Document M4Qe01nvGoR0Y6xxpap45Lwga

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Calumet Tank & Equipment, Chicago, Illinois FROM: Sasha Letuchy, Environmental Engineer AECAB (MI/WI) THRU: Sarah Marshall, Section Supervisor AECAB (MI/WI) TO: File BASIC INFORMATION Facility Name: Calumet Tank & Equipment Facility Location: 12440 S Stony Island Ave, Chicago, Illinois 60633 Date of Inspection: June 26, 2024 EPA Inspector(s): 1. Sasha Letuchy, Environmental Engineer 2. Erin DuMontelle, Environmental Engineer 3. Giles Chickering, Environmental Engineer Other Attendees: 1. Dale Fancher, III, General Manager 2. Preston Forys, Environmental Manager (joined for closing conference only) Contact Email Address: dfancher@calumetcontainer.com, pforys@calumettank.com Purpose of Inspection: Determine compliance with the Clean Air Act and the Illinois State Implementation Plan (SIP) requirements related to volatile organic carbons (VOCs) for tank and truck washing facilities Facility Type: Truck washing Facility Name: Calumet Tank & Equipment Facility Location: 12440 S Stony Island Ave, Chicago, Illinois 60633 Date of Inspection: June 26, 2024 Regulations Central to Inspection: Clean Air Act (CAA) and the Illinois SIP Arrival Time: 8:55 AM Departure Time: 10:25 AM Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet: sent with inspection report Small Business Resource Information Sheet not provided. Provided CBI warning to facility The following information was obtained verbally from Dale Fancher, III unless otherwise noted. Process Description: Calumet Tank & Equipment (the facility) is a tank washing facility. The facility provides these services for tank trailers and International Organization for Standardization (ISO) containers. Materials formerly held in the containers include latex, paints, fatty acids (wax), soaps, resins, oils, glycols, solvents (toluene, iso propyl alcohol), adhesives, slurries, distillates, and mineral spirits. Containers that formerly contained certain materials cannot be washed and are identified on the facility's Do Not Wash list. Residuals are removed from the containers prior to cleaning, collected, and sent off for disposal. Cleaning operations differ depending on the material formerly contained. Cleaning operations can consist of steaming, steaming and hot water, steam and detergent (in hot water), detergents with additives, and a simple rinse. Hot water is kept at 180 - 190 F. Container washing occurs in four bays; Bays 3 and 4 are dedicated to latex/paint. Washes take approximately 45 minutes to two hours depending on the material formerly contained. Wastewater from the wash step in six of the bays is collected in floor drains and is pumped to the wastewater treatment plant (WWTP). No wash water is recycled back into the process. Trucks that need to be washed can be onsite for several days. The facility does not store any containers that are full onsite. Road dust is controlled during dry months using a spray truck and calcium chloride, applied as a dust suppressant 1-2 times per year. Staff Interview: Facility Name: Calumet Tank & Equipment Facility Location: 12440 S Stony Island Ave, Chicago, Illinois 60633 Date of Inspection: June 26, 2024 The facility has 19 employees and operates Monday - Friday, 24 hours per day, and Saturday and Sunday from 8AM - 8PM. Approximately 50 - 60 trucks can be washed in 24 hours. Prior to 2020, the Facility stated that they were cleaning higher numbers of tanks. Calumet Tank & Equipment has not conducted any stack testing. They are covered under a ROSS permit and conducted emission calculations during the permitting process, but do not update the calculations annually. Personal protective equipment is specified when washing the tanks depending on the previously contained materials; employees are required to wear half-mask respirators while cleaning some tanks. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: EPA toured the facility starting with the wash bays. Wash bays 1 - 4 are collocated in one building and were all in use. There were two pull behinds in Bay 4 and 3, a double ISO trailer with two containers in Bay 2, and one pull behind in Bay 1. There is an exhaust point above each bay which is equipped with a fan. The bay doors are left open during the summer and closed during the winter. None of the bays at the Facility have controls for the emissions created during the cleaning process. Two wash water drains are located in each bay. Wash liquids are shared for Bay 3 and 4 and include cold water, hot water (at 190 F), detergent (at 188 F) and detergent (195 F). Photos and/or Videos: were taken during the inspection and are listed in Appendix A. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: The Ross Permit and IEPA approval of application; Calculations that were used for the Ross Permit application; Annual calculation of air emissions from the facility (2020 - 2023); Facility Name: Calumet Tank & Equipment Facility Location: 12440 S Stony Island Ave, Chicago, Illinois 60633 Date of Inspection: June 26, 2024 Do not wash list; and Washed Trailer Logs for the past year (June 2023 to June 2024), in an excel or compatible format. On the log, indicate the contents of the material formerly contained in the trailer. For contents identified by trade name, provide the chemicals or mixture of chemicals in the container or copies of the technical data sheet (or SDS). Concerns: EPA stated that it was generally concerned with VOC emissions from washing operations and lack of controls. The facility indicated that it washed very few containers that formerly contained solvents. DIGITAL SIGNATURES ALEXANDR ALEXANDRA LETUCHY Digitally signed by Date: 2024.08.20 Report Author: _A__L_E_T__U_C__H_Y___15_:1_2:_37_-0_5'_00_' ____________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL Date: 2024.08.21 _M_A__R_S__H_A__L_L__0_8_:07_:2_0_-0_5'0_0_' _____________ APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log Facility Name: Calumet Tank & Equipment Facility Location: 12440 S Stony Island Ave, Chicago, Illinois 60633 Date of Inspection: June 26, 2024 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Erin DuMontelle Archival Record Location: Electronic Records Center\Enf_CalumetTank&Equipment_IL_24\Enf_CalumentTank &Equipment_IL_24_Insp\Photos Image Number 1 2 3 4 5 6 7 File Name P6260001.JPG P6260002.JPG P6260003.JPG P6260004.JPG P6260005.JPG P6260006.JPG P6260007.JPG Date and Time (incl. Time zone and DST) 6/26/2024 9:50 AM CT 6/26/2024 9:55 AM CT 6/26/2024 9:55 AM CT 6/26/2024 9:58 AM CT 6/26/2024 9:59 AM CT 6/26/2024 10:02 AM CT 6/26/2024 10:26 AM CT Description of Image Bay 4 truck washing Wash water tanks in Bay 3/4 Exhaust of Bay 4 Front ISO in Bay 2 being steamed Detergent and hot water in Bay 2 WWTP Bay 1 - 4