Document qRRV6MZjKDKE8zEmRQJ0gv4n

DATE: SUBJECT: FROM: THRO: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 JUL 3 1 28t9 CLEAN AIR ACT INSPECTION REPORT Evonik Materials Corporation, Milton, Wisconsin Jason Schenandoah, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Evonik Materials Corporation Facility Location: 337 Vincent Street, Milton, Wisconsin Date of Inspection: June 24-25, 2019 EPA Inspector(s): 1. Jason Schenandoah, Environmental Engineer 2. Vicky Mei, Environmental Engineer Other Attendees 1. Sondra Klipp, Environmental Manager, Evonik Materials Corporation (Evonik) 2. JeffLaBrozzi, Site Manager, Evonik 3. Dave Welsh, Environmental, Health, and Safety Manager, Evonik 4. Bradley Neils, Senior Principle Process Engineer, Evonik 5. Paul Roberts, Client Project Manager, Montrose Environmental Group, Inc. 6. Jeff Myers, Environmental Toxicologists, Wisconsin Department of Natural Resources (WDNR) 7. Samuel Saeian, Air Management Engineer, WDNR Contact Email Address: david.welsh@evonik.com; sondra.klipp@evonik.com Purpose of Inspection: To ensure compliance with the Clean Air Act and conduct on-site EPA Method 21 (Method 21) monitoring. Facility Type: Chemical manufacturing facility June 24, 2019 Arrival Time: I 0:00 am Departure Time: 3:30 pm June 25, 2019 Arrival Time: 7:00 am Departure Time: 2:00 pm Inspection Type: l2J Unannounced Inspection D Announced Inspection OPENING CONFERENCE l2J Credentials Presented l2J CBI warning to facility provided The following information was obtained verbally from Evonik personnel unless otherwise noted. Company Ownership: Evonik's Milton facility used to be owned and operated by Air Products, Inc. Air Products sold its performance materials division, which included the Milton facility, to Evonik in January 2017. Process Description: There are several different batch processes that can occur at Evonik's facility in Milton, Wisconsin (the Facility). In general, fatty alcohols are processed into ether nitriles. Ether nitriles are further processed into ether amines. Ether amines can then undergo different processes to produce ether diamines, acetate salts, or amphoterics. Methyl chloride and ethylene oxide are brought in by rail car and unloaded into the pressurized vessels using a vapor balance system. Emissions from the batch processes may go to different emissions control devices. Batch reactions that involve ethylene oxide are controlled by a condenser. Batch reactions involving isopropyl alcohol are controlled by a catalytic oxidizer and during unloading a cryogenic condenser is used. Generally, batches take about 24 hours to process and batches regularly change daily depending on demand. Each reactor usually processes batches of certain families of products to minimize cleaning between batches. A small scrubber is used to control ethylene oxide emissions when disconnecting lines, for occupational safety. Ammonia and amines are controlled by a 3-stage water, water, phosphoric acid solution, followed by a 3-stage cryogenic cooler. Final products are stored in storage tanks and unloaded via truck. Staff Interview: The catalyst media in the catalytic oxidizer was last changed in 2010. In October 2016, a catalyst vendor conducted a visual inspection of the catalyst media and indicated that the catalyst was not in need of replacement. A third party, Montrose Environmental Group, Inc., conducts Method 21 monitoring at the Facility to meet Leak Detection and Repair (LDAR) Page 2 of5 requirements. Evonik has voluntarily taken on a 500 part per million (ppm) leak definition in its permit with regard to its LDAR requirements. An internal action level of 100 ppm is used to trigger component repair attempts at the facility. Evonik personnel stated that, from April 2018 to April 2019, there were 18955 monitoring events and 2 leaks were found. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Obsen,ations: Two toxic vapor analyzers (TVA), model 2020, were used by EPA to conduct Method 21 monitoring throughout the facility; Montrose was also using a TVA 2020 to confirm EPA's measurements. Method 21 monitoring was conducted onsite and relevant data is detailed in Appendix A. 3 components appeared to have open-ended lines (OELs) associated with them; Evonik personnel stated that the OELs were associated with lines in steam service. Photos and/or Videos: were not taken during the inspection. Field Measurements: were taken during this inspection. Method 21 monitoring measurements are detailed in Appendix A. RECORDS REVIEW 1. Production information sheet for June 24, 2019 (obtained) 2. Preventative maintenance plan inspection for the catalytic oxidizer for December 21, 2016 (obtained) 3. 2010 Facility map 4. 7/20/2012 Air Products, Inc. Site Utility Plan 5. Reaction PowerPoint presentation 6. Drumming log sununary sheet 6/12/2019- 6/24/2019 CLOSING CONFERENCE Concerns: There were three components monitored that had elevated measurements: component with tag number 04883 on the methyl chloride pressurized tank; manway on tank TK-204; and component labeled EPRV 20501 on tank TK-205; measured values can be referenced in Appendix A. SIGNATURES Page 3 of 4 Facility Name: Evonik Materials Corporation Facility Location: 33 7 Vincent Street, Milton, Wisconsin Date of Inspection: June 24-25, 2019 APPENDICES AND ATTACHMENTS J. Appendix A: Field Measurement Data Page 4 of 4 Facility Name: Evonik Materials Corporation Facility Location: 337 Vincent Street, Milton, Wisconsin Date oflnspection: June 24-25, 2019 APPENDIX A: FIELD MEASUREMENT DATA EPA TVA 2020s serial numbers: A56575 and A56584 Number of components monitored: Type of component Valves Pumps Connectors Number of Components Monitored 308 5 13 Notable measurements: Component identifier Pressure relief vent on methyl chloride tank, tag number 04883 Tank TK-204 manwav Tank TK-205 pressure relief device tag number EPRV 20501 TVA 56575 measurement(ppm) 1100 6800 (flame out) 1272 TVA 56584 measurement (ppm) NIA 3300 1400 Both TVA 2020s were calibrated with zero gas, 500 ppm methane, 2,000 ppm methane, and 10,000 ppm methane. Calibration records (*indicates bump check): Date and time 6/24/2019 12:30 om 6/24/2019 3:30 pm* 6/25/2019 7:00 am 6/25/2019 l 0:40 am* Concentration (oom) A56575 500 2,000 10,000 500 2,000 10,000 500 2,000 10,000 500 2,000 10,000 A56584 495 1,996 1,0200 490 1982 10000 496 2,011 10,000 495 1,995 9,890 490 1,990 9,640 562 2,275 11,200 475 1,943 9,545 518 2,108 10,400 Appendices Page 1 of 1