Document b5MXnGnggDaVgLyb8y6L9qBRO

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEYARD CHICAGO, ILLINOIS 60604 OCT 1 7 2018 CLEAN AIR ACT INSPECTION REPORT Kraton Polymers U.S. LLC Gregory Gehrig, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Chief AECAB (MI/WI) File BASIC INFORMATION Facility Name: Kraton Polymers U.S. LLC Facility Location: 2419 Sate Route 618, Belpre, OH Date of Inspection: September 21, 2018 EPA Inspectors: 1. Gregory Gehrig, Environmental Engineer 2. Kenneth Ruffatto, Environmental Engineer 3. Cary Secrest, Environmental Protection Specialist Other Attendees: 1. Yousheng Zeng, Providence Photonics 2. Sri Motyala, Providence Photonics 3. Jon Morris, Providence Photonics 4. Danielle D. Axsom, Environmental Engineer, Kraton Polymers U.S. LLC 5. Ken Hunt, HSES Manager, Kraton Polymers U.S. LLC 6. David Mongilio, Plant Manager, Kraton Polymers U.S. LLC 7. Robert Law, Kraton Polymers U.S. LLC Contact Email: danielle.axson@kraton.com Purpose of Inspection: CA./:\ Compliance Facility Type: Thermoplastic elastomers manufacturing Facility Name: Kraton Polymers U.S. LLC Facility Location: 2419 Sate Route 618, Belpre, OH Date of Inspection: September 21, 2018 Regulations Central to Inspection: SIP, NSPS and MACT Arrival Time: 0810 hrs Departure Time: 1400 hrs Inspection Type: IZI Unannounced Inspection 0 Announced Inspection OPENING CONFERENCE IZI Credentials Presented IZI CBI warning to facility provided The following information was obtained verbally from facility personnel. Process Description: Kraton Polymers U.S. LLC (Kraton) manufactures thermoplastic elastomers principally using the raw materials of cyclohexane, styrene and butadiene. They principally manufacture synthetic rubber. These raw products are reacted at various temperatures and pressures with various catalysts to produce thermoplastic elastomers. The processes includes hydrogenation, steam addition, polymerization, desolventing and dewatering to produce crumbs, pellets, grains or bails of product. The facility has four process lines. The G-1 and K-1 process lines are located on the south portion of the facility (South side) while the G-2 and K-3 process lines are located on the no1ih portion of the facility (North side). Most process emissions from each of these processes are routed to a control device: for G-1 , a regenerative thermal oxidizer (RIO); K-1, a catalytic oxidizer; G-2, a catalytic oxidizer; and K-3, a vapor combustor. Two steam-assisted flares are also used at this facility. The South flare controls emissions from the South side pressure reliefvalves (PRV), the tank farm and the wastewater treatment plant, while the North flare controls PRV emissions from the North side. Vent gas (VG) routed to these flares is continuous and is monitored with a calorimeter at each flare. Supplemental gas (pipeline natural gas) may be added to each flare to help maintain a minimum VG net heating value (NHV), which is set at 600 BTU/scf for the South flare and 450 BTU/scf for the North flare. Steam flow is measured at each flare and may be controlled by a valve on the steam line. A camera is on each flare and is shown on a screen in the corresponding control room. The last time either flare was observed to be smoking was during a power outage in 2013. EPA/Providence observations of the flares are summarized below. Page 2 of 5 Facility Name: Kraton Polymers U.S. LLC Facility Location: 2419 Sate Route 618, Belpre, OH Date ofinspection: September 21, 20 I8 TOUR INFORMATlON EPA toured the facility: Yes Data Collected and Observations: EPA contracted Providence Photonics (Providence) of Baton Rouge, LA to conduct flare observations at Kraton using a Video Imaging SpectroRadiography (VISR) imaging device, or VISR. VISR uses infrared sensing and imaging technology to determine the combustion efficiency (CE) of hydrocarbons combusted by a flare with a visible flame. Providence used the VISR to observe the flaring along with a dedicated standard video camera. EPA also utilized a FLIR camera to observe the flares and collect images. At the time of inspection, the facility was operating n01mally. Observations of the flares were: South flare - The VISR indicated CE was approx. 