Document KJkXLQjQzv5L4aKaKwoJ5ZjEo

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Evonik, Janesville, Wisconsin Victoria Nelson, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Evonik Corp. (Evonik) Facility Location: 900 S Palm Street, Janesville, Wisconsin Date of Inspection: November 7, 2022 EPA Inspectors: 1. Victoria Nelson, Environmental Engineer 2. Dakota Prentice, Environmental Engineer Other Attendees: 1. David Ansloos, Evonik, Continuous Improvement Manager 2. Hugo Barbosa, Evonik, Production Manager 3. Sondra Klipp, Evonik, Principal Environmental Specialist 4. Jeff LaBrozzi, Evonik, Site Manager 5. Andy Stevenson, Evonik, EHSQ Specialist Contact Email Address: Sondra Klipp - sondra.klipp@evonik.com Purpose of Inspection: To evaluate compliance with the Clean Air Act and the facility's Title V Permit Facility Type: Organic Chemical Manufacturing Regulations Central to Inspection: The facility's Title V Operation Permit; Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemical Manufacturing Industry, 40 C.F.R. Part 60, Subpart VV Arrival Time: 11:15 AM Central Time Departure Time: 3:50 PM Central Time Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Small Business Resource Information Sheet not provided. Reason: Not a small business. Provided CBI warning to facility The following information was obtained verbally from the attendees unless otherwise noted. Process Description: Evonik manufactures surfactants from raw materials, including, but not limited to, animal- and vegetable-derived fats and oils, propylene oxide, ethylene oxide, dimethyl sulfate, and methylene chloride. Raw materials are brought in by truck and rail and held in storage tanks. Evonik combines raw materials to make various products in reactor vessels under heat and pressure. Operations at the facility are divided into two main areas, Areas 1 and 2. Area 1 houses Reactors 2 - 7 and a scrubber. Ethoxylation and propoxylation reactions are conducted in Reactors 2, 4, 5, 6, and 7 and include the reaction of ethylene oxide or propylene oxide with fatty amines. Emissions from these reactors are routed to a steam vacuum stripper and a scrubber, T-91, if making ethoxylates. The scrubbant is phosphoric acid. Area 2 contains Reactors 8 and 10 and Tank 27. Reactor 8 is used to produce dimethyl sulfate quaternary ammonium compounds. Ethylene oxide and propylene oxide are not used in Area 2. Additionally, methyl chloride is recovered with a series of cooler and compressor equipment and a cryogenic system. Recovered methyl chloride is stored in at least four storage vessels. Evonik's processes generate wastewater that is treated on-site. Generated wastewater includes reaction by-products, wash water, and process condensate. Process sewers transfer wastewater to on-site wastewater treatment prior to discharge. On-site wastewater treatment includes pH adjustment and phase separation. Methylene chloride is stripped from the wastewater. Evonik does not treat wastewater for organic compounds. Staff Interview: Evonik operates the facility 24 hours a day for 7 days a week and has 72 employees on-site. Reactor 3 is no longer used. Tank 27 is used as a reactor vessel for a reaction Page 2 of 5 that does not include methylene chloride, or for storage. Evonik does not estimate VOC emissions from this unit. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA toured Areas 1 and 2 and on-site wastewater treatment operations. Photos and/or Videos: were taken during the inspection. EPA took photos using a digital camera. See Appendix A: Digital Image Log. Field Measurements: were taken during this inspection. EPA collected measurements using a flame ionization detector (FID). See Appendix B: Field Measurement Data. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Process flow diagram Most recent stack test reports for air pollution control equipment 2020, 2021 Air emissions calculations with wastewater emissions estimates Wastewater sampling results for organic compounds, including ethylene oxide Additional information and chemical contents for the tanks and switch bank lines found with FID readings during the inspection Compliance Assistance: EPA recommended repair of equipment found with emissions during the inspection. DIGITAL SIGNATURES VICTORIA Digitally signed by VICTORIA NELSON Date: 2023.01.05 Report Author: N__E_L_S__O_N______1_5:2_6_:05_-_06_'0_0'_____________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL _M__A_R_S__H_A__L_L__1_7_:00_:4_9_-0_6'0_0_' _____________ Date: 2023.01.05 Page 3 of 5 Page 4 of 5 Facility Name: Evonik Corp. Facility Location: 900 S Palm Street, Janesville, Wisconsin Date of Inspection: November 7, 2022 APPENDICES AND ATTACHMENTS 1. Confidential Business Information Attachment 2. Appendix A: Digital Image Log 3. Appendix B: Field Measurement Data Page 5 of 5 Contains Items Claimed as CBI - Non-Releasable Facility Name: Evonik Corp. Facility Location: 900 S Palm Street, Janesville, Wisconsin Date of Inspection: November 7, 2022 CONFIDENTIAL BUSINESS INFORMATION ATTACHMENT Facility Name: Evonik Corp. (Evonik) Facility Location: 900 S Palm Street, Janesville, Wisconsin Date of Inspection: November 7, 2022 Evonik claimed the 8 photos taken during the inspection as Confidential Business Information. CBI Page 1 of 1 Facility Name: Evonik Corp Facility Location: 900 S Palm Street, Janesville, Wisconsin Date of Inspection: November 7, 2022 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Dakota Prentice 2. Archival Record Location: R5 Electronic Records Center Image Number 1 2 3 4 5 6 7 8 File Name IMG_0266.JPG IMG_0267.JPG IMG_0268.JPG IMG_0269.JPG IMG_0270.JPG IMG_0271.JPG IMG_0272.JPG IMG_0273.JPG Date and Time (Central Time*) 11/7/2022 2:04 PM Description of Image Propylene oxide storage tanks (left) and ethylene oxide storage tanks (right). 11/7/2022 2:29 PM Tank 41 11/7/2022 2:34 PM Tank 46 11/7/2022 2:38 PM Tank 21 11/7/2022 2:56 PM Pit for Switchbank B 11/7/2022 3:05 PM 11/7/2022 3:29 PM Tank 19 Conservation Vent "Octopus" connections at Switchbank H 11/7/2022 3:31 PM Drain near Tank T-211 IMG_0274.JPG 11/7/2022 Drain near Switchbank G 9 3:33 PM *Note: Timestamps for the photos were originally recorded an hour ahead of local time. Local time is given in the table above. Note: Photos claimed as Confidential Business Information. Appendices Page 1 of 3 Facility Name: Evonik Corp Facility Location: 900 S Palm Street, Janesville, Wisconsin Date of Inspection: November 7, 2022 APPENDIX B: FIELD MEASUREMENT DATA FID Measurement Data Inspector Name: V. Nelson Location FID Reading (ppm) Tank 41 vent for breathing losses 10 Tank 41 conservation vent 30 Tank 46 manway 20 Tank 21 vent 12 Switchbank B: Line 36 to Reactor 6 1300 Switchbank B: Line 21 to Filter Press 1 540 Above collected material in pit below 150 Switchbank B Switchbank B: Line 64 330 Tank 19 Conservation Vent 90 Switchbank G Scupper 16 Above collected material in pit below 25 Switchbank G Switchbank G: Line 224 to S/B-E 800 From P-112 900 Switchbank F Scupper 28 223 Pump 30 Drain near Tank T-211 (marked with purple 25 paint) Drain near Switchbank G (marked with 27 purple paint) Calibration and Instrument Information EPA used one ThermoFisher Toxic Vapor Analyzer 2020 (TVA2020). The EPA TVA2020 response times are in the 4 to 5 second range. Victoria Nelson used TVA2020 ID: B37056 for the duration of the inspection. Instrument calibration was conducted at 1:45 PM Central Time on November 7, 2022: Calibration Gas Concentration (ppm) 500 2,000 10,000 B37056 Reading (ppm) 502 1,996 10,200 EPA performed a drift check reading following the site tour at 3:50 PM Central Time on November 7, 2022: Calibration Gas Concentration (ppm) 500 B37056 Reading (ppm) 502 Appendices Page 2 of 3 Facility Name: Evonik Corp Facility Location: 900 S Palm Street, Janesville, Wisconsin Date of Inspection: November 7, 2022 2,000 10,000 2,104 10,700 Calibration Gas Information Manufacturer Composition Air Systems Zero air International GASCO Methane, 500 ppm Calgaz Methane, 2,000 ppm Calgaz Methane, 1% Lot # 304-402520136-1 304-402518883-1 1434290 1440891 Expiration 8/22/24 8/15/26 6/1/26 6/1/26 Appendices Page 3 of 3