report - Page 245 of 254 EPA Inspection Report - Page 246 of 254 EPA Inspection Report - Page 247 of 254 EPA Inspection Report - Page 248 of 254 EPA Inspection Report - Page 249 of 254 LBC Baton Rouge LLC / Sunshine Terminal Inspection Dates 04/22-23/2019 Appendix 24 Internal Inspection Forms 2018 EPA Inspection Report - Page 250 of 254 EPA Inspection Report - Page 251 of 254 EPA Inspection Report - Page 252 of 254 EPA Inspection Report - Page 253 of 254 EPA Inspection Report - Page 254 of 254