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 ------- 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 ------- 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. Page 3 of 5 ------- 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 ------- 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 Page 5 of 5 ------- 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 ------- 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 ------- |