Document n9Z5dNa8NRpvYmZeJ2YDXZb3G

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEYARD CHICAGO, ILLINOIS 60604 APR 1 9 2019 CLEAN AIR ACT INSPECTION REPORT Innocor Foam Technologies, LLC, West Chicago, Illinois Linda H. Rosen, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Innocor Foam Technologies, LLC Facility Location: 1750 West Downs Drive, West Chicago, Illinois Date of Inspection: February 21, 2019 EPA Inspector(s): 1. Linda H. Rosen, Environmental Engineer 2. Jason Schenandoah, Environmental Engineer Other Attendees 1. Lissette Diaz, Environmental, Health and Safety Manager, Innocor 2. Mark Fernandez, Plant Manager, Innocor 3. Mark DeCoteau, Regional Operations Director, Innocor 4. Jeremy Kessler, Pour Line Manager, Innocor (during tour) Contact Email Address: ldiaz@innocorinc.com Purpose of Inspection: to inspect Innocor in relation to Clean Air Act requirements. Facility Type: Polyurethane foam production Arrival Time: l 0:00 am Departure Time: 1: 15 pm Inspection Type: IZI Unannounced Inspection D Announced Inspection OPENING CONFERENCE IZI Credentials Presented IZI CBI warning to facility provided The following information was obtained verbally from representatives of Innocor unless otherwise noted. Company Ownership: In 2014, Innocor was formed by a merger of Sleep Innovations and Flex Foam. In 2016, Innocor was sold to Bane Capital. Nationwide there are 22 facilities with a corporate headquarters in New Jersey, 1600 employees and three business units. Process Description: The facility makes two types of foam, conventional and memory (visco elastic) foam. Products made from the foam include: (I) short bun material (blocks of foam) which are sold to other manufacturers; (2) toppers for mattresses for retail sale and assembled toppers for retail, original equipment manufacturing (OEM) or internal use; (3) mattresses (retail); (4) specialty items for OEM; and (5) cluster pillows which are filled with ground up foam. Raw material chemicals come in mostly by rail and truck (90 percent) and are transferred to the two tank farms (I and 2) but some materials are received in totes (IO percent). Ancillary raw materials come in by super sacs (e.g., gel beads). Raw materials consist ofpolyols, specific types of polyols for various properties, methylene diphenyl diisocyanate (MDI), toluene diisocyanate (TDI) and other additives. MDI is used on in memory foam and TDI is used for conventional foam. About 45 different chemicals come in with 5 being the prominent ones used and the rest additives. The chemicals are mixed in the trough or pour head and the foam starts expanding as it moves down the line. There is no air pollution control on the pour line. Sections of the foam are cut off by specifications determined by final product or customer demand. Memory foam needs two days to cool on racks. Conventional foam is cooled on tables in rooms. Cooling can be sped up on vacuum tables that pull air through the bun. The air is routed to a baghouse. The foam can be further processed depending on the final product to be achieved. Two waterbased adhesives are used to put layers together: one is rolled on (95 percent) and a second is sprayed on for OEM (5 percent). Building I (1850) contains the pour line, tank farm 1, and tank farm 2. Building 2 (1750) contains storage, cooling, curing, cutting and gluing to create subassembly products shipped out of Building 2. Building 3 (1700) is mattress assembly and OEM. Page 2 of5 Staff Interview: The facility operates five days per week and operates the pour line only during the first shift. Adhesive is applied mostly during the first two shifts and a small amount during the third shift. Prepping occurs during the third shift. The facility calculates TDI HAP emissions using emission factors based on production. They use an outside consultant, GHD, for this purpose. Production is measured in lbs of chemicals poured or board feet produced. The TDI monitor has a yellow visual alarm set to 1/2 of the PEL and a red visual alarm set at 4/5 of the PEL. For cleaning the facility uses simple green. They did not know if any of the adhesives have been tested by Method 24. The facility has recently undergone a $ 2.5 million expansion to enable foam and mattresses to be mechanically moved around the facility. The facility stated this could increase production by making everything move faster. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: We walked through Building 1 and observed the two tank farms inside the building. We met Jeremy Kesler the pour line manager. There were two TDI tanks, one 30,000 gallons and one 6,000 gallons; three MDI tanks, two 10,000 gallons and one 6,000 gallons; base polyol tanks; and various additive tanks. On the TDI tank, they load out through the bottom and load in through the top near the middle of the tank. We observed the pour line even though it was not in operation at the time we observed it. We observed Building 2 where drying and curing occurs. There are four glue stations at the facility, two in this building and two in Building 3. We observed Building 3 where OEM occurs and also medical mattress assembly. A firesock is spray glued onto the medical mattress. We also observed roll coating in Building 3. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. West Manufacturing Process Flow (in EPA files) 2. List of Pourline Chemicals (in CBI files) 3. 2017 Annual Emissions Report Page 3 ofS CLOSING CONFERENCE Requested documents: We indicated to the facility that we would request records either formally through a Section 114 Request or through an email. Concerns: I indicated that I was not clear as to whether submerged loading was occuring at the TDI tank. SIGNATURES ~ Report Author: ~ Section Chief: / ~~ Page 4 of 5 Facility Name: Innocor Foam Technologies, LLC Facility Location: 1750 West Downs Drive, West Chicago, Illinois Date of Inspection: February 21, 2019 APPENDICES AND ATTACHMENTS 1. Media Appendix Page 5 of5 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Jason Schenandoah 3. Company/Facility Name: Innocor Foam Technolo<!ies, LLC 5. Number of Images: 7 2. Date(s) of Inspection: Februarv 21, 2019 4. Street Address, City, State: 1750 West Downs Drive, West Chicago, Illinois 6. Archival Record Location: CD-R labelled "Innocor Inspection Photos, February 21, 2019, West Chicago, Illinois" Image Number 1 2 3 4 5 6 7 8 File Name DC 2043.JPG DC 2044.JPG DC 2045.JPG DC 2046.JPG DC 2047.JPG DC 2048.JPG DC 2049.JPG DC 2050.JPG Date and Time (incl. time zone and DST) 2/21/2019 11:27 am 2/21/2019 (no time) 2/21/2019 12:00 pm 2/21/2019 12:04 pm 2/21/2019 12:05 pm 2/21/2019 12:06 pm 2/21/2019 12:10 pm 2/21/2019 12:29 pm Description of Image Large TDI Tank TNK-0012 specifications (20K is a typo, should be 30K) This photo was accidentally not saved and is not available to view Large TDI Tank TNK-0012 TDI monitor in large TDI tank room, farm 2 TDI monitor in large TDI tank room, farm 2 TDI monitor in small TDI tank room, farm 1 TDI monitor at cut off saw Employee spraying adhesive in OEM Appendices Page 1 of l