Document 15Yq0BjqGeeNmJVLE2ypVDeRo

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Intertape Polymer Group, Marysville, Michigan Erin DuMontelle, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Intertape Polymer Group Facility Location: 317 Kendall Avenue, Marysville, MI 48040 Date of Inspection: June 28, 2023 EPA Inspector(s): 1. Erin DuMontelle, Environmental Engineer 2. Veronica Fischer, Environmental Engineer 3. Natalie Schulz, Environmental Engineer Other Attendees: 1. Jonathan Seals, EHS Manager 2. Steve Matthews, Coating Manufacturing Manager 3. John Fortsch, Process Engineer 4. Sebastian Kallumkal, Michigan Dept. of Environment, Great Lakes and Energy Contact Email Address: Jonathan Seals, jseals@itape.com Purpose of Inspection: to perform an inspection of coating operations for toluene emissions and to inspect for 112(r) applicability or General Duty Clause applicability due to a recent incident at the facility Facility Type: Adhesive Tape Manufacturing Regulations Central to Inspection: 40 C.F.R. Part 63 Subpart JJJJ - National Emissions Standards for Hazardous Air Pollutants: Paper and Other Web Coating and 40 C.F.R. Part 63 Facility Name: Intertape Polymer Group Facility Location: 317 Kendall Avenue, Marysville, MI 48040 Date of Inspection: June 28, 2023 Subpart HHHHH - National Emission Standards for Hazardous Air Pollutants: Miscellaneous Coating Manufacturing Arrival Time: 8:30 AM EST Departure Time: 1:45 PM EST Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility The following information was obtained verbally from Jonathan Seals, Steve Matthews, or John Fortsch unless otherwise noted. Company Ownership: The corporation was bought out by Clearlake Capital Group in 2022, but the facility still operates as Intertape Polymer Group. Process Description: Intertape Polymer Group (the facility) makes adhesives tapes of varying strengths. The adhesives are prepared from raw materials that are brought on site by truck. Toluene is unloaded into one of two underground storage tanks (UST). 1. The Adhesive The adhesives are made in batches. Approximately sixty percent of adhesives start with a batching sheet in the Dry Mix area. The batching sheet provides the "recipe" which is a mix of dry powders and natural rubber. The material is loaded into a Banbury mixer that acts as a dough mixer and relies on the natural breakdown of the rubber to create the dough. Once mixed, the dough is sent through a chilled mill and pressed. The chilled dough is cut into strips and placed on to carts of layered drying mats. These mats store the rubber leaflets until they are sent to the Wet Mix area. In the Wet Mix area, the drying mats are rolled to the mixing stations. There are three stations which are located seven to eight feet above ground level: Mixer #4, Mixer #5, and Mixer #6. Following the batching sheet, the dry ingredients are added to the mixer by weight, then there is a nitrogen purge before the toluene is hard piped into the mixer. A nitrogen blanket is placed over the materials for safety. The mixers are steam heated up to 85oF, and the leaflets break down in a chemical reaction. The mixture is sent to a churn to mix for alloted amount of time to further process before being emptied into a tote; Churn #4, Churn #5, and Churn #6. Emissions from the mixers and churns are routed to condensers before being exhausted to atmosphere. The other thirty percent of the adhesives are mixed in the Wet Mix area in Churn #3. Man-made chipped rubber is added into Churn #3, and then toluene is hard-piped in. A CO2 blanket is added manually by placing a block of dry ice over the shoot. The mixture is churned for a set length of time, depending on the batch before it is screened and added to a tote. Page 2 of 11 Facility Name: Intertape Polymer Group Facility Location: 317 Kendall Avenue, Marysville, MI 48040 Date of Inspection: June 28, 2023 All totes are moved from the Wet Mix area to the Whip Room by forklift. Totes are color-coded into three categories: Topcoat, Base Coat, and Churn #3. These totes can hold any adhesive within their category. The Whip Room acts as a staging and mixing area. About a third of the natural rubber totes are combined with curing additives at either the East or West Curing station. The ready totes are loaded onto platforms and connected so that they are hard piped to the coating lines. Once the totes have been emptied, they are moved to a cleaning station where a recirculation tank of toluene is used to dissolve and flush out the residual adhesive; the cleaning station is not connected to a control device. The solids are seperated and sent out as hazardous waste. The toluene completes approximately 20 wash cycles before needing to be replaced. 