Document DDB8Y2oXkGZY34NxNYBx0eJK5

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 DATE: SUBJECT: FROM: THRU: TO: See Date of Section Chief Signature Below CLEAN AIR ACT INSPECTION REPORT Trialco Inc., Chicago Heights, Illinois Sarah Clark, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Trialco Inc. Facility Location: 900 East Lincoln Highway, Chicago Heights, IL Date of Inspection: August 2, 2021 EPA Inspector(s): 1. Sarah Clark, Environmental Engineer 2. Linda Rosen, Environmental Engineer Other Attendees: 1. Jay Armstrong, President, Trialco Inc. 2. Jim Dee, CFO, Trialco Inc. 3. Bill Larson, Plant Engineer, Trialco Inc. (intermittent) 4. John Colebrook, Managing Consultant, Trinity Consultants Contact Email Address: jdee@trialco.net Purpose of Inspection: Observe technical upgrades, including air pollution capture and collection system upgrades, that Trialco, Inc. has made to comply with the National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production (Secondary Aluminum NESHAP). Facility Type: The facility is a secondary aluminum production facility. Regulations Central to Inspection: Secondary Aluminum NESHAP Arrival Time: 10:17 am Departure Time: 4:00 pm 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: Already provided. Provided CBI warning to facility The following information was obtained verbally from Jim Dee, Bill Larson, and John Colebrook unless otherwise noted. Process Description: Trialco, Inc. (Trialco) smelts aluminum scrap to make aluminum alloys in the form of ingots and sows. There are two reverbatory furnaces, the main furnace (MF) and the small furnace (SF), which operate in batch cycles, and there are three preheat ovens, which are used to preheat sows or wet scrap before charging to the furnaces. Trialco uses solid reactive flux and chlorine gas to separate impurities from the aluminum. Air emissions from the MF and SF are controlled by the ETA baghouse (BH) and Wheelabrator BH, respectively, which are equipped with lime and ammonia injection. For each BH, Trialco monitors the lime and ammonia injection rates, bag leak detection system (BLDS), inlet temperature, and the differential pressure across each BH. Staff Interview: At the start of the inspection, Mr. Dee informed us that the SF was pouring metal and that the MF was filled with a batch that would pour at noon. No charging would occur during EPA's inspection. EPA reviewed hardcopy furnace production schedules. TOUR INFORMATION EPA Tour of the Facility: Yes Page 2 of 7 Data Collected and Observations: EPA observed the furnace labels for the SF and MF (Photos 1 and 2). Between the labels, EPA observed digital readouts of the chlorine usage (Photo 75, top) and temperature (Photo 75, bottom). Mr. Larson accompanied inspectors to the outdoor BH control rooms where EPA observed the new baghouse data historian (Photo 3) and recent alarms (Photo 4). Mr. Larson said that he receives an email each time an alarm is triggered. He explained that the "North Bag House" corresponds to the SF BH (the Wheelabrator BH), the "South Bag House" corresponds to the MF BH (the ETA BH), and the "Precoat Bag Weight" indicates total super sac weight. According to the data historian, and as shown in Photo 4, the most recent alarm occurred at "8/2/2021 10:58:43 PM" with the message, "North Precoat Analog Input Out Of Scale." Mr. Larson explained that he put new belts on the system this morning after the belts got loose. Trialco uses a FilterSense DynaCHARGE PM 100 BLDS. The BLDS monitor displayed the instantaneous and 6-minute averge BLDS output for the SF BH and MF BH (Photos 5-8). Mr. Larson explained that "Particulate 1" corresponds with the North BH or SF BH and "Particulate 2" corresponds with the South BH or MF BH. Mr. Larson said that the system is operating with the factory settings. Mr. Larson was not confident in the exact alarm set points and delay times and told EPA that the information would be in the manual that came with the system. Mr. Larson also explained that if there is any buildup on the sensor, the sensor will automatically reprogram itself. EPA observed the ammonia tank and ammonia injection gauges (Photos 9-15). The