Document zQM0xyzR8mxo7QOExOEjYMo86

EPA Inspection Report - Page 1 of 15 Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 04/13/2022 Air SIP, Title V, NESHAP, NSPS Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Westlake Styrene LP Styrene Marine Terminal 1820 Pak Tank Rd Sulphur, LA, 70665 PO Box 2449 Sulphur, LA, 70664 Calcasieu Parish 337-583-6428 Heather Lechtenberg FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110002347540 AI#: 17904 / 0520-00156-V4 2201900156 424690, 483211 5169 Personnel participating in inspection: James Haynes EPA ECD-AT Ben Rosenthal EPA ECD-AT DeWayne Coffman Westlake Styrene LP Michell Gill Westlake Styrene LP Charlie McGee Westlake Styrene LP Tom Hunt Westlake Styrene LP Engineer, Air Inspector Inspector Air Engineer Water Specialist Operator Production Superintendent EPA Lead Inspector Signature/Date BENJAMIN ROSENTHAL Digitally signed by BENJAMIN ROSENTHAL DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=BENJAMIN ROSENTHAL, 0.9.2342.19200300.100.1.1=68001003844840 Date: 2022.06.16 15:40:46 -05'00' Ben Rosenthal Date Supervisor Signature/Date JAMES LEATHERS Date: 2022.07.17 21:52:42 -05'00' Digitally signed by JAMES LEATHERS James Leathers Date 6ENFORM-019-R8.2 (02/12/2020) 1 EPA Inspection Report - Page 2 of 15 Westlake Styrene LP / Styrene Marine Terminal Inspection Date 4/13/2022 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors James Haynes and I, Ben Rosenthal, ("We", "Us") arrived at the Westlake Styrene LP ("Westlake") Styrene Marine Terminal (the "Facility", the "Site", or the "Terminal") at 9:40 a.m. on April 13, 2022, for an unannounced Clean Air Act ("CAA") inspection. We met with Westlake representatives, Charlie McGee, Operator, DeWayne Coffman, Air Engineer, Tom Hunt, Production Superintendent, and Michell Gill, Water Specialist. Inspector Credentials were presented to Mr. Coffman. We informed the Westlake representatives of the purpose and scope of the inspection. We discussed the monitoring activities that were conducted using EPA's Geospatial Measurement of Air Pollution ("GMAP") vehicle on April 12, 2022. On that date, the GMAP was screening for emissions while traveling on Pak Tank Road. GMAP operators observed a detected reading of 20 parts per billion benzene in front of the facility. The GMAP did not make entry at the facility on the date of the observation. The scope of the inspection is a partial compliance evaluation ("PCE") to identify the cause of the emissions detected by the GMAP at the site. This inspection occurred as part of the Administrator's Journey to Justice initiative. FACILITY DESCRIPTION Westlake operates the terminal. The terminal consists of a storage tank for styrene monomer product and a storage tank for benzene feedstock as well as loading and unloading facilities to transfer materials to and from ships, barges, and railcars as required. Benzene is received by pipeline or unloaded from barges, stored at the terminal, and then transferred by pipeline to the Styrene Monomer Manufacturing Facility at the Westlake Petrochemical Complex. The terminal operates 8,760 hours per year. Tank MT704A ("the benzene tank") is an internal floating roof ("IFR") design and is permitted to hold benzene. The benzene tank is controlled with a nitrogen blanket in the benzene tank's headspace. The benzene Tank is vented to a carbon canister. The styrene monomer storage tank, Tank MT-700, is a fixed roof tank maintained at a temperature below 65 degrees F to prevent polymerization. The terminal also includes a collection and storage system for contaminated stormwater. Contaminated wastewater is collected in a tank on-site and trucked off-site for treatment. Associated utilities include fire-utility water, chilled water, nitrogen, and an ammonia refrigeration system. The terminal has less than 10 employees on-site. Photographs of the carbon canister and benzene tank are included in Appendix 1 - Photographs. Section II - OBSERVATIONS After a discussion with facility personnel of the GMAP findings from the previous day, representatives from Westlake provided us with a description of the site layout and processes. Mr. McGee provided us 2 EPA Inspection Report - Page 3 of 15 Westlake Styrene LP / Styrene Marine Terminal Inspection Date 4/13/2022 with a narrative of the events that occurred at the site during the general time period of the GMAPs observations of benzene emissions by the terminal. Mr. McGee stated that the facility had received a shipment of benzene by barge. The shipment was offloaded to the site's benzene tank and the transfer operations lasted from 10:28 a.m. on April 12, 2022, until 1:30 a.m. on April 13, 2022. Mr. McGee stated that weather conditions, primarily gusty winds, and thunderstorms, had impacted the transfer operation and caused delays. Mr. McGee provided a handwritten descriptive log of the benzene transfer (See Appendix 2 - Correspondence Time Log). Mr. McGee stated that other than the inclement weather, there were no disruptions