Document mbyN7o4nRvZx5rnqxpQ4N8yYJ

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 CLEAN AIR ACT INSPECTION REPORT Royal Adhesives and Sealants, LLC Gregory Gehrig, Environmental Engineer AECAB (Ml/WI) Sarah Marshall, Section Chief AECAB (Ml/WI) File BASIC INFORMATION Facility Name: Royal Adhesives and Sealants, LLC Facility Location: 2001 W. Washington St., South Bend, IN Date of Inspection: March 14, 2019 EPA Inspectors: 1. Gregory Gehrig, Environmental Engineer 2. Eleanor Kane, Environmental Engineer Other Attendees: 1. Rick Reynolds, Indiana Department of Environmental Management 2. Charles Tuskan, Plant Manager, Royal Adhesives and Sealants, LLC 3. Teresa Eland, Global Products Principle Engineer, H.B. Fuller Company Contact Email Address: chuck.tuskan@rascp.com Purpose of Inspection: CAA Compliance Facility Type: Adhesives manufacturing Regulations Central to Inspection: SIP, NSPS and MACT Arrival Time: 0820 hrs Departure Time: 1145 hrs Facility Name: Royal Adhesives and Sealants, LLC Facility Location: 2001 W. Washington St., South Bend, IN Date of Inspection: March 14, 2019 Inspection Type: l2'l Unannounced Inspection D Announced Inspection OPENING CONFERENCE l2'l Credentials Presented l2'l CBI warning to facility provided The following information was obtained verbally from facility personnel. Company Ownership: The facility is owned by Royal Adhesives and Sealants, LLC, which is wholly owned by the H.B. Fuller Company. The facility has had the same ownership since 2017. Process Description: The Royal Adhesives and Sealants, LLC (Royal) facility makes adhesives. Raw materials include hexane, textile mineral spirts, toluene, epoxies and urethanes and binders. These materials are mostly hard piped to the mixers from outdoor storage tanks. Dry products and some liquids are dropped into mixers from a deck above the mixers. Raw materials are mixed in 23 fixed mixers, called chums, and two mixers with portable tanks. Each mixer is vented to a dedicated primary condenser. All primary condensers are then routed to a single secondary condenser, which is then vented to atmosphere. A baghouse controls particulate emissions from dry product additions to the mixers. Particulate emissions are collected at several locations by a series of dust collectors and baghouses. Products are poured into drums and pails, labeled, and warehoused prior to shipping out. Monitors near the floor detect volatile organic compounds (VOCs) for safety purposes. The facility is subject to NESHAP Subpart HHHHH, the Miscellaneous Coatings MACT (MCM). Approximately 1 year ago, the facility began a leak detection and repair (LDAR) program. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: EPA also utilized a FUR camera (MOY files) and regular camera (IMG files) to observe process operations and collect images. At the time of inspection, the facility was operating normally. Four VOC leaks were observed with the FUR camera from: A small churn (chum 4) on the deck. Page 2 of 4 Facility Name: Royal Adhesives and Sealants, LLC Facility Location: 2001 W. Washington St., South Bend, IN Date oflnspection: March 14, 2019 The primary condenser for chum 22. The primary condenser for churn 54. The pressure relief valve (PRV) atop the outdoor hexane storage tank. The pressure differential at DC-2 was zero, and had been recorded as zero for several days. Similarly, for DC-3, several days had pressure differential readings at zero. DC-1 was noted as being "Not in Service." Field Measurements: were not taken during this inspection. RECORDS REVIEW Facility layout (taken). Process overview presentation (taken). CLOSING CONFERENCE Requested documents (to be provided via email): Initial and most recent semiannual LDAR reports 2019 baghouse pressure drop and maintenance readings/information to date. Most recent performance test for secondary condenser. MCM Notice of Compliance Status. Page 3 of 4 Facility Name: Royal Adhesives and Sealants, LLC Facility Location: 2001 W. Washington St., South Bend, IN Date of Inspection: March 14, 2019 DIGITAL IMAGE LOG* 1. Photographer: Gregory Gehrig, FLIR video and Eleanor Kane, photos 3. Company/Facility Name: Royal Adhesives and Sealants, LLC 5. Number of Images: 28 2. Date(s) of Inspection: March 14, 2019 4. Street Address, City, State: 2001 W. Washington St., South Bend, IN 6. Archival Record Location: CD-R labeled Royal Adhesives Images 3.14.2019 Time* Image name (EDT) Description IMG 0703 1001 Chum 43 and hard piping leads for material addition. lMG 0704 1003 Chum 7. IMG 0705 1006 Chum 54. IMG 0706 1018 Row of chums. IMG 0707 1025 Mixer with portable tank. IMG 0708 1027 LDAR tag on hard piped lead for material addition. IMG 0709 1030 Chum 56 material addition port and vent to baghouse on deck above the churn. IMG 0710 1037 Area of observed VOC leak on primary condenser for churn 54. lMG 0711 1038. Chum20 IMG 0712 1041 Chum 4 condenser temp. IMG 0713 1051 Baghouse. lMG 0714 1051 Vents and components on roof. IMG 0715 1051 Vents and components on roof. IMG 0716 1053 Dust collector pressure drop, DC-4 IMG 0717 1053 Dust collector pressure drop, DC-2. IMG 0718 1053 Dust collector pressure drop, DC-3. IMG 0719 1053 Dust collector pressure drop, DC-1, not in service. IMG 0720 1054 Visible emissions notations sheet for DC-3. IMG 0721 1054 Visible emissions and pressure drop notations sheet for DC-2 IMG 0722 1057 Screen shot for secondary condenser IMG 0723 1101 Tank farm, note toluene tank on the right. IMG 0724 1109 PRY for hexane tank, leaking VOCs. MOV 0014 1009 Chum 41 full of product (roofing material) waiting for dispensing. MOV 0015 1029 Churn 54 primary condenser with VOC leak. MOV 0016 1034 Chum 4, small chum on deck, with VOC leak. MOV 0017 1037 Chum 22 primary condenser with VOC leak. MOV 0018 1047 Roof vents. MOV 0019 1106 Hexane tank with PRV leaking VOCs, and components atop other tanks. *time stamp on IMG images (pictures) is CDT. Page 4 of 4