AFS Number: 

Permit Number: 

Inspection Type: 

Inspection Date: 

Company Name: 

Facility Name: 

Physical Location: 

Mailing Address: 

County/Parish: 

SIC Code: 

NAICS Code: 

Reg. Programs 

Facility 

Representative(s): 

EPA Inspector(s): 

State lnspector(s): 

EPA Lead 

Inspector 

Signature/Date 

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2203300018 

0840-00018-V8 

Clean Air Act - Partial Compliance Evaluation 

June 11 - 13, 2013 

EXXONMOBIL CHEMICAL COMPANY 

BATON ROUGE PLASTICS PLANT 

11675 Scotland-Zachary Highway (Louisiana 19) 

Baton Rouge, LA 70821-1607 

P.O. BOX 1607 

Baton Rouge, LA 70821-1607 

East Baton Rouge Parish 

2821 (Plastics Materials, Synthetic Resins and Nonvulcanizablc Elastomers) 

325211 (Plastics Material and Resin Manufacturing) 

Title V 

Pat A. Carrasco Sr. Env. Coordinator (225) 977-6464 

Erin C. Hall Env. Specialist (225) 977-6329 

Craig Lutz 6EN-AT Engineer (2 14) 665-2 190 

Dorothy Crawford 6EN-AT Engineer (214) 665-2771 

Jennifer Gibbs 6EN-AT Environmental Scientist (214) 665-7347 

Greg Valentine 6EN-AT Environmental Scientist (214) 665-3111 

Cory Lormand . Capital Region CAA Inspector (225) 219-3040 

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11675 Scotland-Zachary Highway (Louisiana 19) in Baton Rouge, Louisiana. The inspection 

was conducted under the authority granted by Section 114 of the CAA. The purpose of the 

inspection was to survey all operating process units to locate excess emissions from leaks, 

unpermitted releases, or other discharges to ambient air that do not conform with permit 

requirements. During the inspection, we used the following monitoring equipment to locate 

emissions: 1) FLIR® Infrared cameras (IR cameras), 2) Ion Science® PhoCheck Tiger® 

Photoionization Detectors (PIDs), and 3) Thermo Scientific® Toxic Vapor Analyzers (TV As) 

10008. 

Upon entry, Mr. Craig Lutz, Ms. Dorothy Crawford, Ms. Jennifer Gibbs, and I (Mr. Greg 

Valentine) proceeded to the guardhouse to check in, obtain visitor badges, and view the required 

safety video. We were joined there by Mr. Cory Lormand, Louisiana Department of 

Environmental Quality (LDEQ) CAA inspector. Mr. Pat A. Carrasco, Senior Environmental 

Coordinator, was notified of our arrival by the guard and met us at the guardhouse. Mr. Lutz, 

Ms. Gibbs, and I presented our credentials. Ms. Crawford also presented her government 

identification to Mr. Carrasco, who then escorted us to a conference room, where we were met 

by Ms. Erin C. Hall, Environmental Specialist. 

FACILITY DESCRIPTION 

The Facility employs 214 full-time ExxonMobil employees and 111 contract workers. The 

Facility operates twenty-four (24) hours a day, seven (7) days a week, and 365 days a year. 

There are seven (7) production lines (A-Line through G-Line) and a Purge Gas Purification Unit 

(PGPU) at the Facility that were scheduled to be monitored during this inspection. After our 

arrival, Mr. Carrasco notified us that the PGPU had recently finished a turn-around and the 

operators were having issues bringing the unit back online. The PGPU was not monitored during 

this inspection because the Facility could not get the unit to operate while we were on site. 

Additionally, D-Line was off-line during the entire inspection and was not monitored. 

Production Lines A through F manufacture Low density polyethylene (LOPE) through the 

polymerization of ethylene and other chemicals in a high pressure process. Production Line G 

manufactures ethylene elastomers using a low-pressure slmry process. The PGPU purifies 

ethylene recycle gas from the Facility's operations and auxiliary feed streams for process reuse. 

Block Flow Diagrams for Production Lines A through G are provided in Attachment A. 

