Document Vj3KMo29qRgVm7xnBxwexq79j

f t EA~United States ..:t'!"' Environmental Protection ~ Agency Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): 10/24/2017 Media: Air Regulatory Program(s) NESHAP NSPS Title V Clean Air Act Company Nam~: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Deltech Corporation Deltech Corporation - Baton Rouge Facility 11911 Scenic Highway Baton Rouge, LA, 70807 11911 Scenic Highway Baton Rouge, LA, 70807 East Baton Rouge Parish Doug Griffin I Operations Manager dgriffin@deltechcorj2.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110000450002 Al238 AFS 2203300006 325110 2869 Personnel participating in inspection: Justin Chen EPA 6EN-AT Environmental Engineer James Haynes EPA 6EN-AT Physical Scientist James Leathers EPA 6EN-AT Environmental Engineer Prince Nfodzo EPA 6EN-AA Environmental Engineer Bradley Gauthier LDEQ Environmental Scientist Doug Griffin Deltech Corporation Operations Manager Karen Brignac PPM Consultants Environmental Compliance EPA Lead Inspector Signature/Date ~''"''"-""''"' . / , . .......... Manager (;~;;~;:::;~ ; / -'fcD~o~ ---". Supervisor Signature/Date ~Wt~v\ ~fib~ {Supervihl>r name} 214-665-2273 214-665-6569 214-665-8545 214-665-7 491 225-219-3340 225-358-3171 225-293-7270 t2/,;,;,r- Date 12-/1'3/l 1 Date 6ENFORM-019-R7 (2/15/2017) 1 Deltech Corporation/ Baton Rouge Facility Inspection Date 10/24/2017 Section I - INTRODUCTION PURPOSE OF THE INSPECTION Four United States Environmental Protection Agency (US EPA) Region 6 Air Enforcement inspectors ("the inspection team" or "the team") arrived at the Deltech Corporation - Baton Rouge Facility (Deltech) at 8:10 AM on October 24, 2017 for an announced inspection. The team was led by Justin Chen, Environmental Engineer, and also included James Haynes, Environmental Scientist, James Leathers, Environmental Engineer, and Prince Nfodzo, Environmental Engineer. We met with Doug Griffin, P.E. (Operations Manager) and Karen Brignac (Environmental Compliance Manager, PPM Consultants) at the Opening Conference. Prince Nfodzo presented his credentials to Deltech staff and I informed them that this was an EPA inspection to determine compliance with the facility's Title V Air Permit and the Clean Air Act. The scope of the inspection is a partial compliance evaluation (PCE) that includes an evaluation of compliance with the facility's Title V operating permit and Louisiana State Implementation Plan (SIP) regulations, specifically focusing on flaring operations. This inspection was prompted by the National Enforcement Initiative: Cutting Hazardous Air Pollutants and its associated Enforcement Alert concerning Flaring Efficiency Violations. The inspection was conducted in coordination with the Louisiana Department of Environmental Quality (LDEQ), and Bradley Gauthier (Environmental Scientist) of LDEQ attended the inspection. The sign-in sheet is in Appendix 2. FACILITY DESCRIPTION Deltech Corporation owns and operates the Baton Rouge Facility in Baton Rouge, Louisiana and was originally built in the 1950s to produce both styrene and polystyrene. The facility operates 8760 hours per year producing specialty monomers, including styrene, methyl styrenes, divinyl benzene, ethylvinyl benzene, diisopropenyl benzene, and tertiary butyl styrene. Processes include alkylation, dehydrogenation, purification, and production. Deltech also stores and distributes styrene monomer as a terminal operation. The only flare at the facility, a non-assist flare, began operation in 1975 according to Deltech staff, is permitted as GQ-001, and controls emissions from dehydrogenation reactors DH1, DH4, DH5, and DH303 (Specialty Chemical Process (SCP) dehydrogenation reactor). Section II - OBSERVATIONS At the opening conference, Deltech Facility staff provided documents requested in Appendix 3 and the inspection team reviewed the documents. Karen Brignac explained that the facility typically produces specialty monomers with product changes approximately every 2-3 months and there is an increased usage of the flare at beginning and end of these production campaigns due to startup and shutdown. Karen Brignac explained that at the moment of inspection, only the DH1 and DH303 SCP dehydrogenation units were venting to the flare. Based upon Karen Brignac's explanation as well as the Title V permit, DH1 and DH303 continuously vent to the flare, while DH4 and DH5 only vent to the