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Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection EPA Region 5 Enforcement and Compliance Assurance Division INDUSTRIAL USER PRETREATMENT SCREENING INSPECTION REPORT 06/11/2024 - 8:45 AM (CT) Announced: No 06/11/2024 - 9:30 AM (CT) Access: Granted Sunny, 70 F Water Clean Water Act, NPDES Industrial User Screening Inspection (Pretreatment Direct Implementation) Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Mailing Address (If different) City, State, Zip Code Owner (If different than facility) Com-Pac International, Inc. 800 West Industrial Park Road Carbondale, Illinois 62901 Jackson 37.748161, -89.226284 P.O. Box 2707 Carbondale, Illinois 62901 Same Operator (If Different than Owner) Same Address City, State, Zip Code Location in WWTP Service Area (Yes - Name of WWTP/ or N/A) 1 City of Carbondale WWTP (sanitary only) FRS ID 110001339739 Permit Number(s) (If Applicable) SIC and/or NAICS SIC 3089/NAICS 326199 Lead Inspector Name: Anne Marie Vincent Signature/Date: Digitally signed by ANNE VINCENT ANNE VINCENT Date: 2024.08.08 09:30:03 -04'00' Region: EPA Region 5 Email: vincent.annemarie@epa.gov Telephone Number: (440) 250-1720 Supervisor Review Name: Brooke Furio Signature/Date: Digitally signed by BROOKE FURIO BROOKE FURIO Date: 2024.08.08 09:38:44 -04'00' Region: Email: Telephone Number: EPA Region 5 furio.brooke@epa.gov (440) 250-1705 Compac International Inspection Date: 06/11/2024 SECTION I - INTRODUCTION Site Entry/Opening Conference and Inspection Objectives United States Environmental Protection Agency (EPA) Region 5 Inspectors, Anne Marie Vincent and Megan Zale, and Equipment Specialist, Christopher Frame, arrived at Com-Pac International, Inc. (the "Facility"), located at 800 West Industrial Park Road, Carbondale, Illinois 62901, at 8:45 AM (CT) on 6/11/2024 for an unannounced inspection. EPA Region 5 Lead Inspector Anne Marie Vincent presented credentials to Gregory Sprehe, President of the Facility. Lead Inspector Anne Marie Vincent informed the facility representative that this was an EPA Region 5 Industrial User Screening Inspection to gather information on the facility, its industrial processes, its generation and management of on-site industrial process wastewater and any on-site pretreatment systems to treat process wastewater prior to discharge or disposal as authorized by Clean Water Act (CWA) Section 308 and implementing regulations. Following the presentation of credentials, the EPA representatives conducted an opening conference with Gregory Sprehe. Lead Inspector Anne Marie Vincent stated the purpose of the inspection again and explained that they would be completing a checklist of operational questions. In addition to the review of questions, EPA inspectors discussed the right of the Facility to claim Confidential Business Information (CBI) on any document or information shared with EPA during or after the inspection. The Facility did not make any CBI claims during or after the inspection. This report is based on information supplied by Facility representatives, direct observations made by the EPA Region 5 inspectors, and records and reports maintained by the Facility and Region 5 including: verbal or written statements provided by the Facility representatives during or subsequent to the inspection; and materials, process information, data, or other documents shown, demonstrated, or submitted to the EPA Region 5 inspectors by Facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of EPA, State, and/or public records may be included in this report. Attendees (US EPA, Facility, State, Local) Organization Attendee Name Title EPA Region 5 Anne Marie Vincent Lead Inspector EPA Region 5 Megan Zale Inspector EPA Region 5 Christopher Frame Equipment Specialist Com-Pac Gregory Sprehe International, Inc. President Contact Information Present Present Opening Closing Conference Conference vincent.annemarie@epa.gov Yes Yes 440-250-1720 zale.megan@epa.gov 440-250-1711 Yes Yes frame.christopher@epa.gov Yes Yes 440-250-1714 gregorysprehe@com-pac.com Yes Yes 618-529-2421 Office 618-534-2660 Cell Page 2 of 10 Compac International Inspection Date: 06/11/2024 SECTION II - INDUSTRIAL USER SCREENING CHECKLIST SECTION II.A - Business Activity/Category 1. If the facility employs or will be employing processes in any of the industrial categories or business activities listed below (regardless of whether they generate wastewater, waste sludge, or hazardous waste), place a check beside that category or business activity. Check all that apply. Airport Deicing