EPA Inspection Report - Page 1 of 6
A PR* United States
Environmental Protectior
VLI #1 Agency
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s):
04/13/2022
Media Program:
Air
Regulatory Program(s)
Title V
Company Name:
Lotte Chemical Louisiana LLC
Facility Name:
Lotte Chemical Louisiana LLC
Facility Physical Location:
2200 Bayou D'lnde Pass Road
(city, state, zip code)
Westlake, LA 70669
Mailing address:
2200 Bayou D'lnde Pass Road
(city, state, zip code)
Westlake, LA 70669
County/Parish:
Calcasieu Parish
Facility Phone Number
337-990-6345
Facility Contact:
Kaili Patterson
Environmental Supervisor
Kaili.patterson@lottechem.com
FRS Number:
110070227146
Identification/Permit Number:
0520-00488-V3
Media Identifier Number:
LA0000002201900502
NAICS:
325110, 325199
SIC:
2869
Personnel participating in inspection:
Nicholas Bobbs
EPA/OECA/OCE/AED
Inspector
Richard Helmich
EPA/OECA/OCEFT/NEIC
Chemist
Agustin Martinez
EPA/OECA/OCEFT/NEIC
Technician
Ali Gitipour
E PA/O RD/CEM M/AMCD
Physical Scientist
Elena Mayard
LDEQ/OEC/SD
Inspector
Kaili Patterson
Lotte Chemical
Environmental Supervisor
Heather Holbrook
Lotte Chemical
Environmental Coordinator
Andrew Lavin
Lotte Chemical
EHSS Manager
EPA Lead Inspector
Signature/Date
Digitally signed by NICHOLAS
NICHOLAS BOBBS bobbs
Date: 2022.07.08 15:38:44 -04'00'
{Inspector name}
Date
Supervisor
Signature/Date
1 A IM PQ | P ATI—1 P RQ Digitally signed by JAMES LEATHERS
JMlVIt J LLM 1 rlLnj Date: 2022.07.08 15:24:04 -05'00'
{Supervisor name}
Date
6ENFORM-019-R8.2 (02/12/2020)
1
-------
EPA Inspection Report - Page 2 of 6
Lotte Chemical Louisiana LLC
Inspection Date 04/13/2022
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION
EPA inspectors Richard Helmich, Agustin Martinez, Ali Gitipour, and I, Nicholas Bobbs, and LDEQ
inspector Elena Mayard ("We", "Us") arrived at Lotte Chemical Louisiana, LLC (the "Facility", the "Site",
or "Lotte") at 8:00 AM on April 13, 2022 for an unannounced Clean Air Act ("CAA") inspection. We met
with Kaili Patterson, Environmental Supervisor, Heather Holbrook, Environmental Coordinator, and
Andrew Lavin, EHSS Manager. I presented my credentials to Kaili Patterson and informed her that this
was an EPA inspection to determine compliance with the facility's Title V Air Permit and the Clean Air
Act. The scope of the inspection is a partial compliance evaluation ("PCE") including a survey of the
facility using the Geospatial Measurement of Air Pollutants ("GMAP") Vehicle.
FACILITY DESCRIPTION
The Monoethylene Glycol ("MEG") plant, owned and operated by Lotte Chemical Louisiana, LLC (Lotte), is
a monoethylene glycol manufacturing facility. The Lotte plant has a companion facility which is an
Ethylene Plant operated by LACC, LLC US. The Lotte MEG plant and LACC Ethylene plant are adjacent to
each other and there is no physical barrier between the plants. The two plants share an environmental
staff and share some air pollution control equipment and a wastewater unit. The Lotte plant receives
ethylene feedstock from the LACC plant, as well as other sources, and oxidizes the ethylene in the
presence of a catalyst to make the intermediate product ethylene oxide (EO). The EO is then converted to
make MEG and higher homologue glycols - diethylene glycol (DEG) and triethylene glycol (TEG), by the
direct (non-catalytic) reaction of refined EO and water.
Section II - OBSERVATIONS
The GMAP surveyed the entire facility. The complete GMAP data can be found in the report for the April
2022 GMAP project.
MEG Unit
The GMAP vehicle surveyed the entire MEG unit. The GMAP vehicle detected elevated EO readings
downwind of the SW side of the MEG unit. [AOC 1] Facility personnel informed us that the SW section of
the plant is where EO is combined w/ water in long tube reactors to make glycols. Facility personnel also
told us that acetaldehyde is produced as byproduct of the EO to glycol reaction. The produced
acetaldehyde is sent to a blower and then to the MEG unit's thermal oxidizer. The facility personnel told
us that they monitor for EO using electro-chemical cell sensors, and that they've found that
acetaldehyde is an interferant for EO. The GMAP vehicle collected two summa cannisters concurrent
with EO spikes to verify the EO concentration.
The area of the MEG unit where the GMAP recorded elevated EO concentrations also contained an
enclosed process wastewater sump, labeled F-970. I observed steam and VOC emissions from two drains
that connect to the wastewater sump. [AOC 2] The sump drain under D-910, the knockout pot for the
2
-------
EPA Inspection Report - Page 3 of 6
Lotte Chemical Louisiana LLC
Inspection Date 04/13/2022
thermal oxidizer, had VOC emissions which I measured using a ppbRae PID. The highest total VOC
concentration seen from this sump drain using the PID was 113 ppm. Mr. Helmich recorded a video
using a FLIR GF320 camera, MOV-0186 at 11:23 AM, of the VOC emissions from the sump drain under D-
910. The sump drain under D-970 also had VOC emissions, and the highest total VOC concentration
measured with the PID was 70 ppm.
