Document LoBRpEoykpBMXqa4xewrN7VL5

EPA Inspection Report - Page 1 of 20 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/06/2024 Air Title V, NESHAP Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: OCI Beaumont, LLC OCI Beaumont 5470 North Twin City Highway (Lat 30.017336, Long -94.035029) Nederland, TX 77627 5470 North Twin City Highway Nederland, TX 77627 Jefferson County 409-723-1966 Lisa Anderson Senior Environmental Specialist Lisa.anderson@oci-global.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110070071770 RN102559291 / Title V - O1645; NSR - 901; GHGPSDTX50 AFS 36-0042-3792 325199 - All Other Basic Organic Chemical Manufacturing 2869 - Industrial Organic Chemicals Personnel participating in inspection: Kenneth R. McPherson EPA Region 6 ECDAT Justin Chen EPA Region 6 ECDAT Ben Donaldson EPA Region 6 ECDAT Dan Hoyt EPA OECA AED Nathan Hicks EPA OECA AED Phil Myers, PhD EPA NEIC Richard Helmich, PhD EPA NEIC Zach Adamson OCI-Beaumont Lisa Anderson OCI-Beaumont Brian Lucas OCI-Beaumont Life Scientist Environmental Engineer Environmental Engineer Environmental Engineer Physical Scientist Mechanical Engineer Senior Chemist Plant Director Senior Environmental Specialist Health, Safety and Environment Manager EPA Lead Inspector Signature/Date Digitally signed by KENNETH KENNETH MCPHERSON MCPHERSON Date: 2024.04.16 16:09:58 -05'00' Kenneth R. McPherson Date Supervisor Signature/Date JAMES LEATHERS Date: 2024.04.16 16:19:06 -05'00' Digitally signed by JAMES LEATHERS James Leathers Date 1 EPA Inspection Report - Page 2 of 20 Section I - INTRODUCTION OCI Beaumont LLC / OCI Beaumont Inspection Date 02/06/2024 PURPOSE OF THE INSPECTION EPA inspectors Kenneth McPherson (EPA Region 6, "Region 6"), Justin Chen (Region 6), Ben Donaldson (Region 6), Dan Hoyt and Nathan Hicks (EPA Office of Enforcement and Compliance Assurance "OECA") accompanied by Philip Myers and Richard Helmich (National Enforcement Investigations center, "NEIC") arrived at the OCI Beaumont facility ("Facility") in Nederland, Texas at 13:18 on February 6, 2024, for an unannounced inspection. The EPA inspectors held an opening conference with OCI Beaumont LLC (OCI Beaumont) representatives Zach Adamson, Plant Director; Lisa Anderson, Senior Environmental Specialist; and Brian Lucas, Health, Safety, and Environment Manager. Inspector Chen presented his credentials to Zach Adamson and Lisa Anderson, while Inspector McPherson informed them that we were conducting an EPA inspection to evaluate potential sources of excess emissions using EPA's Geospatial Measurement of Air Pollution ("GMAP") vehicle and to evaluate compliance with the Facility's Title V Air Permit and the Clean Air Act. The scope of the inspection was a partial compliance evaluation ("PCE"). This inspection occurred as part of a multi-scale monitoring project in the BeaumontPort Arthur, Texas area. Photographs and videos taken during the inspection can be found in Appendix 1 and 2, respectively. The sign-in sheet for the opening conference is attached as Appendix 3. FACILITY DESCRIPTION OCI Beaumont is a chemical manufacturing Facility that operates under Clean Air Act ("CAA") Title V Permit Number O1645 issued on January 18, 2023. OCI Beaumont operates an integrated ammonia and methanol production complex located on a 62-acre site at the Beaumont Works Industrial Park ("BWIP") south of Beaumont, Texas on the Neches River. Other facilities at the BWIP include Dow Beaumont Aniline and Jefferson Terminal South. Established in the 1960's, OCI Beaumont acquired the Facility in 2011. The current permitted annual production is 912,500 metric tons of methanol and 355,875 metric tons of anhydrous ammonia. The Facility has 234 employees, including contractors, and operates 8760 hours per year. The primary feedstock for the methanol plant is natural gas which is combusted with recycle streams (process fuel gas) from various units