Document ym9OjGB4xre1ZXEZ55gEM62D

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: 06/21/2018 Water Clean Water Act Lion Elastomers Lion Elastomers 1615 Main Street Port Neches, TX 77651 P.O. Box 667 Port Neches, TX 77651-3039 Jefferson County Derwin K. Poindexter 409-721-1573 Environmental Manager FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: TX0062448 325212 2822 Personnel participating in inspection: Michael Williams EPA/ 6EN-WMH Derwin K. Poindexter Lion Elastomers David Baggett Lion Elastomers Inspector Environmental Manager Environmental Coordinator 281-983-2150 409-721-1573 409-724-8843 EPA Lead Inspector Signature/Date Supervisor Signature/Date Digitally signed by MICHAEL WILLIAMS MICHAEL WILLIAMS DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=MICHAEL WILLIAMS, dnQualifier=0000015063 Date: 2018.09.24 11:21:05 -05'00' Michael D. Williams Date CAROL PETERSWCaAroGl PNetOerNs Digitally signed by CAROL PETERS-WAGNON DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=CAROL PETERS-WAGNON, dnQualifier=0000009981 Date: 2018.10.03 17:30:37 -05'00' Date Lion Elastomers (TX0062448) Inspection Date 06/21/2018 Section I - Introduction PURPOSE OF THE INSPECTION EPA Region 6 inspector, Michael Williams, arrived at Lion Elastomers. at 10:55 am on June 21, 2018 for an unannounced inspection. I met with the Environmental Manager, Derwin K. Poindexter. I presented my credentials to Mr. Poindexter and informed him that this was an EPA lead Compliance Evaluation inspection to determine compliance with the facility's National Pollutant Discharge Elimination System (NPDES) permit and the Clean Water Act. The scope of the inspection was with permit TX0062448, facility operations and maintenance under the Clean Water Act. The inspection was conducted under the authority of the NPDES permit program, in accordance with the Federal CWA. The information presented in this report is based on the materials and information supplied by Huntsman, representatives (the permittee), observations made during the inspection and records and reports maintained by the permittee. FACILITY DESCRIPTION Lion Elastomers is located at 1615 Main Street, Port Neches, Texas. The Lion Synthetic Elastomers plant in Port Neches produces styrene butadiene rubber by the emulsion process. Product is packaged as bales or in boxes. The rubber produced is used to manufacture all manner of rubber products including tires. Styrene and butadiene are combined in one of five reactor trains and partially reacted to produce latex. Unreacted butadiene and styrene are then recovered and recycled in one of five recovery units where these monomers are compressed, condensed into liquid and stored for reuse as feedstock. The final recovery step for the latex is stripping of residual styrene. This is a critical process step for control of downstream emissions. The MACT regulation for the SBR industry requires less than 0.04 % residual styrene in latex. Latex is stored briefly before being processed by one of ten finishing lines. Each finishing line consists of coagulation, dewatering, drying and packaging. In coagulation the latex is converted into crumb rubber by reducing the pH to about 3.5 su. The crumb rubber is then physically pressed to remove water and broken into small pieces. It is then pneumatically conveyed onto the apron of a steam heated air dryer. Volatiles are removed from the crumb rubber and emitted from stacks. The rubber is then conveyed, weighed, baled and packaged. It is then either shipped to a customer or stored in a warehouse. Lion Elastomers is one the partners in the joint wastewater treatment plant (JWWTP) at Huntsman Chemical, that receives process wastewater streams from the TPC Group and Lion Elastomers. JWWTP has four primary clarifiers, equalization basin, two storm water basins, two aeration basins, three final clarifiers, and a polishing pond prior to discharging into the wetlands area which discharges out of outfall 001 to the Neches River under permit TX0005070. Lion Elastomers permit TX0087602 allows for noncontact storm water on site to be discharged. The site is graded to drain towards the west along East Loop Road. There is catch basins and the drainage ditch along the East Loop Road. The storm water is monitored and discharged to the Neches River. 2 Lion Elastomers (TX0062448) Inspection Date 06/21/2018 Section II- Observations This inspection revealed the following observations: On the day of the inspection, process areas (Carbon Black sump, propane tank and railroad crossing area) did not have the grading or barrier to prevent process material or contact storm water from flowing or being tracked into the non-contact area East Loop Road drainage ditch/storm channel. Process materials were observed in the drainage ditch on the day of the inspection. Lion Elastomers had a spill occur on June 16-17, 2018 the weekend before this inspection. The spill occurred in the Tank 9 Dark Extender Oil storage tank area. On the day of the inspection, the tank area looked as if it still needed cleaning to prevent sheet flow of contaminated storm water from commingling with non-contact storm water discharge. Lion Elastomers housekeeping did not appear adequate. Section III- Areas of Concerns This inspection revealed the following areas of concerns: Proper Operation The permittee had two releases from their facility within the past year. The release in January 2018 contributed to a fish kill during rain event. The site does not have the barriers or is designed to contain all storm water runoff from the process area. The site isn't permitted to discharge commingled storm water. Section IV - LIST OF APPENDICES Appendix A -Lion Elastomers - Site Map Appendix B - 30 Day Follow-up Spill Summary 3 Lion Elastomers (TX0062448) Inspection Date 06/21/2018 Appendix A Lion Elastomers - Site Map 4 015 023 NORTH LOOP ROAD 021 WEST LOOP ROAD 022 021 SOUTH LOOP ROAD 015 016 Area of Concern No Barrier to prevent commingling of process runoff. 016 SOUTH LOOP ROAD CROSS STREET EAST LOOP ROAD 018 017 014 CENTER STREET CENTER STREET WEST LOOP ROAD CROSS STREET EAST LOOP ROAD 118 117 NORTH LOOP ROAD PORT NECEHES ELASTOMERS FACILITY, Lion Elastomers (TX0062448) Inspection Date 06/21/2018 Appendix B Lion Elastomers - 30 Day Follow-up Spill Summary 5