Document NBjjnmLQz89pGd579j1b73ww

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Bostik Inc., Calumet City, Illinois FROM: Sasa Dunovic, Inspector/Enforcement Officer AECAB (IL/IN) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: Bostik Inc. Facility Location: 14303 Paxton Ave, Calumet City, Il 60409 Date of Inspection: December 12, 2024 EPA Inspector(s): 1. Sasa Dunovic, Inspector/Enforcement Officer 2. Meaghan Pashen, Environmental Engineer 3. Maggie Nutter, Physical Scientist Other Attendees: 1. Jesse Sowder, Plant Manager 2. Jeff Spamier, Plant Engineer Contact Email Address: jesse.sowder@bostik.com Purpose of Inspection: To investigate compliance with Synthetic Minor limits for hazardous air pollutants (HAPs) Facility Type: Phenolic and Acrylic Resin Manufacturing Facility Name: Bostik Inc. Facility Location: 14303 Paxton Ave, Calumet City, Il 60409 Date of Inspection: December 12, 2024 Regulations Central to Inspection: HAP emissions and regulatory requirements associated with the Clean Air Act Permit Program (CAAPP) Permit number 96030071, the state implementation plan (SIP), and 40 CFR Part 63 Subpart OOO, National Emission Standards for Hazardous Air Pollutant Emissions: Manufacture of Amino/Phenolic Resins. According to the CAAPP permit, the Phenolic Resin Reactor System is considered affected facility under Subpart OOO. Arrival Time: 9:10 a.m. Departure Time: 12:30 a.m. Inspection Type: Unannounced Inspection Announced Inspection 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 Was any information collected during the inspection claimed as CBI? Yes No. The following information was obtained verbally from Bostik's personnel unless otherwise noted. Company Ownership: Bostik, a subsidiary of Arkema, acquired the facility in January 2022. Process Description: Bostik manufactures water- and solvent-based acrylic resins as well as phenolic resins used in adhesives. Raw materials arrive at Bostik via trucks, drums, totes, and rail cars. Materials arriving via rail car are off-loaded into bulk, fixed-roof storage tanks. There are two phenolic resin reactor systems (R-401 and R-601), two solvent-based acrylic resin reactor systems (R-301 and R-501), and one waterand solvent-based acrylic reactor system (R-201). Reactors are fully batched processes, with batches being completed every 8-20 hours, approximately, dependent on the product. Raw materials for the acrylic reactors include acrylic monomers, vinyl acetate, catalysts, toluene, hexane, and additional solvents. Each of the three acrylic reactors feeds into blend tanks before final packaging. Emissions from each reactor and blend tanks are sent to a single bladder tank, which acts as a containment tank before a blower moves the collected emission to the direct fire thermal oxidizer. Raw materials for the phenolic reactors include phenol, formaldehyde, paraformaldehyde, solvents, and special additives. Each of the two phenolic reactors feeds into the "C" tank farm for storage or three intermediate tanks for final packaging. The reactors are rinsed with water and caustic solutions Page 2 of 6 Facility Name: Bostik Inc. Facility Location: 14303 Paxton Ave, Calumet City, Il 60409 Date of Inspection: December 12, 2024 between each batch. Emissions from each reactor are sent to separate, single-pass scrubbers, which use city water as scrubbant fluid. Each phenolic reactor has two rupture disks, which act as pressure relief devices. Staff Interview: The acrylic resin reactor part of the facility operates continuously, 24/7/365, while the phenolic resin reactor system operates continuously, 24/5/365, Monday - Friday. Currently, 57 employees support the facility's operations, working in three shifts. The production at the plant was suspended prior to the inspection for an annual inventory, and the facility was preparing to restart operations on the day of the inspection. Temperature of the thermal oxidizer is monitored continuously with performance tests completed every 5 years. An interlock between the bladder tank and the thermal