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United States Environmental Protection Agency Region 7 Enforcement and Compliance Assurance Division Air Branch Inspection Report Unannounced Full Compliance Evaluation Loparex, Inc. 2000 Industrial Park Road Iowa City, Iowa 52240 FRS# 110017406608 Inspection Date(s): December 10-11, 2024 Christopher Appier, Inspector, ECAD, Air Branch Authorized for Release by: Jodi Bruno, Air Branch Manager, ECAD 11201 Renner Boulevard Lenexa, Kansas 66219 Page 1 of 8 CONTENTS INSPECTION OVERVIEW ................................................................................................................ 3 INSPECTION OBJECTIVE.............................................................................................................3 FACILITY CONTACT INFORMATION............................................................................................3 FACILITY OVERVIEW .................................................................................................................. 3 FACILITY OPERATIONS SUMMARY.............................................................................................4 FIELD ACTIVITIES SUMMARY .....................................................................................................6 Measurement Activities ........................................................................................................ 7 INVESTIGATION OBSERVATIONS AND POTENTIAL FINDINGS ........................................................ 8 TABLES Table 1. Applicable Regulations .................................................................................................... 3 Table 2. Project Team Members ................................................................................................... 3 Table 3. Facility Contact Information ............................................................................................ 3 Table 4. Emission Units and Applicable Regulations .....................................................................4 Table 5. Field Measurement Activities .......................................................................................... 7 APPENDICES A DART Monitoring Report (# pages) B Confidential Business Information (2 pages) C Receipt for Samples (1 page) D Field Video Log (1 page) E Field Photograph Log (74 pages) This Contents page shows all the sections contained in this report and provides a clear indication of the end of this report. Page 2 of 8 INSPECTION OVERVIEW INSPECTION OBJECTIVE The objective of the full compliance evaluation (FCE) inspection was to determine compliance of the facility with the Clean Air Act (CAA), specifically those requirements listed in Table 1. The facility was identified as a possible source of odors and flagged for further investigation during an ambient air monitoring campaign conducted by the EPA in August 2024. The monitoring campaign report can be found in Appendix A. Code of Federal Regulation 40 CFR Part 60 40 CFR Part 60 40 CFR Part 63 40 CFR Part 63 40 CFR Part 63 40 CFR Part 63 Table 1. Applicable Regulations Standard Name Subpart A, General Provisions Subpart RR, Standards of Performance for Pressure Sensitive Tape and Label Surface Coating Operations Subpart A, General Provisions Subpart KK, National Emission Standards for the Printing and Publishing Industry Subpart JJJJ, National Emission Standards for Hazardous Air Pollutants: Paper and Other Web Coating Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters Table 2 lists the inspection team members. Team Member Christopher Appier Ryan Stouder Table 2. Project Team Members Organization EPA Region 7, ECAD, Air Branch Iowa Department of Natural Resources (IDNR) Project Role Lead inspector Field team member FACILITY CONTACT INFORMATION Table 3 lists the primary facility contacts alphabetically. Name, Title Bill Fahey, Maintenance and Engineering Manager Marc Tucker, EHS Manager Heather Schebel, Environmental Consultant Table 3. Facility Contact Information Phone No. (708) 927-2904 (319) 538-4029 (515) 710-1059 Email Address bill.fahey@loparex.com marc.tucker@loparex.com heather@schebelplc.com FACILITY OVERVIEW The facility began operations in 1969. Loparex purchased the facility