Document zzO99n6JZ4vXaDyXgdLkmvJgn

EPA Inspection Report - Page 1 of 29 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 04/13/2022 Air SIP, Title V, NESHAP, NSPS Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Phillips 66 Company Lake Charles Refinery 2200 Old Spanish Trail Westlake, Louisiana, 70669 2200 Old Spanish Trail P.O. Box 37 Westlake, Louisiana, 70669 Calcasieu Parish 337-491-4742 Erin Strang Environmental Team Lead Erin.T.Strang@P66.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000539757 AI#: 2538 / 2626V-17; 2623-V19 2201900005 324110 2911 Personnel participating in inspection: James Haynes EPA ECD-AT Ben Rosenthal EPA ECD-AT Erin Strang Phillips 66 Company Tricia Rapp Phillips 66 Company John Tarasiewicz Phillips 66 Company Dorey Meyers Phillips 66 Company Inspector Inspector Environmental Team Lead Environmental Specialist - Air Lead Environmental Specialist - Tanks Lead Environmental Manager EPA Lead Inspector Signature/Date BENJAMIN ROSENTHAL Digitally signed by BENJAMIN ROSENTHAL DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=BENJAMIN ROSENTHAL, 0.9.2342.19200300.100.1.1=68001003844840 Date: 2022.06.16 15:37:11 -05'00' Ben Rosenthal Date Supervisor Signature/Date JAMES LEATHERS Date: 2022.07.17 21:43:47 -05'00' Digitally signed by JAMES LEATHERS James Leathers Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 29 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors James Haynes and I, Ben Rosenthal, ("We", "Us") arrived at the Phillps 66 Company ("Phillips 66") Lake Charles Refinery (the "Facility", the "Site", or "LCR") on April 13, 2022, for an unannounced Clean Air Act ("CAA") inspection. We entered the facility and received safety passes at 1:55 p.m. We first met with Erin Strang, Phillips 66 Environmental Team Lead. CAA credentials were presented to Ms. Strang. We discussed the monitoring activities that were conducted using EPA's Geospatial Measurement of Air Pollution ("GMAP") vehicle on April 12, 2022. The GMAP made entry at the facility and detected emissions of sulfur compounds and volatile organic compounds while at the site. We explained that the scope of our inspection was to follow-up on the findings of the GMAP. The scope of the inspection is a partial compliance evaluation ("PCE") to identify the cause of the emissions detected by the GMAP at the site. This inspection occurred as part of the Administrator's Journey to Justice initiative. FACILITY DESCRIPTION Phillips 66 owns and operates the Facility, a petroleum refinery. The Facility processes crude oil into various petrochemical products including gasoline, heating oil, residual fuels, petroleum coke, feedstocks, and others. The Facility refines crude oil through atmospheric and vacuum distillation, and operates petroleum coker units, a calcining unit, a fluid catalytic cracking unit ("FCCU"), an alkylation unit, a polymerization unit, catalytic reformers, desulfurization units, sulfur recovery units, a hydrowaxer unit, a hydrofinisher unit, and associated infrastructure including Facility utilities. The facility operates for 8,760 hours per year. The LCR is organized into four process areas: Area A, Area B, Area C, and Area D. Area B includes the Sour/Crude Resid Tank Farm, which is used to receive and store feedstocks and charge them to refinery units in Area A and other areas as needed. One scrubber is used to control odors from the Hot Resid Tanks T-2001 and T-2002. The tanks in this unit are all steam heated. Area D includes the Tank Farm. The Tank Farm is used to receive, store, and charge feedstocks to process units and for outside product transfer. The Tank Farm also blends various components for finished product sales. The Tank Farm consists of external floating roof tanks, internal floating roof tanks, cone roof tanks, and pressure vessels (including spheres and bullets), as well as auxiliary equipment necessary to move and handle feedstocks and products. Section II - OBSERVATIONS We met with Ms. Strang, John Tarasiewicz, Phillips 66 Environmental Specialist - Tanks Lead, and Tricia Rapp, Phillips 66 Environmental Specialist - Air Lead, in a Facility conference room to discuss the scope of the inspection and planned inspection activities. We discussed the GMAP findings from the previous EPA Inspection Report - Page 3 of 29 day, Those findings included emissions observed at, or thought to originate from, tank T-2001 and 2005 -Residual oil holding ("Residuals") tanks, tank T-82-kerosene containing tank, tanks T-85/86-gasoline containing tanks, and tank T-338-FCCU residual containing tank. Ms. Strang explained that the emissions detected from tanks T-2001 and T-2005 where due to ongoing maintenance activities that had increased the amount of material in the tanks. Ms. Strang also explained that because of the GMAP monitoring on April 12, 2022, the gauging hatches of T-2001 and T-2005 where cleaned and re-seated on that day. This cleaning seemed to stop emissions from T-2005 but not T-2001, according to Ms. Strang. We asked for records relating to the maintenance activities that the Facility believed led to the emissions observed by the GMAP at the Residual tanks, including a chronology of events, and any sampling records of the stored tank material. Mr. Tarasiewicz explained that tank T-85 had recently failed a visual inspection with noted deficiencies in the seal gap, guide pole, and vacuum breaker. Ms. Strang also explained that the Facility