Document NeBeMnRKjXNdMD0GJJDNwyNny

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Steel Warehouse of Ohio, Cleveland, Ohio FROM: Matthew Walters, Environmental Engineer AECAB (MN/OH) THRU: Brian Dickens, Section Supervisor AECAB (MN/OH) TO: File BASIC INFORMATION Facility Name: Steel Warehouse of Ohio Facility Location: 3193 Independence Road, Cleveland, OH 44105 Date of Inspection: April 25, 2024 EPA Inspector(s): 1. Matthew Walters, Environmental Engineer 2. Carlo Demma, Physical Scientist Other Attendees: 1. Steven Balog, Quality Manager, Steel Warehouse of Ohio 2. Matt Woodward, Production Supervisor, Steel Warehouse of Ohio 3. Jamie Sobonya, Environmental Consultant, HZW Contact Email Address: steven.balog@steelwarehouse.net, jdietz@hzwenv.com Purpose of Inspection: HCl pickling line inspection Facility Type: Steel pickling Regulations Central to Inspection: Federally enforceable PTIO conditions (Permit No. P0128786) Arrival Time: 8:15 a.m. Departure Time: 9:25 a.m. Inspection Type: Unannounced Inspection Announced Inspection Facility Name: Steel Warehouse of Ohio Facility Location: 3193 Independence Road, Cleveland, OH 44105 Date of Inspection: April 25, 2024 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 facility personnel unless otherwise noted. Process Description: The facility has one HCl pickling line that was constructed in 2019. The facility normally operates from 6 a.m. to 4:30 p.m., Monday through Friday. Sheet steel produced at Steel Warehouse's adjacent main plant is received at the facility and staged for pickling. The facility does not perform any prewashing or shot blasting operations prior to pickling. The pickling line consists of one acid tank and one rinse tank. The acid tank is broken into stages to allow the HCl concentration to change as the steel plates move through the line, with 13% being the strongest HCl concentration used. The pickling line is enclosed, with emissions routed to a single stage scrubber. A blower at the exit of the pickling line removes rinse water and then rust inhibitor is applied to the steel sheet at the oiler machine. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: Sheet steel was being pickled at the time of the inspection, with the acid tank operating at approximately 145F. Inspectors did not observe any significant fugitive steam leaks from the pickling line enclosure. Inspectors observed the operation of the oiler at the end of the pickling line: o The surface of the steel plates was dry upon entering the oiler. o No oil overspray was observed. o Rags were positioned around the oiler to absorb oil drips. Facility personnel indicated that a hydrostatic oiler was on order to provide better control of oil application. Page 2 of 5 Facility Name: Steel Warehouse of Ohio Facility Location: 3193 Independence Road, Cleveland, OH 44105 Date of Inspection: April 25, 2024 PTIO condition C.1(d)(2) states that the scrubber pressure drop shall be between 6 and 12 inches of water, scrubber liquid flow rate shall be not less than 2.0 gallons per minute when the emissions unit is in operation, and pH of the water flowing into the scrubber shall be maintained at a pH of not less than the pH of the incoming municipal water. o Inspectors observed the following continuously monitored scrubber parameters: 7.5 inches of water scrubber pressure drop measured by a Magnehelic differential pressure gauge. 2.8 gallons per minute of municipal makeup water measured by a rotometer. o Inspectors observed a sample port on the scrubber liquid circulation line where the facility takes grab samples to measure pH at an onsite lab. The pH probe in the lab was stored in pH 7 calibration solution at the time of the inspection. The "wet section" of the facility had drums containing an oil/water mixture and an anti-foam, two 10,000 gallon fresh HCl storage tanks, and two rust inhibitor storage tanks. Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: The following daily scrubber records for each operating day from February 1st through April 25th: o Pressure drop (inches of water) o Flow (gallons per minute) o pH Pickling line stack test report Pickling line PTE calculations SDS for rust inhibitor oil Raw material HCl concentration Page 3 of 5 DIGITAL SIGNATURES Report Author: Facility Name: Steel Warehouse of Ohio Facility Location: 3193 Independence Road, Cleveland, OH 44105 Date of Inspection: April 25, 2024 MATTHEW Digitally signed by MATTHEW WALTERS WALTERS Date: 2024.05.30 15:54:23 -05'00' _________________________________ Section Supervisor: Digitally signed by BRIAN BRIAN DICKENS DICKENS Date: 2024.05.31 09:28:30 -05'00' _________________________________ APPENDICES A. Digital Image Log Page 4 of 5 APPENDIX A: DIGITAL IMAGE LOG Facility Name: Steel Warehouse of Ohio Facility Location: 3193 Independence Road, Cleveland, OH 44105 Date of Inspection: April 25, 2024 Inspector Name: Carlo Demma Archival Record Location: R5 Electronic Record Center\AECAB Library\Enf_Steel Warehouse Independence_OH_24\Inspection_2024.04.25\Photos Image Number 1 2 3 4 5 6 File Name IMG_0555.JPG IMG_0556.JPG IMG_0557.JPG IMG_0558.JPG IMG_0559.JPG IMG_0560.JPG Date and Time (EDT) 2024:04:25 09:06:36 2024:04:25 09:08:45 2024:04:25 09:08:56 2024:04:25 09:10:17 2024:04:25 09:12:39 2024:04:25 09:12:39 Description of Image Scrubber Magnehelic differential pressure gauge City water line to scrubber makeup flow rotameter Rotameter for scrubber makeup flow Sample port for pH grab samples on scrubber liquid circulation line Scrubber blower and stack Scrubber blower and stack Page 5 of 5