Document rx2KQE54m9r8pQVgwQ6LBVJaa

ft EPAUnitedStatas .-..r.. Environmental Protedion " Aggncy Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 10/25/2017 Air NESHAP NSPS Title V Clean Air Act Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Total Petrochemicals & Refining USA, Inc. Carville Polystyrene Plant 6225 Hwy 75 Carville, LA, 70721 PO Box 98 Carville, LA, 70721 lberville Parish Jill Lamberth I Environmental Group Leader jill.lamberth@total.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110000597319; 110020042808 Al5176 AFS 2204700036 325211 2821 Personnel participating in inspection: Justin Chen EPA 6EN-AT James Haynes EPA 6EN-AT James Leathers EPA 6EN-AT Prince Nfodzo EPA 6EN-AA Ashlie LeBlanc LDEQ Cory Lormand LDEQ Jill Lamberth TPRI David Shaw EPA Lead Inspector Signature/Date TPRI ~ ---~ 4ffl5pector name} Environmental Engineer Physical Scientist Environmental Engineer Environmental Engineer Environmental Scientist Environmental Scientist Environmental Group Leader Polystyrene Operations Manager 214-665-2273 214-665-6569 214-665-8545 214-665-7 491 225-219-3361 225-219-3040 225-642-4772 225-642-4625 iZ--13 -It- Date Supervisor Signature/Date ll(v\.J\AJ'x ~1\D tlw0-Z... {Supervisor IJSme} /1..- 1-:.-11 Date 6ENFORM-019-R7 (2/15/2017) 1 Section I - INTRODUCTION Total Petrochemicals & Refining USA, Inc./ Carville Polystyrene Plant Inspection Date 10/25/2017 PURPOSE OF THE INSPECTION EPA Region 6 inspectors Justin Chen (lead inspector), James Haynes, James Leathers, and Prince Nfodzo arrived at the Total Petrochemicals & Refining USA, Inc.--Carville Polystyrene Plant at 8:30 AM on 10/25/2017 for an announced inspection. We met with Jill Lamberth (Environmental Group Leader), David Shaw (Polystyrene Operations Manager), Russell Watts (Polystyrene General Supervisor), Michael Roussel (Environmental Engineer), Lance Martin (Health Safety, Security and Environmental Manager), and Donna Schlotzhauer, P.E. (Environmental Engineer) at the Opening Conference. Prince Nfodzo presented his credentials to facility staff and I informed them that this was an EPA inspection to determine compliance with the facility's Title V Air Permit and the Clean Air Act. The scope of the inspection was a partial compliance evaluation (PCE) that included evaluation of the compliance of the facility with its Title V operating permit and Louisiana State Implementation Plan (SIP) regulations, specifically focusing on flaring operations. This inspection was prompted by the National Enforcement Initiative: Cutting Hazardous Air Pollutants and its associated Enforcement Alert concerning Flaring Efficiency Violations. The inspection was conducted in coordination with the Louisiana Department of Environmental Quality (LDEQ), with Ashlie LeBlanc (Environmental Scientist) and Cory Lormand (Environmental Scientist) of LDEQ attending the inspection. See Appendix 2 for Opening Conference Sign-in Sheet. FACILITY DESCRIPTION Total Petrochemicals & Refining USA, Inc. (TPRI), owns and operates the Carville Polystyrene Plant in Carville, Louisiana. The facility was established in 1984 and operates 8760 hours per year. It has a rated annual production of approximately 1.55 billion pounds of polystyrene, and it is contiguous with the CosMar Styrene Monomer Plant. The plant produces polystyrene by continuous polymerization of styrene monomer in liquid phase reactor systems. Unreacted styrene is flashed off in vacuum devolatilizers and the molten polymer is extruded and pelletized. There are 4 active production lines, with an annual production capacity of approximately 200 million pounds for Polystyrene Line 1000 (Line 2000 is permanently shut down), 400 million pounds for Polystyrene Line 3000, 350 million pounds for Polystyrene Line 4000, and 600 million pounds for Polystyrene Line 5000. Regulated Clean Air Act (CAA) units includes hot oil heaters, cooling towers, wastewater collection systems, storage tanks for raw materials, additives and finished products, and thermal oxidizers (3 total) and flares (2 total) for control of air emissions. Section II - OBSERVATIONS At the opening conference, TPRI staff provided documents as requested from Appendix 3 for review. TPRI staff told me that the facility produces 2 grades of polystyrene, one with rubber and one without rubber. I was told that the 2 flares are emergency use only with no continuous venting. All continuous venting is to the 3 thermal oxidizers, where Polystyrene Line 1000 and 3000 share TO-3010, Polystyrene Line 4000 uses TO-4010, and Polystyrene Line 5000 uses TO-5010. For the flares, TPRI staff said that Polystyrene Lines 1000 and 3000 share flare FL-1100, and Polystyrene