Document ybp7MJErokXo5k32Qg2DGM9zE

EPA Inspection Report - Page 1 of 16 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/14/2024 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: Indorama Ventures Oxides LLC Port Neches Facility 2701 Spur 136 Port Neches, TX 77651 2701 Spur 136 Port Neches, TX 77651 Jefferson County 409-722-8381 Rachel Lavergne Environmental Manager rachel.lavergne@us.indorama.net 409-724-4468 FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000599567 Title V Federal Operating Permits: O1230, O2286, O2287, O2288, and O3056 AFS 48-245-00006 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 Kenneth McPherson EPA Region 6 ECDAT Kimberly Hoyt Indorama Micah Mosley Indorama Jack Tindel Indorama David Avanzato Indorama James Kalathra Indorama Allie Sarles Indorama Rachel Lavergne Indorama Troy Allen Indorama Kelly Hargraves Indorama Ronnie Mudd Indorama Lead Air Inspector Air Inspector Environmental Engineer Physical Scientist Air Inspector Site Director Manufacturing Executive Manager Sr. Ops Manager O&O Sr Mgr PO/MTBE/Utilities Engineer Environmental Specialist Environmental Manager Environmental Team Lead LDAR Specialist Utility Engineer Water & Wastewater EPA Lead Inspector Signature/Date NICHOLAS BOBBS Nicholas Bobbs Digitally signed by NICHOLAS BOBBS Date: 2024.04.15 10:34:14 -04'00' Date Supervisor Signature/Date Digitally signed by GREGORY GREGORY FRIED FRIED Date: 2024.04.15 10:56:04 -04'00' Greg Fried Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 16 Indorama Ventures / Port Neches Facility Inspection Date 02/14/2024 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA inspectors Nicholas Bobbs and Daniel Heins (EPA Office of Enforcement & Compliance Assurance Air Enforcement Division) and Kenneth McPherson (EPA Region 6), accompanied by Philip Myers and Conor Goulding (National Enforcement Investigations Center, "NEIC") arrived at the Indorama Ventures Oxides LLC - Port Neches Facility (the "Facility") at 8:30 on February 14, 2024 for an unannounced inspection. We met Kimberly Hoyt, Site Director, Rachel Lavergne, Environmental Manager, and other facility personnel. Credentials were presented to Ms. Lavergne 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. Videos taken during the inspection can be found in Appendix 1. The sign-in sheet for the opening conference is attached as Appendix 2. Chain of Custody ("COC") forms for summa cannisters collected during the inspection can be found in Appendix 3. FACILITY DESCRIPTION The Facility is a petrochemical and industrial organic chemical manufacturing facility that operates under five separate Title V Federal Operating Permits. Permit O1320 covers the F and G Units and was issued November 22, 2019, revised effective April 2020. Permit O2286 covers the E3/E6 Units and was issued July 10, 2018, revised effective April 2020. Permit O2287 covers the E4 Unit. Permit O2288 covers the A3 Unit/Receiving & Shipping Area, and Utilities Area, including the Joint Wastewater Treatment Plant, and was issued January 26, 2016, revised effective April 2020. Permit O3056 covers the Propylene Oxide ("PO") and Methyl tert-butyl ether ("MTBE") Units and was issued September 6, 2019, revised effective April 2020. The facility's key products are amines, ethanolamines, ethylene, ethylene glycols, ethylene oxide, MTBE, propylene, propylene glycol, propylene oxide, and surfactants. The main site is divided into the PO/MTBE Plant and the Oxides & Olefins ("O&O") Plant. The site has approximately 600 employees and covers 3,000 acres. The site was formerly owned by Huntsman Petrochemical LLC and was transferred to Indorama Ventures Oxides LLC in 2020. Section II - OBSERVATIONS The NEIC GMAP was driven by Mr. Goulding and the instruments were operated by Mr. Myers. Facility representatives, including Ms. Lavergne and Mr. Allen, accompanied the GMAP. Conditions were fair with winds from the E to S. Mr. Bobbs, Mr. Heins, and Mr. McPherson followed the GMAP in a