Document rpmwgOyonkLQ65kkbDXJQwRa0

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Pregis LLC FROM: Manojkumar P Patel, Environmental Engineer AECAB (MI/WI) THRU: Sarah Marshall, Section Supervisor AECAB (MI/WI) TO: File BASIC INFORMATION Facility Name: Pregis LLC Facility Location: 2700 Willis Street, Marysville, Michigan 48040 Date of Inspection: July 18 and 19, 2024 EPA Inspector(s): 1. Manojkumar P. Patel Other Attendees: 1. Colin Ferres, Plant Manager, Pregis LLC 2. Marianne Gutknecht, Tetra tech, Pregis LLC Consultant Contact Email Address: cferres@pregis.com Purpose of Inspection: Compliance with the Prevention of Accidental Releases found in Section 112(r) of the Clean Air Act (CAA), 42 U.S.C. 7412(r) Facility Type: Urethane and other foam Products manufacturing (NAICS: 32615) Regulations Central to Inspection: The Chemical Accident Prevention Provisions at 40 C.F.R. Part 68, commonly referred to as the Risk Management Program Facility Name: Pregis LLC Facility Location: 2700 Willis Street, Marysville, Michigan 48040 Date of Inspection: July 18 and 19, 2024 Arrival Time: July 18, 2024 (10:55 AM EST); July 19, 2024 (8:00 AM) Departure Time: July 18, 2024 (4:30 PM); July 19, 2024 (1:00 PM EST) 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: Provided CBI warning to facility. The following information was obtained verbally from the facility personnel unless otherwise noted. Company Ownership: In or around February 2018, Pregis LLC purchased Rex Performance Products' urethane manufacturing plant located in Marysville, Michigan. Pregis LLC has been operating this facility since February 2018. Process Description: Pregis LLC (Formerly REX Performance Products, LLC, Michigan Foam and Fabrication, LLC, and Fagerdala USA Marysville, Inc.) is a manufacturer of extruded polyethylene foam products, which are used for a variety of purposes, such as protective foam packaging. The facility has four extruders and two reclaim units for recycling the materials to be reused in the urethane manufacturing processes. In the extrusion process, polyethylene and polymer beads are melted and blended, and then injected with a blowing agent, isobutane. The plastic mixture is then pushed down a barrel under pressure and through a die. As the mix is pushed through the die, the change in pressure allows the blowing agent to expand and form the foam property in the plastic. As the plastic foam exits the extruder, it is then sliced, cut, and rolled into rolls of foam sheets. Any scrap foam material generated during the production process is taken to the reclaim units, where it is ground up, melted, extruded, and finally cut into small plastic beads that are then reused as feed stock in the extrusion lines. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: I made the following observations during the inspection: Page 2 of 7 Facility Name: Pregis LLC Facility Location: 2700 Willis Street, Marysville, Michigan 48040 Date of Inspection: July 18 and 19, 2024 Risk Management Program Applicability The facility describes its operations as under the North Industrial Classification Standards (NAICS) code 32615 (Urethane and Other foam Products Manufacturing). This NAICS code is not listed under the eligible NAICS code under the RMP regulations. However, the covered process meets the Program Level 3 eligibility requirements because the covered processes are subject to the Occupational Health and Safety Agency (OSHA) Process Safety Management standards at 29 C.F.R. 1910.119 and it satisfies the requirements at 40 C.F.R. 68.10(i)(2). Management System for Implementing Elements of Risk Management Program EPA requested documentation of the management system for implementing elements of the RMP, as specified in 40 C.F.R. 68.15(a). The facility provided records of a RMP management system at the time of inspection. Process Safety Information The facility provided a block flow diagram for