EPA Inspection Report - Page 1 of 15
&EPAL
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s):
04/13/2022
Media Program:
Air
Regulatory Program(s)
SIP, Title V, NESHAP, NSPS
Company Name:
Westlake Styrene LP
Facility Name:
Styrene Marine Terminal
Facility Physical Location:
1820 PakTank Rd
(city, state, zip code)
Sulphur, LA, 70665
Mailing address:
PO Box 2449
(city, state, zip code)
Sulphur, LA, 70664
County/Parish:
Calcasieu Parish
Facility Phone Number
337-583-6428
Facility Contact:
Heather Lechtenberg Engineer, Air
FRS Number:
110002347540
Identification/Permit Number:
Al#: 17904 / 0520-00156-V4
Media Identifier Number:
2201900156
NAICS:
424690, 483211
SIC:
5169
Personnel participating in inspection:
James Haynes
EPA ECD-AT
Inspector
Ben Rosenthal
EPA ECD-AT
Inspector
DeWayne Coffman
Westlake Styrene LP
Air Engineer
Michell Gill
Westlake Styrene LP
Water Specialist
Charlie McGee
Westlake Styrene LP
Operator
Tom Hunt
Westlake Styrene LP
Production Superintendent
EPA Lead Inspector
Signature/Date
C i iitill i ii -d by BENJAMIN ROSENTHAL
DCM I A M IM DOC CMTU A I NN:' " 'J-S- Government, ou-Environmental Protection Agency,
D L 1 MJAIyI 1 1 M nWJL 1 M 1 FlnL cn-BENJAMIN ROSENTHAL, 0.9.2342.19200300.100.1.1-68001003844840
I >.il..'.'ii, 1615:40:46 -OS'OO'
Ben Rosenthal
Date
Supervisor
Signature/Date
IAMFQ I p ATI—ICDC Digitally signed by JAMES LEATHERS
JMlVltl J LCnl nt.ro Date: 2022.07.17 21:52:42 -OS'OO'
James Leathers
Date
6ENFORM-019-R8.2 (02/12/2020)
1
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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 PakTank 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 MT-
704A ("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
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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
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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
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EPA Inspection Report - Page 5 of 15
Westlake Styrene LP / Styrene Marine Terminal
Inspection Date 04/13/2022
Appendix 1
Photograph Log
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EPA Inspection Report - Page 6 of 15
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: 1820 Pak Tank Rd
City: Sulphur
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.
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EPA Inspection Report - Page 7 of 15
§ 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
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.
Location: 1820 Pak Tank Rd
City: Sulphur
County/Parish: Calcasieu
State: Louisiana
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EPA Inspection Report - Page 8 of 15
Westlake Styrene LP / Styrene Marine Terminal
Inspection Date 04/13/2022
Appendix 2
Correspondence Time Log
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EPA Inspection Report - Page 9 of 15