secondary vehicle, and operated a Data Acquisition in Real Time ("DART") unit on their vehicle, 2 EPA Inspection Report - Page 3 of 16 Indorama Ventures / Port Neches Facility Inspection Date 02/14/2024 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. Joint Wastewater Treatment Plant At 9:35, the GMAP and inspection team entered the Joint Wastewater Treatment Plant ("WWTP") on the west side of TX-136, across from the main plant. The inspectors met with Mr. Ronnie Mudd, Utility Engineer for Waste & Wastewater. Mr. Mudd and Ms. Lavergne explained that the joint WWTP is operated by Indorama, but also receives wastewater from the neighboring "TPC" and "Lion Elastomers" facilities. Both of those facilities are to the north of the Joint WWTP. Mr. Mudd said that TPC and Lion don't do any wastewater monitoring or sampling before transferring wastewater to the Joint WWTP. Mr. Mudd informed us that Indorama operates composite samplers that collect a sample over 24 hrs which is sent to a laboratory for analysis. These composite samplers are placed on the TPC/Lion Elastomer stream, as well as the O&O and PO streams. The samples are tested for Total Organic Carbon ("TOC"), Biological Oxygen Demand ("BOD"), Chemical Oxygen Demand ("COD"), Total Suspended Solids ("TSS"), pH, ammonia, and other factors. Mr. Mudd said the facility has also performed "Flux" sampling on wastewater streams in the past. The joint WWTP is covered under Title V permit O2288 and New Source Review ("NSR") permit 49247. The GMAP detected ethylene oxide ("EtO") west (downwind) of the B-1 Equalization Basin. On the west side of the B-1 Equalization Basin there is an open conveyance where wastewater flows to a pump. The wastewater is pumped from there to a "distribution box" where the wastewater is distributed to two aeration basins. The aeration basins are elevated above ground level. The GMAP drove on top of the Aeration Basins, first on the south side then on the north side. On the north side of the aeration basin near the distribution box, the GMAP detected a high concentration of EtO. [AOC 1] I collected a summa cannister (#11612) near the distribution box. I observed through grating that the wastewater was visibly aerated at the distribution box, having just been pumped to the top of the aeration basin. I also observed elevated VOC readings above the distribution box using a handheld ppbRae 3000 PID. The B-1 equalization basin is divided into a north and south side, and the north side was being used during the inspection. Mr. Mudd informed us that they were currently dredging (i.e. removing solids from) the B-1 north equalization basin. Due to the dredging operations, they could not activate the oxygen injectors for the B-1 north equalization basin. 3 EPA Inspection Report - Page 4 of 16 F4, F6, and F8 EtO Units and Wastewater Conveyance Indorama Ventures / Port Neches Facility Inspection Date 02/14/2024 I asked Ms. Lavergne about any EtO limits for the Joint WWTP or the streams leading into the WWTP. Ms. Lavergne told me that the F4, F6, and F8 units (under Title V permit O1230) are EtO production units that have open wastewater conveyances to the Joint WWTP. Unit F4 is covered by NSR permit 5972A and includes a special condition ("SC") 10 which has a limit of 1719 ppm for VOCs and 473 ppm for EtO in the wastewater. Unit F6 is covered under NSR permit 5952A and includes a SC 10 with a limit of 2,125 ppm for VOCs, 11,000 ppm for glycol, and 5 ppm for EtO in the wastewater. Unit F8 is covered under NSR permit 106169 and does not have a limit for EtO in the wastewater. Ms. Lavergne told me that the wastewater from F4 unit goes straight from the unit to the open conveyance. The wastewater from F6 unit goes to a pond ("PV9") across from the F6 unit, and from there to the wastewater conveyance. The pond has a level gauge to determine when to pump over to the conveyance. The wastewater from the F8 unit goes to a sump, which is pumped to the wastewater conveyance. Ms. Lavergne