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DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEYARD CHICAGO, ILLINOIS 60604 MAR 2 2 2il19 CLEAN AIR ACT INSPECTION REPORT A. Schulman Inc. Gregory Gehrig, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Chief AECAB (Ml/WI) File BASIC INFORMATION Facility Name: A. Schulman Inc. Facility Location: 1301 N. Flora Street, Plymouth, IN Date of Inspection: March 13 and 15, 2019 EPA Inspectors: 1. Gregory Gehrig, Environmental Engineer 2. Eleanor Kane, Environmental Engineer Other Attendees: 1. Rick Reynolds, Indiana Department of Environmental Management 2. Karen Ray, Operations Manager, A. Schulman, Inc. Contact Email Address: karen.ray@aschulman.com Purpose of Inspection: CAA Compliance Facility Type: Gelcoat manufacturing Regulations Central to Inspection: SIP, NSPS and MACT Arrival Time: 1330 hrs on March 13, and 0700 hrs on March 15 Departure Time: 1505 hrs on March 13, and 0755 hrs on March 15 Facility Name: A. Schulman Inc. Facility Location: 1301 N. Flora Street, Plymouth, IN Date of Inspection: March 13 and 15, 20 I 9 Inspection Type: ISi Unannounced Inspection D Announced Inspection OPENING CONFERENCE ISi Credentials Presented ISi CBI warning to facility provided The following information was obtained verbally from facility personnel. Company Ownership: The facility is owned by A. Schulman Inc. The facility has had the same ownership since at least 2014. Process Description: The A. Schulman Inc. (A. Schulman) facility makes styrene and resin-based gelcoats for the fiberglass composite manufacturing industry. Raw materials include styrene, unsaturated polyester styrene-based resins, pigments and dyes. Materials are hard-piped to the 3 fixed mixers from outdoor aboveground storage tanks. Material for all mixers is also dispensed from drums. These are mixed in 18 mixers, 3 of which are fixed and vented to a thermal oxidizer (TO) and 15 of which mix for portable tanks. Mixers for portable tanks are vented to the atmosphere. Two roll mills are used to ensure pigments are completely mixed and are also vented to atmosphere. The facility is 'air swept' from floor vents, which are vented to atmosphere. There are air makeup units that provide air into the facility from the ceiling. Plastic sheets, called bonnets, are banded to batches on tanks not currently being mixed or milled. 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). The facility did not have a leak detection and repair program at the time of the inspection. TOUR INFORMATION EPA toured the facility: Yes The facility was not in operation at the time of the inspection on March 13, 2019, as A. Schulman typically operates from 6 am to 2 pm. All vessels and operations were observed then, however. Tank were covered, but lids on top of both permeant and portable tanks at mixers are not air tight (and lids on portable tanks have vents connected to rooftop openings). Data Collected and Observations: EPA utilized a FLIR camera to observe process operations on March 15, 2019 and collect images. Page 2 of 4 Facility Name: A. Schulman Inc. Facility Location: 1301 N. Flora Street, Plymouth, IN Date of Inspection: March 13 and 15, 2019 At the time of inspection on March 15, 2019, the facility was operating nom1ally. Field Measurements: were not taken during this inspection. RECORDS REVIEW Facility layout (taken). CLOSING CONFERENCE Requested documents (to be provided via email): Most recent performance test for TO and emission calculations spreadsheet. Voluntary environmental audit information. SIGNATURES Lead Inspector ( / / A// /~' ' f t ( /L:e/(~ Date .?- ) 0 - ) 0 / q Section C h i e f : ~ ~ Date:3b 2 / I 1 Page 3 of 4 Facility Name: A. Schulman Inc. Facility Location: 1301 N. Flora Street, Plymouth, IN Date of Inspection: March 13 and 15, 2019 DIGITAL IMAGE LOG 1. Photographer: Eleanor Kane, Photos; Gregory Gehrig, FLIR videos 3. Company/Facility Name: A, Schulman Inc. 5. Number of Images: 22 2. Date(s) of Inspection: March 13 and 15, 2019 4. Street Address, City, State: 1301 N. Flora Street, Plymouth, IN 6. Archival Record Location: CD-R labeled A. Schulman Images 3.13 & 15.2019 Image name IMO 0684 IMO 0685 IMO 0686 IMO 0687 IMO 0688 IMO 0689 IMO 0690 IMO 0691 IMG 0692 IMO 0693 IMO 0694 IMG 0695 IMG 0696 IMO 0697 IMO 0698 Date and Time (EDT) March 13, 2019 at 1440 March 13, 2019 at 1441 March 13, 2019 at 1442 March 13, 2019 at 1443 March 13, 2019 at 1444 March 13, 2019 at 1444 March 13, 2019 at 1445 March 13, 2019 at 1445 March 13, 2019 at 1446 March 13, 2019 at 1448 March 13, 2019 at 1448 March 13, 2019 at 1448 March 13, 2019 at 1450 March 13, 2019 at 1452 March 13, 2019 at 1452 Description Portable tanks with bonnets Mixer with portable tank Roll mills Ducting to outside from roll mills and mixer with portable tank and others Mix tanks vented to TO Lid of mix tank vented to TO Lid of tank associated with mix tank vented to TO Lid of tanks associated with mix tank vented to TO Baghouse prior to TO Mix tank group routed to TO Lid of tank associated with mix tank vented to TO Lid of mix tank vented to TO VOC (styrene) detector Floor sweep vent VOC (styrene) detector next to floor sweep vent Page 4 of 5 Facility Name: A. Schulman Inc. Facility Location: 1301 N. Flora Street, Plymouth, IN Date of Inspection: March 13 and 15, 2019 IMG 0699 IMG 0700 IMG 0701 IMG 0702 MOV 0024 MOV 0025 MOV 0026 March 13, 2019 at 1453 March 13, 2019 at 1455 March 13, 2019 at 1458 March 13, 2019 at 1500 March 15, 2019 at 0719 March 15, 2019 at 0736 March 15, 2019 at 0739 Portable tank cleaning operation Tank farm Xylene cleaner TO stack Styrene compound added to Mixer 8 Mixer 10 TO Page 5 of 5