2 
requested that at least one ( l) of the Facility's Leak Detection and Repair (LDAR) contractors 

accompany us during the walk-through to confirm any leaks. The Facility's onsite LDAR 

contractor is Jacobs Field Services (JFS). The JFS personnel who accompanied us during our 

facility walk-through were Mr. Craig Dugas and Mr. Jack Alderman. 

Mr. Carrasco and Ms. Hall informed us that there were five (5) reactors onsite (four (4) high 

pressure and one ( 1) low pressure). In addition to Method 21 LDAR monitoring, JFS personnel 

also conduct monthly surveys (2 to 3 days each in duration) of the facility using an IR camera. 

Typically, the surveys are conducted in areas not covered by a formal LDAR program. The IR 

camera is shared with another ExxonMobil fac ility located near the Facility. Mr. Carrasco also 

informed the team that there are two (2) continuous use flares onsite. For their narcs, the 

Facility monitors steam to gas ratio. They replaced the flare tip of FL-1 three (3) years ago and 

are close to replacing the FL-3 flare tip. According to MI. Carrasco, the Vent Gas Net Heating 

Value is set at 800 British Thermal Units per standard cubic foot (BTU/scf) for the flares, which 

never gets close to the 300 BTU/scf minimum regulatory limit. Prior to breaking for lunch, it 

was decided that we would begin the remaining days of the inspection at 7:30am in order to 

limit the faci lity walk-throughs during the hottest part of the days. After the entrance briefing, 

we took a break for lunch and to give us time to calibrate and prepare all the necessary 

equipment for the faci lity walk-through. 

The following subsections describe the emissions monitoring activities that were conducted in 

each process unit. A Facility Plot Plan is provided in Attachment C. Fugitive Emissions 

Investigation Logs, used for recording information pertaining to what the inspection team finds 

during the process unit walk-throughs, are provided in Attachment D. These subsections are 

arranged in a chronological order by w1it: 

G-Linc: 

Following the entrance briefing and lunch/calibration break on Tuesday, June 11 , 2013, 

we began the facility walk-through of G-Line. As stated in the Facility Description 

section above, G-Line manufactures ethylene elastomers using a low-pressure slurry 

process. The team used two (2) lR cameras and two (2) P!Ds to detect Volatile Organic 

Hydrocarbons (VOC) emissions and two (2) TV As to quantify the emissions, when 

possible. No emissions were discovered during the wa lk-through of G-Linc. Following 

the walk-through of G-Line, we proceeded to the F-Line control room, where we were 

informed that the unit was offline; however, it was expected to be back online the 

following day. Mr. Carrasco then escorted us to E-Line. 

E-Line: 

During the E-Line walk-through on Tuesday, June 11 , 2013, I observed emissions 

coming from a leaking shepherd's crook extruder vent (see Attachment E, Video 

3 
(prirnari ly ethylene). According to Mr. Canasco, this is what I observed with the IR 

camera. These emissions are permitted Lmder EQTOOl l 01-95 (106) - Polymer 

Extrusion (page 4 of 12) in Permit No. 0840-00018-V8 (see Attachment G). No other 

emissions were observed during the E-Line walk-through. Following the walk-tlu·ough 

of E-Line we returned to the conference room to conduct the daily exit briefing, where it 

was agreed that the team would return to the facility the following morning at 7:30AM. 

Upon arrival at the facility on Wednesday, June 12, 2013, we checked in at the guardhouse, were 

met by Mr. Carrasco, and proceeded to the conference room, where Mr. Carrasco informed us 

that B-Line, D-Line, F-Line, and the PGPU were still down. 

A-Line: 

Following Mr. Carrasco's update on which process units were online and which were still 

down, we proceeded to A-Line to begin the walk-through. Mr. Lutz detected emissions 

coming from an old containment sump near component V-962-B with a PID. According 

to Mr. Carrasco, the sump is: 

"from before the inception of the Comparable Fuels Exclusion, when the 

[adjacent] tank was considered hazardous waste (i.e., required I 00% 

containment). Due to piping in the area, the toe wall could not be raised enough 

to contain the contents, thus the sump. There is no connectivity to the sewer from 

that sump; hence, the blue diaphragm pump on the grating (should be able to see 

in RIM GO I 06) to evacuate accumulated storm water to a nearby sewer. VOC are 

suspected to be from a piping modification (made isolation va lves more safe to 

operate, i.e., in a bad location ergonomically) that happened shortly before your 

[EPA's] arrival where some de minimis liquids may have entered the sump. 