also mentioned that all the EtO and Glycol units are part of "Area B" of the plant. I asked Ms. Lavergne about controls for the F4, F6, F8 units and other EtO emissions sources. Ms. Lavergne told me that F4 and F6 are controlled by incinerators, and that F8 is controlled by a boiler. Also, the Receiving and Shipping ("R&S") area has an EtO scrubber for controlling the EtO storage spheres, and if the scrubber is out, there are three plant flares as backup. Main Plant The GMAP and inspection team entered the main plant around 12:00. The main plant is divided into two sub plants; the PO/MTBE on the SW side and the O&O plant on the NE side. We surveyed the PO/MTBE plant first. We surveyed the spheres containing process liquid fuel, which Ms. Lavergne told me is a hazardous waste that the facility burns in boilers. We also surveyed the ground flare for the PO unit. I used the FLIR G-320 camera to observe VOC emissions from two PO product spherical tanks: "F-F5164" and "F-F5-165". [AOC 4] I recorded video FLIR0018.mp4 of a VOC plume from a pressure relief vent ("PRV") on top of the tank. Mr. Allen informed me that the two PO product tanks are pressurized and contain a blanket of steam or "snuff gas", which should not be emitting from the PRV during normal operations. Mr. Allen later informed me that the PO product tanks have rupture disks between the tank and the PRVs. He told us that a facility leak detection and repair ("LDAR") technician went on top of the tank after we observed the VOC plume. The LDAR technician detected VOC readings up to 548 ppm from tank "F-F5-164" and 4,324 ppm from tank "F-F5-165". 4 EPA Inspection Report - Page 5 of 16 Indorama Ventures / Port Neches Facility Inspection Date 02/14/2024 I used the FLIR camera to observe VOC emissions from the iso-octane tank "T-F5-009". [AOC 5] I recorded video FLIR0019.mp4 of VOC emissions from an orange vent hood on top of the tank. Mr. Allen told me that the tank is an internal floating roof tank, and that the vent hood is open to atmosphere. Mr. Allen later informed me that iso-octane was being loaded into tanks"T-F5-009" from a truck at the time and therefore the floating roof was rising and pushing out the headspace of the tank. The inspection team observed VOC emissions with FLIR cameras from tank "T-O-87", a "pyronaptha" tank. [AOC 6] Mr. Meyers recorded FLIR video MOV-0128.mp4 of VOC emissions from a PRV on top of tank T-O-87. Mr. Meyers also took a digital picture DC0127 of the PRV. (See NEIC GMAP report for photos/videos recorded by Mr. Meyers) I recorded FLIR video FLIR0020.mp4 of VOC emissions from a second PRV on the south side of the tank. The GMAP also detected benzene and VOC concentrations downwind of the tank. Mr. Allen told me that the tank is an internal floating roof tank with a closed vent system to the A3 unit flares, specifically the north and center, and that the PRVs should not be emitting during normal operations. The facility informed me that pyronaptha, a type of aromatic distillate, is a byproduct of the A3 Ethylene Unit. Mr. Heins observed VOC emissions using the FLIR camera from the top of tank "TO-30", a spherical EtO storage tank. [AOC 3] Mr. Heins recorded FLIR videos FLIR0021.mp4 and FLIR0022.mp4 of a VOC plume from three stacks on top of the tank. The VOC plume was continuous and visible in auto mode from all three stacks, with the stack on the NE side having the heaviest emissions. Mr. Heins observed VOC emissions from tank "T-E3-368". [AOC 7] Mr. Heins recorded FLIR video FLIR0023.mp4 of emissions from an orange vent on top of the tank. Mr. Allen told me that the tank contains "surfactant composite dry product" and is a fixed roof tank. Mr. Allen said that the tank is not controlled, and that the orange vent is an atmospheric vent. Main Plant - E, F G Units and EtO Detections The inspection team observed the F-8 EtO unit. Ms. Lavergne told me that F-8 is the newest EtO unit which was brought online in 2015 or 2016. She also mentioned that