Document 8ndpqM0zR8Q7jxK7B1vw83Oa

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6 1201 ELM STREET, SUITE 500 DALLAS, TEXAS 75270 November 7, 2022 Jacob LaSavia, Plant Manager St. James Plant Americas Styrenics LLC 9901 Highway 18 St. James, Louisiana 70086 Sent via email: JLLaSavia@amsty.com RE: Clean Air Act Section 114 Information Request Americas Styrenics LLC, St. James Plant Dear Mr. LaSavia: Enclosed is an Information Request ("Request") issued to Americas Styrenics LLC ("AmSty"). This Request is being made pursuant to the authority set forth in Section 114 of the Clean Air Act ("CAA"), 42 U.S.C. 7414. The purpose of this Request is to obtain information regarding AmSty, St. James Plant in St. James, Louisiana to determine compliance with applicable provisions of the CAA. Please provide the information requested in Enclosure A, Section III within the timeframes set forth in this Request. You may direct any technical questions and required notices to Sarah Frey at Frey.Sarah@epa.gov or 214-665-6499. If you have any legal questions, or need to request an extension, please contact Lindsay Rich Steinmetz, Assistant Regional Counsel, at RichSteinmetz.Lindsay@epa.gov or 214-665-7425. Please include the reason(s) for the delay in responding and include the requested subsequent date for responding. In order to allow sufficient time for review, any such request for an extension of time must be made at least ten (10) calendar days prior to the date on which the requested information is due to EPA. An extension of time will be effective only if granted by EPA in writing. Thank you for your attention to this matter. Sincerely, Digitally signed by CHERYL SEAGER Date: 2022.11.07 16:21:34 -06'00' Cheryl T. Seager, Director Enforcement and Compliance Assurance Division Enclosures Americas Styrenics LLC, St. James Plant CAA 114 Information Request Ec: David Thomas, HSE Manager, Americas Styrenics LLC - St. James Plant DThomas@amsty.com Angela Marse, Louisiana Department of Environmental Quality angela.marse@la.gov Chris Williams, Office of Enforcement and Compliance Assurance, EPA Williams.Christopher@epa.gov 2 Americas Styrenics LLC, St. James Plant CAA 114 Information Request ENCLOSURE A INFORMATION REQUEST The U.S. Environmental Protection Agency ("EPA"), Region 6 is issuing this Information Request ("Request") to Americas Styrenics LLC ("AmSty") pursuant to Section 114(a) of the Clean Air Act ("CAA" or "the Act"), 42 U.S.C. 7414(a), for the purpose of determining compliance with the CAA. Section 114(a) authorizes the Administrator of EPA to require the submission of information. The Administrator has delegated this authority to the Director of the Enforcement and Compliance Assurance Division, EPA Region 6. Therefore, AmSty is required to provide a response to this Request regarding the St. James Plant, located in St. James, Louisiana (the "Facility"). The information requested must be submitted whether or not you regard part or all of it a trade secret or confidential business information. You may, if you desire, assert a business confidentiality claim on all or part of the information submitted. Any information subsequently determined to constitute a trade secret will be protected under 18 U.S.C. 1905. Unless you make a claim at the time that you submit the information, it may be made available to the public by EPA without further notice to you. Emissions data is exempt from claims of confidentiality under Section 114 of the Act, and the emissions data that you provide may be made available to the public. Information subject to a business confidentiality claim is available to the public only to the extent allowed under 40 C.F.R. Part 2, Subpart B. Failure to assert a business confidentiality claim makes all submitted information available to the public without further notice. Enclosure B specifies the assertion and substantiation requirements for business confidentiality claims. Information submitted in response to this Request must be certified as true, accurate, and complete by an individual with sufficient knowledge and authority to make such representations on behalf of AmSty. We request that a duly authorized officer or agent of AmSty certify your response to this Request by signing the enclosed Statement of Certification, provided in Enclosure C, and returning it with your response. A knowing submittal of false information in response to this Request may be actionable under 18 U.S.C. 1001 and 42 U.S.C. 7413(c). See also 18 U.S.C. 1341 and 1519. Furthermore, failure to fully comply with this Request may subject AmSty to an enforcement action under Section 113 of the CAA, 42 U.S.C. 7413. EPA may use any information submitted in response to this request in an administrative, civil, or criminal action. We ask AmSty to submit its response electronically by uploading all required information to a OneDrive folder that will be shared with the appropriate personnel. Please contact Sarah Frey at frey.sarah@epa.gov to make arrangements to submit your response. Please be advised that some companies may qualify as a "small business" under the Small Business Regulatory Enforcement and Fairness Act ("SBREFA"). To help small business owners assess their small business status, the U.S. Small Business Administration ("SBA") has established a Table of Small