EPA Inspection Report - Page 1 of 10
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Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s):
04/21/2022
Media Program:
Air
Regulatory Program(s)
Title V
Company Name:
Americas Styrenics LLC
Fac
lity Name:
St. James Plant
Fac
lity Physical Location:
9901 Hwy 18
(c
ty, state, zip code)
St. James, LA, 70086
County/Parish:
St. James Parish
Facility Phone Number
(225)331-3200
Facility Contact:
David Thomas
Health, Safety and Environmental (HSE)
DThomasPamstv.com
FRS Number:
110056954602
Identification/Permit Number:
PSD-LA-551 (M14), Title V: 2560-00007-V17
Media Identifier Number:
AFS 22-093-00013
NAICS:
325110
SIC:
2865
Personnel participating in inspection:
Sarah Frey
EPA ECD-AT
Inspector
Christopher Williams
EPA-OECA-AED
Chemical Engineer
Richard Helmich, Ph.D.
EPA NEIC
Chemist
David Mahoney
EPA NEIC
Technical Coordinator
Ali Gitipour, Ph.D.
EPAORD
Chemical Engineer
Sophia Ong
LDEQ
Environmental Scientist
Durrell Morris
Americas Styren
cs
Environmental Specialist
Sam Duplessis
Americas Styren
cs
Shift Supervisor
David Thomas
Americas Styren
cs
Environmental Compliance Manager
EPA Lead Inspector
Signature/Date
^SoamJL
a
7/12/2022
Sarah Frey ^
Date
Supervisor
Signature/Date
1 A MFQ 1 C ATUCDC Digitally signed by JAMES LEATHERS
JMlVltl J LlM 1 ntirO Date: 2022.07.15 16:25:19-05 00'
James Leathers
Date
6ENFORM-019-R8.2 (02/12/2020)
1
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EPA Inspection Report - Page 2 of 10
Americas Styrenics LLC - St. James Plant
Inspection Date 04/21/2022
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION
EPA inspectors Sarah Frey (Region 6) and Chris Williams (Headquarters) accompanied by Richard
Helmich (National Enforcement Investigations Center, "NEIC"), David Mahoney (NEIC), and Ali Gitipour
(Office of Research and Development) arrived at the Americas Styrenics LLC - St. James Plant ("AmSty")
at 3:30 pm on April 21, 2022 for an unannounced inspection. We were accompanied by Louisiana
Department of Environmental Quality inspector Sophia Ong. After watching a safety video in the lobby,
we met with Mr. Durell Morris, Environmental Specialist Waste/Water, Sam Duplessis, Shift Supervisor,
and David Thomas, Environmental Compliance Manager (by phone). Credentials were presented to Mr.
Morris and we informed him that this was an EPA inspection to evaluate potential sources of excess
emissions using EPA's Geospatial Measurement of Air Pollution ("GMAP") vehicle and evaluate
compliance with the facility's Title V Permit and the Clean Air Act. The scope of the inspection is a partial
compliance evaluation ("PCE"). This inspection occurred as part of the Administrator's Multi-Scale
Monitoring Project called the Pollution Accountability Team ("PAT").
FACILITY DESCRIPTION
The St. James Plant produces styrene via continuous process. The facility consists of an ethyl benzene
("EB") unit, two (2) styrene monomer ("SM") units, and associate utilities, storage, and loading facilities.
The EB unit produces EB from benzene and ethylene using an alkylation process. At the SM units, EB is
dehydrogenated to produced styrene. Crude styrene is purified by vacuum distillation. The gas-fired
process heaters supply the heat for reaction and regeneration. The steam from the boilers provides heat
for the distillation operations. Fuels for combustion sources are natural gas, vent gas, and a mixture of
polyethylbenzene, diethylbenzene, and styrene residues. According to Mr. Duplessis, the facility has less
than 200 employees.
The St. James Plant is a chemical manufacturing plant that operates under Permit Number 2560-00007-
V17 issued October 19, 2021 and Permit Number PSD-LA-551 (M14) issued February 11, 2022.
