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DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEYARD CHICAGO, ILLINOIS 60604 OCT OIt 2018 CLEAN AIR ACT INSPECTION REPORT Firestone Polymers Gregory Gehrig, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Chief AECAB (Ml/WI) File BASIC lNFORMA TION Facility Name: Firestone Polymers Facility Location: 381 West Wilbeth Road, Akron, OH Date of Inspection: September 19, 2018 Lead Inspector: Gregory Gehrig, Environmental Engineer Other Attendees: Kenneth Ruffatto, Cary Secrest, U.S. EPA; Bill Hawks, Manager, Safety & Health and Kevin Culligan, Environmental Engineer, Firestone Polymers Contact Email: bhawks@firestonepolymers.com Purpose of Inspection: CAA Compliance Facility Type: Synthetic rubber manufacturing pilot plant Regulations Central to Inspection: SIP, NSPS and MACT Arrival Time: 1000 hrs Departure Time: 1210 hrs Inspection Type: l?sl Unannounced Inspection Facility Name: Firestone Polymers Facility Location: 381 West Wilbeth Road, Akron, OH Date of Inspection: September 19, 2018 D Announced Inspection OPENING CONFERENCE 12:1 Credentials Presented 12:1 CBI warning to facility provided The following information was obtained verbally from facility personnel. Company Ownership: Same ownership since at least 2013. Process Description: Firestone Polymers (Firestone) manufactures synthetic rubber using butadiene, styrene and hexane in two batch processes and also in two continuous processes. Small amounts of additives are also added at various points in the process. Butadiene and hexane are received via rail car, offloaded and held in tanks. Tank areas have hydrocarbon detectors for safety purposes. Styrene is used in lower quantities and is received and held in totes. This is a pilot plant and formulations and exact process conditions are changed frequently to produce synthetic rubber with different properties. Carbon black is only used on a laboratory scale at this facility. The facility was down for annual planned maintenance at the time of inspection. No processes were running and no emissions were being vented to the flare. Firestone typically operates 24 hours per day Monday to Thursday (production days), and Friday is a maintenance day. The facility uses a single flare to control emissions. Emissions ofbutadiene, styrene and hexane are generated during the transfer of materials via pressure differential, including rail car offloading. Flaring is not continuous and vent gas is routed to the flare approx. 1 hour per operating day. The flare is typically non-assist, but has the capability to be assisted with steam. This steam assist capability was installed after a butadiene emergency venting event with significant visible emissions (VE) in 2013. No steam has ever been used to assist combustion. There is an opacity camera for the flare and control logic to add steam based on the camera's observations, although it wasn't working at the time of the inspection and hasn't been operational for some time. Facility personnel are aware it isn't working, but are confident steam could be added manually if ever needed. Vent gas and steam flows are not measured. Heating value of the vent gas was determined by a perfonnance test. The processes leading to and including the flare header are swept with approx. 45 scfh of nitrogen. Relief valves vent to the flare, but have rupture plates ahead of the valves, both of which are checked regularly. Venting to the flare is recorded in electronic log books. Toi.JR INFORMATION EPA toured the facility: Yes Data Collected and Observations: Page 2 of 4 Facility Name: Firestone Polymers Facility Location: 381 West Wilbeth Road, Akron, OH Date of Inspection: September 19, 2018 The production areas, including the reactors, storage areas, and the flare were visited on the facility tour. At the time of inspection, the facility was not in production. Photos were taken. Field Measurements: were not taken during this inspection. RECORDS REVIEW No records were reviewed during the inspection. CLOSING CONFERENCE Requested documents (lo be sent via email): Photos, collected by U.S. EPA on Firestone's intrinsically safe camera and emailed to G. Gehrig same day. Specifications on the flare, including O&M manuals, design drawings and operating procedures. A summary of recent preventative maintenance activities on the flare . Any recommendations by consultant/mmrnfacturer with respect to flare performance, including in response to the 2013 smoking event. Performm1ce test results for flare vent gas heating value determination. Summary of venting to the flare for the past 12 months . Compliance Assistance: None. Concerns: None noted at inspection. SIGNATURES lrnd lmpWm /f/ / 1 / ~ Section Chief: ~~ Date: - - - - - - - Date: / 0 )Lj /; 3 7 l Page 3 of 4 Facility Name: Firestone Polymers Facility Location: 381 West Wilbreth Road, Akron, OH Date ofinspection: September 19, 2018 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Gregory Gehrig 3. Company/Facility Name: Firestone Polymers 5. Number of Images: 6 2. Date(s) ofinspection: September 19, 2018 4. Street Address, City, State: 381 West Wilbeth Road, Akron, OH 6. Archival Record Location: CD-R labeled Firestone Images 9.19.2018 Image name Time (CDT) Description IMG 20000914 233554 1135 Continuous reactors IMG 20000914 234600 1140 Nitrogen purge inlet IMG 20000914 234611 1141 Hydrocarbon detector in tank area IMG 20000914 235221 1143 Flare at distance IMG 20000915 000509 1148 Flare, closer view IMO 20000915 000902 1150 Header at base of flare Note: Images collected by G. Geluig with Firestone's intrinsically safe camera and emailed to U.S. EPA. Times are approximate as photos not taken with U.S. EPA camera. Page 4 of 4