Document yb49pQwJYLJa8ozry01Ga0vnE

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 MAR. 2 2 2019 CLEAN AIR ACT INSPECTION REPORT ITW Specialty Films Gregory Gehrig, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Chief AECAB (MI/WI) File BASIC INFORMATION Facility Name: ITW Specialty Films Facility Location: 500 State Street, Chicago Heights, IL Date of Inspection: March 15, 2019 EPA Inspectors: 1. Gregory Gehrig, Environmental Engineer 2. Eleanor Kane, Environmental Engineer Other Attendees: 1. Paul Gniadek, Facilities Engineering Manager, ITW Specialty Films Contact Email Address: pauLgniadek@itwsf.com Purpose of Inspection: CAA Compliance Facility Type: Web coating Regulations Central to Inspection: SIP, NSPS and MACT Arrival Time: 1245 hrs Departure Time: 1445 hrs Facility Name: ITW Specialty Films Facility Location: 500 State Street, Chicago Heights, IL Date of Inspection: March 15, 2019 Inspection Type: IZI Unannounced Inspection D Announced Inspection OPENING CONFERENCE IZI Credentials Presented IZI CBI warning to facility provided The following information was obtained verbally from facility persmmel. Company ownership information was also obtained from the company website. Company Ownership: ITW Specialty Films division is part of the Specialty Products segment of Illinois Tool Works Inc., a Fortune 200 global manufacturing company headquartered in Glenview, IL. ITW Specialty Films is comprisedofITW Brand Identity (including CFC, CFC Europe, and Coding Products). This facility was formerly known and is sometimes still identified as CFC International. The facility has had the same ownership since at least 2013. Process Description: The ITW Specialty Films (ITW) facility embosses coatings on a polyethylene, PVC and polyester substrates that are received on rolls. Dyes are ground and mixed in solvents, including toluene, isopropyl ketone MEK and MIK. These materials are mostly hard piped from an outdoor tank farm to a mixing and grinding room where they are mixed and milled. Some solvents and dyes are held in drums and totes. Once mixed, coatings are applied to substrates in six coaters and 3 presses in a permanent total enclosure (PTE). Volatile organic compounds (VOCs) emitted from these coaters and presses are controlled by 4 regenerative thennal oxidizers (RTOs). One RTO is dedicated to coater C-22. The other 3 RTOs operate as necessary to control emissions from the remaining coaters and presses. Fans draw emissions via ducts associated with each coater and press while in operation. Coaters and presses cannot operate if the ducts are not drawing emissions to an operational RTO. Mixing drums are cleaned with solvent in the mixing and grinding room. VOC emissions from the mixing and grinding room are uncontrolled. Pressure drop at the duct inlet for each coater and press is monitored (i.e. facial pressure drop), but pressure drop across non-draft openings is not monitored for the PTE. Products are rolled for delivery to customers. No finishing is performed at this facility. The facility is subject to NESHAP Subpart JJJJ for Web Coating. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: EPA utilized a FUR camera (MOY files) and regular camera (IMG files) to observe process operations and collect images. Page 2 of 4 Facility Name: ITW Specialty Films Facility Location: 500 State Street, Chicago Heights, IL Date of Inspection: March 15, 2019 At the time of inspection, the facility was operating normally. VOCs were observed with the FLIR camera from: A tank being cleaned in the mixing and grinding room. Coater C-9. Field Measurements: were not taken during this inspection. RECORDS REVIEW Facility layout (taken). Process description (taken). CLOSING CONFERENCE Requested documents (to be provided via email): NESHAPs Subpart JJJJ Notice of Compliance Status. Any pressure monitoring for the PTE, including NDOs. Most recent performance test for each RTO. Any capture monitoring plan for the PTE. SIGNATURES Lead lnspector~ / L/, Section Chief: c:.......=..---=-..,,c__-=-~ ----=:c...._----- ate: J:-).. 0 - AO/"') Date: 3 7/ 2 2 / 7 I <-[ Page 3 of 4 Facility Name: ITW Specialty Films Facility Location: 500 State Street, Chicago Heights, IL Date of Inspection: March 15, 2019 DIGITAL IMAGE LOG* 1. Photographer: Gregory Gehrig, FLIR video and Eleanor Kane, photos 3. Company/Facility Name: ITW Specialty Films 5. Number of Images: 8 2. Date(s) of Inspection: March 15, 2019 4. Street Address, City, State: 500 State Street, Chicago Heights, IL 6. Archival Record Location: CD-R labeled ITW Images 3.15.2019 Date and Image name Time* (CDT) Description 3/15/2019 IMG 0740.JPG 13:50 Hard piping into mixing and grinding room. 3/15/2019 IMG 0741.JPG 13:54 Mixing tank. 3/15/2019 IMG 0742.JPG 13:57 Cleaning a mixing tank. 3/15/2019 IMG 0743.JPG 14:01 Mixing and grinding area. 3/15/2019 IMG 0744.JPG 14:05 Tank farm. 3/15/2019 MOY 0032.mp4 19:52 Cleaning a mixing tank. 3/15/2019 MOY 0033.mp4 20:00 Tank farm. 3/15/2019 MOV 0034.mp4 20:08 Coating line C-9. *time stamp on MOY images (videos) is EDT. Page 4 of 4