Document 4J7GVaydK5vMvJxYGz31gwj71

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 DATE: MEMO SUBJECT: See Date of Section Chief Signature Below Redacted Confidential Business Information Corteva Agriscience, Harbor Beach, MI This report was originally completed and shared with Corteva Agriscience on October 15th, 2021. Upon review, Corteva Agriscience claimed additional Confidential Business Information (CBI) beyond the original claims made during the August 18th, 2021 inspection. All CBI has been redacted from this report and all copies of the previous report have been deleted. DIGITAL SIGNATURES EMMA Digitally signed by EMMA LEEDS Report Author: _L_E_E__D_S________D15a_:t2e_7::25_022_-10_.61'1_0.01_'6____________ Section Chief: __________________________________ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 DATE: SUBJECT: FROM: THRU: TO: See Date of Section Chief Signature Below CLEAN AIR ACT INSPECTION REPORT Corteva Agriscience, Harbor Beach, MI Emma Leeds, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Corteva Agriscience ("Corteva") Facility Location: 305 N Huron Ave, Harbor Beach, MI Date of Inspection: August 18th, 2021 EPA Inspector(s): 1. Emma Leeds, Environmental Engineer 2. Kosta Loukeris, Environmental Engineer 3. Brianna Fenzl, Environmental Engineer 4. Daniel Heins, Environmental Engineer Other Attendees: 1. Jim McGee, EHS Manager - Corteva 2. Lisa Callender, Site Leader - Corteva 3. Kevin Soper, Production Leader - Corteva 4. Andrew Volmering, Operations Leader - Corteva 5. Scott Grekowicz, Fermentation and TTU Engineer - Corteva 6. Jessica Sekerak, Improvement Engineer - Corteva 7. Alyssa Gehring, EH&S Data Technician - Corteva 8. Angela Hughes, Operations Leader - Corteva 9. Kris Wolschlager, Technical Advisor and Extraction Coordinator - Corteva 10. Dwane Mogg, Leak Detection and Repair (LDAR) Technician - Corteva 11. Randy Reinke, Environmental Technician - AECOM 12. Shyanna Laus, Chemical Engineer - AECOM 13. Adam Shaffer, Environmental Quality Analyst - Michigan Department of Environment, Great Lakes, and Energy (EGLE) Contact Email Address: James.McGee@corteva.com Purpose of Inspection: CAA compliance Facility Type: Pesticides active ingredient manufacturer Regulations Central to Inspection: 40 C.F.R. Part 63, Subpart MMM - National Emission Standards for Hazardous Air Pollutants (NESHAP) for Pesticide Active Ingredient Production, 40 C.F.R. Part 63, Subpart EEEE - NESHAP for Organic Liquids Distribution, and Title V Permit Requirements Arrival Time: 10:20 AM ET Departure Time: 4:00 PM ET Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility The following information was obtained verbally from Corteva unless otherwise noted. Company Ownership: Corteva separated from DowDuPont in 2019. The site officially changed name from Dow AgroScience to Corteva Agriscience at the start of 2021. There have been no operational or continuity changes at Harbor Beach due to this. Process Description: The Corteva Harbor Beach facility ("the Facility") is a pesticides production plant. The facility uses bacteria to produce spinosad and spinetoram ("product") in fermenters and then extracts the product for packaging and sale. Methanol is a hazardous air pollutant (HAP) byproduct of fermentation, and xylene is a HAP raw material used during extraction. Bacteria arrive on site and are cultured in seed tanks before being transferred to the fermentation tanks. Sugar, flour, yeast, and other raw materials are fed to the fermentation tanks to aid the Page 2 of 5 Inspectors then observed the testing being conducted on the TTUs. AECOM was measuring vapor phase organic and inorganic emissions using Fourier Transform Infrared, following Method 320. Inspectors observed the real-time data in the middle of Run 2, reading 50 parts per million (ppm) formaldehyde at the inlet of TTU 850 and 20 ppm formaldehyde and 8 ppm methanol at the outlet. After pausing for lunch, inspectors continued the tour in the extraction control room. Corteva personnel shared that the lower xylene-containing demulsifier, "DEM3", was in use that day, stored in tank V405. EPA conducted comparative Method 21 LDAR monitoring for V405 with two TVA2020 Thermal Vapor Analyzers. LDAR monitoring data for V405 is included in Appendix A. EPA also performed Method 21 LDAR monitoring on the wastewater treatment bioreactor and found that the pressure relief valve and vacuum relief valve were both venting organic gas to the atmosphere. TVA readings from the bioreactor are included in Appendix A. EPA showed Corteva staff the TVA readings during monitoring. EPA also observed sample ports at the carbon beds that were not capped. EPA observed the extraction process and the TTU outlets with a Forward Looking Infrared (FLIR) camera but did not record any videos. Photos and/or Videos: were not taken during the inspection. Field Measurements: were taken during this inspection. TVA calibration data and Method 21 monitoring data are provided in Appendix A. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: x Dates of the most recent two TTU changeout dates x Preliminary results from TTU testing x Most recent compliance tests x Update on process condenser Concerns: U.S. EPA expressed concerns that all emissions from the bioreactor were not being captured and controlled because the pressure and vacuum relief valves were venting to the atmosphere. DIGITAL SIGNATURES EMMA Digitally signed by EMMA LEEDS Report Author: _L_E_E__D_S_______D1_3a:_t4e6_::24_042_-10._51'00_.01'_5 ____________ Page 4 of 5 NATHAN Digitally signed by NATHAN FRANK Section Chief: _F_R__A_N_K_______D1_4a_t0e0_::23_022_-10_.51'00_.01_'5_____________ Page 5 of 5 Facility Name: Corteva Agriscience Facility Location: 305 N Huron Ave, Harbor Beach, MI Date of Inspection: August 18, 2021 APPENDICES AND ATTACHMENTS 1. Appendix A Facility Name: Corteva Agriscience Facility Location: 305 N Huron Ave, Harbor Beach, MI Date of Inspection: August 18, 2021 APPENDIX A: FIELD MEASUREMENT DATA TVA calibration at 1:05 PM EST on 8/18/21: Span Gas (ppmv) TVA #A56575 (ppm methane) 500 476 2000 1,976 9800 10,000 TVA #A56584 (ppm methane) 496 2,006 9,937 Components monitored on xylene storage tank V405 during the inspection: Component Type Number of Components Valves 19 Connectors 14 Plug 2 Note: background readings during LDAR monitoring of V405 were 1.5 and 0.5 ppm methane. Method 21 LDAR readings on bioreactor: Equipment TVA #A56575 Readings (ppm methane) PRV 722A 3200 VRV 722A 2900 Vacuum recovery line 50 Pressure relief line 3400 TVA #A56584 Readings (ppm methane) 3500 1900 60 2400 Appendices Page 1 of 1