facility has added an additional monitoring system so that there is now one for each furnace's baghouse. The new system is up and running on the MF BH, but the data is not going to the sensor. The existing monitoring system was installed on the SF BH and the ammonia gauge corresponding to the SF BH indicated an ammonia injection rate of approximately 25 cubic feet per hour. The ammonia gauge corresponding to the MF BH did not indicate any flow. Mr. Larson explained that the knobs on top of each gauge adjust the ammonia flow rate. Next, EPA observed the chlorine tanks (Photos 16-19). There is a north and a south tank room, and in each tank room, there are six tanks stored on one platform scale. Each scale is tested every three months and, according to Mr. Larson, has an accuracy of 1 or 5 pounds. The north and south tank rooms are piped together, such that chlorine can flow from one side to the other, balanced by pressure, and connected to this pipe, there is a single pipe that routes chlorine to the facility. When chlorine injection is needed at the facility, the chlorine is drawn from all six tanks on one side at a time. Mr. Larson showed EPA the chlorine weight monitor (Photo 26) which displayed the current weight for the north and south scales separately. Trialco explained that the data historian reported the amount of chlorine used over the last 15-minute period and last 60minute period, and that negative readings could represent flow between the north and south tanks. EPA then observed the BLDS and BH inlet temperature sensors positioned at each BH stack and inlet, respectively (Photos 20-25) before touring the outdoor scrap yard with Mr. Dee (Photos 27- Page 3 of 7 42). EPA observed a variety of aluminum products in the scrap yard including incoming sows, old streetlight and/or flag posts, wheels, furnace run-off, wire, road signs, furnace `clean out' or extrusion, punches from cans, and post-consumer aerosol cans and aluminum water bottles. Mr. Dee characterized the streetlight/flag poles as painted mixed low copper (PTD MLC) scrap. Mr. Dee explained that Trialco was in the process of selling off certain types of scrap, such as the old street signs. Mr. Dee also explained that aerosol cans (i.e. alloy 1070) have a different alloy composition than used beverage cans (UBCs), which are composed of three alloys. Inside the facility, EPA observed the SF capture and collection system (Photos 43-48, 52-53, 5559). Floor-to-hood metal plates were installed on the left and right sides of the metal charge well hood and heat resistant curtains hung from the front of the metal hood and across gaps on either side. EPA observed that the heat resistant curtains that hung from the metal hood were tattered and torn, with gaps between curtains. EPA observed that the duct routing exhaust from the SF to the baghouse was connected to the SF hood at a 90 angle, with the opening of the duct flush with the back of the hood, and that the duct experienced a sharp transition in diameter (enlargement) a few feet downstream from the SF hood. EPA also observed the hooding for the capture and collection system for the SF hearth, where, similarly, the duct connected at a 90 angle flush with the back of the hood. EPA noted that the pump well doors were closed. Immediately in front of the SF charge well, EPA observed a pile of aluminum scrap that Mr. Dee confirmed included alloy 1070 (Photo 54). Across from the SF, EPA observed a large bay door opening to the outdoors (Photos 49-50). Trialco showed EPA the separate ducts that route emissions from the SF and MF to the Wheelabrator BH and ETA BH, respectively, and indicated to EPA that the damper, which can connect the two ducts, was closed (Photo 60). Mr. Larson stated that there was currently no monitor on the duct damper. Mr. Dee said that Trialco will not block off this duct permanently; Trialco plans to continue to use this damper to route emissions to the other BH in case of an emergency or outage. EPA observed the floor scale used to weigh raw materials. Mr. Larson explained that the scale is calibrated at least every 3 months (Photo 51). EPA also observed the preheat ovens, one of which was