Document 3JN1bpN5mRnDkXLRoDJ7YG56O
DATE: SUBJECT: FROM: THRU: TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5
77 WEST JACKSON BOULEYARD CHICAGO, ILLINOIS 60604
SEP 1 7 2019
CLEAN AIR ACT INSPECTION REPORT Westlake Chemical, Calvert City, Kentucky
Ke1meth Ruffatto, Environmental Engineer AECAB (IL/IN)
Nathan Frank, Section Chief AECAB (IL/IN)
File
BASIC INFORMAT!ON
Facility Name: Westlake Chemical
Facility Location: 2468 Industrial Parkway, Calvert City, Kentucky
Date ofinspection: July 15,2019
EPA Inspector(s): l, Kem1eth Ruffatto, Environmental Engineer 2. Victoria Nelson, Environmental Engineer 3. Gregory Gehrig, Environmental Engineer 4. Cary Secrest Enviromnental Protection Specialist 5. Andrew Mills, Environmental Engineer
Other Attendees 1. Jon Morris, Providence Photonics 2. Sri Mutyala, Providence Photonics 3. Elizabeth Lents, KDAQ 4. Isaac Marrs, KDAQ 5. Matt Wallace, KDAQ 6. Mary Evans, KDAQ 7. Jimmy Hobby, EHS Supervisor, Westlake 8. Kevin Sheridan. Regional Manager HSE, Westlake 9. Logan Chavis, Environmental Specialist. Westlake 10. Betsy Taber, Environmental Specialist Westlake
l l. Paul Petitt, Site Manager, Cymetech 12. Todd McKinney, Engineering Manager, Westlake 13. Stan Hunt, Process Engineer, Westlake 14. Jacob Thomas, Senior Process Engineer, Westlake 15. Drew Schoefield. Jntern, Westlake 16. David Davis, VCM Unit Manager, Westlake 17. Brian Black, VCM Process Engineer Supervisor, Westlake 18. Bill Culver, Process Engineer, Westlake 19. Wes Lasher, VCM Operator, Westlake 20. Mitch McClain, Ethylene Operator, Westlake
Contact Email Address: Kevin Sheridan - ksheridan(aJwestlake.com; Jimmy Hobby ihohbv(cuwestlake.com
Purpose of Inspection: Flare Inspection
Facility Type: Chemical Facility
Arrival Time: 9:20 AM Departure Time: 12:50 PM
Inspection Type:
121 Unannounced Inspection
Announced Inspection
OPENING CONFERENCE
121 Credentials Presented 121 CBI warning to facility provided
The following information was obtained verbally from Westlake or Cymetech Staff unless
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Process Description: Westlake Chemical (Westlake) has two main process that vent to flares. The ethylene plant takes in ethane gas by pipeline and feeds it to six furnaces vvfoch decomposes gas at l 800F (cracking process). It is then cooled and compressed to 475 pounds and dried. It is then distilled into ethylene which is either sent by pipeline to a third party or mostly used internally in the vinyl process. Distillation also produces a fuel oil that is sold to a third party and additional coproducts. The two flares that Westlake operates are the: 1) ethylene flare and 2) vinyl chloride (VC) flare.
The ethylene flare controls process vents off the ethvlene process described above and an occasional vent stream from Cymetech. It is a dual assist that uses both air and steam: the air assist is controlled using a two speed (high and low) and steam is monitored using an orifice
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plate flow meter. The vent gas to the flare is measured and recorded using an ultrasonic GE pararnetrics. The flame is monitored using a camera that is directed towards and fire eyes on the pilot. The pilot is fueled using natural gas, and natural gas can be used as an assist to reach the proper net heating value.
The VC flare is used as an emergency flare only with pressure relief valves vented to it Valves and their rupture discs are inspected monthly and there is a velocity meter on the flare to know if there was a relief valve discharge. The flare is non-assisted. There is a small purge stream to the flare. The pilot is fueled using natural gas.
Staff Interview: Westlake is currently in the process of finalizing a Consent Decree with EPA on the flares.
TOI.JR INFORMATION
EPA toured the facility: Ycs
Data Collected and Observations: EPA contracted Providence Photonics (Providence) of Baton Rouge, Louisiana to conduct combustion device observations at the Landfill using Video Imaging Spectra-Radiography (VlSR) imaging device. or VlSR. The VlSR uses infrared sensing and imaging technology to determine the combustion efficiency (CE) of hydrocarbons combusted by a flare. Providence used the V!SR to observe the flares efficiency. EPA also utilized the FLTR camera 10 observe the flare and collect images.
At the time of inspection. the ethylene flare was burning vent gas and the VC flare was the pilot.
The VISR indicated a CE of approximately 99.6% for tbe ethylene flare and 97.3% for the VC flare over the test period. A report from Providence on the VISR data and images is provided in Appendix A.
Photos and/or Videos: were taken during the inspection.
Field Measurements: were taken during this inspection.
CLOSING CONFERENCE
Requested documents: Flare specifications " Operation and maintenance manual for the flare Internal procedures on how flare is operated
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SIGNATURES
Section Chief:
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Facility Name: \Vesflake Chemical Facility Location: 2468. Industrial Parkway, Calvert City, Kentucky Date oflnspeetion: July 15, 2019
APPENDICES AND ATTACHMENTS
I
Appendix A: Digital Image Log
Appendix B: Flare VISR Test Report
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Facility Name: Westlake Chemical Facility Location: 2468 Industrial Parkway, Calvert City, Kentucky Date of Inspection: July 15, 2019
APPENDIX A: DIGITAL IMAGE LOG
1. Inspector Name: Cary Secrest
3. Company/Facility Name: Westlake Chemical
5. Number of Images: 2
2. Date(s) of fo.spection: July l 5, 2019
4. Street Address, City, State: 2468 Industrial Parkway, Calvert Citv, Kentucky
6. Archival Record Location: CD-R labelled "Westlake Inspection 7/15/2019"
File Name MOV 0391 MOV 0392
Description Westlake Ethylene Flare (OGI) Westlake Vinyl Chloride Flare (OGI)
Appendices Page I of 2
Facility Name: Westlake Chemical Facility Location: 2468 Industrial Parkway, Calvert City, Kentucky Date of Inspection: July 15, 2019 APPENDIX B: FLARE VISR TEST REPORT Attached to this inspection report is the Flare VISR Test Report provided by Providence on a CD-R labelled ''Westlake Inspection 7/15/2019," The following is attached as part of the Flare VISR Test Report:
Westlake VISR Data (excel) Westlake East Flare Picture Gpg) Westlake East Flare Spectral Video 1 (avi) Westlake East Flare Spectral Video 2 (avi) Westlake East Flare Visible (mp4) Westlake VISR Report Westlake West Flare Picture (jpg) Westlake West Flare Spectral Video l (avi) Westlake West Flare Spectral Video 2 (avi) Westlake West Flare Spectral Video 3 (avi) Westlake West Flare Visible (mp4)
Appendices Page 2 of 2