Document ZJ2oBj4bNJV5Ne87q4XDmKqpp
EPA Inspection Report - Page 1 of 49
ft EA~United States
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Environmental Protection
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Agency
Region 6 Compliance Assurance and Enforcement Division
INSPECTION REPORT
Inspection Date(s): Media: Regulatory Program(s)
09/10/2018- 09/13/2018 Air NSPS, NESHAP
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code} Mailing address:
(city, state, zip code} County/Parish: Facility Contact:
International Paper Company Bogalusa Mill 401 Avenue U Bogalusa, Louisiana 70427 401 Avenue U Bogalusa, Louisiana 70427 Washington Parish Laura Connor laura.connor@ipaper.com
I EHS Manager
FRS Number: Identification/Permit Number: Media Number: Primary NAICS: Primary SIC:
110033671284 AI: 38936; Title V: 3060-00001-9AA AFS:22-117-00001 322130 2631
Personnel participating in inspection:
James Haynes
EPA/6EN-AT
James Leathers
EPA/6EN/AT
Sarah Frey
EPA/6EN-AT
Davina Witte
LDEQ
Susan Rahey
LDEQ
Tyler Williams
LDEQ
Bernard Chascin
IP Bogalusa Mill
Laura Connor
IP Bogalusa Mill
Alban Bush
IP Bogalusa Mill
Clint Casanova
IP Bogalusa Mill
Physical Scientist Environmental Engineer Physical Scientist Environmental Scientist Environmental Scientist Environmental Scientist Mill Manager EHS Manager Environmental Manager Environmental Engineer
EPA Lead Inspector Signature/Date
Supervisor Signature/Date
~...........
Ja#{es Haynes
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Margarelt)Jsbourne
214-665-8546 214-665-6569 214-665-6499 504-736-7730 507-736-7747 504-736-7729 985-732-8500 985-732-8764 985-516-3075 985-732-8697
to/z3/ lC6
Date
1or?., '311e&
Date
6ENFORM-019-R7 {2/15/2017}
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EPA Inspection Report - Page 2 of 49
Section I - INTRODUCTION
International Paper Company / Bogalusa Mill Inspection Dates 09/10/2018 - 09/13/2018
PURPOSE OF THE INSPECTION
Three Unites States Environmental Protection Agency ("U.S. EPA") Region 6 Air Enforcement inspectors ("the inspection team") arrived at International Paper Company's Bogalusa Mill ("IP Bogalusa Mill") at approximately 11:00 hours on September 10, 2018 for an announced inspection. The inspection team was led by Mr. James Haynes, Physical Scientist, and included Mr. James Leathers, Environmental Engineer, and Dr. Sarah Frey, Physical Scientist. I, James Haynes, conducted an opening conference with the IP Bogalusa Leadership Team that included Mr. Bernard Chascin, Mill Manager, Ms. Laura Connor, EHS Manager, Mr. Alban Bush, Environmental Manager, and Mr. Clint Casanova, Environmental Engineer. Also, Ms. Davina Witte, Ms. Susan Rahey, and Mr. Tyler Williams, Environmental Scientists with the Louisiana Department of Environmental Quality (LDEQ), ("LDEQ inspectors") participated in the inspection. I presented my credentials to Mr. Chascin and informed him that this was a U.S. EPA inspection to determine compliance with the facility's Title V Air Permit and the Clean Air Act ("CAA") New Source Performance Standards ("NSPS") and National Emission Standards for Hazardous Air Pollutants ("NESHAP"). The scope of the inspection was a partial compliance evaluation ("PCE"). Photographs taken during the inspection can be found in Appendix 1. The Sign-In sheet for the inspection's opening conference is attached as Appendix 2.
FACILITY DESCRIPTION
The IP Bogalusa Mill is a kraft pulp and paper mill in Washington Parish, Louisiana and produces linerboard. The mill currently operates under Permit No. 3060-00001-9AA, issued June 19, 2018. The permit is due to expire April 25, 2019. Primary operations at the mill include multiple fuel-fired boilers (power operations), wood pulping operations, chemical recovery operations, papermaking operations, maintenance, and additional operations and equipment necessary to support these activities. Power operations include two steam boilers and associated processes and equipment. The steam is used for the mill's production processes and directed to turbines for the generation of electricity. Wood pulping operations include two continuous digesters where wood chips are converted into pulp. Chemical recovery operations include evaporators, two recovery furnaces, and associated tanks and concentrators. Additional processes and equipment are necessary to support the chemical recovery operations. The papermaking operations include two Fourdrinier machines that create linerboard. Other operations include, but are not limited to, the woodyard, tall oil operations, causticizing and lime recovery operations, and wastewater treatment.
