Document z9VJeMxgyz8z9yE0D1D6kpD3

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III Four Penn Center - 1600 John F Kennedy Blvd Philadelphia, Pennsylvania 19103-2852 Report Title: Inspection Date(s): Regulatory Program(s): Geospatial Measurement of Air Pollution of PQ Corp Chester 03/29/2023 SIP, Title V, NSPS, MACT, NESHAP Company Name: Facility Name: Facility Location: Latitude: County/Parish: PQ LLC PQ Corp Chester 1201 W Front Street Chester, PA 19013 39.840401 Delaware County Longitude: -75.372368 AFS/ICIS-Air Number: Permit Number: NAICS Code: Unique Project #: PA000238534 23-00016 325180 3E23CA089A SIC: 2819 Facility Representatives: Joe Lala, Senior EHS Manager Phone: 484-402-0791 Email: Joe.lala@pqcorp.com Point of Contact EPA Inspectors: Parmatma Adhikari, Air Inspector, 3ED21 Phone: 215-814-2161 Email: Adhikari.parmatma@epa.gov Nicholas Bobbs, AED Phone: 202-562-0726 Email: Bobbs.nicholas@epa.gov Philip Myers, NEIC Phone: 303-462-9301 Email: Myers.philip@epa.gov Scott Yanos, Air Inspector, 3ED21 Phone: 215-814-2128 Email: Yanos.scott@epa.gov State/Local Inspectors: Heather Henry, Air Quality Specialist, PA DEP Phone: 484-877-6092 Email: hehenry@pa.gov EPA Lead Inspector Signature Parmatma Adhikari Digitally signed by Parmatma Adhikari Date: 2023.05.17 12:59:40 -04'00' Parmatma Adhikari 1600 John F Kennedy Blvd Philadelphia, PA 19103-2852 KRISTEN Supervisor HALL Signature Digitally signed by KRISTEN HALL Date: 2023.05.17 13:38:38 -04'00' Kristen Hall Date Date Table of Contents I. Introduction ................................................................................................................................................3 A. Summary of the Facility ........................................................................................................ 3 B. Inspection Opening Conference............................................................................................. 3 II. Site Activity/Process Description .............................................................................................................4 III. Observations ............................................................................................................................................4 IV. Closing Conference .................................................................................................................................4 Unique Project #: 3E23CA089A Page 2 of 5 I. Introduction The United States Environmental Protection Agency (EPA) conducted a Geospatial Measurement of Air Pollution (GMAP) evaluation at PQ Corp Chester (PQ or Facility) to determine if elevated levels of compounds were present. The Pennsylvania Department of Environmental Protection (PA DEP) was notified of the inspection on March 15, 2023, via email. On March 29, 2023, EPA notified the Facility of the planned inspection via phone. A. Summary of the Facility The Facility is located at 1201 W Front Street, Chester, PA 19013. PQ Corp Chester produces sodium silicate by processing soda ash it receives from a barge terminal on the Delaware River. PQ's product is mostly consumed by Evonik Corp Chester, which is located adjacent to PQ and is transferred via a pipe between the facilities. The Facility received a Title V Permit (23-00016) from PA DEP issued on March 11, 2022. PQ Corp Chester is classified as major source for Carbon Monoxide (CO), Nitrogen Oxides (NOx), Sulfur Oxides (SOx), Volatile Organic Compounds (VOCs), Hazardous Air Pollutants (HAP) and Particulate Matter (PM). The Facility is subject to, or potentially subject to the following federal regulations: 40 CFR Part 60 Subpart Dc: Standards of Performance for Small Industrial-CommercialInstitutional Steam Generating Units 40 CFR Part 60 Subpart IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines 40 CFR Part 63 Subpart JJJJJJ: National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources B. Inspection Opening Conference At 3:11 PM on March 29, 2023, EPA inspectors arrived at the Facility for a Clean Air Act (CAA) Inspection and conducted a brief opening conference. PQ was represented by Joe Lala, Senior EHS Manager. Also, Heather Henry, PA DEP was present. EPA inspectors, Parmatma Adhikari, Nicholas Bobbs, Philip Myers, and Scott Yanos, presented their credentials and explained the purpose of the visit was to conduct a Geospatial Measurement of Air Pollution (GMAP) monitoring. EPA inspector Nichola Bobbs explained that the GMAP vehicle has the capability to monitor Hydrogen Sulfide (H2S), Volatile Organic Compounds (VOCs), Methane (CH4), Sulfur Dioxide (SO2) and Benzene (C6H6). Unique Project #: 3E23CA089A Page 3 of 5 II. Site Activity/Process Description PQ Corp produces sodium silicate (NaSiO) by heating the soda ash it receives from the barge terminal to high temperatures to produce a reaction with silica sand which forms water glass. It is then crushed, dissolved in water, and digested under pressure with steam. Joe Lala mentioned that PQ uses a natural gas-fired glass furnace to form sodium silicate. The opening conference concluded at 3:21 PM. III. Observations EPA inspectors were led on a drive through of the Facility at 3:22 PM by Joe Lala of PQ and Heather Henry of PA DEP also present for the drive through. Joe Lala, Heather Henry, and Scott Yanos walked the perimeter of the facility while Nick Bobbs, Phil Myers and Parmatma Adhikari followed in the GMAP vehicle. It is noted that at the time of the GMAP evaluation, the process furnace was not operating to produce the sodium silicate. The EPA GMAP vehicle was lead through the perimeter of the Facility. EPA observed GMAP readings which are represented in Table 1. A designation of "elevated" means elevated concentrations of the listed pollutant were measured above the background level using the GMAP. Actual numeric concentration readings observed during the monitoring event were not yet verified at the time of this report, but can be shared with the Facility, once the data becomes verified. Time H2S 3:25 pm VOCs TABLE 1 CH4 SO2 Elevated C6H6 Approximate Location Barge Terminal The drive through concluded at 3:35 PM. IV. Closing Conference After the drive through, EPA inspectors, Joe Lala and Heather Henry had a brief closing conference to ask additional questions and discuss observations. The EPA inspectors noted that the investigation is on-going, and any areas of concern identified in the final report do not necessarily reflect a violation or deviation, rather, they are areas that will require further investigation. EPA also noted that they would issue an inspection report within in 60 days, with a copy to the State. Simultaneously, EPA will perform a detailed review of records and may have additional questions. Unique Project #: 3E23CA089A Page 4 of 5 The following have been identified as potential issues during the inspection. They are issues that require either further investigation by EPA or additional information or explanation by PQ Corps. Elevated methane emissions The inspection concluded at 3:40 PM. Unique Project #: 3E23CA089A Page 5 of 5