Document DGeyKBQD61ZEv2NJVOLdVZDXa

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Federal Cartridge Co - Anoka, Anoka, Minnesota Dakota Prentice, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Supervisor AECAB (IL/IN) File BASIC INFORMATION Facility Name: Federal Cartridge Co - Anoka Facility Location: 900 Bob Ehlen Drive, Anoka Minnesota Date of Inspection: July 12, 2022 EPA Inspector(s): 1. Dakota Prentice, Environmental Engineer 2. Meaghan Pashen, Environmental Engineer Other Attendees: 1. Adam Bauer, Federal Cartridge - Environmental Tech 2. Mark Bender, Federal Cartridge - Manager EHS 3. Chris Kaminski, Federal Cartridge - Environmental Engineer 4. Tom Lyon, Federal Cartridge - Waste Coordinator 5. Erik Carlson, Federal Cartridge - Senior Director of Operations Contact Email Address: Chris Kaminski - chris.kaminski@vistaoutdoor.com Purpose of Inspection: Determine compliance with the facility's operating permit issued by the Minnesota Pollution Control Agency Facility Type: Ammunition Manufacturing Arrival Time: 12:45PM Departure Time: 3:15PM 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: Not a small business Provided CBI warning to facility The following information was obtained verbally from Federal Cartridge representatives unless otherwise noted. Process Description: The facility manufactures rim fire, center fire, and shotshell ammunition. Ammunition manufacturing starts with the creation of the lead bullet or lead shot. Lead is received in billet form and melted in various lead melt pots. Lead for bullets is poured into cylinders, which are then placed into an extruder that creates lead wire. The bullet is then formed from the lead wire using a swagger process that cuts the wire and creates the shape. Lead shot is created by pouring liquid lead droplets into a liquid bath at bleimeister machines. The different ammunition types require different final case configurations, including a plastic case for shotshell. In general, the bullet case is manufactured from brass strip that is pressed and stretched into the needed shape, based on ammunition type. Additional modifications may be performed, including copper plating of the lead bullet and nickel plating of the brass case. The facility also produces primer which may at times include lead in the mixture. Primer mix manufacturing operations are conducted at an adjacent property and are identified as a chemical manufacturing process. Final assembly of the ammunition occurs in enclosed machines with flash detection equipment that triggers a water quench system should any explosive events occur. The assembled ammunition is then packaged for shipment. Staff Interview: In response to performance testing in 2019 that identified elevated lead emissions at the facility, MPCA will be installing a lead ambient air monitor at the northeast corner of the facility. The installation date is unknown at this time. The facility is currently expanding the facility as a part of a rifle loader expansion project, which is expected to be operational in the spring of 2023. Page 2 of 4 TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA walked through the facility following production observing lead melting and extruding for bullet production, bleimeister operation for shotshell shot production and various other emission units. EPA was also transported to an east adjacent property where primer mix operations are performed. At the lead melting and extruding portion of the facility, EPA observed open overhead doors in close proximity to these lead emission units. Photos and/or Videos: were taken during the inspection. See Attachment A Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Performance test report(s) for testing conducted in 2019 at the facility's lead processing units; Fugitive emission factors used for lead processing units; Lead modeling report submitted to MPCA showing offsite lead concentrations; and Notice of Compliance Status report for NESHAP VVVVVV and any other NESHAP VVVVVV applicability documentation. Compliance Assistance: EPA recommended closing up those portions of the building with lead melting operations to prevent uncaptured lead emissions from escaping the facility. Concerns: EPA noted that some lead melting and processing operations were located adjacent to overhead doors that were open to the exterior of the facility during the plant tour. DIGITAL SIGNATURES DAKOTA Digitally signed by DAKOTA PRENTICE Report Author: ______P_R__E_N__T_IC__E____13_:5_2:4_1_-0_5'_00_' _______ Date: 2022.07.28 Section Supervisor: Frank, Digitally signed by Frank, Nathan _N_a_t_h_a_n_______1_0:_47_:3_1 _-0_5'0_0'______________ Date: 2022.08.02 Page 3 of 4 Facility Name: Federal Cartridge Co - Anoka, Anoka, Minnesota Facility Location: 900 Bob Ehlen Drive, Anoka, Minnesota Date of Inspection: July 12, 2022 APPENDICES AND ATTACHMENTS Appendix A: Digital Photo Log Page 4 of 4 Facility Name: Federal Cartridge Co - Anoka, Anoka, Minnesota Facility Location: 900 Bob Ehlen Drive, Anoka, Minnesota Date of Inspection: July 12, 2022 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Meaghan Pashen 2. Archival Record Location: Region 5 Electronic Records Center Image Number 1 File Name IMG_0141.JPG Date and Time (incl. Time zone and DST) 07/12/2022 2:01 PM CST Latitude and Longitude Not Available Description of Image Lead extruder 2 IMG_0142.JPG 07/12/2022 2:01 PM CST Not Available Building 40, A1 (lead melt pot) 3 IMG_0143.JPG 07/12/2022 2:01 PM CST Note: All photographs are confidential business information Not Available Building 40, A1 (lead melt pot) Appendices Page 1 of 1