Document p70rY2ryMo7NrKx278aZ3OGB
St. James Holding, LLC Koch Methanol St. James, LLC Inspection Date: 11/29/2022 - 11/30/2022
Region 6 Enforcement and Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Contact:
11/29/2022 - 11/30/2022
Air
Clean Air Act (CAA) 112(r) and 40 Code of Federal Regulations (C.F.R.)
Part 68 Chemical Accident Risk Management Plan (RMP) Program 1
St. James Holding, LLC
()
Koch Methanol St. James, LLC
6586 Highway 3127
St. James, Louisiana 70086
P.O. Box 510
Vacherie, Louisiana 70090
St. James
Marc Hoss
VP of Manufacturing & Plant Manager
Marc.Hoss@kochind.com
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS:
110070870131 2560-00295-V4 RMP 1000 0024 5585 325199 - All Other Basic Organic Chemical Manufacturing
Personnel participating in inspection:
Tony Robledo
U.S. EPA
Howard Cole
U.S. EPA
Marc Hoss
Koch Methanol
Haleigh Engler
Koch Methanol
Josh Wiggins
Koch Methanol
Whitney Mantooth
Koch Methanol
Kevan Reardon
Koch Methanol
Inspector/Enforcement Officer Inspector VP of Manufacturing & Plant Manager Environmental Engineer Technical Manager Health and Safety Manager Environmental Health Safety & Security
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: 2022.12.14 16:44:44 -06'00'
Tony Robledo
Supervisor Signature/Date
SAMUEL TATES Date: 2022.12.15 09:25:51 -06'00' Digitally signed by SAMUEL TATES
Samuel Tates
6ENFORM-19-R8.2 (02/12/2020) 1
St. James Holding, LLC Koch Methanol St. James, LLC Inspection Date: 11/29/2022 - 11/30/2022
Section I - INTRODUCTION PURPOSE OF THE INSPECTON
We, the Environmental Protection Agency (EPA) Region 6 inspectors Tony Robledo and Howard Cole, arrived at the St. James Holding, LLC facility at approximately 9:00 a.m. on November 29, 2022, for an announced inspection. We met with facility representatives noted above at the opening meeting. We presented our credentials 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.
FACILITY DESCRIPTION
The Koch Methanol (Koch) Plant was designed to produce approximately 5,000 metric tons per day of refined methanol. Methanol is produced using the licensed Air Liquide Lurgi MegaMethanol technology. The methanol production process consists of three main steps: synthesis gas (syngas) production, crude methanol synthesis, and methanol distillation. The facility handles one regulated flammable chemical (methane) above the RMP threshold quantity. The Koch Plant began operations in June 2021. There are 110 full-time employees at this non-union represented facility. The Plant operates 24 hours a day, 7 days a week.
Section II - OBSERVATIONS
We conducted a walk-through of the facility, accompanied by facility representatives to observe the facility process equipment, and overall operations. We observed no spills, leaks, or fugitive hydrocarbon emission trails with the Forward Looking Infrared (FLIRTM) Series GF77 camera. Additional observations and findings are found on the RMP Program Level 1 Checklist, located in Appendix #1.
Section III - AREAS OF CONCERN
Close-out Meeting - We convened a closing meeting on Wednesday, November 30, 2022. We informed onsite personnel that a written report would be completed pending the review of additional information requested.
AOC 1. Clean Air Act (CAA) 112(r)(1) - The General Duty Clause
The owners and operators of stationary sources producing, processing, handling, or storing such substances [i.e., a chemical in 40 CFR part 68 or any other extremely hazardous substance] have a general duty [in the same manner and to the same extent as the general duty clause in the Occupational Safety and Health Act (OSHA)] to identify hazards which may result from (such) releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking such steps as are necessary to prevent releases, and to minimize the consequences of accidental releases which do occur.
Koch failed to design and maintain a safe facility taking such steps as are necessary to prevent releases. Koch reported to the National Response Center (NRC) 19 separate start-up/upset accidental release events from June 21, 2021, to November 27, 2021, resulting in a total of 4,118 lbs. of ammonia released to the atmosphere (See NRC Incident Chart).
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NRC Incident Chart
St. James Holding, LLC Koch Methanol St. James, LLC Inspection Date: 11/29/2022 - 11/30/2022
Incident Date 21 Jun 2021 23 Jun 2021 24 Jun 2021 25 Jun 2021 26 Jun 2021 27 Jun 2021 13 Jul 2021 14 Jul 2021 30 Jul 2021 31 Jul 2021 06 Aug 2021 26 Aug 2021 09 Sep 2021 13 Sep 2021 17 Sep 2021 06 Oct 2021 03 Nov 2021 07 Nov 2021 27 Nov 2021 Total
Chemical Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia
Amount (lbs.) 108 126 184 162 462 293 542 394 209 135 417 118 119 132 202 114 109 133 159 4,118
The Koch Plant does not appear to meet the RMP threshold quantity for anhydrous ammonia at 10,000 pounds, or for ammonia at a concentration of 20 percent or greater at 20,000 pounds. Koch provided documentation that it receives aqua ammonia from delivery at 19 percent concentration. However, EPA has determined that the ammonia handled at the Koch Plant is considered an extremely hazardous substance.
Koch noted that it took the necessary steps to prevent future releases and minimize the consequences of the start-up/upset releases of ammonia, including procedural changes and permit modifications, which were completed in 2022. The specific procedural changes included updates to the start-up procedure Unit 100 Combined Reforming Initial Start-up (ISP STJ2 02 100 005 Rev. 2.0), and to Standard Operating Conditions and Limits (SOCL STJ2 02 100 001).
Koch submitted its permit modification to the Louisiana Department of Environmental Quality (LDEQ) on June 29, 2022. The permit modification was subsequently approved by the LDEQ on August 12, 2022. LDEQ has delegated authority from EPA to review and issue permit modifications to regulated entities under the CAA.
Section IV - FOLLOW UP
No follow up occurred or was necessary after the inspection.
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St. James Holding, LLC Koch Methanol St. James, LLC Inspection Date: 11/29/2022 - 11/30/2022 Section V - LIST OF APPENDICES Appendix #1 - RMP Program 1 Checklist Inspection Symbol Key: Y - Yes, N - No, N/A - Not Applicable; S - Satisfactory, M - Marginal, U - Unsatisfactory.
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