Lines 4000 and 5000 share flare 2 Total Petrochemicals & Refining USA, Inc./ Carville Polystyrene Plant Inspection Date 10/25/2017 FL-4100, and that the flares are used 1 to 2 times a year as they're only operated when associated rupture disks are breached. TPRI explained that 1 rupture disk had been breached in 2013, 2014, and 2017, 2 rupture disks had been breached in 2015, and a larger event occurred in 2016. I asked the TPRI staff what were the back up control devices for the thermal oxidizers if they were not operable, and they said that each thermal oxidizer had a carbon canister system for back up. TPRI said that there were eight (8) 1000-pound carbon canister vessels, 2 per production line, and if a thermal oxidizer were to fail, the carbon canisters would be automatically routed to from the production lines. When I asked about the details of the flare operations and whether or not performance tests had ever been conducted on either flare, TPRI staff told me that there has been no performance testing because it would require a simulated rupture disc breach scenario, which is potentially hazardous to staff working in the vicinity. TPRI staff told me that flare steam assist injection occurs only during active flare use and if there are visual emissions observed, and that steam injection is controlled from the board of the control room. TPRI staff explained that if a power outage were to occur during flare usage, steam would be injected at its maximum rate, where TPRI staff assume that the steam injection would not snuff out the flame. TPRI staff told me that they assume that, in the event of a rupture, the vent gas being sent to the flare would be of inherently high heat content from the production line. I was also told that each flare monitors if its pilot flame is lit with 2 thermocouples for each flare. I continued to review the TPRI-provided data, including an approved waiver request (Appendix 4) waiving requirements for conducting performance tests on its 2 flares. As part of this waiver request, engineering calculations for the heat content and flare tip velocity were included, substantiating those requirements from 40 CFR 63.11(b)(7). I participated in a site tour of the facility with TPRI staff following the opening conference. We first visited Polystyrene Line 5000 and were shown its thermal oxidizer TO-5010 as well as its backup carbon canister system at surge drum T5007. TPRI staff said that only styrene and ethylbenzene vapor would be sent to the flare in a rupture disc breach scenario. Using a forward looking infrared (FLIR) camera, I observed flare FL4100 and saw no emissions. I observed a steam leak from the flare and informed facility staff. I also observed Polystyrene Line 3000's cooling tower with the FLIR camera and observed no significant emissions. The inspection team moved on to flare FL1100, where I observed the flare with the FLIR camera and observed no emissions. Neither flare FL1100 or FL4100 were in use at the time of inspection. The inspection team returned from the field to have a departure conference from the facility. I requested flare usage data from 2014 to 2017 and Jill Lamberth stated she would send it to me by email. 3 Total Petrochemicals & Refining USA, Inc./ Carville Polystyrene Plant Inspection Date 10/25/2017 Section III - AREAS OF CONCERN I observed no areas of concern (AOCs) at the time of the inspection. At the departure conference I requested flare usage data from 2014 to 2017 for both flares, but had no areas of concern to share with TPRI staff at the departure conference. I received signed Confidentiality Notices from TPRI management for Confidential Business Information (CBI) provided by the facility, and copies of photographs taken at the facility were given to TPRI management at the departure conference. Photos taken during the inspection are located in Appendix 1. Section IV - FOLLOW UP The following information was received by EPA after exiting the Facility on October 25 2017: 2014-2017 SUMMARY OF FLARE EVENTS.xlsx (Appendix 5) 2014-2017 EMISSIONS SUMMARY OF FLARE EVENTS REV 1.xlsx (Appendix 6) These 2 documents provided expanded detail on the periods of time where flare FL1100 and FL4100 were used because rupture disc breaches had occurred. I found no additional AOCs after reviewing these documents. Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 2 photos taken 10/25/2017 Appendix 2 - Opening Conference Sign-in Sheet Appendix 3 - Documents Request Appendix 4 - Request for Waiver of Flare Performance Test & LDEQ Approval Appendix 5 - 2014-2017 SUMMARY OF FLARE EVENTS.xlsx Appendix 6 - 2014-2017 EMISSIONS SUMMARY OF FLARE EVENTS REV 1.xlsx 4 Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Total Petrochemicals & Refining USA, Inc./Carville Polystyrene Plant City: Carville County/Parish: Iberville Parish State: Louisiana Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0203.JPG 10/25/2017 10:37AM Justin Chen Flare FL4100 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Total Petrochemicals & Refining USA, Inc./Carville Polystyrene Plant City: Carville County/Parish: Iberville Parish State: Louisiana Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DSCN0204.JPG 10/25/2017 10:49AM Justin Chen Flare FL1100 Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Appendix 2 Opening Conference Sign-in Sheet Total Petrochemicals & Refining USA, Inc./ Carville Polystyrene Plant Inspection Date 10/25/2017 Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Appendix 3 Documents Request Total Petrochemicals & Refining USA, Inc. - Carville Polystyrene Plant Carville, Louisiana E.P.A. 6EN-AT Records/Documents Request GENERAL PROCEDURE During the focused Clean Air Act compliance investigation at Total Petrochemicals & Refining USA, Inc. (TPRI) - Carville Polystyrene Plant in Carville, Louisiana, inspectors will be reviewing records kept for your facility. In order 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 will be requested for later review by EPA. In preparation for this focused multimedia 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 (only as noted) on October 25, 2017. The second section consists of general and media 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 TPRI to develop a schedule to review these documents. PART 1 - Please have these documents available on October 25, 2017 1. Descriptions for all process areas including the following information: a. Process flow diagrams (4 copies) with attached written descriptions b. Material balances c. Pollution control equipment d. Raw materials used and annual usage e. Products made 2. Site map of the facility (4 copies) 3. Facility organizational chart (including overall responsibilities and environmental department) (1 copy) 4. Monthly production for each type of product manufactured from 2014 to present (1 copy) Clean Air Act (CAA) 5. Most recent Title V operating permit (1 copy) 6. Identification of emission sources subject to MACT requirements 7. Provide the following information for flares at the facility: a. Date of installation b. Manufacturer and model number c. Purpose (e.g., emergency only, routine, intermittent process waste gas) d. General design type (e.g., ground or elevated, multi-tip or single tip, assisted or nonassisted; if assisted, indicate whether flare is steam, air, or pressure assisted) i. Minimum assist steam (in lb/hr) or assist air (in scf/hr) rate at all locations on each flare, and means of control of steam or air (e.g., valve, bypass orifice); e. Please describe how the amount of waste gas, purge gas, sweep gas, supplemental gas, assist steam, and assist air is measured or monitored f. Please provide a diagram that shows the locations of each: i. Measurement or monitoring point for pressure, flow, net heating value, molecular weight, and constituent concentration ii. Injection point for purge gas, sweep gas, and supplemental gas 8. All stack test/performance test reports for the flare(s) describing methods used, test data, calculations, test results and process information. Include all test data from tests done by the company, consultants or regulatory agencies. 9. For all continuous monitoring systems (i.e. COMS, CEMS, etc.), provide a description of monitoring data for each monitored parameter used to demonstrate continuous compliance with any applicable emission standard or permit requirement. Part 2 - Documents to be provided post inspection General 1. Enforcement Actions/Notices of Violations (NOVs) 2. Consent Decrees/Orders/Agreements and related correspondences Clean Air Act 3. For periods when waste gas is sent to the flare(s), please provide the following information for each flare in searchable and editable electronic format (e.g., spreadsheet): a. The hourly average net heating value, in British Thermal Units per standard cubic foot (BTU/scf), of the vent gas for the period beginning 3 years prior to the date of receipt of this request. b. The hourly average concentration of each constituent of the vent gas for the period beginning 3 years prior to the date of receipt of this request. c. The hourly average mass flow rate, in lb/hr, of the vent gas for the period beginning 3 years prior to the date of receipt of this request. d. The hourly average rate at which assist steam and/or assist air was added to the flare, in lb/hr for