Document e7pa5GnddY5bXK66YEqvOMQMM

EPA Inspection Report - Page1 of 23 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/08-09/2024 Air Title V, NSPS Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Ineos Calabrian Corporation Ineos Calabrian Facility 5500 STATE HWY 366 PORT NECHES, TX 77651 See above Jefferson County (409) 727-1471 Ryan Quinn Ryan.quinn@ineos.com Operations Manager FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000746499 TCEQ RN 101645018 48-245-00106 325180 2819 Personnel participating in inspection: Justin Chen Region 6 ECDAT Benjamin Donaldson Region 6 ECDAT Kenneth McPherson Region 6 ECDAT Daniel Hoyt OECA AED Nathan Hicks OECA AED Richard Helmich NEIC Philip Myer NEIC Leslie Pitre Ineos Calabrian Ryan Quinn Ineos Calabrian Roberto Gutierrez Ineos Calabrian Carlos Robles-Sanchez Ineos Calabrian Environmental Engineer Environmental Engineer Life Scientist Environmental Engineer Physical Scientist Chemist Mechanical Engineer SHE Representative Operations Manager Quality Manager Site Manager EPA Lead Inspector Signature/Date JUSTIN CHEN Digitally signed by JUSTIN CHEN Date: 2024.04.16 17:21:53 -05'00' Justin Chen Date Supervisor Signature/Date JAMES LEATHERS Date: 2024.04.16 18:01:45 -05'00' Digitally signed by JAMES LEATHERS James Leathers Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page2 of 23 Ineos Calabrian Facility Port Neches Inspection Date 02/08/20214 2 EPA Inspection Report - Page3 of 23 Ineos Calabrian Facility Port Neches Inspection Date 02/08/20214 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA inspectors Justin Chen (R6 ECDAT), Benjamin Donaldson (R6 ECDAT), Kenneth McPherson (R6 ECDAT), Daniel Hoyt (OECA AED), and Nathan Hicks (OECA AED), accompanied by Philip Myers and Richard Helmich (National Enforcement Investigations center, "NEIC") arrived at the Ineos Calabrian Facility at 9:44AM on February 8, 2024 for an unannounced inspection. We met Ineos Calabrian representatives Ryan Quinn/Operations Manager, Leslie Pitre/Safety, Health, and Environment ("SHE") Representative, and Roberto Gutierrez/Quality Manager. I present my credentials to Ryan Quinn and informed them that this was 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 evaluation ("PCE"). This inspection occurred as part of a multi-scale monitoring project in the Beaumont-Port Arthur area. Photographs and video taken during the inspection can be found in Appendix 1 and 2, respectively. The sign-in sheet for the closing conference is found in Appendix 3. FACILITY DESCRIPTION The Ineos Calabrian facility (Facility) is a sulfur dioxide chemical production facility located in Port Neches, Texas (Jefferson County) that operates under the Clean Air Act ("CAA") as a minor source under New Source Review Permit Number 9214, renewed August 14, 2017. The facility employs 65 employees and operates 8,760 hours per year. The facility produces liquid sulfur dioxide ("SO2"), sodium bisulfite, sodium sulfite, sodium thiosulfate, and sodium meta bisulfite. Section II - OBSERVATIONS The NEIC GMAP was driven by Richard Helmich and the instruments were operated by Philip Myers. Facility representatives, Leslie Pitre, Ryan Quinn, and Roberto Gutierrez followed the GMAP on foot. Conditions were overcast and cloudy. Inspectors Justin Chen, Benjamin Donaldson, and Kenneth McPherson followed the GMAP on foot and Inspectors Daniel Hoyt and Nathan Hicks operated a Data Acquisition in Real Time ("DART") unit on their vehicle, equipped with a photoionization detector ("PID") that measures VOC in the air, and a wind monitor that monitors wind speed, wind direction and geolocation. The DART unit had a 10.6ev PID installed. The Dart equipped vehicle followed the GMAP. The GMAP drove on all available Facility roads measuring air pollutant concentrations downwind of each of the process areas, if possible. We started at the northwestern corner of the Facility property at the Sodium Meta Bisulfite Unit at 10:28AM. At 10:39AM, the GMAP detected SO2 at 500 parts per billion ("PPB"). On a second pass at, the GMAP detected 2 parts per million ("PPM") of SO2, and then 1.5 PPM 3 EPA Inspection Report - Page4 of 23 Ineos Calabrian Facility Port Neches Inspection Date 02/08/20214 SO2 at 10:45AM while continuing to monitor at the Sodium Meta Bisulfite Unit. It was noted by facility staff that a caustic truck was unloading around this time. We then drove to the Sodium Bisulfite Unit, then the Thiosulfate Unit, then the Sodium Sulfite Unit, then the Sulfur Dioxide Unit, then the Sulfur Dioxide Rail Loading Area, and then the Utilities Unit. At 10:55AM, we moved to the Sodium Thiosulfate Tanks and then to the Wastewater Pond, which was adjacent to the Sulfur Solids Disposal roll off