Document 3QgGQxEO8GEgqd2KGM2vMZv80

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 MAY O2 2019 CLEAN AIR ACT INSPECTION REPORT United Alloy, Inc., Janesville, Wisconsin David Sutlin, Environmental Engineer AECAB (MN/OH) Dakota Prentice, Acting Section Chief AECAB (MN/OH) File BASIC INFORMATION Facility Name: United Alloy, Inc. Facility Location: 4100 Kennedy Rd., Janesville, Wisconsin Date of Inspection: March 5, 2019 EPA Inspector(s): 1. David Sutlin, Environmental Engineer 2. Cody Yarbrough, Environmental Engineer Other Attendees 1. Tom Baer, Chairman, United Alloy 2. Rick Sullivan, Facilities & Production Quality Manager, United Alloy 3. Vanessa Dubick, CFO, United Alloy 4. Duffy Dillon, Internal Counsel (by phone) 5. Ted Flynn, EHS Manager, United Alloy (by phone) Contact Email Address: rsullivan@unitedalloy.com (copy tombaer@aol.com) Purpose of Inspection: To determine compliance with applicable federal regulations Facility Type: metal fabrication and finishing Regulations Central to Inspection: 40 CFR Part 63, Subpart XXXXXX - National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Nine Metal Fabrication and Finishing Source Categories Arrival Time: 1:10 PM 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 United Alloy personnel unless otherwise noted. Process Description: Sheets of mild steel are fabricated to form metal enclosures including fuel tanks, trailers and housings for generators. The enclosures are then processed through finishing operations, mainly powder coating, to produce the final products. Fabrication operations at the facility include five laser cutting stations, a plasma cutter, press brake forming equipment, manual and robotic welding. Finishing operations include minimal dry grinding and four powder coating lines. Powder coating occurs in filtered booths. The laser cutters and an enclosed automatic welding unit are controlled by dust collectors. Primarily copper-coated steel wire is used in the welding operations. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: EPA observed an acid wash operation, which uses a solution containing phosphoric acid to clean the metal parts prior to powder coating. Both inspectors experienced a strong odor and temporary breathing discomfort while standing in front of the wash area. Photos and/or Videos: were not taken during the inspection. Field Measurements: were not taken during this inspection. Page 2 of3 CLOSING CONFERENCE Requested documents: SDS for powder paint and acid wash Compliance Assistance: EPA explained that the facility may be subject to the Area Source NESHAP for Nine Metal Fabrication and Finishing Source Categories, at 40 CFR Part 63, Subpart XXXXX::X. SIGNATURES Page 3 of3