.n 1094/2017 Lego. Air Emission Event Report SITE SEARCH: please enter search phrase Texas SUBJECT INDEX Water Waste Search TCEQ Data Aqency Orqanization Map Air Emission Event Reporting Data]: Commission on Environme al Oualitv Regulated entity name ARKEMA CROSBY PLANT Physical location Regulated entity RN number RN100210301 City, County CROSBY, HARRIS Type(s) of air emissions event EMISSIONS EVENT Event began: 08/29/2017 This is based on the: FINAL REPORT Event ended: 08/29/2017 Cause On 08/25/17, the City of Houston and its surrounding areas experienced wide spread flooding as a result of Hurricane Harvey. Due to extensive flooding that took place within the plant due to inclement weather assoicated with Hurricane Harvey, both tanks accumulated large amounts of rain water which exceeded the tanks' capacity which caused it contents to overflow into the tanks' containment dike. Due to the widespread amounts of flooding waters within the plant, the flood waters began to overflow within the tanks' containment dike which consumed a portion of the dike's capacity along with the overflow from the tanks. The containment dike exceeded its capacity which resulted in the release of storm water containing mineral spirits and residual organics into/onto the flood waters within the plant. Ac?on taken Any mineral spirit and residual organic sheen identified on the plant property has been collected and will be properly disposed. Any mineral spirit and residual organic sheen identified within the tank containment dike and/or in the associated tanks will be properly removed and disposed as well. Currently water samples are being taken at and near the containment dike, within the plant's sump system(s), and at and near the plant's storm water outfalls to confirm whether there are any dissolved constituents present for purposes of storm water management. Emissions estimation method Engineering estimates were based on known quantities of organics measured in the tanks prior to the storm events, and waste profiles were used for speciation. A conservative assumption was made that all and maintained per August 28, 2017 TCEQ regulatory guidance on Suspension of TCEQ Rules related to Hurricane Harvey.Please note the event duration was based on the Atacosita Fire Station data, 6:06p last reading showing rainfall accumulation. Additionally, please note the 1i2 1 0f24i?20j 7 Air Emission Event Report following is additional information regarding the list of air contaminants compounds: DimethyI?2,5 Di(T-Butyl Peroxy)Hexane? 698.46 lbs. and T?Amyl alcohol- 2,793.85 lbs. Organic Peroxides: Di?T?Butyl Peroxide? 698.46 lbs. and Di?T-Amyl Peroxide- 698.46 lbs. Source 1: and 14-T-2B FIN number Source 2: WWTAN KS EPN number Contaminant Authorization Limit Amount Released No specific authorizations for 0.0 558.77 this faCility (est) Mineral Spirit No specific emissions authorizations for 0.0 11175.39 this faculity (est) Naphtha No specific emissions authorizations for 0.0 558.77 this facrlity (est) Naphthalene No specific authorizations for 0.0 558.77 this faCIlity (est) Peroxide, organic No specific authorizations for 0.0 1396.92 ?35 this fac1 ity (est) No specific emissions authorizations for 0 3073.23 1,2,4? this facility (est) Unspeciated VOCs No specific authorizations for 0.0 349231 ?35 this faculty (est) tert-butyl alcohol No specific authorizations for 0-0 2793.85 ?35 this faculty (est) Source 3: Wastewater Treatment Plant FIN number No other sources Return to search form Air subjects Region contact information 30 TAC air Ciualitv rulesmi ?Air emiSSionS eventS/ maintenance aC?VitV . 2{2 10/24/2017 1% Q. Texas Air Emission Event Report SITE SEARCH: please enter search phrase SUBJECTINDEX Water Waste Search TCEQ Data Agency Organization Map Air Emission Event Reporting Data]: ommission on Environmen?al Oualitv Regulated entity name ARKEMA CROSBY PLANT Physical location Regulated entity RN number RN100210301 City, County CROSBY, HARRIS Type(s) of air emissions event: EMISSIONS EVENT Event began: 08/31/2017 This is based on the: FINAL REPORT Event ended: 08/31/2017 Cause Due to inclement weather conditions associated with Hurricane Harvey, the plant accumulated an unprecedented six (6) to eight (8) feet of water within the facility. Arkema?s investigation to date indicates that as the water level continued to rise within the plant over the course of several days, the plant was unable to use its primary power, its emergency backup power, and later its nitrogen cooling system. As a result, plant personnel removed the containers of organic peroxides from storage and placed them in refrigerated trailers. Ultimately, the refrigeration of the organic peroxide products in the trailer involved in this emissions event was also compromised by the flood waters, which led to product decomposition, ignition and a subsequent fire. Ac?on taken As agreed with the TCEQ, EPA, and Harris County Pollution Control, and due to the instability of the products in the absence