95% during the observation period and was lowest when wind speed was high. FLIR video collected correspond with the VISR observations. North flare -- CE ranged was approx. 75% during the test period and varied rapidly. FLIR video collected correspond with the VISR observations. A report from Providence on the VISR data with images is provided in Appendix A. EPA observed the flare operating parameters in both control rooms and took screenshots (camera pictures) of the flare SCADA showing conditions at the time of inspection. Control room data showed the NHV for VG routed to the South flare was 629.5 BTU/scf and to the North flare was 443 BTU/scf. While Providence personnel and C. Secrest were conducting flare observations, G. Gehrig and K. Ruffatto conducted a limited tour of the South side. Specifically, EPA saw the G-1 and K-1 process units, focusing on G-1. EPA walked the units with a FLIR camera. Possible VOC emissions were seen coming from a product drying (dewatering) oven exhaust on G-1. EPA also observed the inlet and initial treatment area of the wastewater treatment plant. Field Measurements: were taken during this inspection. RECORDS REVIEW None CLOSING CONFERENCE Requested documents (to be sent via email): Page 3 ofS Facility Name: Kraton Polymers U.S. LLC Facility Location: 2419 Sate Route 618, Belpre, OH Date of Inspection: September 21, 2018 2018 LOAR quarterly reports. Design and operating information for both flares, including recent preventative maintenance procedures. SIGNATURES Lead Inspector: L"_ . .-, _c__L__ _-,1--+--_.._----4,~--- Dat:_:.ee-:--'/_--s---+--~-- / 0 ;1/7/; fJ I I Page 4 of5 Facility Name: Kraton Polymers U.S. LLC Facility Location: 2419 Sate Route 618, Belpre, OH Date oflnspection: September 21, 2018 DIGITAL IMAGE LOG* 1. Inspector Name: Gregory Gehrig 3. Company/Facility Name: Kraton Polymers U.S. LLC 5. Number of Images: 10 2. Date(s) oflnspection: September 21, 2018 4. Street Address, City, State: 2419 Sate Route 618, Belpre, OH 6. Archival Record Location: CD-R labeled Kraton Images 9.21.2018 Time Image name (EDT) Description IMG 0150 1139 G-1 RTO IMG 0151 1139 K-1 catalytic oxidizer IMG 0152 1159 Screen shot of South flare control screen IMG 0153 1234 Screen shot ofNorth flare control screen IMG 0154 1234 Screen shot of North flare control screen MOV 310 1041 FUR video of South flare. CE was 97% but dropped to 90% with increased wind speed. MOV 314 1143 FLIR video of G-1 dryer (dewatering) vent MOV 315 1229 FLIR video of North flare. CE ranged from 69 to 80%, varied rapidly. MOV 316 1240 FUR video of North flare MOV 317 1313 FLIR video of North flare *Additional images of the flares were collected by Providence Photonics as detailed in their report in Appendix A. Page S ofS Facility Name: Kraton Polymers U.S. LLC Facility Location: 2419 Sate Route 618, Belpre, OH Date of Inspection: September 21, 2018 APPENDIX A: FIELD NOTES AND FIELD MEASUREMENT DATA Video Imaging Spectra-Radiography Report provided by Providence Photonics Appendices Page l of 1 Flare VISR Test Report Facility: Kraton Polymers U.S. LLC September 2018 Prepared for US Environmental Protection Agency Region 5 77 West Jackson Boulevard Chicago, IL 60604 PROVIDENCE PHOTONICS PROJECT NO. 1198-001 PREPARED BY Providence Phot onics, LLC I1201 Ma in Street, Baton Rouge, LA 70802 PROVIDENCE -~ PHOTONICS Project No. 1198- 001 US EPA Region 5 Table of Contents INTRODUCTION ...................................................................................................................................... 2 SUMMARY OFVISRTEST RESULTS AND OBSERVATIONS ............. ..................................... ...................... 2 Test Results and Observations - South Flare... ... ... ..... ....................... .. .................... .. ... ...................................... 