Document a4GRwmwjKYEwNEwXJLkJjQXyY

EPA Inspection Report - Page 1 of 16 Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 03/14-15/2018 Water Clean Water Act / NPDES Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Exxon Mobil Corporation Baytown Chemical Plant 5000 Bayway Drive Baytown, Texas 77522-4004 P.O. Box 4004 Baytown, Texas 77522-4004 Harris County Robert S. Catudal robert.s.catudal@exxonmobil.com BTCP Plant Manager FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110000463178 TX0007013 325199, 447110 2869, 2822, 2821, 2813 Personnel participating in inspection: Kenneth L. AuBuchon USEPA/6EN-WMH Kevin Brewer ExxonMobil Corp. Snigdha Joshi Rege ExxonMobil Corp. Lauren Schroeder ExxonMobil Corp. Environmental Engineer Environmental Section Supervisor Environmental Advisor SSH&E Department Wastewater Contact Engineer 281-983-2151 346-259-0101 346-259-5146 346-259-0061 EPA Lead Inspector Signature/Date Supervisor Signature/Date KENNETH AUBUCHON Kenneth L. AuBuchon Digitally signed by KENNETH AUBUCHON DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=KENNETH AUBUCHON, dnQualifier=0000014523 Date: 2018.06.26 10:58:07 -05'00' Date CAROL PETERSWAGNON Carol Peters Digitally signed by CAROL PETERS-WAGNON DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=CAROL PETERS-WAGNON, dnQualifier=0000009981 Date: 2018.06.27 11:11:29 -05'00' Date 6ENFORM-019-R7 (2/15/2017) 1 EPA Inspection Report - Page 2 of 16 Section I - INTRODUCTION ExxonMobil Corporation / Baytown Chemical Plant 03/14-15/2018 PURPOSE OF THE INSPECTION United States Environmental Protection Agency (U.S. EPA) Region 6 inspector Kenneth L. AuBuchon arrived at the ExxonMobil Baytown Chemical Plant, located in Baytown, Texas at approximately 9:00 am on March 14, 2018 for an unannounced Compliance Evaluation Inspection (CEI). I met with Kevin Brewer, ExxonMobil Chemical Company Environmental Section Supervisor, Snigdha Joshi Rege, ExxonMobil Chemical Company Environmental Advisor, and Lauren Schroeder, ExxonMobil Chemical Company Wastewater Contact, at the opening conference. I presented my credentials to all present at the opening conference and explained that this was an EPA inspection to determine compliance with the facility's National Pollutant Discharge Elimination System (NPDES) permit and the Clean Water Act (CWA). The inspection was conducted under the authority of the NPDES permit program, in accordance with the Federal CWA. This report is based on information supplied by the ExxonMobil Chemical Company representatives (the permittee), observations made by the U.S. EPA inspector, and records and reports maintained by the permittee, the State of Texas, and the U.S. EPA. FACILITY DESCRIPTION The ExxonMobil Baytown Chemical Plant (BTCP) is located within the ExxonMobil Baytown Complex adjacent to the ExxonMobil Baytown Refinery (BTRF) and ExxonMobil Baytown Olefins Plant (BOP). Chemical feedstock and products are transferred between facilities, and certain utilities are shared including the water clarification system and the wastewater treatment plant, operated by the BTRF under a separate Texas Pollutant Discharge Elimination System (TPDES) Permit. The BTCP is divided into three business functions identified as Butyl Polymers (BPB), Polypropylene (BTPP), and Olefins and Aromatics (O&A). The O&A units are operated under the Unicorn (UCO) and Northwest Chemicals (NWC) areas. The BPB area consists of polymerization and finishing units that produce synthetic rubber. The NWC operating area consists of the Paraxylene Absorption Unit (PAU), Butenes Processing Unit (BPU), Dihydrogenation Unit (DHU), Propylene Concentration Unit (PCU), Synthesis Gas Unit (SGU)), and Metallocene Polyalphaolefin Unit (MPU), along with offsite utilities. The UCO and BTPP areas discharge all process wastewater and storm water to the BTRF wastewater treatment plant. The BTCP plans to construct and operate two additional processing units, PPU and MPF, which will be co-located. The PPU will combine monomers and generate a pelletized resin. The MPF will be constructed to prepare monomers for use in polymerization. The shared facilities between the two units will include two hot oil heaters, a cooling tower, a thermal oxidizer and steam assisted flare to control vents from routine and maintenance, startup, and shutdown operations. In addition to the shared facilities, process equipment for the PPU and MPF units will include distillation columns, storage tanks, and equipment for unloading/loading raw materials and products in transport vessels. Other new equipment will include pipe and piping components, valves, exchangers, compressors, pumps, separation equipment, instrumentation and analyzers. 