Document QMM1pQ3y26jmY3XMR9opJdkQ8

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Ingredion Incorporated, Bedford Park, Illinois Victoria Nelson, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Ingredion Incorporated (Ingredion) Facility Location: 6400 South Archer Avenue, Bedford Park, Illinois Date of Inspection: June 6, 2023 EPA Inspectors: 1. Victoria Nelson, Environmental Engineer 2. Veronica Fischer, Environmental Engineer 3. Dakota Prentice, Environmental Engineer Other Attendees: 1. Rob Mead, Ingredion, Manager of Environmental and Regulatory Affairs 2. Rafael Caleffi, Ingredion, Plant Manager Contact Email Address: Rob Mead - Robert.mead@ingredion.com Purpose of Inspection: To evaluate compliance with the Clean Air Act, the Illinois State Implementation Plan, and the facility's construction and Title V permits Facility Type: Corn Wet Mill, Corn Oil Extraction, and Starch Processing Regulations Central to Inspection: National Emission Standards for Hazardous Air Pollutants: Solvent Extraction for Vegetable Oil Production, at 40 C.F.R. Part 63, Subpart GGGG Facility Name: Ingredion Incorporated Facility Location: 6400 South Archer Avenue, Bedford Park, Illinois Date of Inspection: June 6, 2023 Arrival Time: 10:00 AM Central Time Departure Time: 2:15 PM Central Time 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 The following information was obtained verbally from Rob Mead unless otherwise noted. Process Description: At its Bedford Park facility, Ingredion operates a corn wet mill, produces industrial and foodgrade starches, extracts and refines corn oil, and manufactures high fructose corn syrup and dextrose. Co-products from the corn wet mill include corn gluten meal and fiber that are sold as animal feed. At the corn wet mill, corn is steeped in a sulfurous acid solution to soften the kernel and make it easier to separate corn into its base components. Steeping occurs in semi-continuous batches at three tank batteries (33 tanks total) with counter-current flow of steepwater. The steep tanks are housed in a building and emissions are routed to the atmosphere. The corn parts, including germ, gluten, fiber, and starch, are separated through a series of mechanical separation steps. Ingredion buys additional germ from off-site suppliers to support production. Once separated, germ, gluten, and fiber are dried. The fiber and germ dryers vent to a thermal oxidizer. The thermal oxidizer vents to the gluten dryer. Emissions from the gluten dryer vent to a caustic scrubber. Starch drying is controlled by a wet scrubber. Separated starch is further refined at other process areas on-site to manufacture industrial starch products, high fructose corn syrup, and liquid and anhydrous dextrose. Separated germ goes to the corn oil extraction process on-site. Germ from the wet mill is stored on-site prior to preparation for the extraction process. Four lines crack and roll germ. The prepped germ then goes to the extraction unit where n-hexane is used as solvent. A mineral oil scrubber is used to control n-hexane emissions from the extraction process. Following extraction, the germ flake goes to the desolventizer, toaster, dryer, and cooler system (DTDC). After the DTDC, the germ flake is ground, dewatered, and dried. The meal grinder and dryer are vented to atmosphere. The germ meal is sold as animal feed. Staff Interview: Ingredion's "Argo" Plant in Bedford Park, Illinois has 420 employees and operates 24 hours a day, 7 days a week. Light steepwater from the wet mill is used to fortify the Page 2 of 5 Facility Name: Ingredion Incorporated Facility Location: 6400 South Archer Avenue, Bedford Park, Illinois Date of Inspection: June 6, 2023 germ and fiber animal feed co-products for additional nutritional value. The steeping process generates acrolein, acetaldehyde, ethanol, methanol, and other organic acids. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA inspectors toured the corn oil refining operation and screened external stacks for hydrocarbon emissions using optical gas imaging. EPA observed hydrocarbon emissions from the dryer cooler unit downstream of the extraction unit. The stack vents to atmosphere from the baghouse controlling the dryer cooler. EPA inspectors also toured the building where steeping is contained. On the top floor of the building, the tops of the steep tanks are accessible. EPA inspectors were carrying a Forensics Detectors single gas monitor that alarmed when inspectors exited the stairwell and walked a few feet onto the top floor. EPA inspectors returned to the stairwell immediately and proceeded to the exit of the building. The single gas monitor alarmed a second time when a door to the stairwell opened at the third floor and two operators exited. On August 3, 2023, following the inspection, Robert Mead from Ingredion communicated to EPA that Ingredion conducted industrial hygiene measurements in the steep building. Ingredion told EPA that the industrial hygiene sampling did not detect ethylene oxide. Photos and/or Videos: were taken during the inspection. EPA inspectors collected video recordings using optical gas imaging. See Appendix A: Video Log. Field Measurements: were not taken during this inspection. See Appendix B: Field Measurement Data. During the inspection, EPA inspectors carried a Forensics Detectors single gas detector calibrated for ethylene oxide. RECORDS REVIEW 1. Facility process flow diagram CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Facility process flow diagram Copies of recent construction permits Copy of the most recent Title V permit Page 3 of 5 Facility Name: Ingredion Incorporated Facility Location: 6400 South Archer Avenue, Bedford Park, Illinois Date of Inspection: June 6, 2023 2015 Fiber Dryer Thermal Oxidizer Stack Test Specification Sheet for Steepwater Emissions estimate for fiber storage Annual emissions calculations for 2021 and 2022 Solvent loss calculations for the last three years Cooling water sampling reports Additional information on acidulation Concerns: EPA inspectors observed hydrocarbon emissions from the meal grinder stack following the solvent extraction unit. Additionally, EPA noted concerns with the personal monitor readings observed at the top level of the building housing the steep tanks. EPA inspectors experienced difficulty breathing in this area of the facility. DIGITAL SIGNATURES VICTORIA Digitally signed by VICTORIA NELSON Date: 2023.08.04 Report Author: _N_E_L__S_O__N_____0_8:_09_:3_7 _-05_'0_0'_____________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL Date: 2023.08.04 _M_A__R_S_H__A_L_L___0_8:_26_:1_8 -_05_'0_0'______________ Page 4 of 5 Facility Name: Ingredion Incorporated Facility Location: 6400 South Archer Avenue, Bedford Park, Illinois Date of Inspection: June 6, 2023 APPENDICES AND ATTACHMENTS 1. Appendix A: Video Log 2. Appendix B: Field Measurement Data Page 5 of 8 Contains Items Claimed as CBI - Non-Releasable Facility Name: Ingredion Incorporated Facility Location: 6400 South Archer Avenue, Bedford Park, Illinois Date of Inspection: June 6, 2023 CONFIDENTIAL BUSINESS INFORMATION ATTACHMENT Facility Name: Ingredion Incorporated Facility Location: 6400 South Archer Avenue, Bedford Park, Illinois Date of Inspection: June 6, 2023 Ingredion claimed the seven FLIR videos as Confidential Business Information. Page 6 of 8 Facility Name: Ingredion Incorporated Facility Location: 6400 South Archer Avenue, Bedford Park, Illinois Date of Inspection: June 6, 2023 APPENDIX A: VIDEO LOG 1. Inspector Name: Victoria Nelson Video Number 1 File Name SEQ_2967.avi Date 6/6/2023 2 SEQ_2968.avi 6/6/2023 3 SEQ_2969.avi 6/6/2023 4 SEQ_2970.avi 6/6/2023 5 SEQ_2971.avi 6/6/2023 6 SEQ_2972.avi 6/6/2023 7 SEQ_2973.avi 6/6/2023 2. Archival Record Location: Region 5 Electronic Records Center Description of Image Germ preparation scrubber stacks with potential hydrocarbon emissions. Germ meal dryer/cooler baghouse stack with hydrocarbon emissions. Mineral oil scrubber stack with hydrocarbon emissions. Building exhaust fan with potential hydrocarbon emissions. Feed, fiber, and germ dryer stacks Non-contact cooling water tower with potential hydrocarbon emissions. Starch C Dryer scrubber stacks in the foreground. Page 7 of 8 Facility Name: Ingredion Incorporated Facility Location: 6400 South Archer Avenue, Bedford Park, Illinois Date of Inspection: June 6, 2023 APPENDIX B: FIELD MEASUREMENT DATA EPA inspectors toured the facility with a Forensics Detectors single gas detector calibrated for ethylene oxide with identification number B39144. The personal monitor is an electrochemical cell that can measure up to 20 ppm. The monitor was calibrated on February 28, 2023. At the top (fourth) floor of the building where steeping is housed, the monitor alarmed and showed a reading of 8.3 ppm. While in the stairwell of the same building, the monitor alarmed a second time and measured 6.0 ppm when a door to the third floor was opened and two operators entered the stairwell. The personal monitor might have cross-sensitivity with carbon dioxide and acetaldehyde. Page 8 of 8