Document e5mJQ3ZxoQraKMak8ZG3j5QKy

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEYARD CIDCAGO, ILLINOIS 60604 DATE: APR O5 2019 SUBJECT: CLEAN AIR ACT INSPECTION REPORT ASW.Pengg, LLC, Bedford Heights, Ohio FROM: David Sutlin, Environmental Engineer AECAB (MN/OH) THRU: Brian Dickens, Section Chief AECAB (MN/OH) TO: File BASIC INFORMATION Facility Name: ASW.Pengg, LLC Facility Location: 26300 Miles Road, Bedford Heights, Ohio Date of Inspection: February 5, 2019 EPA lnspector(s): 1. David Sutlin, Environmental Engineer 2. Gina Harrison, Environmental Scientist Other Attendees 1. Charles White, R.G., EH&S Manager, ASW 2. Mike Howard, Operations Manager, ASW 3. JeffBokshom, Maintenance, ASW Contact Email Address: cwhite@aswpengg.com Purpose of Inspection: To determine compliance with ASW's operating permit and applicable federal regulations Facility Type: Steel wire drawing Regulations Central to Inspection: Ohio SIP Arrival Time: 11 :30 AM Departure Time: 2:00 PM Inspection Type: ISi Unannounced Inspection Announced Inspection OPENING CONFERENCE ISi Credentials Presented ISi CBI warning to facility provided The following information was obtained verbally from Mr. White, Mr. Howard, or Mr. Bokshom unless otherwise noted. Company Ownership: Pengg Austria GmbH purchased half of ASW in October 2016. Subsequently, the current owner is ASW.Pengg, LLC. Process Description: Raw materials consist of 5000 lb steel wire coils. The wire goes through a patenting process, in which it is continuously fed through a lead bath at 1600F. It continues out of the bath and is slowly air-cooled to 800F, which softens the wire before it is drawn through dies to elongate it. The wire next goes through a tempering process in which it is heated to 1600F and then quenched in mineral oil to rapidly cool it to below 200F. It then passes through another lead bath, which heats the wire to 800F for 4 to 24 hours, depending on the wire's diameter, and produces a martensite grain structure in the steel. The wire is then shipped to other facilities, which produce the final spring products. In both patenting and tempering processes, the lead bath consists of a 50,000 lb capacity elongated pot, which is heated either by natural gas burners or electric induction. Lead is added to the pot in the form of 751b pigs. Just as the lead starts to melt, a 4" layer of pea coke is added to cover the lead and suppress particulate emissions. Staff Interview: The pea coke layer's thickness is inspected daily by visually gauging the height of the exposed sidewall of the pot. The consistency of the pea coke is monitored weekly, and it is replaced approximately once per month. The spent pea coke is raked into a hopper and passed through a mesh where some of the lead falls through and can be reclaimed. The spent pea coke containing some oxidized lead is sent to one of two offsite third-party hazardous waste facilities. The exhaust hoods on the tempering lines are centered over the mineral oil quenching process, which tends to produce the most emissions. The facility conducts quarterly lead monitoring of the indoor air. The last performance test was in 2015 for the Tl and T2 tempering furnaces. Tl Page 2 of 4 has since been shut down and removed. The facility is currently constructing a new patenting line and new tempering line to process fine wire. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Obsen,ations: At tempering line T3, fumes from the quenching process were observed escaping the exhaust hood. Mr. White stated that the emissions were from nitrogen introduced into the kettle to prevent oxygen from contacting the wire. Photos and/or Videos: were taken during the inspection. CLOSING CONFERENCE Requested documents: Active air permits 2015 performance test report Annual emission calculations Indoor lead air monitoring results List oflead waste handlers used by the facility SIGNATURES Page 3 of 4 Facility Name: ASW.Pengg, LLC Facility Location: 26300 Miles Road, Bedford Heights, Ohio Date of Inspection: February 5, 2019 APPENDICES AND ATTACHMENTS Appendix A: Digital Image Log Page 4 of 4 Facility Name: ASW.Pengg, LLC Facility Location: 26300 Miles Road, Bedford Heights, Ohio Date of Inspection: February 5, 2019 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: David Sutlin 3. Company/Facility Name: ASW.Pemrn, LLC 5. Number of Images: 4 2. Date(s) of Inspection: Februarv 5, 2019 4. Street Address, City, State: 26300 Miles Road, Bedford Heights, Ohio 6. Archival Record Location: Images are saved to a CD-R labeled "Contains CBI; ASWPENG, Bedford Heights, OH; 2/5/19 Inspection; Images" Image Number I 2 3 4 File Name P2050012.JPG P2050013.JPG P2050014.MOV P2050015.JPG Date and Time (EST) 2/5/2019 11:43 2/5/2019 II :43 2/5/2019 11:55 2/5/2019 11:58 Descriotion of Image Patent line, Pl Patent line, Pl Tempering line, T3, quenching process Cold kettle Appendices Page 1 of 1