warming sows, and the square ducts that routed emissions from the preheat ovens to the main duct for the ETA BH (Photos 61-63). Next, EPA observed the MF capture and collection system (Photos 64-74). EPA noted that the pump well doors were closed. Floor-to-hood metal plates were installed at the front of the charge well hood covering approximately 2/3 of the opening and curtains hung across gaps to either side of the charge well. EPA then observed the lime injection system (Photos 76-81). A super sac of lime is positioned on load cells, and from there, lime enters one of two augers that feed lime through long flexible hoses to each furnace BH duct. Mr. Larson explained how a level sensor is used to detect the presence of lime and explained how Trialco upgraded the lime injection system by increasing the feed diameter to reduce clogging. Mr. Larson stated that he installed a fresh bag of lime the morning of EPA's inspection. Page 4 of 7 Photos and/or Videos: were taken during the inspection. Photos containing confidential business information (CBI) are marked accordingly in Appendix A. Field Measurements: were not taken during this inspection. RECORDS REVIEW CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility During the closing conference, Mr. Colebrook showed EPA electronic records of monitoring data and alarms. EPA observed that the "North baghouse" (the Wheelabrator BH) was off for approximately 25 minutes the morning of the inspection, which Trialco staff explained was to tighten some belts on the fan. When EPA asked about audio and/or visual alarms, Trialco staff said that there were none, apart from the email to Bill Larson for 15-minute deviations. Mr. Armstrong explained that cold air dampers open when the exhaust gets too hot; Mr. Colebrook added that the baghouse damper air has a high set point, above the alarm threshold. When EPA asked about production records or corrective actions reports, Trialco staff explained that records for production and corrective actions were still maintained on paper. When EPA asked about flux, Trialco staff stated that, currently, the solid flux injection rate is maintained on paper and that the chlorine injection rate is determined by integrating over chlorine flow. When EPA asked about lime injection, Trialco staff said that the flow of lime from the super sac is divided approximately 60/40 to the ETA and Wheelabrator BHs, based on the air flow to each BH. The lime auger settings are reported in Hertz or rotations per minute. To confirm the pound per hour (lb/hr) rate, Trialco staff said that Trialco could weigh the output and count the number of rotations on the auger ("bucket test") and said that Mr. Larson periodically checks this. Mr. Colebrook also explained how the lb/hr rate can be estimated by integrating the data reported by the lime super sac load cell. When EPA asked about the ammonia system, Mr. Colebrook showed EPA the current digital readout of approximately 28.4 gallons per minute and said that the digital signal was more accurate than the analog output observed earlier. When EPA asked about the BLDS, Trialco staff said that Trialco was currently using the factory settings but planned on making necessary adjustments if needed during the next stack test. When EPA asked about the chlorine injection system, Trialco staff explained that a small amount of nitrogen gas is present in the system to keep the lines open and that the system must remain on to prevent molten metal from flowing up the line while the chlorine lance is submerged. Trialco staff said that they were currently exploring different metering options capable of handling this type of nitrogen/chlorine system. Page 5 of 7 DIGITAL SIGNATURES SARAH Digitally signed by SARAH CLARK Report Author: _C_L_A__R_K_______D1_3a:_t5e4:_:23_032_-10.5_0'90_.03'_0 ____________ NATHAN Digitally signed by NATHAN FRANK Section Chief: F__R_A__N_K_______D1_4a:t_0e5:_:220_12-_10.51_'00_.00'1______________ Page 6 of 7 Facility Name: Trialco Inc. Facility Location: 900 East Lincoln Highway, Chicago Heights, IL Date of Inspection: August 2, 2021 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log Page 7 of 7 Facility Name: Trialco Inc. Facility Location: 900 East Lincoln Highway, Chicago Heights, IL Date of Inspection: August 2, 2021 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Sarah Clark 2. Archival Record Location: ERC > AECAB Library > Enf_Trialco_IL_19 > Enf_Trialco Inc_IL_19_Inspection 2021 Image Number File Name 1 P8020001.JPG 2 P8020002.JPG 3 P8020003.JPG 4 P8020004.JPG 5 P8020005.JPG 6 P8020006.JPG 7 P8020007.JPG 8 P8020008.JPG 9 P8020009.JPG 10 P8020010.JPG 11 P8020011.JPG 12 P8020012.JPG 13 P8020013.JPG 14 P8020014.JPG 15 P8020015.JPG 16 P8020016.JPG Date and Time (CDT) 2021:08:02 11:18:54 2021:08:02 11:19:06 2021:08:02 11:22:16 2021:08:02 11:24:53 2021:08:02 11:27:55 2021:08:02 11:28:08 2021:08:02 11:28:45 2021:08:02 11:29:06 2021:08:02 11:37:53 2021:08:02 11:38:54 2021:08:02 11:42:10 2021:08:02 11:42:15 2021:08:02 11:42:19 2021:08:02 11:42:58 2021:08:02 11:43:57 2021:08:02 11:49:14 Latitude and Longitude 41.505188, -87.609428 41.505137, -87.60943 41.505, -87.609167 41.505303, -87.608208 41.504825, -87.608447 41.504783, -87.608562 41.504765, -87.608465 41.504767, -87.608482 41.505035, -87.608673 41.505025, -87.608672 41.504963, -87.608713 41.504963, -87.608713 41.504963, -87.608713 41.504928, -87.608755 41.504917, -87.608757 41.504822, -87.608385 Description of Image SF furnace label MF furnace label BH data historian "North Bag House" corresponds to SF BH "South Bag House" corresponds to MF BH Precoat indicates total super sac weight BH Alarm history 7/29/21-8/2/21 BLDS output Screen too dark to read. BLDS output Screen too dark to read. BLDS output "Particulate 1" corresponds to SF BH "Particulate 2" corresponds to MF BH BLDS output: instantaneous and 6-minute average Ammonia tank Ammonia tank Ammonia injection system Left side: SF BH. Right side: MF BH Ammonia injection system Gauge reads 25 cubic feet per hour to SF BH Ammonia injection system Gauge did not indicate flow to MF BH Ammonia injection system Knobs on top adjust flow rate Ammonia injection system, as viewed from outside South chlorine tanks on load scale (CBI) Appendices Page 1 of 4 Facility Name: Trialco Inc. Facility Location: 900 East Lincoln Highway, Chicago Heights, IL Date of Inspection: August 2, 2021 17 P8020017.JPG 2021:08:02 41.50483, North chlorine tanks on load scale (CBI) 11:51:05 -87.60836 18 P8020018.JPG 2021:08:02 41.50483, North chlorine tanks on load scale (CBI) 11:51:16 -87.60836 19 P8020019.JPG 2021:08:02 41.504852, Pipe that connects north and south tank rooms 11:52:09 -87.608298 and routes chlorine to facility (CBI) 20 P8020020.JPG 2021:08:02 41.504722, MF BH stack 11:59:27 -87.608056 21 P8020021.JPG 2021:08:02 41.5047, SF BH stack with BLDS 12:01:52 -87.608435 22 P8020022.JPG 2021:08:02 41.504695, MF BH stack with BLDS 12:03:27 -87.608453 23 P8020023.JPG 2021:08:02 41.504697, MF BH inlet temperature monitor after spark 12:04:34 -87.608458 arrester 24 P8020024.JPG 2021:08:02 41.504697, MF BH inlet temperature monitor after spark 12:04:42 -87.608458 arrester 25 P8020025.JPG 2021:08:02 41.504693, SF BH inlet temperature monitor 12:06:19 -87.608465 26 P8020026.JPG 2021:08:02 41.504687, Chlorine weight monitor 12:07:27 -87.608468 27 P8020027.JPG 2021:08:02 41.504444, Scrap: incoming aluminum sows and old light 12:14:53 -87.608611 poles, "painted category" 28 P8020028.JPG 2021:08:02 41.5048, Scrap yard: Furnace "run off" 12:17:45 -87.608152 29 P8020029.JPG 2021:08:02 41.5048, Scrap yard: Furnace "run off" and wheels 12:17:51 -87.608152 30 P8020030.JPG 2021:08:02 41.504722, Scrap yard: Light poles 12:19:57 -87.608056 31 P8020031.JPG 2021:08:02 41.505062, Scrap yard: Road signs 12:20:42 -87.60816 32 P8020032.JPG 2021:08:02 41.505062, Scrap yard: Light poles and wheels 12:22:33 -87.60816 33 P8020033.JPG 2021:08:02 41.505077, Scrap yard: Road signs 12:24:06 -87.608118 34 P8020034.JPG 2021:08:02 41.505313, Scrap yard: Unknown, possibly clean out / 12:25:27 -87.608137 extrusion 35 P8020035.JPG 2021:08:02 41.505313, Scrap yard: Punches from cans 12:26:25 -87.608138 36 P8020036.JPG 2021:08:02 41.505278, Scrap yard: Post-consumer aerosol cans and 12:33:07 -87.608056 water bottles (Alloy 1070) 37 P8020037.JPG 2021:08:02 41.505492, Scrap yard: Alloy 