Document peX8MGm7yJMQ31D4BMGBrZKOj

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT National Container Services (Mauser Packaging Solutions), Chicago, IL FROM: Giles Chickering, Physical Scientist AECAB (MI/WI) THRU: Sarah Marshall, Section Supervisor AECAB (MI/WI) TO: File BASIC INFORMATION Facility Name: National Container Services Facility Location: 3620 West 38th Street, Chicago, Illinois 60632 Date of Inspection: November 5, 2024 EPA Inspector(s): 1. Giles Chickering, Physical Scientist 2. Sasha Letuchy, Environmental Engineer Other Attendees: 1. Jason Shoff, Regional VP of Operations, Mauser Contact Email Address: jason.shoff@mauserpackaging.com Purpose of Inspection: To oversee a stack test at the drum/tank washing facility required by EPA via a Section 114 Information Request issued on March 28, 2022. Facility Type: Drum/tank washing facility Regulations Central to Inspection: Illinois State Implementation Plan Arrival Time: 10:00 AM CST Departure Time: 4:00 PM CST Inspection Type: Unannounced Inspection Announced Inspection Facility Name: National Container Services Facility Location: 3620 West 38th Street, Chicago, Illinois 60632 Date of Inspection: November 5, 2024 OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Small Business Resource Information Sheet not provided. Reason: Previously provided Provided CBI warning to facility The following information was obtained verbally from facility personnel unless otherwise noted. Process Description: Portions of the process description were obtained from December 7, 2024 inspection report summarizing EPA's October 19, 2021 inspection at the facility. National is an industrial bulk container recycler. There are two process lines; the first is for poly drums (55 gallons, 30 gallons, or 15 gallons) and another for plastic Industrial Bulk Containers (IBC) (275 gallons and 330 gallons). The larger container line was completed in July 2024, replacing an older system for washing larger containers. The facility receives poly drums and IBC in cages from several industrial and commercial establishments. National only accepts RCRA empty poly drums and containers that meet the facility's container acceptance guidelines. The poly drums' washing steps are as follows: 1) Pre-flush with cold water (Station#1) 2) External washing/delabeling (Station #2) 3) Internal washing with warm water (Station #3) 4) Vacuuming for water removal/drying 5) Drums Inspection Station - Air leak testing if passed/ground and recycled if failed The IBC (275 and 330 gallons) washing steps are as follows: 1) Pre-flush with cold water 2) External washing 3) Hot water interior wash 4) Vacuuming for water removal/drying 5) Pressure testing for leaks Page 2 of 5 Facility Name: National Container Services Facility Location: 3620 West 38th Street, Chicago, Illinois 60632 Date of Inspection: November 5, 2024 The facility can process approximately 1,000 drums per day and about 20 totes per hour. The facility also power washes the cages in which the IBCs and poly drums are delivered in. Stained or broken tote containers are removed and broken down using a partially automated process called an automated destruction line that prepares the plastic to be recycled. Everything that goes through a grinder for recycling has been washed. Emissions from the processes are not captured and are not controlled. Wastewater is partially treated for pH, oil/water separation, and acid cracking. Staff Interview: During the stack test on November 5, 2024, EPA observed the tote line operation. The first test run started at 2:45 PM CST. The poly drum line test took place on November 7, 2024. The facility staff notified EPA about an auxiliary hot water heater that was not used during the test runs and the potential impacts this could have for setting the baseline for their operations. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: Bungs are removed by a technician in open air on the exterior loading dock of the facility before they are fed onto the conveyor to enter the first pre-flushing step of washing. EPA discussed with TRC how this could be considered an emission outside of the enclosure. Totes washed during run 1 stored materials including formic acid (90%), acetic acid (90%), Diethylamino ethanol, Versenex 80, Bardac 114, and Barquat 1552. During the first run, the hot water tanks feeding the tote line were at 68C (Heat Tank 1) and 86C (Heat Tank 2). Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Field Measurements: were not taken during this inspection. Page 3 of 5 Facility Name: National Container Services Facility Location: 3620 West 38th Street, Chicago, Illinois 60632 Date of Inspection: November 5, 2024 CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility DIGITAL SIGNATURES GILES Digitally signed by GILES CHICKERING Report Author:C__H__IC__K__E__R__IN__G____-_06_'0_0_' ___________ Date: 2024.12.13 08:55:33 Section Supervisor: SARAH Digitally signed by SARAH MARSHALL MARSHALL 11:10:51 -06'00' Date: 2024.12.13 __________________________________ APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log Page 4 of 5 Facility Name: National Container Services Facility Location: 3620 West 38th Street, Chicago, Illinois 60632 Date of Inspection: November 5, 2024 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Sasha Letuchy (Flir) LLC_IL_22_Stack Test_2024 Archival Record Location: Enf_National Container Group Image Number 1 File Name DC_3493.jpg Date and Time (incl. Time zone and DST) 3:39 PM CST Description of Image TRC Exhaust fan 2 DC_3494.jpg 3:39 PM CST CBI** Tote Wash Line 3 DC_3495.jpg 3:39 PM CST CBI** Tote Wash Line Page 5 of 5