-------
EPA Inspection Report - Page 2 of 29
Phillips 66 Company / Lake Charles Refinery
Inspection Date 4/13/2022
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION
EPA Region 6 inspectors James Haynes and I, Ben Rosenthal, ("We", "Us") arrived at the Philips 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 A includes the Hot
Resid Tanks, which are used to receive and store feedstocks and charge them to refinery
units in Area A and other areas as needed. 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
day, Those findings included emissions observed at, or thought to originate from, tank T-2001 and 2005
2
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EPA Inspection Report - Page 3 of 29
Phillips 66 Company / Lake Charles Refinery
Inspection Date 4/13/2022
-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.
Table 1. List of Tanks Observed by EPA with the OGIC
Tank Number
Tank
Contents
Hydrocarbons
Observed with the
OGIC
Visualized Emissions
Location
Viewing Location
T-82
Kerosene
Yes
Observed at open
gooseneck vent on roof.
Base of Tank
T-85
Gasoline
Yes
Observed at seal gap
and coming from
pinhole leaks.
Roof of Tank
T-86
Gasoline
Yes
Observed at seal gap.
Roof of Tank
T-2001
Residuals
No
None.
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
from the facility with proper protective equipment accessed the roof of T-2001 and took measurements
3
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EPA Inspection Report - Page 4 of 29
Phillips 66 Company / Lake Charles Refinery
Inspection Date 4/13/2022
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,
Philips 66 Environmental Manager. We discussed the visualized emissions at several of the tanks. Mr.
Tarasiewicz 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 visual 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 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.
4
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EPA Inspection Report - Page 5 of 29
Phillips 66 Company / Lake Charles Refinery
Inspection Date 4/13/2022
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-86, 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
5
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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
Photo No. 1
Location: 2200 Old Spanish Trail
City: Westlake
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.
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EPA Inspection Report - Page 8 of 29
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: 2200 Old Spanish Trail
City: Westlake
County/Parish: Calcasieu
State: Louisiana
I
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.
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EPA Inspection Report - Page 9 of 29
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: 2200 Old Spanish Trail
City: Westlake
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.
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EPA Inspection Report - Page 10 of 29
§ 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: 2200 Old Spanish Trail
City: Westlake
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: TankT-2001.
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EPA Inspection Report - Page 11 of 29
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: 2200 Old Spanish Trail
City: Westlake
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.
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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
Appendix 2
32"
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Video Log
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, *
*AII videos can be made available for viewing upon request.
Page 1 of 1
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EPA Inspection Report - Page 14 of 29
Phillips 66 Company / Lake Charles Refinery
Inspection Date 04/13/2022
Appendix 3
Phillips 66 Lake Charles Refinery April 2022 EPA Inspection
Response
-------
EPA Inspection Report - Page 15 of 29
May 12, 2022
Erin T. Strang
Environmental Team Lead
Lake Charles Refinery
Phillips 66
2200 Old Spanish Trail, P.O. Box 37
Westlake, LA 70669
(337) 491-4742
Via Electronic Mail
James Haynes, U.S. Environmental Protection Agency Region 6 (havnes.iames@epa.gov)
Re: Phillips 66 Response to the USEPA's April 12 - 13, 2022 Inspection at the Lake
Charles Refinery
Dear Mr. Haynes:
The April 12-13, 2022 joint EPA/LDEQ inspections resulted in several questions about tanks
located at the Lake Charles Refinery. Phillips 66 is submitting the accompanying files and
documents as requested by the EPA during the onsite inspection closing meeting on April 13,
2022.
Tank 85 (T-85) Gasoline Tank (EOT-225. Permit No. 2626-V17)
T-85 is an external floating roof tank used to store gasoline located in Area D. As mentioned during
the inspection, a seal inspection performed on February 28, 2022, noted deficiencies. The letter to
LDEQ informing the agency of the tank seal inspection failure and the tank seal inspection record
are included in Attachment 1. Repairs were completed within 45 days of the seal inspection.
Tank 86 (T-86) Gasoline Tank (EOT-226. Permit No. 2626-V17)
T-86 is an external floating roof tank used to store gasoline located in Area D. Phillips 66
committed to performing a primary and secondary seal inspection as soon as practicable. Both a
primary and a secondary seal inspection were performed on April 14, 2022. The inspection noted
that the measured primary gap width exceeded the maximum allowable gap width. The letter to
LDEQ informing the agency of the tank seal inspection failure and the tank seal inspection record
are included in Attachment 2.
Tank 82 (T-82) Jet/Kerosene Tank (EOT-222, Permit No. 2626-V17)
T-82 is a cone roof tank used to store jet/kerosene located in Area D. The information below is
representative of the conditions closest to the day of the inspection.