dumpsters. The GMAP detected 40 PPB of SO2 near the Sulfur Solids roll off dumpsters and we also observed sulfur solids on the ground (Appendix 1; Photos 7, 8). We then returned to the Sodium Meta Bisulfite Unit as the caustic truck was no longer loading. At 11:25AM the GMAP measured 250 PPB and 275 PPB SO2. The GMAP survey ended at 11:38AM and we returned to the Facility administrative office. A full report from the GMAP will be issued by NEIC at a later date. Region 6/AED Follow-up Inspection At 3:00PM on February 9, 2024 EPA inspectors Ben Donaldson/Region 6, Kenneth McPherson/Region6, Richard Helmich/NEIC, and Philip Myers/NEIC conducted a follow-up inspection of Ineos Calabrian Facility. The inspection team brought a Forward Looking Infrared ("FLIR") camera model GF77 with them to the follow-up inspection. The FLIR Camera GF77 has the capability to visualize specific SO2 emissions. At 3:00PM, the inspection team used the GF77 to observe emissions being released from the Meta Bisulfite Unit while outside the property of the facility. At the fence line near the Meta Bisulfite Unit, we observed that the grass was dead and was covered with a white powdery substance (Appendix 1, Photos 9-10). At 3:15PM, the inspection team made entry to the facility and met with Leslie Pitre for the opening conference for the follow up inspection. At 3:35PM, the follow up inspection began at the Meta Bisfulfite Unit. From the ground the inspection team observed a visual plume of steam escaping from the top of Tank TK-616. Inspector Helmich used the GF77 camera to observe the steam plume coming from the top of Tank TK-616 and recorded a potential SO2 plume trailing in the wind off of the Facility boundary beyond the steam plume. (Appendix 2, Videos 5-8). The steam and potential SO2 emissions were emanating from an open hole in the top of Tank TK-616. The Inspection team smelled a strong sulfurous odor while in the area. Leslie Petre stated that the open hole was a remnant of "agitator" mechanical equipment that was once equipped on Tank TK-616. The hole was where a rotating shaft used to enter the tank. 4 EPA Inspection Report - Page5 of 23 Ineos Calabrian Facility Port Neches Inspection Date 02/08/20214 At 4:22PM, we returned to the administrative office and conducted a closing conference with Leslie Pitre of Ineos Calabrian in attendance and informed him of the observed emissions at the Meta Bisulfite Unit and Tank TK-616. The inspection team departed the facility at 4:54PM. Section III - AREAS OF CONCERN Justin Chen conducted a closing conference at Ineos Calabrian Facility at 11:45AM on February 8, 2024, for the initial inspection. Philip Myers and Justin Chen summarized the facility tour and presented their emissions observations, including the following Areas of Concern. 1. The GMAP detected SO2 emissions at the Meta Bisulfite Unit. 2. The GMAP detected SO2 emissions at the Solid Sulfur Disposal roll off dumpster area. The facility made no claims of confidential business information regarding the photographs taken on February 8, 2024. The facility was informed that copies of the photos would be made available to the facility following the inspection. We departed the facility at 12:05PM. On February 9, 2024, the Inspectors Ben Donaldson, Kenneth McPherson, Richard Helmich, and Philip Myers conducted a closing conference for the follow up inspection. They summarized the time spent at the Meta Bisulfite Unit and presented their emission observations, including the following areas of concern. 3. The inspection team observed potential SO2 emissions at the Meta Bisulfite Unit with the FLIR GF77 camera, specifically at tank TK-616. The Facility made no claims of confidential business information for photos within this report. The facility was informed that copies of the photos and videos would be made available to the facility following the inspection. We departed the facility at 4:54PM. Section IV - FOLLOW UP The following information was received by EPA on March 4-5, 2024, after exiting the Facility on February 9, 2024: 1. Risk Management Plan program level. 2. TCEQ Air Quality Permit. 3. TCEQ TPDES Permit. 4. TCEQ Stormwater Multi-Sector General Permit. 5 EPA Inspection Report - Page6 of 23 Ineos Calabrian Facility Port Neches Inspection Date 02/08/20214 On March 19, 2024, Justin Chen provided electronic copies of the videos recorded during the inspection to Ryan Quinn. