Fri) 13"?8 C376) State of Wisconsin DEPARTMENT OF NATURAL RESOURCES 2300 N. Dr. Martin Luther King, Jr. Drive walker' G?Vem?r Milwaukee WI 53212-3128 cathy Steppr secretary Telephone 608-266-2621 WISCONSIN Toll Free 1-888-936-7463 DEPT.OFNATUHALRESOUHCES TTY Access via relay - 711 November 2, 2015 Mr. Mark Furgason Site Manager CLCM St. Francis - 3950 Ave. Saint Francis, WI 53235 LETTER OF NONCOMPLIANCE Dear Mr. Furgason, Thank you for allowing us to review your process operations today. The purpose of this letter is to notify CLCM St. Francis of operating in potential noncompliance with Wisconsin?s malodorous emissions regulations. This regulation states, in part, that no person may cause, allow 01' permit emission into the ambient air of any substance or combination of substances in such quantities that an obj ectionable odor is determined to result. The department received an odor complaint on October 30, 2015. In response, I performed an odor survey of the area around your facility and the impacted downwind residential area located to the northeast of your plant (NE of Howard Ave and Hwy 32). The winds were 10 to 15 and from the southwest. Within the residential neighborhood, the odor was identi?able and consisted of a melted plastic odor accompanied by a waste water type odor. As I approached your facility the intensity increased to the point I felt a burning sensation in the back of my throat and sinuses. This observation was made at 11:46 am when approximately 200 yards downwind of your facility. The odors were signi?cant, obnoxious and objectionable. This letter serves to notify CLCM St Francis of my observations and the potential noncompliance situation attributable to the CLCM St Francis operations with respect to malodorous emissions. I returned in the afternoon to review the operations at CLCM St Francis. 1 informed you of the complaint and requested to review the operations at your facility. During our visit, we observed the facility in full production, both steel and plastic containers were being processed. Within the plant, the objectionable odors were identified to those observed in the morning. We noted the large east and west overhead doors were open and blue smoke being emitted from the steel drum curing oven (just inside the east overhead door). While on the roof, we observed a rust colored discharge from the new scrubber stack. This discharge also appears to be depositing 011 the CLCM St Francis roof as the roof is smattered with rust colored stains and centralized around the scrubber discharge stack. The colored discharge indicates this stack may be discharging particulate matter to a degree that is excessive or indications of an upset condition within the scrubber. To this end, CLCM St Francis is requested to respond to the following, within 10 business days of your receipt of this letter: During the operations of 11/032015: 1. Please identify any upset conditions that may have contributed to the observations made. 2. Please provide a copy of the scrubber pH records for each scrubber (hydrochloric acid) and (sodium hydroxide) showing hourly pH values, scrubber liquor ?ow rate and when the respective process line was operating. dnr.wi.gov Wisconsingcv Naturally Page 2 For the facility operations: 3. Please prepare and submit an odor initigatiOn plan. This plan should address each odor source and steps the company will take to abate or control malodors from each source. Please include steps the facility will take to contain fugitive process emissions/odors within the building and not allow untreated passage to the outdoors. (if additional time is necessary to complete an evaluation and prepare a plan, submit a request for additional time but include a timeline for each step to be completed.) 4. Please submit a malfunction prevention and abatement plan for each scrubber. Within each plan provide process description and design details identifying process stream ?ow rates, monitoring parameter and operating ranges (pH, differential pressure ranges, scrubber ?ow rates GPM), influent concentrations and discharge concentrations. Describe how the control devices are connected to each process and each is operated with respect to the process manually or PLC controlled). What setpoints for the control device will shut down the process if exceeded? 5 . Please investigate the rust colored discharge from the large scrubber and determine the source of this material. If this is breakthrough from the scrubber, please address this with maintenance procedures within the malfunction prevention and abatement plan. If it is from the induce draft fan, please address potential acid or caustic carryover within the control system and what corrective actions will be initiated and when. In closing, thank you for your time and attention to the concerns raised. This letter of noncompliance may be closed out when satisfactory measures are taken to abate and control such emissions. If you have any questions or require additional time to prepare a response, please feel free to contact me at (414) 263 ?85 54. Respectfully Yours, Michael Grif?n Air Management Engineer Southeast Region - Milwaukee Service Center Cc: BAM Case File this 344 lgi? ?70 November 13, 2015 VIA EMAIL Mr. Mike Griffin Air Management Engineer Wisconsin Dpartment of Natural Resources Southeast Region Air Program Milwaukee Service Center 2300 N. Dr. Martin Luther King 111, Dr. Milwaukee, WI 53212 Mike.Griffin@Wisconsin. gov RE: November 2, 2015 Letter of Noncompliance CLCM St. Francis Permit Facility Number 341158070 Dear Mr. Griffin, Container Life Cycle Management (CLCM) St. Francis is submitting this response to the November 2, 2015 Letter of Noncompliance. 