steam, or scf/hr for air, at all locations on each flare (i.e., the sum of seal, upper, lower, winterizing, etc.) for the period beginning 3 years prior to the date of receipt of this request. If the hourly averages for any or all of the subsections above are measured, but data is not available, provide an explanation for each time period missing hourly data (e.g., flare not in service, instrumentation malfunction, etc.). If the requested data is not measured or otherwise monitored, use the best means available to calculate/estimate the hourly averages. Provide a narrative explanation and example calculations describing how you arrived at your response. Such methods of calculation/estimation include, but are not limited to, the use of calculations from an online, intermittent, or continuous gas chromatograph (whether at the flare or upstream of the flare), estimating flow from pressure measurements or from valve position data, periodic samples/analysis of gas flowing to the flare, and/or process knowledge. If the requested data was not measured or cannot be calculated or estimated (e.g., lack of equipment, equipment malfunction, and/or maintenance at a flare), provide an explanation of why no data is available and why the data cannot be calculated or estimated.) 4. For each flare (if applicable), provide the hourly average Steam-to-Vent Gas Ratio (lb Steam/lb Vent Gas) for the period beginning 3 years prior to the date of receipt of this request. If the rate at which steam added is not measured, use the best means available to estimate it. Provide a narrative explanation, including considerations for seasonal variations and minimum flow, with example calculations describing how you arrived at your response. All steam (including minimum or bypass steam) should be included in ratio calculation. 5. For each flare, describe how the pilot flame is monitored and how the monitoring data is recorded. Provide the monitoring data for the flare pilot flame for the period beginning 3 years prior to the date of receipt of this request. 6. For each flare, provide copies of documents in your possession, custody, or control pertaining to operating procedures, monitoring procedures, and flare performance testing. 7. For each flare, state whether the flare is configured to receive gases/vapors from one or more pressure relief device(s), which is a safety device used to prevent pressures from exceeding the maximum allowable working pressure of the process equipment. Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Appendix 4 Request for Waiver of Flare Performance Test & LDEQ Approval Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Appendix 5 2014-2017 SUMMARY OF FLARE EVENTS.xlsx SUMMARY OF FLARE EVENTS 2014-2017 YTD 8/5/2014 Flare F-1100 A horizontal reactor pump P-1004 shut down, which led to overpressure and failure of rupture disk. 9/12/2015 A vertical reactor pump P-3101 tripped, which led to overpressure and failure of rupture disk. 10/13/2015 Plugged spillback line on horizontal reactor R-3002 led to overpressure and failure of rupture disk. 2/2/2016 Horizontal reactor R-2002 rupture disk failed prematurely. 6/24/2016 Power outage led to overpressure of vertical reactors and failure of corresponding rupture disks. 1/14/2017 Horizontal reactor R-2004 spillback line overpressured due to operator error, causing rupture disk to fail. Flare F-4100 6/24/2016 Power outage led to overpressure of vertical reactors and failure of corresponding rupture disks. Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Appendix 6 2014-2017 EMISSIONS SUMMARY OF FLARE EVENTS REV 1.xlsx SUMMARY OF FLARE EVENTS 2014-2017 YTD Date Flare F-1100 PSE # 8/5/2014 A horizontal reactor pump P-1004 shut down, which led to overpressure and failure of rupture disk. 9/12/2015 A vertical reactor pump P-3101 tripped, which led to overpressure and failure of rupture disk. 10/13/2015 Plugged spillback line on horizontal reactor R-3002 led to overpressure and failure of rupture disk. 2/2/2016 Horizontal reactor R-2002 rupture disk failed prematurely. 1446 3915 3916 2434 Equip # HAP Emissions (lb) R-1004 8.9 R-3001 4.5 R-3002 8.9 R-2002 8.9 2827A R-2100 8.8 6/25/2016 Power outage led to overpressure of vertical reactors and 2830 R-2101 14.8 failure of corresponding rupture disks. 3937 R-3101 14.8 1/14/2017 Horizontal reactor R-2004 spillback line overpressured 2446 R-2004 4.5 due to operator error, causing rupture disk to fail. Date Flare F-4100 PSE # 4986 Equip # HAP Emissions (lb) R-4100 14.8 4937 R-4101 14.8 6/25/2016 Power outage led to overpressure of vertical reactors and failure of corresponding rupture disks. 5986 R-5100 14.8 5937 R-5101 14.8