to produce Syngas. The Syngas is converted to methanol in the reactors, and then refined in four distillation columns to produce the final methanol product, hydrogen gas and a gaseous recycle stream. Methanol is shipped via the docks or pipeline to various customers. The hydrogen gas is sent to the ammonia plant where it is purified to remove the organic components (which are recycled to the fuel gas system of the reformers), and then combined with nitrogen in a converter reactor to form ammonia. The ammonia is condensed, purified, depressurized for additional cooling, and then shipped as liquid ammonia from the ammonia refrigeration system. The methanol line contains two storage tanks with a combined storage capacity of 42,000 metric tons, a crude methanol surge tank, refined receiver plant, storage tank scrubber, and crude tank scrubber. The ammonia line consists of the ammonia unit, four combustion flares, two process heater/furnaces, process recovery units, and two refrigerated ammonia storage tanks with a combined storage capacity of 33,000 metric tons. 2 EPA Inspection Report - Page 3 of 20 Section II - OBSERVATIONS OCI Beaumont LLC / OCI Beaumont Inspection Date 02/06/2024 At 14:31 on February 6, 2024, we entered the Facility to conduct GMAP surveillance and to identify and observe emission sources. The NEIC GMAP vehicle was driven by Inspector Helmich, and the instruments were operated by Inspector Myers. I was present in the GMAP vehicle observing the survey. OCI Beaumont representatives Lisa Anderson and Brian Lucas were present in a lead company vehicle, guiding the GMAP vehicle. The meteorological conditions during the inspection consisted of a partly cloudy sky, winds from the north/northwest at 7 mph, temperature of 66o F, and a relative humidity of 62%. Inspectors Hoyt and Hicks followed the GMAP in a Data Acquisition in Real Time ("DART") mobile air monitoring system equipped vehicle. Inspectors Chen and Donaldson followed the DART equipped vehicle in a support vehicle. The GMAP vehicle, followed by the DART equipped vehicle and support vehicle, drove on all available Facility roads measuring air pollutant concentrations downwind of each of the process areas, if possible. A full report from the GMAP will be issued by NEIC on a later date. At 14:56 on February 6, 2024, the GMAP vehicle detected an ambient methane (CH4) plume of 4.0 parts per million ("ppm") in the truck terminal south and west of the Methanol Shore Tanks Scrubber ("MSTS") (EPN 35M). I used an infrared optical gas imaging ("OGI") camera to observe the Methanol Shore Tanks (TFX-33 and TFX-34) and the MSTS. Using the OGI camera, I observed the MSTS releasing a plume of hydrocarbons emanating from a vent at the top of the unit (FLIR0009) [AOC 1]. I used the OGI camera in high-definition mode and observed the MSTS releasing a predominant plume of hydrocarbons lifting to the atmosphere from the MSTS vent, and a more disbursed plume of hydrocarbons drifting parallel to the ground from the MSTS vent in a northwest to southeast direction. Per OCI Beaumont representatives Lisa Anderson and Brian Lucas, neither the Methanol Shore Tanks nor the MSTS should have methane in the product or in the demineralized makeup water used as scrubbing water, so they should not emit methane. The GMAP survey of the Facility ended at 15:20 on February 6, 2024. The OCI Beaumont representatives left the inspection team as we continued GMAP surveillance of other facilities at the BWIP. At 17:10 on February 6, 2024, we returned to the OCI conference room. After departing the Facility, I requested and received the monitored MSTS operational parameters data provided by the Facility on February 20, 2024, that covered the period from August 16, 2023, to February 14, 2024. After departing the Facility, I reviewed the Facility's greenhouse gas Permit Number GHGPSDTX50 issued by the Texas Commission on Environmental Quality ("TCEQ"). Neither the MSTS nor the Methanol Shore Tanks were listed as components in the Facility's greenhouse gas permit for allowable fugitive methane (CH4) emissions [AOC 2]. This was supported through a review of the Facility's CAA Title V Permit Number O1645 that lists the MSTS (EPN 35M) and Methanol Shore Tanks (EPN 35) as separate fugitive emissions sources from the Methanol Plant Fugitive Equipment (EPN MET/PRC247). 