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Home My WebLink AboutDAQ-2024-012067Chad Gilgen <cgilgen@utah.gov> Scrubber Pressure Drop 8 messages Chad Gilgen <cgilgen@utah.gov>Wed, Nov 27, 2024 at 12:34 PM To: Dave Lindsey <Dave.Lindsey@tchem.com> Hello Dave, I was recently contacted by a colleague in DWMRC regarding some observations related to DAQ Approval Order DAQE- AN103820013-23 (copy attached) during a recent inspection. Records viewed during this inspection noted the pressure drop associated with AO condition II.A.4 - Hydrochloric Acid Drumming EPA ID #3 were less than 0.4 inches of water column on November 4, 5, 6, 7, 11, and 13, 2024. Please review these logs and let me know how long this pressure drop has been below the 0.4 inches of water column required by AO condition II.A.4. Thanks and please let me know if you have any questions. Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. DAQE-AN103820013-23.pdf 325K Dave Lindsey <Dave.Lindsey@tchem.com>Mon, Dec 2, 2024 at 6:31 AM To: Chad Gilgen <cgilgen@utah.gov> Good morning Chad, I just got back from the holiday and I will check into this issue. I should have a response later today. David S. Lindsey Thatcher Group 801-972-4587 dave.lindsey@tchem.com [Quoted text hidden] The information contained in this e-mail message, and any attachments to it, contain confidential, proprietary, privileged, or otherwise secret information. If you are not the intended recipient, or believe that you may have received this email or attachments in error, any dissemination, use, review, distribution, printing or copying of the information contained in this e- mail message and any attachments to it are strictly prohibited. If you have received this communication in error, please 12/17/24, 4:03 PM State of Utah Mail - Scrubber Pressure Drop https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-a:r-8650805236755186716&simpl=msg-a:r-39670315763686…1/5 REVIEWEDInitials: CG Date: 12-17-24 Compliance Status: Scrubber information request - In compliance File # 10382 (B1) notify us by reply e-mail or telephone and immediately and permanently delete the message and any attachments. Please include in your notice that the message and any attachments have been deleted. Thank you. Dave Lindsey <Dave.Lindsey@tchem.com>Mon, Dec 2, 2024 at 4:13 PM To: Chad Gilgen <cgilgen@utah.gov> Hi Chad, First of all I wanted to let you know I went out and inspected the scrubber in question. It is reading 0.9 on the manometer for the pressure drop. The person who filled out the log showing the pressure drop below the >0.4 requirement associated with AO condition II.A.4 called in sick today. I want to find out why they noted this number below the AO condition. This is a new employee and may not be reading the gage correctly. This should be a quick investigation once I talk to this employee. I’m sorry I don’t have much more than this to give you. I have a surgical procedure tomorrow and will be back in the office on Wednesday. Thanks for your patience. David S. Lindsey Thatcher Group 801-972-4587 dave.lindsey@tchem.com From: Dave Lindsey <Dave.Lindsey@tchem.com> Sent: Monday, December 2, 2024 2:30 PM To: Dave Lindsey <Dave.Lindsey@tchem.com> Subject: RE: Scrubber Pressure Drop Hi Chad, The person who filled out the log showing the pressure drop below the >0.4 requirement associated with AO condition II.A.4 called in sick today. I want to find out why they noted this number below the AO condition. This is a new employee and may not be reading the gage correctly. This should be a quick investigation once I talk to this employee. I’m sorry I don’t have much more than this to give you. I have a surgical procedure tomorrow and will be back in he office on Wednesday. Thanks for your patience. David S. Lindsey Thatcher Group 801-972-4587 12/17/24, 4:03 PM State of Utah Mail - Scrubber Pressure Drop https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-a:r-8650805236755186716&simpl=msg-a:r-39670315763686…2/5 dave.lindsey@tchem.com [Quoted text hidden] [Quoted text hidden] Dave Lindsey <Dave.Lindsey@tchem.com>Mon, Dec 2, 2024 at 4:24 PM To: Chad Gilgen <cgilgen@utah.gov> [Quoted text hidden] Dave Lindsey <Dave.Lindsey@tchem.com>Wed, Dec 4, 2024 at 4:03 PM To: Chad Gilgen <cgilgen@utah.gov> Chad, I’m sorry I haven’t been able to put together a response today. I will make it a first priority tomorrow. Again, thanks for your patience [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] Chad Gilgen <cgilgen@utah.gov>Wed, Dec 4, 2024 at 4:05 PM To: Dave Lindsey <Dave.Lindsey@tchem.com> Hi Dave, Thanks for the updates. I appreciate it and will look forward to your report. Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] 12/17/24, 4:03 PM State of Utah Mail - Scrubber Pressure Drop https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-a:r-8650805236755186716&simpl=msg-a:r-39670315763686…3/5 ~WRD0004.jpg 1K Dave Lindsey <Dave.Lindsey@tchem.com>Thu, Dec 5, 2024 at 2:24 PM To: Chad Gilgen <cgilgen@utah.gov> Hi Chad, I want to be clear that we never had an HCL release from II.A.4 – the Hydrochloric Acid Drumming scrubber during the time the pressure drop was reading blow the 0.4 condition. As a reminder, we have several HCL sensor throughout this area and none of them have been tripped by an HCL release. The sensors alarm at 5ppm. Talking to the area manager about the scrubbers functionality, he noted the scrubber had been working without any problems. And even the low pressure drop didn’t lead to a malfunction of the scrubber operation, i.e. a release. We found a fiberglass cap, which supports one end of the recirculation spray bar for the scrubbing solution, had come off and was pulling ambient air into the scrubber. This caused the pressure to drop in the scrubber. It was repaired 11/27/25, the day I received your original email. The manometer on the scrubber is now consistently reading well above the 0.4 condition. Every condition of II.A.4 is currently being met as required by the AO. After reviewing the logs it appears that the low readings started the first part of August this year. I talked to the employee in question and was told she didn’t know or understand that if she saw the gauge reading below the 0.4 condition to report it to her supervisor. I am currently working with the operations supervisor to make sure these conditions are fully understood by all involved employees. We are in the process of changing our training regarding the scrubber systems and creating double check sign-offs by the area managers. This will identify any problems with our documentation and help address any necessary changes immediately. Our engineering team is working on creating a redundancy which will be tied into a monitoring system. This will letting us know immediately any aberration outside our scrubbers AO conditional guidelines. I hope this helps. Please let me know if you have any questions or requests. V/R David S. Lindsey Thatcher Group 801-972-4587 12/17/24, 4:03 PM State of Utah Mail - Scrubber Pressure Drop https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-a:r-8650805236755186716&simpl=msg-a:r-39670315763686…4/5 dave.lindsey@tchem.com [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] Chad Gilgen <cgilgen@utah.gov>Tue, Dec 17, 2024 at 11:09 AM To: Dave Lindsey <Dave.Lindsey@tchem.com> Hello Dave, Thanks for looking into the matter and providing this detailed response. I concur with your assessment and the steps taken to investigate and remedy the situation. Thanks again, Chad Chad Gilgen | Manager | Minor Source Compliance 385-306-6500 (cell) Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements. [Quoted text hidden] image001.jpg 1K 12/17/24, 4:03 PM State of Utah Mail - Scrubber Pressure Drop https://mail.google.com/mail/u/0/?ik=36f4379b4d&view=pt&search=all&permthid=thread-a:r-8650805236755186716&simpl=msg-a:r-39670315763686…5/5