Document daMD7LJm39VQLVN3V7j08LL7q

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Metalworking Lubricants Company, Indianapolis, Indiana Linda H. Rosen, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Supervisor AECAB (IL/IN) File BASIC INFORMATION Facility Name: Metalworking Lubricants Company Facility Location: 1509 South Senate Avenue, Indianapolis, Indiana Date of Inspection: March 3, 2023 EPA Inspector(s): 1. Linda H. Rosen, Environmental Engineer Other Attendees: 1. Robert Peachey, Attorney, Office of Regional Counsel, EPA Region 5 2. Richard Gladstein, Attorney, Environmental Enforcement Section, U.S. Department of Justice 3. Matthew Chaifetz, Office of Air Quality (OAQ), Compliance and Enforcement Section, Indiana Department of Environmental Management (IDEM) 4. Valerie Tachiritis, Attorney, IDEM 5. Kyle Burns, Attorney, IDEM 6. Brian Williams, OAQ-Permits, IDEM 7. Andy Belt, OAQ-Permits, IDEM 8. Leigh Anne Harvey, Office of Land Quality, Compliance, IDEM 9. Trent Bennett, Attorney, Indiana Attorney General 10. Keith Johnson, Plant Manager, Metalworking Lubricants Company 11. Adam Bujoll, Vice-President, Metalworking Lubricants Company 12. Bill Souders, Assistant Plant Manager, Metalworking Lubricants Company (tour only) 13. Colin Connor, Attorney for Metalworking Lubricants Company Page 1 of 6 Facility Name: Metalworking Lubricants Company Facility Location: 1509 South Senate Avenue, Indianapolis, Indiana Date of Inspection: March 3, 2023 14. Amy Romig, Attorney for Metalworking Lubricants Company (via phone) Contact Email Address: abujoll@metalworkinglubricants.com Purpose of Inspection: To observe Metalworking Lubricants Company's (MLC) current operations in relation to Consent Decree requirements and its Federally Enforceable State Operating Permit (FESOP). Facility Type: tank facility Regulations Central to Inspection: U.S. and the State of Indiana vs. Metalworking Lubricants Company, Consent Decree entered 9/20/2022, Civil No. 1:22-cv-01560-JMS-DLP, and MLC's FESOP Arrival Time: 9:00 a.m. Departure Time: 2:45 p.m. 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: Previously Provided Provided CBI warning to facility The following information was obtained verbally from MLC's representatives unless otherwise noted. Process Description: MLC operates a blending operation where raw materials (e.g., Brite stock high viscosity lube oil, hydraulic oils and blending stock) are mixed with additives (e.g., rust and oxidation inhibitors, demulsifying agents, anti-wear package, and R & O package) in Tanks M1-M5 to make product oils including lubrication oils for bearings, gear oils, and hydraulic oils. MLC also takes in off spec fuel from various customers in the smokestack industries and ships it back out. MLC stated that the fuel product goes out as it comes in, but the diagram provided on February 15, 2023 by MLC indicates that chemicals are added. The M Tanks are currently unheated due to the on-site boiler being inoperable. The M tanks are normally heated to up to 190 degrees Fahrenheit (F). The M tanks are agitated and are not connected to the scrubber. All purchased raw material oils come from virgin crude. Products are shipped out in tank wagons of various sizes from 55 gallon to 7500 gallons or are stored in the B tanks. Page 2 of 6 Facility Name: Metalworking Lubricants Company Facility Location: 1509 South Senate Avenue, Indianapolis, Indiana Date of Inspection: March 3, 2023 The facility operates a tank wagon flushing operation. The inside of tank wagons containing residual oil and solids are flushed with ambient-temperature water for about 20 minutes. When the boiler becomes operational, the water will be heated to 100-140F. After the flush, the vehicles are sent to an off-site commercial truck washing facility. The water is sent to the facility's trench system and then to the small pit in the wastewater treatment plant (WWTP) where it is reprocessed for reuse or shipped off-site. The truck flushing operation is uncontrolled. In-house water processing takes stormwater and in-house wastewater from the small pit and treats it with chemicals under heat (maximum 140F when the boiler becomes operational) in the SHT2 tank, which is vented to the scrubber. The wastewater off this process is sent to the WWTP and the solids are shipped out for disposal. The WWTP takes in water from the in-house water process operation