3 EPA Inspection Report - Page 4 of 20 Section III - AREAS OF CONCERN OCI Beaumont LLC / OCI Beaumont Inspection Date 02/06/2024 Inspectors McPherson, Chen, Donaldson, Hoyt, Hicks, Helmich, and Myers conducted an inspection closing conference at OCI Beaumont LLC / OCI Beaumont at 17:15 on February 6, 2024. Inspectors McPherson and Myers summarized the facility survey and presented their emissions observations, including the following Areas of Concern ("AOC"). The facility made no claims of confidential business information regarding the videos or documents provided. The facility was informed that copies of the videos would be made available to the facility following the inspection. We departed the Facility at 18:15, February 6, 2024. AOC 1) EPA inspectors observed hydrocarbons containing methane being emitted from the Methanol Shore Tanks Scrubber (MSTS) vent. This indicates that either the methanol product or the scrubbing water source may be contaminated with methane, and that the MSTS may be operating with poor efficiency resulting in excess emissions. 40 CFR 63.6(e)(1)(i) requires air pollution control equipment to be operated in a manner consistent with safety and good air pollution control practices for minimizing emissions. 30 TAC 116.115(b)(2)(G) states that permitted facilities shall not be operated unless all air pollution emission capture and abatement equipment is maintained in good working order and operating properly during normal facility operations. AOC 2) EPA inspectors reviewed the OCI Beaumont LLC Green House Gas Permit Number GHGPSDTX50 ("Permit"), approved April 24, 2018, by TCEQ. The Permit replaced Permit Number PSD-TX-1334-GHG. Neither the MSTS nor the two Methanol Shore Tanks were identified as a components of the methanol plant process fugitive equipment (EPN MET-FUG247) in the Permit. This indicates that greenhouse gas emissions, including methane, from the MSTS and/or Methanol Shore Tanks may not be accounted for in OCI Beaumont's maximum allowable emissions rates for methane in the Permit. OCI Beaumont representatives stated during the inspection that the methane should not be part of the MSTS emissions. There may be a problem with contamination of methane in either the methanol product, or the source water for the MSTS. 40 CFR 63.6(e)(1)(i) requires air pollution control equipment to be operated in a manner consistent with safety and good air pollution control practices for minimizing emissions. 30 TAC 116.115(b)(2)(F) states that the total emissions of air contaminants from any of the sources of emissions must not exceed the values stated on the table attached to the permit. 30 TAC 116.115(b)(2)(G) states that permitted facilities shall not be operated unless all air pollution emission capture and abatement equipment is maintained in good working order and operating properly during normal facility operations. Section IV - FOLLOW UP On February 19, 2024, EPA requested additional information relating to the operational parameters monitored and logged for the Methanol Shore Tanks Scrubber (M35). This information was received on February 26, 2025 On March 20, 2024, Inspector McPherson provided electronic copies of the videos recorded during the inspection to OCI Beaumont representative Lisa Anderson. 