Document MMMV04d6wOv9mNMXv91BZjQM9

EPA Inspection Report - Page 1 of 9 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: Dow Chemical Company Texas Operations Dow Beaumont Aniline 5470 North Twin City Highway, Suite A (Lat 30.015406, Long -94.029378) Nederland, TX 77627 P.O. Box 1646 Nederland, TX 77627 Jefferson County 409-651-8881 Ansley Godwin Environmental Health and Safety Delivery Manager Ansley.godwin@dow.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110067678392 RN109031641 / Title V: O1961 AFS 36-0042-3792 325192 (Cyclic Crude and Intermediate Manufacturing) 2865 (Cyclic Organic Crudes and Intermediates) 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 Ben Fregia Dow Beaumont Aniline Liz McIntosh Dow Beaumont Aniline Ansley Godwin Dow Beaumont Aniline Fran Falcon Dow Beaumont Aniline Life Scientist Environmental Engineer Environmental Engineer Environmental Engineer Physical Scientist Mechanical Engineer Senior Chemist Technical Advisor Environmental Health and Safety Leader Environmental Health and Safety Delivery Manager Regional Environmental Leader Charles Grant Dow Beaumont Aniline Environmental Specialist EPA Lead Inspector Signature/Date KENNETH MCPHERSON Date: 2024.04.16 14:05:35 -05'00' Digitally signed by KENNETH MCPHERSON Kenneth R. McPherson Date Supervisor Signature/Date JAMES LEATHERS Date: 2024.04.16 14:40:04 -05'00' Digitally signed by JAMES LEATHERS James Leathers Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 9 Section I - INTRODUCTION Dow Chemical Company / Dow Beaumont Aniline 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 Dow Beaumont Aniline facility ("Facility") in Nederland, Texas at 15:20 on February 6, 2024, for an unannounced inspection. The EPA inspectors held an opening conference with Facility representatives Fran Falcon, Regional Environmental Leader (on phone); Liz McIntosh, Environmental Health, and Safety Leader; Ansley Goodwin, Environmental Specialist (on phone); John Fregia, Technical Advisor; and Charles Grant, Environmental Specialist. Inspector Chen presented his credentials to Liz McIntosh and John Fregia, 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 ("CAA"). The scope of the inspection was a partial compliance evaluation ("PCE"). This inspection occurred as part of a multi-scale monitoring project in the Beaumont-Port Arthur, Texas area. The sign-in sheet for the opening conference is attached as Appendix 1. FACILITY DESCRIPTION Dow Aniline is a chemical manufacturing facility that operates under the CAA Title V Federal Operating Permit Number O1961 issued on March 17, 2021. Dow Aniline operates an integrated mononitrobenzene and aniline production complex located on a 20.5-acre site at the Beaumont Works Industrial Park ("BWIP") south of Beaumont, Texas on the Neches River. Other facilities at the BWIP include OCI Beaumont and Jefferson Terminal South. Dow Aniline acquired the facility in 2016 from The Chemours Chemical Company. The Facility has 90 employees, including contractors, and operates 8760 hours per year. The primary feedstock for the mono-nitrobenzene is benzene which undergoes a direct nitration through a mixed acid process. The benzene is delivered to the facility via barge where it is unloaded into a holding tank and then piped to the mono-nitrobenzene unit. The mono-nitrobenzene is sent to the analine unit, where it is reduced through catalytic hydrogenation to produce aniline. The aniline is shipped via barge, rail tank car, and pipeline to various end use customers. Dow Aniline is categorized as Risk Management Program Level 3 under Section 112(r) of the Clean Air Act. Section II - OBSERVATIONS At 15:52 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. Dow Aniline representatives Charles Grant and Derick Singleton 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 69o F, and a relative humidity of 60%. Inspectors Hoyt and Hicks followed the GMAP in a Data Acquisition in Real Time mobile air 2 EPA Inspection Report - Page 3 of 9 Dow Chemical Company / Dow Beaumont Aniline Inspection Date 02/06/2024 monitoring system ("DART") 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 16:36 on February 6, 2024, the GMAP vehicle detected an ambient benzene (C6H6) plume of 25 parts per billion ("ppb") at the intersection near the Aniline Lab (AOC 1). We could not determine the specific emission source using optical gas imaging ("OGI") cameras or hand-held benzene specific photoionization detectors ("PID"). At 16:49 on February 6, 2024, the GMAP vehicle detected an ambient benzene (C6H6) plume of 45 ppb near the Maintenance Shop (AOC 1). Inspector Myers collected an air sample using a summa canister for benzene at the site at 17:05. We could not determine the specific emission source using OGI cameras or the hand-held benzene specific PID. The GMAP survey of the Facility ended at 17:10 on February 6, 2024, and we departed the facility and returned to the OCI Beaumont LLC conference room. Section III - AREAS OF CONCERN Inspectors McPherson, Chen, Donaldson, Hoyt, Hicks, Helmich, and Myers conducted a closing conference with Dow Beaumont Aniline / Dow Aniline at 17:15 on February 6, 2024, for the inspection. See Appendix 1 for closing conference sign in sheet. Inspectors McPherson and Myers summarized the facility survey and presented their emissions observations, including the following Areas of Concern ("AOC"). We completed the closing conference with the Dow Aniline representatives at 17:30, and they departed the OCI Beaumont conference room. AOC 1) EPA inspectors observed elevated ambient levels of benzene (C6H6) with the GMAP vehicle and hand-held benzene specific PID at the intersection near the Aniline Lab and near the Maintenance Shop. Though we could not identify the specific source(s) of the benzene in the ambient air, the levels are concerning. Dow Aniline should identify the source to determine compliance with applicable regulations. Section IV - FOLLOW UP On March 29, 2024, EPA requested additional information relating to verify the acquisition history of the Facility by Dow Aniline, the size of the Facility, the number of employees at the Facility, and the hours per year the Facility operates. This information was received on March 29, 2024. 3 EPA Inspection Report - Page 4 of 9 Section V - LIST OF APPENDICES Dow Chemical Company / Dow Beaumont Aniline Inspection Date 02/06/2024 Appendix 1 - Opening and closing conference sign-in sheets. Appendix 2 - Federal Operating Permit No. O1961, dated 03/17/2021, signature page. 4 EPA Inspection Report - Page 5 of 9 Dow Chemical Company / Dow Beaumont Aniline Inspection Date 02/06/2024 Appendix - 1 OPENING AND CLOSING CONFERENCE SIGN-IN SHEETS EPA Inspection Report - Page 6 of 9 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Opening and Closing Conference Sign-in Sheets Location: Dow Chemical Company Texas / Dow Beaumont Aniline City: Nederland County: Jefferson County State: Texas Appendix 1 Page 1 of 2 EPA Inspection Report - Page 7 of 9 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Opening and Closing Conference Sign-in Sheets Location: Dow Chemical Company Texas / Dow Beaumont Aniline City: Nederland County: Jefferson County State: Texas Appendix 1 Page 2 of 2 EPA Inspection Report - Page 8 of 9 Dow Chemical Company / Dow Beaumont Aniline Inspection Date 02/06/2024 Appendix - 2 FEDERAL OPERATING PERMIT NUMBER: O1961 Date 03/17/2021 (Signature Page) EPA Inspection Report - Page 9 of 9 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Federal Operating Permit Number: O1961 Location: Dow Chemical Company Texas / Dow Beaumont Aniline City: Nederland County: Jefferson County State: Texas Appendix 2 Page 1 of 1