Document gaMEdErXQbr6OQbjEoj6ZZV3G

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Vibrantz Technologies, Ashtabula, Ohio Meaghan Pashen, Environmental Engineer AECAB (MN/OH) Brian Dickens, Section Supervisor AECAB (MN/OH) File BASIC INFORMATION Facility Name: Vibrantz Technologies Facility Location: 2600 Michigan Avenue, Ashtabula, OH 44004 Date of Inspection: March 23, 2023 EPA Inspector(s): 1. Meaghan Pashen, Environmental Engineer 2. Valeria Apolinario, Environmental Engineer 3. Laura Neudorf, Environmental Engineer Other Attendees: 1. Anthony Noxon, EHS Lead 2. Todd Pew, EHS Manager Contact Email Address: Todd Pew: todd.pew@vibrantz.com; Anthony Noxon: anthony.noxon@vibrantz.com Purpose of Inspection: To investigate facility compliance with synthetic minor source permit conditions, including volatile organic compound (VOC) and hazardous air pollutant (HAP) emission limits. Facility Type: Paint and coating manufacturing Facility Name: Vibrantz Technologies Facility Location: 2600 Michigan Avenue, Ashtabula, OH Date of Inspection: March 22, 2023 Regulations Central to Inspection: The Federally Enforceable Permit-To-Install and Operate (FEPTIO) conditions, including but not limited to the obligation to emit less than 99.9 tons/year of VOCs, and less than 24.9 tons/year of HAPs. The facility's FEPTIO states "the acceptable range established for the pressure drop across the dust collector (DC007) is between 0.5 to 6 inches of water". The facility's FEPTIO P0123420 states "the acceptable range established for the pressure drop across the dust collector (DC004) is between 2 to 8 inches of water". In both FEPTIOs, it states, "the permittee shall record the pressure drop across the dust collector (DC007/DC004) on a daily basis" and "the emissions shall be vented to a dust collector (DC007/D004) at all times the emissions unit is in operation" for all associated emissions units. Emissions unit MX007 (Mixer #7) is controlled by dust collector DC004 and MX011 (Mixer #11) is controlled by duct collector DC007. Both FEPTIOs state the following operational requirement: "use of mixing tank covers with proper ductwork, sufficient to draw a vacuum, pulling PE to the dust collector". Arrival Time: 1:15 PM Departure Time: 4:15 PM 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: Provided with Inspection Report Provided CBI warning to facility The following information was obtained verbally from Anthony Noxon or Todd Pew unless otherwise noted. Company Ownership: In 2021, Chromaflo Technologies Corporation (former facility name) merged with two other companies to form Vibrantz Technologies. This facility is specifically a Vibrantz Technologies - Color Solutions facility. Process Description: Vibrantz Technologies (Vibrantz or facility) manufactures dry pigments and liquid dispersions. Raw materials include resins, additives, and pigments. Raw materials are mixed in pots, which are partially covered with lids. There are about 25 to 30 mixers. There are mixers that contain Page 2 of 7 Facility Name: Vibrantz Technologies Facility Location: 2600 Michigan Avenue, Ashtabula, OH Date of Inspection: March 22, 2023 just liquid materials, and just dry powder. Dry materials are dumped into respective pots, and liquid materials are piped into respective pots. There is a white mixing area, a mixing area, and a solvent area. Emissions from the white mixing and the mixing area are routed to dust collectors (DC004 and DC007, respectively). Emissions from the solvent area go to the facility exhaust system. Pots are cleaned in between batches in a water-based pot wash system. After mixing, materials are sent to milling. There is a non-hazardous milling area, and a hazardous milling area. Submersible basket mills break down particle size. The solvated cellulose acetate butyrate (CAB) production line utilizes hardened chips as raw material, which are then mixed with solvents. The CAB line consists of a solvating mix tank, a holding tank, a vertical sand mill, and a thinning tank. Emissions from the CAB line area are routed to a dust collector (DC007). Staff Interview: In 2022, facility throughput was about 14 million pounds. Emissions calculations are based on material usage and emission factors based on VOC emissions rate per hour. Material usage is automated and tracked at each process step utilizing weight measurement and material specifications. Facility emission calculations for VOCs assume complete volatilization of components and there is no control or capture. EPA requested facility emission calculations, material safety data sheets, and material usage. There is an indoor storage tank farm on-site containing 13 fixed roof tanks with material used in facility operations. Four of the tanks contain solvent, and nine of the tanks contain resin. One 12,000-gallon tank contains styrene, and the remaining 12 are 8,800-gallon tanks. Dust collectors are only operated during the addition of dry material. The dust collectors have magnehelic gauges, and differential pressure is recorded daily. Operating parameter limits are based on manufacturer's recommendations. Deviations are reported to Ohio EPA; however, no deviations were reported to Ohio EPA in the last five years. Dust collectors are inspected quarterly for preventative