Document 4aE3Mrby59Rmor41LyxX2MORQ

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Horsburgh & Scott, Cleveland, Ohio FROM: Brianna Fenzl, Environmental Engineer AECAB (IL/IN) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: Horsburgh & Scott Facility Location: 5114 Hamilton Avenue, Cleveland, Ohio Date of Inspection: April 23, 2024 EPA Inspector(s): 1. Brianna Fenzl, Environmental Engineer 2. Charles Hall, Environmental Engineer Other Attendees: 1. Andrew Pauken, Maintenance Manager 2. Rodie Zcevic, Maintenance Employee 3. Jacob Stringfield, Paint Booth Operator 4. David Turner, Assembly Manager Contact Email Address: amp@horsburgh-scott.com Purpose of Inspection: To determine compliance with Ohio Permit-to-Install and Operate (PTIO) Facility Type: Gear and Gearbox Manufacturer Regulations Central to Inspection: Ohio PTIO Facility Name: Horsburgh & Scott Facility Location: 5114 Hamilton Avenue, Cleveland, Ohio Date of Inspection: April 23, 2024 Arrival Time: 8:30 AM Departure Time: 10:12 AM Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Provided via email after inspection. Small Business Resource Information Sheet not provided. Provided CBI warning to facility The following information was obtained verbally from Horsburgh & Scott unless otherwise noted. Process Description: Horsburgh & Scott is a manufacturer of gears and gearboxes. Throughput varies due to customer demand. Metal is forged, then forgings are grinded, welded, shaped, and painted if needed. Gears are painted in a three-walled paint booth. Horsburgh & Scott's PTIO requires the facility to use a dry filtration system for the control of particulate emissions when the paint booth is in use. The paint booth has a wall of fiberglass and cotton filters that are changed out depending on use. An air blower pulls air from the inside of the booth out and through the filters. Horsburgh & Scott uses all waterbased paint and paint usage is tracked by the safety director. Paint usages are then used to track volatile organic compounds (VOCs), as required by Horsburgh & Scott's PTIO. There is a carburizing furnace down the street from the main facility that is used to heat-treat and harden approximately one-third of gears. The gear is heated while carbon gas is injected into the furnace. Staff Interview: Horsburgh & Scott operates 24 hours a day, 7 days a week with approximately 200 employees. A third-party consultant, the Dell Group, is used by the facility for its emissions tracking and compliance. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: EPA toured the facility and observed the paint booth, paint booth filters and vent, gear manufacturing (grinding, welding, shaping) process units, and final packaging area. Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Facility Name: Horsburgh & Scott Facility Location: 5114 Hamilton Avenue, Cleveland, Ohio Date of Inspection: April 23, 2024 Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Daily spray paint usage log CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Safety Data Sheet's for paints used Last year of VOC emissions calculated at paint booth Inspection log of filter change outs at paint booth DIGITAL SIGNATURES BRIANNA Digitally signed by BRIANNA FENZL Report Author: _____F_E__N_Z_L________17_:3_9:4_9_-0_5'_00_' ________ Date: 2024.06.13 Section Supervisor: NATHAN Digitally signed by NATHAN FRANK _____F_R__A_N_K_______1_4_:18_:4_5_-0_5'_00_' _________ Date: 2024.06.17 APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log Facility Name: Horsburgh & Scott Facility Location: 5114 Hamilton Avenue, Cleveland, Ohio Date of Inspection: April 23, 2024 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Charles Hall Archival Record Location: AECAB Library > Enf_HorsburghScott_OH_24 > Inspection Photos Image Number 1 File Name P4230248.JPG Date and Time (incl. Time zone and DST) 4/23/2024, 8:46 AM CST Description of Image Paint booth P4230249.JPG 4/23/2024, 8:46 Paint booth filter wall 2 AM CST P4230250.JPG 4/23/2024, 8:47 Duct work behind paint 3 AM CST booth P4230251.JPG 4/23/2024, 8:59 Crane inside facility 4 AM CST