Document QXpEwy7Q09MmG61e9Bpd3nJjL
Region 6 Enforcement and Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
02/15/2022 - 02/17/2022 Air Clean Air Act Section 112(r) and 40 Code of Federal Regulations (C.F.R.) Part 68 Chemical Accident Risk Management Plan (RMP)
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Contact:
LACC, LLC US LACC, LLC US 2200 Bayou d'Inde Pass Westlake, LA 70669 P.O. Box 1316 Westlake, LA 70669 Calcasieu Andrew Lavin Andrew.Lavin@lottechem.com
EHSS Manager
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
110070031367
RMP 1000 0024 0465 32511 Petrochemical Manufacturing 2869 Industrial Organic Chemicals, Not Elsewhere Classified
Personnel participating in inspection:
Tony Robledo
U.S. EPA
Glen Jenkins
LDEQ
Andrew Lavin
Lotte Chemical
Kaili Patterson
Lotte Chemical
Heather Holbrook
Lotte Chemical
Lauren Schiffman
Lotte Chemical
Carley Simon
Lotte Chemical
Mark Peters
Lotte Chemical
Maite Sedaba
Lotte Chemical
Samuel Gauspohl
Lotte Chemical
Joshua Cormier
Lotte Chemical
Lance Tucker
Lotte Chemical
Michael Estes
Lotte Chemical
Inspector/Enforcement Officer Inspector EHSS Manager Environmental Supervisor Environmental Coordinator PSM Engineer EHA Admin Assistant Site Executive Director Process Engineer Mechanical Reliability Engineer Day Supervisor IH/Safety Emergency Response
EPA Lead Inspector Signature/Date
ANTHONY
ROBLEDO
Digitally signed by ANTHONY ROBLEDO DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=ANTHONY ROBLEDO, 0.9.2342.19200300.100.1.1=68001003655529 Date: 2022.03.01 08:42:36 -06'00'
Tony Robledo
Supervisor Signature/Date
SAMUEL
Digitally signed by SAMUEL TATES
TATES DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=SAMUEL TATES, 0.9.2342.19200300.100.1.1=68001003655433 Date: 2022.03.03 11:19:43 -06'00'
Samuel Tates
6ENFORM-020-R8.2 (02/12/2020)
LACC, LLC US Inspection Dates: 02/15/2022 - 02/17/2022
Section I - INTRODUCTION PURPOSE OF THE INSPECTION
I, Environmental Protection Agency (EPA) Region 6 inspector Tony Robledo, arrived at LACC, LLC US at approximately 9:00 a.m. on February 15, 2022, for an announced inspection. I met with Andrew Lavin, LACC, LLC US (LACC), and LACC staff at the opening meeting. I presented my credentials to him and LACC staff, and informed them that this was an EPA inspection to determine compliance with the Clean Air Act (CAA) Sections 112(r)(1) and 112(r)(7). The scope of the inspection was a partial compliance evaluation (PCE) and included evaluation of the compliance with 40 C.F.R. Part 68 - Chemical Accident Prevention Provisions. Glen Jenkins, Louisiana Department of Environmental Quality (LDEQ) inspector, assisted with this inspection on February 16 - 17, 2022.
FACILITY DESCRIPTION
The facility manufactures ethylene and is owned and operated by LACC, a joint venture between Lotte Chemical Louisiana LLC, a wholly owned subsidiary of Lotte Corporation of South Korea, and Axiall a Westlake Company. The ethylene facility uses ethane in an ethane cracking process to produce up to 1 million metric tons per year of ethylene product. The facility also consists of an Integrated Combustion Control System that consists of an enclosed ground flare and a high-pressure ground flare. The facility handles both regulated flammable and toxic substances above their threshold quantities. The regulated flammable RMP chemicals are 1,3 butadiene, propane, propylene, ethylene, butene, methane, ethane, butane, and pentane. The regulated toxic RMP chemical is chlorine. There are 243 full-time employees at this non-union plant. The plant operates 24 hours a day, seven days a week.
