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 ------- 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 ------- 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 3 ------- EPA Inspection Report - Page 4 of 6 CITGO Petroleum Corp / Lake Charles Manufacturing Complex Inspection Date 04/14/2022 Appendix 1 Video Log ------- 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 ------- 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 ------- |