EPA Inspection Report - Page 1 of 6
A United States
APrlA Environmental Protection
VLI #1 Agency
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s):
04/14/2022
Media Program:
Air
Regulatory Program(s)
Title V
Company Name:
CITGO Petroleum Corp
Facility Name:
Lake Charles Manufacturing Complex
Facility Physical Location:
4401 HWY. 108 S
(city, state, zip code)
Sulphur, LA 70669
Mailing address:
PO Box 1562
(city, state, zip code)
Lake Charles, LA 70602
County/Parish:
Calcasieu Parish
Facility Phone Number
3377088431
Facility Contact:
Phyllis Holifield
Environmental Manager
pholifi@citgo.com
FRS Number:
110000597248
Identification/Permit Number:
LDEQ Al# 1250; Multiple Permit Numbers
Media Identifier Number:
AFS# 2201900016, AFS#2201900057
NAICS:
324110
SIC:
2911
Personnel participating in inspection:
Nicholas Bobbs
EPA/OECA/OCE/AED
Inspector
Justin Chen
EPA/R6/ECAD
Inspector
Richard Helmich
EPA/OECA/OCEFT/NEIC
Chemist
Agustin Martinez
EPA/OECA/OCEFT/NEIC
Technician
Ali Gitipour
EPA/ORD/CEMM/AMCD
Physical Scientist
Marcie Sharpe
LDEQ/OEC/SD
Inspector
Phyllis Holifield
Citgo Petroleum Corp
Environmental Manager
Gus Fazzio
Citgo Petroleum Corp
Operator
EPA Lead Inspector
Signature/Date
M If 1 IQI AC RHRRQ Digitally signed by NICHOLAS BOBBS
INIL.nU'LM J DUDDj Date: 2022.10.18 10:34:59 -04'00'
Nicholas Bobbs
Date
Supervisor
Signature/Date
1 A IV/1 CC 1 C ATUFRQ Digitally signed by JAMES LEATHERS
JMiVILJ LlM 1 riLnj Date:2022.10.18 10:14:47 -OS'OO1
James Leathers
Date
6ENFORM-019-R8.2 (02/12/2020)
1
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EPA Inspection Report - Page 2 of 6
CITGO Petroleum Corp / Lake Charles Manufacturing Complex
Inspection Date 04/14/2022
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION
EPA inspectors Justin Chen, Richard Helmich, Agustin Martinez, Ali Gitipour, and I, Nicholas Bobbs, and
LDEQ inspector Marcie Sharpe ("We", "Us") arrived at Citgo Petroleum Corp / Lake Charles
Manufacturing Complex (the "Facility", the "Site", or "LCMC") at 11:00 AM on April 14, 2022 for an
unannounced Clean Air Act ("CAA") inspection. We met with Phyllis Holifield, Environmental Manager
and Gus Fazzio, Operator. I presented my credentials to Mrs. Holifield and informed her that this was an
EPA inspection to determine compliance with the facility's Title V Air Permit and the Clean Air Act. The
scope of the inspection is a partial compliance evaluation ("PCE") including a survey of the facility using
the Geospatial Measurement of Air Pollutants ("GMAP") Vehicle. This inspection occurred as part of the
Administrator's Multi-Scale Monitoring Project called the Pollution Accountability Team ("PAT").
FACILITY DESCRIPTION
CITGO Petroleum Corporation operates a petroleum refinery in Lake Charles, Louisiana. The Lake Charles
Manufacturing Complex ("LCMC") process both domestic and foreign crude oils into benzene, propane,
ethane, sulfur, gasoline, distillate, and residual oil, propylene, coke, and other miscellaneous products.
LCMC operates under multiple permits, including but not limited to 2908-V11, 3010-V6, 3009-V6, 2920-
V4, 2930-V7, 2935-V5, and 2796-V11.
Section II - OBSERVATIONS
The NEIC GMAP was driven by Mr. Martinez and the instruments were operated by Mr. Helmich and Mr.
Gitipour. The GMAP surveyed the entire facility, where air pollution data was collected and recorded. A
full report from the GMAP will be issued by NEIC at a later date.