Section II - OBSERVATIONS
The NEIC GMAP was driven by Mr. Mahoney and the instruments were operated by Mr. Helmich and
Mr. Gitipour. A facility representative, Mr. Morris, was present in the GMAP. Conditions were sunny
with no cloud cover and moderate winds coming from the northeast to east. Inspectors Dr. Frey, Mr.
Williams, and Ms. Ong were escorted by Mr. Duplessis in a secondary vehicle. The GMAP drove on all
available plant roads measuring air pollutant concentrations downwind of each of the process areas
accessible by road. A full report from the GMAP will be issued by NEIC at a later date.
Downwind of the storage tanks adjacent to tank MF3100, benzene emissions were detected between 30
and 40 parts per billion ("ppb") above baseline.
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EPA Inspection Report - Page 3 of 10
Americas Styrenics LLC - St. James Plant
Inspection Date 04/21/2022
Downwind of the condensate pumps labeled 4220S and 4220A ("Condensate Pumps"), on the west side
of the SM2 process area, the GMAP detected elevated concentrations of volatile organic carbon ("VOC")
around 23,000 ppb and benzene around 1,000 ppb. Mr. Williams, Dr. Frey, Ms. Ong, and Mr. Duplessis
exited the vehicle to inspect the process area, and the mobile air monitoring vehicle continued to
monitor while driving the road located alongside the Condensate Pumps. Mr. Williams observed a sweet
odor characteristic of benzene when he approached the Condensate Pumps. Mr. Duplessis confirmed
that the odor "smells like benzene," however he indicated that there is no benzene used in the SM2
process area. Mr. Williams observed condensing vapors emitting from two pipe outlets located
alongside the Condensate Pumps. Mr. Williams directed the mobile air monitoring vehicle to a position
directly adjacent to and downwind of the vapor outlets. GMAP detected higher concentrations of VOC
(approximately 42,000 ppb) and benzene (approximately 10,000 ppb) at the location. Mr. Helmich noted
that the reading of 10,000 ppb benzene is above the calibration range of the instrument, so its accuracy
cannot be determined. Mr. Helmich took air canister samples (NEIC4618, ORD12159, and NEIC00279) at
different locations in the plume. Mr. Williams inquired about the source of the vapor outlets. Mr.
Duplessis explained that the facility uses steam in the distillation and regeneration process and that the
vapor outlets were for the process steam. Mr. Duplessis further explained that it was possible benzene
could be entering the steam stream through cracks in the process and that he would have "to confirm
with engineering." Using an optical gas imaging camera ("OGI"), Mr. Williams recorded videos MOV_179
and MOV_ 180 of emissions from the vapor outlets. In high sensitivity mode, Mr. Williams observed a
plume characteristic of hydrocarbons emanating from the vapor outlet in MOV_180. [AOC 2],
Adjacent to the cooling towers and downwind of a tank referred to by Mr. Duplessis as the "DAF Tank",
GMAP detected concentrations of methane greater than 100 parts per million ("ppm") and benzene
around 95 ppb. Mr. Williams, Ms. Ong, and Mr. Duplessis exited the vehicle to inspect the process area,
and the mobile air monitoring vehicle continued to survey the road alongside the DAF Tank and the
boilers. According to Mr. Duplessis the DAF Tank is no longer operating as a Dissolved Air Floatation
("DAF") tank. Currently, the DAF Tank is used as a reservoir to store treated process water prior to
discharge. While inspecting the DAF Tank, Mr. Williams observed a rotten egg odor characteristic of
sulfur and noted that the tank was almost full of liquid. [AOC 3], Mr. Williams observed several process
boilers upwind of the DAF tank. Mr. Duplessis said that the process boilers combust natural gas to
generate heat for the process operations. Using OGI, Mr. Williams recorded significant emissions from
three boiler exhaust stacks as video MOV_181. [AOC 4], No elevated emissions of methane or benzene
were detected by GMAP while positioned upwind of the boiler area and DAF tank.