the covered process equipment. The process chemistry and the maximum intended inventory is described in the RMP plan. EPA observed that based on the facility's document, the maximum intended inventory for the isobutane quantity is consistent. The facility will provide the safe upper and lower limits for temperatures, pressures, and flows for the covered process equipment for EPA's review. Superficially, the safe upper and lower limits for flow from the isobutane tank to the isobutane low pressure pump are missing. The facility provided the piping and instrumentation diagrams (P&ID) to satisfy the requirements under 40 C.F.R. 68.65(d)(1)(iii). The facility did not provide a relief system design and design basis for the covered equipment. After Ball Valves V-32, I observed a pressure indicator that was not in the P&ID. EPA requested documents related to the safety systems on the covered equipment and the facility stated that it will provide a document that will address the safety system for the covered process equipment. The facility claimed that the ventilation system design requirement does not apply to the facility's covered processes. EPA was unable to verify the facility's applicable design codes and standards employed. The facility said it will upload them after the inspection. Process Hazards Analysis The facility used the Hazards and Operability Study (HAZOP) methods for the latest PHA revalidation. EPA observed that the facility has updated or revalidated the PHA every 5 years to show it is consistent with the current covered process. The facility's latest PHA was performed in 2021 and the previous PHA was performed in 2017. Page 3 of 7 Operating Procedures Facility Name: Pregis LLC Facility Location: 2700 Willis Street, Marysville, Michigan 48040 Date of Inspection: July 18 and 19, 2024 The facility will provide all operating procedures for EPA's review. The facility stated that all operating procedures are readily accessible by employees who are involved in the covered processes. The facility operates about 12 isobutane gas monitors - (2 are located outside; 1 located in the pumphouse #4; and 9 are located inside the processing area). Enmet, an outside vendor, annually calibrates and recertifies the isobutane gas monitors. EPA requested the gas monitors manufacturer specifications, and standard operating procedures for calibration and recertification. The facility will upload the information for EPA's review. Management of Change The facility informed EPA that it established and implemented written procedures to manage change to process chemicals, process, technology, and equipment. The facility stated that it has not had any MOC in the last 5 years. Compliance Audits EPA was unable to observe if the facility promptly determined and documented an appropriate response to each of the findings in the audit and whether the documented deficiencies have been corrected. The facility stated that it will upload the July 26, 2024 compliance audit final report for EPA to review. Contractors EPA requested an agreement between the facility and the isobutane supplier, AMCOR. EPA requested AMCOR drivers' training certificates covering the unloading of isobutane at the facility. AMCOR needs to provide the safe operating lower limit for the isobutane storage tank and the percentage fill level. Emergency Response Program: The facility's Emergency Response Program (ERP) does not provide a mechanism for notifying the local fire department in case of any accidental release at the facility. The facility stated that the security alarms would monitor the "emergency event" and notify the local fire department but this is not described in its ERP. Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Field Measurements: were not taken during this inspection. Page 4 of 7 Facility Name: Pregis LLC Facility Location: 2700 Willis Street, Marysville, Michigan 48040 Date of Inspection: July 18 and 19, 2024 RECORDS REVIEW 1. Latest Risk Management Plan Summary 2. Piping and Instrumentation Diagram 3. Simple Process flow diagram 4. Management of change Policy 5. Compliance Audits report June 2021 CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility. Requested documents: 1. Latest PHA Report with findings and recommendations 2. July 2024 Compliance Audits Reports with findings and recommendations 3. Isobutane Gas Monitors Manufacturing Specifications and Standard Operating Practice for calibration and recertification 4. Agreement between Pregis LLC and Isobutane Supplier - AMCOR 5. AMCOR drivers' training certificates 6. Pre-Startup Safety Review Policy 7. Hotwork Policy, and Hotwork Checklist 8. Manufacturer Specifications sheet for flow meter, actuator valve, and 3-stage pump 9. Isobutane Safety data Sheet DIGITAL SIGNATURES MANOJKUM MANOJKUMAR PATEL Digitally signed by Date: 2024.09.17 Report Author: _A_R__P__A_T_E__L___1_3_:40_:2_0_-0_5'0_0_' ____________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL Date: 2024.09.17 _M_A__R_S__H_A__L_L__1_3_:45_:4_5_-0_5'0_0_' _____________ APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log Page 5 of 7 Facility Name: Pregis LLC Facility Location: 2700 Willis Street, Marysville, Michigan 48040 Date of Inspection: July 18 and 19, 2024 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Manojkumar P Patel Archival Record Location: CAA Inspection PCs Upload Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 File Name P7190045.JPG P7190046.JPG P7190047.JPG P7190048.JPG P7190049.JPG P7190050.JPG P7190051.JPG P7190052.JPG P7190053.JPG P7190054.JPG P7190055.JPG P7190056.JPG P7190057.JPG P7190058.JPG P7190059.JPG P7190060.JPG P7190061.JPG P7190062.JPG P7190063.JPG P7190064.JPG P7190065.JPG P7190066.JPG P7190067.JPG P7190068.JPG P7190069.JPG P7190070.JPG P7190071.JPG P7190072.JPG P7190073.JPG P7190074.JPG Date and Time (incl. Time zone and DST) 7/19/2024 8:20 7/19/2024 8:21 7/19/2024 8:23 7/19/2024 8:24 7/19/2024 8:26 7/19/2024 8:26 7/19/2024 8:31 7/19/2024 8:32 7/19/2024 8:35 7/19/2024 8:38 7/19/2024 8:42 7/19/2024 8:46 7/19/2024 8:48 7/19/2024 8:49 7/19/2024 8:50 7/19/2024 8:54 7/19/2024 8:56 7/19/2024 8:58 7/19/2024 9:00 7/19/2024 9:08 7/19/2024 9:09 7/19/2024 9:10 7/19/2024 9:14 7/19/2024 9:17 7/19/2024 9:18 7/19/2024 9:20 7/19/2024 9:21 7/19/2024 9:22 7/19/2024 9:23 7/19/2024 9:28 Latitude Description of Image and Longitude Nitrogen powered Emergency Shut-off Valve Isobutane 2' Unloading Line 9with smaller 1.5" vapor return line) 2nd Emergency Shut-Off Valve Isobutane Storage tank Hazard Marking Labels n the Isobutane Tank Z Overpressure Valve PSV -G221/G22 Name Plate Information on Isobutane tank Isobutane Tank Pressure Gauge Reading @ 22PSI; Valve V-20 and PI-21 Isobutane Tank Volume Gauge Reading @48% Fill Level Isobutane Tank Bottom - Transfer Pump By-Pass Valve (PRV-23 @ 450 PSI) PI @ 5 PSI and PRV 23 (Not a Bypass Currently) PRV -23 SDV - G23 Shutdown Valve SDV-G21 Shutdown Valve DV-32 and DV-34 Standard Ball Valves Unknown Pressure Indicator @275-28 PSI PRV -24 (After V-34 Valve for Process Inside the Building Diaphragm Valve DV-3 (Return to the Atmosphere) S-12 Isobutane Gas Sensor Reading @ 4% S-11 Isobutane Gas Sensor Isobutane Line towards the Isobutane Storage tank Rust G427-16-15 Type Fisher Internal Valve Incoming Line - Rust Observed Incoming Line to the Plant Processes SDV-G24 (on the Left) and SDV-G26 (on the Right) N550-10Model SDV-G26 Severe Corrosion on the pipe Observed V-35 Low Pressure System for Line #4 Diversion for Low Pressure System High Pressure Pump System for Line #4 Page 6 of 7 Facility Name: Pregis LLC Facility Location: 2700 Willis Street, Marysville, Michigan 48040 Date of Inspection: July 18 and 19, 2024 31 P7190075.JPG 7/19/2024 9:30 PRV-L4-6 (Bypass Valve) Actuator Valve on the High-Pressure System for Line 32 P7190076.JPG 7/19/2024 9:35 4 Page 7 of 7