EPA Inspection Report - Page 1 of 3 v/CrM Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): 04/21/2022 Media Program: Air Regulatory Program(s) Title V Company Name: Plains Marketing LP Facility Name: Plains Marketing LP - St. James Terminal Facility Physical Location: 6375 Hwy 18 (city, state, zip code) St. James, LA 70086 Mailing address: 333 Clay St., Ste 1600 (city, state, zip code) Houston, TX 77002 County/Parish: St. James Facility Phone Number 713-646-4100 Facility Contact: Shannon Duncan HSE Specialist Sduncan@paalp.com FRS Number: 110022481777 Identification/Permit Number: 2560-00271-V13AA Media Identifier Number: AFS 22-093-00271 NAICS: 424710 SIC: 4226 Personnel participating in inspection: Sarah Frey EPA ECD-AT Inspector Chris Williams EPAOECA-AED Chemical Engineer Richard Helmich EPA NEIC Chemist David Mahoney EPA NEIC Technical Coordinator Ali Gitipour EPAORD Engineer Sophia Ong LDEQ Environmental Scientist Shannon Duncan (by phone) Plains Marketing HSE Specialist Jon Hotard Plains Marketing Operations Supervisor EPA Lead Inspector Signature/Date 6/23/2022 Sarah Frey u Date Supervisor Signature/Date 1 A IV/I EC 1 C A Tl—1 CDC Digitally signed by JAMES LEATHERS JrUVlLj Ltn 1 nLnj Date: 2022.07.15 16:34:33 -05'00' James Leathers Date 6ENFORM-019-R8.2 (02/12/2020) 1 ------- EPA Inspection Report - Page 2 of 3 Plains Marketing LP - St. James Terminal Inspection Date 4/21/2022 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA inspectors Sarah Frey (Region 6) and Chris Williams (Headquarters), accompanied by Richard Helmich (National Enforcement Investigations Center, "NEIC"), David Mahoney (NEIC), and Ali Gitipour (Office of Research and Development), arrived at the Plains Marketing LP - St. James Terminal at 12:30 pm on April 21, 2022 for an unannounced inspection. We were accompanied by Louisiana Department of Environmental Quality inspector Sophia Ong. We met with Joanna Falgoust, Administrative Assistant and Analyst, Jon Hotard, Operations Supervisor, and Shannon Duncan (by phone), HSE Specialist. Credentials were presented to Jon Hotard and we informed him that this was an EPA inspection to evaluate potential sources of excess emissions using EPA's Geospatial Measurement of Air Pollution ("GMAP") vehicle and evaluate compliance with the facility's Title V Permit and the Clean Air Act. The scope of the inspection is a 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 Plains Marketing LP - St. James Terminal is a bulk storage terminal that operates under Permit Number 2560-00271-V13AA issued May 21, 2020. The facility has multiple internal floating roof tanks and external floating roof tanks. Liquids are received and shipped via pipelines, rail, and marine vessels. Section II - OBSERVATIONS The NEIC GMAP was driven by Mr. Mahoney and the instruments were operated by Mr. Helmich and Mr. Gitipour. A facility representative, Mr. Hotard, was present in the GMAP. Inspectors Dr. Frey, Mr. Williams, and Ms. Ong followed in a separate car. Mr. Hotard guided the GMAP throughout the tank terminal, where air pollution data was collected and recorded. A full report from the GMAP will be issued by NEIC at a later date. Near tank 5280, concentrations of Volatile Organic Carbon ("VOC") emissions were detected, near 400 parts per billion ("ppb"). Mr. Williams attempted to locate the source of the emissions using an OGI camera, but was unsuccessful. Downwind of tank 5210, intermittent VOC was detected at concentrations ranging from 1400 to 2400 ppb. The tank was not in service, but being cleaned. Both tanks were equipped with external floating roofs. No other emissions were detected during the site tour. 2 ------- EPA Inspection Report - Page 3 of 3 Plains Marketing LP - St. James Terminal Inspection Date 4/21/2022 Section III - AREAS OF CONCERN Richard Helmich, Sarah Frey, and Chris Williams conducted a closing conference at Plains Marketing LP- St. James Terminal at 2:30 pm on April 21, 2022 with Mr. Hotard. During the closing conference, Mr. Helmich reviewed the emissions detected by the GMAP during the inspection. We observed no areas of concern at the time of the inspection and departed the facility at 2:40 pm. After departing the facility, the GMAP detected a large plume of VOCs along the public road. The team followed the plume to the barge loading operations for Plains Marketing LP - St. James Terminal at 2:50 pm. Initially, one vapor combustion unit was operating, but it had ceased operations by 3:00 pm. The inspection team observed open hatches on the barges docked at the facility's Marine Unit. Concentrations up to 35,000 ppb VOC, including benzene and toluene concentrations of 100 ppb each, was observed. More details will be provided in the subsequent GMAP report. We departed the area at 3:08 pm. Section IV-FOLLOW UP No additional information was received by EPA after exiting the Facility on April 21, 2022. Section V - LIST OF APPENDICES No Appendices. 3 ------- |