Document J36x4J7MB2yxkOMVY0oNMjZBe

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT UPM Blandin Paper Company FROM: Meaghan Pashen, Environmental Engineer AECAB (MN/OH) THRU: Brian Dickens, Section Supervisor AECAB (MN/OH) TO: File BASIC INFORMATION Facility Name: UPM Blandin Paper Company Facility Location: 115 SW First Street, Grand Rapids, Minnesota 55744 Date of Inspection: April 22, 2025 EPA Inspector(s): 1. Meaghan Pashen, Environmental Engineer 2. Dakota Prentice, Environmental Engineer Other Attendees: 1. Patrick Hecht, Minnesota Pollution Control Agency Inspector 2. Tracy Ritter, Environmental Affairs Manager, UPM Blandin Paper Company 3. Michael Engen, Safety Manager, UPM Blandin Paper Company 4. Shane McKinney, Operations Supervisor, UPM Blandin Paper Company (during tour) Contact Email Address: tracy.ritter@upm.com Purpose of Inspection: To investigate compliance with Part 70 Permit No. 06100001- 011 (the permit) and the National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart JJJJ for Paper and Other Web Coating Facility Type: Paper mill Facility Name: UPM Blandin Paper Company Facility Location: 115 1st Street Southwest, Grand Rapids, MN Date of Inspection: April 22, 2025 Regulations Central to Inspection: The permit, including the following requirements for the Pressurized Groundwood (PGW) Mill: The Permittee shall operate and maintain a Regenerative Thermal Oxidizer (RTO) to control emissions from the General Chest and Grinder Air Lock vents anytime the PGW grinders are grinding wood, and/or screening and cleaning operations are occurring. The Permittee shall operate the RTO at greater than or equal to 90 percent destruction efficiency for volatile organic compounds (VOCs). The Permittee shall operate and maintain the RTO in accordance with the Operation and Maintenance (O&M) plan. The Permittee shall operate the RTO at greater than or equal to 1450 degrees F using a 3-hour rolling average temperature in the combustion chamber. Arrival Time: 9:15 AM Departure Time: 11:15 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 Was any information collected during the inspection claimed as CBI? Yes No. The following information was obtained verbally from Tracy or Michael unless otherwise noted. Process Description: UPM Blandin Paper Company (Blandin or the facility) manufactures lightweight coat paper used in magazines. Raw materials include wood, clay, starch, and pigments. In the wood room, logs go through a debarking drum and are cut to size and sent to the PGW. The PGW introduces steam and increases temperature and pressure to aid in wood grinding. This allows wood fibers to be mechanically seperated. VOCs released by PGW are controlled by an RTO. Water is added to create a pulp slurry which is then dewatered and bleached using magnesium hydroxide and hydrogen peroxide. Kraft, or chemically produced wood pulp, is blended into the process in the blend chest. The paper machine extracts water using vacuums and dryers. Paper is then spooled and sent through the coating machine and dryers. After finishing operations, paper is shipped via truck and rail. Page 2 of 4 Facility Name: UPM Blandin Paper Company Facility Location: 115 1st Street Southwest, Grand Rapids, MN Date of Inspection: April 22, 2025 Staff Interview: EPA observed the RTO control room. The PGW RTO is stack tested every five years. The most recent stack test was conducted in 2023. EPA requested the most recent RTO stack test. The RTO is taken down for about 30 hours biannually for preventive maintenance. RTO ceramic beds are inspected and were most recently redone in 2021. EPA requested the two most recent PGW RTO PM inspection records. The permit requires Blandin to operate and maintain the RTO in accordance with the O&M plan. EPA requested the PGW RTO O&M plan. Blandin uses ~17 to 22% kraft pulp, which is purchased from a third party and not produced onsite. Blandin uses aspen, balsam, and spruce for wood. The wood room only operates during the day. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: EPA observed the RTO control room. The permit requires Blandin to operate the RTO at greater than or equal to 1450 degrees F using 3-hour rolling average in the combustion chamber. The combustion chamber temperature setpoint was 1560 degrees F, and the combustion chamber temperature was 1557 degrees F during the inspection. EPA requested PGW RTO temperature data from the past year. Minnesota Power owns the steam and natural gas boilers in the building next to the PGW building. EPA did not inspect emissions units operated by Minnesota Power. Photos and/or Videos: were not taken during the inspection. Field Measurements: were not taken during this inspection. Page 3 of 4 Facility Name: UPM Blandin Paper Company Facility Location: 115 1st Street Southwest, Grand Rapids, MN Date of Inspection: April 22, 2025 CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Most recent PGW RTO stack test report; Information related to the most recent RTO ceramic bed and media change outs; PGW RTO O&M plan; PGW RTO temperature data from the past year in Microsoft Excel format; and Two most recent PGW RTO PM inspection records. DIGITAL SIGNATURES MEAGHAN Digitally signed by MEAGHAN PASHEN Date: 2025.06.17 Report Author: __P__A_S_H__E_N______08_:5_8:_58_-0_5_'00_' ___________ Section Supervisor: BRIAN Digitally signed by BRIAN DICKENS Date: 2025.06.17 __D_I_C_K_E__N_S_____1_3:_54_:1_5 -_05_'0_0'_____________ Page 4 of 4