Document e8qwv8BXE9mMagrdj1Mx67KM

EPA Inspection Report - Page 1 of 6 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 04/13/2022 Air Title V Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Eagle US 2 LLC, a Westlake Chemical Company Lake Charles South - Eagle 1300 PPG Drive Westlake, Louisiana 70669 1300 PPG Drive Westlake, Louisiana 70669 Calcasieu Parish 337-708-4688 Paula McCain Environmental Manager pmccain@westlake.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000494894 AI No. 1255/2040-V9 LA0000002201900004 325181, 325199 2869 Personnel participating in inspection: Nicholas Bobbs EPA/OECA/OCE/AED Richard Helmich EPA/OECA/OCEFT/NEIC Agustin Martinez EPA/OECA/OCEFT/NEIC Ali Gitipour EPA/ORD/CEMM/AMCD Elena Mayard LDEQ/OEC/SD Paula McCain Westlake Chemical Don Johnson Westlake Chemical Inspector Chemist Technician Physical Scientist Inspector Environmental Manager Environmental Specialist EPA Lead Inspector Signature/Date Supervisor Signature/Date NICHOLAS BOBBS Date: 2022.07.08 15:35:19 -04'00' Digitally signed by NICHOLAS BOBBS {Inspector name} Date JAMES LEATHERS Date: 2022.07.08 15:00:59 -05'00' Digitally signed by JAMES LEATHERS {Supervisor name} Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 6 Section I - INTRODUCTION Eagle US 2 LLC / Lake Charles South Inspection Date 04/13/2022 PURPOSE OF THE INSPECTION EPA inspectors Richard Helmich, Agustin Martinez, Ali Gitipour, and I, Nicholas Bobbs, and LDEQ inspector Elena Mayard ("We", "Us") arrived at Eagle US 2 LLC/Lake Charles South (the "Facility", the "Site", or "WLCS") at 8:00 AM on April 13, 2022 for an unannounced Clean Air Act ("CAA") inspection. We met with Paula McCain, Environmental Manager, and Don Johnson, Environmental Specialist. I presented my credentials to Mrs. McCain and informed her that this was an EPA inspection to determine compliance with the facility's Title V Air Permit and the Clean Air Act. The scope of the inspection is a partial compliance evaluation ("PCE") including a survey of the facility using the Geospatial Measurement of Air Pollutants ("GMAP") Vehicle. This inspection occurred as part of the Administrator's Multi-Scale Monitoring Project called the Pollution Accountability Team (PAT). FACILITY DESCRIPTION The Lake Charles South facility is owned and operated by Eagle US 2 LLC, which is wholly owned by parent company Westlake Chemical. The facility is a chemical manufacturing facility which produces chlorine, caustics, chlorinated derivatives, and solvents, along with other chemicals. Section II - OBSERVATIONS The GMAP surveyed the entire facility. The complete GMAP data can be found in the GMAP R6 Pollution Accountability Team FY2022 report for the April 2022 GMAP project. Plant A The GMAP detected elevated VOCs near the halogenated hydrocarbon tank farm. [AOC 1] I recorded FLIR video MOV_0157 of VOC emissions coming from the area of the tank farm. I recorded FLIR video MOV_0158 of VOC emissions coming from the stack of the Plant A Powerhouse. It is unknown if the GMAP detections were due to emissions from the Plant A Powerhouse or a source in the halogenated hydrocarbon tank farm. Plant B The GMAP detected elevated concentrations of VOCs on Ave H, downwind of the "Per Tri" process area. [AOC 2] Plant C The GMAP detected elevated concentrations of methane downwind of the natural gas breakout south of Plant C. I recorded FLIR videos MOV_0153, MOV_0154, MOV_0155 and MOV_0156 at around 4:10 pm. Mr. Helmich recorded FLIR videos MOV_0187 and MOV_0188 at the same time. We observed several leaks using the FLIR GF320 cameras in the natural gas breakout, including leaks from wheel valves, pilot valves, and gages. [AOC 3] We identified the leaking components to the facility personnel. 2 EPA Inspection Report - Page 3 of 6 Section III - AREAS OF CONCERN Eagle US 2 LLC / Lake Charles South Inspection Date 04/13/2022 EPA inspectors Richard Helmich, Agustin Martinez, Ali Gitipour, and I, Nicholas Bobbs, and LDEQ inspector Elena Mayard conducted a closing conference at Eagle US 2 LLC/Lake Charles South at 5:00 PM on April 14, 2022 for the inspection. During the closing conference, I reviewed the 3 Areas of Concern noted during the inspection. AOC 1 - Elevated VOCs downwind of Powerhouse A and halogenated hydrocarbons tank farm The GMAP detected elevated VOCs downwind of Powerhouse A and the halogenated hydrocarbons tank farm. OGI showed a significant VOC plume from the Powerhouse A stack. There may also be a source within the halogenated hydrocarbon tank farm that contributed to the GMAP detection. AOC 2 - Elevated VOCs downwind of Per Tri process area The GMAP detected elevated VOCs downwind of the Per Tri process area. Facility personnel told me that this process area appeared to have some maintenance activities being performed during the inspection. AOC 3 - Elevated methane downwind of Plant C natural gas pipeline breakout The GMAP detected elevated methane downwind of the natural gas pipeline breakout on the south end of Plant C. We observed several leaks with OGI from various valves in the breakout area. We identified the leaking components to the facility personnel and they started taking action to fix the leaking components. Section IV - FOLLOW UP No additional information was received by EPA after exiting the Facility on April 13, 2022. Section V - LIST OF APPENDICES Appendix 1 - Video Log - 8 FLIR videos taken 04/13/2022 3 EPA Inspection Report - Page 4 of 6 Westlake Chemical/ Lake Charles South, Eagle Inspection Date 04/13/2022 Appendix 1 Video Log EPA Inspection Report - Page 5 of 6 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 1 Location: Westlake Chemical South Eagle City: Westlake Calcasieu Parish State: Louisiana File Name: Date taken: Time taken: Videographer: Description: MOV_153.mp4 04/13/2022 4:10 pm Nicolas Bobbs OGI video of emissions from leaking components in Plant C File Name: Date taken: Time taken: Videographer: Description: MOV_154.mp4 04/13/2022 4:10 pm Nicholas Bobbs OGI video of emissions from leaking components in Plant C File Name: Date taken: Time taken: Videographer: Description: MOV_155.mp4 04/13/2022 4:10 pm Nicholas Bobbs OGI video of emissions from leaking components in Plant C File Name: Date taken: Time taken: Videographer: Description: MOV_156.mp4 04/13/2022 4:10 pm Nicholas Bobbs OGI video of emissions from leaking components in Plant C File Name: MOV_157.mp4 Page 1 of 3 EPA Inspection Report - Page 6 of 6 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 1 Location: Westlake Chemical South Eagle City: Westlake Calcasieu Parish State: Louisiana Date taken: Time taken: Videographer: Description: 04/13/2022 9:00 am Nicolas Bobbs OGI video of emissions from area of the tank farm File Name: Date taken: Time taken: Videographer: Description: MOV_158.mp4 04/13/2022 9:30 am Nicholas Bobbs OGI video of emissions from the stack of power house A File Name: Date taken: Time taken: Videographer: Description: MOV_187.mp4 04/13/2022 4:10 pm Nicholas Bobbs OGI video of emissions from leaking components in Plant C File Name: Date taken: Time taken: Videographer: Description: MOV_188.mp4 04/13/2022 4:10 pm Nicholas Bobbs OGI video of emissions from leaking components in Plant C Page 2 of 2