Document N2r8vXpVNLJ6YL0wy4aaa4oDb

EPA Inspection Report - PagePage 1 of 11 Inspection Date(s): Media Program: Regulatory Program(s) 04/28/2025 - 05/02/2025 Air Clean Air Act Section 112(r) and 40 Code of Federal Regulations (C.F.R.) Part 68 Chemical Accident Prevention Provisions - Risk Management Program (RMP) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: INEOS Group LTD INEOS O&P USA LLC - Battleground Manufacturing 1230 Independence Parkway South La Porte, Texas 77571 (same as above) (same as above) Harris County Rosy Novo BMC PSIM Team Lead Rosa.novo@ineos.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 1100 3870 5817 N/A 1000 0008 4534 325211 - Plastics Material and Resin Manufacturing N/A Personnel participating in inspection: Sherronda Phelps US EPA Region 6 William Steiner INEOS Chock Ganapathy INEOS CAA RMP Inspector PSM Manager SSHE Manager EPA Lead Inspector Signature/Date 06/27/2025 Sherronda Phelps Date Acting Supervisor Signature/Date KAYLA BUCHANAN Date: 2025.07.08 16:30:15 -05'00' Digitally signed by KAYLA BUCHANAN Kayla Buchanan Date EPA Inspection Report - PagePage 2 of 11 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspector, Sherronda Phelps, (I) arrived at the INEOS facility at 9:00 AM on April 28th for an announced inspection. I was met by Rosy Novo (BMC PSIM Team Lead) and other INEOS representatives at the Opening Conference. I presented my credentials to Mrs. Novo and INEOS representatives at the Opening Conference and informed them that this was an EPA inspection focused on the implementation of and compliance (PCE), which included an evaluation of the facility's compliance with the Clean Air Act (CAA) Section 112(r), the Chemical Accident Prevention Provisions in 40 C.F.R. Part 68. FACILITY DESCRIPTION As stated from the Executive Summary in INEOS's Risk Management Plan, INEOS Battleground Manufacturing Complex (BMC) is comprised of multiple polyethylene facilities and a propylene facility. The polyethylene facility manufactures polyethylene for a wide variety of industrial and consumer application. The manufacturing process uses ethylene as the basic building block for producing polyethylene. The regulated substances above the threshold quantity within the polyethylene facility include ethylene, isobutane and propane. Section II - OBSERVATIONS The initial documentation review began on-site with INEOS personnel as listed on the attached, Appendix A, sign in sheets. 40 C.F.R. Part 68 - CHEMICAL ACCIDENT PREVENTION PROVISION Subpart A - General 40 C.F.R. 68.10 Applicability - INEOS is a stationary source that has more than a threshold quantity of regulated substances in their process. The last submittal was made August 12, 2021, due to the 5-year update per 40 CFR 68.190(b)(1). The facility is subject to the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) Standard (29 CFR 1910.119). 40 C.F.R. 68.12 General requirements - INEOS submitted their most recent RMP submission on August 12, 2021. The regulated substance(s) under the toxic and flammable tables are listed over the threshold quantity for the RMP Program Level 3 processes. 40 C.F.R. 68.15 Management - INEOS developed a management system to oversee the implementation of the risk management program elements. INEOS provided an organizational chart that outlined the positions to implement the individual elements of the RMP as required by this subpart. Subpart B - Hazard Assessment EPA Inspection Report - PagePage 3 of 11 40 C.F.R. 68.20 Applicability - INEOS operates an RMP Program Level 3 process which is subject to this subpart and thus is required to prepare a worst-case release scenario analysis and complete the fiveyear accident history. I reviewed the documentation provided to make this analysis and identified no areas of concern with this subpart. 40 C.F.R. 68.22 Offsite Consequence Analysis Parameters - INEOS employed the parameters specified by EPA in this rule by using the RMP*CompTM software. I reviewed the offsite consequence analysis and supporting documentation to assure the data was accurate and correct. 40 C.F.R. 68.25 Worse-case release scenario analysis - INEOS identified and analyzed at least one worst-case scenario in its Program 3 processes using the RMP* CompTM software, thus meeting the requirements of the regulation. 40 C.F.R. 68.28 Alternative Release Scenario Analysis - INEOS identified and analyzed at least one alternative release scenario in its Program 3 processes using the RMP* CompTM software, thus meeting the requirements of the regulation. 