Section II - OBSERVATIONS
On Monday, September 10, 2018, the inspection team, IP Bogalusa Mill staff, and LDEQ inspectors participated in a driving tour of the aeration stabilization basins of the wastewater treatment system and the different process areas of the mill operations following a brief safety orientation. After the driving tour, we reviewed process flow diagrams and other records while discussing the processes at the
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International Paper Company / Bogalusa Mill Inspection Dates 09/10/2018 - 09/13/2018
plant with Mr. Casanova. The records reviewed on-site, such as the process flow diagrams, were provided to the inspection team in response to a Document Request submitted to Ms. Connor approximately one week prior to the inspection on September 4, 2018. This Document Request is included as Appendix 3. The inspection team departed the IP Bogalusa Mill at approximately 17:00 hours.
On Tuesday, September 11, 2018, the inspection team arrived on-site at approximately 07:15 hours and continued to review documents provided in response to the referenced Document Request. Once LDEQ inspectors arrived, we prepared for a tour of the power plant operations, specifically Power Boiler 12. The tour of Power Boiler 12 was led by Ms. Michelle Murray, Area Process Manager (Power), and Mr. Casanova served as our escort. At this operational area, we observed the monitoring equipment near the exit of the stack, the location of the continuous emissions monitoring system ("CEMS") with associated analyzers and calibration gases, and the control room for the operating area (Photo Nos. 1 and 2). Within the control room, we viewed the cameras of several belts feeding Power Boiler 12. Ms. Murray noted that maintenance was being performed on the main bark belt, and the boiler was operating on natural gas; however, the operator controlling the distributed control system ("DCS") confirmed that small amounts of bark were still being fed into the boiler through a screw feed. After the control room we observed the cinder handling area which washes cinders and returns them to the bark belt as seen in Photo Nos. 3 and 4. Upon completing the tour of this area, we requested two documents shown to us by Ms. Murray indicating locations of equipment and a temperature gradient of the flue gas through the boiler.
The inspection team, LDEQ inspectors, and IP Bogalusa Mill staff then began a tour of the pulping operations. We were escorted by Mr. Casanova and the tour was led by Mr. Robert Hambleton, Area Manufacturing Excellence Leader (Pulp). We began by walking past the K1 digester and its impregnation vessel ("IV"). At the bottom of the K1 IV, we observed a leak comprised of what appeared to be both black liquor and white liquor. See Photo Nos. 5 and 9. Mr. Hambleton explained that the leak was discovered upon restarting the plant after the 2018 annual outage. He indicated that this leak would be addressed for permanent repair at the next annual outage. Until that time, an attempt at a temporary repair was scheduled within the next day. We then observed the contaminated warm water tank and discussed the piping entering and exiting the tank as well as the open "gooseneck" vent on the roof visible in Photo No. 6. We returned to the K1 IV leak location after noticing additional black liquor leaking to the concrete opposite of the IV as seen in Photo No. 7. Mr. Hambleton explained that the leak was coming from the head of the blow line refiner of the K4 digester which was recently worked on during the annual outage. The refiner receives the pulp slurry after the digester to reduce wood to a fibrous mass through mechanical processes, and the unit operates at high pressures to move the slurry to the K4 blow tank. Next, we observed the chip bin and other necessary control equipment since the chip bin receives flash steam from the digester. This flashed steam is part of the low volume, high concentration ("LVHC") system and is required to be controlled. In addition to the chip bin and gas collection system, we viewed the coolers that condense liquids from the gas collection system and multiple locations where the control devices can be bypassed, i.e. vent to atmosphere (Photo No. 8). Another part of the gas collection system are pressure relief devices that can allow the gases collected
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to vent to atmosphere if working pressures rise above an unsafe level. An example of a device we viewed is a rupture disk, and Mr. Hambleton explained that the IP Bogalusa Mill records two parameters (temperature and pressure) on either side of the rupture disk as a redundancy (Photo No. 11). From the chip bins, we observed the K1 digester and K1 atmospheric diffusion washer from a distance. No visible emissions were observed. We continued to the control room for this process area and were shown where operators control the processes through the DCS. Mr. Hambleton also showed us how the bypass systems are monitored and controlled through the DCS before breaking for lunch.
After a lunch break, we returned to the pulping operations area to view the steaming vessel of the K1 digester and the additional equipment needed for the process such as the low-pressure and highpressure feeders. We also observed the washers of the K4 digester and tags notating leak detection and repair ("LDAR") components near the washers (Photo Nos. 12 through 14). These are enclosed, drum washers that typically run in series prior to high density storage. The washer for the K1 digester is an atmospheric diffusion washer located separate from the building that housed the K1 and K4 digester. We observed one minor leak of black liquor on the ground floor of the building at a trim backflush pump that is infrequently used; however, due to repairs at another pump, the spare was brought into service. Mr. Hambleton stated that once the repairs were done at the other pump, the trim pump would be taken out of service and the leak at the pump flange would stop and be repaired. Following a brief rain delay, we returned to the office to prepare for a debrief with mill management. The inspection team departed the IP Bogalusa Mill at approximately 17:00 hours.
