Document RJ4qNzO6woo8Jdwa2ERYqp2oX

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Chemtrade Solutions LLC, Fairmont City, IL Brittany Cobb, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Chemtrade Solutions LLC Facility Location: 2500 Kingshighway, Fairmont City, IL Date of Inspection: 7/22/2022 EPA Inspector(s): 1. Brittany Cobb, Environmental Engineer 2. Ethan Chatfield, Environmental Engineer Other Attendees: 1. Gustavo Tonding, Plant Manager 2. Robb Woolen, EHS Manager Contact Email Address: rwoolen@chemtradelogistics.com Purpose of Inspection: Determine compliance with the CAA Facility Type: Chemical manufacturer Regulations Central to Inspection: IL State Implementation Plan Arrival Time: 11:00 AM CT Departure Time: 1:00 PM CT Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet via email Provided CBI warning to facility The following information was obtained verbally from Gustavo Tonding or Robb Woolen unless otherwise noted. Company Ownership: Chemtrade purchased this facility from General Chemical in 2014. Process Description: Chemtrade produces liquid, dry and bulk chemicals for water and wastewater treatment. The primary chemicals produced are aluminum chloride and aluminum sulfate. The raw materials include 36% concentrated HCl, 93% concentrated sulfuric acid, ferric sulfate, hydrate, a polymer and aluminum ingots, which are delivered by rail. Ferric sulfate is delivered in bulk bags and the rest of the material is offloaded into storage tanks. There are two reactors, 5,000 gallons each, used to produce pressurized poly-aluminum chloride (PPAC) and 7 blending vessels to produce poly-aluminum chloride (PAC). The PAC blending vessels run 24 hours per day, 7 days per week. One PPAC reactors operates 17 hours per day and the other operates 9 hours per day. There are also two 15,000-gallon sulfuric acid storage tanks and one HCl storage tank. Additionally, there are two digestors open to the atmosphere used to produce aluminum sulfate with no air emission controls. Chemtrade has one scrubber to control emissions from the HCl storage tank and both PPAC reactors. Chemtrade measures scrubber fluid flow rate and conductivity, in order to calculate the concentration of HCl, which is monitored from the PPAC control room. Chemtrade does not measure the pH of the scrubber. Chemtrade disposed of the waste liquid from the scrubber weekly. There are also four baghouses: one baghouse for the hydrate silo, one baghouse for the PPAC, one baghouse for milling and one baghouse for aluminum unloading. Only one of the baghouses has a gauge for differential pressure. There are four controls rooms at the facility: Aluminum Production, Liquid Aluminum production, PAC area production, and PPAC production. Staff Interview: This facility is operational 24 hours per day, 7 days per week and has 34 employees. There have been recent changes in management in the past year. Page 2 of 4 The facility is currently operating under a construction permit. In Chemtrade's Lifetime Operating Permit, there are two aluminum sulfate mix tanks and one liquid aluminum sulfate mix tank controlled by scrubbers. Chemtrade informed EPA that they no longer use these tanks and instead use digestors with no air emissions controls. The Lifetime Operating Permit also requires a dust collector to control emissions from bulk bag unloading in PAC production, Chemtrade was unsure if they have this dust collector. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA observed excess hydrate on the ground near the railcar (IMG_0117.JPG), silo and throughout the building (IMG_0121.JPG). EPA observed the seed hopper, where very fine dry aluminum hydrate is added to accelerate the drying process. EPA observed the scrubber fluid flow rate to be 15.2 gallons per minute and the concentration of the liquid was 3.56% HCl. Photos and/or Videos: were taken during the inspection. Field Measurements: were taken during this inspection. RECORDS REVIEW 1. PMs on scrubber up until 7/18/2019 2. Lifetime operating permit CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: SDSs of all raw materials Construction permit Construction permit application FESOP, if approved yet PM on the scrubber since 7/18/2019 PM on baghouses since 7/18/2019 Records of scrubber fluid flow rate, temperature, and pH since January 1, 2021 Records of differential pressure on all baghouses, if these records are kept, since 1, 2021 Process flow diagram, including all vessels and air emission control devices January Page 3 of 4 Concerns: 1. EPA identified concerns with excess hydrate and liquid spills on the ground. 2. EPA identified the concern that the same scrubber used to control emissions from the HCl storage tanks is being used to control emissions from the PAC reactors, as the permit identified separate control devices. 3. EPA identified concern that there is no dust collector for the PAC bulk bag unloader, as required in the lifetime operating permit DIGITAL SIGNATURES Digitally signed by Brittany Cobb Date: 2022.09.08 Brittany Cobb 11:05:39 -05'00' Report Author: _________________________________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL MARSHALL 12:24:52 -05'00' Date: 2022.09.08 __________________________________ Page 4 of 4 Facility Name: Chemtrade Solutions LLC Facility Location: 2500 Kingshighway Date of Inspection: July 22, 2022 APPENDICES AND ATTACHMENTS 1. Digital Image Log Page 5 of 4 Facility Name: Chemtrade Solutions LLC Facility Location: 2500 Kingshighway Date of Inspection: July 22, 2022 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Brittany Cobb Image Number File Name 1 IMG_0117.JPG 2 IMG_0118.JPG 3 IMG_0119.JPG 4 IMG_0120.JPG 5 IMG_0121.JPG 2. Archival Record Location: Onedrive Date and Time (Central Time) 7/22/2022 12:08 PM 7/22/2022 12:26 PM Description of Image Railcar offload location for hydrate, excess hydrate on the ground. Wet scrubber for HCl tank and reactors 7/22/2022 12:26 PM 7/22/2022 12:27 PM Digital gauge for conductivity of wet scrubber (3313 mS/cm) Scrubbant for wet scrubber 7/22/2022 12:35 PM Hydrate and liquid spilled on floor. Appendices Page 1 of 1