during the transfer operations that he could recall. Mr. McGee stated the pump that controls the flow of material from the barge to the benzene tank is manually controlled. We discussed the site's carbon canister control system for emissions from the benzene tank. The carbon maintains effective control efficiency for 1 to 2 months of usage on average, according to site personnel. The carbon canister was tested on April 7th, 2022, and found to contain 3 ppm benzene. Mr. Haynes requested records for the last time the carbon canister was changed out and test records for the carbon. The facility representatives also discussed the site's Leak Detection and Repair ("LDAR") program which is administered pursuant to the provisions of the National Emission Standards for Organic Hazardous Air Pollutants ("NESHAP") From the Synthetic Organic Chemical Manufacturing Industry for Process Vents, Storage Vessels, Transfer Operations, and Wastewater-Subpart G. Mr. Haynes and I, then conducted a site walkthrough with representatives of the facility. We explained that we would utilize a Thermo Scientific Toxic Analyzer 2020 ("TVA") Flame Ionization Vapor Detector ("FID") and a FLIR GF320 Optical Gas Imaging Camera ("OGIC") to monitor components at the facility. We walked to the area of the carbon canister at approximately 10:50 a.m. We observed and monitored the carbon canister and associated components. We did not observe detectable readings with the TVA or visualized emissions with the OGIC. Mr. Haynes, Mr. Hunt, and I climbed to the top of the benzene tank and observed the roof and other components. We did not observe any areas of concern at the benzene tank. Section III - AREAS OF CONCERN Before departing the site, we reviewed the observations documented during the inspection with representatives from Westlake. We did not note areas of concern regarding observations made during the inspection. See Section IV for follow-up records provided by the facility. The following areas of concern were noted after the inspection. 1) An Open-ended Valve at the Facility Was Not Capped or Plugged and Contributed to a Leak of Benzene on February 19, 2021. One area of concern was noted upon review of information provided by the facility (See Appendix 3 - Styrene Terminal BZ Leak RQ Calcs - 2-19-21). On February 19, 2021, the facility discovered two benzene leaks. The leaks were estimated to release 9.93 pounds of benzene before being found and stopped. The facility estimated that 1.64 pounds of benzene evaporated to the atmosphere because of the leaks. One of the leaks was described as originating at a bleeder valve that was cracked slightly open without a plug 3 EPA Inspection Report - Page 4 of 15 Westlake Styrene LP / Styrene Marine Terminal Inspection Date 4/13/2022 installed. Equipment leaks for open-ended valves and lines at the facility are subject to 40 CFR Part 63 Subpart H NESHAP for Equipment Leaks. The provisions of the subpart apply to components that are intended to operate in organic hazardous air pollutant service 300 hours or more during the calendar year within a source subject to the provisions of a specific subpart in 40 CFR part 63 that references 40 CFR Part 63 Subpart H NESHAP for Equipment Leaks. According to Permit No. 0520-00156-V4, the entirety of the site is permitted to operate continuously and subject to 40 CFR 63 Subpart F, which references Subpart H. 40 CFR 63.167(a)(1) states that each open-ended valve or line shall be equipped with a cap, blind flange, plug, or a second valve, except as provided in 63.162(b) of this subpart and paragraphs (d) and (e) of the section. 40 CFR 63.167(a)(2) states that the cap, blind flange, plug, or second valve shall seal the open end at all times except during operations requiring process fluid flow through the open-ended valve or line, or during maintenance or repair. Based on the self-reported information from the company, it appears that the bleeder valve identified to be opened on February 19, 2021, and therefore the cause of the noted release of benzene, is an open-ended valve that was not capped or plugged. 2) Marine Offloading Activities Via Barge Could Have Contributed to the Benzene Emissions Detected by the GMAP on April 12, 2022. No cause for the emissions of benzene observed by the GMAP could be identified by EPA inspectors or facility personnel during the inspection. Evaluating emissions from the barge at the time of loading are outside of the scope of the onsite inspection activities. Activities on the barge around the time of the offloading could have contributed to excess emissions. These activities, such as opening and degassing hatches while in transit, are outside of the purview of most CAA regulated activities and must be evaluated pursuant to the applicable regulatory jurisdictions. Section IV - FOLLOW UP On May 12, 2022, I received additional information from Ms. Lechtenberg via email. The information contained in the email is as follows. The vessel offloading benzene on April 12, 2022, was identified as FMT6016. Records were provided for a release of benzene that the facility reported on February 19, 2022 (See Appendix 3). The last receipt of benzene by barge prior to the April 11, 2022-event, occurred on September 27, 2021. Ms. Lechtenberg provided a process description in response to a question about the potential sources or cause of the emissions observed by the GMAP on April 12, 2022. Additional information regarding the observations made by the GMAP at the facility will be provided in a future report. