Document wqvR2xwLodZg2bVNaGvkpqv73

EPA Inspection Report - Page 1 of 5 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/05/2024 Air Title V, NESHAP Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: BASF Corporation BASF Beaumont Agro Plant Latitude 29 58' 17'' Longitude 94 3' 12'' Beaumont, TX 77705 14385 W Port Arthur Rd Beaumont, TX 77705 Jefferson County 409-981-5050 Caitlin Wilding Environmental Health & Safety Manager Cailtlin.wilding@basf.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000464239 RN100634922, CN600124895 48-245-00008 325199 2879 Personnel participating in inspection: Justin Chen EPA Region 6 ECDAT Benjamin Donaldson EPA Region 6 ECDAT Kenneth McPherson EPA Region 6 ECDAT Sarah Frey EPA Region 6 ECDAT Colleen McCarthy EPA Region 6 ECDAT Daniel Hoyt EPA OECA AED Nathaniel Hicks EPA OECA AED Richard Helmich EPA NEIC Philip Myers EPA NEIC Caitlin Wilder BASF Alexis Fischer BASF Environmental Engineer Environmental Engineer Life Scientist Physical Scientist Life Scientist Environmental Engineer Physical Scientist Chemist Mechanical Engineer Environmental Health & Safety Manager Compliance Analyst EPA Lead Inspector Signature/Date NATHANIEL HICKS Date: 2024.04.03 16:24:12 -06'00' Digitally signed by NATHANIEL HICKS Nathaniel Hicks Date Supervisor Signature/Date GREGORY FRIED Date: 2024.04.04 14:15:32 -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 BASF Corporation / BASF Beaumont Agro Plant Inspection Date 02/05/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA inspectors Daniel Hoyt (Headquarters), Nathan Hicks (Headquarters), Justin Chen (Region 6), Benjamin Donaldson (Region 6), and Kenneth McPherson (Region 6) accompanied by Philip Myers and Richard Helmich (National Enforcement Investigations Center, "NEIC") arrived at the BASF Corporation's BASF Beaumont Agro Plant ("Facility") at 1315 on February 5, 2024, for an unannounced inspection. We met with Caitlin Wilder/EHS Manager and Alexis Fischer/Compliance Analyst. Credentials were presented to Ms. Wilder 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 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. Photographs taken during the inspection can be found in Appendix 1. FACILITY DESCRIPTION The Facility is a pesticide active ingredients manufacturing facility. The plant includes the Dicamba Unit, the dimethenamid ("DMTA") Unit, Multi-Purpose Plant ("MPP"), a hazardous waste incinerator, a wastewater treatment area, and a pilot plant which operates periodically during the year. The MPP and hazardous waste incinerator have not operated since 2003. The Facility operates under New Source Review ("NSR") Permit 20057 amended March 9, 2023 and NSR Permit 978B revised March 22, 2022. Federal Operating Permit O-3955, issued June 26, 2019, is listed as "VOID" in Texas Commission on Environmental Quality Central Registry. Section II - OBSERVATIONS The NEIC GMAP was driven by Philip Myers and Richard Helmich and the instruments were operated by Mr. Myers. A BASF Security Officer was present and accompanied the GMAP during its survey. Conditions were sunny and windy, with the wind blowing primarily in the southwest direction. The EPA Inspectors followed the GMAP in a secondary vehicle. 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. Nathaniel Hicks and Daniel Hoyt 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 site GMAP survey ended at 1515 and we returned to the conference room. No significant levels of ambient air pollution were detected. 2 EPA Inspection Report - Page 3 of 5 BASF Corporation / BASF Beaumont Agro Plant Inspection Date 02/05/2024 Region 6 Follow-up Inspection At 1600 on February 12, 2024, EPA Region 6 inspectors Sarah Frey, Colleen McCarthy, and Ken McPherson conducted a follow-up inspection. We met with Caitlin Wilder, presented credentials, and informed her that we wished to inspect Tank WB-501. On November 8, 2023, EPA conducted an infrared aerial survey which detected hydrocarbons emitting from the Facility's Wastewater Storage Tank WB-501. The facility was notified of the observation on December 1, 2023. On December 15, 2023, the Facility provided information of actions taken at Tank WB-501, including ultrasonic ear and Leak Detection and Repair monitoring. The Facility stated that no unauthorized emissions were detected on December 4 and 5, 2023. We entered the field at 1620 and acquired a Safe Work Permit. We were accompanied by Ms. Wilder and two Facility employees. Using an optical gas imaging camera, we observed Tank WB-501 to be full. The Facility stated that the tank has no active pumping and is currently isolated. The Facility is in the process of constructing a thermal oxidizer, which will control vapors from the wastewater tanks. Currently, the vapors are routed to a scrubber. Ms. McCarthy and Mr. McPherson climbed Tank WB-501 with Ms. Wilder. EPA's photoionization detector measured VOCs up to 10 parts per million. Inspectors observed piping and components that had recently been repaired. They also observed visual defects and gaps at flange gaskets along feed lines to the tank (see Photo 1 in Appendix 1.) No hydrocarbons were detected using the optical gas imaging camera. The inspection team departed the facility at 1730. Section III - AREAS OF CONCERN EPA conducted a closing conference at BASF Corporation Beaumont Agro Plant at 1518 on February 5, 2024, for the initial inspection. Mr. Meyers and Mr. Hoyt summarized the facility tour and presented their emissions observations to Facility representatives Caitlin Wilder and Alexis Fischer. We observed no areas of concern at the time of inspection. The Facility made no claims of confidential business information ("CBI"). We departed the Facility at 1530. EPA conducted a closing conference at BASF Agro Plant at 1720 on February 12, 2024, for the follow-up inspection. Ms. McCarthy presented observations to Ms. Wilder. We observed no areas of concern at the time of inspection. One photo was taken, and no claims of CBI were made. Section IV - FOLLOW UP No additional information was received by EPA after exiting the Facility on February 12, 2024. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 1 photos taken 2/12/2024 3 EPA Inspection Report - Page 4 of 5 BASF Corporation / BASF Beaumont Agro Plant Inspection Date 02/05/2024 Appendix 1 Photograph Log EPA Inspection Report - Page 5 of 5 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: BASF Beaumont Agro Plant City: Beaumont County: Jefferson State: TX Photo File Name: DC_0376.jpg Date of Photo: 02/12/2024 Time of Photo: 1705 Photographer: Colleen McCarthy Description: Tank WB-501 feed lines observed with visual defects and gaps at flange gaskets.