Document 6BGDbx11G1X247rOpKaEG1v89

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: 06/19/2018 Water Clean Water Act INEOS-Calabrian INEOS-Calabrain 5500 State Hwy 366 Port Neches, TX 77651 5500 State Hwy 366 Port Neches, TX 77651 Jefferson County Roberto Gutierrez Kristen Westbrooks 409-727-1471 ext 140 FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: TX0062448 2899 Personnel participating in inspection: Michael Williams EPA Troy Lewis INEOS Kristen Westbrooks INEOS Vicky Martin INEOS Quality & Technical Manager Operations Manager Inspector Production Supervisor Operations Manager Safety Coordinator 281-983-2150 409-727-1471 409-727-1471 409-727-1471 EPA Lead Inspector Signature/Date EPA Lead Inspector Signature/Date Digitally signed by MICHAEL WILLIAMS MICHAEL WILLIAMS DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=MICHAEL WILLIAMS, dnQualifier=0000015063 Date: 2018.08.15 11:24:46 -05'00' Michael D. Williams Date Supervisor Signature/Date Supervisor Signature/Date Carol Peters CAROL PETERS-WAGNON Digitally signed by CAROL PETERS-WAGNON DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=CAROL PETERS-WAGNON, dnQualifier=0000009981 Date: 2018.08.16 10:58:18 -05'00' INEOS Calabrain Corp. (LA0062448) Inspection Date 06/19/2018 Section I - Introduction PURPOSE OF THE INSPECTION EPA Region 6 inspector, Michael Williams, arrived at INEOS Calabrain Corp. at 10:46 am on June 19, 2018 for an unannounced inspection. I met with Kristen Westbrooks, Operation Manager. I presented my credentials to Kristen and informed her that this was an EPA lead inspection to determine compliance with the Clean Water Act. The scope of the inspection was with permit LA0062448 and facility operations and maintenance under the Clean Water Act. The information presented in this report is based on the materials and information supplied by the INEOS Calabrain Corp. representatives (the permittee), observations made during the inspection and records and reports maintained by the permittee. FACILITY DESCRIPTION INEOS Calabrain Corp. is located at 5500 State Hwy 366, Port Neches, Texas. The plant makes sulfur dioxide and related derivatives such as sodium bisulfate, sodium metabisulfite and sodium thiosulfate used in wastewater treatment, mining, oilfield and pulp and paper industries. The plant process combines molten sulfur and oxygen to form SO2. The SO2 produced on site is combined with caustic to form a sodium bisulphite/ Sodium sulfite solution. This solution is used in a reaction to from sodium metabisulphite. Wastewater generated comes from the cooling tower blowdown, boiler blowdown, steam condensate, utility water, wash down water, and storm water. The facility treats the wastewater by adding caustic to increase the pH to help settle solids in the two onsite lagoons. The site occasionally adds liquid bleach to help lower COD and ferrous sulfate for settling agent. The site discharges to outfall 001 Section II- Observations This inspection revealed the following observations: On the day of the inspection, the conveyance system made of earthen berms could not contain wastewater flow to the lower lagoon during wet weather conditions. Bypass- On the day of the inspection, the facility had an unauthorized discharge from the conveyance system. The bypass resulted from the discharge of wastewater over the berm of the conveyance system. Metal Exceedance- INEOS have changed settling/ coagulant agent from Alum to Ferrous Sulfate. INEOS believes Alum was contributing to metal exceedance. No metal exceedance the last 12 months. 2 INEOS Calabrain Corp. (LA0062448) Inspection Date 06/19/2018 Section III- Areas of Concerns This inspection revealed the following areas of concerns: Proper Operation and Maintenance The permittee is required to properly operate and maintain all facilities and systems at all times. To ensure INEOS Calabrain Corp can convey all wastewater during wet weather conditions, it needs to Identify practices, design measures, and identify the criteria to prevent bypass or unauthorized discharges. INEOS Calabrain Corp. needs to evaluate the integrity of all earthen berms to ensure it is not compromised. Section IV - LIST OF APPENDICES Appendix A - INEOS Calabrain Corp. Photo log 3 INEOS Calabrain Corp. (LA0062448) Inspection Date 06/19/2018 Appendix A INEOS Calabrain Corp. Photo log 4 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: INEOS-Calabrian City: Port Neches Photo No. 1 County/Parish: Jefferson State: Texas UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: INEOS-Calabrian City: Port Neches Photo No. 2 County/Parish: Jefferson State: Texas