the F-8 unit is controlled by a boiler, and that all of the process vents are Group 1 except the regenerator vent, which is Group 2 under the Hazardous Organic NESHAPS. ("HON") The inspection team observed the F-6 EtO unit. Ms. Lavergne said that F-6 is controlled by an incinerator, and also has a Group 2 regenerator vent which is the only vent in the unit permitted to emit to atmosphere. The inspection team observed the G glycol units. Ms. Lavergne said that the G-2 unit makes propylene glycol, and that the rest of the G-units make ethylene glycol. She also said that the G-4 unit is air-gapped and not in use. 5 EPA Inspection Report - Page 6 of 16 Indorama Ventures / Port Neches Facility Inspection Date 02/14/2024 The inspection team surveyed the E units. Ms. Lavergne told me that the E units are surfactant manufacturing units: The E-2 unit has been out of service for a while. The E-3 unit is out of service, though some E-3 unit tanks are used for E-6 unit operations. The E-4 unit is an ethanolamine unit. The E7 unit is a morphaline unit, which is still owned by Huntsman. Mr. Allen said that the E-6 unit is a batch surfactant manufacturing unit. The unit has several kettles for batch reaction, of which three were active at the time of the inspection. The GMAP detected elevated EO concentrations on "5 street", west of the E-3 Unit, near the intersection of "5 " and "B" streets. The inspection team surveyed the tanks of the E-3 unit, as well as the truck loading rack near the intersection, and did not identify an emission source. The GMAP also drove downwind of the EtO loading racks of the R&S area to the NE of the E-3 unit and did not detect EO downwind of the loading racks at the time. The E-6 unit is near the E-3 unit, on the east side of "5 " street. Mr. Allen told me that EtO is introduced into the kettles of the E-6 unit as part of the batch surfactant manufacturing process. The inspection team surveyed the E-6 unit kettles using the FLIR camera and handheld PIDs and did not identify an emission source. The GMAP also detected EtO along "B" street between "4th" and "5 " streets. "B" street runs from the east to the west in the middle of the plant. I observed an open wastewater conveyance trench along the south side of "B" street, upwind of where the GMAP was detecting EtO. The F-4 EtO unit, which distributes wastewater to the open conveyance, is on the south side of "B" street to the east (upstream) of the GMAP's location at the time. Refer to the GMAP report for EtO concentrations and wind directions. Due to the proximity of this area to the E-3 unit, it's possible that the GMAP EtO detections on "5 1/2" street and "B" street were due to the wastewater conveyance trench on "B" street. [AOC 2] The site GMAP survey ended at approximately 18:15 and we returned to the conference room. Section III - AREAS OF CONCERN Mr. Bobbs conducted a closing conference at Indorama Ventures - Port Neches Facility at 18:30 on February 14, 2024 for the inspection. Mr. Bobbs summarized the facility tour and presented their emissions observations, including the following Areas of Concern. The facility made no claims of confidential business information regarding the videos recorded. The facility was informed that copies of the videos would be made available to the facility following the inspection. We departed the facility at 19:00. 6 EPA Inspection Report - Page 7 of 16 Indorama Ventures / Port Neches Facility Inspection Date 02/14/2024 1) EtO emissions from the joint wastewater treatment plant The GMAP detected EtO concentrations outside and inside the fenceline of the facility's joint Wastewater Treatment Plant. The concentrations detected by the distribution box and other sources in the joint WWTP indicate EtO emissions from the wastewater of the facility. 2) EtO emissions from wastewater conveyances The GMAP detected EtO concentrations inside the facility main plant near the open wastewater conveyance trench along Avenue "B" of the facility. These detections, in combination with the EtO detections at the joint WWTP, point to EtO air emissions from the wastewater. 