4 Test Result s and Observat ions - North Flare..... ....... .. .................. ... .. ......... ............ ... ... ... ..... ......... .. ..... ..... ...... ... 7 ELECTRONIC DATA GENERATED FROM THE TEST.................................................................................. 10 REFERENCES ......................................................................................................................................... 10 Revised: 10/ 10/201 8 10:57:00 AM Page 1 I10 Project No. 1198-001 US EPA Region 5 VISR Flare Testing Introduction EPA Region S retained Providence Photonics, LLC (Providence) to assist the inspection of Kraton Polymers U.S. LLC (Kraton) located at 2419 State Route 618, Belpre, OH. Providence measured the combustion efficiency (CE) and other performance metrics of Kraton's two flares using the Video Imaging Spectral Radiometry (VISR) method. The VISR method utilizes a multi-spectral mid-wave infrared imager to remotely and continuously measure relative concentrations of combustion gases. Based on these relative concentrations, flare CE is calculated. The VISR method provides continuous measurement of the following five flare performance metrics at 1-second data rate. Combustion Efficiency (CE): This is the primary metric that VISR measures. CE is the concentration of unburned hydrocarbons relative to the concentration of carbon dioxide (CO2, the end product of combustion) in the post-combustion gases. CE is expressed in percentage. If combustion is complete and there are no unburned hydrocarbons in the post-combustion gases, CE will be 100%. Smoke Index (SI): SI is used to indicate the level of smoke in the flare flame. It has a range of 0 to 10. When flare has no smoke, the SI is very low (generally below 1 to 2). As smoke level increases, the SI monotonically (but not linearly) increases. Flame Stability (FS): FS is used to measure the degree offlare radiance fluctuation within 1 second, which indicates stability of the flare. It has a range of 0-100. When the FS va lue is in about 80 or higher, it generally indicates a very stable flare. Flame Footprint (FF): FF represents the flame cross section area (in square feet) of the flare and associated hot post-combustion gases perpendicular to the VISR instrument. The footprint is based on the Infrared radiance, and it is generally larger than the size of the flame observed in the visible spectrum by the naked eye. Heat Release (HR). HR measures the amount of heat released by the flare in regions of the midwave Infrared (MWIR) spectrum monitored by the VISR instrument. HR is reported as Btu/min. Because the HR only represents the energy released by the flare in the MWIR, the total heat released by the flare is larger than the HR metric reported by VISR. More information about the VISR method and its validation is provided at https :/ / w w w .providencephotonics.com/flare -monitoring . Summary of VISR Test Results and Observations Date: September 21, 2018 Personnel: Gregory Gehrig (EPA Region 5) Kenneth Ruffatto (EPA Region 5) Cary Secrest (EPA OECA) Yousheng Zeng (Providence) Jon Morris (Providence) Sri Mutyala (Providence) Revised: 10/10/2018 10:57:00 AM Page 2 I10 Facility: Kraton Polymers U.S. LLC 2419 State Route 618, Belpre, Ohio 45714 Location of Flares and VISR Instrument: see Figures 1 and 2. Project No. 11.98-001 US EPA Region 5 VISR Fl are Testi ng Figure 1. South flare. A steam assisted flare. Left: Google map with a red circle ind icating the location of the flare and a red "X" indicating the location of the VISR instrument. Distance: 276 ft. Right: A photo of the flare taken during the test. Figure 2. North flare. A steam assisted flare. Left: Google map with a red circle indicating the location of the flare and a red "X" indicating the location of the VISR instrument. Distance: 180 ft. Right: A photo of the flare taken during the test. Revised : 10/10/2018 10:57:00 AM Page3 [10 Project No. 1.198-001 US EPA Regio n 5 VISR Flare Testing Test Results and Observations - South