Document eaq5LKqGB5z7OxLk5YXw0Kvy

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Nippon Paint Automotive America, Lansing, Illinois Jason Schenandoah, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Supervisor AECAB (IL/IN) File BASIC INFORMATION Facility Name: Nippon Paint Automotive America (NPAA) Facility Location: 2701 E 170th St, Lansing, IL 60438 Date of Inspection: May 30, 2023 EPA Inspector(s): 1. Jason Schenandoah, Environmental Engineer 2. Sasa Dunovic, Environmental Engineer Other Attendees: 1. Mark Renick, Environmental, Health, and Safety Manager 2. Ken Hutchison, Engineering Manager Contact Email Address: mark.renick@nipponpaint.us Purpose of Inspection: To investigate NPAA's emission factors and the effectiveness of the storage tank closed vent systems. Facility Type: Paint and coating manufacturer Regulations Central to Inspection: National Emission Standards for Hazardous Air Pollutants for Area Sources: Paints and Allied Products Manufacturing at 40 C.F.R. Part 63, Subpart CCCCCCC Arrival Time: 9:10 am Departure Time: 12:30 pm Inspection Type: Unannounced Inspection Announced Inspection Facility Name: Nippon Paint Automotive Americas Facility Location: 2701 E 170th St, Lansing, IL 60438 Date of Inspection: May 30, 2023 OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Provided CBI warning to facility The following information was obtained verbally from NPAA personnel unless otherwise noted. Company Ownership: The name of the company changed from NB Coatings to Nippon Paint Automotive Americas, Inc. in January 2021. Process Description: Raw materials for the resin arrive by truck and are stored in one of two tank farms on site. Material stored in the tank farms includes: toluene, xylene, acetone, ethylbenzene, monomers, and oxidizers. The materials are pumped into process vessels and reacted at specific temperatures and pressures to create resins. The resin is pumped into a drum and then transported to the milling area, where it is loaded into a small tank for storage. The resin is pumped from the small tank into the milling process tanks and is combined with pigment. After the resin has been milled to the correct particulate size, it is put into a blending tank. In the blending tank solvent is added and the product is blended until the final product is complete. Samples are pulled from the blending tank and quality is tested in a lab. If the lab results determine that the specifications are off, more raw materials are added to the tank and the blending process continues. If the final product meets specifications, then the product is staged for distribution. Total production takes 1 to 3 days. Staff Interview: Building 3 contains the resin reactors. Emissions from the resin reactors, the bucket wash, the automated dispensing system, and some storage tanks are controlled by a thermal oxidizer. Building 2 has a small paint plant, a large paint plant, and a bucket wash area. The small paint plant utilizes 30-60 gallon mixing tanks that fill 5 gallon pails upon completion. The large paint plant utilizes 500-3400 gallon mixing tanks and fill 55 gallon drums upon completion. NPAA switched to a new emissions estimation software called Emission Masters. TOUR INFORMATION EPA Tour of the Facility: Yes Page 2 of 4 Facility Name: Nippon Paint Automotive Americas Facility Location: 2701 E 170th St, Lansing, IL 60438 Date of Inspection: May 30, 2023 Data Collected and Observations: Two Toxic Vapor Analyzer 2020s (TVAs) were utilized to conduct EPA Method 21 (Method 21) throughout the facility. The closed vent systems on controlled storage tanks were monitored via Method 21, several pieces of equipment on the closed vent system were noted to have detectable emissions. Not all storage tanks had access to monitor closed vent system equipment. VOC concentration was measured in four rooms in Building 2 and along the western outer wall of Building 2 at vent fan locations. Three vent fans on the outer wall of Building 2 were not reachable. Building 2 also has roof ventilation and those vents were not measured either. Method 21 measurements are tabulated in Appendix A: Field Measurement Data. Additional building ventilation is on the roof. All of the doors in the bucket wash room were open; two doors opened to other areas of Building 2 and one door was open to the atmosphere. Photos and/or Videos: were not taken during the inspection. Field Measurements: were taken during this inspection. See Appendix A: Field Measurement Data. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Air emissions reports for the last three years Three separate Emission Masters calculations with supporting information: o A batch from clear coat Tank #41 o A 460-gallon tank from the small paint plant o A batch from Tank #21 Compliance Assistance: A list of equipment that had detectable emissions was communicated to NPAA. Concerns: Ambient air in Building 2 was measured to have volatile organic compound (VOC) concentrations between 50 to 180 parts per million (ppm). Air exiting the vents on the wall of Building 2 had VOC concentrations between 60 and 160 ppm. DIGITAL SIGNATURES JASON Digitally signed by JASON SCHENANDOAH SCHENANDOAH Date: 2023.07.28 Report Author: _____________1_1_:09_:2_0_-0_5'0_0_' ____________ Section Supervisor: Frank, Digitally signed by Frank, Nathan Date: 2023.07.28 N__a_t_h_a_n_______1_6:2_0_:2_8 -_05_'0_0'______________ Page 3 of 4 Facility Name: Nippon Paint Automotive Americas Facility Location: 2701 E 170th St, Lansing, IL 60438 Date of Inspection: May 30, 2023 APPENDICES AND ATTACHMENTS 1. Appendix A: Field Measurement Data Page 4 of 6 Facility Name: Nippon Paint Automotive Americas Facility Location: 2701 E 170th St, Lansing, IL 60438 Date of Inspection: May 30, 2023 APPENDIX A: FIELD MEASUREMENT DATA Two TVAs, EPA equipment IDs B37055 and SL1555, were utilized to conduct Method 21 throughout NPAA's facility. Below are tables containing calibration and measurement data. Calibration Check 10:20 am Calibration Gas Hydrocarbon TVA 2020 Results (ppm) Concentration (ppmv) #B37055 #SL1555 550 547 533 1,960 1,965 1,945 10,000 9,965 9,986 Drift Check 12:30 pm Calibration Gas Hydrocarbon TVA 2020 Results (ppm) Concentration (ppmv) #B37055 #SL1555 550 555 511 1,960 1,964 1,927 10,000 10,100 9,818 Equipment Identifier Tank ST 4 Tank ST 5 Tank ST 5 Tank ST 7 Tank ST 9 Tank ST 12 Tank ST 14 Tank ST 18 Tank TK 32 Bucket wash area Bucket wash area Building 2 Building 2 Small paint plant Equipment Type Emergency vent Housing drain Emergency vent Emergency vent Emergency vent Emergency vent Emergency vent Emergency vent Manway Ambient air At overhead door Air vent 1 Air vent 2 Ambient air Method 21 Measurements TVA #SL1555 TVA # B37055 Measurement Measurement (ppm) (ppm) 9,900 10,100 587 No confirmation 5,725 5,462 1,624 2,415 650 630 1,122 1,015 21,000 8,760 3,128 4,700 27,800 22,200 180 95 160 114 125 Notes The manway was covered by insulation, the measurement was made outside of the insulation Page 5 of 6 Small paint plant Portable mixer Large paint plant Large paint plant Building 2 Building 2 Building 2 Building 2 Ambient air west room Ambient air east room Air vent 3 Air vent 4 Air vent 5 Air vent 6 Facility Name: Nippon Paint Automotive Americas Facility Location: 2701 E 170th St, Lansing, IL 60438 Date of Inspection: May 30, 2023 22,000 Emissions were visible to the naked eye while the operator was actively loading material into the mixer 70 50 65 130 62 60 Page 6 of 6