Downwind of the Inhibitor Storage Building, GMAP detected elevated concentrations of VOC ranging
from 1500 to 7500 ppb, benzene ranging from 40 to 200 ppb, and toluene ranging from 35 to 100 ppb.
Mr. Williams, Dr. Frey, Ms. Ong, and Mr. Duplessis exited the vehicle to inspect the process area, and
the GMAP continued to monitor while driving along the roads around the Inhibitor Storage Building.
The building was a partial enclosure for tanks, piping and process equipment. Mr. Williams could see
into the building and observed tools and other maintenance equipment on the ground. Mr. Williams
observed a glue-like odor characteristic of epoxy while downwind of the building. There was a sign in
front of the building indicating the presence of Butyldinitrophenol ("DNBP") was contained in the area
and that Class B safety equipment is necessary to enter the enclosure. Mr. Williams did not enter the
Inhibitor Storage Building. Mr. Helmich took an air canister sample (NEIC4601) while positioned in the
plume downwind of the Inhibitor Storage Building. [AOC 5],
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EPA Inspection Report - Page 4 of 10
Americas Styrenics LLC - St. James Plant
Inspection Date 04/21/2022
The site tour ended at 6:05 P.M. and we returned to the conference room.
Section III - AREAS OF CONCERN
Richard Helmich, Sarah Frey, and Chris Williams conducted a closing conference at Americas Styrenics
LLC - St. James Plant at 6:20 P.M. on April 21, 2022 for the inspection. Am Sty representatives Mr.
Morris, Mr. Duplessis, Mr. Thomas (via phone), Mr. Ben Brignac, Operations Coordinator and Mr. Jacob
LaSavia, Plant Manager were in attendance. Mr. Williams explained that at around 4:45 P.M. on Monday
April 18, 2022, while driving along the fence line that is adjacent to a sugar cane field and downwind of
the storage tanks, GMAP detected above background concentrations of VOC and benzene at ground-
level. These recordings on suggested that the Am Sty facility was contributing to elevated ambient
concentrations of benzene measured offsite. Mr. Helmich and Mr. Williams summarized the plant tour
and presented their emissions observations, including the following Areas of Concern. The facility made
no claims of confidential business information regarding the three OGI videos recorded. Dr. Frey stated
she would make copies of the videos available to the facility following the inspection. We departed the
facility at 6:55 P.M.
1) Downwind of the benzene storage area, concentrations of benzene were detected between 30 and 40
ppb. The tanks may need closer inspection to identify potential defects and minimize emissions.
2) On the west side of the SM2 process area, concentrations of VOC and benzene were detected at high
levels. VOC reached as high as 42,500 ppb (42.5 ppm) and benzene was detected between 400 and 1,000
ppb and higher, exceeding the instrument's calibration range. Inspectors were told that the SM2 process
does not use benzene. One source may be benzene that has leaked into the steam lines and was being
released from the condensate pumps. These concentrations of benzene could be hazardous to workers
and could be detrimental to the ambient air.
3) Near the Dissolved Air Floatation ("DAF") tank, strong sulfur odors were detected by Mr. Williams. In
addition, the GMAP recorded concentrations of benzene ranging from 40 to 200 ppb. The benzene
detected could be related to AOC #2 or coming from a nearby source. The DAF tank may need to be
evaluated for contaminents before discharging.
4) Downwind of the process boilers, concentrations of methane were detected greater than 100 ppm.
The boilers may be experiencing efficiency issues.
5) Downwind of the Inhibitor Storage Building, the GMAP detected elevated concentrations of VOC
ranging from 1500 to 7500 ppb, benzene ranging from 40 to 200 ppb, and toluene ranging from 35 to
100 ppb. Inspectors could not enter the area to investigate potential sources. The DNBP building may
need further evaluation.
