Tennessee Division of Air Pollution Control (DAPC) Facilities Permits Inspections Complaints eDocuments Parent Site NameSite LocationCountyEFOLatitudeLongitude Tennessee Operations of Eastman Chemical Company200 South Wilcox DriveSullivanJohnson City36.523518-82.543572 COMPLAINT Help Back to Previous Page Complaint Number129454DivisionAPCDate ReceivedNOV-13-2023How ReceivedOther AgencyConcerningOtherConcerning (Other)emissionsAssigned DateNOV-13-2023Site ID4873Facility ID Location based on SITE_ID Site ID 4873 Site Tennessee Operations of Eastman Chemical Company Location 200 South Wilcox Drive City Kingsport Description Industrial Organic Chemicals, NEC County Sullivan EFO Name Johnson City Site Owner Eastman Chemical Company Investigation Results Date InvestigatedNOV-17-2023StatusNOVStatus DetailResponsible PartyDate CompletedJAN-03-2024Referred ToDate ReferredLast updatedJAN-03-2024 Complaint Description and Writeup ACME Mapper Complaint Description and Writeup11/13/2023: EPA Region IV received a complaint/tip on 11/10/2023 (CAA_FY24-285842-3714). The complaint/tip was as follows: "H2S in unknown amounts being vented to atmosphere at these exact coordinates 36.51380° N, 82.54376° W".11/17/2023: MLH conducted a site investigation at Eastman Chemical Co. Upon arrival at 8:00 AM EST, MLH met with Sharon Wellman, Tracy Venett, Matt Fourspring, and Brent Hayes to discuss the nature of the complaint. The coordinates were provided and the location was identified as PES B-331-1 (Production of Synthesis Gas), part of Major Source Operating Permit (MSOP) 17 Permit 572407. A facility tour was conducted following the initial meeting. During the facility tour, it was noted that the biofilter (permitted primary control) was out of service and the caustic scrubber (permitted during biofilter maintenance) associated with Vent ID F was in service. The ducting to the biofilter was observed disconnected. No H2S odors were noted during this time. Following the facility tour discussions with Eastman personnel regarding the change in control equipment was discussed. In February of 2023 an off-gas sample taken from the 12C-1022 biofilter outlet indicated that the biofilter was not controlling VOC or H2S emissions at 99% efficiency as permitted. In response, Eastman began measures to start up the back up 12C-20 caustic scrubber and began troubleshooting the biofilter. In April 2023, Eastman Personnel began detecting H2S by olfactory means. An investigation revealed that that butterfly valve on the outlet of the caustic scrubber was in the closed position due to a broken stem. As a result it was likely that no gas was pulled through the scrubber from 2/20/2023 until 4/14/2023 when the butterfly valve was repaired. The events that occurred between February and April 2023 were reported to the Division by 24-hour prompt notifications and in the Semiannual Report (SAR) covering 1/1/2023 - 6/30/2023. A notice of violation was issued by the Division on 10/4/2023 addressing these events.In preparation for the complaint investigation MLH identified a change in the primary control equipment at PES B-331-1 which removed the 12C-1022 biofilter from the permit renewal application (submitted on 5/19/2023) and replaced the biofilter with the 12C-20 caustic scrubber as primary control. This change indicated a reduction in control efficiency from 99% (biofilter) to 80% (caustic scrubber) which increased the calculated H2S emissions from 0.69 tons/yr to 1.87 tons/yr. These changes were discussed with Eastman personnel during the complaint investigation. Sharon Wellman stated that these calculations were provided in the renewal application based on conservative assumptions without sufficient information to support a more accurate control efficiency. Eastman believes the control efficiency is > 99% based on weekly off gas samples taken. Following the first off-gas sample taken in February 2023 that identified a decrease in biofilter control efficiency, the facility has taken weekly samples of the outlet vent gas and records indicated that 0 ppm of H2S was analyzed from the weekly samples between 4/18/2023 and 11/14/2023. It was also noted that an off gas sample was taken on 11/10/2023 (date of complaint received by EPA Region 4) and the resulting concentration of H2S in the sample was indicated in records reviewed as 0 ppm.MLH requested maintenance records for the 12C-1022 biofilter, K2 blower, and 12C-20 caustic scrubber from 2/1/2023 - 11/16/2023, off gas sample analysis from 2/14/2023 - 11/16/2023, and the lab analysis from the 11/10/2023 off gas sample. 11/21/2023: MLH requested additional information via email with a due date of 11/30/2023.11/30/2023: Additional information received by MLH from Sharon Wellman.1/2/2024: Notice of Violation issued to the facility for failure to notify the Division of a change in air pollution control equipment.
     Tennessee Division of Air Pollution Control (DAPC)