Business Size Standards, which can be found at: https://www.sba.gov/document/support-table-sizestandards. If AmSty qualifies as a small business, please review the SBREFA Information Sheet designed to provide information on compliance assistance to entities that may qualify as small businesses as well as to inform them of their right to comment to the SBREFA Ombudsman concerning EPA enforcement activities. The SBREFA Information Sheet can be found at: https://www.epa.gov/sites/default/files/2017- 3 Americas Styrenics LLC, St. James Plant CAA 114 Information Request 06/documents/smallbusinessinfo.pdf?VersionId=6aAtP3_v8qG6FApYqI6sBZbO8JFa2ple. Please be aware that SBREFA does not eliminate AmSty's responsibility to respond in a timely fashion to any complaint or Request that EPA may issue or other enforcement action that EPA may take, nor does SBREFA create any new rights or defenses under the law other than the right to comment to the SBREFA Ombudsman. If you are unable to access the links provided or need a hard copy, please contact the Enforcement Officer listed above. This Request is not subject to the Paperwork Reduction Act, 44 U.S. C. 3501 et seq., because it seeks collection of information from specific individuals or entities as part of an administrative action or investigation. SECTION I. GENERAL INSTRUCTIONS 1. If information or documents not known or not available to you as of the date of submission of a response to this Request should later become known or available to you, you must supplement your response to EPA. Moreover, should you find at any time after the submission of your response that any portion of the submitted information is false or misrepresents the truth, you must notify EPA of this fact as soon as possible and provide EPA with a corrected response. 2. For each document produced in response to this Request, indicate on the document, or in some other reasonable manner, the number of the question to which it corresponds. 3. Please provide a separate response to each question and subpart of a question set forth in this Request and precede each answer with the number of the question to which it corresponds. If a document is responsive to more than one question, this must be so indicated, and only one copy of the document need be provided. If you have no responsive information or documents pertaining to a particular question or subpart of a question, submit a statement certifying this, along with a detailed explanation for each such question. 4. For each question, identify each person responding to any question contained in this Request on your behalf, as well as each person consulted in the preparation of a response. 5. Please provide copies of documents in searchable electronic format (e.g., Microsoft Word or optical character recognition ("OCR") Adobe Acrobat portable document format ("PDF")). 6. Data should be provided in searchable and editable electronic format (e.g., Microsoft Excel or other electronic spreadsheet format). 7. When a response is provided in the form of a number, specify the units of measure of the number in a precise manner. 8. Paper documents should be electronically produced, i.e., scanned and legible copies, organized by the number of the question to which it responds. "Paper documents" means (i) documents that exist only in paper form, or (ii) paper version of documents that also exist in electronic form, only in cases where the paper version contains additional information, such as annotations or signatures, that exist only on the paper copy. 4 Americas Styrenics LLC, St. James Plant CAA 114 Information Request 9. Please submit confidential business information ("CBI") and non-confidential information separately and identify as such. Please mark each page that is CBI as such. To make a CBI claim on electronic copy documents, mark each page that is claimed, by cover sheet, stamp, or other suitable form of notice with language such as "trade secret," "proprietary," or "company confidential." Allegedly confidential portions of otherwise non-confidential documents should be clearly identified, and submitted separately to facilitate identification and handling by EPA. The assertion and substantiation requirements for CBI claims are discussed in Enclosure B. 10. Indicate the assigned facility-wide federal air program (e.g., AFS) and state (e.g., Agency Interest, Regulated Entity) identification numbers for the subject Facility. 11. Please identify documents consulted, examined, or referred to in the preparation of the response or that contains information responsive to the question, and provide a true and correct copy of each such document if not already provided in response to another specific question. Please indicate the number of the question to which the document corresponds. 12. If information responsive to this Request was previously provided to EPA subsequent to a recent EPA CAA inspection, EPA does not require that such information be submitted again. In lieu of resubmitting such information, please indicate which information was already provided, the date that the information was submitted to EPA, and to whom it was provided. If previously submitted information does not fully and completely respond to a question, AmSty is obligated to provide additional information to fully and completely respond to that question. If AmSty has any questions regarding the responsiveness of previously submitted information, please contact Lindsay Rich Steinmetz at 214-665-7425. 