On Wednesday, September 12, 2018, the inspection team arrived on-site at approximately 07:30 hours and continued to review documents provided in response to the referenced Document Request. Once LDEQ inspectors arrived, we prepared for a tour of the chemical recovery operations. The tour of the chemical recovery operations was led by Mr. David Villarrubia, Capital Projects Engineer, and Mr. Casanova was our escort. We began the tour by walking to the eight-effect evaporator system (Photo No. 17). We discussed several pieces of equipment, such as the evaporator hotwell and nearby coolers, before climbing to the level of the evaporators. We walked past each evaporator and followed the piping for the LVHC gases generated at the evaporators at an attempt to see where the LVHC line ties into the existing piping; however, we were unable to obtain a good vantage point to view that location. After viewing the evaporators, we walked to the recovery boiler process area. We viewed the black liquor oxidation tanks associated to Recovery Boiler No. 20 and the concentrator for Recovery Boiler No. 21 (Photo No. 18). We then entered the building for Recovery Boiler No. 21, and we viewed the location where concentrated black liquor is fed into the recovery boiler, the location high volume, low concentration ("HVLC") and LVHC gases - sometimes referenced together as non-condensable gases, or NCGs - are fed into the recovery boiler, and the location where smelt leaves the recovery boiler and enters the smelt dissolving tank (Photo Nos. 20 through 22). We were also able to review the electrostatic precipitator ("ESP") for the Recovery Boiler No. 21 and looked at the continuous opacity monitoring system ("COMS") at the stack. Following the walkthrough of Recovery Boiler No. 21, we entered the control room to look at the controls available to the operators and to see where conditions of the evaporators and other equipment is monitored. While we were in the control room, we observed IP Bogalusa Mill remove the feed of concentrated black liquor that was being sent to Recovery Boiler No.
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20 and to switch to natural gas as the primary fuel of the recovery boiler. After the control room of the chemical recovery operations, we toured the Recovery Boiler No. 20 building and viewed the location were black liquor is concentrated prior to being fed into the boiler. The Recovery Boiler No. 20 is categorized as a direct contact evaporator recovery boiler, and the black liquor is concentrated a final time by the hot flue gas of the boiler. At this boiler, we viewed the black liquor being sprayed down one of two evaporators while the hot flue gases travel upwards and are rejoined before entry into the boilers ESP (Photo No. 23). We also viewed the location where HVLC gases are routed during times the Recovery Boiler No. 21 is unable to receive waste gases. Following the tour of Recovery Boiler No. 20, we returned to the building of Recovery Boiler No. 21, walked by the smelt dissolving tank, and entered the CEMS shack to view the associated analyzers and calibration gases. After the tour, we returned to the office and began our lunch break.
We returned from lunch and continued to review documents and discuss parts of the Document Request with IP Bogalusa Mill technical staff, such as the site-specific LDAR monitoring plan. Following the discussion, we stated that we would like to view a portion of Power Boiler 10C - specifically, the belt carrying bark and cinders. We were unable to obtain an adequate vantage point of the area of interest, and we left the area of Power Boiler 10C. We then began walking in the direction of the lime kiln; however, we stopped en route near the evaporator hotwell to compare the site-specific, LDAR monitoring plan with the components in service (Photo No. 24). Additionally, we began searching for LDAR tags to identify components identified on the plan. We observed groups of tags that were attached to the hand rails, and it was explained to us by multiple IP Bogalusa Mill staff that this was done to simplify the monthly inspections. The idea is that an observer can stand at a specific location and confirm the group of tags, and they will be at a vantage point to observe the components and identify visible evidence of defects in ductwork, piping, enclosures, and connections. After viewing some diagrams and equipment, we continued to the lime kiln operations and turpentine tank. At the lime kiln, the tour was led by Mr. Mark Bryan, Area Process Manager (Caustic). Mr. Bryan gave us a detailed process summary in the control room before viewing the DCS and observing the lime kiln burners. At the time we were at the lime kiln, Mr. Bryan stated that the lime kiln was in service as the backup control device for the LVHC gases that are normally routed to Recovery Boiler No. 21. While we were near the burner, Mr. Bryan pointed out the piping where LVHC gases are introduced into the lime kiln (Photo No. 25). During that time, Mr. Casanova and Dr. Frey were looking at additional LDAR diagrams and tags to confirm components identified in the plan and locations of the components. Following the lime kiln, we viewed the lime kiln condensate tank and continued to the turpentine tank (Photo No. 26). From the turpentine tank, we ended the tour for the day and returned to the office. We conducted a debrief with mill management and departed the IP Bogalusa Mill at approximately 17:15 hours.
On Thursday, September 13, 2018, the inspection team arrived on-site at approximately 07:45 hours and reviewed documents provided in response to the referenced Document Request. Once LDEQ inspectors arrived, we continued discussions regarding the Document Request. Dr. Frey and Ms. Witte met with Mr. Casanova regarding the site-specific, LDAR monitoring plan to discuss discrepancies within the plan. Additionally, I reviewed the 2016 emission inventory to compare reported emissions to permit limits established by the state-issued permit. Following additional discussions among the inspection
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team and LDEQ inspectors, we departed the facility for lunch, and we returned to prepare for a closing conference with IP Bogalusa Mill staff.