2 EPA Inspection Report - Page 3 of 16 ExxonMobil Corporation / Baytown Chemical Plant 03/14-15/2018 The process units will also utilize existing facilities located at the Baytown Complex. Internal Outfalls 103 and 203 are permitted to discharge storm water commingled with other wastewaters (commingled waters). There are no flow limits for these outfalls when discharges occur. Outfall 103 serves the Butyl Process Unit and Outfall 203 serves the Northwest Chemicals Process Unit. Both units route process water and commingled waters through an oil/water separator and then to the respective lift stations. Under normal circumstances, process water is pumped to Exxon Mobil Baytown Refinery for treatment. When the wet well reaches high capacity during periods of heavy rainfall, commingled waters are pumped to one of two retention ponds. Commingled water pumped to the retention ponds is held until it can be pumped to the Refinery for treatment. In circumstances in which the respective wet well and retention pond are inundated, a discharge is made through the respective internal outfall. See Appendices 1 (BTCP Wastewater System Flow Schematic). Outfall 003 is permitted to discharge storm water commingled with other wastewaters, fire water control system test and flush water, other de minimis losses from the fire water control system, other de minimis losses from the decorative ponds, hydrostatic test water, potable water system flush water, irrigation water from the landscape sprinkler system, steam condensate and air conditioner condensate, other de minimis losses of potable water, and other de minimis losses of clarified water, and previously monitored effluents from Outfalls 103 and 203. There are no flow limits for Outfall 003. See Appendices 1 (BTCP Wastewater System Flow Schematic). Section II - OBSERVATIONS During the review of the facility's required paperwork it was noted that the facility's permit has Daily Maximum (mg/L) limits for the following parameters: Acrylonitrile at 0.022 ppm (22 ppb) Benzo(a)anthracene at 0.0031 ppm (3.1 ppb) Benzo(a)pyrene at 0.0031 ppm (3.1 ppb) Hexachlorobenzene at 0.0000260 ppm (.026 ppb) Phenanthrene at 0.0077 ppm (7.7 ppb) The facility is reporting ZERO values for the above parameters based on an established minimum analytical level (MAL) listed in the permit (refer to Appendix 2). Other Requirements #2 in the permit has listed established MALs, and states "Test methods utilized shall be sensitive enough to demonstrate compliance with the permit effluent limitations. Permit compliance/noncompliance determinations will be based on the effluent limitations contained in this permit with consideration given to the minimum analytical level (MAL) for the parameters specified". A review of the test results for the parameters listed above show that the test method used is not sensitive enough to demonstrate compliance with permit effluent limitations (see Section III for further discussion on MALs) but, due to consideration given to established MALs for parameters specified in the permit, ZERO values are used in calculations and reporting requirements. A tour of the Outfalls and the process overview of succession of events for discharge was conducted on 3/15/2018. It was explained per the permit that: Process wastewater, sanitary sewage, and utility wastewater are typically routed to the ExxonMobil Baytown Refinery for treatment and discharge. De minimus quantities of these wastestreams (except for sanitary sewage) may commingle with storm water and discharge via Outfalls 103, 203, and/or 003 as a result of excessive storm events, or 3 EPA Inspection Report - Page 4 of 16 ExxonMobil Corporation / Baytown Chemical Plant 03/14-15/2018 succession of events. Discharges of these wastestreams from Outfalls 103, 203, and/or 003 are only authorized following an excessive storm event or successions of events which result in runoff volumes that exceed the capabilities of the lift station pumps and exceed the storage capacity of the storm water retention ponds for the Butyl Polymers plant and/or the Northwest Chemical facility, or the Syngas Unit's first flush sump. The permittee shall take all reasonable steps to minimize these discharges from Outfall 003. Process wastewater and utility wastewater are not authorized to be discharged under any other conditions than those storm events described above. Sanitary sewage is prohibited from discharge via any outfall of this permit. The processes at outfalls 103, 003 and 203 were as described in the permit. Both oil/water separators were observed, the sumps and pumps for transfer to the refinery were operational, and the sumps and pumps to the retention ponds were operational. The retention ponds were observed and maintenance concerns were noted regarding the sediment build up in both ponds and the vegetation growth on the berms of the Butyl Polymers storm water retention pond. The Northwest Chemicals storm water retention pond, pictured below, had noticeable sediment deposit built up. When asked if the sediment build up affected the capacity of the pond, it was explained that the permit did not require maintenance on the ponds. It was further explained, that if the ponds were modified (cleaned out) that additional requirements per the permit would be required. Refer to Areas of Concern. 