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DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CIDCAGO, ILLINOIS 60604 NOV O1 Z018 CLEAN AIR ACT INSPECTION REPORT Koppers, Inc, Galesburg, Illinois Vicky Mei, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Koppers, Inc. Facility Location: 1291 U.S. 41, Galesburg, Illinois 61401 Date of Inspection: October 25, 2018 EPA lnspector(s): 1. Vicky Mei, Environmental Engineer Other Attendees 1. Jim Evans, Plant Manager, Koppers, Inc. 2. Drew Lozier, Assistant Plant Manager, Koppers, Inc. 3. John Luke, Treating Supervisor, Koppers, Inc. 4. Nick Ward, Safety and Health Coordinator, Koppers, Inc. Contact Email Address: EvansJR@koppers.com Purpose of Inspection: General Clean Air Act Inspection Facility Type: Creosote Wood Treatment Facility Arrival Time: 2: 1OPM Departure Time: 3:55PM Inspection Type: ~ Unannounced Inspection D Announced Inspection OPENING CONFERENCE ~ Credentials Presented ~ CBI warmng to facility provided The following information was obtained verbally from Mr. Evans, Mr. Lozier, Mr. Luke, and Mr. Ward unless otherwise noted. Process Description: Koppers, Inc. received ownership and started operations of the 100-year-old facility in 1988. The facility produces about 800,000 to 1 million crossties and 30,000 to 40,000 switch ties annually. The neighboring BNSF facility provides Kopper, Inc. with untreated ties, which are left out to dry for 6 to 12 months. Creosote is injected into the dried untreated ties under 165 psi for 12 hours in enclosed cylinders. While still in the cylinders, the ties are dried for approximately 3 hours under 21 to 22 inches of mercury. The excess creosote from the cylinders is recycled into the work tanks. The work tanks are controlled by a 17-year-old Venturi scrubber and the liquid effluent stream enters the biological air system for pretreatment. The treated ties are then taken out of the cylinders to dry for 1 to 2 hours on a drip pad that catches any remaining creosote drips. The treated ties are loaded onto railcars or moved to ground storage. Staff Interview: The enclosed cylinders are visually checked for steam leaks. The creosote storage and work tanks are checked for temperature and creosote levels. The scrubbers are checked for the presence of water flow. The last odor complaint about the facility was from 2 years ago. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: Cylinder # 1 parameter: Pressure: 51 psi Cylinder #3 parameters: Pressure: 165 psi Storage tank temperature: 209 F Cylinder temperature: 208 F Vacuum: -1.2 psi The FLIR camera detected plumes of volatile organic material (VOM) emitted from both the scrubber stack and the release valve of work tank WT #2. Page 2 of 4 Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Lifetime operating permit 2008 2. Air Pollution Control System Performance Evaluation 2007 3. Wastewater Phenol Analytical Report 2018 4. Monthly Wastewater Analytical Report 2018 5. Quarterly diesel, gasoline, electricity, and natural gas consumption (Jan 2018 - Sept 2018) 6. Creosote solution safety data sheet 7. Charge report from I 0/24/2018 CLOSING CONFERENCE Requested documents: Premier Solutions, Inc. manual for the Venturi scrubber, if available Monthly usage of creosote (Jan 2014- Sept 2018) Monthly treatment production (Jan 2014- Sept 2018) 20 I 7 Emissions report SIGNATURES Report Author: -;::.--,,,,~,-""'~.S..--:-?f-::-..~- - - 4 ~ - - - - - - Date: "/ ? ---~ ~7 Section Chief: ,:;~/~-,:?"?f,-c: Date: / ;o/3c,/zo1 '/j / //0// :? 7 ,/ / Page 3 of 4 Facility Name: Koppers, Inc Facility Location: 1291 U.S. 41, Galesburg, Illinois Date of Inspection: October 25, 2018 APPENDICES AND ATTACHMENTS I. Appendix A: Digital Image Log Page 4 of 4 Facility Name: Koppers, Inc Facility Location: 1291 U.S. 41, Galesburg, Illinois Date of Inspection: October 25, 2018 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Vicky Mei 3. Company/Facility Name: Koppers, Inc 5. Number of Images: 2 2. Date(s) of Inspection: October 25, 2018 4. Street Address, City, State: 1291 U.S. 41, Galesburg, Illinois 6. Archival Record Location: CD-R, labelled "Koppers, Inc. Galesburg, IL Inspection Videos 10/25/2018" Image Number 1 2 File Name MOV 2272.mp4 MOY 2273.mp4 Date and Time (incl. time zone and DST) 10/25/2018 16:24 10/25/2018 16:27 Description of Image Emissions from the scrubber stack. Emissions from the work tank WT #2 release valve. Appendices Page 1 of 1