Document zQ9dmRryMp0vvd4jKok60Goxa

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6 1201 ELM STREET, SUITE 500 DALLAS, TEXAS 75270 September 22, 2020 VIA EMAIL: csanfilippo@txpetinv.com Mr. Chris Sanfilippo Texas Petroleum Investment Company - Bayou Sale Production Facility 101 La Rue France Ste. 406 Lafayette, Louisiana 70508 RE: Emission Inventory Permit Consistency Review Texas Petroleum Investment Company - Bayou Sale Production Facility (AI# 16846) Dear Mr. Sanfilippo: The U.S. Environmental Protection Agency (EPA) Region 6 is working with the Louisiana Department of Environmental Quality (LDEQ) and has reviewed your facility's emission inventory for criteria pollutant and hazardous air pollutant (HAP) emission totals, as reported to LDEQ. Based upon this review, EPA has determined that your reported emissions for some Emission Points exceeded your permit authorization limits. EPA had also reviewed your Title V reports for 2018 and did not find that these permit exceedances were reported. A detail by Emission Point of the differences between the reported emissions and permitted limits is included in the attachment to this letter. EPA is providing you the opportunity to clarify or explain these differences, especially if any of the following conditions are present: Sources and associated emissions included in the emission inventories that are not represented in permits (e.g. de minimis sources); Criteria pollutants or individual HAPs reported in the facility's emission inventories that are not represented in LDEQ permits or authorizations; Reported or unreported upset or other excess emission events (e.g. startup/shutdown). If Texas Petroleum Investment Company is interested in discussing or providing information about this matter, you have ten (10) working days from receipt of this letter to inform EPA by e-mail by contacting: Jack Telleck Enforcement Officer (ECDAT) Air Toxics Enforcement Section email: telleck.jack@epa.gov Subsequent to the above-referenced due date, Jack Telleck will arrange to meet with Texas Petroleum Investment Company via conference call. At that time, Texas Petroleum Investment Company may provide additional information to address the potential violations and present evidence that contravenes EPA's evidence. The primary goal is to ensure compliance with the applicable environmental laws and regulations; however, settlements will be available where appropriate. The EPA acknowledges that the COVID-19 pandemic may impact your business. If that is the case, please contact us regarding any specific issues you need to discuss. Please direct questions to Jack Telleck of the Air Enforcement Branch at 214-665-9732 or at telleck.jack@epa.gov. Thank you for your attention to this matter. Sincerely, STEVEN THOMPSON Digitally signed by STEVEN THOMPSON DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=STEVEN THOMPSON, 0.9.2342.19200300.100.1.1=68001003652657 Date: 2020.09.22 15:27:33 -05'00' Steve Thompson Chief Air Enforcement Branch Attachment ECC: Celena Cage, Louisiana Department of Environmental Quality, celena.cage@la.gov Attachment A TPIC - Bayou Sale Production Facility - Bayou Sale Field AI # Facility Name Permit Subject Item Subject Item Type Subject Item Desc Emission Type Parameter Desc Texas Petroleum 16846 Investment Company - 2660-00067-V5 EQT00000000020 Internal combustion 24, Compressor Routine CO Bayou Sale Production engine Engine 5A Facility Texas Petroleum 16846 Investment Company - 2660-00067-V5 EQT00000000020 Internal combustion 24, Compressor Routine NOx Bayou Sale Production engine Engine 5A Facility Permitted Limit (tpy) 24.47 30.95 ERIC Reported Emissions (tpy) 152.249 90.4492 Reported Emissions Over Permited Limit (tpy) 127.77 59.49