13. The enclosed Statement of Certification (Enclosure C) must be filled out and signed by a responsible corporate official and submitted along with your responses to this Request. 5 Americas Styrenics LLC, St. James Plant CAA 114 Information Request SECTION II. DEFINITIONS All terms used in the Request will have their ordinary meaning unless such terms are defined in the CAA, 42 U.S.C. 7401 et seq., other CAA implementing regulations, or otherwise defined herein: 1. The terms "document," "documents," and "documentation" means any object that records, stores, or presents information, and includes writings of any kind, formal or informal, draft or final, whether or not wholly or partially in handwriting, including documentation solely in electronic form, including by way of illustration and not by way of imitation, any invoice, manifest, bill of lading, receipt, endorsement, check, bank draft, canceled check, deposit slip, withdrawal slip, order, correspondence, record book, minutes, memorandum of telephone and other conversations, including meetings, agreements and the like, diary, calendar, desk pad, scrapbook, notebook, bulletin, circular, form, pamphlet, statement, journal, postcard, letter, telegram, telex, report, notice, message, email, analysis, comparison, graph, chart, interoffice or intraoffice communications, photostat or other copy of any documents, microfilm or other film record, any photograph, sound recording on any type of device, any hard drive, USB drive, CD, DVD, or other type of memory generally associated with computers and data processing (together with the programming instructions and other written material necessary to use such hard drive, USB drive, CD, DVD, or other type of memory and together with printouts of such hard drive, USB drive, CD, DVD, or other type of memory); and (a) every copy of each document which is not an exact duplicate of a document which is produced, (b) every copy which has any writing, figure or notation, annotation or the like on it, (c) drafts, (d) attachments to or enclosures with any document, and (e) every document referred to in any other document. 2. The term Americas Styrenics LLC ("AmSty") includes any officer, director, agent, or employee of AmSty, including any merged, consolidated, or acquired predecessor or parent, subsidiary, division, or affiliate thereof. 3. The terms "person" or "persons" shall have the meaning set forth in Section 302(e) of the Act, 42 U.S.C. 7602(e), and includes an individual, corporation, partnership, association, State, municipality, political subdivision of a State, and any agency, department, or instrumentality of the United States and any officer, agent, or employee thereof. 4. The terms "you" or "yours" means all companies or corporations with which AmSty is affiliated, including its subsidiaries, division, affiliates, predecessors, successors, assigns, and its former and present officers, directors, agents, employees, representatives, attorneys, consultants, accountants, and all other persons acting on its behalf. 5. Words in the masculine shall be construed in the feminine, and vice versa, and words in the singular shall be construed in the plural, and vice versa, where appropriate in the context of a particular question or questions. 6 Americas Styrenics LLC, St. James Plant CAA 114 Information Request SECTION III. QUESTIONS Using the Instructions and Definitions set forth in Sections I and II of Enclosure A, please provide responses to the following Questions about the Facility. Responses due within thirty (30) days of the date of this Request. 1. Provide a detailed plot plan, or set of plot plans if more appropriate, of your entire facility, including all process units, buildings, and support structures. The plans should include Emissions Point Numbers ("EPNs"), Equipment Numbers ("EQTs"), and tank numbers. 2. Provide process flow diagrams for each process at the Facility. Identify each wastewater stream and the wastewater sampling locations on these diagrams. 3. Provide records, in excel spreadsheet format, of daily production of styrene (lbs/day) and ethylbenzene (lbs/day) from January 1, 2018, to date of receipt of this Request. 4. Provide records, in excel spreadsheet format, of the benzene (lbs/month) and ethylene (lbs/month) imported to the facility from January 1, 2018, to date of receipt of this Request. 5. Provide a copy of Total Annual Benzene Reports required by 40 C.F.R. 61.357 from 2018 to date of receipt of this Request. 6. Provide records relating to any emissions event of VOC or HAPs that has occurred since January 1, 2018, including but not limited to, the event reported to LDEQ on April 27, 2022 (Incident Number 22-02200), the emissions detected by EPA at the condensate pumps during the Clean Air Act Inspection (CAA) on April 21, 2022, and the event reported to LDEQ on September 24, 2021 (Incident Number 21-04796). Provide, separately for each emissions event: a. Estimated mass of VOC and specific HAPs emitted; b. Calculations indicating how emissions associated with the incident were estimated; c. A detailed description of the incident and events leading-up to the incident, including a Piping and Instrumentation Diagram ("P&ID(s)") showing the compromised equipment, EPNs and stream(s), including piping and vent location(s); d. A detailed description of any corrective actions taken to stop the emissions event and prevent future releases of VOC and HAPs; e. A detailed description of how off-site impacts were determined; and, f. Any records related to the emissions event, including but not limited to, correspondence internal and external, work orders, and records of any monitoring conducted to ensure or demonstrate that the incident was corrected. 