UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: CLEAN AIR ACT INSPECTION REPORT Vopak Industrial Infrastructure Americas St. Charles, LLC, Hahnville, Louisiana FROM: Victoria Nelson, Environmental Engineer AECAB (MI/WI) THRU: Sarah Marshall, Section Supervisor AECAB (MI/WI) TO: File Basic Information Facility Name: Vopak Industrial Infrastructure Americas St. Charles, LLC (Vopak) Facility Location: 355 LA Highway 3142, Hahnville, Louisiana Date of Inspection: April 21, 2022 EPA Inspectors: 1. Victoria Nelson, Environmental Engineer 2. Karina Kuc, Environmental Engineer Other Attendees: 1. Charles Cuti, Union Carbide Corporation, Leveraged Air Specialist 2. Brandt Dufrene, Vopak, Site Supervisor 3. Clarence McGee, Vopak, Terminal Operator 4. Tyrone Wheaten, Think Environmental, LDAR Technician 5. Alex LeDet, Vopak, Terminal Manager (only present during the Closing Conference) 6. Frank, Fazio, Vopak, Environmental Engineer (only participated by phone during the Closing Conference) Contact Email Address: Frank Fazio - Frank.fazio@vopak.com Purpose of Inspection: To evaluate compliance with the Clean Air Act Facility Type: Chemical and Wastewater Storage Tank Terminal ------- Regulations Central to Inspection: National Emission Standards for Benzene Waste Operations, 40 C.F.R. Part 61, Subpart FF Arrival Time: 9:00 AM CT Departure Time: 1:45 PM CT Inspection Type: M Unannounced Inspection ~ Announced Inspection Opening Conference M Presented Credentials M Stated authority and purpose of inspection M Small Business Resource Information Sheet not provided. M Provided CBI warning to facility The following information was obtained verbally from Brandt Defrene and Clarence McGee unless otherwise noted. Company Ownership: Vopak became the owner and operator of the terminal supporting the adjacent Union Carbide Corporation (UCC) facility in December 2020. Process Description: Vopak is co-located with and stores raw materials, product, and benzene-containing wastewater for the UCC facility in Hahnville, Louisiana. Vopak operates three external floating roof tanks to store benzene-containing wastewater from the UCC facility. Product storage includes two propane bullet tanks and two propylene bullet tanks. Other storage at the facility includes methyl carbitol, methyl aery I ate, methanol, and butyl acrylate. Staff Interview: Several tanks on-site have been refurbished and brought back into service, including Tanks 2109, 2210, 2220, and 2230. Tank 2301 contains ethylenediamine and is controlled by a water scrubber. Tanks 1301,1311, 1321, and 1331 store benzene-containing wastewater from the UCC facility. Think Environmental conducts leak detection and repair (LDAR) requirements for both Vopak and UCC facilities. According to Alex LeDet: Tank 1331 was refurbished and is still undergoing installation of new equipment. It was brought back into service in July 2021. The stilling well at Tank 1331 is fitted with a slotted emissions sleeve that is open to atmosphere by design. A level meter will be installed at the top, but the pipe connecting to the external floating roof was left open at the time of the inspection. Page 2 of 5 ------- Tank 1331 was 17 percent full at the time of the inspection. Tank 2337 stores butyl acrylate and was loaded the day before the inspection. Interview of Dennis Fleming, Site Supervisor and Irving Range, Operations Manager with Think Environmental on April 19, 2022: Think Environmental staff perform LDAR monitoring for the Vopak facility, as well as for the UCC facility. Think Environmental LDAR Technicians use ThermoFisher Toxic Vapor Analyzer 1000 flame ionization detectors (TVA 1000) to conduct EPA Method 21 monitoring. Prior to use, each TVA 1000 is calibrated using methane span gases of 500,1,000, 5,000, and 10,000 parts per million (ppm). EPA reviewed calibration records that showed past use of isobutylene calibration gases. In April 2021, Think Environmental technicians switched from using Phoenix 21 photo ionization detectors to the TVA 1000 FID. Tour Information EPA Tour of the Facility: Yes Data Collected and Observations: As detailed in Appendices A and B, EPA inspectors observed organic emissions at four storage tanks operated by Vopak using the FLIR GFx-320 and a flame ionization detector (FID). Think Environmental LDAR Technician, Tyrone Wheaten, confirmed EPA's FID readings using the FID regularly used for LDAR monitoring conducted on-site. EPA observed wastewater Storage Tank 1301 with organic emissions venting from one of the tank legs, however, due to an equipment malfunction the video is unrecoverable. EPA and Think Environmental were