There is a 55 gallon satellite station adjacent to the tank for filter cleaning." 

I recorded IR video (see Attachment E, Video MOV _0182) and Ms. Crawford took 

digital photographs of the sump (see Attachment H, Photographs RIM GO 106 and 

RIMG0107). Ms. Gibbs quantified the leak using a TVA at approximately 13,000 ppm. 

A photograph showing how the stormwater sump works was provided (see Attachment 

H, Photograph RIMG0114). No other issues were observed in A-Line. Following the 

walk-through of A-Line, we proceeded to C-Line. 

C-Line: 

Continuing from A-Line, we proceeded to C-Line, where 1 discovered a used oil collection system vent stack on the C-Line compressor building emitting VOCs (see 

Attachment E, Video MOV _0183). The vent stack is attached to and is significantly 

taller than the compressor building, which made it impossible to obtain a quantifying 

4 
high pressures in the primary and secondary compressors, the oil contai ns low

level 

volatile contamination despite three (3) prior leak recovery steps. The three (3) leak 

recovery steps are the Packing Bleed Off System (primary packing leak recovery routed 

to purge compressor suction), the Cooling Oil Recovery (secondary recovery system 

where volatiles arc stripped from the oil by heat and routed to the fl are and the oil is 

recycled in the system), and the Nitrogen Buffered Packing (tina! " barri er fluid" system 

routed to the flare). There is no forced flow from the used oil coll ection system (gravity 

drained); therefore, low-level volatiles can build up. Mr. Carrasco believes this buildup 

is what I saw with the IR camera. The used oi l collection system is permitted under 

0840-00018-V8 (sec Attachment G). Insignificant Activities List (page 4). 

We proceeded through C-Line, where I discovered two (2) initiator pumps and Mr. Lutz 

discovered a connector emitting VOCs in Building 200C. The initiator pump (in the 

southwest corner of the building) was emitting VOCs in a range of 25,000 to 40,000 ppm. 

l recorded IR video (see Attachment E, Video MOV _ 0188) and Ms. Crawford took 

photographs of the leaking pump (see Attachment H, Photographs R!MG0109 and 

RlMGOllO). The connector next to the initiator pump (in the southwest corner of the 

building) was emitting VOCs at greater than I 0,000 ppm. I recorded an TR video (see 

Attachment E, Video MOV _ 0189) and Ms. Crawford took a photograph of the leaking 

connector (see Attachment H, Photograph RIM GO 111 ). The initiator pump (in the 

northwest corner of the building) was also found to be leaking. I recorded an IR video 

(see Attachment E, Video MOV _ 0190) and Ms. Crawford took photographs of the 

leaking pump (see Attachment H, Photographs RIMGOl 12 and RlMGO JI 3). A 

photograph showing how the initiator pumps work was provided (see Attachment H, 

Photograph RIM GO 114). Following the walk-through of C-Line, we broke for lunch, 

passing through B-Line and A-Line on the way back to the conference room. 

B-Line: 

B-Line was down during the duration of our onsite inspection. However, while 

conducting the wa lk-through ofthe Facility, Ms. Crawford observed an open-ended line 

(OEL) when returning to the conference room to break for lunch on Wednesday, June 12, 

2013 . Ms. Gibbs attempted to obtain a reading directly from the OEL interface; however, 

she was unable to reach it. She did obtain a reading of3,000 ppm approximately six (6) 

inches away from the OEL. Additionally, this leak "flamed out" (e.g., extinguished the 

flame inside the TVA) our TVA. 1 recorded IR video (see Attachment E, Video 

MOV _0 187) and Ms. Crawford took a photograph of the leaking OEL (see Attachment 