7 Americas Styrenics LLC, St. James Plant CAA 114 Information Request 7. For each Boiler Unit (EPNs: 3-88, 2-96, HB-302, HS-301A, HS-301B and HS-301C) and Heater Unit (EPN 2-88, 4-88, and 1-97), provide the following records, in Microsoft Excel spreadsheet format (.xls), from January 1, 2020, to date of receipt of this Request, unless otherwise noted: a. A copy of the test report(s), in portable document format ("PDF"), for any test measuring emissions that was conducted on any Boiler Unit or Heater Unit on or after January 1, 2018, for any reason; b. Daily average temperature (F) for each operating day; c. Daily average fuel gas rate (dsfm and BTU/hr) for each operating day; d. Daily average residue oil mass input rate (lb/min) for each operating day; e. Daily average steam rate (lb/hr) for each operating day; f. Average oxygen content (%O2) of the flue gas for each day, the permitted %O2 limit, any alarm due to the oxygen content, and any corrective action taken as the result of any oxygen alarm for each operating day; g. Weekly visible emission inspections or opacity checks using Method 9 conducted on each Boiler Unit and Heater Unit exhaust stack (PDF); and h. Inspections and repair(s), or attempt(s) of repair, for each boiler, heater and associated ductwork, piping, or connections (PDF), including but not limited to: i. the date(s) of inspection, repair(s), or attempt(s) at repair; ii. description(s) of the observed defect(s), the repair(s), or attempt(s) of repair; and, iii. verification that the repair was successful, or the attempt(s) of repair(s) were unsuccessful. 8. Provide operation and maintenance records from January 1, 2020, to date of receipt of this Request for the heat exchange process, including but not limited to tube bundle inspections, work orders for repair, mechanical integrity tests, and operation and maintenance manuals. Provide any standard operating procedures ("SOP") and P&IDs for the heat exchange process. 9. Provide a list of all liquid streams that feed into the wastewater treatment system(s), and describe which process generates the listed streams. Provide a water balance diagram. 10. Provide a description of the function, operation of, frequency of use, typical volume contained, contents contained, residence time of contents, and history of the equipment referred to EPA inspectors on April 21, 2022, as "Dissolved Air Flotation ("DAF") tank." Include any sampling records related to the DAF tank from January 1, 2020, to date of receipt of this Request. 11. Provide a process flow diagram and P&ID of the Inhibitor Storage Area, also known as the Butyldinitrophenol ("DNBP") Inhibitor Area. Provide operation and maintenance records from January 1, 2020, to date of receipt of this Request including, but not limited to inspections, work orders for repair, control devices used, monitoring records, mechanical integrity tests, and operation and maintenance SOP or manuals. 12. Provide the procedures for the usage of the carbon canisters installed at the "frac tanks" in the DNBP Inhibitor Area referenced in an email to EPA on May 9, 2022. Provide the following: a. Manufacturer's recommended replacement schedule; b. Actual replacement schedule; and, c. Results of any monitoring performed. 8 Americas Styrenics LLC, St. James Plant CAA 114 Information Request 13. For each storage tank at the Facility which contains Styrene, Benzene and Ethylbenzene, provide the following information: a. Tank ID number and EPN or EQT (where applicable); b. Contents of tank; c. Type of tank (internal floating roof, external floating roof, fixed roof, etc.); d. Type of rim seals (primary and secondary), if applicable; e. Tank dimensions; f. Dates of last tank visual inspection, seal gap inspection, and 10-year inspection; g. Set-point pressure for each pressure relief device and vacuum breaker. If the tank contains a nitrogen blanket, provide the set-point pressure for the nitrogen; h. Monthly average Temperature (F) and temperature monitoring system calibration from January 1, 2020, to date of receipt of this Request; i. Calculated True Vapor Pressure ("TVP"); and, j. Potential Emissions and Actual Emissions calculations, including working and breathing losses. 14. For each tank listed in Question 13, describe if and how tank emissions are controlled and where emissions are routed to a control device, include a description of the control device used. 15. For each floating roof tank listed in Question 13, provide any documents describing tank inspection procedures. If such documentation does not exist, then provide a narrative description of such procedures. 16. For each floating roof tank listed in Question 13, provide a copy of the 10-year inspection report and seal gap inspection report immediately preceding April 21, 2022. 