Document dQ4rDeEjm7z0X66ObVK4jkQJ9

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 MAR 1 8 2019 CLEAN AIR ACT INSPECTION REPORT Powder Processing and Technology, LLC., Valparaiso, Indiana Vicky Mei, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Powder Processing and Technology, LLC. (PPT) Facility Location: 5103 Evans Ave., Valparaiso, Indiana Date of Inspection: June 28, 2018 EPA Inspector(s): 1. Vicky Mei, Environmental Engineer 2. Sarah Clark, Environmental Engineer Other Attendees 1. Brad Monton, Manager of Operations, Powder Processing and Technology Contact Email Address: bmonton@pptechnology.com Purpose of Inspection: Assess compliance with the Clean Air Act Facility Type: Metal oxide product manufacturing Arrival Time: 10:30AM Departure Time: 1: 11PM Inspection Type: IZI Unannounced Inspection  Announced Inspection OPENING CONFERENCE ISi Credentials Presented ISi CBI warning to facility provided The following information was obtained verbally from Mr. Monton unless otherwise noted. Process Description: Since 2002, PPT has been owned by EJ Vestco Company. PPT processes powder in batches on a contract basis. Raw materials are primarily oxide-based, though PPT also processes nitrate-based materials and nickel-metal. Depending on the material and customer needs, PPT may process the oxide powders through a variety of units, such as direct- and indirect-fired calciners, spray dryers, kilns, and ball millers that are scattered throughout the plant in Areas A, B, and C. Nickel-metal is processed in calciners, Area C kiln, ball mill, and spray dryer, sequentially. Calciners operate at high temperatures, up to 2000 P, and are used for moisture removal and some phase change. The #6, #10, #11, and #12 Calciners can process nitrate-based products, though this is rare for #10. The #2 and #9 Calciners have been dedicated to processing iron oxide for catalyst applications for the past 5 years. The spray dryers are used to dry and reshape slurry materials, as follows: the Area A Spray Dryer makes materials more 'flowable' for use in the oil industry; within the Area B Spray Dryer, zinc oxide reacts with weak hydrochloric acid to produce zinc chloride, which is then dried and sold for use as a micronutrient in animal feed; and the Area C Spray Dryer, which only operated for six months in 2017, usually processes alumina into small beads. The spray dryers run at inlet temperatures of 500 to 800 P and outlet temperatures of220 to 600 P. The Area C kiln is operated approximately once per month for two weeks for small 10-ton production batches consisting of electric powders or multilayer chip beads. Material is hand-loaded into a kiln car and heated up to 2400 P. The North kiln was last operated 10 years ago, and the South kiln last operated in October 2017. The North and South kilns operate at higher temperatures of around 2800 P. The pilot 14-inch diameter calciners and dryers in the Innovative Material Center pilot lab process low solids materials at a slow throughput rate. Most units are controlled by pulse jet cartridge-style dust collectors, several of which (identified in PPT's Title V permit) are considered 'integral.' A NOx scrubber, connected in series to a dust collector, controls the #6, #10, #11, and #12 calciners when nitrate-based products are processed. The scrubber operates at a box temperature around 550 P and injects 19% ammonia at about 10 gallons per hour. The injection rate automatically adjusts to achieve 97% removal based on the measured inlet amount ofNOx. Staff Interview: According to Mr. Monton, the facility started as a powder processing plant in 1959. At some point in the company's recent history, a Phase 3 Environment remediation was completed which Page 2 ofS included the digging out of two retention ponds that contained barium and removing hazardous waste barrels. The ratio of nitrate to oxide materials processed at PPT is about 28:72, with majority of the materials being zinc oxide, iron oxide, and manganese oxide. The facility experienced