Document B8ZOonXa44ExJkLD1e15Xp5Jj

United States Environmental Protection Agency Region 7 Enforcement and Compliance Assurance Division Air Branch Inspection Report Unannounced Full Compliance Evaluation Plaze, Inc. (also known as PLZ Corp.) 105 Bolte Lane Saint Clair, Missouri 63077-3219 FRS# 110017984582 Inspection Date(s): May 21-22, 2024 Charlotte Papp, Inspector, ECAD, Air Branch Authorized for Release by: Tracey Casburn, Air Branch Chief, ECAD 11201 Renner Boulevard Lenexa, Kansas 66219 Page 1 of 7 CONTENTS INSPECTION OVERVIEW ................................................................................................................3 INSPECTION OBJECTIVE.............................................................................................................3 FACILITY CONTACT INFORMATION............................................................................................ 3 FACILITY OVERVIEW .................................................................................................................. 3 FACILITY OPERATIONS SUMMARY.............................................................................................4 FIELD ACTIVITIES SUMMARY ..................................................................................................... 5 Measurement and/or Sampling Activities ............................................................................. 5 INSPECTION OBSERVATIONS AND POTENTIAL FINDINGS..............................................................6 TABLES Table 1. PROJECT TEAM MEMBERS................................................. Error! Bookmark not defined. Table 2. FACILITY CONTACT INFORMATION ..................................................................................3 Table 3. APPLICABLE REGULATIONS AND STANDARDS .................................................................4 Table 4. FIELD MEASUREMENTS ACTIVITIES..................................................................................5 APPENDICES A - Confidential Business Information (4 pages) B - Receipt for Documents and Records Requested (5 pages) C - Field Photographs (23 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 7 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 3 below. The facility is a synthetic minor source. Table 1 lists the inspection team members. Team Member Charlotte Papp Jonathan Boyd Table 1. PROJECT TEAM MEMBERS Organization EPA Region 7, ECAD, Air Branch EPA Region 7, ECAD, Air Branch Project Role Lead Inspector Field team member FACILITY CONTACT INFORMATION Table 2 lists the primary facility contacts in order of contact during the inspection. Table 2. FACILITY CONTACT INFORMATION Name, Title Phone No. Email Address Jason Honzell, EHS Manager 636-629-3400 Jason.Honzell@plzcorp.com Mike Lutkewitte, Plant Manager 636-629-3400 ext. 1118 Michael.Lutkewitte@plzcorp.com James Purgasou, EHS Director 636-629-3400 James.Purgasou@plzcorp.com Jon Bachmann, Compounding Manager 636-629-3400 Jon.Bachmann@plzcorp.com Noah Casby, Support Compounds 636-629-3400 Noah.Casby@plzcorp.com John Barnard, Maintenance Supervisor 636-629-3400 John.Barnard@plzcorp.com Jean Sedilo, Environmental and Hazardous Waste Director 636-629-3400 Jean.Sedilo@plzcorp.com FACILITY OVERVIEW Plaze, Inc. (Plaze), is a full-service contract packager that specializes in aerosol packaging. Some chemicals are blended onsite while other chemicals are received pre-blended. Aerosol cans are filled with the blended chemicals on one of the facility's eight fill lines prior to being sent to a gassing house for pressurization. Plaze uses the North American Industry Classification System (NAICS) code of 325998 for All Other Miscellaneous Chemical Product and Preparation Manufacturing and a Standard Industrial Classification (SIC) code of 7389 for Business Services. Plaze is a major source for volatile organic compounds (VOCs) and is a synthetic minor source for Hazardous Air Pollutants (HAPs). Page 3 of 7 The last onsite compliance monitoring activity at the facility was on August 3, 2023, and consisted of a FCE conducted by the Missouri Department of Natural Resources (MoDNR). MoDNR completed a Title V certification review on April 1, 2024. According to Environment and Compliance History Online (ECHO) there has been one CAA formal and four informal enforcement actions at this facility in the past five years. MoDNR issued warning letters to the facility on November 12, 2020 for late submittal of a semi-annual monitoring report, August 23, 2023 for failure to provide records immediately to MoDNR personnel and failure to submit a record of number of batches of each process operated per month, and March 13, 2024 for late submittal of a semi-annual monitoring report. MoDNR issued a Notice of Violation on May 25, 2022, to the facility for the late submittal of a permit renewal application. MoDNR then entered into an Administrative Compliance Order with the facility on December 30, 2022 to resolve the permit renewal application violation. According to the Plaze's Operating Permit issued by MoDNR on March 13, 2017, the facility is subject to the following regulations and standards subject to review during this inspection (Table 3): Table 3. APPLICABLE PERMIT CONDITIONS, REGULATIONS AND STANDARDS Code of Federal Standard Name Regulation 40 CFR Part 63 Subpart VVVVVV, National Emission Standards for Hazardous Air Pollutants for Chemical Manufacturing Area Sources FACILITY OPERATIONS SUMMARY The facility stores bulk chemicals in tanks located in two tank farms (one for Building 1, another for Building 5). Chemicals are piped in to designated mixing rooms where they are blended with other chemicals based on customer specifications. These blends are then transferred to the fill lines either via pipe for larger scale projects or via tote for smaller projects. The product is filtered and then sprayed into the appropriate container. If needed, the containers are taken to "gas houses" to be pressurized. Once pressurized, containers are run through a water bath to clean and check for leaks or other issues. Once cleared, the containers receive their tips/caps and are taken to shipping and distribution. The facility does not have any emission control devices onsite. Compliance is verified using emission calculations. Because the tanks can be changed to other chemicals, depending on what product is being packaged at the facility, in order to calculate the potential to emit, nHexane (Cas No. 110-54-3), is assumed as the chemical being stored in the tanks as this is the chemical with the highest emissions that the company would store on site. Page 4 of 7 FIELD ACTIVITIES SUMMARY The inspection team arrived at the facility on May 21, 2024, at 8 a.m. and completed a drive by surveillance inspection. We did not observe visible emissions. I made entry at the front office and introduced myself and Mr. Boyd. I presented my credentials and provided my business card to the facility staff listed in Table 2. 