maintenance. EPA requested daily maintenance and differential pressure logs from each dust collector, including documentation of any time periods when the baghouse was not in service when the respective emissions unit was in operation. EPA requested the most recent performance test for each dust collector including the manufacturer's recommendations that established the respective differential pressure range. There is no Leak Detection and Repair (LDAR) program at the facility. A combustible gas reader is used, as well as low level vapor monitors. The low-level vapor monitors are calibrated quarterly. Facility staff did not recall any recent odor complaints from the community. The facility is undergoing a construction project to add two mixers, a mill, and a holding tank. These units are not yet in operation, and no permit has been applied for considering these units. Page 3 of 7 TOUR INFORMATION Facility Name: Vibrantz Technologies Facility Location: 2600 Michigan Avenue, Ashtabula, OH Date of Inspection: March 22, 2023 EPA Tour of the Facility: Yes Data Collected and Observations: The CAB production line was not in operation during the inspection. EPA visualized emissions from mixing and milling operations at Mixer #7, Mixer #11, Mixer #22, Mill #24, and Mill #6. These operations are partially covered. See Digital Image Log. EPA observed the tank farm. There was a dent in the roof of the styrene tank. See Digital Image Log. No emissions were visualized from the styrene tank with the FLIR camera. EPA observed tank farm pressure relief valves and facility exhaust systems on the roof. No emissions were visualized with the FLIR camera. DC004 was not in operation during the inspection. DC007 was not in operation during the inspection. Photos and/or Videos: were taken during the inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Emission calculations, including all calculation methodology, emission factors, and assumptions for the past 3 years; Safety data sheets for each raw material brought on-site, including pigments, resins, and solvents, in the last year that contains VOC or HAP material, including metal HAP (cadmium, chromium, lead, and nickel); Daily maintenance and differential pressure logs from each dust collector, including documentation of any time periods when the baghouse was not in service when the respective emissions unit was in operation, for the past year; Most recent performance test for each dust collector, if applicable, including the manufacturer's recommendations that established the pressure drop range; Provide any communication with Ohio EPA that established the dust collectors may be turned off after the addition of dry powders; Solvent usage for the past year, seperated by solvent type; Resin usage for the past year, seperated by resin type. Compliance Assistance: EPA expressed that the facility's permits state that emissions are to be vented to emission control equipment when associated emission units are in operation. Page 4 of 7 Facility Name: Vibrantz Technologies Facility Location: 2600 Michigan Avenue, Ashtabula, OH Date of Inspection: March 22, 2023 Concerns: EPA expressed concerns related to emissions visualized on the FLIR camera from mixing and milling operations due to partial coverings. EPA expressed concerns related to DC004 and DC007 not being in operation during associated emission unit operation. DIGITAL SIGNATURES Pashen, Digitally signed by Pashen, Meaghan Report Author: _M_e_a__g_h_a_n_____1_6:_50_:3_4 _-05_'0_0'_____________ Date: 2023.05.16 Section Supervisor: Brian Digitally signed by Brian Dickens Date: 2023.05.17 _D_i_c_k_e_n_s______0_6:_35_:0_6 _-0_5'0_0'______________ Page 5 of 7 Facility Name: Vibrantz Technologies Facility Location: 2600 Michigan Avenue, Ashtabula, OH Date of Inspection: March 22, 2023 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log Page 6 of 7 Facility Name: Vibrantz Technologies Facility Location: 2600 Michigan Avenue, Ashtabula, OH Date of Inspection: March 22, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Laura Neudorf 2. Archival Record Location: Region 5 Electronic Records Center Image Number 1 File Name IMG_0343.JPG Date and Time (incl. Time zone and DST) * Description of Image Pots before milling IMG_0344.JPG * 2 Fixed roof of tank with vapor space pipe IMG_0345.JPG * 3 Dent in roof of styrene tank IMG_0346.JPG * 4 Dent in roof of styrene tank 5 IMG_0347.JPG * 6 IMG_0348.JPG * 7 MVI_0349.MP4 * 8 IMG_0350.JPG * 9 IMG_0351.JPG * 10 IMG_0352.JPG * 11 IMG_0353.JPG * 12 IMG_0354.JPG * 13 IMG_0355.JPG * 14 IMG_0356.JPG * 15 IMG_0357.JPG * 16 MOV_3066.mp4 * 17 MOV_3067.mp4 * 18 MOV_3068.mp4 * 19 MOV_3069.mp4 * 20 MOV_3070.mp4 * *Date and Time metadata did not preserve from digital camera. DC004 differential pressure gauge White mix room Digital video of Mixer #11 Mixer #11 and DC007 DC007 differential pressure gauge Batch routing/specification label Low explosive limit (LEL) monitor gauge in hazardous mixing area LEL monitor gauge in hazardous mixing area Batch distillation and distillation product tank Facility map with emission units Facility map with emission units FLIR video at white room Mixer #7 FLIR video at Mixer #11 FLIR video at Mill #24 FLIR video at Mill #6 FLIR video at Mixer #22 Page 7 of 7