• Temperature = 91F (measured 4/12/2022)
• API gravity = 42.9 (measured 4/12/2022)
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EPA Inspection Report - Page 16 of 29
Tank 2001 t T-2001) Residual Oil Tank (KQT-540. Permit No. 2&23-V19)
T-2001 is a residual oil tank located in Area A. As noted during the inspection, level in T-2001
was building mote rapidly than normal due a heater deeoke. cleaning, and preventative
maintenance occurring on the da>s of the inspection. During heater deeokes, the Cokcr goes 1o
two drum operation ralher than four drum operation, and as a result level builds in T-2001 more
quieklv than it does during normal Coker operation. During the inspection, the gauging hatch was
observed to be periodically lifting (presumably due to tank pressurination) but this was likely
occurring more Frequently than usual due to the le\ el building in the tank because of the deeoke.
The information provided below is representative of the conditions in the tank closest to the day
of the inspection.
• temperature - 37c> (measured 4; 11/2022)
• API gravity 5.1 (measured 4/1 1/2022)
If vou have anv questions regarding this response, please contact Frin Strang at 337-491-4742 or
erin.t.stran g(
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EPA Inspection Report - Page 17 of 29
II. Attachments
Attachment 1: 1-85 Tank Seal Inspection Record
4
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EPA Inspection Report - Page 18 of 29
John Tarasiewicz
Environmental Specialist
Environmental Department
Lake Charles Refinery
Phillips 66
2200 Old Spanish Trail, P.O. Box 37
Westlake, LA 70669
(337) 491-4906 Fax: (337) 491-5613
CERTIFIED MAIL - RETURNED RECEIPT REQUESTED - 70191120 0000 9105 1032
March 2, 2022
Mr. Chance McNeely
Louisiana Department of Environmental Quality
Office of Environmental Compliance
Post Office Box 4301
Baton Rouge, Louisiana 70821-4301
Notice of Failure 2022 Seal Inspection
Tank 85 (EQT-225), Permit No. 2626-V17
Phillips 66 Inc., Lake Charles Refinery - Agency Interest #2538
Dear Mr. McNeely:
The Phillips 66 Lake Charles Refinery Tank 85 is an external floating roof tank with primary and secondary
seals. As required by 40 CFR 63 Subpart CC, 40 CFR 63 Subpart WW and LAC 33:111.2103, Phillips 66
performed a seal inspection on the secondary seal on February 28, 2022.
During the inspection, a small oily spot was observed on the floating roof and gaskets for the vacuum
breaker vent and guide pole were found to be in need of repair. Repairs have been initiated within 7 days by
scheduling work to clean the floating roof and replacing the gaskets. Repairs will be completed within 45
days or the tank will be taken out of service.
Please contact me at 337-491-4906 if there are any questions concerning this notification for the above
referenced tank.
Sincerel
John Tarasiewicz
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EPA Inspection Report - Page 19 of 29
Mr. McNeely
T-134-S,eal Inspection Failure Notice
February 28, 2022
Page 2
cc:
Louisiana Department of Environmental Quality
Regional Manager
Southwest Regional Office
1301 Gadwall Street
Lake Charles, LA 70615
7Q11 112D DDDD lias 1032
SENDER: COMPLETE THIS SECTION
Complete items 1, 2, and 3.
Print your name and address on the reverse
so that we can return the card to you.
Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
Mr. Chance McNeely
La. Dept. of Environmental Quality
Office of Environmental Compliance
Post Office Box 4301
Baton Rouge, LA 70821-4301
9590 9402 6477 0346 4660 49
9 Article Number CTransfer from service label)
7Dn 1120 D0Q0 TIDS 1Q32
.&NDREA CRA!'^1
B. Received by (Printed Name)
ML
~ Agent
C. Date of Delivery
D. Is delivery address different from item 1 ? O Yes
If YES, enter delivery address below: ~ No
PS Form 3811, July 2020 PSN 7530-02-000-9053
3. Service Type
~ Adult Signature
~ Adult Signature Restricted Delivery
tified Mail®
~"Certified Mail Restricted Delivery
O Collect on Delivery
~ Collect on Delivery Restricted Delivery
f~l IncitroH Mail
tail Restricted Delivery
3)
~ Priority Mail Express®
~ Registered Mail™
~ Registered Mail Restricted
~ Signature Confirmation™
~ Signature Confirmation
Restricted Delivery
Domestic Return Receipt
-------
EPA Inspection Report - Page 20 of 29
Rev- -I-2649
-------
EPA Inspection Report - Page 21 of 29
'.ink V;».
