EPA Inspection Report - Page 1 of 3
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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)
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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.
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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.
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