Document RJYZX87oRam9VDp96DbpBVx7X
DATE:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS
77 WEST JACKSON BOULEVARD CHICAGO, IL 60604
JUL O3 2019
SUBJECT: FROM:
CLEAN AIR ACT INSPECTION REPORT
The Lubrizol Company, Painesville, Ohio
JJ Charles Hall, Environmental EngineerC
AECAB (MN/OH)
.
THRU:
Dakota Prentice, Acting Section Chief AECAB (MN/OH)
TO:
File, The Lub1izol Company, Painesville, Ohio
BASIC lNFORMATION
Facility Name: The Lubrizol Company
Facility Location: 155 Freedom Road, Painesville, Ohio 44077
Date of Inspection: May 8, 2019
EPA Inspector(s): 1. Charles Hall, Environmental Engineer 2. Kosta Loukeris, Environmental Engineer
Other Attendees: 1. Patricia Kay, Environmental Assurance Engineer 2. Greg McCullough, General Manager 3. Kirk Oswald, Utilities Superintendent 4. Ciara Seitz, Environmental Superintendent 5. Suzanne Skrab, Environmental Specialist 6. Kelly Winfield, Health, Safety, Environmental, & Security Manager (by telephone)
Contact Email Address: ciara.seitz@lubrizol.com
Purpose of Inspection: hazardous waste incinerator ("HWI") inspection
Facility Type: chemical manufacturer
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Regulations Central to Inspection: National Emission Standard for Hazardous Air Pollutants from Hazardous Waste Combustors at 40 C.F.R. Part 63, Subpart EEE ("HWC MACT"); National Emission Standard for Benzene Waste Operations, at 40 C.F.R. Part 61, Subpart FF (BWON); and National Emissions Standards for Hazardous Air Pollutants for Chemical Manufacturing Area Sources, at 40 C.F.R. Part 63, Subpart VVVVVV (NESHAP VVVVVV)
Arrival Time: I0:00 a.m. EDT
Departure Time: 5:55 p.m. EDT
Inspection Type: IZ'J Unannounced Inspection Announced Inspection
OPENING CONFERENCE
lg] Credentials Presented IZ'J CBI warning to facility provided
The following information was obtained verbally from Kay, McCullough, Oswald, Seitz, Skrab, and Winfield, unless otherwise noted.
Process Description:
Lubrizol bums recovered organics, aqueous waste, pipe and process tank flushes, distillates, and containerized waste in its hazardous waste incinerator. All of the waste is generated onsite. Lubrizol does not accept any waste from offsite. Lubrizol collects liquid wastes from 90-day tanks in Tank W34 in which the aqueous and organic layers separate. Organic wastes are pumped into Tank W33 then to Tanks W3 l and W32 before they are fed to the HWI. Aqueous wastes are pumped into Tank WI 5 and then Tank Wl4 before they are fed to the HWI.
Staff Interview:
The site representatives stated that the concentrations of the HWC MACT-regulated pollutants in the waste streams vary over a narrow range. Oswald noted that the waste streams higher heating value is very consistent. The most common cause of an exceedance of an operating parameter limit or the carbon monoxide emission standard is a power outage.
TOUR INFORMATION
EPA toured the facility: Yes
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Data Collected and Observations:
At the time of the inspection, Lubrizol was re-starting the HWI after an extensive maintenance project. Consequently, Lubrizol was not burning hazardous waste at the time of the inspection and operating parameter limit and carbon monoxide emission data are not available.
Photos and/or Videos: were taken during this inspection.
Field Measurements: were taken during this inspection.