H, Photograph RIM GO 1 08). According to Mr. Carrasco, the equipment was in 

lockout/tagout and was required by Occupational Safety and Health Administration 

(OSHA) regulations to be left in an open position. A hand drawn diagram of the piping 

layout for the OEL was provided (see Attachment H, Photograph RIMG01 15). More 

5 
double isolation of chemical ene rgy sources with a bleed va lve open to the 

atmosphere. The open bleed valve to the atmosphere ensures that any leakage 

past the first valve seat does not build up pressure leading to a slow continuous or 

unexpected release of stored ene rgy (i.e., chemical) on workers performing 

maintenance on downstream equipment. Although not at an optimum angle in 

photograph RIM GO 108, the white-red tag affixed with a black tie-wrap is a 

LOTO (lock-out, tag out) tag on said OEL and was associated with maintenance 

on the compressor downstream of the valve. When a work permit is closed 

(temporarily or permanent), all bleeder va lves open to the atmosphere are closed." 

Upon our return from lunch, we adjourned to the conference room to meet up with Mr. Carrasco. 

J le contacted JF personnel and we proceeded to the Chemical Storage Area. meeting them 

along the way. Within the Chemical Storage Area. we observed emissions exiting a roof vent on 

Tank 260. 

Chemical toragc Area: 

Mr. Lutz found Tank 260 (located in the Chemical Storage Area) to be emitting YOCs 

from a roof vent. According to Mr. Carrasco, the tank contai ns hexane and has an 

internal fl oating roof with a nitrogen blanket. The vent was inaccessible and a 

quantify ing concentration measurement \·vas not recorded. However, Mr. Lutz and I did 

record lR videos (see Attachment E , MOV _0192 (Va lentine), MOY _0194 (Valentine), 

MOY 

_

2554 (Lutz), MOY _2555 (Lutz), and MOY _2557 (Lutz)) and Ms. Crawford took 

a photograph ofthe leaking tank (see Attachment H, Photograph RIMG0116). A 

photograph of a hand drawn diagram showing what Mr. Carrasco believes is causing 

Tank 260 to leak was provided (see Attachment H, Photograph RIM GO 120). 

Ncar Tank 260. Ms. Gibbs discovered two (2) nanges on filters F-255-A (Tag No. 

59627) and F-255-B (Tag No. 59634) to be emitting VOCs at 600 ppm, each. JFS 

personnel observed the leaks with their TV As at concentrations of 475 ppm for F-255-A 

and 680 ppm for F-255-B. Each component was tagged as a leakcr by JFS personnel and. 

according to Mr. Carrasco, the Facility would count each leak as an unauthorized 

discharge. Each leak could not be observed using theIR camera. Ms. Crawford took 

photographs of the leaking filter flange (see Attachment H , Photographs RIMG0117, 

RIM GO 1 18, and RIM GO 11 9). A photograph showing a hand drawn diagram of how the 

filter flanges F-255-A and f -255-B work was provided (see Attachment H, Photograph 

RIM GO 120). Following the observation of Tank. 260 and filter flanges F-255-A and F255-B, we adjourned to the conference room to conduct the daily close-out meeting, 

where we reviewed the leaks found during the day's walk-through of the Facility prior to 

leaving for the day. 

6 
F-Line: 

Ms. Crawford discovered a leaking plug/OEL near valve 20962 leaking at approximately 

3,000 ppm. JFS personnel recorded the leak at approximately 1,600 ppm. JFS personnel 

conducted a first attempt at repair by replacing the Teflon® tape on the plug. A follow-up 

reading showed the leak to still be in excess of 500 ppm. JFS persom1el then replaced the 

plug and the leak fell below the leak definition threshold of 500 ppm. I was unable to see 

the leak using the IR camera; therefore, JR video was not recorded. Ms. Gibbs took a 

photograph ofthe repaired plug (see Attachment H, Photograph RIMG0121). 

Ms. Gibbs discovered a leaking p lug/OEL near valve 2 1623 leaking at approximately 

14,000 ppm. This leak was a "visible 1eaker," meaning the leak could be seen without 

use of our emissions monitoring equipment (e.g. TVA, PID, or IR camera). J recorded an 

IR video (see Attachment E, Video MOV _ 198) and Ms. Gibbs took a photograph of the 

leaking plug/OEL (see Attachment H, Photograph R1MG0122). JFS personnel repaired 

the leaking plug/OEL on the spot. Follow-up measurements showed the leak to be below 

the leak definition threshold of 500 ppm. 