3) VOC emissions observed from EtO storage tank We observed VOC emissions with the FLIR camera from the top of EtO spherical tank TO-30. This could indicate a leak or an issue with the pressure relief valves on the EtO tank. 4) VOC emissions observed from PO product tanks We observed VOC emissions with the FLIR camera from spherical propylene oxide tanks "F-F5-164" and "F-F5-165". The VOC detections from the facility's LDAR technician were above the leak detection threshold of 500 ppm which indicates a leak in the rupture disks that needs to be repaired. They also may indicate an issue with the pressure relief valve or the steam blanket pressure settings. 5) VOC emissions observed from iso-octane tank We observed VOC emissions with the FLIR camera from the internal floating roof iso-octane tank "T-F5009". The VOC plume could indicate an issue with the floating roof seal. 6) VOC emissions observed from pyronaptha tank We observed VOC emissions with the FLIR camera from the pyronaptha closed vent internal floating roof tank "T-O-87". The GMAP also detected benzene and VOCs downwind of the tank, which indicates a leak from the closed vent system of benzene and other VOCs. 7) VOC emissions observed from the surfactant composite dry product tank We observed VOC emissions with the FLIR camera from the fixed roof surfactant composite dry product tank "T-E3-368". Section IV - FOLLOW UP No additional information was received by EPA after exiting the Facility on February 14, 2024. 7 EPA Inspection Report - Page 8 of 16 Section V - LIST OF APPENDICES Indorama Ventures / Port Neches Facility Inspection Date 02/14/2024 Appendix 1 - Video Log - 6 FLIR videos taken 2/14/2024 Appendix 2 - Opening conference sign-in sheets Appendix 3 - Chain of Custody forms for summa cannisters collected 8 EPA Inspection Report - Page 9 of 16 Indorama Port Neches Plant Inspection Date 02/14/2024 Appendix 1 Video Log EPA Inspection Report - Page 10 of 16 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Location: Indorama Ventures - Port Neches Plant City: Port Neches County: Jefferson State: Texas Appendix 1 File Name: Date taken: Time taken: Videographer: Description: FLIR0018.mp4 02/14/2024 12:48 Nicholas Bobbs OGI video of VOC emissions from PRVs on two PO product spherical tanks: "F-F5-164" and "F-F5-165". File Name: Date taken: Time taken: Videographer: Description: FLIR0019.mp4 02/14/2024 12:59 Nicholas Bobbs OGI video of VOC emissions from the iso-octane tank "T-F5-009" File Name: Date taken: Time taken: Videographer: Description: FLIR0020.mp4 02/14/2024 14:11 Nicholas Bobbs OGI video of VOC emissions from pyronaptha tank "T-O-87" File Name: Date taken: Time taken: Videographer: Description: FLIR0021.mp4 02/14/2024 17:52 Dan Heins OGI video of VOC emissions from three small stacks on top of tank "TO-30", a spherical EtO tank. Page 1 of 2 EPA Inspection Report - Page 11 of 16 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Location: Indorama Ventures - Port Neches Plant City: Port Neches County: Jefferson State: Texas Appendix 1 File Name: Date taken: Time taken: Videographer: Description: FLIR0022.mp4 02/14/2024 17:54 Dan Heins OGI video of VOC emissions from three small stacks on top of tank "TO-30", a spherical EtO tank. File Name: Date taken: Time taken: Videographer: Description: FLIR0023.mp4 02/14/2024 18:13 Dan Heins OGI video of VOC emissions from vent on fixed roof surfactant dry composite product tank "T-E3-368". Page 2 of 2 EPA Inspection Report - Page 12 of 16 Indorama Port Neches Plant Inspection Date 02/14/2024 Appendix 2 Opening conference sign-in sheets EPA Inspection Report - Page 13 of 16 EPA Inspection Report - Page 14 of 16 Indorama Port Neches Plant Inspection Date 02/14/2024 Appendix 3 Chain of Custody forms for summa cannisters collected EPA Inspection Report - Page 15 of 16 EPA Inspection Report - Page 16 of 16