40 C.F.R. 68.30 Defining offsite impacts- Population - INEOS used the most current Census Bureau population data and the distances to endpoints, as specified in the regulation, to calculate the population numbers reported in their RMP. 40 C.F.R. 68.33 Defining offsite impacts- Environment - INEOS used US Geological Survey maps data to determine the environmental receptors and the distances to endpoints. 40 C.F.R. 68.36 Review and update - INEOS understands documentation associated with the worstcase scenarios that should be updated and reviewed at least every five years and are anticipating a review in 2026. 40 C.F.R. 68.39 Documentation - INEOS operates a RMP Program Level 3 process which is subject to this subpart and thus is required to prepare a worst-case release scenario analysis and complete the five-year accident history. I reviewed the documentation provided to make this analysis and identified no areas of concern with information pertaining to this subpart to include the Offsite Consequence Analysis (OCA) data. The facility used the EPA Model RMP*CompTM. 40 C.F.R. 68.42 Five-year accident history - INEOS did not report any accidental release(s) in their RMP that resulted in deaths, injuries or property damage. Subpart D - Program 3 Prevention Program 40 C.F.R. 68.65 Process safety information (PSI) - EPA reviewed various sections of the process safety information for the RMP covered processes at INEOS. There were no areas of concern identified. EPA Inspection Report - PagePage 4 of 11 40 C.F.R. 68.67 Process Hazard Analysis (PHA) - EPA reviewed the Process Hazard Analysis (PHA) for the RMP. The PHA study was conducted using What-if, Checklist, and Layer of Protection Analysis (LOPA). EPA reviewed several recommendations for follow-up purposes. The PHA study was conducted using the Hazard and Operability Analysis (HAZOP) method. No areas of concern were observed from the information reviewed. 40 C.F.R. 68.69 Operating procedures - EPA reviewed and discussed with INEOS personnel operating procedures of several units, which included the Standard Operating Procedure (SOP) certification procedure, confined space entry, and lockout/tag out procedures. EPA requested the last five years of annual operating procedure certifications, and all were current. 40 C.F.R. 68.71 Training - INEOS has established operator training as required by this subpart. Operator Training consists of both On the Job Training and Computer Based Training. Written tests were used to evaluate operator competency. As a new hire, at least three to four months is allocated to initial job training while refresher training is required every three years per the regulation or sooner. EPA requested training records for review and was provided the files for several employees at different experience levels. I reviewed employee training records and determined training to operate in the unit is current and refresher trainings are administered as required. There were no areas of concern noted from the information reviewed. 40 C.F.R. 68.73 Mechanical integrity - I reviewed mechanical integrity records for randomly selected inspections of RMP covered equipment and the written procedure for maintaining the integrity of the process. 40 C.F.R. 68.75 Management of change (MOC) - EPA reviewed and discussed written procedures for MOCs with site personnel and their implementation at the facility. The MOCs were implemented using their onsite SharePoint site. EPA reviewed several MOC's from a query of MOCs created over the last five years. They were reviewed for proper implementation and completeness. EPA did not identify any areas of concern. 40 C.F.R. 68.77 Pre-startup safety review (PSSR) - INEOS provided documentation regarding prestartup safety procedures and site plan. EPA did not identify any areas of concern. 40 C.F.R. 68.79 Compliance audits - EPA requested the two most recent compliance audits for review. INEOS provided compliance audit reports completed in February of 2022 and the most recent audit was completed in February 2025, however the report is still in draft form and has not been finalized. EPA did not identify any areas of concern. 40 C.F.R. 68.81 Incident investigation - I reviewed a list of incident reports/investigations for all incidents, which resulted in, or could have reasonably resulted in, a catastrophic release of a regulated substance for the last five years. Of the incident investigations reviewed there were two investigations noted for failing to initiate as promptly as possible, but not later than forty-eight (48) hours following EPA Inspection Report - PagePage 5 of 11 the incident. Incident No: 17672 and 10517. INEOS failed to implement 68.81(b) as required by the regulation. 40 C.F.R. 68.83 Employee participation - INEOS has implemented the requirements of this subpart. No areas of concern were noted at the time of the inspection. 