Document xddaoLb7rdOzZ56pj2ko2oo3E

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 OCT 31 2019 CLEAN AIR ACT INSPECTION REPORT Energizer Holdings, Inc., Fennimore, Wisconsin Dakota Prentice, Enviromnental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Energizer Holdings, Inc. Facility Location: 100 Rayovac Court, Fennimore, Wisconsin Date ofinspection: 10/21 /19 EPA lnspector(s): 1. Dakota Prentice, Environmental Engineer Other Attendees 1. Wayne Kerrigan, Safety Health and Environmental Affairs Coordinator - Energizer 2. Dean Rindy, Senior Facilities Supervisor - Energizer 3. Michael D. Vida, Plant Manager - Energizer Contact Email Address: Wayne.Kerrigan@energizer.com Purpose of Inspection: Determine compliance with applicable State and Federal regulations Facility Type: Alkaline battery manufacturing Regulations Central to Inspection: National Emission Standards for Hazardous Air Pollutants for Chemical Manufacturing A.rea Sources, at 40 C.F.R. Part 63, Subpart VVVVVV (NESHAP VVVVVV) Arrival Time: 1:40 PM Departure Time: 3:20 PM Inspection Type: ISl Unannounced Inspection D Announced lnspection OPENING CONFERENCE ISl Credentials Presented ISl CBI warning to facility provided The following information was obtained verbally from Energizer Holdings representatives unless otherwise noted. Company Ownership: ln January 2019 Energizer Holdings purchased the facility. The facility was previously owned by Spectrum Brands as a part of its Rayovac battery unit. Process Description: The facility produces alkaline batteries. Each battery size is produced on a dedicated production line. The facility manufactures AAA, AA, C, and D sized batteries. Battery production begins with raw material delivery, including manganese dioxide. Manganese dioxide is stored onsite at internal silos. Manganese dioxide is mixed with additional compounds, granulated, and pressed into a cathode tablet. Tablets are then placed into the battery casing, which is open on one end. A separator is added to the casing followed by an anode gel including zinc and potassium hydroxide. The battery is completed by inserting a cap with a rod into the battery opening. This cap is held in place with a volatile organic compound (VOC) containing sealant. Staff Interview: The facility has three main baghouses and one vacuum dust collection system for particulate matter control. VOCs are controlled by a thermal oxidizer. The facility transitioned to a registration permit in approximately 2010. The facility is in the process of installing an additional battery production line. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: EPA walked the production process from cathode mixing to battery labelling and observed the thermal oxidizer. Photos and/or Videos: were taken during the inspection. See Appendix A. Page 2 of 4 Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Requested documents: Most recent performance test conducted at the thermal oxidizer Compliance Assistance: EPA used an infrared camera designed to identify voes during the tour of production areas of the plant. EPA informed Energizer representatives that the infrared camera did not detect VOes during the tour. Concerns: EPA informed Energizer representatives that the facility may be subject to the requirements ofNESHAP VVVVVV. ~~ SIGNATURES Report Author: / , : ') . ~ Section Chie~ 4 ~ Date: (c?/Z S/ l'3 Date: / &I /' 3/l/lo/ Page 3 of 4 Facility Name: Energizer Holdings, Inc. Facility Location: I 00 Rayovac Court, Fennimore, Wisconsin Date of Inspection: I 0/21/19 APPENDICES AND ATTACHMENTS I. Appendix A - Photo Log 2. Confidential Business Information Attachment Page 4 of 4 Facility Name: Energizer Holdings, Inc. Facility Location: 100 Rayovac Court, Fennimore, Wisconsin Date oflnspection: 10/21/19 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: D. Prentice 3. Company/Facility Name: Enern.izer Holdirnrs, Inc. 5. Number of Images: 3 2. Date(s) ofinspection: 10/21/19 4. Street Address, City, State: 100 Rayovac Court, Fennimore, Wisconsin 6. Archival Record Location: CD-R labelled as "Energizer - Fennimore, WI Photo Log" Image Number 1 2 3 File Name PA210001.JPG PA210002.JPG PA210003 .J PG Date and Time (incl. time zone and DST) 2019:10:2114:50:19 2019:10:2114:57:23 2019:10:2115:11:17 Description of Image Cathode Mixing Accumulation Table - AA Line Thermal Oxidizer Appendices Page 1 of 1