4 EPA Inspection Report - Page 5 of 20 Section V - LIST OF APPENDICES OCI Beaumont LLC / OCI Beaumont Inspection Date 02/06/2024 Appendix 1 - Video Log - OGI video taken 02/06/2024. Appendix 2 - Opening and closing conference sign-in sheets. Appendix 3 - Greenhouse Gas Permit No. GHGPSDTX50, dated 04/25/2018, selected pages. Appendix 4 - Federal Operating Permit No. O1645, dated 01/18/2023, selected pages. 5 EPA Inspection Report - Page 6 of 20 OCI Beaumont LLC / OCI Beaumont Inspection Date 02/06/2024 Appendix - 1 VIDEO LOG EPA Inspection Report - Page 7 of 20 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 1 Location: OCI Beaumont LLC / OCI Beaumont City: Nederland County: Jefferson County State: Texas Video File Name: Date of Video: Time of Video: Videographer: Web Source: Description: FLIR0009.mp4 02/06/2024 3:11 PM Kenneth McPherson https://youtu.be/2NbIGHQMduk Methanol Shore Tanks Scrubber (EPN 35M) and Methanol Store Tanks (TFX-33 and TFX23). Visible volatile organic compound emissions observed from vent pipe at the top of of the Methanol Shore Tanks Scrubber. Page 1 of 1 EPA Inspection Report - Page 8 of 20 OCI Beaumont LLC / OCI Beaumont Inspection Date 02/06/2024 Appendix - 2 OPENING AND CLOSING CONFERENCE SIGN-IN SHEETS EPA Inspection Report - Page 9 of 20 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Opening and Closing Conference Sign-in Sheets Appendix 2 Location: OCI Beaumont LLC / OCI Beaumont City: Nederland County: Jefferson County State: Texas Page 1 of 2 EPA Inspection Report - Page 10 of 20 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Opening and Closing Conference Sign-in Sheets Appendix 2 Location: OCI Beaumont LLC / OCI Beaumont City: Nederland County: Jefferson County State: Texas Page 2 of 2 EPA Inspection Report - Page 11 of 20 OCI Beaumont LLC / OCI Beaumont Inspection Date 02/06/2024 Appendix - 3 GREENHOUSE GAS PERMIT NUMBER: GHGPSDTX50 Date 04/25/2018 (Select Pages) EPA Inspection Report - Page 12 of 20 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Greenhouse Gas Permit Number: GHGPSDTX50 Location: OCI Beaumont LLC / OCI Beaumont City: Nederland County: Jefferson County State: Texas Appendix 3 Page 1 of 4 EPA Inspection Report - Page 13 of 20 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Greenhouse Gas Permit Number: GHGPSDTX50 Location: OCI Beaumont LLC / OCI Beaumont City: Nederland County: Jefferson County State: Texas Appendix 3 Page 2 of 4 EPA Inspection Report - Page 14 of 20 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Greenhouse Gas Permit Number: GHGPSDTX50 Location: OCI Beaumont LLC / OCI Beaumont City: Nederland County: Jefferson County State: Texas Appendix 3 Page 3 of 4 EPA Inspection Report - Page 15 of 20 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Greenhouse Gas Permit Number: GHGPSDTX50 Location: OCI Beaumont LLC / OCI Beaumont City: Nederland County: Jefferson County State: Texas Appendix 3 Page 4 of 4 EPA Inspection Report - Page 16 of 20 OCI Beaumont LLC / OCI Beaumont Inspection Date 02/06/2024 Appendix - 4 FEDERAL OPERATING PERMIT NUMBER: O1645 Date 01/18/2023 (Select Pages) EPA Inspection Report - Page 17 of 20 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Federal Operating Permit Number: O1645 Location: OCI Beaumont LLC / OCI Beaumont City: Nederland County: Jefferson County State: Texas Appendix 4 Page 1 of 4 EPA Inspection Report - Page 18 of 20 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Federal Operating Permit Number: O1645 Location: OCI Beaumont LLC / OCI Beaumont City: Nederland County: Jefferson County State: Texas Appendix 4 Page 2 of 4 EPA Inspection Report - Page 19 of 20 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Federal Operating Permit Number: O1645 Location: OCI Beaumont LLC / OCI Beaumont City: Nederland County: Jefferson County State: Texas Appendix 4 Page 3 of 4 EPA Inspection Report - Page 20 of 20 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Federal Operating Permit Number: O1645 Location: OCI Beaumont LLC / OCI Beaumont City: Nederland County: Jefferson County State: Texas Appendix 4 Page 4 of 4