UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO, ILLINOIS 60604

SUBJECT: CLEAN AIR ACT INSPECTION REPORT

Koch Methanol, St. James, Louisiana

FROM:

Karina Kuc, Environmental Engineer
AECAB (IL/IN)

THRU:

Nathan Frank, Section Supervisor
AECAB (IL/IN)

TO:

File

Basic Information

Facility Name: Koch Methanol St. James

Facility Location: 6586 LA-3127, St James, LA 70086

Date of Inspection: April 21, 2022

EPA Inspector(s):

1.	Karina Kuc, Environmental Engineer

2.	Victoria Nelson, Environmental Engineer

Other Attendees:

1.	Kevan Reardon, EHS Leader, Koch Methanol

2.	Haleigh Engler, Environmental Engineer, Koch Methanol

3.	Matthew Avery, Environmental Engineer, Koch Methanol

4.	Marc Hoss, Plant Manager, Koch Methanol

5.	Dana Jacobs, Production Manager, Koch Methanol (closing only)

6.	Daniel Frank, Process Engineer, Koch Methanol (closing only)

7.	Darien Carson, Operations Superintendent, Koch Methanol (closing only)

Contact Email Address: Kevan.Reardon@kochind.com
Purpose of Inspection: to assess compliance with the Clean Air Act
Facility Type: methanol production


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Facility Name: Koch Methanol St. James

Facility Location: 6586 LA-3127, St James, LA 70086

Date of Inspection: April 21, 2022

Regulations Central to Inspection: National Emission Standards for Organic Hazardous Air
Pollutants (NESHAP) from the Synthetic Organic Chemical Manufacturing Industry, 40 C.F.R.
Part 63, Subparts F, G, and H (HON)

Arrival Time: 3:00 PM
Departure Time: 6:45 PM

Inspection Type:

E Unannounced Inspection
~ Announced Inspection

Opening Conference

IEI Presented Credentials
El Stated authority and purpose of inspection
El Provided Small Business Resource Information Sheet
E Provided CBI warning to facility

The following information was obtained verbally from Koch Methanol employees unless
otherwise noted.

Company Ownership: When construction of the facility began in 2018, Koch Methanol was
40% owner and a Chinese investment firm, YCI, was 60% owner. In 2019, Koch Methanol
became 60% owner of the facility and 100% owner of the terminal. In 2020, construction was
finished and Koch Methanol became the sole owner. Production began in 2021.

Process Description:

Methanol production is achieved by first producing synthesis gas or "syngas," followed by
methanol synthesis and finally methanol distillation. Syngas production begins with
desulfurization of natural gas. It is then routed to the steam methane reformer (SMR), where it is
combined with a catalyst and steam to create syngas. Next, the syngas is combined with natural
gas, then oxygen is introduced. An air separation system located at the facility but owned by Air
Liquide, supplies oxygen and nitrogen to Koch Methanol. Methanol synthesis consists of two
reactors in series. The syngas is reacted with a catalyst to produce crude methanol. The crude
methanol is then distilled through several distillation columns to produce pure methanol. The
product grade methanol is then distributed by pipeline or stored in tanks equipped with internal
floating roofs before being shipped out by barge, railcar or tanker truck. Barge and ship loading
is handled by a third party.

Staff Interview: Emissions from normal operations, sweeps, process sumps, slop tank, reactors
and the emergency system are vented to an unassisted flare. The storage tanks are controlled by a
condenser and scrubber. A design evaluation was done for assuming a range of control
efficiencies at the scrubber under different operating scenarios. The SMR is controlled by a

Page 2 of 4


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Facility Name: Koch Methanol St. James

Facility Location: 6586 LA-3127, St James, LA 70086

Date of Inspection: April 21, 2022

selective catalytic reduction unit. Emissions from loading railcars and tank trucks are routed to a
vapor combustor. A third party conducts Leak Detection and Repair (LDAR) requirements for
the facility.