flare during startup and shutdown. Karen Brignac said that that during styrene production there is a process 2 Deltech Corporation/ Baton Rouge Facility Inspection Date 10/24/2017 vent subject to 40 CFR 63 Subpart FFFF (National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing) group 1 requirements, but there is no flaring potential. I was told and observed that the flare's flame detection was done using a remote UV sensor that is connected to an analog strip recorder (Appendix 1, Photo No. 2). The results of the strip recorder are transcribed to a digital sheet to document any deviations. During the tour of the facility, we observed two internal floating roof (IFR) tanks. Facility staff stated that these IFR tanks were meant for benzene chemical storage in the production of pure styrene; however, they were currently storing light byproduct (tank 808) and toluene (tank 811). Facility staff stated that the SCP unit was producing divinyl benzene at the time of the inspection. When the inspection team reached the flare (Appendix 1, Photo No. 1), facility staff stated that there was no sweep gas or supplemental gas injected into the flare and that the only control on the flare was a manual valve. The units are routed to the flare with the manual valve. At the departure conference, Karen Brignac stated that estimation of the flare's operating data as presented in the Flare Vents Worksheet (Appendix 4) were based upon the process knowledge from a former engineering employee who retired several years ago. She also stated that the tables and calculations of the Flare Vents Worksheet (Appendix 4) were based upon a steady state understanding of the plant. In addition to this worksheet, Karen Brignac stated that a performance test on the flare had been conducted in 2011 by Metco Environmental. I requested this document and it was sent to me after I returned to the EPA Region 6 office. Also at the departure conference, I asked Doug Griffin how long a startup or a shutdown for DH4 or DH5 typically took. He stated that those actions typically take between 4 to 6 hours each, for which the flare would be operating to control emissions from those operations. I was also told that each product change, which forces a shutdown/startup cycle, is on its own schedule and there is typically no overlap. At the departure conference, I requested follow up information for how the Flare Vents Worksheet (Appendix 4) was developed, and I also requested the flare performance test report that Karen Brignac had informed me about at the opening conferenceI received signed Confidentiality Notices from Deltech management for Confidential Business Information (CBI) provided by the facility, and copies of photographs taken at the facility were given to Deltech management at the departure conference. The photos taken are located in Appendix 1. Section III - AREAS OF CONCERN I observed no areas of concern (AOCs) at the time of the inspection, but I noted an AOC subsequent to the onsite inspection that flare operational data provided at the time of inspection did not match other data provided in follow up documentation. These discrepancies are detailed in Section IV. Section IV - FOLLOW UP 3 Deltech Corporation/ Baton Rouge Facility Inspection Date 10/24/2017 The following information was received by EPA after exiting the Facility on October 24, 2017: Metco Environmental's 2011 Source Emissions Survey of Deltech Corporation Baton Rouge Louisiana East (Metco Flare Performance Test; Appendix 5) Flare Vents Worksheet Explanation (Appendix 6) After reviewing the Metco Flare Performance Test and comparing it with the Flare Vents Worksheet (Appendix 4), which was provided during the inspection, I noted the differences found between the two documents with regards to flare operational values. Document Flare Gas Net Heating Value (MJ/scm) Actual Exit Velocity (m/sec) Allowable Requirements: 40 CFR 63.11 (b) 7.45 37.2/293 Metco Flare Performance Test (2011) Average Value Measured: 10.234 Average Value Measured: 1.81 Flare Vents Worksheet Minimum Heat Release Calculated: 53.524 Maximum Flare Exit Velocity Calculated: 3.73 According to the Metco Flare Performance Test, the flare was operated under the condition that only the SCP was being routed to the flare at the time of testing. According to the Flare Vents Worksheet Explanation, the Flare Vents Worksheet engineering calculations do include DH1, DH4, DH5, and DH303 SCP being routed to the flare, however, the minimum heat release calculation only includes SCP vent gas and pilot gas being routed to the flare. The flare gas net heating values from both documents should be comparable, but the Flare Vents Worksheet value is over five times greater than what was found in the Metco Flare Performance Test. This is possibly due to differences in chemical compositions used to characterize the vent gas being sent to the flare. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 2 photos taken 10/24/17 Appendix 2 - Opening conference sign-in sheet Appendix 3 - Documents Request Appendix 4 - Flare Vents Worksheet 4 Deltech Corporation/ Baton Rouge Facility Inspection Date 10/24/2017 Appendix 5 - Metco Environmental's 2011 Source Emissions Survey of Deltech Corporation Baton Rouge Louisiana East Appendix 6 - Flare Vents Worksheet Explanation 5 Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Deltech Corporation - Baton Rouge Facility City: Baton Rouge County/Parish: East Baton Rouge State: LA Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0195.JPG 10/24/2017 10:18AM Justin Chen Non-assisted Flare UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Deltech Corporation - Baton Rouge Facility City: Baton Rouge County/Parish: East Baton Rouge State: LA Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0196.JPG 10/24/2017 10:33AM Justin Chen Control Room Flare Flame Presence Scroll Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Appendix 2 Opening Conference Sign-In Sheet Deltech Corporation/ Baton Rouge Facility Inspection Date 10/24/2017 Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Appendix 3 Documents Request GENERAL PROCEDURE Deltech Corp - Baton Rouge Facility Baton Rouge, Louisiana E.P.A. 6EN-AT Records/Documents Request During the focused Clean Air Act compliance investigation at Deltech Corp - Baton Rouge Facility (Deltech) in Baton Rouge, Louisiana, inspectors will be reviewing records kept for your facility. In order to expedite this portion of the investigation, EPA is providing you advanced notification of the records that will likely be reviewed on-site. For most documents, EPA will review the records on-site and request copies, as needed. In certain cases, document copies will be requested for later review by EPA. In preparation for this focused multimedia compliance investigation, EPA has divided this record and document request into two sections. The first section consists of documents that EPA would like available and copies prepared (only as noted) on October 24, 2017. The second section consists of general and media specific documents that will most likely be reviewed by EPA inspectors during the inspection. Other documents may also be requested that are not listed. During the investigation, EPA will work with Deltech to develop a schedule to review these documents. PART 1 - Please have these documents available on October 24, 2017 1. Descriptions for all process areas including the following information: a. Process flow diagrams (4 copies) with attached written descriptions b. Material balances c. Pollution control equipment d. Raw materials used and annual usage e. Products made 2. Site map of the facility (4 copies) 3. Facility organizational chart (including overall responsibilities and environmental department) (1 copy) 4. Monthly production for each type of product manufactured from 2014 to present (1 copy) Clean Air Act (CAA) 5. Most recent Title V operating permit (1 copy) 6. Identification of emission sources subject to MACT requirements 7. Provide the following information for flares at the facility: a. Date of installation b. Manufacturer and model number c. Purpose (e.g., emergency only, routine, intermittent process waste gas) d. General design type (e.g., ground or elevated, multi-tip or single tip, assisted or nonassisted; if assisted, indicate whether flare is steam, air, or pressure assisted) i. Minimum assist steam (in lb/hr) or assist air (in scf/hr) rate at all locations on each flare, and means of control of steam or air (e.g., valve, bypass orifice); e. Please describe how the amount of waste gas, purge gas, sweep gas, supplemental gas, assist steam, and assist air is measured or monitored f. Please provide a diagram that shows the locations of each: i. Measurement or monitoring point for pressure, flow, net heating value, molecular weight, and constituent concentration ii. Injection point for purge gas, sweep gas, and supplemental gas 8. All stack test/performance test reports for the flare(s) describing methods used, test data, calculations, test results and process information. Include all test data from tests done by the company, consultants or regulatory agencies. 