Document NrB4YvEkkzz1zBa59LMQVbk8

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEYARD CHICAGO, ILLINOIS 60604 NOV 2 0 2019 CLEAN AIR ACT INSPECTION REPORT Industrial Container Services, Inc., Hastings, Minnesota Manojkumar P. Patel, Enviromnental Engineer AECAB (MI/WI) Sarah Marshall, Section Chief AECAB (MI/WI) File BASIC INFORMATION Facility Name: Industrial Container Services, Inc., Hastings, Minnesota Facility Location: 990 Spiral Blvd., Hastings, Minnesota 55033 Date of Inspection: September 25, 2019 EPA Inspector(s): 1. Manojkumar P. Patel, Enviromnental Engineer 2. Albana Bega, Enviromnental Engineer Other Attendees 1. Joseph Slattery, Facility Manager, Industrial Container Services, Inc. Contact Email Address: joe.slattery@iconserv.com Purpose of Inspection: Evaluation of Industrial Container Washing Operations Facility Type: Container Refurbishing Industry Regulations Central to Inspection: Minnesota State Implementation Plan Requirements Arrival Time: 9:00 AM CST Departure Time: 3:45 PM CST Inspection Type: [;gJ Unannounced Inspection D Announced Inspection OPENING CONFERENCE i;gJ Credentials Presented i;gJ CBI warning to facility provided The following information was obtained verbally from the facility personnel unless otherwise noted. Company Ownership: In or around March 2019, Mouser Packaging Corporation purchased Industrial Container Services, Inc. In or around 2016, Industrial Container Services, Inc. purchased Twin City Container which owned and operated this facility. Process Description: Industrial Container Services, Inc. (the facility) is located at 990 Spiral Blvd., Hastings, Minnesota. The facility receives empty drums from food, coil, surface coating, spent oil industries, industrial solvent manufacturing, and chemical industries around the local area. Empty metal drums are washed, cleaned, repaired, painted, and then resold into the market. A detailed process description is attached in Appendix B. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: None Photos and/or Videos: were taken during the inspection. The facility personnel took digital images as requested by EPA during this inspection. The facility has not submitted these digital images to EPA. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Requested documents: (1) Bag House Maintenance Schedule; (2) Fume Scrubber Maintenance Sheet; (3) Hastings Air Permit; Page 2 of 4 (4) Photos - All of the photos taken during the inspection; and (5) All of the SDS sheets for coatings used at the facility. Concerns: We informed the facility that several drum refurbishing facilities in Region 5 are emitting significant amount ofvolatile organic compounds (VOC) from the interior and exterior washing operations. Based on the EPA's experience, EPA believes that they may be of concerns here as well. EPA informed the facility personnel that EPA may issue a Section 114 of the CAA Information Request to the facility to perfonn VOC testing on the dry scrubber. EPA may seek additional information from the facility. EPA also informed that EPA will investigate type of the permit this facility may have as it was issued "Option D Registration Permit" in or around June 21, 2002. SIGNATURES Page 3 of 4 Facility Name: Industrial Container Services, Inc., Hastings, Minnesota Facility Location: 990 Spiral Blvd., Hastings, Minnesota 55033 Date oflnspection: September 25, 2019 APPENDICES AND ATTACHMENTS 1. Appendix A - Digital Image Log 2. Production Process Description - Detailed - Submitted by ICS - Hastings, MN. Page 4 of 4 Facility Name: Industrial Container Services, Inc., Hastings, Minnesota Facility Location: 990 Spiral Blvd., Hastings, Minnesota 55033i Date of Inspection: September 25, 2019 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Manojk:umar P. Patel AlbanaBega 3. Company/Facility Name: Industrial Container Services, Inc., Hastings, Minnesota 5. Number of Images and Videos: 04 2. Date(s) of Inspection: September 25, 2019 4. Street Address, City, State: 990 Spiral Blvd., Hastings, Minnesota 55033 6. Archival Record Location: ICS Hastings, MN CAA Inspection 09/25/2019 Appendices Page l of 2 Facility Name: Industrial Container Services, Inc., Hastings, Minnesota Facility Location: 990 Spiral Blvd., Hastings, Minnesota 55033 Date of Inspection: September 25, 2019 APPENDIX B: PROCESS DESCRIPTION See Attached. Appendices Page 2 of2 m INDUSTRIAL CONTAINER SERVICES ICS - Twin City Container 990 Spira I Blvd Hastings, MN 55033 Phone 651-480-3786 Fox 651-480-2542 www.iconserv.com To whom it concerns: Production process for Hastings, MN plant. The following is a description of the