EPA Inspection Report - Page 1 of 5
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Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s):
04/18/2022
Media Program:
Air
Regulatory Program(s)
SIP, Title V
Company Name:
NuStar Energy L.P.
Fac
lity Name:
St. James Terminal
Fac
lity Physical Location:
7167 Koch Road
(c
ty, state, zip code)
St. James, LA, 70086
County/Parish:
St. James Parish
Facility Phone Number
225-746-2117
Facility Contact:
Brad Roig
Health, Safety and Environmental (HSE)
Brad.roig@nustarenergy.com
FRS Number:
110007278908
Identification/Permit Number:
LDEQ Agency Interest Number 36538, Title V: 2560-00013-V9
Media Identifier Number:
AFS#: 22-093-00013
NAICS:
424710, Petroleum Bulk Stations and Terminals
SIC:
5171, Petroleum Bulk Stations and Terminals
Personnel participating in inspection:
Christopher Williams
EPA-OECA-OCE-AED
Chemical Engineer
Richard Helmich, Ph.D.
OECA-OCEFT-ONEIC-LB
Senior Chemist
David Mahoney
OECA-OCEFT-ONEIC-FB-CRSS
Physical Scientist Technician
Ali Gitipour, Ph.D.
EPA-ORD-CEMM-AMCD
Federal Postdoctoral Research
Fellow/Chemical Engineer
Cory Lormand
LDEQ-OEC-Surveillance Division
Environmental Scientist
EPA Lead Inspector
Signature/Date
CHRISTOPHER WILLIAMS
'ISTOPHER WILLIAMS
54 -04'00'
Christopher Williams
Date
Supervisor
Signature/Date
1 A IV/I CC 1 C ATMFRQ Digitally signed by JAMES LEATHERS
JAlVICj Ltn 1 nLnj Date: 2022.07.12 09:26:42 -05'00'
{Supervisor name}
Date
6ENFORM-019-R8.2 (02/12/2020)
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EPA Inspection Report - Page 2 of 5
NuStar / St. James Terminal
Inspection Date 04/18/2022
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION
On April 18, 2022, the Government Team consisting of Mr. Richard Helmich (EPA-NEIC), Mr. Ali Gitipour
(EPA-ORD), Mr. David Mahone (EPA-NEIC), Mr. Christopher Williams (EPA-OECA) and Mr. Cory Lormand
(LDEQ-OEC) arrived at the NuStar Energy L.P. ("Nustar") St. James Terminal in St. James Parish at around
1:30 P.M. local time to conduct an unannounced Clean Air Act ("CAA") inspection.
The Government Team signed in with security at the gate and were directed to a conference room in the
main office building. In the conference room the Government Team was introduced to NuStar
representatives Mr. Brad Roig, HSE Supervisor, Mr. Marcello Cornejo, Terminal Manager, and Mr. Jean
Zeringue, General Manager of Operations. Mr. Williams presented his inspector credentials to Mr.
Zerinque and notified him of the Government Team's intent to conduct a CAA Partial Compliance
Evaluation ("PCE"). This inspection occurred as part of the Administrator's Multi-Scale Monitoring
Project called the Pollution Accountability Team (PAT).
FACILITY DESCRIPTION
Petroleum products are transported to the St. James Terminal (LDEQ Agency Interest Number 36538) by
barges, ships, pipelines, rail cars and truck where they are either stored until shipped out by barges,
ships an pipelines or to other facilities or pipelines. The petroleum products transported to/from and
stored at the St James Terminal include crude oil, no. 6 oil, distillate fuel oil no. 2, vacuum gas oil and
marine diesel. The facility operated over 35 storage tanks with a combination of fixed roofs, external
floating roofs ("EFRs"), and internal floating roofs ("IFRs").
Section II - OBSERVATIONS
Opening Conference
At around 1:55 P.M., the Government Team conducted an opening conference with NuStar
representatives, Mr. Roig, Mr. Carnejo and Mr. Zerinque. Mr. Helmich explained that the compliance
evaluation would include a mobile air monitoring survey of the facility using Geospatial Measurement of
Air Pollution ("GMAP") and provided an overview of the vehicle and equipment. Mr. Williams explained
that he would be using a FLIR GF320 optical gas imaging ("OGI") camera and a handheld photoionization
detector ("PID") to locate any hydrocarbon emission sources upwind of detections made by GMAP. Mr.
