EPA Inspection Report - Page 1 of 6

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Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT

Inspection Date(s):

04/13/2022

Media Program:

Air

Regulatory Program(s)

Title V

Company Name:

Eagle US 2 LLC, a Westlake Chemical Company

Facility Name:

Lake Charles South - Eagle

Facility Physical Location:

1300 PPG Drive

(city, state, zip code)

Westlake, Louisiana 70669

Mailing address:

1300 PPG Drive

(city, state, zip code)

Westlake, Louisiana 70669

County/Parish:

Calcasieu Parish

Facility Phone Number

337-708-4688



Facility Contact:

Paula McCain

Environmental Manager

pmccain@westlake.com

FRS Number:

110000494894

Identification/Permit Number:

Al No. 1255/2040-V9

Media Identifier Number:

LA0000002201900004

NAICS:

325181, 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

EPA/ORD/CEMM/AMCD

Physical Scientist

Elena Mayard

LDEQ/OEC/SD

Inspector

Paula McCain

Westlake Chemical

Environmental Manager

Don Johnson

Westlake Chemical

Environmental Specialist



























EPA Lead Inspector
Signature/Date

M.run. AC DHRRQ Digitally signed by NICHOLAS BOBBS
IMILrlULMj DUDDj Date:2022.07.0815:35:19~04'00'



{Inspector name}

Date

Supervisor
Signature/Date

IAMFQ I C AT|_|FDC Digitally signed by JAMES LEATHERS
JMIVICj LCM I ntnj Date: 2022.07.08 15:00:59-OS'OO'



{Supervisor name}

Date

6ENFORM-019-R8.2 (02/12/2020)

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EPA Inspection Report - Page 2 of 6

Eagle US 2 LLC / Lake Charles South
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 Eagle US 2 LLC/Lake Charles South (the "Facility", the
"Site", or "WLCS") at 8:00 AM on April 13, 2022 for an unannounced Clean Air Act ("CAA") inspection.
We met with Paula McCain, Environmental Manager, and Don Johnson, Environmental Specialist. I
presented my credentials to Mrs. McCain 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. This inspection occurred as part of the
Administrator's Multi-Scale Monitoring Project called the Pollution Accountability Team (PAT).

FACILITY DESCRIPTION

The Lake Charles South facility is owned and operated by Eagle US 2 LLC, which is wholly owned by
parent company Westlake Chemical. The facility is a chemical manufacturing facility which produces
chlorine, caustics, chlorinated derivatives, and solvents, along with other chemicals.

Section II - OBSERVATIONS

The GMAP surveyed the entire facility. The complete GMAP data can be found in the GMAP R6 Pollution
Accountability Team FY2022 report for the April 2022 GMAP project.

Plant A

The GMAP detected elevated VOCs near the halogenated hydrocarbon tank farm. [AOC 1] I recorded
FLIR video MOV_0157 of VOC emissions coming from the area of the tank farm. I recorded FLIR video
MOV_0158 of VOC emissions coming from the stack of the Plant A Powerhouse. It is unknown if the
GMAP detections were due to emissions from the Plant A Powerhouse or a source in the halogenated
hydrocarbon tank farm.

Plant B

The GMAP detected elevated concentrations of VOCs on Ave H, downwind of the "PerTri" process area.
[AOC 2]

Plant C

The GMAP detected elevated concentrations of methane downwind of the natural gas breakout south
of Plant C. I recorded FLIR videos MOV_0153, MOV_0154, MOV_0155 and MOV_0156 at around 4:10
pm. Mr. Helmich recorded FLIR videos MOV_0187 and MOV_0188 at the same time. We observed
several leaks using the FLIR GF320 cameras in the natural gas breakout, including leaks from wheel
valves, pilot valves, and gages. [AOC 3] We identified the leaking components to the facility personnel.

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EPA Inspection Report - Page 3 of 6

Eagle US 2 LLC / Lake Charles South
Inspection Date 04/13/2022

Section III - AREAS OF CONCERN

EPA inspectors Richard Helmich, Agustin Martinez, Ali Gitipour, and I, Nicholas Bobbs, and LDEQ
inspector Elena Mayard conducted a closing conference at Eagle US 2 LLC/Lake Charles South at 5:00 PM
on April 14, 2022 for the inspection. During the closing conference, I reviewed the 3 Areas of Concern
noted during the inspection.

AOC 1 - Elevated VOCs downwind of Powerhouse A and halogenated hydrocarbons tank farm

The GMAP detected elevated VOCs downwind of Powerhouse A and the halogenated hydrocarbons tank
farm. OGI showed a significant VOC plume from the Powerhouse A stack. There may also be a source
within the halogenated hydrocarbon tank farm that contributed to the GMAP detection.

AOC 2 - Elevated VOCs downwind of PerTri process area

The GMAP detected elevated VOCs downwind of the PerTri process area. Facility personnel told me
that this process area appeared to have some maintenance activities being performed during the
inspection.

AOC 3 - Elevated methane downwind of Plant C natural gas pipeline breakout

The GMAP detected elevated methane downwind of the natural gas pipeline breakout on the south end
of Plant C. We observed several leaks with OGI from various valves in the breakout area. We identified
the leaking components to the facility personnel and they started taking action to fix the leaking
components.

Section IV-FOLLOW UP

No additional information was received by EPA after exiting the Facility on April 13, 2022.

Section V - LIST OF APPENDICES

Appendix 1 - Video Log - 8 FLIR videos taken 04/13/2022

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EPA Inspection Report - Page 4 of 6

Westlake Chemical/ Lake Charles South, Eagle
Inspection Date 04/13/2022

Appendix 1
Video Log


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EPA Inspection Report - Page 5 of 6





Appendix 1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Video Log

Location: Westlake Chemical South Eagle

City: Westlake

Calcasieu Parish

State: Louisiana

File Name: MOV_153.mp4
Date taken: 04/13/2022
Time taken: 4:10 pm
Videographer: Nicolas Bobbs

Description: OGI video of emissions from leaking components in
Plant C

File Name: MOV_154.mp4
Date taken: 04/13/2022
Time taken: 4:10 pm
Videographer: Nicholas Bobbs

Description: OGI video of emissions from leaking components in
Plant C

File Name: MOV_155.mp4
Date taken: 04/13/2022
Time taken: 4:10 pm
Videographer: Nicholas Bobbs

Description: OGI video of emissions from leaking components in
Plant C

File Name: MOV_156.mp4
Date taken: 04/13/2022
Time taken: 4:10 pm
Videographer: Nicholas Bobbs

Description: OGI video of emissions from leaking components
in Plant C

File Name: MOV_157.mp4

Page 1 of 3


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EPA Inspection Report - Page 6 of 6





Appendix 1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Video Log

Location: Westlake Chemical South Eagle

City: Westlake

Calcasieu Parish

State: Louisiana

Date taken: 04/13/2022
Time taken: 9:00 am
Videographer: Nicolas Bobbs

Description: OGI video of emissions from area of the tank farm

File Name: MOV_158.mp4
Date taken: 04/13/2022
Time taken: 9:30 am
Videographer: Nicholas Bobbs

Description: OGI video of emissions from the stack of power
house A

File Name: MOV_187.mp4
Date taken: 04/13/2022
Time taken: 4:10 pm
Videographer: Nicholas Bobbs

Description: OGI video of emissions from leaking components
in Plant C

File Name: MOV_188,mp4
Date taken: 04/13/2022
Time taken: 4:10 pm
Videographer: Nicholas Bobbs

Description: OGI video of emissions from leaking components
in Piant C

Page 2 of 2


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