was undergoing a maintenance turnaround. We decided to focus the field portion of the inspection on the Tank Farm in area D. We explained that we would utilize a FLIR GF320 Optical Gas Imaging Camera ("OGIC") to monitor components for leaks and to take photographic documentation (See Appendix 1 - Photograph Log and Appendix 2 - Video Log). Mr. Tarasiewicz stated he would bring the facility's OGIC to take comparative videos and photos. We departed the conference room and arrived in area D around 3:00 p.m. Using the OGIC, we observed hydrocarbon emissions from three tanks in area D. See Area of Concern ("AOC") 1. On T-82, we had noted that two large "door sheets" or areas where portions of the tank had been cut open for maintenance activities and then replaced. Ms. Strang noted that it was a maintenance practice to cut openings into the tank for construction equipment to remove built-up sludge from the interior of the tank. We observed several other tanks in the tank farms that appeared to have door sheets. See AOC 2. We also traveled to T-2001 in area B and made additional observations with the OGIC. The following table summarizes some of the observations made with the OGIC. Tank Number Tank Contents T-82 Kerosene T-85 T-86 T-2001 Gasoline Gasoline Residuals Table 1. List of Tanks Observed by EPA with the OGIC Hydrocarbons Visualized Emissions Observed with the Location OGIC Yes Observed at seal gap and coming from pinhole leaks. Yes Observed at seal gap. Yes Observed at open gooseneck vent on roof. No None. Viewing Location Base of Tank Roof of Tank Roof of Tank Base of Tank The top ten feet of the stairway leading to the roof of tank T-2001 was not accessible without a full-face respirator and supplied air due to safety concerns. A Leak Detection and Repair ("LDAR") Technician EPA Inspection Report - Page 4 of 29 from the facility with proper protective equipment accessed the roof of T-2001 and took measurements with a flame ionization detector. The technician did not observe detectable emission from the regulator flanges or connectors in proximity to the top of the stairwell. A high reading of 31,886 parts per million volatile organic compounds ("VOC") was observed along the observation hatch. The technician attempted to lift and re-seat the hatch, which she described as loose and vibrating. The technician was unsure if the hatch was gasketed or the connection at the opening was metal to metal. See AOC 3. We proceeded to the oil water separator. Mr. Haynes did not observe emissions with the OGIC at the oil water separator. Section III - AREAS OF CONCERN We returned to the facility conference room to discuss our observations and met with Dorey Meyers, Phillps 66 Environmental Manager. We discussed the visualized emissions at several of the tanks. Mr. Terasiewicz stated that a seal gap inspection would be conducted on T-86 due to the observations of hydrocarbon emissions. We also discussed our observations of the condition of the tanks themselves, including the door sheets. We also noted the high reading of VOC at the observed hatch of T-2001. This reading seems to indicate some level of volatile material is being stored in the tank. Before departing the site, Mr. Haynes confirmed that the OGI videos taken would be subsequently shared with the facility electronically. Ms. Strang also confirmed that information that we requested would be shared electronically with EPA. 1) Visualized hydrocarbon emissions were observed at tanks T-82, T-85, and T-86. We observed hydrocarbon emissions using the OGIC at three tanks: T-82, T-85, and T-86. The OGIC video suggests that the tanks may not be effectively controlling emissions. Information provided by the facility indicates T-85 and T-86 failed respective seal gap measurement inspections. See Appendix 3 - Phillips 66 Lake Charles Refinery April 2022 EPA Inspection Response, for the T-85 and T-86 inspection report. T-86 was noted to have a 6-inch gap between the edge of the primary seal and the tank wall. T-85 was noted to have seal gap exceedances in and other deficiencies including an oily substance on the roof, a deficient gasket at the guide pole, and a deficient gasket at the vacuum breaker. T-85 and T-86 are classified as Group 1 storage vessels under 40 CFR Part 63 Subpart CC (MACT CC) - National Emission Standards for Hazardous Air Pollutants ("NESHAP") From Petroleum Refineries which subjects them to the provisions or 40 CFR Part 63 Subpart WW - National Emission Standards for Storage Vessels (Tanks) - Control Level 2. 2) Door sheets were observed cut into several tanks at the tank farm. Tanks can be physically distorted when large openings are cut into a tank shell. Force displacements from this type of disruption can cause flattening above the door sheet itself, bulging at the corners of the door sheet, and could cause the tank shell to deform into a more oval shape (Lieb, John M. Importance of Door Sheet Stiffening). Without proper stabilization of the tank shell, these changes in design characteristics could lead to excess emissions. EPA Inspection Report - Page 5 of 29 3) VOCs were observed at a hatch on the roof of T-2001. A facility LDAR technician observed readings over 30,000 ppm, or above 3% of the sampled air, at a hatch on the roof of T-2001. The tank is not currently classified or monitored as a MACT CC Group 1 storage vessel. The facility must record any data, assumptions and procedures used to make the determination that the weight percent total of the HAP of the stored liquid is less than or equal to 4 percent. Additionally, the Facility should maintain best practical housekeeping and maintenance practices to the highest possible standards to reduce the quantity of organic compound emissions pursuant to the practices listed in Title 33 of the Louisiana Administrative Code Section 2113. 