Document Gmd3BoVE1ydMR3wVMgobJxeV7

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Magna International, Lansing, Michigan FROM: Justin Smith, Environmental Engineer AECAB (IL/IN) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: Magna International, Inc. - DexSys Facility Location: 5589 West Mount Hope Highway, Lansing, Michigan 48917 Date of Inspection: May 16, 2024 EPA Inspector(s): 1. Justin Smith, Environmental Engineer 2. Ethan Chatfield, Environmental Engineer Other Attendees: 1. Timothy Gibbons, Environmental Specialist, Magna International Contact Email Address: timothy.gibbons@magna.com Purpose of Inspection: Ensure compliance with emission requirements in the plastic molding and surface coating operations Facility Type: Motor vehicle parts manufacturing Regulations Central to Inspection: Facility is subject to 40 C.F.R. Part 63, Subpart PPPP - National Emission Standards for Hazardous Air Pollutants (NESHAP) for surface coating of plastic parts and products; 40 C.F.R. Part 63, Subpart 63 DDDDD - NESHAP for major source: industrial, commercial, Facility Name: Magna International Inc. - DexSys Facility Location: 5589 West Mount Hope Highway, Lansing, MI 48917 Date of Inspection: May 16, 2024 and institutional boilers and process heaters; and facility's renewable operating permit (ROP), MIROP-P0429-2023. Arrival Time: 10:15 AM Departure Time: 11:50 AM 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. Reason: Not a small business Provided CBI warning to facility The following information was obtained verbally from Timothy Gibbons unless otherwise noted. Process Description: Magna International, Inc. (Magna or the facility) manufactures front and rear fascias for several type of vehicles. Thermoplastic olefin (TPO) beads are delivered to the facility via trucks and stored into silos. The TPO beads are then vacuumed from the silos into one of six mold presses. There are four 4,000-ton and two 2,200-ton mold presses After the mold is complete, the facility uses an open gas flame to sharpen the edges of the fascias. A portion of the fascias go into storage while the others are transported to the coating line. The coating line consists of a conveyor system that goes through a five-stage parts washer, one adhesive promoter (AdPro) spray booth, three base coat spray booths, two clear coat spray booths, three drying ovens, and three cooling tunnels. Each spray coating operation occurs in a permanent total enclosure (PTE) and emissions are routed to a regenerative thermal oxidizer (RTO). Any paint spillage is washed off with water and then separated. The paint goes into waste storage while the water is recirculated back into the process line. The coated fascias are sent to assembly where parts are added to complete the product. Completed fascias are then shipped to two other Magna plants. Staff Interview: The PTE is installed with pressure differential monitors and is set to automatically shut down the paint line if the pressure is greater than -0.007 in H2O. Fabric filters in the spray booths are replaced periodically. The RTO is kept at a minimum temperature of 1500 degrees Fahrenheit. Magna uses EPA Method 24 to determine the VOC content of each coating batch. Gibbons stated that the results have remined fairly consistent for each batch. Gibbons also stated there has been no instances of RTO bypass in the past 3 years. Facility Name: Magna International Inc. - DexSys Facility Location: 5589 West Mount Hope Highway, Lansing, MI 48917 Date of Inspection: May 16, 2024 TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: EPA inspectors observed the coating line and the spray booths from outside the PTE. EPA inspectors observed the control panel for the RTO and viewed a temperature reading of 1533 degrees Fahrenheit. An opening was observed on the duct venting to the RTO. EPA inspectors asked Gibbons to have the duct inspected to determine if the integrity of the RTO's ability to capture all emissions had been compromised. On June 4, 2024, Gibbons contacted EPA inspectors informing them that observed damage was only covering insulation and that the actual air duct did not have any damage. Repair to the insulation had also been completed as of June 4, 2024. Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Most recent performance/stack test for the RTO Monitoring data for the RTO and the PTE between May 6, 2024, and May 15, 2024 Paint Line Flow Diagram VOC and HAP emissions calculations between January 2022 and April 2024 Annual Emission Report for 2022 and 2023 Latest Method 24 result for each coating batch DIGITAL SIGNATURES Smith, Justin Digitally signed by Smith, Justin Date: 2024.06.27 09:52:14 -05'00' Report Author: _________________________________ Section Supervisor: DAKOTA Digitally signed by DAKOTA PRENTICE PRENTICE Date: 2024.06.27 10:06:40 -05'00' __________________________________ Facility Name: Magna International Inc. - DexSys Facility Location: 5589 West Mount Hope Highway, Lansing, MI 48917 Date of Inspection: May 16, 2024 APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log Facility Name: Magna International Inc. - DexSys Facility Location: 5589 West Mount Hope Highway, Lansing, MI 48917 Date of Inspection: May 16, 2024 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Ethan Chatfield Archival Record Location: Enf_Magna Dexsys_MI_24 Image Number 1 File Name IMG_1693.JPG Date and Time (incl. Time zone and DST) 5/16/2024 9:26 AM Latitude and Longitude NA Description of Image Image of RTO 2 IMG_1694.JPG 5/16/2024 9:26 AM NA Additional image of RTO 3 IMG_1695.JPG 5/16/2024 9:28 AM NA Opening in duct vent to RTO 4 IMG_1696.JPG 5/16/2024 NA Control panel for RTO 9:30 AM