Document 50ER4r8o42J11N4y0xjN5b0qR

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEYARD CHICAGO, ILLINOIS 60604 JUN 1 8 2019 CLEAN AIR ACT INSPECTION REPORT ChemDesign, Marinette, Wisconsin Alexandra Letuchy, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Chief AECAB (MI/WI) File BASIC INFORMATION Facility Name: ChemDesign Facility Location: 2 Stanton Street, Marinette, Wisconsin Date of Inspection: April 30, 2019 EPA Inspector(s): I. Alexandra Letuchy, Environmental Engineer 2. Albana Bega, Environmental Engineer Other Attendees I. David J. Mielke, President & CEO 2. Joel D. Salzman, Vice President of Operations 3. Tom Willis, Director of Health, Environmental, and Safety 4. Chris Karikula, RCRA Contact Email Address: Tom Willis, twillis@chemdesign.com Purpose of Inspection: Chemical manufacturing plant inspection Facility Type: Chemical manufacturing plant Regulations Central to Inspection: MACT Subpart VVVVVV (Subpart 6V) Arrival Time: 2:15 PM Page 1 of3 Departure Time: 5:30 PM luspection Type: IZl Unannounced Inspection D Announced Inspection OPENING CONFERENCE IZl Credentials Presented [SJ CBI warning to facility provided The following information was obtained verbally from facility personnel unless otherwise noted. Process Description: ChemDesign operates a contract manufacturing chemical plant. Operations at the facility include charging chemicals, mixing, reacting, filtration, centrifugation, distillation, phase separation, and drying. The facility has 40 - 45 reactors that can be used in production. Emissions from the various operations are controlled by wet scrubbers. Batch sheets are used for each process. Solvent tanks that range in size from 8,000 - 10,000 gallons contain isopropyl alcohol, methanol, toulene, isohexane, and chlorobenzene. Two tanks onsite contain hazardous waste. The facility operates a process that uses a Subpart 6V chemical to produce a material described by North American Industry Classification System code 325. This process is described in the Confidential Business Information portion of this report. The facility has a leak detection and repair program for the hazardous waste portion of the site but not for the process side. Pressure checks are conducted as part of batch set up. Staff Interview: ChemDesign has not assessed whether the facility is subject to and complying with Subpart 6V. TOUR INFORMATION EPA toured the facility: Yes Photos and/or Videos: were not taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Diagram of process that uses a Subpart 6V chemical (copy obtained) Page 2 of3 CLOSING CONFERENCE Requested documents: Subpart 6V Summary ofApplicability and Requirements Emission calculation for Subpart 6V chemical Compliance Assistance: EPA discussed with ChemDesign personnel which portions of Subpart 6V may apply to the facility based on the process description. Concerns: EPA expressed concern that the facility may not be currently complying with Subpart 6V. SIGNATURES Page 3 of3