Tank Farm
The GMAP detected elevated VOCs downwind of Tank 55. Facility personnel told me Tank 55 contains
reformate. I recorded an infrared video of the tank using a GF320 FLIR camera. I recorded MOV 0168
with the FLIR camera of VOC emissions from an eyebrow vent on the west side of Tank 55. (AOC 1)
I observed visible plumes of yellowish smoke from Tank 805. Facility personnel told me Tank 805 is a
heated tank containing molten sulfur. I recorded MOV_0163 with the FLIR camera of trailing VOC
plumes from multiple mushroom vents on top of tank 805. (AOC 2)
The GMAP detected elevated total VOCs and toluene downwind of Tank 2. Facility personnel told me
Tank 2 contains "long residual". I recorded FLIR video MOV_0165 of Tank 2 from the ground. Flare B-14
was also a potential source and I recorded FLIR videoMOV_0166. Mr. Fazzio told me that Flare B-14
controls vapors from the refinery docks, and that the refinery was loading gasoline, diesel, and jet fuel at
2
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EPA Inspection Report - Page 3 of 6
CITGO Petroleum Corp / Lake Charles Manufacturing Complex
Inspection Date 04/14/2022
the docks at the time of the inspection. Mr. Chen and I went to the roof of Tank 2 and observed with the
FLIR camera. Mr. Chen recorded FLIR video MOV_0191 of VOC emissions from a pressure relief vent on
top of Tank 2. (AOC 3)
Wastewater T reatment Plant
The GMAP detected elevated total VOCs, toluene, and benzene downwind of the API oil-water
separators. Inspector Chen and I went on top of the oil-water separators and observed a significant VOC
plume using the FLIR camera from an elbow joint vent on top of API oil-water separator L-202. I
recorded FLIR video MOV_0167 of a VOC plume coming from oil-water separator L-202. I also measured
the concentration of VOCs downwind of the elbow joint on top of L-202 using a handheld PID "ppbRae
3000" and detected over 8 ppm of total VOCs. Mr. Fazzio told us that L-202 was out of service at the
time of the inspection and was currently being purged with nitrogen prior to cleaning. The elbow joint is
known as the "bird's nest", and the facility refers to the nitrogen purge as "purging through the bird's
nest". Mr. Fazzio informed us that the facility's standard operating procedure when purging the oil-
water separators is to send the vapors to the flare for the wastewater treatment area, but when the
flare is at capacity, they vent the nitrogen purge to the atmosphere instead. Mr. Fazzio said that the
wastewater treatment flare was at capacity at the time of the inspection, which is why the emissions
from the nitrogen purge of L-202 were being sent to atmosphere. (AOC 4)
Section III-AREAS OF CONCERN
EPA inspectors Nicholas Bobbs, Justin Chen, Richard Helmich, Agustin Martinez, and Ali Gitipour and
LDEQ inspector Marcie Sharpe conducted a closing conference at CITGO Petroleum Corp - Lake Charles
Manufacturing Complex at 15:00 on April 14, 2022, for the inspection. Facility representatives Phyllis
Holifield and Gus Fazzio were present during the closing conference. During the closing conference,
Inspector Bobbs reviewed the four Areas of Concern (AOC) noted during the inspection.
1) Elevated VOC concentrations downwind of Tank 55
2) VOC plume and visible emissions from Tank 805
3) Elevated VOC and toluene concentrations downwind of Tank 2
4) Elevated VOC, toluene, and benzene concentrations downwind of oil-water separator L-202 during
nitrogen purging to atmosphere
Section IV-FOLLOW UP
No additional information was received by EPA after exiting the Facility on April 14, 2022.
Section V - LIST OF APPENDICES
Appendix 1 - Video Log -6 taken 4/14/22
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EPA Inspection Report - Page 4 of 6
CITGO Petroleum Corp / Lake Charles Manufacturing Complex
Inspection Date 04/14/2022
Appendix 1
Video Log
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EPA Inspection Report - Page 5 of 6
Appendix 1
O
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Video Log
Location: CITGO Petroleum Corp - Lake Charles Manufacturing Complex
City: Sulphur
Calcasieu Parish
State: Louisiana
File Name: MOV_0163.mp4
Date taken: 04/14/2022
Time taken: 12:39 pm
Videographer: Nicholas Bobbs
Description: Optical Gas Imagine (OGI) video of emissions from
mushroom vents on top of Tank 805
File Name: MOV_0165.mp4
Date taken: 04/14/2022
Time taken: 1:08 pm
Videographer: Nicholas Bobbs
Description: OGI video of emissions from Tank 2
File Name: MOV_0166.mp4
Date taken: 04/14/2022
Time taken: 1:11pm
Videographer: Nicholas Bobbs
Description: OGI video of emissions from Flare B-14
File Name: MOV_0167.mp4
Date taken: 04/14/2022
Time taken: 2:01pm
Videographer: Nicholas Bobbs
Description: OGI video of emissions from vent on API oil-water
separator L-202
Page 1 of 2
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EPA Inspection Report - Page 6 of 6
Appendix 1
O
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Video Log
Location: CITGO Petroleum Corp - Lake Charles Manufacturing Complex
City: Sulphur
Calcasieu Parish
State: Louisiana
File Name: MOV_0168.mp4
Date taken: 04/14/2022
Time taken: 2:42 pm
Videographer: Nicholas Bobbs
Description: OGI video of emissions from eyebrow vent on west
side of Tank 55
File Name: MOV_0191.mp4
Date taken: 04/14/2022
Time taken: 1:08 pm
Videographer: Justin Chen
Description: OGI video of emissions from pressure relief vent on
roof of Tank 2
Page 2 of 2
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