EPA v. HILCORP ENERGY COMPANY/ANNIE HILL TANK BATTERY

Case summary

9/13/18 -ADMINISTRATIVE COMPLIANCE ORDER ISSUED. FINDINGS: ON AUG 16, 2017, EPA INSPECTORS CONDUCTED AN AIR COMPLIANCE EVALUATION (INSPECTION) AT THE ANNIE HILL FACILITY UTILIZING A FORWARD LOOKING INFRARED GAS FINDING CAMERA (FLIR). THE FLIR CAMERA IS AN IMAGING TECHNOLOGY THT USES INFRARED RADIATION TO DETECT VARIOUS GASES AND HYDROCARBONS. THE FLIR CAMERA CAN VISUALIZE CHEMICALS THAT ABSORB INFRARED RADIATION BETEEN 3.2 AND 3.4 MICRONS. THE CHEMICALS METHANE, ETHANE, PROPANE BUTANES, AND PENTANES ALL HAVE STRONG ABSORBANCE BANDS WITHIN THE FLIR CAMERA'S DETECTABLE RANGE, AND SUCH CHEMICALS ARE MADE VISIBLE WITH THE FLIR CAMERA. PRESSURE RELIEF DEVICE (PRD) - DURING THE INSPECTION, THE EPA INSPECTORS USED THE FLIR CAMERA TO DETECT CONTINUOUS RELEASES OF REGULATED AIR POLLUTANTS, INCLUDING METHANE, ETHANE, AND VOCs INCLUDING PROPANE, BUTANES, AND PENTANES INTO THE AMBIENT AIR. THE INSPECTORS DETERMINED THAT THE EMISSIONS WERE BEING RELEASED FROM THE PRD THAT WAS CONNECTED TO BOTH CONDENSATE STORAGE TANKS (TANKS 2a-16-OST-CV AND 2b-16-OST-CV). THE CONTINUOUS RELEASES OF VOCs FROM THE PRD CONNECTED TO THE TWO STORAGE TANKS, DEMONSTRATE THAT THE RESPONDENT FAILED TO, AT ALL TIMES, INCLUDING PERIODS OF STARTUP, SHUTDOWN, AND MALFUNCTION, TO THE EXTENT PRACTICABLE, MAINTAIN AND OPERATE THE AFFECTED FACILITIES IN A MANNER CONSISTENT WITH GOOD AIR POLLUTION CONTROL PRACTICE FROM MINIMIZING EMISSIONS, AND IS IN VIOLATION OF 40 CFR 60.5370a. ANNIE HILL FACILITY'S PERSONNEL WERE PRESENT DURING THE INSPECTION AND WITNESSED EPA INSPECTORS USING FLIR CAMERA TO DETECT CONTINUOUS RELEASES OF VOC EMISSIONS AND THEY ALSO HAD THE OPPORTUNITY TO VIEW THE FLIR VIDEOS.

Defendants (2)

• ANNIE HILL TANK BATTERYNamed in settlement
• HILCORP ENERGY COMPANYNamed in settlement

Facilities (1)

• HILCORP ENERGY COMPANY

  12303 ROBERTS RD, CHUNCHULA, AL, 36606

  Registry ID: 110007235973

Statutes cited

• CAA 111 — New Source Performance Standards

Enforcement conclusions (1)

• HILCORP ENERGY COMPANY/ANNIE HILL TANK BATTERYentered 2018-09-13

  Primary law: CAA

Timeline (2 milestones)

• 2018-09-13Enforcement Action Data Entered
• 2018-09-13Final Order Issued