a 40% increase in business in 2017. The #12 Calciner was installed in June 2018. PPT conducted the first #12 Calciner trial run at the end of June and had another trial scheduled for July 2018. The NOx scrubber was installed in 2015. The most recent emissions test, conducted in December 2015 while running one calciner (#6), measured a control efficiency of97-98%. Differential magnehelic pressure gauges on the dust collectors are checked daily and calibrated annually. The stacks are visually checked 4 times each day. No combustible dust is used. At the time of the EPA inspection, the #7 and # 11 Calciners and the Area B Spray Dryer were in operation. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: Calciner # 11: Material feed rate: 400 pounds per hour NOx scrubber: Inlet measurements: 851.8 ppm ofNOxand 2.0% CO2 Outlet measurements: 0.0 ppm ofNOxand 0.4% CO2 Ammonia feed rate: 6.51 gallons per hour NOx scrubber box temperature: 541.9 F Differential Pressure: 2.6 inches of water column Calciner #12: The process area and equipment were caked in white powder (zinc). Mr. Monton explained that a trial run was cancelled, so manpower was diverte\i. Area B Spray Dryer: The process area and equipment were dusty (zinc). Mr. Monton explained that the area is swept every day around 3 pm. Dust Collector for Calciners #2 and #9: 2.4 inches of water column Photos and/or Videos: were taken during the inspection. Page 3 ofS Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Requested documents: Most recent emissions tests for the NOx scrubber and spray dryers Emission estimates and calculations 2017 NOx scrubber box temperatures and ammonia flow rates 2018 Pressure logs for dust collectors 2018 Maintenance logs ofdust collectorpressure gauges 2016-2017 Toxic Release Inventory 201 7 Quarterly deviation report 2018 Compliance Monitoring Report 201 7 Emergency Occurrence Reports 2017-2018 Daily visual stack checks 2018 SIGNATURES Page 4 of 5 Facility Name: Powder Processing and Technology, LLC. Facility Location: 5103 Evans Ave., Valparaiso, Indiana Date of Inspection: June 28, 2018 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log Page 5 ofS Facility Name: Powder Processing and Technology, LLC. Facility Location: 5103 Evans Ave., Valparaiso, Indiana Date of Inspection: June 28, 2018 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Sarah Clark 3. Company/Facility Name: Powder Processing and Technology, LLC. 5. Number of Images: 15 2. Date(s) of Inspection: June 28, 2018 4. Street Address, City, State: 5103 Evans Ave., Valparaiso, Indiana 6. Archival Record Location: CD-R, labelled "Powder Processing Technology, LLC Valparaiso, IN Inspection Photos 6-28-2018" Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 File Name P6280001.JPG P6280002.JPG P6280003 .JPG P6280004.JPG P6280005 .JPG P6280006.JPG P6280007 .JPG P6280008.JPG P6280009 .JPG Date and Time (CDT) 6/28/2018 11:49 6/28/201811:49 6/28/2018 11 :54 6/28/2018 11 :54 6/28/2018 11 :55 6/28/2018 11:56 6/28/2018 11 :56 6/28/2018 12:06 6/28/2018 12:06 Latitude and Lone;itude 41.478333, -86.998056 41.478333, -86.998056 41.478333, -86.998056 41.478333, -86.998056 41.478333, -86.998056 41.478333, -86.998056 41.478333, -86.998056 41.478333, -86.998056 41.478333, -86.998056 P628001 0.JPG P6280011.JPG P6280012.JPG 6/28/2018 12:10 6/28/2018 12:11 6/28/2018 12:11 41.478333, -86.998056 41.478333, -86.998056 41.478333, -86.998056 P6280013 .JPG 6/28/2018 12:11 41.478333, -86.998056 P6280014.JPG 6/28/2018 12:13 41.478333, -86.998056 P6280015.JPG 6/28/2018 12:32 41.478333, -86.998056 Description of Image Inlet NOx Control Outlet NOx Control #12 Calciner #12 Calciner #12 Calciner, overhead vent #12 Calciner, overhead vent #12 Calciner Area B slurry making Area B slurry making Area B Spray Dryer dust collector pressure drop Area B Spray Dryer cyclones Area B Spray Dryer cyclones Area B Spray Dryer cyclones and dust collector Area B Spray Dryer cyclones and dust collector Dust Collector for #2, #9 Calciner Appendices Page 1 of 1