Document jyVQjVGdaze4RgLqag8RDVJGN

EPA Inspection Report - Page 1 of 5 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/13/2024 Air Title V, NESHAP, NSPS, SIP Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Chevron Phillips Chemical Company Port Arthur Plant 2001 S Gulfway Dr Port Arthur, TX 77640 2001 S Gulfway Dr Port Arthur, TX 77640 Jefferson County 1-409-985-0726 Kevin Mercy Environmental Supervisor mercyk@cpchem.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110020148008 Title V Federal Operating Permit O-1235 AFS 48-245-00125; 48-245-00162 325110-Petrochemical Manufacturing; 325199-All Other Basic Organic Chemical Manufacturing 2869-Industrial Organic Chemicals, Not Elsewhere Classified Personnel participating in inspection: Nicholas Bobbs EPA OECA AED Daniel Heins EPA OECA AED Philip Myers EPA NEIC Conor Goulding EPA NEIC Kevin Mercy Chevron Phillips Chemical Company Connie Weber Chevron Phillips Chemical Company Davis Turner Chevron Phillips Chemical Company Jim Dykes Chevron Phillips Chemical Company James Alan Johnson Chevron Phillips Chemical Company Hayden Guidry Chevron Phillips Chemical Company Gary Parsley Chevron Phillips Chemical Company Brian Kubsch Chevron Phillips Chemical Company Lead Air Inspector Air Inspector Environmental Engineer Physical Scientist Environmental Supervisor EHSS Manager Technical Manager Maintenance Manager Aromatics Operator Environmental Specialist Plant Manager Ops Manager EPA Lead Inspector Signature/Date NICHOLAS BOBBS Date: 2024.04.12 08:59:47 -04'00' Digitally signed by NICHOLAS BOBBS Nicholas Bobbs Date Supervisor Signature/Date GREGORY FRIED Date: 2024.04.12 09:09:55 -04'00' Digitally signed by GREGORY FRIED Gregory Fried Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 5 Section I - INTRODUCTION Chevron Phillips Chemical / Port Arthur Plant Inspection Date 02/13/2024 PURPOSE OF THE INSPECTION EPA inspectors Nicholas Bobbs and Daniel Heins (EPA Office of Enforcement & Compliance Assurance Air Enforcement Division), accompanied by Philip Myers and Conor Goulding (EPA National Enforcement Investigations center, "NEIC") arrived at the Chevron Phillips Chemical Company - Port Arthur Plant (the "Facility") at 15:00 on 2/13/2024 for an unannounced inspection. We met Kevin Mercy, Environmental Supervisor, Connie Weber, EHSS Manager, and other facility personnel for an opening conference. Credentials were presented to Mr. Mercy, and we 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 evaluate compliance with the facility's Title V Air Permit and the Clean Air Act. The scope of the inspection is a partial evaluation ("PCE"). This inspection occurred as part of a multi-scale monitoring project in the Beaumont-Port Arthur area. The sign-in sheet for the opening conference is attached as Appendix 1. FACILITY DESCRIPTION The Facility is a petrochemical manufacturing plant that operates under Title V Permit number O-1235 issued August 29, 2018 and revised effective March 2023. The Port Arthur plant manufactures ethylene, propylene, and cyclohexane. The Facility is adjacent to the Valero Port Arthur Refinery and shares some air pollution control devices with Valero. Cyclohexane is mainly used in the industrial production of nylon and is produced by hydrogenation of benzene. Ethylene and propylene are used as building blocks for various polymers and other products. The Facility conducts fenceline monitoring at 18 locations for benzene under an existing Consent Decree (Civil Action No. 4:11-cv-437) with EPA. The monitoring started in June 2023, and has shown elevated concentrations of benzene at locations PAC-5, PAC-6, and PAC-15. Section II - OBSERVATIONS The NEIC GMAP was driven by Mr. Goulding and the instruments were operated by Mr. Myers. A Facility representative, Mr. Mercy, followed the GMAP. Conditions were fair with winds from the SW. Mr. Bobbs and Mr. Heins followed the GMAP in a secondary vehicle, and operated a Data Acquisition in Real Time ("DART") unit on their vehicle, equipped with a photoionization detector ("PID") that measures volatile organic compounds ("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 GMAP 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 at a later date. 2 EPA Inspection Report - Page 3 of 5 Chevron Phillips Chemical / Port Arthur Plant Inspection Date 02/13/2024 The inspection team observed benzene fenceline monitoring location PAC-15, which is near Flare 40. Mr. Mercy informed us that Flare 40 controls the cyclohexane unit and tanks owned by Valero. The Valero tanks were de-inventorying at the time of the inspection, and Flare 40 was active. The inspection team observed the tank farm owned by the Facility, which is separate from the main site and on the east side of Route 87. The tank farm had 5 tanks in use. The inspection team observed monitor locations PAC-5 and PAC-6, which are on the fenceline of the tank farm. See Table 1 for the tank numbers and their contents at the time of the inspection. Table 1 Tank Number Contents 834 Offspec Cyclohexane 816 Cyclohexane 822 Cyclohexane 815 Benzene 800 Benzene Mr. Mercy explained that benzene from tanks 815 or 800 is sent to the hydrogenation unit to produce cyclohexane, which is sent to tanks 822 or 816. At the time of the inspection, Tanks 800 and 816 were active i.e., the facility was drawing benzene off tank 800 and sending cyclohexane to tank 816. Tank 834 was also active, as offspec cyclohexane was being drawn off to send to distillation. The GMAP and DART did not have any significant findings at the time of the inspection. The site GMAP survey ended at 16:45 and we returned to the conference room/parking lot. Section III - AREAS OF CONCERN Mr. Bobbs conducted a closing conference at Chevron Phillips Chemical Company - Port Arthur Plant at 17:00 on February 13, 2024, for the inspection. Mr. Myers and Mr. Bobbs summarized the facility tour and presented their emissions observations. The inspection team had no Areas of Concern at the time of the closing conference. We departed the Facility at 17:15. Section IV - FOLLOW UP No additional information was received by EPA after exiting the Facility on February 13, 2024. Section V - LIST OF APPENDICES Appendix 1 - Opening Conference Sign-in Sheet 3 EPA Inspection Report - Page 4 of 5 Chevron Phillips Chemical / Port Arthur Plant Inspection Date 02/13/2024 Appendix 1 Opening Conference Sign-In Sheet EPA Inspection Report - Page 5 of 5