4) The Facility may be underestimating emissions of materials stored in tanks. Visible emissions observed by EPA at T-82, and emissions detected with handheld monitoring equipment at T-2001, indicate that the physical characteristics of the materials contained within those vessels are not consistent with the assumptions the Facility is making about the product's vapor pressure and emissions profile, and increased emissions from those tanks may be due to a misapplied regulatory scheme. T-82 contains Kerosene and T-2001 contains residual oil. Kerosene and Residual Oil are commonly applied names for refined petroleum products that are assumed to have similar respective physical characteristics. However, different facilities use proprietary processes in the storage and transport of materials and products and may apply additives to decrease the viscosity of products with higher specific gravities. These additives may increase the vapor pressure of the stored products and materials and subject them to additional requirements for controls and monitoring. The Facility should ensure that the materials stored in tanks are assessed based on quantifiable and empirical data specific to those materials rather than qualitative assessments based on industry assumptions. Section IV - FOLLOW UP On May 13, 2022, Ms. Strang provided follow-up information, including visual inspection reports conducted on T-85 and T-85, and a chronology of maintenance events that the Facility believed caused the emissions observed from T-2001 and T-2005 (See Appendix 3). Additional information regarding the observations made by the GMAP at the facility will be provided in a future report. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 5 Photographs Appendix 2 - Video Log - 4 OGIC videos taken on 4/13/2022 Appendix 3 - Phillips 66 Lake Charles Refinery April 2022 EPA Inspection Response EPA Inspection Report - Page 6 of 29 Phillips 66 Company / Lake Charles Refinery Inspection Date 04/13/2022 Appendix 1 Photograph Log EPA Inspection Report - Page 7 of 29 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 2200 Old Spanish Trail City: Westlake Photo No. 1 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN0703.jpg Date of Photo: 4/13/2022 Time of Photo: 15:37 Photographer: Ben Rosenthal Description: Tank T-85. OGIC-visualized hydrocarbon emissions were observed on the roof of the tank. EPA Inspection Report - Page 8 of 29 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 2200 Old Spanish Trail City: Westlake Photo No. 2 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN0704.jpg Date of Photo: 4/13/2022 Time of Photo: 16:30 Photographer: Ben Rosenthal Description: Tank T-86. OGIC-visualized hydrocarbon emissions were observed on the roof of the tank. EPA Inspection Report - Page 9 of 29 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 2200 Old Spanish Trail City: Westlake Photo No. 3 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN0702.jpg Date of Photo: 4/13/2022 Time of Photo: 16:42 Photographer: Ben Rosenthal Description: Tank T-82. OGIC-visualized hydrocarbon emissions were observed exiting the gooseneck valve at the top of the tank. Two door sheets are visible at the base of the tank. EPA Inspection Report - Page 10 of 29 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 2200 Old Spanish Trail City: Westlake Photo No. 4 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN0707.jpg Date of Photo: 4/13/2022 Time of Photo: 17:45 Photographer: Ben Rosenthal Description: Tank T-2001. EPA Inspection Report - Page 11 of 29 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 2200 Old Spanish Trail City: Westlake Photo No. 5 County/Parish: Calcasieu State: Louisiana Photo File Name: DSC0708.JPG Date of Photo: 4/13/2022 Time of Photo: 17:51 Photographer: Ben Rosenthal Description: Facility LDAR technician using handheld monitoring equipment at the top of T-2001. EPA Inspection Report - Page 12 of 29 Phillips 66 Company / Lake Charles Refinery Inspection Date 04/13/2022 Appendix 2 Video Log EPA Inspection Report - Page 13 of 29 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 2 Location: Phillips 66 Company / Lake Charles Refinery City: Westlake Calcasieu State: Louisiana Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_0051.mp4 04/13/2021 15:50 James Haynes OGIC visualized emissions from the roof of T-85 near the primary seal-tank shell interface. * Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_0054.mp4 4/13/2022 15:55 Ben Rosenthal OGIC visualized emissions from the roof of T-85 at pinhoil leaks on the surface of the roof. * Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_0056.mp4 04/13/2021 16:40 Ben Rosenthal OGIC visualized emissions from the roof of T-86 near the primary seal-tank shell interface. * Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_0061.mp4 4/13/2022 16:30 Ben Rosenthal OGIC visualized emissions from the gooseneck vent on T-82. * *All videos can be made available for viewing upon request. 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