in 2001. The facility is operated 24 hours a day, 7 days a week and employs approximately 165 employees. Page 3 of 8 The facility produces specialty paper and film release liners. Operations include chemical storage and mixing, paper and film treatment, primer and coating applications, drying, printing, cutting, and auxiliary heat production. The last onsite compliance monitoring activity at the facility was on December 19, 2022, and consisted of a FCE inspection conducted by IDNR. IDNR completed a Title V certification review on March 29, 2024. According to Enforcement and Compliance History Online (ECHO) website, there has been one formal enforcement action at this facility in the past five years. EPA issued an Administrative Order on June 7, 2022, under the Resource Conservation and Recovery Act (RCRA) program. According to Loparex Title V operating permit issued by the Iowa Department of Natural Resources (IDNR) on March 17, 2022, the facility is subject to the regulations and standards subject to review during this inspection as noted in Table 1. FACILITY OPERATIONS SUMMARY The facility consists of nine production lines that produce various specialty paper and film release liners, and auxiliary equipment such as mixing booths and a boiler. Table 4 shows the various emission units for each production line and which regulation is applicable. Line Emission Point EP-003-1 EP-003-2 3 EP-003-3 EP-003-5 EP-008-1 8 EP-008-3 EP-008-4 EP-012-1A EP-012-1 EP-012-2 12 EP-012-3 EP-012-4 012-5a 012-5b Table 4. Emission Units and Applicable Regulations Emission Unit Description EU-003-1 Corona Treater EU-003-2 Electron Beam Curing #1 EU-003-3 Electron Beam Curing #2 EU-003-5 UV Cure EU-008-1A Primer Coater EU-008-1B Primer Coating Dryer EU-008-3 Extrusion Coater EU-008-4 Print Treater EU-012-1C Press Printer EU-012-1D Infrared Oven EU-012-1A Primer Coater 1 EU-012-1B Primer Dryer 1 EU-012-2 Extruder Laminator 1 EU-012-3 Primer Coater and Dryer 2 EU-012-4 012-5-1a 012-5-1b 012-5-2 Extruder Laminator 2 Infeed Corona Treater Infeed Corona Treater Extruder #1 Treater Page 4 of 8 NSPS RR RR RR RR NESHAP JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ KK KK KK KK KK KK KK 012-5c 012-5-3 EP-014-1 EU-014-1 EP-014-3C EU-014-3C EP-014-5C EU-014-5C EU-014-2 EU-014-3A EU-014-3B EU-014-5A 14 EU-014-5B EP-014/016 EU-014-6 EU-016-2 EU-016-3A EU-016-3B EU-016-3C EU-022-2 EU-022-3 EP-022-1 EU-022-1 22 EP-022-3 EU-022-2 EU-022-3 EP-022-4 EU-022-4 EP-015-1 15 EU-015-1a EU-015-1b EP-15-2 EU-15-2 EP-016-1 16 EU-016-1a EU-016-1b EP-016-4 EU-016-4 EP-017-1 EU-017-1 EU-017-2 EP-017-2 & EP017-BP EU-017-3A 17 EP-017-3 EU-017-3B EU-017-3C EP-017-4 EU-017-3D EP-17-5 EU-017-4 EP-17-6 EU-017-5 EP-018-1 EU-018-1 EP-018-2 & EP018-BP EU-018-2 EU-018-3A EU-018-3B 18 EP-018-3 EU-018-3C EP-018-4 EU-018-3D EP-018-5 EU-018-4 EP-018-6 EU-018-5 EP-018-7 EU-018-6 Extruder #2 Treater Print Treater Silicon Coating Dryer 1, Zone 3 Silicon Coating Dryer 2, Zone 3 Floor Sweep from Coating Booth Silicon Coating Dryer 1, Zone 1 Silicon Coating Dryer 1, Zone 2 Silicon Coating Dryer 2, Zone 1 Silicon Coating Dryer 2, Zone 2 Mixing Booth Floor Sweep from Coating Booth Silicon Coating Dryer 3, Zone 1 Silicon Coating Dryer 3, Zone 2 Silicon Coating Dryer 3, Zone 3 Rod Coating Head RR Arch Type Dryer Oven RR Mixing Room Bypass: Rod Coating Head RR Bypass: Arch Type Dryer Oven RR Corona Treater RR Ink Dryer (2 MMBtu/hr) Ink Application Mix Booth Corona Treater Flame Treater Mixing Area for Silicon Coatings Corona Print Treater RR Coating Booth Floor Sweep RR Silicon Coating Oven, Zone 1 RR Silicon Coating Oven, Zone 2 RR Silicon Coating Oven, Zone 3 RR Silicon Coating Oven, Zone 4 RR Mix Booth Auxiliary Heater Print Treater RR Coating Booth Floor Sweep RR Silicon Coating Oven, Zone 1 RR Silicon Coating Oven, Zone 2 RR Silicon Coating Oven, Zone 3 RR Silicon Coating Oven, Zone 4 RR Mix Booth Auxiliary Heater Boiler Page 5 of 8 JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ KK KK JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ DDDDD JJJJ JJJJ JJJJ JJJJ JJJJ JJJJ DDDDD DDDDD EP-018-8 EP-018-7 Flame Treater FIELD ACTIVITIES SUMMARY I arrived at the facility on December 10, 2024, at 9:30 a.m. I completed a drive by surveillance and did not