Document X7BVb1j0e2odJj7DZpL44DMjB

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: 09/27/2018 Water Clean Water Act Linde Gas North America, LLC Linde Syngas Plant 11603 Strang Rd La Porte, TX 77571 11603 Strang Rd LaPorte, TX 77571 Harris County Terry Phipps 713-767-4150 Plant Manager FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: TX0118389 2899 Personnel participating in inspection: Michael Williams EPA/ 6EN-WMH Chelsey Cobb Linde Syngas Inspector Environmental 281-983-2150 713-767-4175 EPA Lead Inspector Signature/Date Supervisor Signature/Date MICHAEL WILLIAMS Michael D. Williams Digitally signed by MICHAEL WILLIAMS DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=MICHAEL WILLIAMS, 0.9.2342.19200300.100.1.1=68001003655912 Date: 2018.12.18 13:41:27 -06'00' Date CAROL PETERS-WAGNON Digitally signed by CAROL PETERS-WAGNON DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=CAROL PETERS-WAGNON, 0.9.2342.19200300.100.1.1=68001003652679 Date: 2018.12.18 14:44:38 -06'00' Carol Peters Date Linde Gas North America, LLC (TX0118389) Inspection Date 09/27/2018 Section I - Introduction PURPOSE OF THE INSPECTION EPA Region 6 inspector, Michael Williams, arrived at Linde Syngas Plant at 11:24 am on September 27, 2018 for an unannounced inspection. I met with Plant Manager, Terry Phipps. I presented my credentials to Mr. Phipps and informed him that this was an EPA lead Compliance Evaluation inspection to determine compliance with the facility's National Pollutant Discharge Elimination System (NPDES) permit and the Clean Water Act. The scope of the inspection was with permit TX0118389, facility operations and maintenance under the Clean Water Act. The inspection was conducted under the authority of the NPDES permit program, in accordance with the Federal CWA. The information presented in this report is based on the materials and information supplied by Linde Gas North America, LLC., representatives (the permittee), observations made during the inspection and records and reports maintained by the permittee. FACILITY DESCRIPTION The Linde Syngas Facility in La Porte, Texas produces synthesis gas, or syngas, which is a mixture of carbon monoxide and hydrogen. Linde provides the adjacent La Porte Methanol Company, LP facility1 with carbon monoxide and hydrogen to produce methanol. La Porte Methanol Company is a joint venture between Linde and LyondellBasell, operated by Linde. Crude methanol can also be received from offsite for refining at La Porte Methanol. The primary process wastewater is from three Syngas partial oxidation units (POX), the Syngas methanol water column bottoms, methanol stripper tail wastewater from methanol production, miscellaneous steam condensate, process area wash downs, and safety shower drains. The miscellaneous steam condensate and process area wash downs are routed to process sewer collection hubs. The POX wastewater contains ammonia and trace amounts of total organic carbon and total suspended solids. The POX wastewater is routed to an ammonia stripper, then to the neutralization tank, then to the diversion tank. Wastewater in the diversion tank can be routed to the equalization tank. Wastewater from the diversion tank can be provided with additional treatment if needed before routing to the Mid Basin; alternatively, wastewater from the diversion tank can be routed offsite for treatment. Wastewater in the Mid Basin can be transferred to either the West Basin or Aeration Basin and then back to the Mid Basin. Discharge from the Mid Basin is routed to Outfall 001. The methanol water column bottoms wastewater is generated in the Rectisol Syngas treatment unit. Methanol is used as a solvent in the Rectisol process to absorb acid gas components and remove impurities from raw syngas and the methanol water column removes the final impurities from the loaded methanol stream. The methanol water column bottoms wastewater is routed either to the Mid Basin for discharge to Outfall 001 or can be transferred offsite for treatment. This wastewater is pH controlled to prevent corrosion and contains trace amounts of methanol. Utility wastewaters discharged through Outfall 001 include cooling tower blowdown, boiler blowdown, steam condensate, demineralizer regenerate wastewaters, belt press wash water, raw or filtered water, and sample cooler water. Boiler blowdown is normally routed to the 2 Linde Gas North America, LLC (TX0118389) Inspection Date 09/27/2018 bulk recirculating cooling tower, but in some cases such as when there is an issue with a pump, it may be routed to Outfall 001 via the clear water sewer. The methanol stripper tail wastewater from the distillation step is currently transferred offsite for treatment to the Gulf Coast Waste Disposal Authority Bayport Facility (GCA Bayport) for further treatment under the Bayport Facility's TPDES Permit No. WQ0001054000 Section II- Observations This inspection revealed the following observations: The site recently built and was operating a membrane bio-reactor (MBR) because of previous permit exceedance. The MBR was built in 2017 (Appendix A). Linde was not able to send the same amount of process water to Gulf Coast Waste Disposal and the exceedance was from the wastewater restriction. The restriction required Linde to treat the additional 140 gpm flow onsite. Linde built and tied the MBR into the existing process to treat the additional flow. No exceedance has occurred since MBR operation has started. The facility needs to provide a certified thermometer inside the compositor. On the day of the inspection, Linde was utilizing a digital thermometer. A certified thermometer is needed to verify and ensure accuracy of digital readings and recordings. Section III- Areas of Concerns This inspection revealed the following areas of concerns: No major areas of concern Section IV - LIST OF APPENDICES Appendix A - MBR Technical Details 3 Linde Gas North America, LLC (TX0118389) Inspection Date 09/27/2018 Appendix A MBR - Technical Details 4