Document LpEkvgeeznQjEQpeO24eD5N8X
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5
77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604
SUBJECT: FROM: THRU: TO:
CLEAN AIR ACT INSPECTION REPORT Crystal Finishing Systems Inc, Schofield, Wisconsin
Jacob Herbers, Environmental Engineer AECAB (MI/WI)
Sarah Marshall, Section Supervisor AECAB (MI/WI)
File
BASIC INFORMATION
Facility Name: Crystal Finishing Systems, Inc. (Crystal)
Facility Location: 2610 Ross Ave, Schofield, Wisconsin
Date of Inspection: 3/21/2023
EPA Inspector(s): 1. Brittany Cobb, Environmental Engineer 2. Jacob Herbers, Environmental Engineer
Other Attendees: 1. Lee Bergmann, Environmental Engineer, Crystal 2. Bob Rhode, Vice President, Crystal
Contact Email Address: lee.bergmann@crystalfinishing.com
Purpose of Inspection: To determine compliance with the Clean Air Act and perform a full compliance evaluation.
Facility Type: Metal and plastic parts coating and fabrication manufacturer
Regulations Central to Inspection: 40 C.F.R. Part 63, Subpart PPPP - National Emission Standards for Hazardous Air Pollutants for Surface Coating of Plastic Parts and Products; 40 C.F.R. Part 63, Subpart MMMM - National Emission Standards for Hazardous Air Pollutants for Surface Coating of Miscellaneous Metal Parts and Products; and the Wisconsin State Implementation Plan.
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Arrival Time: 8:25 AM CT Departure Time: 3:25 PM CT
Inspection Type: Unannounced Inspection
OPENING CONFERENCE
Presented Credentials Stated authority and purpose of inspection Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility
The following information was obtained verbally from Lee Bergmann and Bob Rhode unless otherwise noted.
Process Description: The Crystal Facility in Schofield performs aluminum extrusion, aluminium fabrication and coats metal and plastic parts with paint and powder. There are six plants housed at the Facility.
Plant 1 contains the main coating line (14 Spray Guns) and curing/drying ovens, in addition to the small jobs coating line (4 Spray Guns) and curing/drying ovens. Emissions from both coating lines are controlled by a shared regenerative thermal oxidizer (RTO), 4 stage filter systems, and dry filter system.
Plant 2 contains aluminum extrusion lines which include aluminum billet heaters, tempering ovens and presses. There are no air pollution control devices.
Plant 3 is primarily empty and has a small maintenance station with no air pollution control devices.
Plant 4 contains the powder coating lines, cure oven, parts washer, and dryer, all which have no air pollution control devices. There is also a coating line with 4 spray guns and a cure oven, that has not been used in a year, emissions are controlled by a filter. In addition, there is an aluminum decor line that vents into the building and has no stack or air pollution control device.
Plant 5 also contains aluminum extrusion lines which include aluminum billet heaters, tempering ovens and presses. There are no air pollution control devices.
Plant 6 contains the plastic coating line (12 spray guns), emissions are controlled by an overspray filter systems and RTO.
Staff Interview: There are approximately 680 employees at the Schofield Facility, and over 1,000 companywide. The main coating line operates 5:45 AM - 1:00 PM.
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The main coating line in Plant 1 was built over 30 years ago, the small jobs coating line was built in 2006, and the plastic coating line in Plant 6 was built in 2016. The main coating line and plastic coating line each have a permanent total enclosure (PTE). The coating line in plant 4 has not been operated since May 2022. The burn-off oven in plant 6 is listed in the permit but has not been constructed.
The facility uses 100% soluble chrome in the washers and therefore doesn't track chrome emissions for the washers.
TOUR INFORMATION
EPA Tour of the Facility: Yes
Data Collected and Observations:
Plant 1
EPA observed the pressure drop for the filters in each booth of main coating line:
Booth number Pressure drop (in.
WC)
1
0.1
2
0.2
3
0.4
4
0.3
5
0.2
6
0.5
7
0.1
8
0.2
Booths 1 and 2 use paint containing chromium.
