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Home My WebLink About9602 ALR000012252 097 06-10-2021 HWTM MSJ Trip Report ADEN ALABAMA HAZARDOUS WASTES MANAGEMENT AND MINIMIZATION ACT (AHWMMA) Compliance Evaluation Inspection (CED Report 1) Author of Report Lanny Sasser Environmental Scientist, Sr. Compliance and Enforcement Section, Industrial Hazardous Waste Branch Alabama Department of Environmental Management(ADEM) 1400 Coliseum Boulevard Montgomery, Alabama 36110 2) Facility Information Ineos Phenol,A Division of Ineos Americas,LLC (Ineos) 7770 Rangeline Road Theodore (Mobile County),Alabama 36582 EPA ID Number: ALR000012252 NAICS Codes(s): 325199 Telephone: (251)443-3032 Website: ineos.com 3) Responsible Officials Mr. Marcelles M. Prather, Environmental Engineer Phone: (251) 443-3031 Email: marcelles.prather@ineos.com 4) Inspection Participants Mr. Marcelles Prather, Environmental Engineer—Ineos Mr. Mike Hamner, Environmental Engineer—Ineos Mr. Lanny Sasser—ADEM 5) Date(s) of Inspection June 2, 2021 6) Applicable Regulations ADEM Administrative Code Division 335-14, Hazardous Waste Program Regulations 1 Page 7) Purpose of Inspection The purpose of the inspection was to determine Ineos's compliance with all applicable requirements of Division 14 of the ADEM Administrative Code. 8) Facility Description Ineos is a division of INEOS Americas LLC, which is owned by Ineos. Ineos Phenol is an industrial chemical manufacturer of two basic chemicals,phenol and acetone, and a co-product, PC Oil. Acetone is used by manufacturers of derivative products including aspirin, compact discs, car bumpers, household appliances and acrylic glass. Phenol is used by manufacturers of phenolic resins that are in turn used by manufacturers who make plywood and other wood products used in construction and furniture manufacturing. PC Oil is used by the carbon black industry to make toners. The facility began operation at its current location in March 2000 on 40 acres of previously undeveloped land. The site is located directly across Rangeline Road from an Alabama State Dock facility that includes a deep-water dock and a tank farm. INEOS Phenol leases the dock facility and is connected to it by road and pipeline.The facility currently has 125 employees along with contractors. The facility operates twenty-four hours per day year- round. Cumene, a coal tar derivative is the feedstock used to manufacturer acetone and phenol. The Cumene is received by railroad car, barge and ship. The acetone and phenol are both simultaneously produced in an oxidation reactor continuous process. The plant has six oxidation reactors (two banks of three train reactors)located at the north end that are connected to the cleavage process where the acetone and phenol are initially produced. The products continue to the south end acetone and phenol distillation units equipped with thirteen columns and ten columns, respectively, and then finally through filtration and purifying lines until they emerge as finished products. Alphamethylstyrene could be produced as a by- product at the plant but is recycled back into the process as feedstock. The products are shipped by trucks, railroad cars, barges and ships. Hazardous waste are generated and placed in SAA containers at various locations throughout the facility. The main CAA for containers is equipped with a coated secondary containment system with a capacity of approximately fifty 55- gallon drums. A second CAA is for bulk containers on an as needed basis for remediation related waste. Used oil is accumulated in a 330-gallon tote located underneath the lean-to connected to the maintenance building. Universal waste is accumulated in areas inside the storeroom. The non-hazardous sludge generated at the WWTP is disposed at a permitted solid waste landfill. The facility discharges to Middle Fork Deer River under a National Pollutant Discharge Elimination System permit. In its most recent notification of regulated waste activity (ADEM Form 8700-12),which was received by the Department on December 21, 2020, Ineos identified itself as a large quantity generator (LQG) of hazardous waste, a used oil (UO) generator and a small quantity handler of universal waste (UW). 2 1 P a g e ADEN 9) Observations At approximately 10:30 a.m. on June 6, 2021, I arrived at Ineos and checked in at the front desk. I presented my identification and explained the purpose of the inspection.Mr. Prather and Mr. Hamner met me at the front desk and escorted me back to a conference room where I conducted the opening conference. Following the opening conference, Mr. Hamner escorted me on a tour of the facility where the following areas were inspected: Maintenance Shop [3 satellite accumulation areas (SAA)]; Warehouse (22 UW containers); Wash Pad (1 SAA); Distillation Area (1 SAA); Thermal Oxidizer Area (1 SAA); Truck & Rail Loading (1 SAA); Absorption Unit(1 SAA); Cleavage Unit (1 SAA); Concentration Unit (1 SAA); Intermediate Tank Farm (1 SAA); Phenol Removal (1 SAA); and the Lab (3 SAA). All SAA for these units were closed and appropriately labeled. I The central accumulation area (CAA) contained nineteen 55-gallon drums. The CAA was secure, had appropriate warning signs and secondary containment was adequate, coated and free of cracks and gaps. All containers were closed,labeled appropriately and the earliest accumulation start date found was April 15, 2021. No areas of concern were noted during the facility tour. After the walkthrough, Mr. Hamner escorted me to his office where he presented me with the following documents for review: Ineos's contingency plan, quick reference guide and proof of its submittal to local authorities; ADEM Form 8700-12; 2020 Biennial Report; Hazardous waste manifests (2017-present); CAA's weekly inspection logs (2017-present); and training records for selected facility personnel that handle hazardous waste. No areas of concern were noted during the record review. 10)Summary Based on the observations made during the inspection, Ineos appears to be a LQG of hazardous waste; a UO generator; and a small quantity handler of UW. At the conclusion of the inspection, I held a closing conference with Mr.Prather and Mr.Hamner.During the closing conference, I reviewed and discussed my observations, presented the findings to Ineos's representatives, and provided Ineos's representatives with an opportunity to ask questions. At the conclusion of the closing conference, I prepared a Preliminary Inspection Report noting that no areas of concern were found during the inspection. Mr. Prather acknowledged receipt by signing the form. The "original" signed form was given to Mr. Prather for the facility's records. I concluded the closing conference and departed the facility at 12:20 p.m. 3 1 P a g e 11)signed Compliance and Enfo ment Section, Industrial Hazardous Waste Branch Land Division June 10,2021 Date 12)Concurrence a/ 40.� Q. Brent A. Watson, Chief Compliance and Enforcement Section, Industrial Hazardous Waste Branch Land Division June 10,2021 Date Attachment: A) Photo Log B) Preliminary Inspection Report 4 Page ADEM ATTACHMENT A: PHOTO LOG 5 1 P a g e wi. b A! � rya 06/02/ 2021 10 28 PhenolIncos ADFA Y� Maintenance Shop 06/ 02/ 2021 10 : 31 QDEM - s� . .� . 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