oxidizer prevents emissions from being transferred to the thermal oxidizer if the combustion temperature falls below the set point of 1650-degrees Fahrenheit. The scrubbers are equipped with continuous flow and pressure drop monitoring. The pH of the rinse water is monitored and adjusted before being sent to the municipal water treatment plant. The phenolic reactors' pressure relief devices (rupture disks) are hard-piped to catch tanks (301/401/501 tank and 601 tank). These tanks are designed to contain the liquid and solid content released from the reactor and vent the vapors into the atmosphere. The facility established a Leak Detection and Repair (LDAR) program to reduce fugitive emissions from the phenolic reactor system. A third party, Montrose Environmental, conducts periodic monitoring of the components included in the LDAR program and maintains the electronic database. According to Bostic's personnel, instances of finding components that leak above the regulatory threshold are rare. Environmental Monitoring Technology (EMT) conducts quarterly sampling and analysis of heat exchange cooling water to detect the presence of organic hazardous air pollutants (HAP) and volatile organic compounds (VOCs), as these indicate potential leaks. The facility conducts weekly visual inspections of the agitator seal and open-ended lines in the phenolic reactor system. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: EPA first observed the outdoor solvent unloading tank farms along with the direct fire thermal oxidizer and related controls before moving to the reactor units, working our way up each floor. The thermal oxidizer was operating during the site tour, and its control panel indicated temperatures between 1646- and 1659-degrees Fahrenheit. Page 3 of 6 Facility Name: Bostik Inc. Facility Location: 14303 Paxton Ave, Calumet City, Il 60409 Date of Inspection: December 12, 2024 During the site visit, both scrubbers, R-401 and R-601, were operational. The control room screen displayed water flows of 5.5 gallons for R-401 and 5.9 gallons for R-601. At the same time, the differential pressure measurements indicated -0.2 inches of water column for scrubber R-401 and 0.7 inches of water column for scrubber R-601. EPA observed all five reactors during the site tour; however, none of them were operational at the time. Additionally, EPA observed the pressure relief devices, specifically rupture disks, associated with their respective catch tanks and the conservation vent exhaust for tank 609. Furthermore, we observed R-401, R-601, and BT-609 agitators, along with pumps in liquid service. At the base of the reactors, we observed various tagged LDAR components. As we made our way up the floors of the reactor units, LDAR tags were not observed. Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Field Measurements: were not taken during this inspection. RECORDS REVIEW January - June 2024 Semiannual report. Blank check list for weekly visual inspections of agitators R-401, R-601, and BT-609. Phenol resin system open-ended lines inspection checklist. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: 1. Monitoring data recorded between January 1, 2023, and December 12, 2024, for the following process and control devices: o Records from R-401 and R-601 scrubbers' continuous flow rate monitoring devices averaged over the same time period as the performance test. o Records from R-401 and R-601 scrubbers' static pressure drop monitoring devices. o The average combustion chamber temperature of the thermal oxidizer measured continuously and averaged over the same time period as the performance test. o Results of the monitoring following a pressure release. o Results of the monitoring Heat exchange systems. 2. Backup copy of all facility LDAR records management databases used during the five (5) years prior to the date of the inspection. 3. Records of each pressure release to the atmosphere. Page 4 of 6 Facility Name: Bostik Inc. Facility Location: 14303 Paxton Ave, Calumet City, Il 60409 Date of Inspection: December 12, 2024 4. Phenolic Resin Reactor System piping and instrumentation diagrams (PIDs) for pressure relief devices in organic HAP service. 