UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO, ILLINOIS 60604

SUBJECT: CLEAN AIR ACT INSPECTION REPORT

Americas Styrenics LLC, St. James, Louisiana

FROM:

Jason Schenandoah, Environmental Engineer
AECAB (IL/IN)

THRU:

Nathan Frank, Section Supervisor
AECAB (IL/IN)

TO:

File

Basic Information

Facility Name: Americas Styrenics LLC (AmSty)

Facility Location: 9901 LA-18, St James, LA 70086
Date of Inspection: April 11-12, 2022

EPA Inspector(s):

1.	Jason Schenandoah, Environmental Engineer

2.	Constantinos Loukeris, Environmental Engineer

3.	Ben Rosenthal, Environmental Engineer

4.	James Haynes, Environmental Engineer

Other Attendees:

1.	Jacob LaSavia, Plant Manager, AmSty

2.	Kristen Newman, Environmental Air Specialist, AmSty

3.	Durell Morris, Environmental Specialist, AmSty

4.	Jodi Fife, API Mechanical Inspector, Reliability Technician Specialist, AmSty

5.	Dave Thomas, Environmental Compliance Manager, AmSty

6.	Tjokro Hermanto, Manager: Conduct of Operations, AmSty

7.	Ben Brignic, Operations Coordinator, AmSty

8.	Israel Billoit, Logistics Manager, AmSty

9.	Kevin Sanchez, Monitoring Supervisor, Clean Harbors

10.	Sammie Coleman, Monitoring, Clean Harbors

Contact Email Address: dmorris@amsty.com


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Purpose of Inspection: To ensure compliance with the Clean Air Act
Facility Type: Sytrene manufacturing facility

Regulations Central to Inspection: 40 CFR 63.11(b)(4): Flares shall be designed for and
operated with no visible emissions, except for periods not to exceed a total of 5 minutes during
any 2 consecutive hours. 40 C.F.R. Part 63 Subpart H: National Emission Standards for Organic
Hazardous Air Pollutants for Equipment Leaks. 40 C.F.R. Part 60 Subparts K and Kb: Floating
roof tank seal gap inspections.

Arrival Time: 9:25 am
Departure Time: 4:50 pm

Arrival Time: 8:35 am
Departure Time: 1:15 pm

Inspection Type:

M Unannounced Inspection

~	Announced Inspection

Opening Conference

M Presented Credentials
M Stated authority and purpose of inspection

~	Provided Small Business Resource Information Sheet

M Small Business Resource Information Sheet not provided. Reason: Not a small business.
M Provided CBI warning to facility

The following information was obtained verbally from Am Sty personnel unless otherwise noted.
Process Description:

Benzene, received by barge and stored in one of three external floating roof tanks, is reacted with
ethylene, received by pipeline, to create ethylbenzene through an alkylation process in the
ethyl benzene unit (EB unit). Most ethylbenzene is then routed to one of two styrene monomer
(SM) units to undergo a dehydrogenation process to produce styrene; some ethylbenzene is sold
instead of undergoing further reactions. Emissions from the EB unit are routed to a flare for
control. Styrene is then stored in temperature-control led tanks to await shipment via barge, ship,
rail, or truck. Polyethylbenzene residue, toluene, and diethylbenzene are biproducts of the
process that is also sold by AmSty.

Staff Interview: The EB unit operates under pressure, while the SM units operate on a vacuum.
The flare that controls emissions from the EB unit is steam assisted and manually adjusted.
Loading and unloading operations are vapor balanced. The external floating roof (EFR) tanks

Page 2 of 5


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operate with a mechanical shoe primary seal and a wiper blade secondary seal on the roof. The
EFR tanks utilize anti-rotational guide poles with teflon seals.

