Document 3QGd6BxJ2q794oQ7ZDyk2vV8D

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT TJM Innovations, LLC, Milwaukee, Wisconsin FROM: DeMarkus Hodge, Environmental Engineer AECAB (MI/WI) THRU: Sarah Marshall, Section Supervisor AECAB (MI/WI) TO: File BASIC INFORMATION Facility Name: TJM Innovations, LLC Facility Location: 5519 W Woolworth Ave, Milwaukee, WI 53218 Date of Inspection: December 3, 2024 EPA Inspector(s): 1. DeMarkus Hodge, Environmental Engineer 2. Matthew Walters, Environmental Engineer Other Attendees: 1. Ted McNamara, CEO 2. Julie McNamara, President 3. Sam Rawson, Chemist 4. Marla Maebane, HR/ Safety Director 5. Jesus Zamora, Operations Director Contact Email Address: julie@tjminnovations.com Purpose of Inspection: To ensure compliance with the Chemical Accident Prevention Provisions (CAPP) at 40 C.F.R. Part 68. Facility Type: Foam Manufacturer Facility Name: TJM Innovations, LLC Facility Location: 5519 W Woolworth Ave, Milwaukee, WI 53218 Date of Inspection: December 3, 2024 Regulations Central to Inspection: Part 68 - Chemical Accident Prevention Provisions Arrival Time: 12:45 PM CT Departure Time: 3:00 PM CT Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Provided CBI warning to facility Was any information collected during the inspection claimed as CBI? Yes No. The following information was obtained verbally from TJM Innovations Personnel unless otherwise noted. Process Description: TJM Innovations, LLC (TJM) manufactures polyether and polyurethane foam gutter filters and other foam products. TJM uses various raw materials such as toluene 2,4-diisocyanate (2,4-TDI), toluene 2,6-diisocyanate (2,6-TDI), polyols, additives, certain catalysts, and colorants (pigments) in the foam manufacturing process. TJM uses two TDI formulations: TD-80 (80% 2,4-TDI, 20% 2,6-TDI) and TD-65 (65% 2,4-TDI, 35% 2,6-TDI). TJM also uses three types on polyols that all have different molecular weights. TDI and polyols are delivered from tankers and unloaded at the facility. The tanker pumps TDI and polyols into the storage tanks. TJM stores TD-80, TD-65, graft polyol, and base polyol in four 6,000-gallon bulk storage tanks. Each of the tanks have a carbon filter and pressure relief valve (PRV). The tanks are located within a concrete diked system, inside the building. TD-80 and TD-65 are mixed at different ratios in the foam manufacturing process. TJM operates one manufacturing line, utilizing a production machine that was purchased new approximately 7 years ago. The foam slab is sent to the next stage for fabrication. The foam is infused with pigments to add color. Staff Interview: TJM began manufacturing foam in 2017. TJM typically operates from 7 a.m. to 3:30 p.m. Monday through Friday. TJM employes about 29 employees currently. Occasionally, TJM receives totes and barrels of polyols but mainly handles tankers. TJM has carbon filters for emision control on the tanks. TJM decommissioned the spray booth to paint the foam and currently uses a pigment injection method to color the foam. Page 2 of 6 TOUR INFORMATION EPA Toured the Facility: Yes Facility Name: TJM Innovations, LLC Facility Location: 5519 W Woolworth Ave, Milwaukee, WI 53218 Date of Inspection: December 3, 2024 Data Collected and Observations: During the inspection, EPA visited the offloading area, storage tanks, foam manufacturing area, and foam packaging area. EPA used an optical gas imaging (OGI) camera to screen for potential VOC emissions from tanks and other equipment at the facility. No fugitive emissions were observed, and no videos were recorded. The storage tanks are labeled and are located next to each other. In the storage area, TJM has 4 pumps to move TDI and polyols into the storage tanks from the offloading area. TJM has an emergency stop (E-Stop) in the storage area and in the offloading area. EPA reviewed the offloading procedures for TD-80 and TD-65 at the time of the inspection. TJM posted the written offloading procedures in the offloading area near the controls for the employees to reference. To ensure the correct chemical is offloaded in the appropriate storage tank (TDI vs polyol), the hose connections are different at each offloading station. In addition, EPA visited the foam manufacturing area. In the manufacturing area, EPA reviewed the foam manufacturing procedures. Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Field Measurements: were not taken during this inspection. RECORDS REVIEW Risk Management Program (RMP) documents in the following categories were reviewed onsite during the inspection: Operating Procedures Offsite consequence analysis (OCA) CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Page 3 of 6 Facility Name: TJM Innovations, LLC Facility Location: 5519 W Woolworth Ave, Milwaukee, WI 53218 Date of Inspection: December 3, 2024 Requested documents: Description of the Risk Management Program Management structure. Most recent Hazard Review for the foam production covered process. Operating Procedures for TDI unloading to storage tanks. Startup checklist in the foam production room. Training documentation for the four employees who are involved in the TDI unloading operation, including the initial training and any refresher training. Most recent Risk Management Program compliance audit, including the audit report, findings of the audit, and how these findings have been resolved or corrected. Supporting documentation for the most recent coordination activities with the local response organizations (LEPC and Fire Department). Underlying calculations for the reported facility wide actual emissions in an Excel spreadsheet, including any supporting documentation on assumed emission factors. Compliance Assistance: Inspectors recommended that TJM have a more involved coordination exercise with fire department to ensure that TJM's emergency action plan is understood by the emergency responders. Concerns: Compliance Audits records were not readily available at the site for review. TJM only completed a facility walkthrough with the fire department instead of a complete coordination exercise. DIGITAL SIGNATURES DEMARKUS Digitally signed by DEMARKUS HODGE Report Author: _H_O__D_G__E__________D_a_te:_2_02_5._01_.2_7 _08_:5_2:2_6_-0_6'_00_' Section Supervisor: SARAH Digitally signed by SARAH MARSHALL MARSHALL Date: 2025.01.27 08:59:42 -06'00' __________________________________ Page 4 of 6 Facility Name: TJM Innovations, LLC Facility Location: 5519 W Woolworth Ave, Milwaukee, WI 53218 Date of Inspection: December 3, 2024 APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log Page 5 of 6 Facility Name: TJM Innovations, LLC Facility Location: 5519 W Woolworth Ave, Milwaukee, WI 53218 Date of Inspection: December 3, 2024 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: DeMarkus Hodge Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 File Name PC030090.JPG PC030091.JPG PC030092.JPG PC030093.JPG PC030094.JPG PC030095.JPG PC030096.JPG PC030097.JPG PC030098.JPG PC030099.JPG PC030100.JPG PC030101.JPG PC030102.JPG Date and Time (CST) 12/3/2024 2:12 PM 12/3/2024 2:12 PM 12/3/2024 2:13 PM 12/3/2024 2:14 PM 12/3/2024 2:16 PM 12/3/2024 2:16 PM 12/3/2024 2:18 PM 12/3/2024 2:19 PM 12/3/2024 2:20 PM 12/3/2024 2:25 PM 12/3/2024 2:25 PM 12/3/2024 2:30 PM 12/3/2024 2:30 PM 2. Archival Record Location: R5 Electronic Record Center Description of Image Graft Poly Label Base Poly Label TD-80 Label TD-65 Label TDI 80 Unloading Procedures TDI 80 Unloading Receiving Station Receiving Deliveries and Spill Leak Procedures Pumps form Unloading Station Pump Label Tank Containing Base Poly Pressure Relief Valve and Carbon Absorber Control Box Control Box Page 6 of 6