Section III - AREAS OF CONCERN
Areas of Concern 1 through 5 were relayed to the facility during the closing conference conducted at approximately 13:45 on Thursday, September 13, 2018. The Sign-In sheet for the inspection's closing conference is included as Appendix 4. Additionally, a copy of all photographs taken were provided to the facility, and no claims of confidential business information ("CBI") were made regarding the photos or documents provided.
1) Regulatory Applicability: The IP Bogalusa Mill has a new tank that may be subject to additional requirements. For example, the IP Bogalusa Mill constructed a spill collection tank in 2013 that is designed to store weak black liquor spills. This project was designed to limit the loading of black liquor to the wastewater treatment system. While this is not currently permitted as a "weak liquor storage tank" as defined by Title 40 of the Code of Federal Regulations (40 C.F.R.), Part 63, Subpart S, it serves a similar function to a weak liquor storage tank. According to 40 C.F.R. 63.443(a)(2)(iv), total hazardous air pollutant emissions from new source, weak liquor storage tanks shall be controlled.
2) Leak Detection and Repair: The IP Bogalusa Mill has numerous inconsistencies between the sitespecific LDAR monitoring plan and actual components that were discovered during the on-site inspection. Additionally, a missing car seal was also noted during the on-site inspection at LDAR Tag No. MV-11014E.
3) Contaminated Warm Water Tank and Controls: The IP Bogalusa Mill operates a contaminated warm water tank that operates as part of the condensate collection system; therefore, the requirements of 40 C.F.R. 63.446(d)(2) may be applicable. Those requirements state that all openings on a condensate tank shall be maintained in a closed, sealed position. In addition, those requirements state that all openings must be free of detectable leaks as indicated by an instrument reading of less than 500 parts per million above background. The "gooseneck" vent not included in the site-specific LDAR plan, and no negative pressure tests have been performed.
4) Emission Inventory: The IP Bogalusa Mill may not have accurately reported emissions to the state of Louisiana for their emission inventory in the latest year available to U.S. EPA at the time of the inspection. For example, the IP Bogalusa Mill operates three high density storage tanks; however, the reported emissions for all three storage tanks appear to be reported under one unique release point. Also, emissions reported for the primary black liquor oxidation tank are not listed as having any permit limits within the state-issued permit.
5) Notification of Compliance Status ("NOCS"): The IP Bogalusa Mill is required to submit a NOCS for each of the MACT rules it is subject to in accordance with 40 C.F.R. 63.9(h). When there is an applicable change to the NOCS already submitted to the Administrator, 40 C.F.R. 63.9(j) requires that
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change be provided to the Administrator within 15 days. The IP Bogalusa Mill has inconsistencies within the NOCS; however, no updated submissions have been identified.
Additional Areas of Concern, noted below, have been identified following the on-site portion of the inspection:
6) Emissions Standards: The IP Bogalusa Mill has reported exceedances for opacity, total reduced sulfur, and nitrogen oxides within their NSPS reports at the recovery boiler and power boilers.
7) Alternative Monitoring Plan ("AMP"): The IP Bogalusa Mill submitted two AMPs with the latest permit application that are intended to cover specific monitoring requirements at the power boilers and LDAR components. For the boilers, only Power Boiler 12 is referenced in the approved AMP; therefore, the AMP may not be applicable to Power Boiler 10C. For the LDAR components, the IP Bogalusa Mill is using an AMP that was approved for other International Paper facilities and may not apply to the IP Bogalusa Mill.
8) Quality Assurance/Quality Control ("QA/QC"): The IP Bogalusa Mill is required to maintain the CEMS unit at Recovery Boiler No. 21 in accordance with 40 C.F.R. Part 60, Appendix F. During an initial review, it appears that a cylinder gas audit may have been conducted closer than two months from the last audit, and the IP Bogalusa Mill may not be meeting the requirements of Appendix F, Procedure 1.
Section IV - FOLLOW UP
Additional information has been received by the U.S. EPA after exiting the Facility on September 13, 2018. The U.S. EPA received drawings related to the contaminated warm water tank and emission records at the recovery boilers and power boilers. The U.S. EPA will continue to work with IP Bogalusa Mill on addressing and evaluating the Areas of Concern identified in Section III as we continue the investigation.