17. For each tank listed in Question 13, provide mechanical integrity test results, work orders for repair, and records of any inspection or monitoring conducted to verify or demonstrate a repair was completed from January 1, 2020, to date of receipt of this Request. 9 Americas Styrenics LLC, St. James Plant CAA 114 Information Request ENCLOSURE B CONFIDENTIAL BUSINESS INFORMATION (CBI) CLAIM ASSERTION & SUBSTANTIATION REQUIREMENTS Assertion - You may assert a business confidentiality claim covering all or part of the information requested in response to this Request, as provided in 40 C.F.R. 2.203(b). You may assert a business confidentiality claim covering such information by placing on (or attaching to) the information you desire to assert a confidentiality claim, at the time it is submitted to EPA, a cover sheet, stamped, or typed legend (or other suitable form of notice) employing language such as "trade secret," "proprietary," or "company confidential." Allegedly confidential portions of otherwise non-confidential documents should be clearly identified and submitted separately to facilitate identification and handling by EPA. If confidential treatment is desired up until a certain date or until the occurrence of a certain event, the notice should state this. Information covered by such a claim will be disclosed by EPA only to the extent, and by means of the procedures, set forth in Section 114(c) of the Clean Air Act (CAA) and 40 C.F.R. Part 2. EPA will construe the failure to furnish a CBI claim with your response to this Request as a waiver of that claim, and the information may be made available to the public without further notice to you. You should read 40 C.F.R. Part 2 carefully before asserting a confidentiality claim, since certain categories of information are not properly the subject of a claim. Emission data is exempt from claims of confidentiality under Section 114 of the CAA. Any emissions data you provide may be made available to the public. Information subject to a confidentiality claim is available to the public only to the extent allowed under 40 C.F.R. Part 2, Subpart B. Substantiation - All confidentiality claims are subject to EPA verification in accordance with 40 C.F.R. Part 2, Subpart B. The criteria for determining whether material claimed as confidential is entitled to such treatment are set forth at 40 C.F.R. 2.208(a)-(d) and 2.301. These regulations provide that business information is entitled to confidential treatment if: (a) The business has asserted a business confidentiality claim which has not expired by its terms, nor has been waived nor withdrawn; (b) that the business has satisfactorily shown that it has taken reasonable measures to protect the confidentiality of the information and it intends to continue to take such measures; the information is not, and has not been, reasonably obtainable without the business's consent by other persons (other than governmental bodies) by use of legitimate means (other than discovery based on a showing of special need in a judicial or quasi-judicial proceeding); (d) no statute specifically requires disclosure of the information; and either (e)(1) disclosure of the information is likely to cause substantial harm to your business's competitive position1; or (e)(2) the information is voluntarily submitted, and its disclosure would be likely to impair the Government's ability to obtain necessary information in the future. See 40 C.F.R. 2.208(a)-(e). Emissions data, as defined at 40 C.F.R. 2.301(a)(2), is expressly not entitled to confidential treatment under 40 C.F.R. Part 2, Subpart B. See 40 C.F.R. 2.301(e).. Pursuant to 40 C.F.R. Part 2, Subpart B, EPA may at any time send you a substantiation request letter (separate from this Request) asking you to substantiate your CBI claim. If you receive a substantiation 1 You will not be required to show that disclosure of the information is likely to cause substantial harm to your competitive position, in light of the Supreme Court's decision in Food Marketing Institute v. Argus Leader Media, No. 18-481 (U.S. Supreme Court, June 24, 2019). As a result of that decision, EPA will not consider whether there is substantial competitive harm in evaluating your CBI claim 10 Americas Styrenics LLC, St. James Plant CAA 114 Information Request request letter, you must provide EPA with a response within the time frame set forth in the letter. Failure to submit a response within that time would be regarded as a waiver of your claim, and EPA may release the information. If you receive a substantiation request letter, EPA will ask you to specify which portions of the information you consider CBI. You must be specific by page, paragraph, and sentence when identifying and substantiating the information subject to your claim. Any information not specifically identified as subject to a CBI claim may be disclosed without further notice to you. If you receive a substantiation request letter, for each item or class of information that you identify as being subject, you will be asked to answer the questions below, giving as much detail as possible, in accordance with 40 C.F.R. 2.204(e): 1. What specific portions of the information do you allege to be entitled to confidential treatment? For what period of time do you request that the information be maintained as confidential, e.g., until a certain date, until the occurrence of a specified event, or permanently? If the occurrence of an event will eliminate the need for confidentiality, please specify the event. 