I recorded two videos using a FLIR GF306 camera. I recorded MOV_0172 at 9:40 AM of a large stack
connected to the boiler which provides steam to the plant. I recorded MOV_0173 at 9:48 AM of a stack
in the MEG unit. The MEG unit stack had a steam plume along with trailing VOCs. I recorded MOV_0174
at 10:06 AM of a shorter stack connected to the thermal oxidizer for the plant. A VOC plume was seen
from the thermal oxidizer stack.
Pygas Tanks
The GMAP vehicle detected elevated benzene concentrations downwind of tanks T-1806 and T-1807.
[AOC 3] Facility personnel informed us that these tanks both contained pygas (pyrolysis gasoline) and
that both tanks were internal floating roof tanks. The facility personnel also told us that all emissions
from tanks T-1806 and T-1807 are vented to the thermal oxidizer and flare. I surveyed the tanks using
the FLIR GF306 camera but did not identify any emission sources.
LACC Ethylene Plant
The GMAP vehicle surveyed the LACC ethylene manufacturing plant but did not have any notable
detections. Facility personnel informed us that the ethylene plant was currently shut down due to
turnaround activities.
Process Wastewater Storage Tanks
The GMAP vehicle surveyed the process wastewater storage tanks located directly south of the facility's
wastewater treatment unit. Facility personnel informed us that these tanks were temporary storage
tanks that contained process wastewater which was drained from the wastewater treatment unit's
equalizer tank and contained material from the chemical cleaning of the saturator. The GMAP vehicle
detected elevated benzene and total VOC concentrations downwind of the temporary wastewater
storage tanks. [AOC 4] There were approximately 12 temporary wastewater storage tanks. There was
one carbon filter for every two tanks. Mr. Helmich and I surveyed the wastewater storage tanks area
using the FLIR camera and PID but did not identify any specific sources. The PID detected elevated total
VOC concentrations in the wastewater storage tank area.
Section III - AREAS OF CONCERN
EPA inspectors Nicholas Bobbs, Richard Helmich, Agustin Martinez, and Ali Gitipour and LDEQ inspector
Elena Mayard conducted a closing conference at Lotte Chemical Louisiana, LLC at 12:00 PM on April 13,
2022 for the inspection. Facility representatives Kaili Patterson, Environmental Supervisor, Heather
3
-------
EPA Inspection Report - Page 4 of 6
Lotte Chemical Louisiana LLC
Inspection Date 04/13/2022
Holbrook, Environmental Coordinator, and Andrew Lavin, EHSS Manager were present during the
closing conference. During the closing conference, Inspector Bobbs reviewed the three Areas of Concern
noted during the inspection.
1) The GMAP recorded elevated ethylene oxide concentrations near MEG Unit
The GMAP vehicle recorded elevated ethylene oxide concentrations near the MEG unit. At the time of
this report we are waiting for confirmation of the ethylene oxide detections from the summa cannister
samples collected onsite.
2) The drains connected to the enclosed process wastewater sump was emitting VOCs
We identified two drains that connect to the process wastewater sump that were emitting VOCs. It is
unknown whether these emissions are represented in the facility's permit applications to LDEQ or the
facility's emissions inventory submittals to LDEQ. It is also possible that these emissions contributed to
the ethylene oxide detections identified in AOC 2.
3) The GMAP detected elevated benzene concentrations near Pygas tanks T-1806 and T-1807
The GMAP detected elevated benzene concentrations downwind of tanks T-1806 and T-1807. A specific
emission point on these tanks could not be identified with the monitoring equipment we had at the time
of the inspection. Upwind GMAP measurements confirmed that the benzene concentrations are not due
to another source upwind of the Pygas tanks.
4) The GMAP detected elevated benzene and total VOC concentrations near the temporary process
wastewater storage tanks
The GMAP detected elevated benzene and total VOC concentrations downwind of the temporary
process wastewater storage tanks. The facility personnel told us that the carbon filters attached to the
wastewater storage tanks are monitored for VOCs every 12 hours to check for breakthrough.
Section IV-FOLLOW UP
No additional information was received by EPA after exiting the Facility on April 13, 2022. Additional
information regarding the observations made by the GMAP at the facility can be found in the main
GMAP Project Report.
Section V - LIST OF APPENDICES
Appendix 1 - Video Log - 4 FLIR videos taken 04/13/22
4
-------
EPA Inspection Report - Page 5 of 6
Lotte Chemical/ Lotte Chemical
Inspection Date 04/13/2022
Appendix 1
Video Log
-------
EPA Inspection Report - Page 6 of 6
Appendix 1
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Video Log
Location: Lotte Chemical Louisiana LLC
City: Westlake
Calcasieu Parish
State: Louisiana
File Name: MOV_186.mp4
Date taken: 04/13/2022
Time taken: 11:23 am
Videographer: Richard Helmich
Description: OGI video of emissions from the sump drain under
D-910.
File Name: MOV_172.mp4
Date taken: 04/13/2022
Time taken: 9:40 am
Videographer: Nicholas Bobbs
Description: OGI video of emissions from a large stack connected
to the boiler which provides steam to the plant
File Name: MOV_173.mp4
Date taken: 04/13/2022
Time taken: 9:48 am
Videographer: Nicholas Bobbs
Description: OGI video emissions from of a stack in the MEG unit.
File Name: MOV_174,mp4
Date taken: 04/13/2022
Time taken: 10:06 am
Videographer: Nicholas Bobbs
Description: OGI video of emissions from a shorter stack
connected to the thermal oxidizer for the plant
Page 1 of 1
------- |