EPA observed the temperature of the RTO was 1480 F. The pressure drop of the filter before the RTO was 1.4 inches of water column (in. WC). The pressure drop of the natural draft opening (NDO) on the main coating line was -0.005 in. WC. EPA observed two spray guns operating at the time of the inspection. The temperature of the burn-off ovens were 1,700 F and 1475 F.
EPA observed the pressure drop for the filters in each booth of the small jobs coating line:
Booth number Pressure drop (in.
WC)
1
0.3
2
0.3
There was one spray gun operating at the time of the inspection.
Plant 6 EPA observed the temperature of the RTO in plant 6 to be 1,539 F. Crystal calibrated the pressure sensors for the filter located before the RTO while the RTO was operating and during the inspection. After the sensors were calibrated, EPA observed the pressure drop to be 0.4 in.
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WC. EPA observed the pressure drop for the entrance to the topcoat NDO to be -0.006 in. WC, the entrance to the primer to be -0.007, the exit of the topcoat booth to be -0.006 in. WC. EPA observed 2 spray guns operating during the inspection.
EPA observed the pressure drop for the filters in each booth of the plastic coating line:
Booth # Pressure drop (in. WC)
1
1.3
2
1.14
3
1.5
4
1.1
The total pressure drop gauges for the filters in booths 2 and 3 malfunctioned. EPA added up the
pressure drops across each filter to get the total pressure drop for booths.
EPA observed the burn-off oven was off, the exhaust temperature was 1540 F and the operating temperature was 787 F.
Photos and/or Videos: were taken during the inspection.
Field Measurements: were not taken during this inspection.
RECORDS REVIEW
Plant 1 1. September 2022, January 2023, and February 2023 daily filter inspections 2. Specification sheet for all spray guns 3. Stack drawing to evaluate stack heights 4. Documentation of filter efficiency 5. PTE evaluations 6. Volatile Organic Compound (VOC) capture and destruction efficiency stack test reports
for the RTO 7. RTO temperature logs 8. Semiannual report 9. Pressure drop across the enclosure 10. SDS of solutions for parts washer (Oakite, Cryscoat, and Permatreat products) 11. Burn-off oven temperature logs (2)
Plant 2 12. Specifications indicating the fuel usage design of the aluminum extrusion lines is for gas 13. Internal inspections
Plant 4 14. Design documents of aluminum decor line indicating emissions are not exhausted to
ambient air 15. Design documents of powder coating booths indicating there is no stack 16. Name plate on powder coating line indicating gas is used for fuel 17. SDS of powdering coatings
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18. Burn-off oven temperature log (1)
Plant 6 19. VOC Capture and Destruction efficiency stack test report for the RTO
Facility-wide 20. CAM Plan 21. MPAP
CLOSING CONFERENCE
Provided U.S. EPA point of contact to the facility
Requested documents: Copy of 2020 PTE evaluation for Plant 1 Temperature and exhaust fan current records for RTO from March 1, 2021 to March 21, 2023 VOC content of each coating or solvent used from February 1, 2023 to March 21, 2023 Temperature logs for paint hook burn-off oven (P05) from March 1, 2021 to March 21, 2023 Manufacturer specifications for paint hook burn-off oven (P05) Manufacturer specifications for Plant 1 RTO and Plant 6 RTO Record of the number of spray guns operated during each day from March 1, 2022 to March 21, 2023 CAM Plan MPAP
Concerns: EPA identified concerns that Crystal did not have documentation showing the transfer efficiency of Aerobell 168 and Ransburg spray guns to be at least 65%. EPA identified concerns that the PTE for the main coating line has less than 100% capture.