WESTLAKESTYRENE LP
(9
CORRESPONDENCE TIME LOG
PORT/TERMINAL
VESSEL
DATE
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,,/^i CUSTOMER _ £{Q U$Q
ORDER# ^OlHSSlZt
CARGO g£
DATE _ HOUR J
l2> 2Z_ 0500 _ DOCK_mN. ARR\V„E£>
DATE
____OS_2-0__ . (N5P£CTD_R„.agRlveD_ ..
_ 0550 TANKERmAH .ARRWED
lOGSO OPEN fiAU^F fl>mP LETS
0700 : gftR&g ARRwEP IN SLIP
O$3o SAmPitg Recen/gp , td M0
_._0?45 Sftmpies lap,
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_ LOGO g£. SArnpLETS PASSED l_£lQQ_D_.TD QFP i-OAP
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CALL£D__DEVALL FLEET FOR A TU6a S- THEV SAtp to
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of 15
CORRESPONDENCE TIME LOG
PORT/TERMINAL
VESSEL
DATE
yi4mBlH&JER»JfclAk
PMT frOllg
4/13/27. __
CUSTOMER
ORDER#
CARGO
RIO -> USC
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EPA Inspection Report - Page 11 of 15
Appendix 3
Styrene Terminal BZ Leak RQ Calcs - 2-19-21
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EPA Inspection Report - Page 12 of 15
Westlake
Chemical
DATE: February 22nd, 2021
TO: Howard Wasserman
CC: Joanne Sovereign, Tom Hunt, Barry Willy
FROM: Chris Tumey
RE: 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 pin-
hole 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 (ftA2)
1.332E-06
Pl(psig)
30
P2 (psig)
0
Liquid Density (lbs/ftA3)
54.8
SG Liquid
0.877
Volumetric Flow (ftA3/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 3/4 of a gallon, or at most 5.49 lbs.
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EPA Inspection Report - Page 13 of 15
Westlake
Chemical
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 Terminal
Chemical: Benzene
Case: Benzene Spill
Date: 2/19/21
ChemSoft
Q ^Eyngineering
Constants
Liquid
Universal Gas Law Constant atm-cm3 / gmol K
82.05
Pool Temperature
Liquid
Pool Liquid Temperature F Tank temperature: TI-C185
50.00
Pool Liquid Temperature C
10.00
Pool Liquid Temperature K
283.15
Physical Properties
Liquid
Molecular Weight Of Liquid
78.11
Vapor Pressure Of Liquid at Pool Temperature (mmHg (See attached table
45.4
Surface Area Of The Pool
Liquid
Length ft)
1.0
Width ft)
1.0
Surface Area Of The Pool ft2
1.0
Wind Speed
Liquid
Wind Speed mph)
8.00
Wind Speed fps
11.73
Wind Speed meters/sec
3.58
Evaporation Rate Ib/min
Liquid
Evaporation Rate Ib/min
0.03
Evaporation Rate Ib/hr
1.64
Evaporation Rate lb/day)
39
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EPA Inspection Report - Page 14 of 15
Westlake
Chemical
Appendix B - Release Notification Form
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EPA Inspection Report - Page 15 of 15
Release Notification Form
WESTLAKE COMPLEX
RELEASE I DISCHARGE NOTIFICATION FORM
1 RELEASE TYPE ;
a) STATE POLICE y j b) L-DEQ J c) LEPC J d) Other
2 DEPARTMENT > V| -¦'» 'U • 3. LOCATION: J £) y')• \ /' '< ^
MAILING: • \> k4tA , , , •
4. DESCRIPTION: h ^ - . 1 1
a) Date/Time Started: f . _//*;' | Date/Time Stopped:
b) Material: K < f< Wind Direction, Precipitation
c) Material's Hazard Class • Wind Speed •' h ~ "
d) Quantity (attach calculation): Temperature'
CAUSE: ,J., /LQ
/ '' ' "
l Corrective Action Taken /. i ; ,'t? \ *'/»*
J V ' ' t)
in' i.
/)¦< /'¦ A
...
7. Did incident result in fire, injury, or fatality? "
8. Were there any road closures or evacuation?
aA •'
9. Report to :
a) State Police (225) 925-6595 Date/Time: / Person Rec. Rpt" ^ f 1
Call Back: * /, it % »\f
Incident Number: ,?/"('% *)
b) L-DEQ Hotline: (225) 342-1234 Date/Time: ~ ' "person Rec. Rpt:
Call Back:
Division: Incident Number:
c) LEPC Date/Time:" r 3* Person Rec. Rpt:' ~/ft-1/77
Days/Nights/Weekends (337) 439-9911 Call Back:
d) NRC- Hotline : 1-800^24-8802 Date/Time: 3 J/, (J / / p0rson Rec R t., ?
Ca,,Back: ' - (v*ri
DATE OF SUBMITTAL:
fi\rl
SHIFT , /1
SUPERVISOF
SIGNATURE:
SUPERVISOR l- I' i '' , /
Form 11.001
Rev 0.0 (5-10-02)
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