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 10 photos taken 2/08-09/2024 Appendix 2 - Video Log - 9 FLIR videos taken 2/09/2024 Appendix 3 - Closing conference sign-in sheets 6 EPA Inspection Report - Page7 of 23 Ineos Calabrian Facility Port Neches Inspection Date 02/08-09/2024 Appendix 1 Photograph Log EPA Inspection Report - Page8 of 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Ineos Calabrian Facility City: Port Neches Photo No. 1 County/Parish: Jefferson County State: Texas EPA Inspection Report - Page9 of 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Ineos Calabrian Facility City: Port Neches Photo No. 2 County/Parish: Jefferson County State: Texas EPA Inspection Report - Page10 of 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Ineos Calabrian Facility City: Port Neches Photo No. 3 County/Parish: Jefferson County State: Texas EPA Inspection Report - Page11 of 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Ineos Calabrian Facility City: Port Neches Photo No. 4 County/Parish: Jefferson County State: Texas EPA Inspection Report - Page12 of 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Ineos Calabrian Facility City: Port Neches Photo No. 5 County/Parish: Jefferson County State: Texas EPA Inspection Report - Page13 of 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Ineos Calabrian Facility City: Port Neches Photo No. 6 County/Parish: Jefferson County State: Texas EPA Inspection Report - Page14 of 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Ineos Calabrian Facility City: Port Neches Photo No. 7 County/Parish: Jefferson County State: Texas EPA Inspection Report - Page15 of 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Ineos Calabrian Facility City: Port Neches Photo No. 8 County/Parish: Jefferson County State: Texas EPA Inspection Report - Page16 of 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Ineos Calabrian Facility City: Port Neches Photo No. 9 County/Parish: Jefferson County State: Texas EPA Inspection Report - Page17 of 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: Ineos Calabrian Facility City: Port Neches Photo No. 10 County/Parish: Jefferson County State: Texas EPA Inspection Report - Page18 of 23 Ineos Calabrian Facility Port Neches Inspection Date 02/08-09/2024 Appendix 2 Video Log EPA Inspection Report - Page19 of 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 2 Location: Ineos Calabrian Facility Port Neches City: Port Neches Jefferson County State: Texas Video File Name: Date of Video: Time of Video: Videographer: Description: URL: MOV_60255.mp4 02/09/2024 14:58 Philip Myers Visible spectrum video, Metabisulfite unit. https://youtu.be/5C5R1UxSzzs Video File Name: Date of Video: Time of Video: Videographer: Description: URL: MOV_60256.mp4 02/09/2024 14:58 Philip Myers Possible trailing emissions from metabisulfite unit. https://youtu.be/RrMxotEJkSQ Video File Name: Date of Video: Time of Video: Videographer: Description: URL: MOV_60257.mp4 02/09/2024 15:01 Philip Myers Possible trailing emissions from metabisulfite unit. https://youtu.be/7bNK4nbOLkI Video File Name: Date of Video: Time of Video: Videographer: Description: URL: MOV_60258.mp4 02/09/2024 15:07 Philip Myers Possible trailing emissions from metabisulfite unit. https://youtu.be/joJDqa9Ih1c EPA Inspection Report - Page20 of 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 2 Location: Ineos Calabrian Facility Port Neches City: Port Neches Jefferson County State: Texas Video File Name: Date of Video: Time of Video: Videographer: Description: URL: MOV_60259.mp4 02/09/2024 15:52 Philip Myers Venting steam and possible SO2 emissions from tank no. TK-616. https://youtu.be/GMekeX-flws Video File Name: Date of Video: Time of Video: Videographer: Description: URL: MOV_60260.mp4 02/09/2024 15:59 Philip Myers Venting steam and possible SO2 emissions form tank under agitation, adjacent to TK-616. https://youtu.be/LQnatOAJyBI Video File Name: Date of Video: Time of Video: Videographer: Description: URL: MOV_60261.mp4 02/09/2024 16:02 Richard Helmich Venting steam and possible SO2 emissions from tank no. TK-616 (different angle). https://youtu.be/ysVy-F3MYRI Video File Name: Date of Video: Time of Video: Videographer: Description: URL: MOV_60262.mp4 02/09/2024 16:06 Philip Myers Venting steam and possible SO2 emissions from tank no. TK-616 (different angle). https://youtu.be/BT05Xcib4S0 EPA Inspection Report - Page21 of 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 2 Location: Ineos Calabrian Facility Port Neches City: Port Neches Jefferson County State: Texas Video File Name: Date of Video: Time of Video: Videographer: Description: URL: MOV_60263.mp4 02/09/2024 16:10 Richard Helmich Ground level view of metabisulfite unit and possible SO2 emissions. https://youtu.be/bAskCNa1XuA EPA Inspection Report - Page22 of 23 Ineos Calabrian Facility Port Neches Inspection Date 02/08/20214 Appendix 3 Closing Conference Sign-In Sheet EPA Inspection Report - Page23 of 23 Ineos Calabrian Facility Port Neches Inspection Date 02/08/20214