Document 3evZ452GMZV95v4QpDjQejdZ3

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEYARD CHICAGO, ILLINOIS 60604 DEC 1 9 2019 CLEAN AIR ACT INSPECTION REPORT Battery Builders Inc., Naperville, Illinois Daniel Heins, Environmental Scientist AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Battery Builders, Inc. (BBI) Facility Location: 31 W. 238 91st Street, Naperville, Illinois Date of Inspection: 12/16/2019 EPA Inspector(s): 1. Daniel Heins, Environmental Scientist 2. Jason Schenandoah, Environmental Engineer 3. Karina Kuc, Environmental Scientist Other Attendees 1. Jim Hanslik, President - BBI 2. Chris Gatrel, Health & Safety Engineer - BBI Contact Email Address: chris.gatrel@batterybuilders.com Purpose of Inspection: To determine compliance with State and Federal regulations. Facility Type: Industrial lead-acid battery manufacturer Arrival Time: 11 :55AM Departure Time: 12:45PM Inspection Type: l2l Unannounced Inspection D Announced Inspection OPENING CONFERENCE l2l Credentials Presented l2l CBI warning to facility provided The following information was obtained verbally from BBI representatives unless otherwise noted. Company Ownership: Invision Capital bought Battery Builders in June 2017, retaining previous management on-site. Process Description: Lead alloy ingots are delivered to the facility via truck. The ingots are melted down and cast into grid plates. Grid plates form the base of the battery. Grid plates are then brought to the pasting room. In the pasting room, lead oxide, water, and acid are mixed to form a paste, which is used to fill the voids in the grid plates. The filled plates are then conveyed through an oven and curing chamber to cure the paste. Cured plates that are designated to be positively charged are sent to the plate wrapping machine, which wraps each plate in fiberglass to act as a nonconductive barrier between negative and positive plates. Plates next go to one of two Cast-On-Strap (COS) machines, where they are grouped to form battery cells and positive and negative bars are affixed to the battery cell. There is an older, manually run machine that was made by TBS Engineering (the "TBS COS"), and a newer, automated machine made by MAC Engineering and Equipment (the "MAC COS"). The cells are brought to the formation room, water and acid levels are adjusted to specification, and the batteries are charged. After charging, cells are put into battery trays and final touches are added, resulting in completed batteries ready to be shipped to customers via truck. The complete process, from casting to finished product, takes roughly threeweeks. Emissions from all stages of the manufacturing process from grid casting through the COS machine are routed to one of three baghouses. The plate wrapping and TBS COS machine areas have an integrated ventilation system, which can route emissions from just the plate wrapping and stacking area or both the plate wrapping and stacking process and the TBS COS machine areas to a baghouse. The integrated ventilation system is manually switched between operating modes depending on if the TBS COS is in use. Staff Interview: Around 2017/2018, the facility upgraded equipment and ran an emissions stack test in association with a construction permit issued for the MAC COS. The permit replaced most operations of the TBS COS machine with the MAC COS machine and subsequently increased production and reduced worker lead exposure. The modem MAC COS machine is primarily in operation, though the older TBS COS machine normally operates about 4 hours a day in the evening. Based on improved performance test results in their emissions stack test, BBI may seek to re-open its permit with the state again to increase production and operating hours. Page 2 of 4 All baghouses are typically operated with a pressure drop in the range of 2"-5" of water, with pressure drop manually recorded daily. The pasting process and the MAC COS have their own baghouses. Filter changes are initiated when pressure drops approach 4.5-5" water. Dust is collected in drums from the baghouses and sent off site for recycling. Formulation room acid mist is vented through filters. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: The baghouse that serves the pasting area had a pressure drop of 4" water. The MAC COS baghouse was at 4" water. The baghouse serving the plate wrapping area had a pressure drop at 0.5'' water. Mr. Gatrel stated that they had just replaced the baghouse filters and that the pressure drop would go up to approximately 2" of water if the integrated ventilation system started routing emissions from both the plate wrapping and TBS COS machine processes. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Schematic obtained of ventilation for plate wrapping and TBS cast on strap machine CLOSING CONFERENCE Requested documents: Most recent emissions stack test SIGNATURES I 9 Report Author: __::~~'-1-~~-;---=._-.==::::::::====-1.Jate: _/_z_)_f J_J_'J__ /,t / 4 , ( 1 /9 7 / Page 3 of 4 Facility Name: Battery Builders, Inc. Facility Location: 31 W. 238 91st Street, Naperville, IL Date of Inspection: December 16, 2019 APPENDICES AND ATTACHMENTS Appendix A - Digital Image Log Page 4 of 4 Facility Name: Battery Builders, Inc. Facility Location: 31 W. 238 91st Street, Naperville, IL Date of Inspection: December 16, 2019 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Karina Kuc I 2. Archival Record Location: CD-R labeled "Battery Builders, Inc.; Naoerville, IL; Inspection Pies; 12/16/2019" Image Number 1 File Name PCJ 60004.JPG Date and Time (CST) 2019:12:16 12:19:22 Latitude and Longitude 41.708889, -88.207222 Description of Image Pasting ventilation 2 PC 160005 .JPG 2019:12:16 12:25:52 41. 708889, -88.207222 Gauge at 0.5'' for plate wrapping baghouse 3 PCJ60006.JPG 2019:12:16 12:25:57 41. 708889, -88.207222 Control indicating baghouse operation for wrapping/stacking and TBS COS machine areas Appendices Page 1 of 1