I observed a pump (R-1260F) to be leaking at approximately 2,500 ppm, which had 

previously been tagged as a leaker by JFS persom1el. I recorded an IR video of the leak 

(see Attachment E, Video MOV _199) for future training purposes. 

Following the walk-through ofF-Line, we proceeded to the conference room to have a 

p1ivate meeting in preparation for the exit briefing. 

During the private meeting and prior to the exit briefmg, all IR videos and photographs collected 

during the Facility inspection were transferred to Mr. Lutz's computer so they could be 

transferred to a Facility computer prior to the exit briefing. It was later determined theIR video 

file sizes and administrative controls on the Facility's computers prevented the transfer of the 

files. Both parties agreed that transfening the IR videos and photographs to a CD/DVD, when 

we returned to EPA Region 6 Offices in Dallas, Texas, and mailing the CD/DVD to the Facility 

would work better. 

The exit briefing was conducted at 10:30 am on Thursday, June 13, 2013. Mr. Pat L. Fontenot, 

Operations Manager, and Mr. Dominic T. Clausi, Site Manager, of the Facility joined the group 

for the exit briefing. A sign-in sheet for the exit briefing is provided in Attachment B. Mr. Lutz 

thanked the facility personnel for their hospitality and requested that Mr. Carrasco thank Mr. 

Dugas and Mr. Alderman for their assistance during the inspection. Mr. Lutz informed the 

Facility persom1el of the Areas of Concern (AOC) that were found during the inspection (see 

Section III - Areas of Concern, below). Additionally, Mr. Lutz discussed with the .Faci lity 

personnel the process following the inspection (e.g., the report writing, quality assurance/quality 

7 
Unmooitorcd Process Units: 

0 -Line: 

The D-Line was offline during the duration of the Facility inspection. Therefore, we 

were unable to conduct a walk-through of the tmit during the inspection. 

PGPU: 

Facility personnel were unable to bring the PGPU back online following a planned 

shutdown. Therefore, we were unable to conduct a walk-tlu·ough of the tmit during the 

inspection. 

Section III- AREAS OF CONCERN 

The following are concerns observed with theIR camera and/or detected by the PID and TVA 

during the walk-through of the Facility: 

I. Containment sump emitting YOCs at 13,000 ppm in the A-Line, near V -962-B. 

2. Vent stack on compressor building in C-Line, apparently from the recycled oil tank for 

A-Line through 0-Line (Base Plant) compressors. 

3. Open-ended Line near Tag 4527 emitting VOCs at 3,000 ppm on the TVA from six 

inches away. It eventually flamed out the TV A. 

4. Southwest initiator pump in Building 200C emitting VOCs from 25,000 to 40,000 ppm. 

5. Connector next to the southwest initiator pump emitting VOCs at >10,000 ppm (visible 

leaker). 

6. Northwest initiator pump in Building 200C emitting VOCs. 

7. Tank 260 (storing hexane) emitting hexane from a roof vent. 

8. Filter flange F-255-A (tag# 59627) emitting VOCs at 600 ppm. 

9. Filter flange F-255-B (tag # 59634) emitting VOCs at 600 ppm. 

10. End Cap next to valve 20962 emitting VOCs at 3,000 ppm on F-Line. 11. End Cap next to valve 2 1623 emitting VOCs at 14,000 ppm. 

For additional infonnation on these AOC, see Section II- Observations, above. 

8 
Attachment C 

• Facility Plot Plan 

Attachment D 

• Fugitive Emissions Logs 

Attachment E 

• IR Video Log 

Attachment F 

• Shepherd·s Crook Vent P&ID 

Attachment G 

• Permit No. 0840-00018-V8 

Attachment H 

• Photograph Log 

Attachment I 

• V-135P&ID 

Attachment J 

• 29 C.F.R. § 191 0.147 Sununary 

9