EPA Inspection Report - Page 1 of 7
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s):
04/18/2022
Media Program:
Air
Regulatory Program(s)
SIP, Title V
Company Name:
Evonik Corporation
Facility Name:
Reserve Plant
Facility Physical Location:
474 West 19th Street
(city, state, zip code)
Reserve, LA, 70084
County/Parish:
St. John the Baptist Parish
Facility Phone Number
(973) 929-8000
Facility Contact:
Brittany Breaux
EHSS Manager
brittany.breaux@evonik.com
FRS Number:
110017758381
Identification/Permit Number:
LDEQ. Agency Interest Number 13560
Media Identifier Number:
AFS# 22-095-00023
NAICS:
325613
SIC:
2843
Personnel participating in inspection:
James Haynes
EPA-R6-ECAD-Air Toxics Enforcement
Physical Scientist
Christopher Williams
EPA-OECA-OCE-AED
Chemical Engineer
Richard Helmich, Ph.D.
E PA-0 ECA-OCEFT-O NEIC-LB
Senior Chemist
David Mahoney
EPA-OECA-OCEFT-ONEIC-FB-CRSS
Physical Scientist Technician
Ali Gitipour, Ph.D.
EPA-ORD-CEMM-AMCD
Federal Postdoctoral Research
Fellow/Chemical Engineer
Cory Lormand
LDEQ-OEC-Surveillance Division
Environmental Scientist
EPA Lead Inspector
Signature/Date
6/28/2022
J|ymes Haynes
Date
Supervisor
Signature/Date
1 A IV/l PC I C ATI—1 CDC Digitally signed by JAMES LEATHERS
J Ml VIE J Ltn 1 ntnj Date: 2022.07.17 21:49:50 -05'00'
James Leathers
Date
6ENFORM-019-R8.2 (02/12/2020)
1
-------
EPA Inspection Report - Page 2 of 7
Evonik / Reserve Plant
Inspection Date 04/18/2022
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION
On April 18, 2022, the Government Team consisting of Mr. Richard Helmich (EPA-NEIC), Mr. Ali Gitipour
(EPA-ORD), Mr. David Mahone (EPA-NEIC), Mr. Christopher Williams (EPA-AED), and Mr. Cory Lormand
(LDEQ) arrived at the Evonik Corporation's (Evonik) Reserve Plant in St. John the Baptist Parish at around
08:45 local time to conduct an unannounced Clean Air Act ("CAA") inspection.
The Government Team signed in at the reception area and were directed to a conference room in the
main office building. The Government Team watched a safety video and were introduced to Evonik
representatives Mr. John Marion, Site Manager, and Ms. Brittany Breaux, EHSS Manager. Mr. Williams
presented his inspector credentials to Mr. Marion and Ms. Breaux and notified them of the Government
Team's intent to conduct a CAA Partial Compliance Evaluation ("PCE"). This inspection occurred as part
of the Administrator's Multi-Scale Monitoring Project called the Pollution Accountability Team (PAT).
FACILITY DESCRIPTION
The Reserve Plant (LDEQ Agency Interest No. 13560) primarily produces alkoxylate alcohols by
combining alcohols and ethylene oxide ("EO") and/or propylene oxide ("PO") in the presence of a
catalyst. The facility currently uses four batch reactors to produce a variety of surfactant products from
the reaction of ethylene oxide with alcohols, fatty acids, amines and glycols. Storage tanks receive and
store raw materials and products used and produced by this process. Raw material and products are
received and shipped via railcar, truck, drum and tote.
Section II - OBSERVATIONS
Opening Conference
At around 09:00, the Government Team conducted an opening conference with Evonik representatives,
Mr. Marion and Ms. Breaux. Mr. Helmich explained that the compliance evaluation would include a
mobile air monitoring survey of the facility using Geospatial Measurement of Air Pollution ("GMAP") and
provided an overview of the vehicle and equipment. Mr. Williams explained that he would be using a
FLIR GF320 optical gas imaging ("OGI") camera and a handheld photoionization detector ("PID") to
locate any emission sources upwind of any detections made by GMAP. Mr. Helmich and Mr. Williams
asked the Evonik representatives to begin processing any hot work permits required by the company to
gain full access to the facility using the described equipment. Mr. Williams asked the company to let the
Government Team know if any Confidential Business Information is obtained during the PCE, so that the
information could be treated by the custodians as such.
Mr. Marion explained that currently there was a batch in process, and that two other batches would
begin later in the evening. Mr. Williams explained that on Saturday April 16th, EPA had also measured
2
-------
EPA Inspection Report - Page 3 of 7
Evonik / Reserve Plant
Inspection Date 04/18/2022
elevated concentrations of EO (between 5 and 10 parts-per-billion ("ppb")) using GMAP in the
communities adjacent to the facility at around 11:30. Mr. Marion confirmed that the facility had not
experienced any upsets over the weekend and was operating normally. Ms. Breaux provided the
schedule for rail unloading of EO and PO and described that the most recent unloading of EO occurred
Saturday beginning around 23:15. Ms. Breaux said that operations staff anticipated that loading of EO
would begin later in the evening after 18:00. Mr. Marion said that the facility operates a caustic wet
scrubber to control all waste process streams that contain EO and that the scrubber vent stack is an
authorize emissions point. At around 09:45 the opening conference concluded, and the Government
Team prepared the mobile air monitoring vehicle and equipment for entry into the operations area.
GMAP Site Tour*
*The EO concentrations identified below are preliminary and will be verified through analysis of the
samples obtained during the site tour; the analysis results will be available at a later date.