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log Appendix 2 - Correspondence Time Log Appendix 3 - Styrene Terminal BZ Leak RQ Calcs - 2-19-21 4 EPA Inspection Report - Page 5 of 15 Westlake Styrene LP / Styrene Marine Terminal Inspection Date 04/13/2022 Appendix 1 Photograph Log EPA Inspection Report - Page 6 of 15 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1820 Pak Tank Rd City: Sulphur Photo No. 1 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN0701.jpg Date of Photo: 4/13/2022 Time of Photo: 11:00 Photographer: Ben Rosenthal Description: Carbon canister controlling emissions from the benzene tank. EPA Inspection Report - Page 7 of 15 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 1820 Pak Tank Rd City: Sulphur Photo No. 2 County/Parish: Calcasieu State: Louisiana Photo File Name: DSCN0702.jpg Date of Photo: 4/13/2022 Time of Photo: 11:21 Photographer: Ben Rosenthal Description: Roof of the benzene tank. A blue thief hatch and sample valves are visible. EPA Inspection Report - Page 8 of 15 Westlake Styrene LP / Styrene Marine Terminal Inspection Date 04/13/2022 Appendix 2 Correspondence Time Log EPA Inspection Report - Page 9 of 15 EPA Inspection Report - Page 10 of 15 EPA Inspection Report - Page 11 of 15 Appendix 3 Styrene Terminal BZ Leak RQ Calcs - 2-19-21 EPA Inspection Report - Page 12 of 15 DATE: TO: CC: FROM: RE: February 22nd, 2021 Howard Wasserman Joanne Sovereign, Tom Hunt, Barry Willy Chris Tumey Styrene Terminal Benzene Leak RQ Calculations Howard, on Friday February 19th, 2021 at or around 1430 there were two leaks found at the Styrene Marine Terminal. Below is both a brief write-up of events as well as the release calculation to determine if a reportable quantity of benzene was released. Once the ambient temperature was above the 42 F freezing point of benzene, operations began walking the lines looking for any potential leaks or issues. At this time, there were two leaks found. The first was a pinhole in piping. This leak persisted for no more than 15 minutes uncaptured; the below table details the amount of material that "hit the ground" prior to being captured; approximately 2.8 lbs. Once this leak was identified, all of the material was captured prior to the leak being patched. This captured material was subject to evaporation for the approximate 1-hour duration of the leak. The evaporation rate of 1.64 lbs/hr was calculated based on ambient conditions at the time of the leak, these calculations can be seen below. Flow of Liquid Through Hole in Pipe Discharge Coefficient 0.6 Hole Diameter (in) 0.015625 Hole Area (ft^2) 1.332E-06 P1 (psig) 30 P2 (psig) 0 Liquid Density (lbs/ft^3) 54.8 SG Liquid 0.877 Volumetric Flow (ft^3/s) 0.000 Volumetric Flow (gpm) 0 Mass Flow (lbs/hr) 11 Velocity (ft/s) 43 Leak Duration (min) 15 Total Liquid BZ (lbs) 2.80 The second leak found was a bleeder that was cracked slightly open without a plug installed. This leak was all initially "uncaptured" prior to being found and immediately stopped. The amount of benzene leaked to the pad was reclaimed and was measured to be less than of a gallon, or at most 5.49 lbs. EPA Inspection Report - Page 13 of 15 Based on the all of the available information, the two combined leaks were just below the reportable quantity of 10 lbs at 9.93 lbs: Total Benzene Released "Uncaptured" from Pin-Hole (lbs) 2.8 Evaporation from Pin-Hole (lbs) 1.64 Total Release from Bleeder (lbs) 5.49 Total Released 9.93 Appendix A - Evaporation Calculations EVAPORATION RATE (EPA METHOD) (Inputs are in red; Outputs are in black) Location: Westlake Plant: Styrene Term inal Chem ical: Benzene Case: Benzene Spill Date: 2/19/21 Cons tants Universal Gas Law Constant (atm -cm 3)/(gm ol K) Pool Tem perature Pool Liquid Tem perature (F) *Tank tem perature: TI-C185 Pool Liquid Tem perature (C) Pool Liquid Tem perature (K) Physical Properties Molecular Weight Of Liquid Vapor Pressure Of Liquid at Pool Tem perature (m m Hg) *(See attached table) Surface Area Of The Pool Length (ft) Width (ft) Surface Area Of The Pool (ft2) Wind Speed Wind Speed (m ph) Wind Speed (fps) Wind Speed (m eters/sec) Evaporation Rate (lb/m in) Evaporation Rate (lb/hr) Evaporation Rate (lb/day) Evaporation Rate (lb/m in) Liquid 82.05 Liquid 50.00 10.00 283.15 Liquid 78.11 45.4 Liquid 1.0 1.0 1.0 Liquid 8.00 11.73 3.58 Liquid 0.03 1.64 39 EPA Inspection Report - Page 14 of 15 Appendix B - Release Notification Form EPA Inspection Report - Page 15 of 15