Flare Test results for the South Flare are summarized in Table 1. Variability (or trending) of the flare during the test can be seen in Figures 3-5. Figure 6 provides a snapshot of the spectral image and a visible image of the flare. A lower CE was observed when wind picked up and vent gas flow rate appeared to be low (low exit ve locity). When vent gas flow increased, CE generally improved. At about 11:37 am, the vent gas increased evidenced by the sound of the flare and visua lly observed exit veloc ity. The VISR results showed increased FF, increased HR, and improved CE from about 11:37 am to the end of the test- see Figure 4. Table 1. VISR test resu lts for the South Flare Average for the Duration {10:41 am - 11:47 am) Combustion Efficiency(%) 95 .5 Smoke Index (unitless) 0.78 Flame Stabi lity (unitless) 94.9 Flame Footprint (ft2) 161.36 Heat Release (Btu/min) 2,286 1-sec (Avg.-SD, Avg.+SD) {92.6, 98.5) (0.63, 0.93) (91.9, 97 .8) {108.80, 213.92) {1,315, 3,256) 1-min (Avg.-SD, Avg.+SD) {93.7, 97.4) (0.68, 0.87) (93.8, 95.9) (112 .51, 210 .67) (1,376, 3,193) Revised: 10/10/201810:57:oo AM Page 4 J 10 Proj ect No. 119 8 -001 US EPA Region 5 VISR Flare Testing Kraton - South Flare (1-sec results) 100.0 90.0 80.0 V'I 70.0 LL -e"C 60.0 C: (tJ 50.0 w 40.0 u 30.0 20.0 10.0 0.0 I-' I-' I-' I-' I-' I-' I-" I-' I-" I-' I-" I-" I-" 9 0 0 9 9 !-:' !-:' !-:' !-:' !-:' !-:' !-:' !-:' w :.,;. :.,;. V, V, 0 0 I-" 1--" N N w w V, 0 V, 0 V, 0 V, 0 V, 0 V, 0 V, );> )> sss ss s~ss ssss Local Time CE (1-s) - FS (1-s) - SI (1-s) 1.80 1.60 1.40 1 .20 1.00 V'I 0.80 0.60 0.40 0.20 0 .00 I-" I-" I-" I-' !-:' !-:' :.,;. V, V, 0 ~ s s s Figure 3. South Flare. Time series plot of 1-second results for CE, FS, and SI. 450.00 400.00 350.00 - 300.00 -=. 250.00 CT f 200.00 LL 150.00 100.00 50.00 0.00 Kraton - South Fla re (1-second results) 7,000 6,000 5,000 -C 4,000 E ::s -+' 3,000 i::o -0:: :c - 2,000 1,000 0 I-" I-" I-' I-' I-' I-' I-' I-' I-' 1--" 0 !-:' !-:' !-:' !-:' !-:' I-' I-' !-:' !-:' :.,;. I-" N N w w :.,;. :.,;. V, V, V, 0 V, 0 \J1 0 V, 0 ~ )> )> )> )> )> )> s s s s ss s s ss Local Time - FF (1-s) - HR (1-s) Figure 4. South Flare. Time series plot of 1-second results for FF and HR. Rev ised: 10/10/2018 10:57:00 AM Pages I10 Project No. 1198-001 US EPA Reg ion 5 VISR Flare Testing Flare CE in Different Averaging Periods Kraton - South Flare 100.0 98.0 96.0 94.0 92.0 l w 90.0 u 88.0 86.0 84.0 82.0 80.0 ..... I-" I-" ..... ..... I-" ..... ..... ..... I-" ..... ..... ..... ..... ..... I-" 9 0 0 9 9 t-:' t-:' t-:' t-:' t-:' t-:' t-:' t-:' p ..... t-:' w :i:;.. :i:;.. V, V, 0 0 ..... ..... N N w w :i:;.. :i:;.. V, V, 0 V, 0 V, 0 V, 0 u, 0 V, 0 V, 0 V, 0 )> )> )> )> )> )> )> )> )> )> )> s s s s s s s s s s s s s s s s Local Time - CE (1-s) - CE (1-m) ..._CE (15-m} - CE (du ration ) Figure 5. South Flare. Time series plot of CE with different averaging periods. Figu re 6. South Flare. Left: A representative composit e spectral image generated by VISR instrument. Red colo r represents CO2; green color rep resents hydrocarbon; and blue or bluish white colo r rep resents aeroso l (e .g., soot) or hot solid object (e.g., t he shield for pilot s). Right : A represent ative image in visible spect ru m. Revised: 10/10/201810: 57:00 AM Page 6 I10 Project No. 1198-001 US EPA Region 5 VISR Flare Testing Test Results and Observations - North Flare Test results for the North Flare are summarized in Table 2. Variability (or trending) of the flare during the test can be seen in Figures 7-9. Figure 10 provides a snapshot of the spectral image and a visible image of the flare. Low CE at the North flare was observed during the entire test period and appeared to be due to excess steam. Unburned hydrocarbon was noticeable in the spectral image (green color in Figure 10). The flame was completely quenched at times, but would then be reignited. The flame was very unstable during a period between 1:00 pm and 1:10 pm -see Figures 7 and 8. The quenches and reignitions can be vividly seen in a short spectral video clip (Kraton North Flare Run 9.wmv). Table 2. VISR test results for the North Flare Average for the Duration (12:18 pm -1:23 pm) Combustion Efficiency(%) 75.1 Smoke Index (unitless) 1.00 Flame Stability (unitless) 86.4 Flame Footprint (ft2) 42.58 Heat Release (Btu/min) 478 1-sec Avg. SD (69.0, 81.2) (0.84, 1.16) (74.3, 98.4) (23.00, 62.16) (207, 750) 1-min Avg. SD (72.4, 77.8) (0.88, 1.13) (77.2, 95.0) (25.62, 59.00) (242, 709) Revised: 10/10/201810:57:oo AM Page 7 [ 10 Proje ct No . 