Section IV-FOLLOW UP
On May 2, 2022, Dr. Frey provided electronic copies of the videos recorded during the inspection to Mr.
Morris.
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EPA Inspection Report - Page 5 of 10
Americas Styrenics LLC - St. James Plant
Inspection Date 04/21/2022
On May 2, 2022, an informal conference call was held between Dr. Frey of EPA and Am Sty
representatives Mr. Thomas, Mr. Morris, and Ms. Kristen Newman. During this call, Am Sty provided the
following information:
• Stack tests were performed at the boilers during the 3rd quarter of 2021 and no problems were
identified at that time. The potential source of the methane may be the DAF tank itself.
• Am Sty has started the process of conducting area monitoring for VOCs and Benzene at the
fenceline. Am Sty offered to share the results of the monitoring with EPA at a f utu re date.
• Maintenance activities at the DNBP building had been completed a few hours prior to the arrival
of the inspection team and they believe no ongoing issues exist in the area.
• The boilers, EB unit, and SMI unit have been shutdown since April 26th due to an operational
issue related to the boilers. It was anticipated that the shutdown would last several weeks.
On May 3, 2022, Am Sty submitted a written notification to the State of Louisiana regarding a unit
shutdown and benzene leak. A copy of the letter can be found in Appendix 2. The notification mentions
EPA's identification of a benzene leak on April 21, 2022. On Tuesday, April 26, 2022, a boiler upset
triggered the shut down of 4 of the 6 boilers. A fifth boiler was already shutdown for repair. These
outages caused all three process units to "trip" and shutdown. During restart of the EB unit, benzene
was detected. On Wednesday, April 27, 2022, the EB unit was shutdown to address the benzene leak.
On that date, Am Sty reported that benzene had leaked into the steam system around 6am. The letter
states that the leak was stopped by 4pm on April 27th. The total estimated amount of benzene released
is 267 pounds, from April 21 to April 27. The National Response Center was notified on April 29, 2022.
On May 9, 2022, Mr. Morris sent an email update to Dr. Frey.
• A leadership meeting was help on April 25, 2022 in response to the EPA inspection to make a
plan to determine the potential root cause of the leaks identified by EPA.
• AmySty staff monitored the area around the DAF tank using a 4-gas meter and optical gas
imaging camera. No elevated H2S or methane was located.
• The DNBP area was evaluated on April 22, 2022, and it is still believed that there are no ongoing
issues. As a precaution, carbon canisters were placed on the frac tanks and Method 21 was
performed on the frac tanks and carbon canisters.
Section V - LIST OF APPENDICES
Appendix 1 - Photo and Video Log - 3 OGI videos taken April 21, 2022.
Appendix 2 - Follow-Up Notification Report, Incident Number 22-02200 from Am Sty to the
Department of Public Safety and Corrections, May 3, 2022.
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EPA Inspection Report - Page 6 of 10
Americas Styrenics / St. James Plant
Inspection Date 04/18/2022
Appendix 1
Video Log
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EPA Inspection Report - Page 7 of 10
Appendix 1
' \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
" Video Log
\ /
pro^
Location: Americas Styrenics St. James Plant
City: St. James
St. James Parish
State: Louisiana
File Name: MOV_179.mp4
Date taken: 04/21/2022
Time taken: 5:00 pm
Videographer: Christopher Williams
Description: OGI video of emissions from condensing vapor
outlets near Condensate Pumps for AS4202.
File Name: MOV_180.mp4
Date taken: 04/21/2022
Time taken: 5:02 pm
Videographer: Christopher Williams
Description: OGI video of emissions from a condensing vapor
outlet near Condensate Pumps for AS4202.
File Name: MOV_181.mp4
Date taken: 04/21/2022
Time taken: 5:20 pm
Videographer: Christopher Williams
Description: OGI video emissions from boiler exhaust stacks.