production process as it relates to steel and plastic 55 gal. closed head containers. Closed head steel and plastic containers are transported to the Hastings plant via semitrucks. These semi-trucks can be customer owned, 3rd party carriers or our own company trucks. Semitrailers will hold, on average, 300 empty containers. Semi-trailers are set at the shipping/receiving docs and off loaded by hand by dock workers. The containers are sorted by product last contained. Containers last containing non-oil products are processed 1st through the chemical flushing machines. These chemical flushing machines flush the containers with 190 degree F water that is charged with sodium hydroxide for a period of 18 seconds. Once the containers have been processed they are transferred to the progressive wash line where they meet up with containers that last contained oil products. Workers load the containers onto a conveyor that transfers and orientates the containers to the proper positions for washing. Each container is rinsed on the inside with 190 degree F water (no added detergent.) There are 6 stations each container passes through for interior washing, each station is set at 18 second wash times. Throughput capacity is 3 containers per minute when processing steel containers and 2 per minute when processing plastic containers. Containers exit the progressive wash line and transfer by roller conveyor through an external rinse. The external rinse sprays each container with 190 degree F water, no detergent added. Containers exit the external rinse station and are transferred by chain and roller conveyor to the interior inspection station. Workers inspect the interior of each container for cleanliness. Up to this point steel and plastic containers have underwent the exact same processing. From here steel and plastic containers branch in different directions. Plastic Containers Upon completing the interior inspection plastic containers are transferred by hand to the pressure differential testing station. At this station each plastic container is tested for leak proofuess. Containers that pass the test have the fittings tightened and are transferred to the exterior washing station. Containers that fail are marked and sent to the plastic shredder. Workers use hand scrub pads to remove dirt and any stencils. Plastic containers are loaded on the plastic brusher/rinser for cleaning and final rinsing of the exterior. Plastic containers are inspected both inside and out at the final inspection. Workers apply a test approval stencil on each plastic container and load each onto the semi-trailer. Steel Containers Upon completing the interior inspection steel containers are capped and transferred to the label removal station. Workers use angle grinders to remove labels from the containers. The containers are transferred by chain conveyor to the steel shot blaster. The blasting machine uses small steel balls to blast/remove the paint from the exterior of the containers. The containers are transferred out of the blaster to the submersion leak proofuess testing stations. Two containers are plugged, pressurized and submerged. Solutions rcCONTAIN"fourWorld m INDUSTRIAL CONTAINER SERVICES JCS - Twin City Container 990 Spira! Blvd Hastings, MN 55033 Phone 651-480-3786 Fax 65 l -480-2542 www.iconserv.com The worker visually inspects the water surface area for the presence of leaks for each submerged container. Upon completion of the leak proofuess test containers are transferred by chain conveyor to an inspection station. Workers complete an interior and exterior inspection of each container. Containers that fail are transferred to the scrap crusher and recycled. Containers that pass inspection are transferred to a roller conveyor and moved to the paint booth. A worker installs a 2" fitting in the container and transfers it to the rotator where the paint coating is applied using Graco airless spray guns. Operating pressure is 1500 psi and there are 14 different colors of paint. The containers are transferred out of the rotator and onto a roller conveyor that transports each container to the bake oven. Containers are transferred to a chain conveyor that moves each container through the 325 degree F bake oven, travel time through the oven is 12.5 minutes. Upon exiting the bake oven each container transfers via chain conveyor to the final inspection station. At this station workers conduct an interior and exterior inspection of each steel container. Quality labels are applied and each container is loaded in to a semitrailer for shipment. Truly Joseph Slattery Plant Manager Solution:; rcCONTAl~ourWorld