Tour Information

EPA Tour of the Facility: Yes

Data Collected and Observations:

The flare was observed to have visible black smoke several times throughout the two-day
inspection. There was constant black smoke observed from 9:26 am to 9:32 am on April 11,
2022 and constant black smoke from 8:39 am to 8:44 am on April 12, 2022. Black smoke was
noted at 9:42 am, 10:05 am, 10:28 am, and 1:23 pm on April 11, 2022. EPA inspectors utilized a
Forward Looking Infrared (FLIR) camera to conduct optical gas imaging (OGI) throughout
AmSty's facility. A video was taken of the flare on April 12, 2022 and is documented in
Appendix A. OGI was performed on several storage tanks at the facility. Two videos were taken
of tank MF322; emissions were imaged venting from a pontoon vent. A camera is used for
operators to view the flare in the control room. The screen is located across the room from the
main control screens and EPA noted that the resolution on the viewing screen made it difficult to
note any visible emissions. Some pressure relief valves on the EB unit were noted to have a
bypass and would allow for emissions to be uncontrolled. Detectable emissions at the pressure
relief valves are noted in the table in Appendix B.

Photos and/or Videos: were taken during the inspection.

See Appendix A: Digital Image Log

Field Measurements: were taken during this inspection.

•	Two Toxic Vapor Analyzer 2020s (TVA) (EPA units A56584 and SL1555) were used to
perform Method 21 throughout the Facility. Measurements taken with the TVAs are
tabulated in Appendix B: Field Measurement Data.

Closing Conference

M Provided U.S. EPA point of contact to the facility

Requested documents:

•	Last three years of flare monitoring data

•	Tank levels and flow for April 12, 2022

•	Tank seal inspections

•	First half 2021 semi-annual fugitive emissions report

•	LDAR backup data file

Compliance Assistance: EPA informed Am Sty personnel about the visible emissions on the
flare. EPA informed Am Sty personnel that some pressure relief valves have a design issue that
allows for bypassing of emissions from emissions control.

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Concerns: Visible emissions for greater than 5 continuous minutes on both days of the
inspection. Potential bypassed emissions at some pressure relief valves.

Digital Signatures

. n _ _ . .	Digitally signed by JASON

JASON	SCHENANDOAH

Report Author: SCHENANDOAH		

Frank,

Section Supervisor: Nathan

Digitally signed by Frank,
Nathan

Date: 2022.06.09
09:31:58 -05'00'	

Page 4 of 5


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Facility Name: Facility Name

Facility Location: Facility Address

Date of Inspection: Select date by clicking on the arrow

Appendices and Attachments

7, Appendix A: Digital Image Log
2. Appendix B: Field Measurement Data

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Facility Name: Facility Name

Facility Location: Facility Address

Date of Inspection: Select date by clicking on the arrow

Appendix A: Digital Image Log

1. Inspector Name: Jason

Schenandoah/Constantinos Loukeris

2. Archival Record Location: Region 5 Electronic
Records System (ERC)	

Image
Number

File Name

Date and Time
(incl. Time zone
and DST)

Latitude
and

Longitude

Description of Image

1

MOV_0170.mp4

4/12/2022 9:57



FLIR video of the flare

2

MOV_0172.mp4

4/12/2022 13:00



FLIR video of external floating roof,
no gases i maged

3

MOV_0173.mp4

4/12/2022 13:05



FLIR video of the flare

4

MOV_0174.mp4

4/12/2022 13:15



Tank MF 322 pontoon vent

5

MOV_0175.mp4

4/12/2022 13:19



Tank MF 322 pontoon vent

Appendices Page 1 of 2


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Facility Name: Facility Name

Facility Location: Facility Address

Date of Inspection: Select date by clicking on the arrow

Appendix B: Field Measurement Data

FID Instrument

TV A 2020: A56584

TVA 2020: SL1555

500 ppm

481 ppm

496 ppm

10000 ppm

9857 ppm

10200 ppm

Bump Check





500 ppm

450 ppm

440ppm

Ta

ble 1: Instrument Calibration 4/11/2022

FID Instrument

TV A 2020: A56584

TVA 2020: SL1555

500 ppm

475 ppm

499 ppm

10000 ppm

9821 ppm

9981 ppm

Ta

ble 2: Instrument Calibration 4/12/2022

Components

Number Measured

Valves

679

Pumps

12

Plugs

40

Table 3: Total Components Measured

Components

Number Measured

Valves

3

Open ended lines

2

Table 4: Leaks Detected

Appendices Page 2 of 2


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