Section V - LIST OF APPENDICES
Appendix 1 - Photograph Log Appendix 2 - Opening Conference Sign-in Sheet Appendix 3 - Document Request Appendix 4 - Closing Conference Sign-in Sheet Appendix 5 - Permit No. 3060-00001-V9AA, Selected Pages (Regulatory Applicability)
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Appendix 1 Photograph Log
EPA Inspection Report - Page 9 of 49
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0262-00.JPG 09/11/2018 09:12 James Haynes Distant view of Power Boiler 12
EPA Inspection Report - Page 10 of 49
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0263-00.JPG 09/11/2018 09:22 James Haynes Sampling at stack of Power Boiler 12
EPA Inspection Report - Page 11 of 49
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0264-00.JPG 09/11/2018 10:00 James Haynes Shaker to handle cinders
EPA Inspection Report - Page 12 of 49
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0265-00.JPG 09/11/2018 10:02 James Haynes Distant view of cinder system; Cinders return to belt feeding into power boilers
EPA Inspection Report - Page 13 of 49
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0266-00.JPG 09/11/2018 10:51 James Haynes Leak at bottom of K1 impregnation vessel
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 6
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0267-00.JPG 09/11/2018 10:58 James Haynes Tank identification for Contaminated Warm Water Tank - also labeled Foul Condensates
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 7
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0268-00.JPG 09/11/2018 11:08 James Haynes Weak black liquor leak at head of blow line at K4 refiner
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 8
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0269-00.JPG 09/11/2018 11:30 James Haynes Bypass of control device allowing LVHC gases to vent to atmosphere
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 9
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0270-00.JPG 09/11/2018 11:39 James Haynes Top of Contaminated Warm Water Tank at center showing "gooseneck" vent
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 10
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0271-00.JPG 09/11/2018 11:45 James Haynes Standpipe in foreground; Evaporators and recovery boiler buildings in background
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 11
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0272-00.JPG 09/11/2018 12:03 James Haynes Monitoring for temperature and pressure at rupture disk
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 12
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0273-00.JPG 09/11/2018 14:35 James Haynes Grouped LDAR tags in building near drum washers
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 13
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0274-00.JPG 09/11/2018 14:39 James Haynes Additional LDAR tags attached to railing in building near drum washers
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 14
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0275-00.JPG 09/11/2018 14:41 James Haynes Grouped LDAR tags attached to line in foreground; Previously monitored components in background of tags (no longer in LDAR plan)
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 15
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0276-00.JPG 09/12/2018 09:22 James Haynes White water tank overflowing
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 16
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0277-00.JPG 09/12/2018 09:26 James Haynes Ground-level view of standpipe and additional vent lines
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 17
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0278-00.JPG 09/12/2018 09:43 James Haynes Ground-level view of eight-effect evaporators
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 18
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0279-00.JPG 09/12/2018 10:23 James Haynes View of boilout tank and black liquor oxidation tanks near Recovery Boiler No. 20
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 19
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0280-00.JPG 09/12/2018 10:27 James Haynes LVHC condensate tank near recovery boilers with different color for LDAR tags
EPA Inspection Report - Page 28 of 49
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 20
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0281-00.JPG 09/12/2018 10:41 James Haynes Smelt exiting at bottom of Recovery Boiler No. 21
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 21
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0282-00.JPG 09/12/2018 10:43 James Haynes Black liquor being sprayed into Recovery Boiler No. 21
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 22
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0283-00.JPG 09/12/2018 10:53 James Haynes NCGs being fed into Recovery Boiler No. 21
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 23
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0284-00.JPG 09/12/2018 11:30 James Haynes Black liquor is sprayed down the DCE of Recovery Boiler No. 20
EPA Inspection Report - Page 32 of 49
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 24
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0285-00.JPG 09/12/2018 15:16 James Haynes Evaporator Hotwell near the eighth effect evaporator at ground-level; LDAR tags visible
EPA Inspection Report - Page 33 of 49
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 25
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0286-00.JPG 09/12/2018 15:48 James Haynes Natural gas burner at lime kiln; LVHC can be directed to lime kiln and enter above and to left of natural gas burner
EPA Inspection Report - Page 34 of 49
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 26
Location: International Paper Company, Bogalusa Mill
City: Bogalusa
County/Parish: Washington
State: LA
Photo File Name: Date of Photo: Time of Photo: Photographer: Description:
DSCN0287-00.JPG 09/12/2018 16:12 James Haynes Turpentine storage tank
EPA Inspection Report - Page 35 of 49
International Paper Company / Bogalusa Mill Inspection Dates 09/10/2018 - 09/13/2018
Appendix 2 Opening Conference Sign-in Sheet
EPA Inspection Report - Page 36 of 49
EPA Inspection Report - Page 37 of 49
International Paper Company / Bogalusa Mill Inspection Dates 09/10/2018 - 09/13/2018
Appendix 3 Document Request
EPA Inspection Report - Page 38 of 49
INTERNATIONAL PAPER COMPANY, BOGALUSA MILL BOGALUSA, LOUISISANA
EPA REGION 6 RECORDS/DOCUMENTS REQUEST
GENERAL PROCEDURE
During the Clean Air Act (CAA) compliance investigation at International Paper Company - Bogalusa Mill (the "Mill"), inspectors will be reviewing records kept for your facility. 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, either electronic or paper, will be requested for later review by EPA.
In preparation for this 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 (as noted) on September 10, 2018. The second section consists of general and 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 the Mill to develop a schedule to review these documents.