observe visible emissions. I made entry at the front door at 9:45 a.m. and introduced myself and Ryan Stouder, presented my credentials, and provided my business card to Mr. Tucker. I conducted an opening conference during which I explained that the purpose of the visit was to conduct an inspection to determine compliance with the CAA, specifically, to determine compliance with the regulations and standards listed in Table 1. I explained that after asking for some general business information, I would observe process units, emission units, control equipment, and also review associated records demonstrating compliance with the applicable permit and regulatory requirements. I explained to Mr. Tucker that the facility would have an opportunity to make a claim of business confidentiality at the end of the inspection and provided him with a Confidential Business Information (CBI) form. Mr. Tucker did make a claim of confidentiality (Appendix B). After the opening conference, I asked Messers. operations, reviewed the facility map, and discussed their investigations into community odor complaints. The inspection team was given a facility tour by Messers. Fahey and Tucker. I wore a hard hat, steel toed boots, safety glasses, ear plugs, and cut resistant gloves during the facility tour per my site health and safety plan. I obtained copies of the records as indicated on the Receipt for Documents (Appendix C) via a shared OneDrive folder. The documents were uploaded on December 12, 2024, through January 6, 2025. I received a paper copy of the facility map during the inspection. I conducted optical gas imaging which is described in the Measurement Activities section below. We broke for lunch at 11:45 a.m. and returned to the inspection at 12:45 p.m. The facility tour continued with Mr. Fahey and Ms. Schebel. After the facility tour, I discussed emission calculations with Ms. Schebel. I left the facility at 3:10 p.m. I returned to the facility at 8:35 a.m. on December 11, 2024. Ms. Schebel and I continued our Fahey. Page 6 of 8 I conducted a closing conference with the facility contacts listed in Table 3. I provided the facility with copies of the CBI form and a Receipt for Documents. I left the facility at 10:15 a.m. Observations and potential findings from the facility tour, records review, and measurement activities are noted in the Investigation Observation and Potential Findings section below. Measurement Activities I conducted optical gas imaging throughout the entire facility during the onsite inspection. A video was captured when emissions were observed and can be found in Appendix D. Table 5 summarizes field measurement and field sampling activities. All environmental measurement activities were performed in accordance with the EPA Region 7 quality system. Table 5 summarizes field measurement activities. Table 5. Field Measurement Activities Date Method and/or Procedure1, and Equipment December 10, 2024 Region 7 procedure: FLIR ThermaCAM GasFindIR, GF320, and Similar Infrared Cameras Equipment: FLIR GX320, C15517 - FLIR GX320 10400138 1 The current version of each procedure, at the time of the investigation, was followed. Measurer Name Christopher Appier Page 7 of 8 INVESTIGATION OBSERVATIONS AND POTENTIAL FINDINGS Ambient weather, site conditions, and field activities were documented in the field records. All photographs are attached as Appendix E. I made the following observations during the inspection. I discussed all observations with facility representatives during the closeout meeting unless otherwise noted in the observation description. These observations are not final compliance determinations. The EPA Region 7 Air Branch case review team will make the final compliance determinations based on its review of this report and other technical, regulatory, and facility information. permits. During the inspection, I observed emissions coming from the equipment in the line 14 mixing room. A video was recorded and can be seen in Appendix D. I did not observe any leaks from the underground storage tanks outside of the facility. The records submitted to demonstrate compliance with the regulations listed in Table 1 are still under review as of the time of this report writing. End of report. Page 8 of 8