2. The Coating Lines The adhesive from the tanks that is hard piped to the coating lines goes to one of three separate lines: Line 1, Line 4, and Line 3. Line 1 and Line 4 are in the room next to the Whip Room; Line 3 is in one room further. Lines are set up with a master roll at the beginning. At the beginning of each line, a water-based release agent is added. Line 1 and Line 4 have two units for adding adhesive: A Unit adds the base coat, and B Unit adds the topcoat. Line 3 has three units for adding adhesives: A Unit, B Unit, and C Unit. Each unit contains a coating area and an oven. The ovens are kept at approximately 240 - 400 F. The coating areas are vented to the Solvent Recovery System (SRS) onsite, and emissions from the final ovens of each line are sent solely to the Regenerative Thermal Oxidizer (RTO). When units run water-based adhesives, the SRS connection is shut off. The rolls reach the end of the line and are rewound and sent to the packaging area. They are place onto slitting machines. There are four automatic slitters and one lathe slitter. There are no dust controls on the slitters, but most of the machining is enclosed for safety and sound hazard reduction. The final rolls are boxed up by either the machine or by hand and then sent to warehousing before being shipped off site. 3. The Solvent Recovery System The emissions of Solvent Laden Air (SLA) from Units A and B of Line 1, Units A and B of Line 4, and Units 2, 3, and 4 of Line 3 are collected and transferred via 72" diameter ducting to the SRS. There is continuous monitoring on the SLA inlet and outlet. The SLA is pushed to the SRS holding tank before being pushed by underground absorbers to four carbon absorbers. Three of the absorbers accept air while the fourth removes buildup. The toluene that is stuck to the carbon is removed by steam that comes from a 30,000 mmBTU boiler. Liquid created from the condensing of the steam and toluene mix is sent to a decanter. The decanter separates the less dense toluene from the denser condensate; the toluene is sent back to the process while the steam is reheated into steam to use in the absorbers. 4. Other The facility also has two pilot lines on site used for research and development. There is also a small spray booth onsite that is used on very rare occasions. Staff Interview: The facility has approximately 240 employees and operated 24 hours / 5 days per week. Each year, there is a scheduled shutdown for large repairs and projects. The facility is approximately 70 years old. The facility ships some of the adhesive that is made within Mixer #6 and Churn #6 to other facilities; this operation is subject to NESHAP HHHHH. There is a CO2 suppression Page 3 of 11 Facility Name: Intertape Polymer Group Facility Location: 317 Kendall Avenue, Marysville, MI 48040 Date of Inspection: June 28, 2023 system on site and alarms are tested on the first Wednesday of each month. The facility manages leak detection with visual and olfactory observations; there are continuous LEL monitors at the load ends of the coaters and the wet mix area. The facility also has personal monitors that are used during non-routine work. The facility has a tank of isopropyl alcohol on site that is used as an alternative releasing agent. There are also two 20,000-gallon USTs for storing toluene. There are weekly additions to the toluene USTs. There was a flash fire incident that occurred on Thursday, October 13, 2022. According to facility representatives, an employee had added the required dry material. Upon the addition of toluene, the material became clumped and would no longer mix; this forced a system shutdown of the process. During that shutdown, a radio fell into the open vessel. In trying to remove the radio, a spark ignited, and a flash fire occurred. The investigation by MIOSHA was still on-going at the time of EPA's inspection. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: The tour started with the Dry Mix area where the batch sheet was reviewed for the materials that were staged. The dust collection system had a bucket to catch the dust. In the Wet Mix area, Mixer #6 was actively being loaded. Resin was being added per the reviewed batch sheet. It smelled strongly of toluene next to the mixer and the intensity of the smell grew with proximity to the churns. Emissions were seen coming from the mixer and churns using an Optical Gas Imaging (OGI) camera. Mixer #5 was down for maintenance. Mixer #4 was at the stage of adding the rubber leaflets to the mixer. Dust was seen exiting the opening of the mixer while waiting for the leaflets to be brought from the Dry Mix area. It was noted by IPG that normally there is one operator that runs Mixer #6 and one operator that runs Mixer#4 and Mixer #5. In the Whip Room, the totes that were observed at the curing station and the cleaning station were open. The bay doors in the Whip Room and the rooms that contain the coating lines were open. Walked down Lines 1, 4, and 3. Line 3 was stated as being 190 yards in length. The static pressure of the line 3 fans was between 0" and 3.75". The RTO display showed that it was running at 1474oF to 1458oF across the media beds. The temperatures fluctuated while the inspectors were looking at it and went as low as 1438oF on the RTO panel. A VOC plume of emissions was seen coming from the RTO using the OGI camera. The SRS was walked down, and OGI footage was taken of the absorber tanks. Footage was also taken of the manways of the underground storage tanks. Building 46 contains one of the pilot lines and the spray both, neither of which were in use. IPG stated that the pilot line is hooked up to the RTO The second pilot line was also off, but it was noted that this line does not use toluene. All of the splitters were also shutoff due to the tour being at lunch time. It was noted that the weather outside included blue skies and sunshine with a light breeze at the end of the inspection. Photos and/or Videos: were taken during the inspection. Footage was captured with an Optical Gas Imaging camera. Page 4 of 11 Facility Name: Intertape Polymer Group Facility Location: 317 Kendall Avenue, Marysville, MI 48040 Date of Inspection: June 28, 2023 RECORDS REVIEW 1. Batching Sheet for "Dry Stock" that was staged to be mixed. 2. Batching Sheet from batch being mixed into Mixer #6 CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: 1. A facility flow diagram that includes all process equipment, including the solvent recovery system (SRS), and pollution control equipment 2. Average number of batches of adhesive mixed and applied per day 3. The VOC records from the past three months AND June 1st through August 31st for the years 2020, 2021, and 2022 4. The Daily Usage Logs for adhesive on the three coating lines for the month of May 2023 5. RTO Temperature Logs from the last three months AND June 1st through August 31st for the years 2020, 2021, and 2022 6. Condenser Temperature and Flow Logs as required by the MCM MACT from the last three months AND June 1st through August 31st for the years 2020, 2021, and 2022. 7. The Capture System Monitoring Plan per 40 C.F.R. Part 63.3350(f) for JJJJ compliance 8. Semi-annual reports for the MCM MACT and the POWC MACT for the years 2018 through 2022 9. NOCS submitted under the MCM MACT and POWC MACT 10. The most recent stack test results for the RTO 11. The initial performance test results for the RTO 12. The date of install for the RTO 13. The most recent performance test results for the SRS capture and control 14. The date of install for the SRS 15. The latest purity test results for the collected toluene from the SRS 16. The facility's original Title V Permit 17. The facility's current Title V Permit 18. The facility's last 10 years of construction permits and applications sent to the State 19. Calculations for facility-wide annual emissions 20. Calculations for capture efficiency 21. Calculations for condenser efficiency 22. Calculations for the daily SRS efficiency 23. Calculations for the RTO destruction efficiency 24. Calculations of emissions created and solvent recovery during tote washing 25. Calculations for the amount of toluene remaining in the product prior to being slit and packaged 26. Any other calculations performed by the facility to demonstrate compliance with JJJJ if not already included in the semi-annual report 27. The Receiving Logs for Toluene brough onsite from January 1st, 2020 through June 1st 2023 28. The SDS for the toluene onsite 29. Leak detection and repair logs for 2021, 2022, and January through June 2023 30. The facility's Risk Management Plan Page 5 of 11 Facility Name: Intertape Polymer Group Facility Location: 317 Kendall