2. Information submitted to EPA becomes stale over time. Why should the information you claim as confidential be protected for the time period specified in your answer to Question #1? 3. What measures have you taken to protect the information claimed as confidential? Have you disclosed the information to anyone other than a governmental body or someone who is bound by agreement not to disclose it? If so, why should the information be considered confidential? 4. Is the information contained in any publicly available material such as the Internet, publicly available databases, promotional publications, annual reports, or articles? Is there any means by which a member of the public could obtain access to the information? Is the information of a kind that you would customarily not release to the public? 5. Has any governmental body made a determination as to the confidentiality of the information? If so, please attach a copy of the determination. 6. For each category of information claimed as confidential, explain with specificity whether release of the information is likely to cause substantial harm to your competitive position. Explain the specific nature of those harmful effects, why they should be viewed as substantial, and the causal relationship between disclosure and such harmful effects. How could your competitors make use of this information to your detriment? You will not be required to respond to this question in light of the Supreme Court's decision in Food Marketing Institute v. Argus Leader Media, No. 18-481 (U.S. Supreme Court, June 24, 2019). As a result of that decision, EPA will not consider whether there is substantial competitive harm in evaluating your CBI claim.2 7. Do you assert that the information is submitted on a voluntary or a mandatory basis? Please explain the reason for your assertion. If you assert that the information is voluntarily submitted 2 For more information, please visit the Department of Justice's guidance at: https://www.justice.gov/oip/exemption-4-aftersupreme-courts-ruling-food-marketing-institute-v-argus-leader-media 11 Americas Styrenics LLC, St. James Plant CAA 114 Information Request information, explain whether and why disclosure of the information would tend to lessen the availability to EPA of similar information in the future. 8. Any other issue you deem relevant. Please note emissions data provided under Section 114 of the Act, 42 U.S.C. 7414, is not entitled to confidential treatment under 40 C.F.R. 2.301(a)(2)(i)(A)-(C). "Emission data" means, with reference to any source of emission of any substance into the air: (A) Information necessary to determine the identity, amount, frequency, concentration, or other characteristics (to the extent related to air quality) of any emission which has been emitted by the source (or of any pollutant resulting from any emission by source), or any combination of the foregoing; (B) Information necessary to determine the identity, amount, frequency, concentration, or other characteristics (to the extent related to air quality) of the emissions which, under an applicable standard or limitation, the source was authorized to emit (including, to the extent necessary for such purposes, a description of the manner and rate of source operation); and (C) A general description of location and nature of source to extent necessary to identify and distinguish from other sources (including, as necessary for such purposes, a description of the device, installation, or operation constituting the source). If you receive a substantiation request letter from EPA, you bear the burden of substantiating your CBI claim. Conclusory allegations will be given little or no weight in the determination. Pursuant to 40 C.F.R. 2.205(b)(2), you may request an extension of this deadline specified in a substantiation request letter, should you receive such a letter. EPA will construe your failure to furnish a timely response to a substantiation request letter as a waiver of your confidentiality claim, consistent with 40 C.F.R. 2.204(e)(1), and EPA may release the information. 12 ENCLOSURE C STATEMENT OF CERTIFICATION St. James Plant Americas Styrenics LLC St. James, LA You are responding to the U.S. Environmental Protection Agency's ("EPA") Information Request, issued pursuant to Section 114 of the Clean Air Act, to determine compliance with the Clean Air Act and its affiliated regulations. Please sign the certification statement below. I certify under penalty of law that am familiar with the information submitted in this document and all attachments and that, based on my inquiry of those individuals responsible for obtaining the information, I believe that the information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine or imprisonment for knowing violations pursuant to Section 113(c)(2) of the Clean Air Act, and 18 U.S.C. 1001 and 1341. ________________________________________ Signature ________________________________________ Printed Name ________________________________________ Title Executed on _____________________________