1. 5. Identify any upset that may have contributed to the observations made. inn a {fie Eititii iri'ii?i??tar m- .r Ln: in; midi {can i . . . . t. if.) (Hz: Jig-i i gain.- rib.? {grime if; brim ?it: ism-- Hilts lift. .. .. .- Hal air-3 a?s?vii a} .i'g?mil with iirif 31:51.51) alt-if. Hi" li ii} is} (2.) Hit}?! (refill farm fire-f i-iifiifi'iililf ruff. "Heart :?ri?e?tfrfie?l?iint-?Iii, r. i - it's.? mains". it! MRI with??! irin? I. .- 031" ilir {Lia} {rift}; :i r?ste ?in? :73; Ull?'tfl tantrum tint-2? ?arirg?iy'iirfi new: ,wr'riaii'ira: i u) mtg-itanxieties; i iniftrsiarii slit-f i=2 Mr.- within Hi .r Lilli." gin-Hr!) itii.? with"! Ni: ii: tilt? gift?; Hfri I i . tun-1?- -i In. -.-.- ., ii. :tm Lin); .3: :3 a: man-5.? eh. .- liar-.1: (in: im, Hi mi? nit-J {sit-xi . if (in: rows. E-I Irmr Mint; Marta?? (ii-Ids {Fifw'lirirt .x in: Us} Hit? 3. . a i r- .Iasiia's?a tile-rifts rim; (.5 .rsisiaifii?i Uzi Ammo. {Niki ail-m.- i? to {he inc h'iiltfii he as; Lia-st is or rains; it??'df Haitian {ire Please investigate the rust colored discharge (observed on November 2, 2015) from the large scrubber and determine the source of this material. If this is breakthrough from the scrubber, please address this with maintenance procedures within the malfunction prevention and abatement plan. If it is from the induce draft fan, please address potential acid or caustic carryover within the control system and what corrective actions will be initiated and when. Mr. Mike Griffin November 13 2015 Page 2 From November 4 through 13, 2015, multiple facility personnel visually observed on a daily basis the opacity and color of the discharge from the Caustic Wet Scrubber?s stack. At no times was there a coloration noted for the discharge. The facility also reviewed the records of the clients that sent drums that were processed on November 2, 2015. Typical drums from these clients, including those that were onsite from November 4 through 13, 2015, did not have any residue that would logically create a rust-color discharge. For this time period the facility also investigated its other various potential sources of malodorous emissions. a All incoming drums were inspected/smelled for off-smelling residue. 0 Vents leading to the Acid Scrubber and the Caustic Wet Scrubber were visually inspected to confirm no breakage. The Caustic Wet Scrubber?s fans, pumps, and pressure gauges were all inspected for proper operations. a The Caustic Wet Scrubber and stack were visually inspected for any channeling, breakthrough, bypasses, clogs, etc. The pH for the discharge from the Acid Scrubber, the in?uent of the Caustic Wet Scrubber, and for the ef?uent of the Caustic Wet Scrubber were checked (see Tables 2a. and 2b. below). 0 Acid and caustic addition rates were reviewed. No issues were observed that indicated malfunctions, and no issues were cited of atypical odors. Even so, the facility will start recording pH values of the discharges coming off of the two scrubber?s to confirm operational compliance. This is above-and-beyond current air permit requirements. 2. Please provide a copy of the scrubber pH records for each scrubber (hydrochloric acid) and (sodium hydroxide) showing hourly pH values, scrubber liquor ?ow rate and when the respective process line was operating. On November 4, 2015, facility personnel logged the following records for the Caustic Wet Scrubber and Acid Scrubber. The results are listed below. Mr. Mike Griffin November 13, 2015 Page 3 Table 2a. November 4, 2015 Caustic Wet Scrubber Records Caustic Wet Scrubber Time Discharge pH Liquid Flow Line in Operation? 5:00 am. No 6:00 am. 7.0 Yes 7:00 am. 7.0 Yes 8:00 am. 7.0 Yes 9:00 am. 7.0 Yes 10:00 am. 7.0 450-500 gal/min Yes 11:00 am. 7.0 Yes 12:00 pm. 7.0 Yes 1:00 pm. 7.0 Yes 2:00 pm. 70 Yes 3:00 pm. 70 Yes Table 2a. November 4, 2015 Acid Wet Scrubber Records Acid Wet Scrubber Time Discharge pH Liquid Flow Line in Operation? 5:00 am. No 6:00 am. 9.7 Yes 7:00 am. 9.3 Yes 8:00 am. 9.8 Yes 9:00 am. 9.7 Yes 10:00 am. 9.4 3468 gal/min Yes 11:00 am. 9.4 Yes 12:00 pm. 9.8 Yes 1:00 pm. 9.8 Yes 2:00 pm. 9.7 Yes 3:00 pm. 9.4 Yes 3. Please prepare and submit an odor mitigation plan. This plan should address each odor source and steps the company will take to abate or control malodors from each source. Please include steps th facility will take to contain fugitive process emissions/odors within the building and not allow untreated passage to the outdoors. Attached is a new Odor Prevention and Abetment Plan for the CLCM St. Francis facility. Mr. Mike Griffin November 13, 2015 Page 4 4. Please submit a malfunction prevention and abatement plan for each scrubber. Within each plan provide process description and design details identifying process stream ?ow rates, monitoring parameter and operating ranges (pH, di??erential pressure ranges, scrubber ?ow rates), in?uent concentrations, and discharge concentrations. Describe how the control devices are connected to each process and each is operated with respect to the process e. manually or PLC controlled). What set-points for the control device will shut down the process if?erceeded? Attached is the updated Malfunction Prevention and Abatement Plan for the CLCM St. Francis facility. Please let us know if you have additional comments or questions related to this issue. Sincerely, Container Life Cycle Management W2 Mark-Fu/rgason General Manager Enclosures cc: Scott Swosinski CLCM Amy Litscher Saga Environmental and Engineering, Inc.