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 3. I explained that after asking for some general business information, we would observe storage tanks, process units, and review associated records demonstrating compliance with the standards. I explained to Mr. Lutkewitte 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. Lutkewitte did make a claim of confidentiality (Appendix A). The inspection team was given a facility tour by the facility staff listed in Table 2 (excluding Jean Sedilo). We were given a facility safety briefing by the facility staff. I was asked to wear the following PPE for general site safety: steel-toed boots, safety glasses, and ear protection. Due to the spark/combustion risks onsite, all photographs were taken on the facility's intrinsically safe camera with my instructions on framing and content. I obtained copies of the records as indicated on the Receipt for Documents (Appendix B-1). Additional records were requested via email (Appendix B-2) and submitted via a OneDrive folder on May 21, 2024, and June 7, 2024. We broke for lunch at approximately 11:30 a.m. and returned to the facility at 12:24 p.m. We obtained a "hot work" permit and re-visited key process areas with the Forward Looking InfraRed (FLIR) camera. We returned to the conference room at approximately 2:00 p.m. and broke for the day. The following day, May 22, 2024, we arrived at the facility at 8:29 a.m. We discussed records for approximately one hour, and then I prepared for the closing conference. I conducted a closing conference at 10:05 a.m. with the facility staff listed in Table 2. I provided the facility with copies of the CBI form (Appendix A), receipt for documents including documents requested for digital submittal (Appendix B-1 and 2), and small business information sheet. We departed the facility at 10:17 a.m. Page 5 of 7 Measurement and/or Sampling Activities I conducted field measurements using a FLIR camera during the onsite inspection. Table 4 summarizes field measurement activities. All environmental measurement activities were performed in accordance with the EPA Region 7 quality system. I followed manufacturer and EPA processes for instrument calibration which was documented in an EPA internal database. Table 4 summarizes field measurement activities. Table 4. FIELD MEASUREMENT ACTIVITIES Location Identifier Date(s) and Time Method and/or Procedure1, and Equipment MOV_0001.mp4 Building 1 Tank Farm 5/21/24 Region 7 procedure: FLIR ThermaCAMTM GasFindIR, GF320, and Similar Infrared Cameras, Equipment: Teledyne, Model No.GF320, and Serial No. 44401229 MOV_0002.mp4 Building 1 Propellant Tanks 5/21/24 Region 7 procedure: FLIR ThermaCAMTM GasFindIR, GF320, and Similar Infrared Cameras, Equipment: Teledyne, Model No.GF320, and Serial No. 44401229 MOV_0003.mp4 Batch Mixing Room 1 5/21/24 Region 7 procedure: FLIR ThermaCAMTM GasFindIR, GF320, and Similar Infrared Cameras, Equipment: Teledyne, Model No.GF320, and Serial No. 44401229 MOV_0004.mp4 Building 1 Fill Line 5/21/24 Region 7 procedure: FLIR ThermaCAMTM GasFindIR, GF320, and Similar Infrared Cameras, Equipment: Teledyne, Model No.GF320, and Serial No. 44401229 MOV_0005.mp4 Mixing Room A 5/21/24 Region 7 procedure: FLIR ThermaCAMTM GasFindIR, GF320, and Similar Infrared Cameras, Equipment: Teledyne, Model No.GF320, and Serial No. 44401229 MOV_0006.mp4 Mixing Room B 5/21/24 Region 7 procedure: FLIR ThermaCAMTM GasFindIR, GF320, and Similar Infrared Cameras, Equipment: Teledyne, Model No.GF320, and Serial No. 44401229 MOV_0007.mp4 Building 5 Tank Farm 5/21/24 Region 7 procedure: FLIR ThermaCAMTM GasFindIR, GF320, and Similar Infrared Cameras, Equipment: Teledyne, Model No.GF320, and Serial No. 44401229 1 The current version of each procedure, at the time of the investigation, was followed. Measurer Name Charlotte Papp Charlotte Papp Charlotte Papp Charlotte Papp Charlotte Papp Charlotte Papp Charlotte Papp INVESTIGATION OBSERVATIONS AND POTENTIAL FINDINGS Ambient weather, site conditions, and field activities were documented in the field records. All photographs are attached as Appendix C. I made the following observations during the Page 6 of 7 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. While observing the Building 1 Fill line with the FLIR camera, I noted there was very little emission coming off of the tops of filled bottles. No emissions were visible with the FLIR camera on any exterior tanks or feed lines from those tanks. I reviewed records required by the facility's permit and Subpart VVVVVV. These included chemical lists, storage capacities, emission calculations, and others. As of the date of this report, all records appear complete and to demonstrate compliance. For example, Plaze has a facility wide limit and must emit less than 10 tons of each individual HAP and less than 25 tons combined of HAPs from the installation in any consecutive 12-month period. Plaze demonstrates compliance with these plant wide limits by calculating the monthly and rolling 12-month HAP emissions for each individual HAP and for total combined HAPs and maintaining a complete set of Safety Data Sheets (SDS) for all HAP containing materials at the installation. The emission calculation and SDS records must be kept for no less than five years and be made available immediately to MoDNR and EPA personnel upon request. I reviewed the emissions calculation and SDS sheets and they appear to be complete and to demonstrate compliance. End of report. Page 7 of 7