Document b542v4KBdVgd76ykwgOwGpejZ

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Cargill Inc., Bloomington, Illinois David Sutlin, Environmental Engineer AECAB (MN/OH) Brian Dickens, Section Supervisor AECAB (MN/OH) File BASIC INFORMATION Facility Name: Cargill Inc. Facility Location: 115 South Euclid Avenue, Bloomington, Illinois 61701 Date of Inspection: March 7, 2023 EPA Inspector(s): 1. David Sutlin, Environmental Engineer 2. Brittany Cobb, Environmental Engineer Other Attendees: 1. Scott Bruemmer, EHS Coordinator, Cargill 2. Nathan Wallace, Trinity Consultants (by phone) 3. Austin Madsen, Process Engineer, Cargill 4. Rafael Ruas, Regional EHS Lead, Cargill Contact Email Address: Scott_Bruemmer@cargill.com Purpose of Inspection: Identify potentially unreported point-source emissions of VOC using optical gas imaging Facility Type: Vegetable oil processing Facility Name: Cargill Inc. Facility Location: 115 South Euclid Avenue, Bloomington, Illinois 61701 Date of Inspection: March 7, 2023 Regulations Central to Inspection: Illinois State Implementation Plan; currently, meal grinding, meal storage, meal loadout, white flake storage and white flake loadout do not have VOC limits in the permit. Arrival Time: 8:45 AM Departure Time: 1:45 PM 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 Scott Bruemmer, Austin Madsen, and Nathan Wallace unless otherwise noted. Process Description: Soybeans are unloaded, graded, and run through a dryer. Next, the beans are cracked, conditioned with steam, and formed into flakes. 20 percent of the flakes are then expanded using steam injection. Next the flakes are washed in hexane solvent in order to extract the oil. At this point, flakes intended for animal feed are desolventized using steam in the desolventizer-toaster (DT). During this process, the flakes absorb some moisture from the steam, and are next run through the dryer-cooler until they are reduced to nine to ten percent moisture content. Next the flakes are ground into meal using three hammer mills and stored in large, vented bins. Flakes intended to be converted to a high protein additive product are desolventized quickly through the flash desolventizing system (FDS) using higher temperatures and vacuum pressure. They are then stored in large bins, without being ground into meal. The oil extracted from the beans is distilled in stages, also utilizing vacuum pressure. Hexane from the desolventizing process and distillation process is condensed for reuse, with any residual fumes controlled by a mineral oil absorber. Staff Interview: The facility operates 24 hours per day, five days per week. The most recent emissions calculations included facility-wide VOC emissions of approximately 400 tons per year. The extraction process, as permitted, includes the dryer-cooler, but does not include meal grinding. The facility is not subject to any source-wide VOC limit. In terms of the final products, the Page 2 of 4 Facility Name: Cargill Inc. Facility Location: 115 South Euclid Avenue, Bloomington, Illinois 61701 Date of Inspection: March 7, 2023 soybean oil is tested in every rail car for hexane, and is under 5 ppm. The meal product is under 100 ppm, and white flakes product is 100-200 ppm. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: Using an infrared, optical gas imaging camera, EPA recorded a video of possible VOC emissions escaping the top of the white flakes day tank, and a second video of possible VOC emissions at the exhaust of the white flakes, truck loadout dust control system. EPA also observed and recorded digital video of dust exiting one of the truck loadout enclosures. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Daily pressure drop readings for all baghouses Copy of the latest version of the facility's CAM Plan(s) Copy of the latest compliance demonstration plan, pursuant to 40 CFR Subpart GGGG Last 4 semi-annual air compliance deviation reports Records of all Method 22 readings since January 1, 2022 2021 and 2022 emission calculation Excel spreadsheets DIGITAL SIGNATURES DAVID Digitally signed by DAVID SUTLIN Report Author: _S_U_T__L_IN_______2_0:_41_:1_8 _-05_'0_0'_____________ Date: 2023.05.03 Section Supervisor: Brian Digitally signed by Brian Dickens _D_i_c_k_e_n_s______0_6:_31_:0_6 _-0_5'0_0'______________ Date: 2023.05.04 Page 3 of 4 Facility Name: Cargill Inc. Facility Location: 115 South Euclid Avenue, Bloomington, Illinois 61701 Date of Inspection: March 7, 2023 APPENDICES AND ATTACHMENTS Appendix A: Digital Image and Video Logs Page 4 of 4 Facility Name: Cargill Inc. Facility Location: 115 South Euclid Avenue, Bloomington, Illinois 61701 Date of Inspection: March 7, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Names: David Sutlin and Brittany Cobb 2. Archival Record Location: Region 5 Electronic Record Center Image Number 1 2 3 4 5 6 7 8 9 10 11 File Name Date and Time Description of Image MOV_3041.mp4 P3070143.JPG P3070144.JPG P3070145.JPG P3070146.JPG P3070147.JPG P3070141.MOV P3070142.MOV P3070148.MOV MOV_3042.mp4 P3070149.JPG 2023:03:07 12:58 2023:03:07 13:10:38 2023:03:07 13:12:13 2023:03:07 13:12:39 2023:03:07 13:15:22 2023:03:07 13:15:29 2023:03:07 2023:03:07 2023:03:07 2023:03:07 13:53 2023:03:07 14:00:58 FLIR video: white flake day tank Truck loadout Truck loadout Truck loadout Truck loadout Truck loadout Dust from truck loadout Dust from truck loadout Dust from truck loadout FLIR video: white flake truck loadout exhaust Meal dryer stack Page 1 of 1