Document JrnmwX8k5ODz7BVwVOnKMmbjX
EPA Inspection Report - Page 1 of 6
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
04/18-21/2022 Water CWA-NPDES
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Phone Number Facility Contact:
Denka Performance Elastomer LLC
Pontchartrain Plant
560 Highway 44
LaPlace, Louisiana 70068
560 Highway 44
LaPlace, Louisiana 70068
St. John the Baptist Parish
985-536-7802
Patrick Walsh
SHE/PSM Manager
patrick-walsh@denka-pe.com
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
110067396669 LA0127190 LAR000009415 325212 - Synthetic Rubber 2822 - Synthetic Rubber
Personnel participating in inspection:
Kenneth AuBuchon
US EPA - Region 6
Justin Young
US EPA - Headquarters
John Penland
US EPA - Region 6
Janosh Wolters
ERG
George Wieber
ERG
Joseph Watson
ERG
Patrick Walsh
Denka
Chris Meyers
Denka
Cory Green
Denka
Kevin Voelkel
Bracewell
Akihiko Kusaka
Denka
Jimbo Earles
LDEQ
Jenifer Kidd
LDEQ
Karen Price
LDEQ
Terry Dedon
LDEQ
Environmental Engineer Environmental Scientist Environmental Scientist EPA Contractor EPA Contractor EPA Contractor Denka Environmental Manager Denka Environmental Denka Environmental Denka Counsel Denka Counsel Louisiana State Inspector Louisiana State Inspector Louisiana State Inspector Louisiana State Inspector
EPA Lead Inspector Signature/Date
KENNETH AUBUCHON
Kenneth AuBuchon
Digitally signed by KENNETH AUBUCHON Date: 2022.06.29 12:21:54 -05'00'
Date
Supervisor Signature/Date
ROBERTO BERNIER Date: 2022.06.29 13:12:52 -05'00' Digitally signed by ROBERTO BERNIER
Roberto Bernier
Date
6ENFORM-019-R8.2 (02/12/2020)
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EPA Inspection Report - Page 2 of 6
Denka Performance Elastomer LLC / Pontchartrain Plant Inspection Date 04/18-21/2022
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION
EPA Region 6 inspector Kenneth AuBuchon arrived at the Denka Performance Elastomer LLC Pontchartrain Plant at 9:00am on April 18, 2022, for an unannounced Compliance Evaluation Inspection (CEI). The National Pollutant Discharge Elimination System (NPDES) CEI was conducted in conjunction with a Resource Conservation and Recovery Act (RCRA) CEI. This was an EPA Headquarters RCRA and EPA Headquarters RCRA contractor (ERG) lead inspection. We met with Chris Meyers and Cory Green, both with Denka Environmental, at the Opening Conference. We presented our credentials to everyone that was present at the opening conference including Mr. Chris Meyers. After the RCRA inspectors presented their credentials and informed Denka representatives on the scope of the RCRA inspection, I informed Mr. Meyers and other Denka representatives, that this was also an EPA NPDES inspection to determine compliance with the facility's NPDES permit and the Clean Water Act (CWA). The inspection was conducted under the authority of the NPDES permit program, in accordance with the Federal CWA.
This NPDES report is based on information supplied by Denka Performance Elastomer LLC Pontchartrain Plant representatives (the permittee), observations made by the U.S. EPA inspectors, and records and reports maintained by the permittee, the State of Louisiana, and the U.S. EPA. A separate RCRA report will be written containing observations and areas of concern related to the Resource Conservation and Recovery Act.
FACILITY DESCRIPTION
Denka Performance Elastomer LLC (Denka) owns and operates the Pontchartrain Plant located at 560 Louisiana Highway 44, approximately 2.8 miles west of LaPlace, Louisiana in St. John the Baptist Parish. In the 1960s, E.I. DuPont de Nemours & Co. (DuPont) constructed the Pontchartrain Works facility to manufacture adiponitrile, used in the manufacturing of nylon. Over time, the facility began manufacturing both Neoprene and Kevlar at the site. The Neoprene unit eventually became one of the largest manufacturing sites of Neoprene in North America. Denka purchased and took over manufacturing operations of the Pontchartrain Plant, specifically the Neoprene, Chloroprene, and Hydrochloric Acid (HCI) Recovery units, from DuPont in 2015. As landowners of the entire Pontchartrain Works property, DuPont retained the Diamine manufacturing unit and support operations as well as providing various grades of utility water. This portion of the facility is known as DuPont's Pontchartrain Works. Overall, the Pontchartrain facility employs an average of 300-500 workers.
