Document Oz1bJK08pwam6LK0XDzG1LaNe

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 DATE: SUBJECT: FROM: THRU: TO: June 4, 2021 CLEAN AIR ACT INSPECTION REPORT James Hardie Building Products, Inc., Peru, Illinois Dakota Prentice, Environmental Engineer AECAB (IL/IN) Costantinos Loukeris, Acting Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: James Hardie Building Products, Inc. Facility Location: 17 Unytite Drive, Peru, Illinois Date of Inspection: Opening Conference - April 27, 2021 Facility Tour - May 13, 2021 Closing Conference - May 13, 2021 EPA Inspectors1: 1. Dakota Prentice, Environmental Engineer 2. Avery Bowers, Environmental Engineer 3. Brianna Fenzl, Environmental Engineer 4. Emma Leeds, Environmental Engineer Other Attendees1: 1. Jason Gahan, Plant Manager - James Hardie 2. JT Huey, Health and Safety Manager - James Hardie 3. Ryan Lampson, Environmental Health and Safety - James Hardie 4. Ryan Pugh, National Environmental Compliance Manager - James Hardie 5. Nick Tzourtzouklis, Environmental Director - James Hardie 6. Therese Dorigan - Burns McDonald 1 Represents those people that attended either the opening conference and/or the facility tour and closing conference Contact Email Address: Nick Tzourtzouklis - Nick.Tzourtzouklis@Jameshardie.com Purpose of Inspection: Inspection to determine compliance with federally enforceable permits and applicable state and federal regulations. Facility Type: Fiber Cement Board Manufacturing Arrival Time: 10:30AM Departure Time: 11:50AM 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 James Hardie representatives unless otherwise noted. Process Description: The facility manufactures concrete fiber board at what it describes as the "Sheet Plant" and the "Trim Plant". Production at the Sheet Plant begins with preparation of certain raw materials at two ball mills and a mixer/digester. Raw material is then sent to one of two mixers that make up the mix plant. The mix plant produces a slurry that is piped to two tub machines. From the tub machines the sheets are imprinted with a pattern and cut to size. These "green sheets" are then loaded to autoclaves for curing under high pressure and temperature. Coating operations follow the autoclaves and include primer and final color coating application. Coated sheets are then sent to storage before shipment to customers. The overall process at the Trim Plant is similar to the Sheet Plant; however, the Trim Plant uses an extrusion process unit to create the trim product rather than a tub machine. Staff Interview: Emissions from the Sheet Plant autoclaves are controlled by a blowdown system. The blowdown system routes autoclave steam through a water tank, moving water-soluble organics to the water phase. Water from the blowdown tank is sent to the publicly owned treatment works Page 2 of 5 (POTW). The autoclaves at the Trim Plant are uncontrolled. Coating operations at the facility are not controlled; however, low volatile organic compound (VOC) coatings are reportedly used. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA walked the process for both the Sheet Plant and Trim Plant. At the Sheet Plant, the blowdown system was not in operation during the inspection due to an upset in the POTW system that caused damage to the blowdown tank. Photos and Videos: were taken during the inspection. See Appendix A Field Measurements: were not taken during this inspection. RECORDS REVIEW2 Clean Air Act permits issued to the facility by Illinois EPA Process flow diagrams for the Sheet Line and Trim Line CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Performance test report for Blowdown System Trim Plant autoclave emissions estimates Title V permit application EPA requested the above listed documents at the Opening Conference on April 27, 2021. James Hardie representatives have since provided all requested information. 2 Provided by James Hardie representative prior to the Opening Conference Page 3 of 5 SIGNATURES DAKOTA Digitally signed by DAKOTA PRENTICE _P_R__E_N_T__IC__E___D1_2a:_t1e9:_:25_062_-10.5_0'60_.00'_4 _________ Dakota Prentice Report Author CONSTANTIN Digitally signed by CONSTANTINOS LOUKERIS _O_S__L_O_U_K__E_R_I_S_D-0_a5t'_e0:0_2' 0_21._06_.08_2_3:5_2:_24_______ Constantinos Loukeris Acting Section Chief Page 4 of 5 Facility Name: James Hardie Building Products, Inc. Facility Location: 17 Unytite Drive, Peru, Illinois Date of Inspection: May 13, 2021 APPENDICES AND ATTACHMENTS Appendix 1 - Digital Image Log Appendix 2 - Digital Video Log Page 5 of 5 Facility Name: James Hardie Building Products, Inc. Facility Location: 17 Unytite Drive, Peru, Illinois Date of Inspection: May 13, 2021 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: B. Fenzl Image Number File Name 2. Archival Record Location: R5 Electronic Record Center Description of Image 1 IMG_1129.JPG Sheet Plant Autoclave Pit 2 IMG_1130.JPG Sheet Plant Autoclave Pit 3 IMG_1131.JPG Accidental Photo 4 IMG_1132.JPG Coating Line CP3 Dryer 5 IMG_1133.JPG Blowdown System Tank 6 IMG_1134.JPG Cooling Towers 7 IMG_1135.JPG Ball Mill Appendices Page 1 of 2 Facility Name: James Hardie Building Products, Inc. Facility Location: 17 Unytite Drive, Peru, Illinois Date of Inspection: May 13, 2021 APPENDIX A: DIGITAL VIDEO LOG 1. Inspector Name: E. Leeds Video Number File Name 2. Archival Record Location: R5 Electronic Record Center Description of Image 1 MOV_2560.mp4 Sheet Plant Autoclave Pit 2 MOV_2561.mp4 Sheet Plant Autoclave Pit 3 MOV_2562.mp4 Coating Line CP3 Dryer 4 MOV_2563.mp4 Coating Line CP3 Dryer 5 MOV_2564.mp4 Blowdown System Tank 6 MOV_2565.mp4 Ball Mill Appendices Page 2 of 2