Calibration of EPA Toxic Va or Analyzer (Cleveland Office)
Calibration Gas Standard Confim1ation Readin,
500 Ill
501
Summarv of Outlet Concentrations from Carbon Canister on 90-Day Storae:e Tanks
Carbon Canister Capacity, Highest Measured Concentration, Location of Highest
on 90-Day
gallons
parts per million by Volume
Measured Concentration
Storage Tank
Pl0
2.390
N/A
N/A
.115
6,000
N/A
NIA
102T
4J90
125
Top Flange
181
Carbon
130T
6,000
77
Top Flange
' 35
I 31T
3,000
29
Carbon Carbon
E75
6,000
200
Carbon
Summary of Outlet Concentrations from Waste Storage Tank Equipment
Storage Tank
Capacity, Highest Measured Concentration, Location of Highest
gallons
parts per million by Volume
Measured Concentration
WI 1
11,200
4,100
Emern:ency Vent
Wl2
24,000
79
-Emern:ency Vent
W13
26,000
79
Emergency Vent
136
Tank Cover
Wl4
30,000
92
Emergency Vent
20
Tank Cover
WIS
25,000
6,893 to 11,000
Emergency Vent
W31
I 0,500
4,100
Emern:ency Vent
W32
10,500
162
Manwav
'133
50,000
12,500
Emergency Vent
55
Flange
W34
50,000
110
Emergency Vent
787
Manway
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RECORDS REVIEW
Lubrizol provided BWON records from 2011 and 2016 indicating that the total annual benzene was 0.257 megagrarns/year (Mg/yr) and 1.24 Mg/yr, respectively. Lubrizol indicated that they do not submit an annual report to the Agency.
Lubrizol implements the following leak detection and repair (LDAR) programs:
1. Title V: Monitor a subset of 25% of equipment annually using Method 21; 2. NESHAP VVVVVV: monitor one of the four chemical manufacturing process units
using Method 21 as applicable under the standard; 3. Resource Conservation and Recovery Act: Method 21 performed at sources that manage
hazardous waste at the facility.
Lnbrizol indicated that they used to monitor a subset of 50% of equipment components annually under the Title V permit but had recently modified that to 25%. Proactive Environmental is the cunent LDAR contractor. The emission estimates from the components monitored are applied to the unmonitored components at the facility for the purposes of determining total HAP fugitive em1ss10ns.
CLOSING CONFERENCE
Requested Documents: Exhibit D-1 Swrnnary of Physical Characteristics of Tanks; Exhibit D-5 'N Tank Farm Containment; Summary of 20 I 8 Speciated HAP Emissions; 1st quarter CY 2018 Deviations reported per Title V Pennit A.2.c)(2); 2nd quarter CY 2018 Deviations reported per Title V Permit A.2.c)(2); 3'd quarter CY 2018 Deviations reported per Title V Permit A.2.c)(2); 4th quarter CY 2018 Deviations reported per Title V Pennit A.2.c)(2); Tables 6-1, 6-2, and 6-3 from Report for 2018 Comprehensive Performance Test; Annual inspection record for Tanks Wl5, W31, and W33 Total Fugitive Component by Program and Type; Leak DAS LDAR date restored in a MS Access database 2 years Carbon for 90-day tank 2016 Total Annual Benzene Report Fugitive Emission Strategy
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Concerns: EPA did not raise any concerns regarding the HWI; however, EPA raised the following concerns:
1. Lubrizol does not maintain a!1llual records under the BWON to determine the total a!1llual benzene quantity since the materials and quantities processed vary from year to year.
2. Lubrizol does not submit an annual report for the BWON as required for sources that have greater than 1 Mg/yr of benzene annually.
3. Fugitive HAP emissions are being underestimated.
SIGNATURES
Lead Inspector:
Section Chief:
APPENDICES AND ATTACHMENTS
1.
Digital image/video log
2.
Digital images and videos on CD
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APPENDIX A: DIGITAL IMAGE LOG
1. Inspector Name: Constantinos Loukeris
3. Company/Facility Name: T,uhrizol
5. Number of Images: 3
2.
4.
- -----------
6.
Date(s) of Inspection: May 8, 2019 Street Address, City, State: 155 Freedom Road. Painesville, Ohio Archival Record Location: CD-R labeled "Lubrizol, Painesville, OH, Insnection nhotos/video 5/8/2019"
Image
Number File Name
Date
I
MOV 0056.mn4 5/8/2019
2
MOV 0057.mo4 5/8/2019
3
MOV 0060.mn4 5/8/2019
Descrintion ofimage Hydrocarbon emissions were imaged from the emern:ency vent on tank, W33. Hydrocarbon emissions were imaged from the emergency vent on tank, W31. Hydrocarbon emissions were imaged from the emernencv vent on tank, W15.
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