Section II - OBSERVATIONS
At the opening meeting introductions were made and the inspection objectives for both the RCRA CEI and NPDES CEI were presented. Due to Confidential Business Information (CBI) and Homeland Security sensitive information (HSSI) claims by the facility, many of the documents presented and discussed were declared sensitive until a final CBI substantiation determination is made by EPA and not included in this report. The facility's claims regarding CBI and HSSI did not restrict the facility's presentation or discussions and do not restrict the information presented in this report. For the purposes of this inspection report, the information presented has been taken from public NPDES permits, NPDES permit
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EPA Inspection Report - Page 3 of 6
Denka Performance Elastomer LLC / Pontchartrain Plant Inspection Date 04/18-21/2022
applications, information publicly available, and observations not claimed as CBI or HSSI by the facility. The inspection consisted of multiple days of process reviews and field visits to review Denka's Neoprene manufacturing and supporting operations. The following units of Denka's Neoprene manufacturing and supporting operations were reviewed and discussed:
It was explained that the Chloroprene unit manufactures chloroprene from the raw materials Npentane, 1,3-butadiene, chlorine, and sodium hydroxide. Chloroprene is an intermediate product used as a feedstock for the manufacturing of Neoprene rubber. The process wastewaters and process area storm waters from the chloroprene unit are collected and routed to the Aqueous Waste (AW) Area for disposal through one of three permitted hazardous waste UIC deep wells and not discharged to surface waters.
During a visit to the Chloroprene unit, I observed a concrete-lined ditch next to the Chloroprene unit's northside that lead to Dupont's fifth street internal roadside ditch. This concrete-lined ditch had gate valves from the Chloroprene unit along its length. The following overhead view was obtained from Google maps and the blue shaded area show the ditch and ditch flow to fifth street. At the time of the inspection there were no indications of discharges from the Chloroprene unit into the concrete-lined ditch. Concerns regarding the concrete ditch are contained in the Areas of Concern Section of this report.
Fifth Street
Location of Open Valve Pictured Below
`A' Avenue
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EPA Inspection Report - Page 4 of 6
Denka Performance Elastomer LLC / Pontchartrain Plant Inspection Date 04/18-21/2022
Later I observed a gate valve located on the southside of the Chloroprene unit, open, as seen in the following picture.
Collection Sump Open Valve
The open valve is located at the Chloroprene unit's process wastewater and process area storm water collection sump. It was explained at the time that outer gate valves are maintained open in the event of a fire but before flow would be allowed to overflow and go thru the valves that pumps are used to evacuate the wastewaters to the AW Area before a discharge would occur. I requested the process SOPs for this operation of controlling process wastewaters and fire activities. At the time of this report no SOPs were provided. The aerial contained on the previous page shows the red shaded area where the open valve was located and flow direction to Dupont's `A' avenue internal roadside ditch. At the time of the inspection there were no indication of discharges from the Chloroprene unit collection sump thru the open valve. Concerns regarding the open valve at the collection sump are contained in the Areas of Concern Section of this report. The Anti-Crystallization Reagent (ACR) manufacturing unit is located in the Chloroprene Area, and manufactures 2,3-dichloro-1,3-butadiene from the intermediate t-1,4-dichloro-2-butene and chlorine. ACR is an intermediate product used as a feedstock for the onsite manufacture of Neoprene rubber or it can be blended with perchloroethyene, dichloromethane or xylene for offsite sales and shipment. The ACR unit footprint shares part of the Chloroprene and Neoprene manufacturing areas. Process wastewater and process area storm water from the portion of the ACR unit located in the Chloroprene manufacturing area is collected and routed to the AW Area for disposal through one of three permitted hazardous waste UIC deep wells, and not discharged to surface waters. Process wastewater and process area storm water from the portion of the ACR unit located in the Neoprene manufacturing area are routed to the Neoprene biological wastewater treatment plant (BWWTP). The Neoprene manufacturing unit manufactures liquid rubber emulsions and ACR blends and dry polychloroprene synthetic rubber (Neoprene) using Chloroprene, Neoprene emulsions, and ACR as the primary raw materials. Certain surfactants, catalysts and numerous additives are required. The process