unable to access the venting Tank 1301 tank leg to monitor with a FID due to the external roof being classified as a confined space. Photos and/or Videos: were taken during the inspection. EPA inspectors recorded videos using the FLIR GFx-320. Field Measurements: were taken during this inspection. EPA inspectors collected organic emissions data using a FID. Records Review 1. Storage Tank Inventory Closing Conference M Provided U.S. EPA point of contact to the facility Requested documents: • Work orders documenting the repair of Storage Tanks 1301,1331, and 2337 Compliance Assistance: EPA recommended repair of the emissions observed from Tank 1301 and other leaks observed from equipment in Vopak's LDAR program, as detailed in Appendix B. Page 3 of 5 ------- Concerns: EPA noted that the benzene wastewater storage tanks should not be emitting from the external floating roof. Digital Signatures VICTORIA Report Author: NELSON Digitally signed by VICTORIA NELSON Date: 2022.05.16 11:43:26 -05'00' SARAH Digitally signed by Section Supervisor: MARSHALL SARAH MARSHALL Date: 2022.05.16 12:09:26 -05'00' Page 4 of 5 ------- Facility Name: Vopak Industrial Infrastructure Americas St. Charles, LLC Facility Location: 355 LA Highway 3142, Hahnville, Louisiana Date of Inspection: April 21, 2022 Appendices and Attachments ?, Appendix A: Digital Video and Image Log 2, Appendix B: EPA Monitoring Results and Calibration Information Page 5 of 5 ------- Facility Name: Vopak Industrial Infrastructure Americas St. Charles, LLC Facility Location: 355 LA Highway 3142, Hahnville, Louisiana Date of Inspection: April 21, 2022 Appendix A: Digital Video and Image Log 1. Inspector Name: Karina Kuc 2. Archival Record Location: Region 5 Electronic Records Center Video Number File Name Date and Time (Central Time)* Description of Image 1 MOV_0237.mp4 FLIR malfunction - video unrecoverable 4/21/2022 11:34:00 AM Organic emissions from the tank leg of the external fIoating roof of Tank 1301 2 MOV_0238.mp4 FLIR malfunction - video unrecoverable 4/21/2022 11:35:00 AM Organic emissions from the tank leg of the external f I oati ng roof of Tank 1301 3 DC_0242jpg 4/21/2022 12:42:00 PM Photo of the top of the slotted emission sleeve 4 MOV_0243.mp4 4/21/2022 12:42:00 PM Slotted emissions sleeve for the stilling well at the Tank 1331 external floating roof "The time reflected on the timestamp is an hour later than the video was recorded. Appendices Page 1 of 3 ------- Facility Name: Vopak Industrial Infrastructure Americas St. Charles, LLC Facility Location: 355 LA Highway 3142, Hahnville, Louisiana 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 Process Equipment and Wastewal .er Transfer Points Location Notes EPA Inspector EPA Reading (ppm) Think Environmental Reading (ppm) Top of Tank 1301 Background reading Victoria N. 3 — Base of Tank 1301 Background reading Victoria N. 0.3 __ Top of Tank 1331 Open stilling well connected to the top of the external floating roof through a slotted emissions sleeve Victoria N. 19 Manway R50172 at top of Tank 2337 Tank 2337 had been loaded the day before Victoria N. 4,000 Flame out OEL near Valve D1880 OEL on propylene line operated and monitored by UCC. Victoria N. 2,700 2,500 Valve 26812 Valve on Propane Discharge Line Victoria N. 860 925 OEL below Valve 26663 OEL at line from Safety Valve Discharge. The Safety Valve Discharge is routed back into the tank. Victoria N. > 30,000 33,000 Legend: OEL - Open-ended valve or line Appendices Page 2 of 3 ------- Facility Name: Vopak Industrial Infrastructure Americas St. Charles, LLC Facility Location: 355 LA Highway 3142, Hahnville, Louisiana Date of Inspection: April 21, 2022 Calibration and Instrument Information EPA used one ThermoFisher Toxic Vapor Analyzers 2020 (TVA2020). The EPA TVA2020 response times are in the 4 to 5 second range. During the inspection, Tyler Wheaten, Think Environmental LDAR Technician, used a flame ionization detector (FID), model ThermoFisher Toxic Vapor Analyzer 1000, to confirm EPA's readings. All readings were collected on April 21, 2022. Victoria Nelson used TVA2020 ID: SL1555 for the duration of the survey. Table 2. Instrument Calibration April 21, 2022 SL1555 Reading (ppm) 10:30am Calibration Reading, 500 ppm 495 10:30am Calibration Reading, 10,000 ppm 10,300 1:36pm Drift Check, 500 ppm 512 1:36pm Drift Check, 10,000 ppm 10,200 Table 3. Calibration Gases Manufacturer Composition Lot# Expiration TG Technical Services Zero air TDBJ-1-22 3/27/2023 TG Technical Services Methane, 500 ppm TDBJ-150A-500-11 3/27/2023 TG Technical Services Methane, 1% TIBJ-135A-1-1 8/21/2023 Appendices Page 3 of 3 ------- |