and from the dewatering process (discussed below) and treats it so that it can be shipped off site. Wastewater from the small pit is returned to in-house water processing or the big pit for storage. No equipment is controlled in the WWTP. The wet solids from the FET1-FET4 settling tanks in the WWTP and from in-house water processing are dewatered in the Geo Tube tank. Wet solids from the WWTP are heated in the W8 tank to 140F (when the boiler is operational) to produce oil which is sent to the customer or off-site disposal and wastewater is sent to the WWTP. The W8 tank is connected to the scrubber. The Geo Tube is not connected to the scrubber. Staff Interview: The facility currently sends out about two wagons of product per week. The B tanks are being used mostly for raw materials. The dryers are no longer operating. Some of the P tanks still contain material but have not been processing since November 12, 2022. In addition, Tanks W2-W7 are no longer operating. SHT2 and W8 are operating and connected to the scrubber. The FET tanks are operating but are not controlled and do not meet fixed roof tank requirements. The tanks are not being used for industrial wastes but essentially are recovering rainwater. Seven tanks were to be removed and 5 were to be added but no tanks have been removed partly due to the boiler not being operational. MLC does not intend to install a new carbon adsorption system, as required by the Consent Decree. MLC provides centrifuges to facilities and provides consulting services so that these facilities can process their waste at their location and sell the product to MLC. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: I observed the loading and load out operation which consisted of two manifolds (Photos 1-8). I observed a tank wagon used for product (Photos 9-10). Inside the blending room, I observed the M tanks (Photo 11). They are 4500 to 6000 gallons each. They were not operating. I observed the pump that is used to bring liquids from the tank farm to the top of the tank (Photo 12), During Page 3 of 6 Facility Name: Metalworking Lubricants Company Facility Location: 1509 South Senate Avenue, Indianapolis, Indiana Date of Inspection: March 3, 2023 the tour, MLC clarified that they have not been testing incoming materials per the FESOP since November 2022. They rely on the customers specifications or the results of previous testing. I observed tank liquid overflow and vents for gas (Photos 13-16). The vents work similarly to a hot water heater. I saw a silver tank wagon that they were using for storage at the truck flush station (Photos 17-18). The truck flush was not operating during the inspection. It was raining on the day of the inspection and there were copious amounts of oil, sludge, mud and water on the ground of the facility (Photos 19-22). I observed the processing tanks (Photos 23-24). They were not processing although about 60 percent of them still contain material. I observed an out of service trailer (Photos 25-26), used drums (Photos 27-30) and a tank truck with nothing in it (Photos 31-32). From the east side of the facility, I observed the processing tanks (Photos 33-34). MLC stated that the scrubber was still operating and that the P tanks were still connected to the scrubber. I observed the scrubber, existing carbon box and stack (Photos 35-41). Next, we went inside and observed the WWTP, specifically, the DAF (Photo 43) and the clarifier (Photo 44). There was a lot of oily water and sludge throughout the plant (Photos 45-49 and 52). I observed where the water circulates from the DAF (Photo 50). I observed the Big Pit which was covered (Photo 51), a caustic chemical tank which MLC claims is no longer used (Photo 53), one of the FET tanks (Photo 54), and the SHT2 tank (Photos 55-57). Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW During the inspection, MLC provided a facility diagram and schematic diagrams of the following processes. These diagrams are located in EPA's Electronic Records Center. WWTP Dewatering Process Truck Flush Process In-house Water Processing Finished Product Blending CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: MLC's redline proposed changes to the CD based on changes in operations; Updated, current diagrams of what equipment is operating; Page 4 of 6 Facility Name: Metalworking Lubricants Company Facility Location: 1509 South Senate Avenue, Indianapolis, Indiana Date of Inspection: March 3, 2023 Quantity and type of all incoming materials and all outgoing products/materials; Monthly report of emissions instead of quarterly as required by the FESOP; Names of the customers where work is done offsite; Stack test report done 3/8/22; and Water generation points at the facility and quantities We stated that we would be sending them an email with requested documents that may include others not listed here. DIGITAL SIGNATURES Report Author: _________________________________ Section Supervisor: Frank, Nathan Date: 2023.04.27 13:18:34 -05'00' Digitally signed by Frank, Nathan __________________________________ Page 5 of 6 Facility Name: Metalworking Lubricants Company Facility Location: 1509 South Senate Avenue, Indianapolis, Indiana Date of Inspection: March 3, 2023 APPENDICES AND ATTACHMENTS 1. Digital Media Appendix Page 6 of 6 Facility Name: Metalworking Lubricants Company Facility Location: 1509 South Senate Avenue, Indianapolis, Indiana Date of Inspection: March 3, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Linda H. Rosen 2. Archival Record Location: Region 5 Electronic Records Center Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 File Name IMG_0324.JPG IMG_0325.JPG IMG_0326.JPG IMG_0327.JPG IMG_0328.JPG IMG_0329.JPG IMG_0330.JPG IMG_0331.JPG IMG_0332.JPG IMG_0333.JPG IMG_0334.JPG IMG_0335.JPG IMG_0336.JPG IMG_0337.JPG IMG_0338.JPG IMG_0339.JPG IMG_0340.JPG IMG_0341.JPG IMG_0342.JPG IMG_0343.JPG IMG_0344.JPG IMG_0345.JPG IMG_0346.JPG IMG_0347.JPG IMG_0348.JPG IMG_0349.JPG IMG_0350.JPG IMG_0351.JPG IMG_0352.JPG IMG_0353.JPG IMG_0354.JPG IMG_0355.JPG IMG_0356.JPG IMG_0357.JPG IMG_0358.JPG IMG_0359.JPG Date and Time 2023:03:03 10:29:55 2023:03:03 10:29:56 2023:03:03 10:30:17 2023:03:03 10:30:17 2023:03:03 10:33:21 2023:03:03 10:33:21 2023:03:03 10:33:27 2023:03:03 10:33:27 2023:03:03 10:34:19 2023:03:03 10:34:19 2023:03:03 10:36:23 2023:03:03 10:38:16 2023:03:03 10:38:20 2023:03:03 10:53:52 2023:03:03 10:54:48 2023:03:03 10:54:53 2023:03:03 11:03:54 2023:03:03 11:03:54 2023:03:03 11:07:44 2023:03:03 11:07:44 2023:03:03 11:08:09 2023:03:03 11:08:10 2023:03:03 11:09:49 2023:03:03 11:09:50 2023:03:03 11:12:41 2023:03:03 11:12:42 2023:03:03 11:13:37 2023:03:03 11:13:38 2023:03:03 11:14:17 2023:03:03 11:14:17 2023:03:03 11:17:36 2023:03:03 11:17:36 2023:03:03 11:17:54 2023:03:03 11:17:54 2023:03:03 11:25:15 2023:03:03 11:25:16 Description Loadout; oil slick on ground Loadout; oil slick on ground Loadout; oil slick on ground Loadout; oil slick on ground Loadout; oil slick on ground Loadout; oil slick on ground Loadout; oil slick on ground Loadout; oil slick on ground Tank wagon Tank wagon M Tank Pump for M tank Tank overflow pipe Tank overflow pipe Tank overflow pipe Tank overflow pipe Tanker wagon at truck flush Tanker wagon at truck flush Water and oil on ground Water and oil on ground Water and oil on ground Water and oil on ground Processing tanks Processing tanks Out of service trailer Out of service trailer Used drums Used drums Used oil drums Used oil drums Tanker not being used Tanker not being used P tanks P tanks Carbon box Carbon box Page 1 of 2 Facility Name: Metalworking Lubricants Company Facility Location: 1509 South Senate Avenue, Indianapolis, Indiana Date of Inspection: March 3, 2023 37 IMG_0360.JPG 2023:03:03 11:25:21 Scrubber 38 IMG_0361.JPG 2023:03:03 11:25:21 Scrubber 39 IMG_0362.JPG 2023:03:03 11:25:57 Scrubber/carbon box stack 40 IMG_0363.JPG 2023:03:03 11:25:57 Scrubber/carbon box stack 41 IMG_0364.JPG 2023:03:03 11:26:01 Scrubber 42 IMG_0365.JPG 2023:03:03 11:26:01 Scrubber 43 IMG_0366.JPG 2023:03:03 11:28:05 DAF in WWTP 44 IMG_0367.JPG 2023:03:03 11:28:14 Clarifier in WWTP 45 IMG_0368.JPG 2023:03:03 11:28:47 Oil, water and sludge 46 IMG_0369.JPG 2023:03:03 11:28:52 Oil, water and sludge 47 IMG_0370.JPG 2023:03:03 11:28:56 Oil, water and sludge 48 IMG_0371.JPG 2023:03:03 11:29:45 Oil, water and sludge 49 IMG_0372.JPG 2023:03:03 11:29:58 Oil, water and sludge 50 IMG_0373.JPG 2023:03:03 11:30:42 Re-circulating water DAF 51 IMG_0374.JPG 2023:03:03 11:31:41 Big pit 52 IMG_0375.JPG 2023:03:03 11:32:10 Oil, water and sludge 53 IMG_0376.JPG 2023:03:03 11:34:16 Caustic chemical tank 54 IMG_0377.JPG 2023:03:03 11:37:12 FET 55 IMG_0378.JPG 2023:03:03 11:37:35 SHT2 56 IMG_0379.JPG 2023:03:03 11:37:36 SHT2 57 IMG_0380.JPG 2023:03:03 11:37:39 SHT2 Page 2 of 2