Leather Tanning and Finishing Aluminum Forming Meat and Poultry Products Asbestos Manufacturing Metal Finishing Battery Manufacturing Metal Molding and Casting (Foundries) Canned and Preserved Fruit and Vegetable Processing Metal Products and Machinery Canned and Preserved Seafood Processing Mineral Mining and Processing Carbon Black Manufacturing Nonferrous Metals Forming Cement Manufacturing Nonferrous Metals Manufacturing Centralized Waste Treatment Oil and Gas Extraction Coal Mining Ore Mining and Dressing Coil Coating Organic Chemicals, Plastics, and Synthetic Fibers Concentrated Animal Feeding Operation and Feedlots Paint Formulating Concentrated Aquatic Animal Production Paving and Roofing Manufacturing Construction and Development Pesticide Chemicals Copper Forming Petroleum Refining Dairy Product Processing or Manufacturing Pharmaceutical Manufacturing Dental Office Phosphate Manufacturing Electrical and Electronic Components Manufacturing Photographic Processing Electroplating Plastics Molding and Forming (Extrusion) Explosives Manufacturing Porcelain Enameling Fertilizer Manufacturing Pulp, Paper, and Paperboard Manufacturing Ferroalloy Manufacturing Rubber Manufacturing Glass Manufacturing Soap and Detergent Manufacturing Grain Mills Steam Electric Power Generating Gum and Wood Chemicals Manufacturing Sugar Processing Hospital Textile Mills Ink Formulating Timber Products Inorganic Chemicals Manufacturing Transportation Equipment Cleaning Iron and Steel Manufacturing Waste Combustors Landfill Other: 2. Date of facility construction/operation start date or date(s) of significant process changes (for purposes of existing/new source designation if applicable): MM/YYYY Or MM/DD/YYYY Approximately 1989 Page 3 of 10 Compac International Inspection Date: 06/11/2024 Section II.B - Facility Sewer Information 1. Is the facility presently connected to a public or private sanitary sewer system? Yes/Private Yes/Public No If Yes: Are any process wastewater streams discharged directly to the public or private sewer system? Yes No Does the facility have a permit with the local POTW or are they a co-permittee on a permit to discharge untreated process wastewater to the public sewer system? Yes No Not Applicable If yes: POTW/WWTP Name _________________________________, Permit #______________________ If No, have you applied for a sanitary sewer connection? Yes No 2. Is there an on-site treatment system for process wastewater? Yes No (If yes, also See Section II.H) If Yes: Does the treatment system effluent discharge to the public sewer system? Yes No Not Applicable If Yes: Does the facility have a permit to discharge the effluent to the public sewer system? Yes No If Yes: Permit # _____________________________________ 3. List the location, diameter, and average flow of each discharge pipe that connects to the sanitary sewer system. Location of Sewer Connection Diameter of Pipe (inches) Average Flow (gpd) Unknown for regular sanitary Unknown Unknown Section II.C - Facility Operational Characteristics 1. Provide the following shift information: Mon Tue Wed Shifts (3) 8-hr shifts (3) 8-hr shifts (3) 8-hr shifts Per East Production East Production East Production Workday Building Building Building (1) 8-hr shift warehouse (1) 8-hr shift warehouse (1) 8-hr shift warehouse Thu (3) 8-hr shifts East Production Building (1) 8-hr shift warehouse Fri Sat Sun (3) 8-hr shifts East Production Building (1) 8-hr shift warehouse (2) 10-hr shifts (2) 10-hr shifts (2) 10-hr shifts (2) 10-hr shifts West Production West Production West Production West Production Building Building Building Building 2. Indicate whether the business activity is: None - West Production Building X Continuous throughout the year Seasonal Months when business operates: J F M A M J J A S O N D 3. Indicate whether the facility discharge is: X Continuous throughout the year (Typical sanitary only) Seasonal Months when discharges occur: J F M A M J J A S O N D 4. List types and amounts (mass or volume per day) of raw materials used or planned for use: Raw Material Amount Plastic resins/pellets Plastic films Not readily known - but amounts purchased are tracked in system *More specific/complete material lists are available from inventory system Page 4 of 10 Compac International Inspection Date: 06/11/2024 Section II.C - Facility Operational Characteristics (Continued) 5. List types and quantities (mass or volume per day) of chemicals used or planned for use: Chemical Quantity Alcohols (For product printing process) Not readily known Printing inks (For product printing process) Water (For product printing process) 6. Brief general description of all operations at this facility (detailed process unit information noted in Section II.F). Dry inputs to produce blown plastic tubes used to produce bags. Cooling/chilling system cools motors and blows cooled air onto plastic products after extrusion. 