9. For all continuous monitoring systems (i.e. COMS, CEMS, etc.), provide a description of monitoring data for each monitored parameter used to demonstrate continuous compliance with any applicable emission standard or permit requirement. Part 2 - Documents to be provided post inspection General 1. Enforcement Actions/Notices of Violations (NOVs) 2. Consent Decrees/Orders/Agreements and related correspondences Clean Air Act 3. For periods when waste gas is sent to the flare(s), please provide the following information for each flare in searchable and editable electronic format (e.g., spreadsheet): a. The hourly average net heating value, in British Thermal Units per standard cubic foot (BTU/scf), of the vent gas for the period beginning 3 years prior to the date of receipt of this request. b. The hourly average concentration of each constituent of the vent gas for the period beginning 3 years prior to the date of receipt of this request. c. The hourly average mass flow rate, in lb/hr, of the vent gas for the period beginning 3 years prior to the date of receipt of this request. d. The hourly average rate at which assist steam and/or assist air was added to the flare, in lb/hr for steam, or scf/hr for air, at all locations on each flare (i.e., the sum of seal, upper, lower, winterizing, etc.) for the period beginning 3 years prior to the date of receipt of this request. If the hourly averages for any or all of the subsections above are measured, but data is not available, provide an explanation for each time period missing hourly data (e.g., flare not in service, instrumentation malfunction, etc.). If the requested data is not measured or otherwise monitored, use the best means available to calculate/estimate the hourly averages. Provide a narrative explanation and example calculations describing how you arrived at your response. Such methods of calculation/estimation include, but are not limited to, the use of calculations from an online, intermittent, or continuous gas chromatograph (whether at the flare or upstream of the flare), estimating flow from pressure measurements or from valve position data, periodic samples/analysis of gas flowing to the flare, and/or process knowledge. If the requested data was not measured or cannot be calculated or estimated (e.g., lack of equipment, equipment malfunction, and/or maintenance at a flare), provide an explanation of why no data is available and why the data cannot be calculated or estimated.) 4. For each flare (if applicable), provide the hourly average Steam-to-Vent Gas Ratio (lb Steam/lb Vent Gas) for the period beginning 3 years prior to the date of receipt of this request. If the rate at which steam added is not measured, use the best means available to estimate it. Provide a narrative explanation, including considerations for seasonal variations and minimum flow, with example calculations describing how you arrived at your response. All steam (including minimum or bypass steam) should be included in ratio calculation. 5. For each flare, describe how the pilot flame is monitored and how the monitoring data is recorded. Provide the monitoring data for the flare pilot flame for the period beginning 3 years prior to the date of receipt of this request. 6. For each flare, provide copies of documents in your possession, custody, or control pertaining to operating procedures, monitoring procedures, and flare performance testing. 7. For each flare, state whether the flare is configured to receive gases/vapors from one or more pressure relief device(s), which is a safety device used to prevent pressures from exceeding the maximum allowable working pressure of the process equipment. Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Appendix 4 Flare Vents Worksheet Vent Flows MS Unit Dehydrogenation Reactor DH001 Dehydrogenation Reactor DH004 Dehydrogenation Furnace HF004 Atm. Flare GQ-001 Start up and shut down only Dehydrogenation Reactor DH005 Dehydrogenation Furnace HF005 Alkylation Vents Boilers Vent Flows SCP Unit SCP Dehydrogenation Reactor Flare GQ-001 FLARE Vents Component Formula Molecular Weight Heat of Dehydro Combustion Off-Gas LHV Dry Mbtu/LB lbs/Hr Dehydro Alkylation Heat Off-Gas release Max MMBtu/Hr Lbs/Hr Alkylation Heat Release MMBTU/hr SCP Dehydro Off-Gas Lbs/Hr SCP Heat Release MMBtu/Hr Combined Off-Gas to Flare Lbs/HR Total Heat Release (MMBtu.Hr) Hydrogen Methane Ethane Ethylene Propane Propylene Butyls H2 CH4 C2H6 C2H4 C3H8 C4H10 2.016 16.042 30.068 28.052 44.094 58.12 51.39 197.04 23.43 70.56 20.27 Trace 19.93 8.2 19.68 Trace Trace 19.64 Trace 10.126 1.666 0.166 15.65 2.1 69.2 146.58 10.75 13.67 0.804 28.275 0.05 10.725 1.414 Trace 2.971 1.4625 0.214 Trace 0.269 Trace 1.453 0.253 0.03 240.965 83.385 69.2 156.2425 10.75 13.67 12.383 1.954 1.403 3.114 0.212 Benzene C6H6 Toluene C7H8 Ethylbenzene/Xylene C8H10 Styrene C8H8 Ethyltoluene C9H12 Methylstyrene C9H10 Diethylbenzene C10H14 Carbon Monoxide CO Carbon Dioxide CO2 Nitrogen N2 Subtotal Water H2O Natural Gas CH4 Total 78.108 92.134 106.16 104.144 120.186 118.17 134.212 28 44 28 18 16.042 1065.548 17.43 23.8 17.58 7.32 17.74 8.08 17.57 5.44 17.82 17.69 17.95 4.35 3.29 170.98 Trace 282.47 494.71 0.415 0.129 0.143 0.096 0.014 12.755 0.01 0.01 4.55 262.52 23.61 306.08 16.89 511.6 0.399 0 0.975 0 0.78 0.3 0.285 0.2925 0.2925 0.017 0.014 0.005 0.005 0.005 0.005 24.785 8.11 8.38 5.725 0.2925 0.2925 1.0725 53.04 5.722 Trace 97.5 0.005 1.792 4.3625 224.02 224.02 854.73 0.432 0.143 0.149 0.101 0.005 0.005 0.019 16.89 871.62 0.399 20.317 Maximum Vent Gas Flow Volume Calculation Pounds All Vent Gas/Hr Pounds/cubic ft @ STP 871.62 Lbs/Hr 0.075 Lbs/Ft3 SCP Vent Flow Pounds SCPVent Gas/Hr Pounds/cubic ft @ STP 97.5 Lbs/Hr 0.075 Lbs/Ft3 NG Pilot Pounds Natural Gas/Hr Pounds/cubic ft @ STP 16.89 Lbs/Hr 0.075 Lbs/Ft3 MAX - All Vents 11621.6 SCF/Hr SCP 1300 SCF/Hr NG Pilot 225.2 SCF/Hr STP = 60F 14.7 psia Heat Release Calculation Maximum - All vents to Flare MMBtu/Hr SCF/Hr 20.317 MMBtu/Hr X1000000 Max Heating Value 11621.6 SCF/Hr 1748.21 Btu/SCF Minimum - SCP and Pilot Gas Only (normal operation) MMBtu/Hr SCF/Hr 1.792 MMBtu/Hr+ 0.399 MMBtu/Hr 1525.2 SCF/Hr X1000000 Min Heating Value 1436.53 Btu/SCF Maximum Vent Gas Flow Volume Adjusted for Actual Temerature and Pressure Use Charles' Law for Temperature Adjustment Initial Volume Initial Temp Final Volume Final Temp Initial Volume is Initial Temp is Final Temp is 11621.6 SCF/Hr 60F 90F 90 F 60 F Final Volume adjusted for Temp 11621.6 SCF/Hr 17432.4 SCF/Hr Use Boyle's Law for Pressure Adjustment Initial Pressure Final Volume Final Pressure Initial Volume Initial Volume is Initial Pressure is Final pressure is 17432.4 SCF/Hr 14.7 psia 16.7 psia (Use temp adjusted) (use 2 psig) 14.7 psia 16.7 psia Final Volume adjusted for temp and pressure 17432.4 SCF/Hr 15344.69 SCF/Hr Maximum Flare Exit Velocity Calculation Flare Tip Area 8 inch flare tip 8 inches 12 inches/ft Area = r = 0.3483684 Sq Ft 0.6667 ft Radius = = 0.333 ft 3.141596 Velocity Ft/s = CFM 60(Area ft) 255.7448 CFM 60 (0.349 Ft) 15344.69 SCF/Hr 60 Min/Hr Flare Exit Velocity 12.235362 Ft/Sec 255.7448 CFM Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Appendix 5 Metco Environmental's 2011 Source Emissions Survey of Deltech Corporation Baton Rouge Louisiana East Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Appendix 6 Flare Vents Worksheet Explanation Flare Vents Worksheet The information on the composition of each stream sent to the flare was developed by a process engineer who retired a few years ago. He had extensive knowledge of the site. It is our understanding that these numbers were based on design information as well as limited sample results. The SCP Dehydro reactor vents to the flare at all times it is operating. Dehydro reactors #4 and #5 and the alkylation reactor vent to the flare only on startup and shutdown. For permitting and emissions estimation purposes, it is assumed that they vent to the flare 12 hours per month with the remainder of operational time venting back to the furnace. The actual venting time to the flare is not documented. The Dehydro reactor #1 vent stream is piped into the vent from the #4 Dehydro reactor however the compressor going back to the #4 Dehydro furnace is only sized for the flow from one reactor with the excess going to the flare. Essentially, the entire vent stream from Dehydro reactor #1 goes to the flare. Please note that this is slightly different from what is depicted in the diagram previously provided.