Document 3NYXGn950K83r9Q4J0akpaZ4D

United States Environmental Protection Agency Region 7 Enforcement and Compliance Assurance Division Air Branch Inspection Report Unannounced Partial Compliance Evaluation Evonik Corporation 650 Industrial Park Drive Blair, NE 68008 FRS# 110040981532 Inspection Date: April 23, 2024 Christopher Appier, Inspector, ECAD, Air Branch Authorized for Release by: Tracey Casburn, Air Branch Chief, ECAD 11201 Renner Boulevard Lenexa, Kansas 66219 Page 1 of 7 CONTENTS INSPECTION OVERVIEW .................................................................................................................. 3 INSPECTION OBJECTIVE .............................................................................................................. 3 FACILITY CONTACT INFORMATION ............................................................................................. 3 FACILITY OVERVIEW .................................................................................................................... 3 FACILITY OPERATIONS SUMMARY .............................................................................................. 4 FIELD ACTIVITIES SUMMARY....................................................................................................... 4 Measurement Activities.......................................................................................................... 5 INVESTIGATION OBSERVATIONS AND POTENTIAL FINDINGS......................................................... 6 TABLES Table 1. APPLICABLE PERMIT CONDITIONS .................................................................................... 3 Table 2. PROJECT TEAM MEMBERS ................................................................................................ 3 Table 3. FACILITY CONTACT INFORMATION ................................................................................... 3 Table 4. FIELD MEASUREMENT ACTIVITIES .................................................................................... 6 APPENDICES A - NDEE NOV (1 page) B - Construction Permit CP11-024 (19 pages) C - Construction Permit CP12-024 (7 pages) D - Construction Permit CP13-036 (6 pages) E - Construction Permit CP19-022 (4 pages) F - CBI Form (2 pages) G - Receipt for Documents (1 page) H - Photo Log (35 pages) This Contents page shows all the sections contained in this report and provides a clear indication of the end of this report. Page 2 of 7 INSPECTION OVERVIEW INSPECTION OBJECTIVE The objective of the partial compliance evaluation (PCE) inspection was to confirm the facility's status as a minor source of emissions and compliance of the facility with the Clean Air Act (CAA), specifically those requirements relating to volatile organic compounds (VOCs) and hazardous air pollutants (HAPs) listed in Table 1. Permit Number CP13-036 CP19-022 Table 1. APPLICABLE PERMIT CONDITIONS Section III.(B) Specific Conditions for Granulation III.(A) Specific Conditions for Fermentation Table 2 lists the inspection team members. Team Member Christopher Appier Charlotte Papp Table 2. PROJECT TEAM MEMBERS Organization EPA Region 7, ECAD, Air Branch EPA Region 7, ECAD, Air Branch Project Role Lead inspector Field team member FACILITY CONTACT INFORMATION Table 3 lists the primary facility contacts alphabetically. Name, Title Paul Caldwell, Site Director Jeff Jacobson, QA Manager Ryan Jensen, Plant Manager David McLean, ESH Regional Coordinator Table 3. FACILITY CONTACT INFORMATION Phone No. (402) 553-1562 (402) 427-3726 -- (402) 237-6955 Email Address paul.caldwell@evonik.com jeff.jacobson@evonik.com ryan.jensen@evonik.com david.mclean@evonik.com FACILITY OVERVIEW The Evonik facility in Blair, Nebraska, began operating in 2000. The facility operates 24 hours per day and employs 127 people. The facility was originally constructed to produce the amino acid L-lysine, sold as Biolys. In 2019, the facility was expanded and began producing the omega-3 fatty acids eicosapentaenoic acid (EPA) and docosahexaenoic acid (DHA) from algae. These products are used in the animal nutrition industry. The facility's operations include fermentation, granulation, and materials handling. Page 3 of 7 There are no previous compliance monitoring activities at this facility. According to EPA's Environment and Compliance History Online website, there has been no formal enforcement at this facility for the past five years. The Nebraska Department of Environment and Energy (NDEE) issued a Notice of Violation to Evonik on July 23, 2021, for a failure to submit stack test results within 60 days of completion (Appendix A). According to the active construction permits (Appendices B, C, D, and E) issued for the facility, the facility is not subject to any New Source Performance Standards, National Emission Standards for Hazardous Air Pollutants, or Maximum Available Control Technology requirements. FACILITY OPERATIONS SUMMARY For both the Biolys and omega-3 fatty acids (algal) production lines, the facility utilizes fermentation. The requirements for the fermentation process are covered in the construction permit CP19-022. These requirements include conducting a one-time initial performance test on the Omega-3 Fatty Acids Fermentation Exhaust (EP1) for VOCs to demonstrate compliance with the 1.46 lbs/hr emission limit. Construction permit CP11-024, which was superseded by CP19-022, required initial performance testing on the Biolys Fermentation Exhaust (EP13) to demonstrate compliance with the 0.85 lbs/hr emission limit. For the production of Biolys, the facility uses a granulation process. The emission points for the granulation process include Granulators 1 through 