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EPA Inspection Report - Page 1 of 7 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/15/2024 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 Orange Plant 5309 Farm to Market Road 1006 Orange, Texas 77630 5309 Farm to Market Road 1006 Orange, Texas 77630 Orange County 1-409-985-0726 Kevin Mercy Environmental Supervisor mercyk@cpchem.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110034635367 Title V Federal Operating Permit: O-1310 AFS 48-361-00014 325111-Plastics Material and Resin Manufacturing; 325199-All Other Basic Organic Chemical Manufacturing 2821-Plastics Materials and Resins 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 Gina James Chevron Phillips Chemical Company Carrie Phillips Chevron Phillips Chemical Company Kent Marze Chevron Phillips Chemical Company Lead Air Inspector Air Inspector Environmental Engineer Physical Scientist Environmental Supervisor EHSS Manager Technical Manager Environmental Specialist Plant Manager Ops Supervisor EPA Lead Inspector Signature/Date Supervisor Signature/Date NICHOLAS BOBBS Date: 2024.04.12 08:58:46 -04'00' Digitally signed by NICHOLAS BOBBS Nicholas Bobbs GREGORY FRIED Date: 2024.04.12 09:32:43 -04'00' Digitally signed by GREGORY FRIED Gregory Fried Date Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 7 Section I - INTRODUCTION Chevron Phillips Chemical / Orange Plant Inspection Date 02/15/2024 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 - Orange Plant (the "Facility") at 12:00 on 2/15/2024 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. A video taken during the inspection can be found in Appendix 1. The sign-in sheet for the opening conference is attached as Appendix 2. FACILITY DESCRIPTION The Facility is a polymer manufacturing plant that operates under Title V Permit number O-1310 issued March 17, 2021. The Facility manufactures high-density polyethylene ("HDPE"), a thermoplastic polymer with high strength-to-density used in durable consumer products like kayaks and toys. The Facility produces different varieties of HDPE in two separate reactor units: A gas phase reactor unit ("GPO") and a particle form C loop reactor ("CPF"). The main feed into the reactors is ethylene. Additives to the process include isobutane, hexene, and isopentane. Propane is also used as a refrigerant. The site also has several bullet storage tanks, and a wastewater treatment plant for physical removal of plastic pellets using dissolved air flotation ("DAF"). Section II - OBSERVATIONS The NEIC GMAP was driven by Mr. Goulding and the instruments were operated by Mr. Myers. Facility representatives, including Mr. Mercy and Mr. Marze, accompanied the GMAP. Conditions were fair with winds from the southwest. 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. The GMAP detected elevated VOCs downwind of the CPF unit, at the corner of the facility's "14th St." and "S Ave". Mr. Marze explained that in the CPF unit ethylene, catalyst, and isobutane are mixed into a slurry going into the reactor to make HDPE. The GMAP was downwind of two blower outlets for system 41A and 41B. Mr. Heins used a handheld "ppbRae 3000" PID to monitor the blower outlet of System 2 EPA Inspection Report - Page 3 of 7 Chevron Phillips Chemical / Orange Plant Inspection Date 02/15/2024 41A, and detected up to 1,960 ppb total VOCs at 2 inches from the outlet. Mr. Bobbs recorded FLIR video FLIR0025.mp4 of the blower outlet from system 41A, which was connected to F-803 System 41A (see Appendix 1). The GMAP took a summa cannister No. 117 for TO-15 analysis downwind of the system 41A blower. Mr. Mercy took a duplicate summa cannister for the facility. [AOC 1] I asked Mr. Mercy if there were any HAP emissions permitted for the system 41A blower outlet. Mr. Mercy said that the blower is permitted for some hexene emissions and added that the Facility is an area source for HAP. The site GMAP survey ended at 14:00 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 - Orange Plant at 14:10 on February 15, 2024 for the inspection. Mr. Myers and Mr. Bobbs summarized the facility tour and presented their emissions observations, including the following Area of Concern. The facility made no claims of confidential business information regarding the video taken. The facility was informed that a copy of the video would be made available to the facility following the inspection. We departed the facility at 14:30. 1) VOC Detection Downwind of CPF Unit System 41A Blower As documented in the report, the GMAP detected elevated VOCs and took a summa cannister downwind of the CPF Unit System 41A Blower. The summa cannister results are not available at the time of this inspection report, but will be evaluated when they are included in the full report from the GMAP to be issued by NEIC at a later date. Section IV - FOLLOW UP No additional information was received by EPA after exiting the Facility on February 15, 2024. Section V - LIST OF APPENDICES Appendix 1 - Video Log - 1 FLIR video taken 2/15/2024 Appendix 2 - Opening Conference Sign-in Sheet 3 EPA Inspection Report - Page 4 of 7 Chevron Phillips Chemical / Orange Plant Inspection Date 02/15/2024 Appendix 1 Video Log EPA Inspection Report - Page 5 of 7 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 1 Location: Chevron Phillips Chemical Company - Orange Plant City: Orange Orange County State: Texas File Name: Date taken: Time taken: Videographer: Description: FLIR0025.mp4 02/15/2024 13:51 Nicholas Bobbs OGI video of emissions from System 41A blower outlet of CPF HDPE unit Page 1 of 1 EPA Inspection Report - Page 6 of 7 Chevron Phillips Orange Plant Inspection Date 02/15/2024 Appendix 2 Opening Conference Sign-In Sheet EPA Inspection Report - Page 7 of 7