Document K67mxDGB9qdKp1BByKQMOJkEK

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT New-Indy Hartford City, LLC, Hartford City, Indiana FROM: Sasa Dunovic, Inspector/Enforcement Officer AECAB (IL/IN) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: New-Indy Hartford City, LLC (New-Indy) Facility Location: 501 South Spring Street Hartford City, IN 47348 Date of Inspection: January 24, 2024 EPA Inspector(s): 1. Sasa Dunovic, Inspector/Enforcement Officer 2. Jason Schenandoah, Environmental Engineer Other Attendees: 1. Phillip Freel, General Manager 2. Ian Miller, Environmental Manager Contact Email Address: Phillip Freel phil.freel@new-indycb.com and Ian Miller ian.miller@newindycb.com Purpose of Inspection: Investigate odor complaints. Facility Type: Stationary recycled paper mill. Regulations Central to Inspection: Federally Enforceable State Operating Permit (FESOP) Arrival Time: 1:00 pm EST Departure Time: 3:40 pm EST Inspection Type: Unannounced Inspection Announced Inspection Facility Name: New-Indy Hartford City, LLC Facility Location: 501 South Spring Street Hartford City, IN 47348 Date of Inspection: January 24, 2024 OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Small Business Resource Information Sheet not provided. Reason: Not a Small Business Provided CBI warning to facility The following information was obtained verbally from New-Indy's personnel unless otherwise noted. Process Description: New-Indy recycles used paper. They mainly use Old Corrugated Containers (OCC) from distribution centers and municipal recycling facilities. They also use Double-lined Kraft (DLK), primarily made up of clippings from box plants. In addition, they use a mix of all types of paper, such as cereal boxes, envelopes, brown boxes, etc. There is only one production line comprising three main parts: a pulper, a paper machine with a dryer, and a roll-up section, each with auxiliary devices. Additionally, NewIndy operates a wastewater treatment plant consisting of primary and final clarifiers, an aeration lagoon with three aerators, and a sludge collection/storage and treatment facility. The boiler house with three boilers (two operational) provides heat to the facility and steam for drying part of the paper machine. Recycled paper is fed into a pulper through a conveyor. Water is added to the paper, mixing everything to create a sludge or slurry. Any glass, metals (such as staples), or other materials are removed from the mix on the auxiliary equipment. Once the slurry is free of debris, it is mixed with additional water and fed into the forming, press, and dryer sections. The dryer section uses steam from boilers to dry the paper as it heads toward the rolling section at the end of the process. The paper is then rolled into large rolls, re-rolled into smaller ones, and stored for future use. The paper produced is primarily used to make boxes in other locations. Staff Interview: The facility operates 24 hours a day, seven days a week, with two 12-hour shifts. The facility employs around 95 employees. There have been no changes in the ownership of the facility, the manufacturing process, or any process equipment in the last five years. The facility's representatives acknowledged they were aware of odor complaints made by neighboring residents, which coincided with the operational issues with the wastewater lagoon aeration system. However, they did not believe that the lagoon was the source of the odor. As a result, the facility has acquired a portable hydrogen Page 2 of 6 Facility Name: New-Indy Hartford City, LLC Facility Location: 501 South Spring Street Hartford City, IN 47348 Date of Inspection: January 24, 2024 sulfide (H2S) monitor and has started monitoring H2S concentrations east of the lagoon and northeast of the parking lot since the week of January 8th, 2024. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: Before entering the facility for inspection, we detected a strong, sewer-like odor at the intersection of South Spring Street and County Road 75 E, located approximately 0.3 miles southeast of the facility. During the site tour, we observed the paper production process, wastewater treatment facility, and associated equipment. The paper production line was operating nominally. During the tour of the wastewater facility, the facility representatives informed us that the sludge filter press had been out of service since November 2023 and that Merrell Bros hauled all sludge from the thickner holding tank off-site for further treatment and disposal. The lagoon is located on the north side of the facility. All three lagoon aerators were operating during the inspection. We used a forward-looking infrared camera (FLIR) to inspect the site for volatile organic compound (VOC) emissions and a portable four-gas meter to screen for excessive hydrogen sulfide (H2S) emissions during the site tour. However, we did not observe or detect any VOC or H2S emissions during the tour. Furthermore, we did not detect any unusual odors that could significantly impact the facility's vicinity, nor any odors described in the odor complaints received by the EPA before the inspection. 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: Process flow diagrams for all current processes. SDS for the following chemicals: o Solenis additive, o Alkaline and Acidic Cleaners, o Defoaming agent, o Wastewater flocculant. H2S Monitoring data, including but not limited to the following: o Model and specification of the monitoring device, Page 3 of 6 Facility Name: New-Indy Hartford City, LLC Facility Location: 501 South Spring Street Hartford City, IN 47348 Date of Inspection: January 24, 2024 o Dates and times of the monitoring, o All monitoring results, o Locations of the monitoring indicated on the plant layout. DIGITAL SIGNATURES Digitally signed by Dunovic, Dunovic, Sasa Date: 2024.03.01 12:40:41 Sasa Report Author: _________________-_06_'0_0'_____________ Section Supervisor: NATHAN Digitally signed by NATHAN FRANK _F_R___A_N___K_________1_4:_1_0:_5_0_-0_6_'0_0_' ______ Date: 2024.03.01 Page 4 of 6 Facility Name: New-Indy Hartford City, LLC Facility Location: 501 South Spring Street Hartford City, IN 47348 Date of Inspection: January 24, 2024 APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log Page 5 of 6 Facility Name: New-Indy Hartford City, LLC Facility Location: 501 South Spring Street Hartford City, IN 47348 Date of Inspection: January 24, 2024 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Sasa Dunovic and Jason Schenandoah Archival Record Location: Images and Videos Image Number 1 2 3 4 5 6 7 8 9 10 File Name IMG_0546.JPG IMG_0547.JPG IMG_0548.JPG IMG_0549.JPG IMG_0550.JPG IMG_0551.JPG IMG_0552.JPG IMG_0553.JPG IMG_0554.JPG IMG_0555.JPG 11 IMG_0556.JPG 12 IMG_0557.JPG 13 IMG_0558.JPG 14 IMG_0559.JPG 15 IMG_0560.JPG 16 IMG_0561.JPG 17 MVI_0562.MP4 18 IMG_0563.JPG 19 IMG_0564.JPG 20 IMG_0565.JPG 21 IMG_0566.JPG Date and Time 1/24/2024 14:23 1/24/2024 14:28 1/24/2024 14:28 1/24/2024 14:28 1/24/2024 14:28 1/24/2024 14:35 1/24/2024 14:43 1/24/2024 14:46 1/24/2024 14:47 1/24/2024 14:51 1/24/2024 14:51 1/24/2024 14:55 1/24/2024 14:57 1/24/2024 15:00 1/24/2024 15:02 1/24/2024 15:02 1/24/2024 15:02 1/24/2024 15:06 1/24/2024 15:09 1/24/2024 15:09 1/24/2024 15:15 Description of Image Hand-drawn process flow diagram Two images of the same scene: Recycling paper loading area onto the conveyer leading to the pulper Image incidentally taken Bottom portion of the pulper Centrifugal Cleaner Paper forming and drying line Water collection basin under the forming section of the paper machine Press section of the paper machine Reel section, where paper coming out of the machine is wound onto individual jumbo rolls Post processing section, where jumbo rolls are rewinded Primary clarifier Thickening, holding tank Merrell Bross sludge pump used to pump out sludge from the thickening, holding tank Two images of the aeration lagoon Video of the aeration lagoon Surge tank, collected water goes back to the process from here Final clarifier Boiler house Page 6 of 6