of refrigeration and safety concerns of trying to fight a fire of this nature, the trailer and products were allowed to burn to completion. This event was beyond Arkema's reasonable control, and Arkema Inc. closely coordinated the response to this event with the local, state, and national authorities. Precautionary evacuations were implemented as part of the unified command response plan. Emissions estimation method Engineering estimates were based on known quantities of organic peroxide products stored in the trailer, product packaging, and the trailer construction materials, USEPA and TCEQ emission factors, and expected decomposition products.P ease note the following is additional information regarding the list of air contaminants compounds: VOC- remainder reflects Naphtha (petroleum), hydrotreated heavy, Naphtha (petroleum), heavy alkylate, and VOC emissions from diesel fuel combustion? 1,699.49 lbs. For particulate matter: PM- 1,014.45, PM10- 1,014.54 lbs., and PM2.5- 1,014.54 lbs. 1/3 1012432017 if ii I Source 1: Refrig.Trailer storing organic peroxide Bldg. 21, EPN Air Emission Event Report number Contaminant Authorization Limit Amount Released No-specific emissions authorizations for this 0.0 527.41 faCility (est.) Acetone No-s-pecific emissions authorizations for this 0.0 284.84 faculty (est.) Acetophenone No-speCIfic emi55ions authorizations for this 0.0 1376.21 faculty (est.) Carbon No specific emissions authorizations for this 1589.46 . . . 0.0 MonOXIde fac1lity (est.) Ethane Nospecrfic authorizations for this 0.0 23.0 (est.) fac1lity Nitrogen authorizations for this 0.0 98.76 (est.) faCIlity Nonane Nos-pacific emissions authorizations for this 0.0 1573.6 faCIlity (est.) Nonene Nospecific emissions authorizations for this 0.0 518.76 faCIlity (est.) Particulate No specific emissions authorizations for this 3043.53 . . 0.0 Matter faCIlity (est.) Sulfur dioxide No'specmc authorizations for this 0.0 1.78 (est.) fac1 ity Unspeciated No specific emissions authorizations for this 0 0 3270.18 VOCs facility (est.) Source 2: Refrig.Trailer storing organic peroxide Bldg. 21, FIN numb er Source 3: Refrig.Trailer storing organic peroxide Bldg. 21, FIN numb er No other sources Air subjects ??ow rates" searcnrorm ReCIion contact information 213 1 0/24/201 7 scan. Texas Commission on Environmen Air Emission Event Report SITE SEARCH: please enter search phrase SUBJECT INDEX Water Waste Search TCE Data Aqency Organization Map Air Emission Event Reporting Data]: 'al Duality Regulated entity name ARKEMA CROSBY PLANT Physical location Regulated entity RN number RN100210301 City, County CROSBY, HARRIS Type(s) of air emissions event: EMISSIONS EVENT Event began: 09/01/2017 This is based on the: FINAL REPORT Event ended: 09/01/2017 Cause Due to inclement weather conditions associated with Hurricane Harvey, the plant accumulated an unprecedented six (6) to eight (8) feet of water within the facility. Arkema?s investigation to date indicates that as the water level continued to rise within the plant over the course of several days, the plant was unable to use its primary power, its emergency backup power, and later its nitrogen cooling system. As a result, plant personnel removed the containers of organic peroxides from storage and placed them in refrigerated trailers. Ultimately, the refrigeration of the organic peroxide products in the two trailers involved in this emissions event was also compromised by the flood waters, which led to product decomposition, ignition and a subsequent fire. Ac?on taken As agreed with the TCEQ, EPA, and Harris County Pollution Control, and due to the instability of the products in the absence of refrigeration and safety concerns of trying to fight a fire of this nature, the trailers and products were allowed to burn to completion. This event was beyond Arkema's reasonable control, and Arkema Inc. closely coordinated the response to this event with the local, state, and national authorities. Precautionary evacuations were implemented as part of the unified command response plan. Emissions estimation method ?inform?a'tio ?g'a?r?d ingt BF f' a i'l?WCO?'tEi'??ii ?El?l?lT?S? Engineering estimates were based on known quantities of organic peroxide products stored in the trailers, product packaging, and the trailer construction materials, USEPA and TCEQ emission factors, and expected decomposition products.Please note the following additional unspeciated: OMS- 932.44 lbs. and the remainder reflects Naphtha (petroleum), hydrotreated heavy, Naphtha (petroleum), heavy alkylate, and VOC emissions from combustion? 