Tour Information
EPA Tour of the Facility: Yes

Data Collected and Observations: EPA conducted the inspection equipped with a FLIR GFx-
320 (FLIR) and a flame ionization detector (FID) made by ThermoFisher Toxic Vapor Analyzer
2020 (TVA2020). EPA inspected the terminal storage tanks. Using the TVA2020, EPA observed
readings from about 20 to 27 parts per million (ppm) from the hatch on Tank 2301. Using the
FLIR, EPA observed the flare, SMR, and boiler. EPA observed the control room and parameters
being monitored.

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

EPA inspectors recorded videos using the FLIR.

Field Measurements: were taken during this inspection.

EPA inspectors measured organic emissions data using a TVA2020.

Records Review

1.	Process Flow Diagram

2.	Notice of Compliance Status for the HON

Closing Conference

IE] Provided U.S. EPA point of contact to the facility

Requested documents:

•	Unloading schedule at terminal tanks for April 20 and 21, 2022

•	LDAR database in Microsoft Access for 1 year

•	Parametric monitoring records for the flare for the past 3 months

•	Parametric monitoring records for the scrubber and condenser for the past 3 months

Compliance Assistance: EPA recommended that the facility check the integrity of the internal
floating roof at Tank 2301.

Page 3 of 4


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Facility Name: Koch Methanol St. James

Facility Location: 6586 LA-3127, St James, LA 70086

Date of Inspection: April 21, 2022

Digital Signatures

Digitally signed by Kuc,

. Kuc, Karina ^2022.05.17
Report Author:	i3:2i:sb-osw

Frank,

Section Supervisor: Nathan

Digitally signed by Frank,
Nathan

Date: 2022.05.17
15:09:13 -05'00'

Appendices and Attachments

Appendix A: Digital Video Log

Appendix B: EPA Monitoring Results and Calibration Information

Page 4 of 4


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Facility Name: Koch Methanol St. James

Facility Location: 6586 LA-3127, St James, LA 70086

Date of Inspection: April 21, 2022

Appendix A: Digital Image Log

1. Inspector Name: Victoria
Nelson

2. Archival Record Location: Region 5 Electronic
Records Center

Image
Number

File Name

Date and Time
(central time)*

Description of Image

1

MOV_0245.mp4

4/21/2022 18:41

Video of flare

2

MOV_0246.mp4

4/21/2022 18:42

Video of SMR and boiler stacks

3

MOV_0247.mp4

4/21/2022 18:51

Video of SMR and boiler stacks

4

MOV_0248.mp4

4/21/2022 18:52

Video of high pressure steam release

"The time reflected on the timestamp is an hour later than the video was recorded

Appendices Page 1 of 2


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Facility Name: Koch Methanol St. James

Facility Location: 6586 LA-3127, St James, LA 70086

Date of Inspection: April 21, 2022

Appendix B: EPA Monitoring Results and Calibration Information

Monitoring Results from Inspection 4/21/2022 and Calibration and Instrument Information

Table 1. Monitoring of Terminal Storage Tanks

Location

Notes

EPA Inspector

EPA
Reading (ppm)

Hatch on Tank 2301

Under lip of hatch

Karina Kuc

20-27

Calibration and Instrument Information

EPA used one ThermoFisher Toxic Vapor Analyzer 2020 (TVA2020). The TVA2020 response times
are in the 4 to 5 second range. No confirmation readings were taken.

Karina Kuc used TVA2020 ID: SL1555 for the duration of the survey.

Table 2. Instrument Calibration

April 21, 2022

SL1555 Reading (ppm)

4:20 PM Calibration Reading, 500 ppm

493

4:20 PM Calibration Reading, 10,000 ppm

10,100

Table 3. Calibration Gases

Manufacturer

Composition

Lot #

Expiration



Zero air

TDBJ-1-22

3/27/2023



Methane, 500 ppm

TDBJ-150A-500-11

3/27/2023



Methane, 1%

TIBJ-135A-1-1

8/21/2023

Appendices Page 2 of 2


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