1070 12:35:38 -87.607832 38 P8020038.JPG 2021:08:02 41.50536, Scrap yard: Alloy 1070 12:38:31 -87.607838 Appendices Page 2 of 4 Facility Name: Trialco Inc. Facility Location: 900 East Lincoln Highway, Chicago Heights, IL Date of Inspection: August 2, 2021 39 P8020039.JPG 2021:08:02 41.50536, Scrap yard: Painted mixed low copper scrap 12:39:19 -87.607837 40 P8020040.JPG 2021:08:02 41.505252, Scrap yard: Punches from cans. 12:41:09 -87.607833 41 P8020041.JPG 2021:08:02 41.50525, Scrap yard: Punches from cans. 12:41:19 -87.60783 42 P8020042.JPG 2021:08:02 41.50525, Scrap yard: Punches from cans. 12:41:24 -87.60783 43 P8020043.JPG 2021:08:02 41.50538, SF front (CBI) 13:31:04 -87.609383 44 P8020044.JPG 2021:08:02 41.50532, SF side of charge well, with well walker 13:34:33 -87.609443 45 P8020045.JPG 2021:08:02 41.50532, SF side of charge well, with well walker 13:34:37 -87.609443 46 P8020046.JPG 2021:08:02 41.505297, SF hearth door 13:35:33 -87.609438 47 P8020047.JPG 2021:08:02 41.505292, SF pump well 13:36:51 -87.609345 48 P8020048.JPG 2021:08:02 41.505292, SF pump well (CBI) 13:36:56 -87.609345 49 P8020049.JPG 2021:08:02 41.505295, Bay door across from SF 13:38:55 -87.609313 50 P8020050.JPG 2021:08:02 41.505295, Bay door across from SF 13:38:55 -87.609313 51 P8020051.JPG 2021:08:02 41.505108, Floor scale 13:41:35 -87.609357 52 P8020052.JPG 2021:08:02 41.505, SF hood duct connection 13:44:10 -87.609167 53 P8020053.JPG 2021:08:02 41.505108, SF hood duct connection 13:45:02 -87.609323 54 P8020054.JPG 2021:08:02 41.505108, Alloy 1070 on floor in front of SF 13:45:58 -87.609323 55 P8020055.JPG 2021:08:02 41.5051, SF ductwork connection to back of hood 13:49:35 -87.609308 56 P8020056.JPG 2021:08:02 41.505098, SF ductwork connection to back of hood 13:49:43 -87.609283 57 P8020057.JPG 2021:08:02 41.505103, SF ductwork connection to back of hood 13:53:05 -87.60927 58 P8020058.JPG 2021:08:02 41.50506, SF hearth door hood (CBI) 13:56:27 -87.60924 59 P8020059.JPG 2021:08:02 41.50506, SF hearth door hood duct connection (CBI) 13:56:40 -87.60924 60 P8020060.JPG 2021:08:02 41.505, Left: SF BH duct; Right: MF BH duct; 14:01:47 -87.609167 Connection with damper Appendices Page 3 of 4 Facility Name: Trialco Inc. Facility Location: 900 East Lincoln Highway, Chicago Heights, IL Date of Inspection: August 2, 2021 61 P8020061.JPG 2021:08:02 41.504973, MF BH with square duct connection to preheat 14:02:33 -87.609288 ovens 62 P8020062.JPG 2021:08:02 41.504925, Preheat ovens 14:06:50 -87.60925 63 P8020063.JPG 2021:08:02 41.504882, Preheat ovens 14:07:15 -87.609392 64 P8020064.JPG 2021:08:02 41.504878, MF hearth door 14:08:24 -87.609473 65 P8020065.JPG 2021:08:02 41.504878, MF hearth duct 14:10:08 -87.609473 66 P8020066.JPG 2021:08:02 41.504878, MF charge well 14:10:54 -87.609473 67 P8020067.JPG 2021:08:02 41.504885, MF duct to pump well, as viewed from charge 14:11:48 -87.609487 well 68 P8020068.JPG 2021:08:02 41.504885, MF charge well hood duct connection 14:12:03 -87.609492 69 P8020069.JPG 2021:08:02 41.504883, MF charge well hood old "blocked off" duct 14:13:32 -87.609493 connection 70 P8020070.JPG 2021:08:02 41.504722, MF charge well hood front (CBI) 14:17:30 -87.609167 71 P8020071.JPG 2021:08:02 41.504882, MF pump well (CBI) 14:18:02 -87.609502 72 P8020072.JPG 2021:08:02 41.504862, MF ductwork 14:19:39 -87.609517 73 P8020073.JPG 2021:08:02 41.504862, MF ductwork front of hood (CBI) 14:19:44 -87.609517 74 P8020074.JPG 2021:08:02 41.504872, MF pump well (CBI) 14:21:00 -87.609535 75 P8020075.JPG 2021:08:02 41.504838, Chlorine rate display 14:31:28 -87.609415 76 P8020076.JPG 2021:08:02 41.504722, Lime injection system auger 14:38:33 -87.608889 77 P8020077.JPG 2021:08:02 41.504722, Lime injection system level sensor 14:38:37 -87.608889 78 P8020078.JPG 2021:08:02 41.504722, Lime injection system super sac on load cells 14:38:42 -87.608889 79 P8020079.JPG 2021:08:02 41.504795, Lime injection system readout with total 14:38:53 -87.608757 weight of super sac bag 80 P8020080.JPG 2021:08:02 41.504722, Lime injection system tubing to MF BH duct 14:41:50 -87.608611 81 P8020081.JPG 2021:08:02 41.504803, MF BH duct 14:41:52 -87.608753 Appendices Page 4 of 4