2,021.54 lbs. For 113 1 0724901 7 Air Emission Event Report particulate matter: PM- 1,407.47 PM10- 1407.63 lbs., and PM2.5- 1,407.63 lbs. Source 1: 2-Refrg.Trailrs storing organic peroxide B1dg.27, EPN number Contaminant Authorization Limit Amount Released No specific authorizations for 0.0 301.38 this faCIlity (est) 2? No specific emissions authorizations for 0 0 98.13 the facility (est) Acetone No specific emissions authorizations for 0-0 752.32 this faCIlity (est) Acetophenone No specific authorizations for 0.0 654.81 this faCIlity (est) 4. \arbon Monoxide No specific authorizations for 00 2059.54 5 this faculty (est) Ethane No specific emISSIons authorizations for 0.0 23.0 (est) this faculty itrogen dioxide No specific authorizations for 0.0 110.65 this faCility (est) Nonane No specific emissions authorizations for 0.0 1770.34 this fac1lity (est) Nonene No specific emissions authorizations for 0-0 582.02 this faCIlity (est) Particulate No specific emissions authorizations for 0 0 4222.73 Matter this facility (est) Sulfur dioxide No specific emISSions authorizations for 0.0 3.55 (est) this Unspeciated No specific emissions authorizations for 0 0 2953.98 VOCs this facility (est) Source 2: 2?Refrg.Trailrs storing organic peroxide Bldg.27, FIN number numb?"er? No other sources Source 3? 2Re??gTra?rS storlngorgamcperomde Bldg27 FIN 2I3 . 10r24i?2017 a EEQEQ. Texas fiommission on Environmen'al Quality Air Emission Event Report SITE SEARCH: please enter search phrase SUBJECT INDEX Water Waste Search TCE Data Aqency Organization Map Air Emission Event Reporting Data]: Regulated entity name ARKEMA CROSBY PLANT Physical location Regulated entity RN number RN 100210301 City, County CROSBY, HARRIS Type(s) of air emissions event: EMISSIONS EVENT Event began: 09/03/2017 This is based on the: FINAL REPORT Event ended: 09/03/2017 Cause Due to inclement weather conditions associated with Hurricane Harvey, the plant accumulated an unprecedented six (6) to eight (8) feet of water within the facility. Arkema?s investigation to date indicates that as the water level continued to rise within the plant over the course of several days, the plant was unable to use its primary power, its emergency backup power, and later its nitrogen cooling system. As a result, plant personnel removed the containers of organic peroxides from storage and placed them in refrigerated trailers. Ultimately, the refrigeration of the organic peroxide products in the six trailers involved in this emissions event was also compromised by the flood waters, which led to product decomposition. In this specific event and in coordination with federal, state and local authorities, a controlled ignition of the trailers and fire occurred. Ac?on taken As agreed with the TCEQ, EPA, and Harris County Pollution Control, and due to the instability of the products in the absence of refrigeration and safety concerns of trying to fight a fire of this nature, the trailers and products were allowed to burn to completion. This event was beyond Arkema's reasonable control, and Arkema Inc. closely coordinated the response to this event with the local, state, and national authorities. Precautionary evacuations were implemented as part of the unified command response plan. Emissions estimation method 'EX'p'E'Cte?d?d e?c'o?m p'OS'iti ?p'I'Od Please "l?i'O'tE there I 'n?g a dd lti'O?h'?'l "m Engineering estimates were based on known quantities of organic peroxide products stored in the trailers, product packaging, and the trailer construction materials, USEPA and TCEQ emission factors, and information regarding the list of air contaminants compounds: VOC- unspeciated: n-propanal- 20.72 lbs., sec?butanol? 93.51 lbs., sec- butanone- 30.32 lbs, OMS- 1, 342.10 lbs, and the remainder reflects Naphtha (petroleum), hydrotreated heavy and Naphtha (petroleum), .tceq .texas. govfocefeeriindex. cfm?fuseaction= ?main 113 It I (1 0i24i20? 7 lbs. Air Emission Event Report heavy alkylate and combustion products- 6,046.53 lbs. For particulate matter: PM- 4,304.58 lbs., PM10- 4,304.58 lbs., and 4,304.58 Source 1: 6-Refrg.Tra1rs storing organic peroxide-behind MPU, EPN number Contaminant Authorization Limit Amount Released No specific emissions authorizations for 0-0 1458.89 this faCIlity (est.) 2- No specific emissions authorizations for 0 0 475.0 this facility (est.) Acetone No Specific emissions authorizations for 0.0 111759 this faCIlity (est.) Acetophenone No specific authorizations for 0.0 641.86 this faCIlity (est.) Carbon Monoxide No specific emissions authorizations for 0-0 6333.98 this faculty (est.) Ethane No specific authorizations for 0.0 14.7 (est.) - this faCIlity Isobutane No specific emissions authorizations for 0.0 242.0 - this faCIlity (est.) Isobutene Specific emissions authorizations for 0.0 77.87 this faCIlity (est.) Nitrogen dioxide No specific authorizations for 0.0 344.75 this faCIlity (est.) Nonane No specific emissions authorizations for 00 1830.98 this faCIlity (est.) Nonene No specific emissions authorizations for 0.0 601.89 ?35 this faCIlity (est.) Particulate No specific emissions authorizations for 0 0 12913.74 Matter this facility (est.) Unspeciated No specific emissions authorizations for 0 0 7533.18 VOCs this facility (est.) No specific emissions authorizations for 64.32 prepanol this facility 0'0 (est.) Source 2: 6-Refrg.Tralrs storing organic peroxide-behind MPU, FIN number