PART 1 - Please have these documents available on September 10, 2018
1. Description for all process areas including process flow diagrams (3 copies)
2. Site map of the facility (3 copies)
3. Facility organizational chart (including overall responsibilities, Risk Management Program responsibilities, and environmental department) (1 copy)
4. Information on change of ownership or separation of divisions (subsidiaries) within the last 5 years (1 copy)
5. Effective Title V Operating Permits for the last 3 years, with applications (1 copy)
6. Identification of all process areas subject to NESHAP or MACT requirements with documentation for any sources claimed to have negative applicability (1 copy)
7. For 40 CFR Part 63, Subpart S provide: A. Initial notification report (1 copy) B. Notification of compliance status (1 copy) C. Semiannual reports from 2015 to present (1 copy) D. Initial performance tests for emissions sources subject to 63.443 and 63.446 Page 1 of 4
EPA Inspection Report - Page 39 of 49
(electronic copy, if possible) E. Start-up, shut-down, and malfunction plan (1 copy) F. Visual inspections of closed vent system from 2015 to present, annual inspections,
and the site-specific inspection plan (electronic copy, if possible) G. Requests and approvals for alternatives and/or variances from requirements (1
copy) H. For all continuous monitoring systems (i.e. COMS, CEMS, CPMS etc.) at each air
pollution control device, provide continuous monitoring data in electronic format for each monitored parameter used to demonstrate continuous compliance with 40 CFR Part 63, Subpart S and/or permit requirements. Please provide the data (preferably in Microsoft Excel format) from 2015 to present.
8. For 40 CFR Part 63, Subpart MM provide: A. Initial notification report (1 copy) B. Notification of compliance status (1 copy) C. Initial performance tests used to establish operating ranges for monitoring parameters (electronic copy, if possible) D. Semiannual reports from 2015 to present (1 copy) E. Start-up, shut-down, and malfunction plan (1 copy) F. Requests and approvals for alternatives and/or variances from requirements G. For all continuous monitoring systems (i.e. COMS, CEMS, CPMS etc.) at each pollution control device, provide continuous monitoring data in electronic format for each monitored parameter used to demonstrate continuous compliance with 40 CFR Part 63, Subpart MM and/or permit requirements. Please provide the data (preferably in Microsoft Excel format) from 2015 to present.
9. For 40 CFR Part 63, Subpart DDDDD provide: A. Initial notification report (1 copy) B. Notification of compliance status (1 copy) C. Initial performance tests used to establish operating ranges for monitoring parameters (electronic copy, if possible) D. Semiannual reports from initial date of compliance to present (electronic copy, if possible) E. Requests and approvals for alternatives and/or variances from requirements (electronic copy, if possible) F. For all continuous monitoring systems (i.e. COMS, CEMS, CPMS etc.) at each pollution control device, provide continuous monitoring data in electronic format for each monitored parameter used to demonstrate compliance with 40 CFR Part 63 Subpart DDDDD and/or permit requirements. Please provide data from the date of compliance to present.
10. For 40 CFR Part 60, Subparts D, Db, and BB, provide:
Page 2 of 4
EPA Inspection Report - Page 40 of 49
A. Initial performance tests used to establish operating ranges for monitoring parameters (electronic copy, if possible)
B. Semiannual reports from 2015 to present C. Requests and approvals for alternatives and/or variances from requirements
(electronic copy, if possible) D. For all continuous monitoring systems (i.e. COMS, CEMS, CPMS etc.) at each
pollution control device, provide continuous monitoring data in electronic format for each monitored parameter used to demonstrate compliance applicable federal and/or permit requirements. Please provide the data (preferably in Microsoft Excel format) from 2015 to present.
11. Excess emission summary reports for 2015 to present (1 copy)
12. For all CEMS and COMS, provide the pages of each QA/QC activity - activities such as CGAs, RATAs, optical alignment checks, etc. - that include the date of the activity and summary tables. (electronic copy, if possible)
13. List all opacity monitor and parameter sensor downtimes, including starting and ending dates/times from 2015 to present. (1 copy)
14. List all process unit shut-downs that have occurred during the last 3 years, including starting and ending dates/times. (1 copy)
