Document emgXDO5Nq6OOE551rqbj96qQe

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Aludyne, Benton Harbor, Michigan Natalie Schulz, Environmental Engineer AECAB (MN/OH) Brian Dickens, Section Supervisor AECAB (MN/OH) File BASIC INFORMATION Facility Name: Aludyne Facility Location: 1320 Paw Paw Avenue, Benton Harbor, Michigan 49022 Date of Inspection: March 28, 2023 EPA Inspector(s): 1. Natalie Schulz, Environmental Engineer 2. Meaghan Pashen, Environmental Engineer Other Attendees: 1. Art Caldwell, Aludyne, Environmental Health and Safety Manager 2. Jason Howland, Aludyne, Operations Manager - Stevensville Location Contact Email Address: art.caldwell@aludyne.com Purpose of Inspection: Hazardous air pollutant emissions from secondary aluminum production Facility Type: Secondary aluminum production Regulations Central to Inspection: Permit-to-Install Arrival Time: 10:35 a.m. Departure Time: 12:00 p.m. Facility Name: Aludyne Facility Location: 1320 Paw Paw Avenue, Benton Harbor, Michigan Date of Inspection: March 28, 2023 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 Provided CBI warning to facility The following information was obtained verbally from Art Caldwell unless otherwise noted. Company Ownership: Company ownership has not changed in the past five years; however, the name has been changed from Alutech, LLC. Process Description: Aludyne is a secondary aluminum production facility that makes parts for the automotive industry. The facility does not pre-treat the scrap metal before melting and only melts aluminum that is already processed, in the form of crushed wheels, sows, and remelt secondary ingot. National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production (NESHAP RRR) excludes from applicability secondary aluminum production facilities that only melt clean charge, customer returns, or internal scrap, as defined in NESHAP RRR. The scrap is placed into one of the facility's three reverberatory furnaces, listed in the permit as EUREVERB2, EUREVERB3, and EUREVERB5. The hoods above the reverberatory furnaces exhaust directly to the atmosphere. The melted aluminum is then pumped to the crucible furnaces. Fluxing material is manually added to the crucible furnaces. The amount of magnesium, strontium, or iron added is based on in-house sampling of the aluminum composition. Nitrogen is added with the flux to bring up impurities. The impurities are then skimmed off as slag and taken to a third party. The aluminum is then cast. There are some holding stations between the processes to keep the melted aluminum warm; the material is kept at temperature of approximately 1300 to 1400F. The parts are placed in a quench tank after casting; the castings are then sawed and trimmed. The facility's two enclosed heat treatment ovens operate asynchronously. Every part undergoes heat treatment for approximately eight hours. The finished parts undergo liquid penetrant inspection (LPI) to test for cracks and defects; the liquid is washed off prior to the part being sent out for delivery. There is no coating of the parts completed at the facility. Page 2 of 6 Facility Name: Aludyne Facility Location: 1320 Paw Paw Avenue, Benton Harbor, Michigan Date of Inspection: March 28, 2023 Staff Interview: Fluoride or chlorine is not used in fluxing or other portions of the process. There are approximately three dust collectors at the facility; the dust collectors are not included in the facility's permit-to-install No. 170-19. The permit requires no visible emissions from openings and vents of the building housing the reverberatory furnace #5. No visible emissions were observed. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: Inspectors observed the scrap metal prior to being placed into the furnace; the scrap appeared to be clean charge. Inspectors observed fluxing material being ladled into the crucible furnace. Inspectors observed finished parts undergoing LPI. Safety data sheets for LPI requested for review. The amount of scrap charged to each furnace is limited in the permit by the reverberatory furnaces' melt rates; each reverberatory furnace is limited to 86 pounds per day of fluxing material. The crucible furnaces are limited by the permit to use no more than 15 pounds per hour of flux. The permit requires that the facility record the weight of all charge materials and fluxing materials added to the furnaces on a daily basis; three months of these logs are requested for later review. The permit requires that the facility maintain a listing of the chemical composition of each flux material used; the SDS sheets are requested for later review. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Three months of charge logs Facility air permits SDS sheets for LPI, additives, and fluxes Facility flow diagram Maintenance schedule for dust collectors Page 3 of 6 DIGITAL SIGNATURES Facility Name: Aludyne Facility Location: 1320 Paw Paw Avenue, Benton Harbor, Michigan Date of Inspection: March 28, 2023 NATALIE Digitally signed by NATALIE SCHULZ SCHULZ Date: 2023.05.25 10:01:59 -05'00' Report Author: _________________________________ Section Supervisor: Brian Digitally signed by Brian Dickens __D_i_c_k_e_n_s______1_4:_41_:3_9 _-05_'0_0'_____________ Date: 2023.05.25 Page 4 of 6 Facility Name: Aludyne Facility Location: 1320 Paw Paw Avenue, Benton Harbor, Michigan Date of Inspection: March 28, 2023 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log Page 5 of 6 Facility Name: Aludyne Facility Location: 1320 Paw Paw Avenue, Benton Harbor, Michigan Date of Inspection: March 28, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Natalie Schulz 2. Archival Record Location: Electronic Records System Image Number 1 File Name IMG_0469.JPG Date and Time (incl. Time zone and DST) March 28, 2023, 10:50 a.m. CST Description of Image Reverbatory furnace B IMG_0470.JPG March 28, 2023, 10:51 Reverbatory furnace B 2 a.m. CST Page 6 of 6