7. Request copies of the process diagram, flow diagram, and/or general facility diagram (if previous responses warrant more detailed information to understand the processes, flows or sewer connections). Yes No Section II.D - Spill Prevention 1. Do you have liquid storage containers (tanks, drums, totes, bins, ponds, etc.) at your facility? Yes No 2. Do you have floor drains in the manufacturing area or where liquids are stored? Yes No If yes, where do floor drains drain to? There are no floor drains. Printing ink alcohols are stored in special storage areas within the plant. 3. Indicate whether an accidental spill at your facility could lead to a discharge to any of the following. Check all that apply. On-site disposal/treatment system Ground (outside) Public sanitary sewer system Floor (inside) - Cleaned via mop Storm drain Other - Specify: 4. Does facility have a spill prevention plan to prevent spills of liquids from entering the Control Authority's collection/sewer system? Yes No N/A (No potential for spill to discharge to public sewer/collection system) Page 5 of 10 Compac International Inspection Date: 06/11/2024 Section II.E - Water Supply 1. Water Source: Municipal Water Utility Specify: City of Carbondale Name as listed on water bill: Com-Pac International Address: 800 West Industrial Park Road, Carbondale, IL 62901 Private Well Surface Water Other: 2. Provide the following information for all water usage at the facility: Type of Water Use Sanitary Non-contact cooling water (Closed loop chilling system) Boiler feeding Average Water Usage (gpd) Unknown Estimated or Measured Unknown : Make-up water can be added as needed to the closed loop system. Process Equipment/facility washdown Contact cooling water Air pollution control Irrigation and lawn watering Contained in product Other: Total: Section II.F - Wastewater Discharge Information 1. Provide the following information for all wastewater generated (gallons per day - GPD) at the facility: Type of Wastewater Average Maximum Estimated or Type of Volume (GPD) Volume (GPD) Measured Discharge Discharges To Sanitary Unknown Unknown Continuous Sanitary Non-contact cooling water Boiler blowdown Process wastewater Use table below. Equipment/facility washdown Contact cooling water Air pollution control Stormwater runoff Other: Stormwater flow to storm sewer system - no stormwater collection/ diversion on site. Closed loop vacuum tube system in place for unloading plastic pellets from rail car/hopper truck into storage, no potential contact with stormwater. Vacuum tube system also moves pellets from storage to production lines. Page 6 of 10 Compac International Inspection Date: 06/11/2024 Section II.F - Wastewater Discharge Information (Continued) 2. Provide the following information for process wastewater generated by each unit process: Unit Process Description Average Wastewater Generated (gpd) Maximum Wastewater Generated (gpd) Estimated or Measured Type of Discharge None - No wastewater generated in plastic packaging production Discharges To 3. Flow Rates for discharge of process wastewater to the sanitary sewer system: N/A Average daily flow rate (gpd): N/A Maximum daily flow rate (gpd): N/A Peak hourly flow rate (gpd): N/A Hours per day of wastewater discharge to sanitary sewer system: (e.g., 8) Mon Tue Wed Thu Fri Sat Sun 4. Do batch discharges to the sanitary sewer system occur (or will occur)? Yes No N/A Number of batch discharges per time period (specify per day, week, month, etc.): N/A Average volume per batch discharge (gal): N/A Flow rate (gpm): N/A 5. Do you have (or plan to have) continuous wastewater flow metering equipment at this facility? Yes No N/A 6. Do you have (or plan to have) automatic sampling equipment at this facility? Yes No N/A If yes, describe the present or future location of the automatic sampling equipment and describe the equipment: N/A Page 7 of 10 Compac International Inspection Date: 06/11/2024 Section II.F - Wastewater Discharge Information (Continued) 7. Has the discharge at this facility changed historically? Yes No Are any process changes or expansions planned during the next three years that could alter wastewater volumes or characteristics (i.e., substantially increase/decrease flow characteristics/flow rates) to the