Document 5b50a0ypX1axYeG8bLLm736Qe

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Bluewater Thermal Solutions LLC Manojkumar P Patel, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Bluewater Thermal Solutions LLC Facility Location: 75 East Lake Street, Northlake, IL 60164 Date of Inspection: 01/25 and 1/26/2023 EPA Inspector(s): 1. Manojkumar P Patel, Environmental Engineer Other Attendees: 1. Mike Andersons, Safety Manager, Bluewater Thermal Solutions LLC 2. Tyrone Pearson, General Manager, Bluewater Thermal Solutions LLC 3. Rutilio Torres, Maintenance Supervisor, Bluewater Thermal Solutions LLC 4. Jesus Quiroga, Union Representative, United Steelworkers Local 9777, District 7 Contact Email Address: tpearson@bluewaterthermal.com Purpose of Inspection: Compliance Inspection for the Chemical Accident Prevention Provisions (CAPP) Facility Type: Metal heat treatment NAICS Code: 332811 Regulations Central to Inspection: 40 C.F.R. Part 68 Arrival Time: 9:20 AM CST Facility Name: Bluewater Thermal Solutions LLC Facility Location: 75 East Lake Street, Northlake, Illinois 60164 Date of Inspection: January 25, 2026 Departure Time: 1:30 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. Reason: Small Business Category was not determined at the time of the inspection Provided CBI warning to facility The following information was obtained verbally from the facility personnel unless otherwise noted. Process Description: Bluewater is a commercial heat treatment facility which utilizes electric and natural gas heat treated furnaces to perform several manufacturing processes to produce customized parts. These manufacturing processes include hardening of 410 stainless steel, annealing of all types of steel and cast iron, tempering and stress relieving, copper, silver, nickle brazing; copper stripping and alkaline washing. The facility handles and stores liquefied Anhydrous Ammonia (CAS#7664-41-7). The anhydrous ammonia is stored outside in the 10,000 gallons tank and 1,000 gallons tank. The facility uses ammonia in the dissociators to convert ammonia vapors into nitrogen and hydrogen to be used in these furnaces for hardening process of steel. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: I observed the following information from the 10,000 gallons tank located outside of the facility: Serial No.: 11153 National Board No.: 11153 Maximum Allowable Design Pressure: Maximum Allowable Design Temperature: Head: 0.2307 Year Built: 1954 250 PSI 300 Degree F Page 2 of 5 Percent Fill Level: 87% Management System: Facility Name: Bluewater Thermal Solutions LLC Facility Location: 75 East Lake Street, Northlake, Illinois 60164 Date of Inspection: January 25, 2026 The facility did not assign a qualified person for the implementation and integration of the risk management program elements. The facility did not document persons responsible for implementing individual requirements of the risk management plan and defined the lines of authority through an organizational chart. Process Safety Information The process safety information for the technology of the process did not contain the safe upper and lower limits for temperatures, pressures, flows, or some other compositions. The facility's PSI did not contain an evaluation of the consequences of deviation. Operating Procedures The facility provided two versions of the ammonia unloading procedures, one from the ammonia supplier, Air Gas, and the second unloading procedure is created by Bluewater. The standard operating procedures for dissociators #224, #226, and #228 did not contain normal operation, temporary procedures, emergency shutdown, emergency operation, normal shutdown, and startup following a turnaround or after emergency shutdown. I did not see consequences of deviations and the steps required to correct or avoid deviations from 3 ammonia dissociators. The facility did not implement safe work practices to provide for the control of hazards during the specific operations. Training I did not see that the facility certified 3 employees that have the required knowledge, skills, and abilities to safely carry out the duties and responsibilities. The facility was not able to provide employee training records by means used to verify that employees understood the training. Mechanical Integrity The facility was not able to ensure the frequency of inspections and tests of process equipment are consistent with applicable manufacturers' recommendations and good engineering practices. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. Page 3 of 5 RECORDS REVIEW Facility Name: Bluewater Thermal Solutions LLC Facility Location: 75 East Lake Street, Northlake, Illinois 60164 Date of Inspection: January 25, 2026 The following is a list of documents that were provided during the site visit by electronic mail: Bluewater Risk Management Program (1 page) Anhydrous ammonia power point presentation (non-refrigeration) Plant #2 Ammonia Delivery Procedures Airgas Operating Procedures (Duplicate copy sent by Michael Andersons of Bluewater) LOTO and Confine Space Entry procedures Dissociators operating procedures API 510 Inspection Report for 10,000 gallon Anhydrous Ammonia Tank Phased Array Calibration Data report Management of Change Procedures (Section 10 of Bluewater RMP) Compliance Audit Report dated November 1, 2021 Compliance Audit Report dated June 2017 Ammonia Onsite Storage Review dated April 19, 2022 Ammonia Onsite Storage Review dated January 13, 2011 PHA Spreadsheet dated July 29, 2015, and April 10, 2019 CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility DIGITAL SIGNATURES Patel, Digitally signed by Patel, Manojkumar Report Author: _M_a__n_o_jk_u_m__a_r______D_a_te_: 2_02_3_.03_.2_4_11_:1_3:_57_-0_5'_00_' Section Supervisor: SARAH Digitally signed by SARAH MARSHALL _M_A__R_S__H_A_L__L_______D_a_te:_2_02_3_.03_.2_4_1_1:4_4_:1_6 _-0_5'0_0' Page 4 of 5 Facility Name: Bluewater Thermal Solutions LLC Facility Location: 75 East Lake Street, Northlake, Illinois 60164 Date of Inspection: January 25, 2026 APPENDICES AND ATTACHMENTS 1. Digital Image Log 2. Program Level 3 Checklist Page 5 of 8 Page 6 of 8 Facility Name: Bluewater Thermal Solutions LLC Facility Location: 75 East Lake Street, Northlake, IL 60164 Date of Inspection: January 25, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Manojkumar P. Patel 2. Archival Record Location: OneDrive/Bluewater Thermal IL/ Inspection Pics Image File Name Number 1 P1260122.JPG 2 P1260123.JPG 3 P1260124.JPG 4 P1260125.JPG 5 P1260126.JPG 6 P1260127.JPG 7 P1260128.JPG 8 P1260129.JPG 9 P1260130.JPG 10 P1260131.JPG 11 P1260132.JPG 12 P1260133.JPG 13 P1260134.JPG 14 P1260135.JPG 15 P1260136.JPG 16 P1260137.JPG 17 P1260138.JPG 18 P1260139.JPG 19 P1260140.JPG Date and Time (incl. Time zone and DST) 2023:01:26 13:07:21 2023:01:26 13:07:51 2023:01:26 13:08:10 2023:01:26 13:10:07 2023:01:26 13:11:26 2023:01:26 13:11:42 2023:01:26 13:13:10 2023:01:26 13:22:50 2023:01:26 13:26:50 2023:01:26 13:27:02 2023:01:26 13:29:00 2023:01:26 13:31:14 2023:01:26 13:32:24 2023:01:26 13:32:30 2023:01:26 13:34:31 2023:01:26 13:34:42 2023:01:26 13:34:57 2023:01:26 13:36:11 2023:01:26 13:36:25 Latitude and Longitude Description of Image Eye Washing Station Liquid Ammonia Line (B/H of Eye Washing Station) Liquid Ammonia Line (Closer View) Dissociators Line Pressure and Temp Guage Valves Dissociators Lines Gauges Temp and Pressure Dissociators Temp Controller Display Yellow Painted Line at Dissociators Plant #3 Ammonia Line (from Plant #2) Relief Valve inside Plant Relief Valve (Inside the Plant) 10,000 Gallon Tank Volume Gauge Relief Valves Pressure Guage Relief Valve Pressure Gauge Display Safety Valve on the 10,000 Gallon Ammonia Tank Safety Valve Closer View Safety Valves Liquid Anhydrous Ammonia Line (Exterior View) Anhydrous Ammonia Tank Location at the Facility Anhydrous Ammonia Tank Location (Next to Transforme Page 7 of 8 Facility Name: Bluewater Thermal Solutions LLC Facility Location: 75 East Lake Street, Northlake, IL 60164 Date of Inspection: January 25, 2023 APPENDIX B: PROGRAM LEVEL 3 CHECKLIST ATTACHED HERE. 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