Page 1 of 1
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EPA Inspection Report - Page 8 of 10
Americas Styrenics / St. James Plant
Inspection Date 04/18/2022
Appendix 2
Follow-Up Notification Report, Incident Number 22-02200
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EPA Inspection Report - Page 9 of 10
^AmSty
Jacob L. LaSavia
Plant Manager
Americas Styrenics LLC
9901 Highway 18
St. James, LA 700H6
Phone: 225.331 3332
Fax; 2253313319
jLLasoviQiipatmty.com
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;>/
May 3, 2022
Certified Mail Receipt # 7020 1290 0000 3493 3399
Department of Public Safety and Corrections
Office of State Police
TESS/Right-to-Know Unit
P.O. Box 86168
Baton Rouge, IA 70896
RE: Follow-up Notification Report
Incident Number: 22-02200
LDEQ Agency Interest No.: 2384
Dear Sir or Madam:
In accordance with Louisiana Administrative Code (LAC) 33:1.3925 and R,S.
32:1510, Americas Styrenics LLC - St, James Plant (Americas Styrenics),
hereby submits its written notification report regarding a unit shutdown and
a benzene leak that occurred on April 27, 2022. The initial, verbal
notification was made to the Louisiana State Police (LSP) representative
Daria, who assigned the incident number 22-02200. Americas Styrenics also
notified the St. James Parish Emergency Operations Center (EOC). The
National Response Center (NRC) was notified on April 29, 2022. The release
did not cause any injuries or offsite impact.
RECEIVED
ON
my' v m
pv
LDEG/SPOC
During an inspection by USEPA on Thursday, April 21, 2022, a benzene leak
was identified within an operating area of the facility. Americas Styrenics
initiated routine area monitoring for personnel safety and to identify the
source of the benzene emissions, On Tuesday, April 26, 2022, at
approximately 1400 hours, one of Americas Styrenics' six boilers tripped
upsetting the steam system and causing three more boilers to shut down.
One of the six boilers was already shutdown for repairs. The sudden loss of
steam caused all three process units to immediately trip and shutdown.
During restart of the EB Unit on the night shift, operations personnel
detected higher benzene emissions during monitoring. On Wednesday, April
27, 2022, it was decided by facility management to completely shutdown the
Ethylbenzene (EB) to address the leak. Mr. Sam Duplessis provided verbal
notification to the Louisiana State Police {LSP} that, at approximately 0611
hours, there was an unauthorized release of benzene (CAS# 71-43-2) into the
steam. All personnel were removed from the area during shutdown.
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EPA Inspection Report - Page 10 of 10
May 3, 2022
Follow-up Notification
Incident Number: 22-02200
Agency Interest No.: 2384
All personnel responding to the leak donned the proper personal protective equipment. Area and fence
line monitoring were conducted by operations personnel. Regular updates were provided to LSP until
the leak was stopped. The leak was stopped and secured by approximately 1600 hours on Wednesday,
April 27, 2022.
Based on review of the available data, Americas Styrenics determined that the leak likely started on April
21, 2022 and was aggravated by the process unit upset on April 26, 2022. The total estimated amount of
benzene released since April 21, 2022 was approximately 26? pounds. This release exceeded the
Reportable Quantity threshold for benzene,
It is always Americas Styrenics' intent to always operate our Plant in a safe and environmentally
responsible manner. If you have any questions or require additional information regarding this matter,
please contact Ms. Kristen Newman at (225) 331-3242 or electronically at knewman@amsty.com.
Jacob I, LaSavia
cc/Mrs, Celena Cage, Assistant Secretary
^ Louisiana Department of Environmental Quality
Office of Environmental Compliance/SPOC
Post Office Box 4314
Baton Rouge, LA 70821-4341
UNAUTHORIZED DISCHARGE NOTIFICATION REPORT
Certified Mail Receipt # 7020 1290 0000 3493 3405
St. James Parish Emergency Operations Center
Post Office Box 106
Convent, LA 70723-0108
Certified Mail Receipt # 7020 1290 0000 3493 3412
Sincerely,
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