15. Description of any wastewater treatment plants (WWTP) including schematic diagrams which include any process changes since submittal of the NPDES permit application (electronic copy, if possible)
16. Water balance diagram (1 copy)
17. For the calendar years 2015, 2016, and 2017 list all reportable releases, the root cause, and corrective action taken for each event. (electronic copy, if possible)
PART 2 - Documents likely to be requested by EPA inspectors (Schedule TBD)
1. Enforcement Actions/Notices of Violations (NOVs)
2. Consent Decrees/Orders/Agreements and related correspondences
3. List of laboratories (on-site and off-site) and types of analyses conducted
Page 3 of 4
EPA Inspection Report - Page 41 of 49 4. Provide all subsequent stack test/performance test reports describing methods used,
test data, calculations, test results and process weights. Include all test data from tests done by the company, consultants, or regulatory agencies. 5. All correspondence regarding spills, bypasses, or upsets during the last 3 years
Page 4 of 4
EPA Inspection Report - Page 42 of 49
International Paper Company / Bogalusa Mill Inspection Dates 09/10/2018 - 09/13/2018
Appendix 4 Closing Conference Sign-in Sheet
EPA Inspection Report - Page 43 of 49
EPA Inspection Report - Page 44 of 49
International Paper Company / Bogalusa Mill Inspection Dates 09/10/2018 - 09/13/2018
Appendix 5
Permit No. 3060-00001-V9AA, Selected Pages (Regulatory Applicability)
EPA Inspection Report - Page 45 of 49
L UISIANA LEPARTMENT OF ENVIRONMENTAL QUALITY
Bogalusa Mill Agency Interest No.: 38936 International Paper Company ogalusa, Washington Parish, Louisiana
X. Table I. Applicable Louisiana and Federal Air Quality Requirements
ID No. Description
40 CFR Part 60 Subpart
40 CFR Part 61 40 CFR Part 63 Subpart 40 CFR
A K D Da Db Dc GG BB JJJJ A J M A 5D S MM 4Z 64 82
UNFOO1 Bogalusa Mill
1
1 1
1 1
1
ARE001 27 -- Wastewater Treatment System
EQT005 04 -- Smelt Dissolving Tank No. 20
1
1
EQT006 05 -- Lime Kiln
1 1
EQT007 06 -- Hogged Fuel Boiler No. 10C
1
1
3
EQT008 20-- Recovery Furnace No. 20
1
EQT009 21-- Hogged Fuel Boiler No. 12
1
1
3
EQT010 22 - Recovery Furnace No. 21
1
1 1
EQT011 23 --Smelt Dissolving Tank No. 21
1
1
EQT013 25A -- BLO Primary Tank
EQT013 25B -- BLO Secondary Tank
EQT018 26D -- Paper Machine No. 7
EQT019 26E -- Paper Machine No. 8
EQT020 28 --Tall Oil Reactor
EQT021 40A --Southyard Tank (50% BL)
EQT022 40B -- North Strong Liquor Tank (50% BL)
EQT023 40C -- Post-Ox Black Liquor Tank
EQT024 40D -- Pre-Ox Black Liquor Tank
EQT026 43B -- Causticizer No. 1
EQT027 43C -- Causticizer No. 2
EQT028 43D -- Causticizer No. 3
19
EPA Inspection Report - Page 46 of 49
LOUISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY
Bogalusa Mill Agency Interest No.: 38936 International Paper Company Bogalusa, Washington Parish, Louisiana
X. Table I. Applicable Louisiana and Federal Air Quaity Requirements
ID No. Description
40 CFR Part 60 Subpart
A K D Da Db Dc GG
EQT032 45A-- HD Storage Tank - East
EQT033 45B-- HD Storage Tank- West
EQT034 45C -- Small Digester HD Storage Tank
EQT038 58A -- Weak Liquor Storage Tank No. 1
EQT039 58B -- Weak Liquor Storage Tank No. 2
EQT040 58C -- Soap Skimmer Tank (Weak BL)
EQT041 61A -- Sawdust Cyclone
EQT042 61B -- Rechipper Cyclone
EQT043 64 -- No. 6 Fuel Oil Tank
EQT044 67 -- Gasoline Tank
EQT049 LVHC1-- Multiple Effects Evaporator Hotwell
EQT050 LVHC2 --Turpentine Decanters
EQT051 LVHC3 --Large Digester through Turpentine Condenser No. 1 and No. 2
EQT052 LVHC4 --Small Digester through Turpentine Condenser No. 3
EQT053 LVHC5 -- Recovery Furnace No. 21Concentrator
EQT055 HVLC2 --Large Digester Chip Bin via Chip Bin Condenser
EQT056 HVLC3 -- Large Digester Diffusion Washer/Filtrate Tank
EQT058 HVLC5 --Small Digester Washer Hoods
EQT061 HVLC8 --Contaminated Warm Water Tank
EQT062 HVLC9 --Small Digester Blow Tank
EQT066 40E -- Deaerator Tank
40 CFR Part 61 40 CFR Part 63 Subpart BB JJJJ A J M A 5D S MM 4Z
1
1
1
1
1
1
1
1
1
1
1
1
3
1
3
1
1
1
1
1
40 CFR 64 82
20
EPA Inspection Report - Page 47 of 49
L UISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY
ogalusa Mill Agency Interest No.: 38936 International Paper Company Bogalusa, Washington Parish, Louisiana
X. Table I. Applicable Louisiana and Federal Air Quality Requirements
ID No. Description
40 CFR Part 60 Subpart
40 CFR Part 61 40 CFR Part 63 Subpart 40 CFR
A K D Da Db Dc GG BB JJJJ A J M A 5D S MM 4Z 64 82
EQT067 40F -- 70% Black Liquor Storage Tank
EQT068 58D -- Boil Out Storage Tank
