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MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Essex Furukawa, Fort Wayne, Indiana FROM: Justin Smith, Environmental Engineer AECAB (IL/IN) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: Essex Furukawa Facility Location: 1601 Wall Street and 1700 West Swinney Ave, Fort Wayne, Indiana 46802 Date of Inspection: August 20, 2024 EPA Inspector(s): 1. Justin Smith, Environmental Engineer 2. Sasa Dunovic, Environmental Engineer Other Attendees: 1. Eric Trauner, Regulatory Compliance Manager, Essex Furukawa 2. Bob Distler, EHS Director, Essex Furukawa 3. Paul Karkiewicz, Air Compliance Inspector, Indiana Department of Environmental Management 4. Ryan Waldroup, Engineering Manager, Essex Furukawa (Tour Only) 5. Alan Siebert, Senior Engineer, Essex Furukawa (Tour Only) Contact Email Address: Eric.Trauner@essexfurukawa.com and Robert.Distler@spsx.com Purpose of Inspection: To determine compliance with facility's operating permit, T003-43872-00269 Facility Type: Magnet wire manufacturing Facility Name: Essex Furukawa Facility Location: 1601 Wall Street and 1700 West Swinney Ave, Fort Wayne, Indiana 46802 Date of Inspection: August 20, 2024 Regulations Central to Inspection: 40 CFR Part 63, Subpart MMMM - National Emission Standards for Hazardous Air Pollutants for Surface of Miscellaneous Metal Parts and Products Arrival Time: 1:30 PM EST Departure Time: 5:00 PM EST 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: Not a Small Business Provided CBI warning to facility The following information was obtained verbally from Essex Furukawa staff unless otherwise noted. Company Ownership: In 2020, Essex Magnet Wire and Furukawa Electric Company completed a joint venture. The combined parties started doing business as Essex Furukawa (Essex). Process Description: Essex operates both a coating production plant and a magnet wire coating plant located at 1601 Wall Street and 1700 West Swinney Ave respectively. Coating Production Plant Raw materials delivered to the facility for coating production are resins and solvents. Resins include polyesters, polyurethanes, and polyvinyl. Solvents include phenols, cresols, xylenes, and aromatic 100s. Solvents are delivered via tanker cars are and stored in the tank farm just east of the coating production plant. The tank farm consists of 24 storage tanks, each with a capacity between 10,000 and 15,000 gallons. There are also two unloading bays. Nitrogen is used to transfer solvents from the tanker cars by creating pressure inside and vapors are displaced to the atmosphere. Resins are delivered in drums and super sacs. The facility houses seven blend kettles, each with a capacity between 1,000 and 6,000 gallons, and three continuous stirred-tank reactors, each with a capacity between 5,000 and 6,000 gallons. Water cooled condensers are used for the reactors and kettles. A media mill is used to grind beads. A dust collector is used collect particle emissions from the media mill. Solvents are transferred to the reactors via pumps and pipes, and resins are transferred to the reactors directly from their containers. Reactors run for several hours, with the length depending on the batch being made. Completed Page 2 of 5 Facility Name: Essex Furukawa Facility Location: 1601 Wall Street and 1700 West Swinney Ave, Fort Wayne, Indiana 46802 Date of Inspection: August 20, 2024 mixtures go through filtration then are dispensed into 400-gallon totes and 55-gallon drums for delivery. Magnet Wire Coating Plant Facility receives copper and aluminum rods. Rods are drawn into the desired shape and size and then passed through an annealing oven. The wire goes through flow coating bath and a series of dyes contained within a permanent total enclosure (PTE). The coated wire then goes back through the oven for curing. Essex operates 15 oven lines, and several ovens have an internal oxidizer to control emissions. Ovens that do not have an internal oxidizer have their emissions routed to an incinerator. There are two incinerators at the facility. After wire is cooled, it is assembled into spools for weighing and then prepared for shipment. Staff Interview: Essex monitors the facial velocity of air in the PTE to check if the direction of the air flow goes into the enclosure. Approximately 90% of the wire they receive is copper and the remaining is aluminum. Emissions from oven lines identified as Ovens 53 through 57 are routed to the west incinerator, and emissions from oven lines identified at Ovens 58 through 60 are routed to the east incinerator. The temperature for the thermal oxidizers is monitored with two thermocouples and those are calibrated or replaced quarterly. There are three alarm buffers that give warning when the temperature drops close to the 3-hour average minimum temperature limit. Essex stated that they are not required to conduct a performance test on each oven line with internal oxidizers every five years. Instead, they can select a representative oven line for the performance test where the representative oven line is very similar to the other lines that it is representing. A performance test for an oven line would not be repeated until all oven lines in the representative group have been tested. Essex has two distinct oven types with internal oxidizers made by different manufacturers. Copper scrap is melted off-site then returned as copper wire rods. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: EPA observed the outside tank farm, coating production operation, and wire coating operation. EPA utilized a FLIR optical gas imaging (OGI) camera, FLIR GF 320 IF, during the tour. On the roof of the coating production plant, EPA inspectors observed emissions coming from reactor R-2's stack on the FLIR. Essex staff stated that heat is applied to reactor to drive water off and the emissions were potentially water vapors. Thermocouple readings for the thermal oxidizers and incinerators were observed, with the lowest temperature observed as 1395F (excluding Oven 61 which was down at the time of tour). Essex staff stated that the minimum temperature limit was approximately 1000 F for the thermal oxidizers. The mimimum temperature limit for the incinerators was not stated, but there did not appear to be visual indicators of low temperatures on the incinerator control panels. Page 3 of 5 Facility Name: Essex Furukawa Facility Location: 1601 Wall Street and 1700 West Swinney Ave, Fort Wayne, Indiana 46802 Date of Inspection: August 20, 2024 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: MACT Semi-annual reports submitted in the last three years Quarterly deviation and monitoring reports submitted in the last three years Emission calculations for the past two years Past performance tests for thermal oxidizers Results of capture efficiency measurements conducted in the last two years 3-hour average temperature records monitored on the incinerators that control emissions from ovens 52-66 for the period of August 1, 2023, to July 31, 2024. DIGITAL SIGNATURES JUSTIN SMITH Date: 2024.10.09 14:35:39 -05'00' Digitally signed by JUSTIN SMITH Report Author: _________________________________ Section Supervisor: Frank, Nathan Digitally signed by Frank, Nathan Date: 2024.10.15 16:50:01 -05'00' __________________________________ APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log Page 4 of 5 Facility Name: Essex Furukawa Facility Location: 1601 Wall Street and 1700 West Swinney Ave, Fort Wayne, Indiana 46802 Date of Inspection: August 20, 2024 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Sasa Dunovic Archival Record Location: Enf_EssexFurukawa_IN_24_InspRpt Image Number 1 File Name MOV_3476 Date and Time (incl. Time zone and DST) 8/20/2024 2:41 PM EST Latitude and Longitude N/A Description of Image R-2 stack emissions 2 MOV_3478 8/20/2024 N/A Confidential Business 3:29 PM EST Information Page 5 of 5