During its inspection, EPA contracted Providence Photonics, LLC to use their Video Imaging Spectral Radiometry (VISR) method to determine the combustion efficiency (CE) of the North Side Flare (NSF) and South Side Flare (SSF), determined to be 75.1% and 95.5%, respectively, in violation of 85% required by the Ohio SIP and 98% required by its permit. Through the 114 Request for Information, EPA learned that Kraton was not monitoring steam flow in conformance with its design, in violation of 40 C.F.R. Subpart A and H. A CAFO is being issued concurrently.
This ACO requires Kraton Corporation to:
? continue operating the Injunctive Relief (IR) it has installed (consisting of control valves, flow meters, supplemental natural gas line, programming to control steam and measure and target a Net Heating Value in the Combustion Zone (NHVcz) of 270 btu/scf);
? continue monitoring NHVcz at the North and South Side Flares in accordance with the developed monitoring scheme to determine and report deviations from 270 btu/scf; and
? submit a permit application to Ohio EPA incorporating the upgraded equipment, monitoring, recordkeeping and reporting into a new permit.