1198 -001 US EPA Region 5 VISR Flare Testing l<raton - North Flare (1-sec results) 100.0 2.00 90.0 1.80 80.0 V'l 70.0 u.. --"tl 60.0 C: n:, 50.0 ~ 40.0 LU u 30.0 - 1 1.60 1.40 1.20 1.00 f,/') 0.80 0 .60 20.0 0.40 10.0 0.20 0 .0 0.00 s s s :s: s s s s s s s :s: :s: I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' N N. . N N N N N N N N 0 0 I-' I-' iv iv w I-' I-' N N w w ~ ~ u, u, 0 u, 0 u, 0 u, 0 0 u, 0 u, 0 u, 0 u, 0 u, -0 -0 -0 -0 -0 -0 -0 :s: -0 -0 -0 -0 -0 -0 -0 -0 -0 -0 $ $ $ Local Time CE (1-s) - FS (1-s) - SI (1-s) Figure 7. North Flare. Time series plot of 1-second resu lts for CE, FS, and SI. l<raton - North Flare (1-second results) 200.00 3,000 180.00 160.00 2,500 140.00 120.00 ]: 100.00 u.. u.. 80.00 60.00 2,000 "'2 ..E..... 1,500 .:.:.:,, i::c 0:: 1,000 :r: 40.00 500 20.00 0 .00 0 s s s s s s s s :s: :s: :s: :s: :s: s:: s I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' I-' N N N N N N N rv !'::' N 0 0 I-' I-' iv iv UJ I-' I-' N N OJ OJ ~ ~ u, u, 0 u, 0 u, 0 u, 0 0 u, 0 u, 0 u, 0 u, 0 u, "Cl -0 -0 -0 "Cl -0 -0 -0 -0 -0 -0 -0 -0 -0 "Cl "Cl "Cl s s Local Time - FF (1-s) - HR (1-s) Figure 8. North Fla re. Time series plot of 1-second resu lts fo r FF and HR. Rev ised: 10/10/201810:57:oo AM Page 8 I10 Project No. 1198-001 US EPA Region 5 VI SR Flare Testing Flare CE in Different Averaging Periods Kraton - North Flare 100.0 95.0 90.0 85.0 80.0 l w 75.0 u 70.0 65.0 60.0 55.0 50.0 - f-\ f-\ f-\ f-\ f-\ f-\ f-\ f-\ f-\ f-\ 1--' 1--' 1--' f-\ 1--' N N N N N N N N N N 0 0 1--' 1--' N 1--' 1--' i-:> i-:> lJJ lJJ i. :i;;. V, V, 0 V, 0 V, 0 0 V, 0 V, 0 V, 0 V, 0 V, -0 -0 -0 -0 -0 s s s s s s s s s s s s s s s -0 -0 -0 -0 -0 -0 -0 -0 -0 -0 Local Time - CE (1-s) - CE (1-m) -..-cE (15-m) - CE (duration) Figure 9. North Flare. Time series plot of CE with different averaging periods. Figure 10. North Flare. Left: A representative composite spectra l image generated by VISR instrument. Red color represents CO2; green color represents hydrocarbon; and blue or bluish white color represents aerosol (e.g., soot) or hot solid object (e.g., the shield for pilots). Right: A representative image in visible spectrum . Revise d: 10/10/201810:57:oo AM Page 9 j 10 Project No. 1198-001 US EPA Region 5 VISR Flare Testing Electronic Data Generated from the Test The following electronic data are submitted to the US EPA Region 5 as part of this report: A Microsoft Excel file containing second-by-second results from the VISR instrument, derived 1minute average results, and 15-minute average results when applicable. Video recording of the flare during the test, taken by a regular video camera in visible spectrum. Spectral video generated by the VISR instrument, including a clip the North Flare (Kraton North Flare Run 9.avi) References 1. Validation of a New Method for Measuring and Continuously Monitoring the Efficiency of Industrial Flares, Y. Zeng, J. Morris, M. Dombrowski, J. Air & Waste Manage. Assoc. 66:76-86 (2016). 2. Perfor(llance Review of Remote and Direct Flare Combustion Efficiency Monitor, Y. Zeng and J. Morris, presented at American Fuel & Petrochemical Manufacturers (AFPM) 2017 Environmental Conference, Denver, Colorado, October 15-17, 2017 3. Video Imaging Spectral Radiomet er (VISR) Based Flare Monitor, Y. Zeng, presented at Air Quality Measurement Methods and Technologies, Long Beach, California, November 7-9, 2017 More information about the VISR method and its validation can be found at https://www.providencephotonics.com/flare-monitoring. Revised: 10/10/201810:57:oo AM Page 10 I10