Document 3N85M14aqxYZjvM1bJMreR1BJ

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 DATE: SUBJECT: FROM: THRU: TO: May 26, 2021 CLEAN AIR ACT INSPECTION REPORT Libra Industries, Inc., Chicago, Illinois Emma Leeds, Environmental Engineer AECAB (IL/IN) Constantinos Loukeris, Acting Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Libra Industries, Inc. Facility Location: 1951 Arthur Ave., Elk Grove Village, IL 60007 Date of Inspection: April 29 & 30, 2021 EPA Inspector(s): 1. Emma Leeds, Environmental Engineer 2. Karina Kuc, Environmental Engineer 3. Daniel Heins, Environmental Scientist 4. Brianna Fenzl, Environmental Engineer Other Attendees: 1. Charles Lagoni - Libra Industries, Inc. 2. Bill Maki - Libra Industries, Inc. 3. Jennifer Kinsella - Libra Industries, Inc. Contact Email Address: Clagoni@librasafety.com Purpose of Inspection: To determine compliance with the Clean Air Act 40 CFR 63 Subpart M - Dry Cleaning NESHAP Facility Type: Industrial dry-cleaning and reconditioning for personal protective equipment Virtual Conference (4/29) Start Time: 1:00 PM Virtual Conference (4/29) End Time: 2:30 PM On Site (4/30) Arrival Time: 12:30 PM On Site (4/30) Departure Time: 1:15 PM Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Provided CBI warning to facility The following information was obtained verbally from Libra Industries, Inc. representatives. Process Description: Libra Industries, Inc. (Libra) cleans soiled personal protective equipment (PPE) for their industrial customers and returns the cleaned items for reuse. Libra predominantly clean gloves but also accept other types of PPE clothing. Eight perchloroethylene (PCE) dry-cleaning machines and five halogen-free organic solvent dry-cleaning machines are used to clean the soiled PPE materials. After dry-cleaning, materials are hand inspected on-site before they are sent back to their owners. The facility also has standard washing and drying machines that are used for certain materials. To control volatile organic compound (VOC) and hazardous air pollutant (HAP) emissions created from the dry-cleaning process, each machine uses a refrigerated condenser with the exhaust passing through an activated carbon absorber. Concentrated dirty PCE is sent through a piping system to a Hydro-tech cooking machine which recycles PCE through a distillation process. The recovered PCE is sent back to dry-cleaning machines and the waste cake, composed of oils, metals and soil, is disposed as hazardous waste. The PCE recycling system is fully enclosed. Staff Interview: The facility began using the halogen-free organic solvent in 2008 to reduce perchloroethylene use. The halogen-free organic solvent machines are predominantly used for cotton materials and are not used for any leather or other skins because they leave a residue odor in these materials. A photoionization detector is used to check the seals on the perchloroethylene machines and related piping on a weekly basis as part of the leak detection and maintenance plan. Page 2 of 4 TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: Libra has not been using their Hoyt Sentinel - DF 2000 dry-cleaning machine because it is not as efficient as the other machines. The carbon absorbers for the dry-cleaning machines are changed every two months. Photos and/or Videos: were not taken during the inspection. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Reviewed documents: 2019 Clean Air Act Permit Program permit Overview of emissions units and controls Process flow diagram for facility Monthly solvent use and VOC emissions for 2019 and 2020 Requested documents: PCE calculation spreadsheet Carbon absorber exhaust values Leak inspection records SIGNATURES Digitally signed by Emma X Emma Leeds Leeds Date: 2021.05.26 15:28:23 -05'00' Emma Leeds Report Author X CONSTANTIN Digitally signed by CONSTANTINOS LOUKERIS OS LOUKERIS Date: 2021.06.08 23:58:35 -05'00' Constantinos Loukeris Section Chief Page 3 of 4