4 EPA Inspection Report - Page 5 of 16 ExxonMobil Corporation / Baytown Chemical Plant 03/14-15/2018 The Butyl Polymers storm water retention pond, pictured below, also had noticeable sediment deposit built up with excessive vegetation growth on the berms. When asked if the sediment build up affected the capacity of the pond or the vegetation was controlled, it was again explained that the permit did not require maintenance on the ponds. It was further explained, that if the ponds were modified (cleaned out) that additional requirements per the permit would be required. Refer to Areas of Concern. Section III - AREAS OF CONCERN Requirement A: TPDES Permit No. TX0007013 has Daily Maximum Limits based on Water Quality Criteria for the following parameters: Acrylonitrile at 0.022 ppm (22 ppb) Benzo(a)anthracene at 0.0031 ppm (3.1 ppb) Benzo(a)pyrene at 0.0031 ppm (3.1 ppb) Hexachlorobenzene at 0.0000260 ppm (.026 ppb) Phenanthrene at 0.0077 ppm (7.7 ppb) Concern A: The facility's permit compliance/noncompliance determinations are based on a minimum analytical level (MAL), as listed in their permit. The following MALs are higher than the Daily Maximum Limits based on Water Quality Criteria. 5 EPA Inspection Report - Page 6 of 16 ExxonMobil Corporation / Baytown Chemical Plant 03/14-15/2018 Acrylonitrile Benzo(a)anthracene Benzo(a)pyrene Hexachlorobenzene Phenanthrene 0.05mg/L 0.01mg/L 0.01mg/L 0.01mg/L 0.01mg/L 2.3 times greater than Water Quality Based limit 0.022mg/L 3.2 times greater than Water Quality Based limit 0.0031mg/L 3.2 times greater than Water Quality Based limit 0.0031mg/L 385 times greater than Water Quality Based limit 0.0000260mg/L 1.3 times greater than Water Quality Based limit 0.0077mg/L At the time of the inspection, the ExxonMobil Baytown Chemical Plant was in compliance with the above permitted reporting requirements. Requirement B: TPDES Permit No. TX0007013 Other Requirements 3. ...Discharges of these wastestreams from Outfalls 103, 203, and/or 003 are only authorized following an excessive storm event or successions of events which result in runoff volumes that exceed the capabilities of the lift station pumps and exceed the storage capacity of the storm water retention ponds for the Butyl Polymers plant and/or the Northwest Chemical facility, or the Syngas Unit's first flush sump. The permittee shall take all reasonable steps to minimize these discharges from Outfall 003... Concern B: Sediment build up in the Northwest Chemicals storm water retention pond reduces the pond's storage capacity. 6 EPA Inspection Report - Page 7 of 16 ExxonMobil Corporation / Baytown Chemical Plant 03/14-15/2018 Requirement C: TPDES Permit No. TX0007013 Other Requirements 3. ...Discharges of these wastestreams from Outfalls 103, 203, and/or 003 are only authorized following an excessive storm event or successions of events which result in runoff volumes that exceed the capabilities of the lift station pumps and exceed the storage capacity of the storm water retention ponds for the Butyl Polymers plant and/or the Northwest Chemical facility, or the Syngas Unit's first flush sump. The permittee shall take all reasonable steps to minimize these discharges from Outfall 003... Concern C: Sediment build up in the Butyl Polymers storm water retention pond reduces the pond's storage capacity. Excessive vegetation growth on the berms weakens the berms integrity and may weaken the ponds liner system. 7 EPA Inspection Report - Page 8 of 16 ExxonMobil Corporation / Baytown Chemical Plant 03/14-15/2018 8 EPA Inspection Report - Page 9 of 16 Section IV - FOLLOW UP ExxonMobil Corporation / Baytown Chemical Plant 03/14-15/2018 6/25-26/2018 - E-mail exchange in reference to final report clarifications. Section V - LIST OF APPENDICES Appendices 1 - BTCP Wastewater System Flow Schematic Appendices 2 - TPDES Permit TX0007013 Other Requirements pages 14-17 9 EPA Inspection Report - Page 10 of 16 ExxonMobil Corporation / Baytown Chemical Plant 03/14-15/2018 Appendix 1 BTCP Wastewater System Flow Schematic EPA Inspection Report - Page 11 of 16 EPA Inspection Report - Page 12 of 16 ExxonMobil Corporation / Baytown Chemical Plant 03/14-15/2018 Appendix 2 TPDES Permit TX0007013 Other Requirements pages 14-17 EPA Inspection Report - Page 13 of 16 EPA Inspection Report - Page 14 of 16 EPA Inspection Report - Page 15 of 16 EPA Inspection Report - Page 16 of 16