40 C.F.R. 68.85 Hot work permit - INEOS discussed the process for conducting hot work onsite and several hot work permits were reviewed from within the last quarter of 2025. All hot work permits are retained for three years as required by the regulation. There were no areas of concerned noted at the time of the inspection. 40 C.F.R. 68.87 Contractors - INEOS uses Zachary, an embedded contractor, to conduct in house maintenance. INEOS uses ISNET World for its contractor selection and assures that all contractors that may work on site have been trained on the potential hazards related to the process equipment and work that the contractor may perform. In addition, performance reviews are handled annually. There were no areas of concern noted at the time of the inspection. Subpart E - Emergency Response 40 C.F.R. 68.90 Applicability -INEOS is a first responder stationary source in case of an accidental release of a regulated substance, therefore, the facility is subject to the requirements of part 68.95. 40 C.F.R. 68.95 Emergency Response - INEOS is a first responder facility. EPA reviewed the facility's Integrated Contingency Plan - Emergency Response Plan. INEOS has an Emergency Response Team (ERT) of forty (40) employees from varied process units and participation is voluntarily. The Emergency Response Plan details the steps to take in the event of a release of the regulated substances. EPA reviewed training records for several ERT members, and no areas of concern were identified. Subpart G - Risk Management Plan 40 C.F.R. 68.190 Updates - No updates. 40 C.F.R. 68.195 Required corrections -The next RMP re-submission is due by August 12, 2026, unless an update or correction is required by 40 C.F.R. 68.190 and 68.195. Section III - AREAS OF CONCERN (AOC) 1) Incident investigation, 40 C.F.R. 68.81 - A list of incident reports/investigations for all incidents, which resulted in, or could have reasonably resulted in, a catastrophic release of a regulated substance for the last five years. Of the incident investigations reviewed there were two investigations noted for failing to initiate as promptly as possible, but not later than forty- EPA Inspection Report - PagePage 6 of 11 eight 48 hours following the incident. Incident No: 17672 and 10517. INEOS failed to implement 68.81(b) as required by the subpart. Closing Meeting - EPA Region 6 inspector, Sherronda Phelps, conducted a closing conference Closeout/Exit Briefing on May 1, 2025, for the inspection. During the closing conference, I reviewed the Areas of Concern noted and any comments or questions while on site. Section IV - FOLLOW UP No follow up correspondence was provided from the facility nor were there any requests made. Section V - LIST OF APPENDICES (Confidential Business Information (CBI) is not included in published version of the report) 1. Appendix A - Sign in sheets EPA Inspection Report - PagePage 7 of 11 APPENDIX A EPA Inspection Report - PagePage 8 of 11 Sq 4ISEPA 4t PRO1C Clean Air Act Section 112(r)! Chemical Accident Prevention Provisions (40 C.F.R. Part 68) Opening Meeting Sign in Sheet Name (Please Print) J) l L% i&' M- civo Employer __________ INoS __________________ Title ek6 /'1cte 44i iL Tec L'c v3u-e- ot-' _____________ itock _______________ ________________ 1APJA6 i1 A)rL. ____________________ A1tos _______________ Te iiiCOS 'Yo PS.-,11 __________ 1'cM iw McjeiL_ EPA Inspection Report - PagePage 9 of 11 ,g 11 ; _I%) USEPA Clean Air Act Section 112(r) / Chemical Accident Prevention Provisions (40 C.F.R. Part 68) Sign in Sheet Name (Please Print) W\\\u%- PT /1AJMPA7LIy \ (cc 13 k &-cAe /ci_ck QC icel 44yvcjL fk4/l1I)oAf fi 4r ' /A)IJ/ Title A1 Mf-' Sf-E MAg ze- Cu2 SIipre'i^o/t QSW\ Ic Lecid E,Q ' r C&rv(ccc4oc Cocr-oc If4.e1&%(e c.,,eril(QJ..P Program _________ _____________ 0 /- ____________ _____________ _________ _______________ __________ fe.oct 1eQ, Lfa 4! 3f/ei'i1- 7,bc EPA Inspection Report - PagePage 10 of 11 4p s:1 () 3%, 1fic$J USEPA Clean Air Act Section 112(r) / Chemical Accident Prevention Provisions (40 C.F.R. Part 68) Sign in Sheet Name (Please Print) C. / Jf/4 ___________________ Sco,'d J-4rc S ________________ Title ftl rr Itc,,.i c i ') ItAi __________________ teoth ___________ 44 ____________ Mr , /45r Cb JAxpcI-1r ________ Program I1 I EPA Inspection Report - PagePage 11 of 11 9kS 4q USEPA Clean Air Act Section 112(r) / Chemical Accident Prevention Program (40 C.F.R. Part 68) Close Out Meeting Sign in Sheet Name (Please Print) UoMb PL c&oo, M j/J(I114 tit-Z c_1 ock Gi- o-- U ______________ __________ Employer fl- o-. ___________ ____________ s Title _______ it Le& _________ '2-Q. _____________ VLa14AqT __________ SrI ___________ Yet, cos/4