Vopak North America Inc. (d/b/a Vopak Americas) is a subsidiary of Royal Vopak, an international tank storage company headquartered in Rotterdam, Netherlands, with 74 terminals in 26 countries. Today, Vopak Americas owns three terminals in the United States, the largest of which is the subject of this matter and is co-located with a waste treatment, recovery and disposal operation on the Houston Ship Channel in or around Deer Park, Texas (the Facility). The terminal provides temporary storage for a range of products, including biofuels, chemicals, petroleum products, base oils, and lubricants, consisting of 243 tanks with a collective capacity of over 7 million barrels. The tanks range from 1,000 barrels to 80,000 barrels in size and receive products from barge, pipeline, rail, truck and marine vessels.
The air emissions at the terminal facility derive from three primary sources: terminal bulk storage tanks, flares, and the waste treatment, recovery and disposal operation, which includes a wastewater treatment system (WWTS). The terminal generates storm water and process wastewater that contain volatile organic compounds (VOCs), which Vopak treats on site at the WWTS. The EPA inspections of the Facility in 2012, 2014, and 2015 identified, among other things, leaking tanks, inefficient flares, and process equipment (e.g., open-top tanks and VOC/water separators) at the WWTS that were releasing excess emissions of VOCs. The complaint alleges violations associated with all thre