5. Dates of process unit or the facility shutdowns. 6. Records of the weekly visual inspections of each pump and agitator seal conducted during 2024. 7. Copies of the performance tests conducted on R-401 and R-601 scrubbers and the thermal oxidizer since 2018. 8. A maintenance log for the capture system, control device, and monitoring equipment detailing all routine and non-routine maintenance performed, including dates and duration of any outages between January 1, 2023, and December 12, 2024. 9. Actual air emissions calculations for the Facility, in editable spreadsheet covering calendar years 2021 through 2023. 10. Toxic Release Inventory (TRI) emissions calculations for the Facility, in editable spreadsheet or other native format covering calendar years 2021 through 2023. 11. List of true vapor pressure of the volatile organic liquids stored in TK-101 - TK-140, TK-699 - TK719, and TK-801 - TK-805. 12. Copies of the initial and any supplemental Notifications of Compliance Status (including any attachments or appendices to the notifications) for the National Emission Standards for Hazardous Air Pollutants (NESHAP) at 40 C.F.R. Part 63, Subpart OOO submitted to IEPA or other responsible agency for all affected sources at the Facility. 13. Copies of the last 4 periodic reports required by 40 CFR 63 Subpart UU as referenced by 40 CFR 63 Subpart OOO. 14. Copy of the process overview slides shown during the inspection. Concerns: EPA indicated that emissions of organic HAP to the atmosphere from pressure relief devices in organic HAP service are prohibited. DIGITAL SIGNATURES Digitally signed by Dunovic, Dunovic, Sasa Date: 2025.01.29 14:23:16 Sasa Report Author: _________________-_06_'0_0_' ____________ Section Supervisor: Digitally signed by Frank, Frank, Nathan Date: 2025.02.03 21:37:01 Nathan __________________-0_6_'0_0'_____________ APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log Page 5 of 6 Facility Name: Bostik Inc. Facility Location: 14303 Paxton Ave, Calumet City, Il 60409 Date of Inspection: December 12, 2024 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Maggie Nutter Archival Record Location: Images Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 File Name IMG_0724.JPG IMG_0725.JPG IMG_0726.JPG IMG_0727.JPG IMG_0728.JPG IMG_0729.JPG IMG_0730.JPG IMG_0731.JPG IMG_0732.JPG IMG_0733.JPG IMG_0734.JPG IMG_0735.JPG IMG_0736.JPG IMG_0737.JPG IMG_0738.JPG IMG_0739.JPG IMG_0740.JPG IMG_0741.JPG IMG_0742.JPG IMG_0743.JPG IMG_0744.JPG IMG_0745.JPG IMG_0746.JPG IMG_0747.JPG IMG_0748.JPG IMG_0749.JPG IMG_0750.JPG IMG_0751.JPG Date and Time (CST) 12/12/2024 11:00 12/12/2024 11:00 12/12/2024 11:02 12/12/2024 11:04 12/12/2024 11:05 12/12/2024 11:07 12/12/2024 11:11 12/12/2024 11:15 12/12/2024 11:16 12/12/2024 11:17 12/12/2024 11:19 12/12/2024 11:21 12/12/2024 11:24 12/12/2024 11:28 12/12/2024 11:32 12/12/2024 11:37 12/12/2024 11:42 12/12/2024 11:44 12/12/2024 11:48 12/12/2024 11:50 12/12/2024 11:50 12/12/2024 11:53 12/12/2024 11:57 12/12/2024 11:59 12/12/2024 12:01 12/12/2024 12:02 12/12/2024 12:05 12/12/2024 12:07 Description of Image Raw materials storage Raw materials storage aisle "E" Tank Farm: raw material (toluene, ZEHA) unloading Thermal oxidizer control panel "Delta V" thermal oxidizer system "C" Tank Farm: phenolic finished product Caustic solution and water rinse tanks Pump P-609 Pump P-601: pumps from reactor to tank Bag filters tagged for LDAR Phenolic and acrylic final packaging Pump P-401 "A" Tank Farm: bulk finished product Bladder tank Thermal oxidizer control system Scrubber PM-613 vacuum pump R-401 Reactor rupture disks with monitors, vented to 301/401/501 catch tank Drip from raw material hose R-601 Reactor rupture disk R-601 catch tank Scrubber control system R-501 rupture disks, vented to catch tank Catch tank pressure relief (R-301. R-501) 401 agitator 601 agitator 609 agitator 609 conservation vent exhaust Page 6 of 6