EQT069 68A -- Paper Machine Oil Tank (No. 7 Paper Machine)
EQT070 68B -- Paper Machine Oil Tank (No. 8 Paper Machine)
EQT076 49 -- No. 20 Salt Cake Mix Tank
EQT077 50 -- No. 21Salt Cake Mix Tank
EQT079 SN-7313-- New Log Debarker
EQT080 43E -- New Lime Slaker
EQTO81 74A --South LD Tank (PM7)
EQT082 74B North LD Tank (PM8}
EQT083 75 -- Post HD Screening System
3
EQT084 76 -- Recovery Area Spill Tank
EQT085 Influent Plant Backup Generator
1
EQT086 Lime Kiln Auxilliary Drive
1
EQT087 Fire Pump Auxilliary Drive
1
EQT088 Outfall Emergency Backup Generator
1
1
EQT089 Admin Building Emergency Generator
1
FUG001 61C -- Bark Pile Fugitives
FUG002 61D -- Chip Pile Fugitives
FUG003 Cond.2 -- Pulp Mill Turpentine Decanter Underflow
1
Standpipe
21
EPA Inspection Report - Page 48 of 49
LOUISIANA EPARTMENT I F ENVIRONMENTAL QUALITY
Bogalusa Mill Agency Interest No.: 38936 International Paper Company ogalusa, Washington Parish, Louisiana
X. Table 1. Applicable Louisiana and Federal Air Quality Requirements
ID No. Description
40 CFR Part 60 Subpart
40 CFR Part 61 40 CFR Part 63 Subpart 40 CFR
A K D Da Db Dc GG BB JJJJ A J M A 5D S MM 4Z 64 82
FUG004 Cond.1-- Evaporator Turpentine Decanter Underflow
1
Standpipe
FUG005 Cond.3 -- Evaporator Process Condensate Header
1
FUG006 Cond.4 -- Warm Water Tank
1
FUG007 Cond.5 --Surface Condenser Condensates
1
FUG010 62 --Paved and Unpaved Roads
FUG011 66-- Recycle Fiber Fugitives (Repulpers)
FUG012 72A -- Lime Storage and Handling
FUG013 72B --Ash Storage and Handling
KEY TO MATRIX 1 - The regulations have applicable requirements that apply to this particular emission source.
-The emission source may have an exemption from control stated in the regulation. The emission source may not have to be controlled but may have monitoring,
recordkeeping, or reporting requirements. 2 -The regulations have applicable requirements that apply to this particular emission source but the source is currently exempt from these requirements due to
meeting a specific criterion, such as it has not been constructed, modified or reconstructed since the regulations have been in place. If the specific criteria changes the source will have to comply at a future date. 3 -The regulations apply to this general type of emission source (i.e. vents, furnaces, towers, and fugitives) but do not apply to this particular emission source. Blank --The regulations clearly do not apply to this type of emission source.
22
EPA Inspection Report - Page 49 of 49
LOUISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY
ogalusa Mill Agency Interest No.: 38936 International Paper Company ogalusa, Washington Parish, Louisiana
XL Table 2. Explanation for Exemption Status or Non-Applicability of a Source
ID No:
Requirement
Notes
EQT086
Standards of Performance for Stationary CI ICE [40 CFR 60 DOES NOT APPLY. This gasoline IC engine was manufactured prior to January
Subpart JJJJ]
1, 2009 (emergency engine).
EQT085 EQT087 -- EQT089
Standards of Performance for Stationary SI ICE [40 CFR 60 DOES NOT APPLY. These diesel IC engines were manufactured prior to July
Subpart 1111]
11, 2005.
EQT083
NESHAP from the Pulp and Paper Industry [40 CFR 63 Subpart EXEMPT. The screen system is located after the high density storage tanks.
S]
[40 CFR 63.441]
EQT056, EQT058
NSPS Subpart BB--Standards of Performance for Kraft Pulp EXEMPT. EQT 56 is a diffusion washer. 40 CFR 60.281(e). EQT 58 qualifies as
Mills [40 CFR 60 Subpart BB]
an exempt system per 40 CFR 60.283(a)(1)(iv).
EQT049 -- EQT053 EQT055 -- EQT056 EQT058, EQT062
NSPS Subpart BB--Standards of Performance for Kraft Pulp EXEMPT FROM TEMPERATURE MONITORING. These gases are assumed to
Mills
be subjected to a minimum temperature of 650 C (1200 F) for at least 0.5
[40 CFR 60 Subpart BB]
second (10-4-1993 EPA Region IV letter to GA EPD); therefore, no temperature monitoring is required [40 CFR 60.283(a)(1)(iii)]"
EQT006, EQT008
NSPS Subpart BB--Standards of Performance for Kraft Pulp DOES NOT APPLY. Source was constructed prior to September 24, 1976. [40
Mills [40 CFR 60 Subpart BB]
CFR 60.280(b)]
EQT043
Storage of Volatile Organic Compounds [LAC 33:111.2103]
DOES NOT APPLY. Contents have a true vapor pressure less than 1.5 psia at storage conditions. [LAC 33:111.2103]
Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984. [40 CFR 60 Subpart Ka]
DOES NOT APPLY. No. 6 fuel oil is not considered a petroleum liquid. 40 CFR 60.111a(b)
The above table provides explanation for either the exemption status or non-applicability of a source cited by 1, 2 or 3 in the matrix presented in Section X (Table 1) of this permit.
25