sewer in the future? Yes No If yes, briefly describe these changes and their effects on the wastewater volume and characteristics: N/A 8. Are any recycling or reclamation systems in use or planned? Yes No If yes, briefly describe the recovery process, substance recovered, percent recovered, and the concentration in the spent solution: No recycling of waste chemicals. No process wastewater to recycle. Facility does recycle scrap plastic material from the production process. Section II.G - Slug Discharge Control 1. Do you have the potential for a slug discharge to the sewer system? Yes No A slug discharge is any discharge of a non-routine episodic nature, including but not limited to an accidental spill or a non-customary batch discharge, which has a reasonable potential to cause interference or pass-through, or in any other way violate the POTW's regulations, local limits, or permit conditions [40 CFR 403.8(f)(2)(v)]. 2. Describe the type of potential slug discharge, including quality and content. N/A 3. Describe the current mechanisms for prevention of slug discharges. N/A Page 8 of 10 Compac International Inspection Date: 06/11/2024 Section II.H - Treatment 1. Is any form of process wastewater treatment (see list below) used at this facility? Yes No If yes, place a check beside the treatment devices or processes that are used (or will be used) for treating wastewater or sludge at this facility. Check all that apply. Air flotation Grease trap Screen Centrifuge Grinding filter Sedimentation Chemical precipitation Grit removal Septic tank Chlorination Ion exchange Solvent separation/recovery Cyclone Neutralization, pH correction Spill protection Filtration Ozonation Sump Flow equalization Reverse osmosis Rainwater diversion or storage Grease or oil separation Biological treatment: Specify Other chemical treatment: Specify Other physical treatment: Specify Other: 2. Do you have a treatment operator(s)? Yes No Not Applicable If yes, provide the following information: Name: Operator Class/Type: Title: Hours: Phone: Name: Operator Class/Type: Title: Hours: Phone: Name: Operator Class/Type: Title: Hours: Phone: Name: Operator Class/Type: Title: Hours: Phone: 3. Is any form of wastewater treatment (or changes to existing wastewater treatment) planned for this facility within the next three years? Yes No If yes, describe any changes in treatment or disposal methods planned or under construction for the wastewater discharge to the sanitary sewer and estimated completion dates. N/A 4. Does the process wastewater treatment system effluent discharge to a surface waterbody? Yes No If Yes: Does the facility have a permit to discharge the effluent directly to a waterbody? Not Applicable Yes No If Yes: Permit # _____________________________________ Page 9 of 10 Com-Pac International Inspection Date: 6/11/2024 Section II.I - Non-Discharged Wastes 1. Are any waste liquids or sludges generated and not disposed of in the sanitary sewer system? Yes If no, skip the remainder of Section II.I. If yes, list in the table below: Waste Generated Quantity (per year) Disposal Method Alcohol/ink mixtures Unknown - available in Third party contractor billing documents No 2. If any facility wastes are sent to an off-site centralized waste treatment facility, identify the facility and the wastes that it receives. N/A 3. If an outside firm removes any of the wastes, list the name, address, and permit number of all waste haulers: Name Address Permit Number (if applicable) Unknown by President - Would be available in bills and office documents 4. Have you been issued any federal, state, or local environmental permits? Yes No If yes, list the permits: Per President: Air permit. Ozone permit (for evaporation of printing ink. No limits but is tracked) 5. Describe where and how waste liquids and sludges are stored prior to disposal. Collected in drums and buckets for third party contractor to pick up. It is characterized as nonhazardous due to the dilution per Mr. Sprehe, Facility President. SECTION III - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The EPA Region 5 Lead Inspector, Anne Marie Vincent, held a closing conference at 9:15 AM (CT) on 6/11/2024. During the closing conference, Lead Inspector Anne Marie Vincent restated the purpose of the inspection survey and explained that a copy of the final survey inspection checklist will be provided to Com-Pac International, Inc. At the time of the inspection, EPA did not request any follow up documents. Communication Log EPA did not receive any additional information following the inspection. Page 10 of 10