DIGITAL SIGNATURES
Herbers, Jacob Date: 2023.05.17 13:18:57 -05'00' Digitally signed by Herbers, Jacob
Report Author: _________________________________
DANIEL
Digitally signed by DANIEL
SCHAUFELBERGER
SCHAUFELBERGER Date: 2023.05.17 13:13:58 -05'00'
Section Supervisor: __________________________________
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APPENDICES AND ATTACHMENTS 1. Digital Image Log
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Facility Name: Crystal Finishing Systems Inc. Facility Location: S 2610 Ross Ave, Schofield, WI
Date of Inspection: March 21, 2023
APPENDIX A: DIGITAL IMAGE LOG
1. Inspector Name: Jacob Herbers
2. Archival Record Location: EPA Electronic Records
Image # 1 2 3 4 5 6 7 8 9 10 11
12 13 14
15 16 17
18 19 20
21 22 23 24
25 26
27 28 29 30 31
File Name IMG_1464.JPG IMG_1465.JPG IMG_1466.JPG IMG_1467.JPG IMG_1468.JPG IMG_1469.JPG IMG_1470.JPG IMG_1471.JPG IMG_1472.JPG IMG_1473.JPG IMG_1474.JPG
IMG_1475.JPG IMG_1476.JPG IMG_1477.JPG
IMG_1478.JPG IMG_1479.JPG IMG_1480.JPG
IMG_1481.JPG IMG_1482.JPG IMG_1483.JPG
IMG_1484.JPG IMG_1485.JPG IMG_1486.JPG IMG_1487.JPG
IMG_1488.JPG IMG_1489.JPG
IMG_1490.JPG IMG_1491.JPG IMG_1492.JPG IMG_1493.JPG IMG_1494.JPG
Date and Time 2023:03:21 10:16:56 2023:03:21 10:21:03 2023:03:21 10:23:43 2023:03:21 10:24:43 2023:03:21 10:27:04 2023:03:21 10:27:35 2023:03:21 10:29:15 2023:03:21 10:31:55 2023:03:21 10:32:52 2023:03:21 10:34:14 2023:03:21 10:34:26
2023:03:21 10:35:03 2023:03:21 10:36:34 2023:03:21 10:36:44
2023:03:21 10:39:43 2023:03:21 10:46:22 2023:03:21 10:49:12
2023:03:21 10:51:02 2023:03:21 10:53:29 2023:03:21 10:56:14
2023:03:21 10:58:49 2023:03:21 11:25:16 2023:03:21 11:26:11 2023:03:21 11:31:56
2023:03:21 11:40:29 2023:03:21 11:41:49
2023:03:21 11:44:21 2023:03:21 11:45:48 2023:03:21 11:47:40 2023:03:21 11:49:45 2023:03:21 11:50:13
Description of Image Product on the P03 painting line P03 paint booth #5 using two bells Air handler with filter on paint booth #5 Residue / corrosion on side of multi cleaner Paint booth #1 control screen Chrome coating area with residue View into line of paint booths RTO temperature reading and control panel Filters connected to RTO outside Ductwork into RTO Ductwork into RTO Residue on side of Permanent Total Enclosure (PTE) Accidental blurry photo Dusty filters on PTE air intake Portable air fans next to paint hanger monorail line Burn-off ovens P03 offline paint booth Main duct from paint booth to RTO with oven in background Ductwork on side of paint booth Small jobs painting line Attempt to manually measure flow with streamer in small jobs line Product sanding area with large air duct above Same duct leading to filters outside PTE with exhaust filters? Inside + outside Robot painter in tunnel, with product in paint line - CBI Residue on seam of PTE PTE appears to exhaust some into atmosphere, and some into large duct Air compressor with filters Gauges for air filters 12, 13, and 14 Residue below PTE window Residue below different PTE window
Appendix 1 of 2
Facility Name: Crystal Finishing Systems Inc. Facility Location: S 2610 Ross Ave, Schofield, WI
Date of Inspection: March 21, 2023 32 IMG_1495.JPG 2023:03:21 12:02:49 P19 paint line, accidentally included worker 33 IMG_1496.JPG 2023:03:21 12:03:50 Residue on air ducts above P19 entrance
Large amounts of debris on ceiling in gap on 34 IMG_1497.JPG 2023:03:21 12:04:33 other side of P19 line 35 IMG_1498.JPG 2023:03:21 12:05:25 Debris on PTE seam 36 IMG_1499.JPG 2023:03:21 12:05:53 Debris on duct above PTE 37 IMG_1500.JPG 2023:03:21 12:12:48 Pressure gauges on exhaust
Appendix 2 of 2