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EPA Inspection Report - Page 5 of 6
Denka Performance Elastomer LLC / Pontchartrain Plant Inspection Date 04/18-21/2022
wastewater, process area storm water runoff, laboratory wastewaters and incidental non-process wastewaters from the Neoprene unit are co-located and routed to the BWWTP. The HCL Recovery unit receives as a feedstock, chlorinated wastes from the Chloroprene and Neoprene units that is combusted in a Hydrochloric Acid Production Furnace (HAPF) to make HCL that is recycled back into manufacturing process operations. Process generated wastewater and process area storm water from the HCL Recovery unit are routed to the AW Area for underground injection via permitted disposal wells. No process wastewater or process area storm water from the HCL Recovery unit are discharged to surface waters. Wastewaters sent to the AW Area undergoes the process of storage, clarification, neutralization and filtration prior to being deep well injected through one of three permitted hazardous waste UIC deep wells. All process wastewater and process area storm waters that make up the Neoprene business are disposed through one of three permitted hazardous waste UIC deep wells, except for the Neoprene manufacturing unit where process wastewater and process area storm water that is treated by the BWWTP. The BWWTP receives and treats process wastewaters, process area storm waters, laboratory wastewaters and non-process wastewaters generated within the process area associated with Neoprene unit and supporting operations. Effluent from the BWWTP is monitored at Outfall 101 prior to being routed to the River Water Return system for final discharge through Outfall 001 to the Mississippi River. The BWWTP includes the following treatment system processes, equalization, sedimentation, activated sludge, clarification, sludge dewatering, and effluent pH adjustment (as necessary). The BWWTP is pictured below, the aerial was obtained from Google maps.
DuPont's Pontchartrain Works units or areas were not reviewed as part of this inspection. 5
EPA Inspection Report - Page 6 of 6
Denka Performance Elastomer LLC / Pontchartrain Plant Inspection Date 04/18-21/2022
Section III - AREAS OF CONCERN
Requirement: LPDES Permit LA0127190, Other Conditions: In addition to the standard conditions required in all NPDES permits and listed in standard conditions for LPDES permits, the Louisiana Department of Environmental Quality (LDEQ) has established the following additional conditions in accordance with the Louisiana Water Quality Regulations. A. This permit does not in any way authorize the permittee to discharge a pollutant not listed or quantified in the application or limited or monitored for in the permit. As stated in the facility's permit application, the process wastewaters and process area storm waters from the Chloroprene unit are collected and routed to the Aqueous Waste (AW) Area for disposal through one of three permitted hazardous waste UIC deep wells and not discharged to surface waters.
Concern 1: As described on page 3 of this report, the Chloroprene unit has a concrete ditch along the Northside of the unit. If process wastewaters or stormwaters are released into this ditch and flow to DuPont's internal ditch on fifth street this would constitute an unpermitted discharge and would be a violation of the Clean Water Act. No discharges thru this ditch were observed or could be verified at time of the inspection.
Concern 2: As described on page 4 of this report, I observed an open valve on the southside of the Chloroprene unit. This open valve is located at the process wastewater and storm water collection sump inside the Chloroprene unit. If the sump overflows thru this open valve and releases into DuPont's internal ditch on `A' Avenue this would constitute an unpermitted discharge and would be a violation of the Clean Water Act. Requested process SOPs for the operation of controlling process wastewaters and fire activities related to this valve were not provided prior to the time of this report. No discharges thru this valve were observed or could be verified at time of the inspection.
EPA Region 6 inspectors Kenneth AuBuchon conducted a closing conference at Denka Performance Elastomer LLC - Pontchartrain Plant at approximately 4:30pm on April 21, 2022, for the NPDES inspection. During the closing conference, Kenneth AuBuchon reviewed the NPDES Areas of Concern noted during the inspection.
Section IV - FOLLOW UP
Additional information was received by EPA inspectors after exiting the facility on April 21, 2022. Documents were requested under the authority by RCRA 3007(a), 42 U.S.C. 6927 and CWA 308, 33 U.S.C. 1318.
Section V - LIST OF APPENDICES
No appendices are attached to this report. All documents received under RCRA CBI and Homeland Security sensitive information (HSSI) claims by the facility will be contained in a separate RCRA report using RCRA CBI requirements.
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