Document 3NYy704zEJk5QbN4gG2xYXJ9x

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT H. Kramer & Co., Chicago, Illinois FROM: DeMarkus Hodge, Environmental Engineer AECAB (MI/WI) THRU: Sarah Marshall, Section Supervisor AECAB (MI/WI) TO: File BASIC INFORMATION Facility Name: H. Kramer & Co. Facility Location: 1345 West 21st St, Chicago, IL 60608 Date of Inspection: February 4, 2025 EPA Inspector(s): 1. DeMarkus Hodge, Environmental Engineer 2. Charles Hall, Environmental Engineer Other Attendees: 1. Cory Henry, Plant Superintendent 2. Adam Chapman, Executive VP 3. Sanchay Kumar, Safety Manager Contact Email Address: henryc@hkramer.com Purpose of Inspection: The purpose of this inspection is to determine compliance with 40 C.F.R. Part 63, Subpart TTTTTT Facility Type: Secondary nonferrous metals processing facility Regulations Central to Inspection: 40 C.F.R. Part 63, Subpart TTTTTT Facility Name: H. Kramer & Co. Facility Location: 1345 West 21st St Date of Inspection: February 4, 2025 Arrival Time: 9:40 AM CST Departure Time: 12:00 PM CST Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Provided CBI warning to facility Was any information collected during the inspection claimed as CBI? Yes No. The following information was obtained verbally from H. Kramer & Co. staff unless otherwise noted. Process Description: H. Kramer & Co. (H. Kramer) describes itself as a secondary nonferrous metals processing facility. H. Kramer produces brass ingots that have a wide range of applications. H. Kramer uses a variety of scrap to charge in their melting operations. H. Kramer charges scrap that requires less processing of the material in a coreless induction furnace. It charges the scrape that needs more refinement in a gas rotary furnace. H. Kramer has two gas rotary furnaces and three coreless induction furnaces. After the H. Kramer charges the scrap in the furnaces, the scrap is melted at the desired temperature. Once the heat is within specification, it pours the metal into molds, cools, and stacks the metal on pallets for shipment to customers. H. Kramer routes the emissions from the gas rotary furnaces to the north and south baghouses, while the emissions for the coreless induction furnaces are sent to Baghouse #4. The north and south baghouses have a HEPA filter to further control emissions from the scrap melting operations. Staff Interview: H. Kramer operates the rotary furnaces 5 days a week and the coreless induction furnaces 6 days a week. H. Kramer employs 105 employees. H. Kramer uses a bar code to identify and maintain scrap in their inventory. It scans each scrap shipment and analyzes them to fulfill different material compositions required for orders. The coreless induction furnaces run completely on electricity. The gas rotary furnaces have a water jacket on the charge door and the burner is air cooled due to increased safety and efficiency. H. Kramer produces most of the product in the gas rotary furnaces. Page 2 of 5 TOUR INFORMATION EPA Toured the Facility: Yes Facility Name: H. Kramer & Co. Facility Location: 1345 West 21st St Date of Inspection: February 4, 2025 Data Collected and Observations: During the inspection, EPA visited the scrap storage area, gas rotary furnaces, coreless induction furnaces, and the baghouses associated with the gas rotary and coreless induction furnaces. EPA observed a variety of scrap used for producing brass ingots in the scrap storage area. EPA observed the coreless induction furnaces while the scrap melting operation occurred. During the scrap melting operation, the coreless induction furnace charged scrap using a charging box. In the coreless induction area, there were multiple emergency stops (e-stop) around the furnaces. H. Kramer uses the e-stops to manually halt the furnace operation. Next, EPA observed the melting and pouring operation occuring in the gas rotary furnace #2. Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Operational logs for all furnaces from February 2024 - February 2025; Maintenance and repair records for Rotary furnaces #1 and #2 from February 2024 - February 2025; Charge Sheets for Rotary furnaces #1 and #2 from February 2024 - February 2025; Most recent performance test for all baghouses; Monitoring plan for all baghouses; Pressure drop over time data for all baghouses from November 2024 - February 2025; Baghouse Inspections documents for all baghouses from February 2024 - February 2025; and Facility Map. DIGITAL SIGNATURES DEMARKUS Digitally signed by DEMARKUS HODGE HODGE Date: 2025.03.18 07:27:05 -05'00' Report Author: _________________________________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL MARSHALL Date: 2025.03.18 07:32:34 -05'00' __________________________________ Page 3 of 5 APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log Facility Name: H. Kramer & Co. Facility Location: 1345 West 21st St Date of Inspection: February 4, 2025 Page 4 of 5 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Facility Name: H. Kramer & Co. Facility Location: 1345 West 21st St Date of Inspection: February 4, 2025 Inspector Name: Charles Hall Archival Record Location: Electronic Record Center (ERC) Image Number 1 2 3 4 5 6 7 8 9 10 11 12 File Name P2040001.JPG P2040002.JPG P2040003.JPG P2040004.JPG P2040005.JPG P2040006.JPG P2040007.JPG P2040008.JPG P2040009.JPG P2040010.JPG P2040011.JPG P2040012.JPG Date and Time (CST) 2/4/2025 - 11:05 AM 2/4/2025 - 11:06 AM 2/4/2025 - 11:08 AM 2/4/2025 - 11:09 AM 2/4/2025 - 11:10 AM 2/4/2025 - 11:10 AM 2/4/2025 - 11:11 AM 2/4/2025 - 11:19 AM 2/4/2025 - 11:36 AM 2/4/2025 - 11:39 AM 2/4/2025 - 11:39 AM 2/4/2025 - 11:39 AM Description of Image Electric Furnace Electric Furnace Charge box preparing for charging of electric furnace Charging electric furnace Hood lifting in charging operation Charging of electric furnace Flame during charging of the electric furnace Differential pressure of baghouse #4 Gas furnace pouring from rotary furnace #2 Rotary gas furnace #2 Rotary gas furnace #2 Rotary gas furnace #1 Page 5 of 5