Avenue, Marysville, MI 48040 Date of Inspection: June 28, 2023 Concerns: Emissions were seen with the OGI camera around the facility which included: the mixers, the churns, the open totes in the WHIP Room, along areas of adhesive application for the coating lines, the outlet of Line 3, the RTO, the vents on the absorbers, and from the manways on the underground storage tanks. DIGITAL SIGNATURES Digitally signed by ERIN DUMONTELLE Date: 2023.08.22 10:45:33 Report Author: _________________-_0_5'0_0_' ____________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL _M__A__R__S_H__A__L_L_____-0_5_'0_0'_____________ Date: 2023.08.22 13:54:28 Page 6 of 11 Facility Name: Intertape Polymer Group Facility Location: 317 Kendall Avenue, Marysville, MI 48040 Date of Inspection: June 28, 2023 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log Page 7 of 11 Facility Name: Intertape Polymer Group Facility Location: 317 Kendall Avenue, Marysville, MI 48040 Date of Inspection: June 28, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Veronica Fischer 2. Archival Record Location: Region 5 Electronic Record Center Image Number 1 File Name IR_2976.jpg 2 DC_2977.jpg 3 IR_2978.jpg 4 DC_2979.jpg 5 IR_2980.jpg 6 DC_2981.jpg 7 MOV_2982.mp4 8 MOV_2983.mp4 9 DC_2984.jpg 10 MOV_2985.mp4 11 DC_2986.jpg 12 MOV_2987.mp4 13 DC_2988.jpg 14 MOV_2989.mp4 15 DC_2990.jpg 16 MOV_2991.mp4 17 DC_2992.jpg 18 MOV_2993.mp4 Date and Time (CST) 6/28/2023 9:00 AM 6/28/2023 9:00 AM 6/28/2023 9:00 AM 6/28/2023 9:00 AM 6/28/2023 9:03 AM 6/28/2023 9:03 AM 6/28/2023 9:04 AM 6/28/2023 9:06 AM 6/28/2023 9:06 AM 6/28/2023 9:08 AM 6/28/2023 9:08 AM 6/28/2023 9:09 AM 6/28/2023 9:09 AM 6/28/2023 9:11 AM 6/28/2023 9:11 AM 6/28/2023 9:13 AM 6/28/2023 9:13 AM 6/28/2023 9:14 AM Description of Image Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Page 8 of 11 19 DC_2994.jpg 20 MOV_2995.mp4 21 DC_2996.jpg 22 MOV_2997.mp4 23 MOV_2998.mp4 24 MOV_2999.mp4 25 DC_3000.jpg 26 MOV_3001.mp4 27 DC_3002.jpg 28 MOV_3003.mp4 29 DC_3004.jpg 30 MOV_3005.mp4 31 DC_3006.jpg 32 MOV_3007.mp4 33 DC_3008.jpg 34 MOV_3009.mp4 35 DC_3010.jpg 36 MOV_3011.pm4 37 DC_3012.jpg 38 MOV_3013.mp4 39 DC_3014.jpg 40 MOV_3015.mp4 Facility Name: Intertape Polymer Group Facility Location: 317 Kendall Avenue, Marysville, MI 48040 Date of Inspection: June 28, 2023 6/28/2023 9:14 AM 6/28/2023 9:16 AM 6/28/2023 9:16 AM 6/28/2023 9:18 AM 6/28/2023 9:21 AM 6/28/2023 9:24 AM 6/28/2023 9:24 AM 6/28/2023 9:26 AM 6/28/2023 9:26 AM 6/28/2023 9:30 AM 6/28/2023 9:30 AM 6/28/2023 9:31 AM 6/28/2023 9:31 AM 6/28/2023 9:32 AM 6/28/2023 9:32 AM 6/28/2023 9:38 AM 6/28/2023 9:38 AM 6/28/2023 9:40 AM 6/28/2023 9:40 AM 6/28/2023 9:46 AM 6/28/2023 9:46 AM 6/28/2023 9:47 AM Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Page 9 of 11 41 DC_3016.jpg 42 MOV_3017.mp4 43 DC_3018.jpg 44 MOV_3019.mp4 45 DC_3020.jpg 46 MOV_3021.mp4 47 DC_3022.jpg 48 MOV_3023.mp4 49 DC_3024.jpg 50 MOV_3025.mp4 51 DC_3026.jpg 52 IR_3027.jpg 53 IR_3028.jpg 54 DC_3029.jpg 55 MOV_3030.mp4 56 DC_3031.jpg 57 MOV_3032.mp4 58 DC_3033.jpg 59 MOV_3034.mp4 60 DC_3035.jpr 61 MOV_3036.mp4 62 DC_3037.jpg Facility Name: Intertape Polymer Group Facility Location: 317 Kendall Avenue, Marysville, MI 48040 Date of Inspection: June 28, 2023 6/28/2023 9:47 AM 6/28/2023 9:51 AM 6/28/2023 9:51 AM 6/28/2023 9:52 AM 6/28/2023 9:52 AM 6/28/2023 9:56 AM 6/28/2023 9:56 AM 6/28/2023 9:58 AM 6/28/2023 9:58 AM 6/28/2023 10:04 AM 6/28/2023 10:04 AM 6/28/2023 10:06 AM 6/28/2023 10:06 AM 6/28/2023 10:13 AM 6/28/2023 10:13 AM 6/28/2023 10:17 AM 6/28/2023 10:17 AM 6/28/2023 10:18 AM 6/28/2023 10:18 AM 6/28/2023 10:21 AM 6/28/2023 10:21 AM 6/28/2023 10:24 AM Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Page 10 of 11 63 MOV_3038.mp4 64 DC_3039.jpg 65 MOV_3040.mp4 66 DC_3041.jpg 67 MOV_3042.mp4 68 DC_3043.jpg 69 MOV_3044.mp4 70 DC_3045.jpg 71 MOV_3046.mp4 72 DC_3047.jpg 73 MOV_3048.mp4 74 DC_3049.jpg 75 MOV_3050.mp4 76 DC_3051.jpg 77 MOV_3052.mp4 78 DC_3053.jpg Facility Name: Intertape Polymer Group Facility Location: 317 Kendall Avenue, Marysville, MI 48040 Date of Inspection: June 28, 2023 6/28/2023 10:24 AM 6/28/2023 10:25 AM 6/28/2023 10:25 AM 6/28/2023 10:28 AM 6/28/2023 10:28 AM 6/28/2023 10:34 AM 6/28/2023 10:34 AM 6/28/2023 10:34 AM 6/28/2023 10:34 AM 6/28/2023 10:41 AM 6/28/2023 10:36 AM 6/28/2023 10:36 AM 6/28/2023 10:39 AM 6/28/2023 10:39 AM 6/28/2023 10:41 AM 6/28/2023 10:41 AM Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Claimed as CBI Page 11 of 11