Section II - OBSERVATIONS
Glen Jenkins, LDEQ inspector, and I conducted a walk-through of the facility, accompanied by LACC personnel, to observe the facility process, equipment, pressure vessels, and operations. I observed no spills, leaks, or fugitive hydrocarbon emission trails with the Forward Looking Infrared (FLIRTM) Series GF320 camera. Additional observations and findings are found on the RMP Program Level 3 Checklist, located in Appendix #1.
Section III - AREAS OF CONCERN
Closing Meeting - I convened a closing meeting on Thursday, February 17, 2022, to discuss the Areas of Concern (AOC) noted during the inspection, the completion process, and to answer questions from LACC personnel.
AOC 1 - 40 C.F.R. 68.30(b) Defining off site impacts - population
(b) Population to be defined. Population shall include residential population. The presence of institutions (schools, hospitals, prisons), parks and recreational areas, and major commercial, office, and industrial buildings shall be noted in the RMP.
In its worse-case scenario and alternative-release scenarios, LACC failed to identify the presence of public receptors within a circle with its center at the point of release and a radius determined by the distance to the endpoint, as defined in 68.22(a). LACC used EPA's RMP*Comp program for its offsite consequence analysis and indicated public receptors in its RMP.
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LACC, LLC US Inspection Dates: 02/15/2022 - 02/17/2022
AOC 2 - 40 C.F.R 68.67(f) Process Hazard Analysis (PHA)
(f) At least every five (5) years after the completion of the initial process hazard analysis, the process hazard analysis shall be updated and revalidated by a team meeting the requirements in paragraph (d) of this section, to assure that the process hazard analysis is consistent with the current process. Updated and revalidated process hazard analyses completed to comply with 29 CFR 1910.119(e) are acceptable to meet the requirements of this paragraph.
LACC failed to complete a PHA five years after its initial PHA completed on May 20, 2016. LACC noted that it initiated its most recent PHA on January 25, 2021, but has yet to complete a final report.
AOC 3 - 40 C.F.R 68.69(c) Operating Procedures
(c) The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to stationary sources. The owner or operator shall certify annually that these operating procedures are current and accurate.
LACC failed to provide documentation that it conducted an annual certification of its operating procedures for years 2020 and 2021.
AOC 4 - 40 C.F.R 68.96(b)(1)(i)(ii) Emergency Response Exercises
(b)(1) Emergency response field exercises. The owner or operator shall conduct field exercises involving the simulated accidental release of a regulated substance (i.e., toxic substance release or release of a regulated flammable substance involving a fire and/or explosion).
(i) Frequency. As part of coordination with local emergency response officials required by 68.93, the owner or operator shall consult with these officials to establish an appropriate frequency for field exercises.
(ii) Scope. Field exercises shall involve tests of the source's emergency response plan, including deployment of emergency response personnel and equipment. Field exercises should include: Tests of procedures to notify the public and the appropriate Federal, state, and local emergency response agencies about an accidental release; tests of procedures and measures for emergency response actions including evacuations and medical treatment; tests of communications systems; mobilization of facility emergency response personnel, including contractors, as appropriate; coordination with local emergency responders; emergency response equipment deployment; and any other action identified in the emergency response program, as appropriate.
LACC failed to conduct emergency response field exercises in coordination with local emergency response officials for the year 2021.
AOC 5 - 40 C.F.R 68.195(b) Risk Management Plan Required Corrections
(b) Emergency contact information - Beginning June 21, 2004, within one month of any change in the emergency contact information required under 68.160(b)(6), the owner or operator shall submit a correction of that information.
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LACC, LLC US Inspection Dates: 02/15/2022 - 02/17/2022 LACC failed to update in its RMP the name of the designated emergency contact within one month from the retirement of that individual in October 2019. LACC updated its RMP with a new designated emergency contact on February 8, 2022. Section IV - FOLLOW UP There were no additional records requested and no additional follow up for this inspection. Section V - LIST OF APPENDICES Appendix #1 - RMP Program 3 Checklist Inspection Symbol Key: Y - Yes, N - No, N/A - Not Applicable; S - Satisfactory, M - Marginal, U - Unsatisfactory.
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