Diameter
85
KKR/1FR FLOATING; ROOF INSPECTION KKPORT
PhhIuc! *sL»red VVVH'f BASF, In-ipetior
ISO
RdoC Dcsi-jn
KFK
Dale
2S-Fc(i-22
m
Ladder position mi lank
111 o'clock to the North):
"iaj> caloiilalions are made on a triangular area
A 1. \ \\
i
.
Gap Width, W
¦
Gap lonmh. 1 »
Secondary Seal Gaps
\S FOl'ND Stf\I "GAP CONDITIONS
Gap I ocatian
(clock minion;
It
1
y
S
jo
ioia! Gapfsu, melto)
Mj\. (iap Wiihh, inches
(iap length 1
Mj\ widths W
Total Gap, A
(inches)
oncheO
(sq. inches)
0
X
0
o
0
X
a
D
§
X
0
- O
$
X
0
o
0
X
9
o
G>
\
C>
o
"D
I Indicate ladder and «al ^ap mmIioik ahov j)
1'hillips 66 Westlakc Refinery
Rev: 4-26-10
-------
EPA Inspection Report - Page 22 of 29
Attachment 2: T-86 Tank Seal Inspection Records
5
-------
EPA Inspection Report - Page 23 of 29
John Tarasiewicz
Environmental Specialist
Environmental Department
Lake Charles Refinery
Phillips 66
2200 Old Spanish Trail, P.O. Box 37
Westlake, LA 70669
(337) 491-4906 Fax: (337) 491-5613
CERTIFIED MAIL - RETURNED RECEIPT REQUESTED - 7019 1120 0000 9105 1049
April 21,2022
Mr. Chance McNeely
Louisiana Department of Environmental Quality
Office of Environmental Compliance
Post Office Box 4301
Baton Rouge, Louisiana 70821-4301
Notice of Failure 2022 Seal Inspection
Tank 86 (EQT-226), Permit No. 2626-V17
Phillips 66 Inc., Lake Charles Refinery - Agency Interest #2538
Dear Mr. McNeely:
The Phillips 66 Lake Charles Refinery Tank 86 is an external floating roof tank with primary and secondary
seals. As a result of an EPA inspection, Phillips 66 performed a seal inspection on the primary and
secondary seals on April 14, 2022.
The measured primary gap width exceeded the maximum allowable gap width. Repairs have been initiated
within 7 days by assessing the primary seal and scheduling work to complete the repair. Repairs will be
completed within 45 days or the tank will be taken out of service.
Please contact me at 337-491-4906 if there are any questions concerning this notification for the above
referenced tank.
pSincerely,
John Tarasiewicz
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EPA Inspection Report - Page 24 of 29
:> ininnioV.tl tsKj,ihi v
-------
EPA Inspection Report - Page 25 of 29
7011 1150 DODO 1105 1041
50:
s?
1
3:
3
EH s
0*
SENDER: COMPLETE THIS SECTION
Complete items 1,2, and 3.
Print your name and address on the reverse*
so that we can return the card to you. [
Attach this card to the back of the mailpieceROl
or on the front if space permits.
COMPLETE THIS SECTION ON DELIVERY
1. Article Addressed to:
Mr. Chance MclMeely
La. Dept. of Environmental Quality
Office of Environmental Compliance
Post Office Box 4301
Baton Rouge, LA 70821-4301
9590 9402 6477 0346 4658 68
- XI i /Trnncfar frnnrt .CPn//Cfi label)
?nn 11ZD 0000 T10S
A. Signature
~ Agent
~ Addresset
2 6 Itfifcate of Delivery
D. Is delivery address different from Item 1 ? ~ Yes
If YES, enter delivery address below: ~ No
3. Service Type
~ Adult Signature
f Adult Signature Restricted Delivery
Certified Mail®
Certified Mail Restricted Delivery
~ Collect on Delivery
~ Collect on Delivery Restricted Delivery
10 4C} I Restricted Delivery
~ Priority Mail Express®
~ Registered Mail™
~ Registered Mail Restricte
Delivery
~ Signature Confirmation™
~ Signature Confirmation
Restricted Delivery
PS Form 3811, July 2020 PSN 7530-02-000-9053
Domestic Return Receipt
-------
EPA Inspection Report - Page 26 of 29
|«TOJ,JPS 66 LAKH CHARLES RKFINKRV
PRIMARV SEAL tNSfEf TIO-N
ENVIRONMENTAL REGULATORY
vigi4tiHslral Shi
MMMJtrT-
uyuif>u-:vt*:t
WAMHSIR
ifABIIirv
I ITEM __
MtfMAlft SEAL; a It)-1«*«, mm
YES
IS'l
-u', \ KV
,\0 1 S \
m -1
I'KIM \,i\
viM'i )l)\ i I'MVi \ l\
"Are there vMMc gap* between lite leal
ami lie tmk sail?
