Document 93Ea2npVj8D6dJjxyD1bV6er6

SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 CLEAN AIR ACT INSPECTION REPORT Plasman Cleveland Manufacturing, Cleveland, Ohio Charles Hall, Environmental Engineer AECAB (MN-OH) Brian Dickens, Section Chief AECAB (MN-OH) File, Plasman Cleveland Manufacturing, Cleveland, Ohio BASIC INFORMATION Facility Name: Plasman Cleveland Manufacturing (PCM) Facility Location: 3000 West 121st Street, Cleveland, Ohio Date of Inspection: 24 April 2024 EPA Inspectors: 1. Charles Hall 2. Matthew Walters Other Attendees: 1. Tim Atkas, General Manager 2. Vickie Chapman, Environmental, Health, & Safety Manager Contact Email Address: Vickie.Chapman@plasman.com Purpose of Inspection: To determine PCM's compliance with its Permit-To-Install and Operate (PTIO) and the National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (Chromium Electroplating MACT). Facility Type: chromium electroplater Regulations Central to Inspection: PCM's PTIO and the Chromium Electroplating MACT. Arrival Time: 10:00 hrs EDT Departure Time: 12:00 hrs EDT 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 The following information was obtained verbally from Atkas and Chapman unless otherwise noted. Company Ownership: The ownership of the facility has not changed since 2014. However, the name changed to Plasman Cleveland Manufacturing in 2020. Process Description: The PTIO identifies three emission units at PCM: B-LINE Hexavalent (P009), B-LINE Trivalent (P011), and Decorative Trivalent and Hexavalent (P012). PCM has dismantled all electroplating equipment for B-LINE Hexavalent and B-LINE Trivalent. See photograph 1 in Appendix A. PCM installed the Decorative Trivalent and Hexavalent plating line, which the PCM representatives call the Hoist Line, in 2015 and has not made any physical changes to the Hoist Line since then. The Hoist Line is a decorative trivalent and hexavalent chrome plating line with three trivalent chrome tanks and one hexavalent chrome tank. The trivalent chrome tanks employ an integrated wetting agent and foam blanket. The hexavalent chrome tank uses a foam blanket and chemical fume suppressant with a wetting agent. Each tank is controlled by a composite mesh pad scrubber. In simplified description of the Hoist Line, parts are loaded onto a plating rack, cleaned in a nitric acid bath, electroplated with copper, nickel, and trivalent or hexavalent chromium in succession. After a quality assurance inspection, the parts are loaded into boxes for shipment. PCM operates 20 hours per day on 4 days per week and conducts maintenance work on Fridays. PCM currently has 93 employees. TOUR INFORMATION EPA Tour of the Facility: Yes Page 2 of 4 Data Collected and Observations: After the initial 40 hours of operation with no surface tension measurements greater than 33 dynes per centimeter, the PTIO requires PCM to measure the surface tension at least once every 8 hours of tank operation. The PCM representatives stated that a PCM employee measures the surface tension up to four times per day. After the inspection, PCM provided and Hall reviewed PCM's surface tension data from January 1 to April 30, 2024. None of the 215 surface tension measurements were greater than 33 dynes per centimeter. However, there was no day with four surface tension measurements, and 39 second or third measurements on a particular day were more than 8 hours apart. The PTIO prohibits PCM from using a perfluorooctane sulfonic acid (PFOS)-based fume suppressants (containing 1% or greater PFOS by weight) in decorative chromium electroplating tanks. After the inspection, PCM provided an electronic copy of the Safety Data Sheet (SDA) of its fume suppressant. The SDS's ingredients list does not include PFOS. The PTIO requires PCM to prepare an operation and maintenance plan for the composite mesh pad scrubber which must specify criteria for the add-on air pollution control device. PCM monitors several criteria for the Hoist Line including the differential pressure across the composite mesh pad scrubber and the observation of scrubber liquor flow from a pipe outlet. After the inspection, PCM provided and Hall reviewed the daily checklists for January through April 2024. The checklists did not report any out-of-range pressure drops or the absence of scrubber liquor flow. Photos and/or Videos were taken during the inspection. Field Measurements were not taken during the inspection. RECORDS REVIEW After the inspection, Hall requested records to review. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: After the inspection, Hall sent an e-mail to request the following documents: A process flow diagram; A copy of the MSDS for the chemical fume suppressant; A copy of the operation and maintenance plan; The Hoist Line surface tension measurements from January 1 to April 30, 2024; The Hoist Line pressure drop monitoring data from January 1 to April 30, 2024; Page 3 of 4  The initial notification for the Hoist Line for the National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (Chromium Electroplating MACT); The 2023 Notification of Compliance Status for the Chromium Electroplating MACT; Initial Notification and Notification of Compliance Status for the National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations, 40 C.F.R. Part 63, Subpart WWWWWW, The records specified in 63.10(b)(2)(i) through (iii) and (xiv) of the MACT General Provisions; and The records required to show continuous compliance with each management practice and equipment standard that applies to you, as specified in 63.11508(d), "What are my compliance requirements?" DIGITAL SIGNATURES CHARLE Report Author: S HALL Digitally signed by CHARLES HALL Date: 2024.05.30 10:40:50 -05'00' Section Chief: BRIAN DICKENS Digitally signed by BRIAN DICKENS Date: 2024.05.30 15:46:17 -05'00' Page 4 of 4 Facility Name: Plasman Cleveland Manufacturing Facility Location: 3000 West 121st Street, Cleveland, Ohio Date of Inspection: April 24, 2024 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log Page 5 of 5 Facility Name: Plasman Cleveland Manufacturing Facility Location: 3000 West 121st Street, Cleveland, Ohio Date of Inspection: April 24, 2024 APPENDIX A: DIGITAL IMAGE LOG Photographer: Matt Walters Image File Name Number 1 P4240005 Camera: Olympus Tough TG-6 EPA Bar Code: SZ4061 Date Description of Image 04/24/2024 Factory Area which B-Line Previously Occupied 2 P4240006 04/24/2024 Control Panel for Copper and Nickel Scrubber Appendices Page 1 of 8 Facility Name: Plasman Cleveland Manufacturing Facility Location: 3000 West 121st Street, Cleveland, Ohio Date of Inspection: April 24, 2024 Image Number 3 File Name P4240007 Date 04/24/2024 Description of Image Control Cabinet for Copper and Nickel Scrubber 4 P4240008 04/24/2024 Plating Bath and Pickup Slots for Scrubber Appendices Page 2 of 8 Facility Name: Plasman Cleveland Manufacturing Facility Location: 3000 West 121st Street, Cleveland, Ohio Date of Inspection: April 24, 2024 Image Number 5 File Name P4240009 Date 04/24/2024 Description of Image Plating Baths with Racks filled with Parts 6 P4240010 04/24/2024 Plating Baths with Racks filled with Parts Appendices Page 3 of 8 Facility Name: Plasman Cleveland Manufacturing Facility Location: 3000 West 121st Street, Cleveland, Ohio Date of Inspection: April 24, 2024 Image Number 7 File Name P4240011 Date 04/24/2024 Description of Image Scrubber Header 8 P4240012 04/24/2024 Control Cabinet for Chrome Scrubber Wash Down Appendices Page 4 of 8 Facility Name: Plasman Cleveland Manufacturing Facility Location: 3000 West 121st Street, Cleveland, Ohio Date of Inspection: April 24, 2024 Image Number 9 File Name P4240013 Date 04/24/2024 Description of Image Control Panel for Chrome Scrubber Wash Down Appendices Page 5 of 8 Facility Name: Plasman Cleveland Manufacturing Facility Location: 3000 West 121st Street, Cleveland, Ohio Date of Inspection: April 24, 2024 Image Number 10 File Name P4240014 Date 04/24/2024 Description of Image Chrome Recovery/Evaporator System Overview Appendices Page 6 of 8 Facility Name: Plasman Cleveland Manufacturing Facility Location: 3000 West 121st Street, Cleveland, Ohio Date of Inspection: April 24, 2024 Image Number 11 File Name P4240015 Date 04/24/2024 Description of Image Diagram of Chrome Recovery/Evaporator System 12 P4240016 04/24/2024 Back Side of Hoods for Plating Baths Appendices Page 7 of 8 Facility Name: Plasman Cleveland Manufacturing Facility Location: 3000 West 121st Street, Cleveland, Ohio Date of Inspection: April 24, 2024 Image Number 13 File Name P4240017 Date 04/24/2024 Description of Image PCM's Tensiometer 14 P4240018 04/24/2024 Calibration Marker on the Tensiometer. Appendices Page 8 of 8