4 (EP2, EP3, EP4, and EP14, respectively), and the combination of the Granulation Dryer/Cooler, Biolysis Oil Receiver, and Aquavilys Crusher/Receiver (EP5). The requirements for the granulation process are covered in the construction permit CP13-036. These requirements include VOC emission limits, performance testing requirements, operating parameter monitoring, and calculating and recording VOC emissions. FIELD ACTIVITIES SUMMARY The inspection team arrived at the facility on April 23, 2024, at 9:05 a.m. and completed a drive by surveillance inspection. I did not observe visible emissions. I made entry at the front gate at 9:15 a.m. I reviewed site safety information in the guard shack until 9:30 a.m. I then introduced myself and Ms. Papp, presented my credentials, and provided my business card to the facility representatives listed in Table 3. I conducted an opening conference during which I explained that the purpose of the visit was to conduct an inspection to determine compliance with the CAA, specifically, the permit requirements listed in Table 1. I explained that after asking for some general business information, I would observe process units, emission units, control equipment, and also, review associated records demonstrating compliance with the permit Page 4 of 7 requirements. I explained to Mr. Caldwell that the facility would have an opportunity to make a claim of business confidentiality at the end of the inspection and provided him with a Confidential Business Information (CBI) form. Mr. Caldwell did make a claim of confidentiality (Appendix F). The inspection team was given a facility tour by Mr. Jensen. I wore a hard hat, steel toed boots, safety glasses, and earplugs during the facility tour per my site health and safety plan. We broke for lunch at 12:30 p.m. and returned to the facility at 1:40 p.m. I obtained copies of the records as indicated on the Receipt for Documents (Appendix G) via a OneDrive shared folder on the day of the inspection. On May 6, 2024, a log for the baghouse was uploaded to the shared folder. On May 10, 2024, updated potential to emit calculations, control device operating parameters, and a photograph of an oil spill cleanup were uploaded to the shared folder. On July 29, 2024, I sent Mr. McLean an email inquiring about emission inventory reports. On August 1, 2024, an updated emission inventory was sent to me by Mr. McLean via email. I conducted a closing conference with the facility representatives listed in Table 3. I provided the facility with copies of the receipt for documents and CBI form. I departed the facility at 3:45 p.m. Observations and potential findings from the facility tour, records review, and measurement activities are noted in the Investigation Observation and Potential Findings section below. Measurement Activities Ms. Papp conducted field measurements during the onsite inspection under my direction. Ms. Papp used a forward looking infrared (FLIR) camera to monitor for leaking equipment in the fermentation and granulation areas of the site. Table 4 summarizes field measurement and field sampling activities. All environmental measurement activities were performed in accordance with the EPA Region 7 quality system. Ms. Papp followed manufacturer and EPA processes for instrument calibration; instrument calibration is documented in an EPA internal database. Table 4 summarizes field measurement activities. Page 5 of 7 Table 4. FIELD MEASUREMENT ACTIVITIES Date and Time Method and/or Procedure1, and Equipment 4/23/2024 2:00 p.m. - 2:45 p.m. Region 7 procedure: FLIR ThermaCAMTM GasFindIR, GF320, and Similar Infrared Cameras Equipment: FLIR, GF320, SN: 44402263 1 The current version of each procedure, at the time of the investigation, was followed. Measurer Name Charlotte Papp INVESTIGATION OBSERVATIONS AND POTENTIAL FINDINGS Ambient weather, site conditions, and field activities were documented in the field records. All photographs are attached as Appendix H (claimed as CBI). I or a team member under my direct supervision made the following observations during the inspection. I discussed all observations with facility representatives during the closeout meeting unless otherwise noted in the observation description. These observations are not final compliance determinations. The EPA Region 7 Air Branch case review team will make the final compliance determinations based on its review of this report and other technical, regulatory, and facility information. Based on the information reviewed, Evonik appears to be a minor source of emissions under the CAA. The facility conducted and passed an initial performance test for both the Omega-3 Fatty Acids Fermentation Exhaust (EP1) and the Biolys Fermentation Exhaust (EP13) as required by construction permit CP19-022. The facility conducted and passed an initial performance test for EP2, EP3, EP4, EP5, and EP14 as required by construction permit CP13-036. The facility monitors operating parameters and calculates VOC emission estimates as required by construction permit CP13-036. No leaks were found during the FLIR measurement activities. Baghouse daily inspection logs were reviewed on site. The logs were well organized and appeared to meet the requirements in the permits. Replacement bags for the baghouses were observed during the facility tour. During the facility tour, a barrel of petroleum-based lubricant was observed to be leaking onto the floor (see Image 20240423_154929012_iOS.jpg - claimed as CBI) based on an oil stain Page 6 of 7 below the barrel. A photograph was submitted to OneDrive on May 10, 2024, documenting cleaning of the oil stain (claimed as CBI). End of report. Page 7 of 7