V
Art tkmre rhible ittfscis? (Such a*
Art! awlosiisiie bleeder brtafeef)
nm eimed? Are gntkets equipped
H.
Art rim
iinit in food coiidilipfl"'
1$ well roof opening {oilier flan
automatic Mecder %ci»ls» riia tpxe w»t».
roof dr;«i-w* and l«!g stems) equipped
wilh » gtnketed ewer, soil or lid? in
goed MKlilfcof
Equipped with an cBicr|>«ie> roof drain
I Iks I emptier buck into the rank? II" yes. Is
rimf drain equipped with * fnbric that
BWtt '#**•» »f
Equipped with i»tBfe!»«J guide pole? If
f«, equipped »ith g;«kE»«I tilting eover
»«»pmt condition? Equipped -with relief*
In good condition? 1* cap dored?
Equipped with tfcffled iinitfc pule? If >-«,
equipped with gasketetl -sJltHofi cover ami.
flnMe fabric lit good (hMm?
Equipped witfc r®tlcm in good coRdiliun?
is CS1|I tfescll?
Notes:
y
h\o! U •'Wl v ' WU * • * ',
I i)MO C'OKK ESPONOfc N( T
I J< HRC.
nvikuwi
Repairs Needed:
Adjustment it> Scaf|\>
!: RciwirofStwfts)
_ _ ' -" ' s° H>)
-------
EPA Inspection Report - Page 27 of 29
150
| | Vt
0:,H\v!cr
i .viviv'I jV.sMori li.|*k
.1 >\,tu:k tiu- V>;Un.
(j.jn v\*LuUik»h> /.ts- PAtiilc,»?: ti (r >u!guLt ic;i
\ I v \\
EFR/IFR FLOATING ROOF INSPKCTIOK REPORT
Pr>.Juct Sh-;vU MMNill'U) (JASO Sits,i-vu.t
EI-"K
IXiSc
12 o'cbck
(i,i|> Widili, W
liap k-iut'i.
Primary Seal Gaps
\S FOUND SEAL CAP CONDITIONS
Gap Location
Gap length 1.
widths W
1 (\io A
(clock position)
(inches)
f mdies)
{ SI1CJCN)
o
&o'
* -O
I
<¦> 10
aH
, 6
('»
im
/ ,1"
x / 6
(&
/ So
a"
" , s
Q>
120"
! si /
1KCT
ii(a! Cia|i(Squiiru Incites)
M.-v \V idih, molw;.
nQ
.w,\
mr
2?!!-'
Phillips 6ti Wcsllakc Refinery
(Indicate latiiJur and seal gap pwsMons above)
Rc\ lUOivISl
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EPA Inspection Report - Page 28 of 29
In;;' i !i>^< ¦.K; i !!>n! is\i
,>! n-.u \k\ %: r •>:»'> \ i >o\
I
ENVIRONMENTAL REGULATORY
1
:, i. EFR
428 mV Akclmn
|J si ('M J > " ^ ,i Ai \Jn.M . vl ^ i ~.»
i\; APWtrAmuiY *
•«x (Af \in
fji] i>A i i
SECONDARY SEAL ANNUAL INSPECTION
! i: M "i ¦ * \n ' \ \
AIMMTICJXAI, CttMMKYfS
SECONDARY SEAL: any holes. lettsT] | ~*
deiacbeii or other opming?? | [ |_
Are there visible gaps beri^Hhc teal !* f r" (
tntl llic l;»lt wall? J 1 ' 1
Are there vhible defects? tSucli a« v/
corcorfon or pools of Handing )lt|uhh) | | |
Are auioiitatk bleeder tmmam breaker) 1
vent* clued? Are fpttkeft equipped and ^
In good condition? J V j |
An; iim ipmv \tiiH ctemf ? Are gmkefv j /" J 1
equipped will in good condition? J | |
h each roof opening Jotter than
automatic bleeder *en»s, rim = W» «»f opening?
v/
~-
Equipped with bikImwI guide pole? If
»c», equipped »M« gasfalol ifbfitig cover
ill good condition? Is cap ctosal?
Equipped with {lotted guhie pole? tf yes.
equipped with RMkewf sibling timet anci
ifulble fabric "itervc In go®il condition?
(V cap closed?
..
Soles;
i \ /
1 \ v* M |\>»l '\( M \ "
« V SU'JV-t1 M v. N
I.{)(-() COKUf-SPOM>l:N(" ¥
KFASON'
\ 1 / it i. '< i > 1 »
,,A
Repairs Needed:
CT1 Adiusimaii to SsaiHl
i j Repair of So»U>)
f ] Replacement of S^jI{s}
fk' V. <> v . V
0
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EPA Inspection Report - Page 29 of 29
Rev: 4-26-10
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