Helmich and Mr. Williams asked the NuStar representatives to begin processing any hot work permits
required by the company to gain full access to the facility using the described equipment. Mr. Williams
asked the company to let the Government Team know if any Confidential Business Information is
obtained during the PCE, so that the information could be treated by the custodians as such. Mr.
Carnejo confirmed that the facility was operating as normal and that EFR Tank 9 was the only tank being
loaded at this time. At around 2:20 P.M. the opening conference concluded, and the Government Team
prepared the vehicles and equipment for entry into the tanks' operations area.
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EPA Inspection Report - Page 3 of 5
NuStar / St. James Terminal
Inspection Date 04/18/2022
Site Tour
At around 2:25 P.M., Mr. Williams took a photo of the NuStar entry sign (DC_171.jpg) and the
Government Team began the site tour. Conditions were sunny with some cloud cover, and with
moderate winds coming from the north to northwest. In the mobile air monitoring vehicle, Mr. Helmich,
Mr. Gitipour and Mr Mahone were escorted by Mr. Roig. In a company vehicle following, Mr. Williams
and Mr. Lormand were escorted by Aaron Martinez, Maintenance. The mobile air monitoring vehicle
drove on all available roads in the tanks' operations area.
At around 3:00 P.M. downwind of IFR Tank 25, GMAP detected elevated concentrations of VOC (at
around 2,500 ppb) at ground-level. Mr. Williams and Mr. Lormand exited the vehicle to inspect Tank
25. Using OGI, Mr. Williams recorded video MOV_172 of emissions emanating from the downwind
brow vents and video MOV_173 of emissions emanating from the upwind brow vents on Tank 25. Mr.
Roig confirmed that Tank 25 was not loading at the time of the emissions observations.
At around 3:40 P.M. downwind of the EFR Tank 6, GMAP detected elevated concentrations of VOC (at
around 1,200 ppb) at ground-level. Mr. Williams, and Mr. Lormand exited the vehicle to inspect Tank 6.
Using OGI, Mr. Williams recorded video MOV_174 of emissions coming out of the top rim of Tank 6. Mr.
Roig confirmed that Tank 6 was not loading at the time of the emissions observations.
At around 3:50 P.M., the Government Team exited the tanks' operations area and returned to the
conference room.
Section III - AREAS OF CONCERN
At around 4:00 P.M., the Government Team conducted a closing conference with NuStar
representatives Mr. Roig, Mr. Carnejo and Mr. Zerinque. Mr. Helmich and Mr. Williams provided a
summary of the areas of concern, which include the observations of emissions coming from Tank 25 and
Tank 6 as described above. Mr. Williams was designated as the EPA contact for any potential follow-
up. The closing meeting concluded at around 4:30 P.M. and the Government Team exited NuStar's
facility.
Section IV-FOLLOW UP
No additional information was received by EPA after exiting the NuStar's facility on April 18, 2022.
Section V - LIST OF APPENDICES
Appendix 1 - Photo and Video Log - 1 photo and 3 OGI videos taken April 18, 2022.
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EPA Inspection Report - Page 4 of 5
NuStar / St. James Terminal
Inspection Date 04/18/2022
Appendix 1
Photo and Video Log
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EPA Inspection Report - Page 5 of 5
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Appendix 1
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photo and Video Log
Location: NuStar St. James Parish
City: St. James
St. James Parish
State: Louisiana
File Name: DC_171.jpg
Date taken: 04/18/2022
Time taken: 2:26 pm
Videographer: Christopher Williams
Description: Photo of the NuStar entry sign.
CEIC
File Name: MOV_172,mp4
Date taken: 04/18/2022
Time taken: 3:09 pm
Videographer: Christopher Williams
Description: OGI video of emissions emanating from downwind
brow vents on Tank 25.
File Name: MOV_173.mp4
Date taken: 04/18/2022
Time taken: 3:28 pm
Videographer: Christopher Williams
Description: OGI video of emissions emanating from upwind
brow vents on Tank 25.
MB
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I I 1 J I
File Name: MOV_174.mp4
Date taken: 04/18/2022
Time taken: 3:41pm
Videographer: Christopher Williams
Description: OGI video of emissions from the top circumference
of Tank 6.
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