At around 10:00, Mr. Williams took a photo of the Evonik Reserve facility entry sign (DC_169.jpg) and
the Government Team began the site tour. Conditions were some cloud cover, and moderate winds
coming from north. In the mobile air monitoring vehicle, Mr. Helmich, Mr. Gitipour and Mr Mahone
were escorted by Ms. Breaux. On foot, Mr. Williams and Mr. Lormand were escorted by Mr. Marion and
Mr. Steven Millet, Operator. The mobile air monitoring vehicle drove on all available roads in the
operations area.
At around 10:15 downwind of the scrubber stack, GMAP detected elevated concentrations of EO (at
around 30 ppb) at ground-level. Using OGI, Mr. Williams recorded video MOV_170 of emissions
emanating from the scrubber stack. Mr. Williams observed a sweet odor while standing downwind of
the scrubber stack. Mr. Helmich took an air canister sample (NEIC# 4606 and ORD# 12172) while
positioned in the plume downwind while in the EO plume at 10:59.
At around 11:05 the Government Team exited the operations area and returned to the conference
room.
At 11:17, the Government Team conducted a closing conference with Evonik representatives Mr.
Marion and Ms. Breaux. Mr. Helmich and Mr. Williams provided a summary of their observations of the
emissions coming from the scrubber stack. The elevated EO concentrations measured onsite and offsite
were a concern to EPA. Ms. Breaux was identified as the Evonik contact for any further questions and
any reports. The Government Team notified Evonik of their plans to return later in the evening after
18:00 to conduct mobile air monitoring during rail unloading of EO. The closing meeting concluded at
around 11:30 and the Government Team exited the Evonik facility.
Region 6 Follow-up Inspection
At 15:15, Mr. Haynes conducted a separate site-entry for a follow-up inspection of the Reserve Plant.
Mr. Haynes watched a safety video and met with Evonik representatives Mr. Marion, Ms. Breaux, and
Mr. Dustin Lowry, Operations Supervisor. Mr. Haynes presented his inspector credentials to Mr. Marion
3
-------
EPA Inspection Report - Page 4 of 7
Evonik / Reserve Plant
Inspection Date 04/18/2022
and Ms. Breaux and notified them of his intent to conduct a CAA PCE in response to the elevated
readings and findings from the GMAP and GMAP Site Tour. Mr. Lowry provided Mr. Haynes with an
overview of the site operations and current conditions. Mr. Haynes indicated that he would be using a
Toxic Vapor Analyzer (TVA) Model 2020, a FLIR OGI Model GF320, and a Nikon digital camera during the
site inspection. Mr. Haynes asked the Evonik representatives to begin processing any hot work permits
required by the company to gain full access to the facility using the described equipment. Mr. Haynes
used the equipment to screen equipment for leaks that were in light liquid and/or gas/vapor service at
the rail cars and on top of the EO tank. No elevated readings were noted. Using the OGI camera, Mr.
Haynes noted light hydrocarbons from the scrubber stack and took digital images of the reactors,
scrubber, and other associated equipment.
Mr. Haynes shared all media files with Evonik upon returning to the office and requested additional
records for further review.
GMAP during rail loading of EO
At around 19:45, the Government Team returned to the Evonik facility and met James Haynes (EPA-R6)
who had been conducting a follow-up CAA inspection and Evonik representatives Mr. Millet, Mr. Marion
and Ms. Breaux. Mr. Millet confirmed that EO loading by rail had started. The Government Team and Mr
Haynes entered the operations area. In the mobile air monitoring vehicle, Mr. Helmich, Mr. Gitipour and
Mr Mahone were escorted by Ms. Breaux. Mr. Williams, Mr. Haynes, and Mr. Lormand were escorted by
Mr. Marion and Mr. Millet. Winds were moderate from the northeast. The mobile air monitoring vehicle
drove to a position downwind of the scrubber stack and took air measurements during rail loading of
EO. GMAP detected elevated concentrations of EO (at around 30 ppb) at ground-level.
At around 20:45, the Government Team, including Mr. Haynes exited the operations area, provided
Evonik representatives with a description of the mobile measurements taken that evening and left the
Evonik facility.
Section III - AREAS OF CONCERN
During the closing meeting the Government Team notified the company that the elevated EO
concentrations measured onsite downwind of the scrubber stack, and the EO concentrations measured
offsite were a concern to EPA.
Separately, Mr. Haynes noted potential concerns with the Reserve Plant's leak detection and repair
program; however, further investigation is necessary.
Section IV-FOLLOW UP
EPA electronically received the LDAR database on May 13, 2022, after exiting the Facility on April 18,
2022.
4
-------
EPA Inspection Report - Page 5 of 7
Evonik / Reserve Plant
Inspection Date 04/18/2022
Section V - LIST OF APPENDICES
Appendix 1 - Photo and Video Log - 1 photo and 1 OGI video taken April 18, 2022.
5
-------
EPA Inspection Report - Page 6 of 7
Evonik / Reserve Plant
Inspection Date 04/18/2022
Appendix 1
Photo and Video Log
-------
EPA Inspection Report - Page 7 of 7
^DST/>%^ Appendix 1
\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
" Photo and Video Log
v <*s°
*L PRO^
Location: Evonik Corporation Reserve Plant
City: Reserve
St. John the Baptist Parish
State: Louisiana
1r
© evoniH
¦ I l
*1
X
File Name: DC_169.jpg
Date taken: 04/18/2022
Time taken: 10:00 am
Videographer: Christopher Williams
Description: Photo of the Evonik Reserve Plant entry sign.
File Name: MOV_170.mp4
Date taken: 04/18/2022
Time taken: 10:20 am
Videographer: Christopher Williams
Description: OGI video of emissions emanating scrubber vent
stack.
Page 1 of 1
------- |