Document 71ay7GRGnwXRkeEaLVJDvbZME

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Primient, Duluth, Minnesota FROM: Dakota Prentice, Environmental Engineer AECAB (IL/IN) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: Primary Products Ingredients Americas LLC (dba Primient) Facility Location: 110 Spring Street, Duluth, Minnesota Date of Inspection: October 29, 2024 EPA Inspector(s): 1. Dakota Prentice, Environmental Engineer 2. Brianna Fenzl, Environmental Engineer Other Attendees: 1. Richard Benner, Primient - Plant Manager 2. Andy Paasch, Primient - EHS Coordinator 3. Lucy Okerstrom, Minnesota Pollution Control Agency - Environmental Specialist Contact Email Address: Richard Benner - richard.benner@primient.com Purpose of Inspection: to determine compliance with the Minnesota state implementation plan (SIP) Facility Type: Chemical plant producing malic acid and fumaric acid Regulations Central to Inspection: The Minnesota SIP Facility Name: Primary Products Ingredients Americas LLC (dba Primient) Facility Location: 110 Spring Street, Duluth, Minnesota Date of Inspection: October 29, 2024 Arrival Time: 9:00AM Departure Time: 10:25AM Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided Provided CBI warning to facility The following information was obtained verbally from Primient personnel unless otherwise noted. Company Ownership: In 2022, Tate & Lyle PLC sold the facility to KPS Capital Partners, LP. Process Description: The Primient facility produces the acidulants, malic acid (MA) and fumaric acid (FA), for the food and beverage industry. Production begins with the delivery of maleic anhydride. The maleic anhydride is mixed with water and sent to a reactor where heat is added and MA and FA are formed. The material leaving the reactor moves to a flash drum where FA is crystallized. The MA and FA are then separated at a centrifuge. The FA leaving the centrifuge is sent to a dryer prior to classification and bagging. The MA leaving the centrifuge moves through multiple purification processes and is then cooled to crystallize the MA. The crystallized MA is then separated with a centrifuge and dried prior to classification and bagging. Staff Interview: Priment has five baghouses at classification and packaging to control particulate matter (PM). The FA dryer and MA dryer each have a dedicated venturi scrubber for PM control. Scrubbers are also used to control emissions from the reactor system and the water and maleic anhydride mixing vessel. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: EPA walked the production process while the facility was in operation. During the plant tour EPA observed that emissions from the MA and FA dryers were sent to a cyclone, then a venturi scrubber, then through another cyclone, prior to being routed to the atmosphere. Page 2 of 3 Facility Name: Primary Products Ingredients Americas LLC (dba Primient) Facility Location: 110 Spring Street, Duluth, Minnesota Date of Inspection: October 29, 2024 Photos and/or Videos: were not taken during the inspection. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Process flow diagram; Last six months of scrubber water flow data with minimum flow setpoints; Last three years of annual emission reports; and Potential to emit calculations. DIGITAL SIGNATURES DAKOTA Digitally signed by DAKOTA PRENTICE Report Author: _P_R__E_N__T_IC__E___1_4_:06_:0_5_-0_6'0_0_' ____________ Date: 2024.11.15 Section Supervisor: Frank, Digitally signed by Frank, Nathan _N_a_t_h_a_n_______1_0:_43_:0_8 _-06_'0_0'______________ Date: 2024.11.19 Page 3 of 3