Document axX5K6vZnm6Z7GXwaKY3K8Xe

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Z Technologies Corporation, Redford, MI 48239 FROM: Aileen Drum, Physical Scientist AECAB (IL/IN) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: Z Technologies Corporation Facility Location: 26500 Capitol Avenue, Redford, MI 48239 Date of Inspection: February 27, 2024 EPA Inspector(s): 1. Aileen Drum, Physical Scientist 2. Emma Leeds, Environmental Engineer 3. Karina Kuc, Environmental Engineer Other Attendees: 1. Wayne Hall, Plant Manager 2. Jill Zimmerman, EGLE Environmental Engineer Contact Email Address: waynehall@ztechprotection.com , ellisbreskman@ztechprotection.com Purpose of Inspection: To ensure compliance with the Clean Air Act Facility Type: Paint and Coating Manufacturing Regulations Central to Inspection: Emissions thresholds in the Permit to Install issued June 26, 2008, and 40 CFR Part 63, Subpart CCCCCCC. Facility Name: Z Technologies Corporation Facility Location: 26500 Capitol Avenue, Redford, Michigan 48239 Date of Inspection: February 27, 2024 Arrival Time: 8:45 AM Departure Time: 10:30 AM Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Provided CBI warning to facility The following information was obtained verbally from Wayne Hall unless otherwise noted. Process Description: Raw materials including calcium carbonate, acetone, methyl ethyl ketone (MEK), mineral spirits, thickeners, and pigments are received at the dock, staged, and tagged. Batch tickets are prepared based on customer specifications. Water based paints are mixed in containers ranging from 300gallon totes to 1200-gallon tanks, and solvent-based paints are mixed in 3000-gallon reactors, which are pressurized vessels. Pressure is released from the reactors after the product cools. Final products are sent to the lab for quality control. Once cleared, the paints are packaged into 5-gallon pails, 50gallon tubs, and 330-gallon plastic totes. Shipments are distributed by truck. Staff Interview: The facility has 18 employees and runs production from 6am to 3pm Monday through Friday. Shipping is done on Saturday and Sunday. Three dust collectors serve as controls for the Barge Liner Tank, X-Tank 1, and X-Tank 2. The dust collectors are turned on when pigment is added. The facility has plans to install one additional dust collector for the American Axil Tank in response to observations of excess dust accrual on the floor overnight. Pressure drop is not monitored. There are no controls for VOCs, however all products produced are low VOC. Overhead exhaust fans run for most of the day. Reactors are heated to a maximum temperature of 265 degrees Fahrenheit. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: EPA walked the production process with a Toxic Vapor Analyzer (TVA) and a camera. A high TVA background reading of 51 ppm was recorded for the resin storage room. The American Axil Tank and Facility Name: Z Technologies Corporation Facility Location: 26500 Capitol Avenue, Redford, Michigan 48239 Date of Inspection: February 27, 2024 its associated baghouse were observed. On the second floor Reactors 1 and 2 were examined and a leak with a TVA reading of 12,900 ppm was found at Reactor 2. The top of Reactor 1 displayed buildup and corrosion. The baghouses for X-Tank 1 and X-Tank 2 were observed, according to Mr. Hall the filters are usually changed two times per week. Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Field Measurements: were taken during this inspection and are listed in Appendix B. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Monthly records for the preceding 12-month rolling time-period of the hours of operation for the product manufacturing portion of EUPROCESS Monthly records for the preceding 12-month rolling time-period of the amount of product produced in EUPROCESS Facility-wide emissions calculations including all emissions factors and assumptions in an unlocked excel spreadsheet for the preceding 12-months 2023 and 2024 Compliance Reports SDS sheets o Top 10 products produced (by quantity) o Top 10 VOC/HAP containing raw materials Most recent permit Process diagram Capacities of the baghouses Any reasons you may be reporting elevating levels of PM Concerns: EPA advised that there is a leak on Reactor 2 and that the TVA background reading for the resin storage room was high. DIGITAL SIGNATURES Digitally signed by Drum, Drum, Aileen Date: 2024.03.19 Aileen Report Author: _______________10_:4_5:4_3_-0_5'_00_' ___________ Section Supervisor: NATHAN Digitally signed by NATHAN FRANK Date: 2024.03.21 _F_R__A_N__K_______14_:0_6:_29_-_05_'00_' _____________ Facility Name: Z Technologies Corporation Facility Location: 26500 Capitol Avenue, Redford, Michigan 48239 Date of Inspection: February 27, 2024 APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log 2. Appendix B: Field Measurement Data APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Emma Leeds Archival Record Location: AECAB LIBRARY > Enf_ZTechnologiesCorp_MI_24 > Enf_ZTechnologiesCorp_MI_24_Inspection Image Number 1 File Name P2260179.JPG Date and Time (incl. Time zone and DST) 2/27/24 10:02 AM EST Description of Image Baghouse for Barge Liner Tank 2 P2260180.JPG 2/27/24 Reactor 2 where leak was 10:09 AM EST found P2260181.JPG 2/27/24 X-Tank 1 10:10 AM EST 3 P2260182.JPG 2/27/24 Filter baghouse over X- 4 10:13 AM EST Tank 1 P2260183.JPG 2/27/24 Top of Reactor 1 5 10:13 AM EST 6 P2260184.JPG 2/27/24 Front of X-Tank 1 10:15 AM EST 7 P2260185.JPG 2/27/24 Filter dust collector for X- 10:16 AM EST Tank 2 8 P2260186.JPG 2/27/24 Reactor #2 10:17 AM EST Facility Name: Z Technologies Corporation Facility Location: 26500 Capitol Avenue, Redford, Michigan 48239 Date of Inspection: February 27, 2024 APPENDIX B: FIELD MEASUREMENT DATA Span Gas (ppm methane) 500 1960 9750 TVA- B37055 Calibration Data TVA Reading (ppm methane) 486 1892 9688 Location Final product area Raw material resins Raw material solvents Raw material solvents and resins Above open drum of solvent based paint Reactor room Reactor 2 Reactor 1 Reading (ppm methane) 32 51 7.6 5.4 1040 222 12,900 128