Document MJJ4pdrrvMrJavbVQD0zzYN1k

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Victory White Metal Company, Cleveland, Ohio FROM: Dakota Prentice, Environmental Engineer AECAB (IL/IN) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: Victory White Metal Company Facility Location: 3027 East 55th Street, Cleveland, Ohio Date of Inspection: November 15, 2023 EPA Inspector(s): 1. Dakota Prentice, Environmental Engineer 2. Liam Klaiman, Environmental Engineer 3. Meaghan Pashen, Environmental Engineer Other Attendees: 1. Ben Krafcik, Victory White Metal Company - Quality Manager Contact Email Address: Ben Krafcik - bkrafcik@vwmc.com Purpose of Inspection: to determine compliance with the Ohio state implementation plan (SIP) Facility Type: Lead Alloy Manufacturing Regulations Central to Inspection: Ohio SIP Arrival Time: 8:30am Departure Time: 9:45am Inspection Type: Unannounced Inspection Announced Inspection Facility Name: Victory White Metal Company Facility Location: 3027 East 55th Street, Cleveland, Ohio Date of Inspection: November 15, 2023 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 Ben Krafcik unless otherwise noted. Process Description: The facility produces lead alloy products including anodes, solder, ingots, and billets. Production starts at one of five melt pots in the casting area. At the melt pots, lead ingots are melted down with additional metals, typically tin and/or antimony, added to meet final product specifications. The melt pots are controlled by the facility's one baghouse. Process cycle times range from approximately one to three days. At the end of the cycle, the metal is cast to produce ingots or billets. Ingots are final products, while most billets move to extrusion. At one of three extrusion melt pots, the billets are melted down then extruded into wire or anodes. Emissions from the extruder melt pots are controlled by the baghouse. Final products are then shipped to customers. Staff Interview: The facility operates Monday through Friday from 7:30am to 4:30pm and employs 30 people, 20 on the shop floor and 10 in the office. The facility does not have an air permit from Ohio EPA. There are respirator areas at the facility, including at casting and cutting. Blood-lead monitoring is conducted for facility personnel. The melt pots typically maintain some molten metal while the facility is not in operation. The baghouse may not always be operated while the furnaces contain molten lead. Baghouse fires have occurred previously. In response to these fires, a fire suppression system was installed at the baghouse. No previous emissions testing has been conducted at the baghouse. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA observed the five melt pots in the casting area. The largest melt pot, a 40,000 pound capacity unit, is currently not in operation due to a broken conveyor. EPA observed open roof monitors in the room containing these melt pots. Each melt pot has a hood for emission capture. At the extrusion process, EPA asked about a lack of airflow at a hood over a melt pot. EPA was informed that the facility's baghouse was not in operation. Facility personnel then turned the baghouse on. There is Page 2 of 4 Facility Name: Victory White Metal Company Facility Location: 3027 East 55th Street, Cleveland, Ohio Date of Inspection: November 15, 2023 neither monitoring nor specified operating parameter limits for baghouse pressure drop. The pressure drop across the baghouse at the time of the inspection, when operational, was approximately 0.1 inches of water. EPA observed building openings between respirator and non-respirator areas of the shop and building openings to atmosphere. Photos and/or Videos: were taken during the inspection. See Appendix A. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Information on baghouse capacity; Baghouse manufacturers recommended operating conditions; Baghouse performance test records, if testing has been performed; Any permit documentation or communications with Ohio EPA and/or Cleveland Department of Public Health related to air emissions; and Facility emissions calculations. Concerns: EPA noted the failure to operate the baghouse while lead emission units were in operation as an area of concern. DIGITAL SIGNATURES DAKOTA Digitally signed by DAKOTA PRENTICE Report Author: _P_R__E_N__T_IC__E___0_9_:38_:1_6_-0_6'0_0_' ____________ Date: 2023.11.27 Section Supervisor: NATHAN Digitally signed by NATHAN FRANK _F_R_A__N_K_______1_6:_47_:5_7 -_06_'0_0'______________ Date: 2023.11.30 Page 3 of 4 APPENDICES AND ATTACHMENTS Appendix A: Digital Image Log Facility Name: Victory White Metal Company Facility Location: 3027 East 55th Street, Cleveland, Ohio Date of Inspection: November 15, 2023 Page 4 of 5 Facility Name: Victory White Metal Company Facility Location: 3027 East 55th Street, Cleveland, Ohio Date of Inspection: November 15, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: M. Pashen 2. Archival Record Location: Region 5 Electronic Record Center Image File Name Date and Time Latitude and Description of Image Number (incl. Time zone Longitude and DST) 1 IMG_0441.JPG 2023:11:15 Not Available Furnace Nos. 15, 16, 17, and 09:21:41 18 2* IMG_0442.JPG 2023:11:15 Not Available Extrusion Machine 09:25:27 3 IMG_0443.JPG 2023:11:15 Not Available Baghouse 09:29:35 4 IMG_0444.JPG 2023:11:15 Not Available Baghouse and duct run from 09:30:11 furnaces * Image No. 2 of the Extrusion Machine was claimed as confidential business information Page 5 of 5