Document gaz1RDBXygaXa8EmV9DQ3bovQ

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Tremco CPG Inc., Cleveland, Ohio FROM: Natalia Vazquez, Environmental Engineer AECAB (MI/WI) THRU: Sarah Marshall, Section Supervisor AECAB (MI/WI) TO: File BASIC INFORMATION Facility Name: Tremco CPG Inc. Facility Location: 4475 East 175Th Street, Cleveland, Ohio Date of Inspection: April 22, 2024 EPA Inspector(s): 1. Natalia Vazquez, Environmental Engineer 2. Carlo Demma, Physical Scientist (Env.) Other Attendees: 1. Nick Shun Environment, Health and Safety, Tremco 2. Igor Mijic, Plant Manager, Tremco 3. Philip Kalal Director of Manufacturing, Tremco 4. Michael Adamczyk, Engineering and Facilities Manager, Tremco Contact Email Address: nshun@tremcoinc.com Purpose of Inspection: Hazardous air pollutant inspection Facility Type: Rubberized sealant manufacturing Facility Name: Tremco CPG Inc. Facility Location: Cleveland, Ohio Date of Inspection: April 22, 2024 Regulations Central to Inspection: State permit requirements and may be subject to 40 C.F.R. Part 63 Subpart CCCCCCC Arrival Time: 1:00 p.m. Departure Time: 5:00 p.m. Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Provided CBI warning to facility The following information was obtained verbally from Nick Shun, Igor Mijic, Philip Kalal, and Mike Adamczyk unless otherwise noted. Process Description: Tremco CPG Inc. (Tremco or Facility) is a sealant manufacturer for the construction and restoration industry. All raw material is received by trucks. The bulk material storage area has nine storage tanks. Powder additives are stored in 50 pounds bags. The Facility has 15 mixers, referred to as kettles, used during the manufacturing of the solvent-based sealants. The odd numbered kettles manufacture longer chained polymers using urethane, while the even numbered kettles add additional additives to the long-chained polymer. Liquid and powder additive materials are added to the kettles to lower viscosity and for some products to provide ultraviolet light stability. The end products are packaged on five gallon buckets, cartridges, or sausage-shaped packages. Staff Interview: The Facility has replaced some of its old packaging lines for automated lines, replaced some bulk storage tanks, and it has purchased a calk tube machinery within the past five years. There has been some increase in production, but it wasn't the basis for its capital investments. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: EPA examined the main baghouse. The baghouse had a large crack in the clean air side of that controls Unit K-10 Rotating Dryer emissions. The pressure gauge reading indicated 3.5 inches of water column. Facility Name: Tremco CPG Inc. Facility Location: Cleveland, Ohio Date of Inspection: April 22, 2024 EPA inspected all the tanks containing raw materials used in the rubber sealant process. Importantly, EPA noted the indicator screen on storage tank no. 150 wasn't functioning, and that the emergency vents of storage tanks no. 152, 153, and 156 had an emission leak and the top of the tank was stained with material spillage. Tank Pressure (PSI) 150 0.052 151 0.017 152 0.050 153 0.157 154 0.362 155 3.8 156 0.004 124 0.065 123 0.04 Table 1: Tanks inspection notes from C. Demma % Full Gallons Notes (if applicable) stored (Lbs) Broken N/A Continuous level monitor readout broken. 38% N/A N/A 51,696 Gasket on emergency vent visibly leaking fumes. FLIR N/A 66,240 Gasket on emergency vent visibly leaking fumes. FLIR 39.33 N/A 16.739 N/A - N/A % full gauge not accessible. Has 2 emergency vents, FLIR. Gasket on emergency vent visibly leaking fumes. 78.9% N/A Has 2 emergency vents, FLIR 32% N/A Has 2 emergency vents, FLIR Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Photographs were taken with a Canon 360HS digital camera. Videos were taken with the FLIR GF 320 IR camera. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Facility map CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Safety data sheets of materials that contain xylene, cadmium, chromium, lead, nickel and/or benzene; Last performance test (i.e., emission test, stack test) completed on the baghouse; Facility Name: Tremco CPG Inc. Facility Location: Cleveland, Ohio Date of Inspection: April 22, 2024 12-month rolling averages of hazardous air pollutants (total and each individual HAP) for the past 3 years on an excel spreadsheet; Equations and assumptions used in the HAP calculations; Daily monitoring data of the dust collector for the past year; and 3 years of the annual deviation report and the last quarterly deviation report. Concerns: The crack on the baghouse clean air side. The tank level sensor's screen appeared to be burned out, on storage tank 150. The emergency vent of three storage tanks were venting gas. DIGITAL SIGNATURES NATALIA Digitally signed by NATALIA VAZQUEZ RIVERA VAZQUEZ RIVERA Date: 2024.05.20 14:09:31 Report Author: _________________-_05_'0_0'_____________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL _M_A__R_S_H__A_L_L________D_at_e:_20_2_4.0_5_.2_2 0_9_:4_2:2_8_-0_5'_00_' APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Facility Name: Tremco CPG Inc. Facility Location: Cleveland, Ohio Date of Inspection: April 22, 2024 Inspector Name: Carlo Demma, Natalia Vazquez Archival Record Location: Photographs, videos Image Number 1 2 3 4 5 6 7 8 9 10 11 File Name IMG_0568.JPG IMG_0569.JPG IMG_0570.JPG MOV_0005.mp4 MOV_0006.mp4 MOV_0007.mp4 MOV_0008.mp4 MOV_0009.mp4 MOV_0010.mp4 MOV_0011.mp4 MOV_0012.mp4 Date and Time (incl. Time zone and DST) 4/22/2024 1:56:00 PM Description of Image Dust collector with hole on the exhaust pipe 4/22/2024 1:57:00 PM EST Dust collector with hole on the exhaust pipe 4/22/2024 2:15:00 PM EST Emergency vent of tank 152 4/22/2024 3:22:00 PM EST Emergency vent venting on storage tank number 153 4/22/2024 3:23:00 PM EST Emergency vent venting on storage tank number 153 4/22/2024 3:23:00 PM EST 4/22/2024 3:24:00 PM EST 4/22/2024 3:24:00 PM EST 4/22/2024 3:31:00 PM EST 4/22/2024 3:33:00 PM EST 4/22/2024 3:47:00 PM EST Emergency vent venting on storage tank number 153 Emergency vent venting on storage tank number 153 Emergency vent venting on storage tank number 153 Emergency vent venting on storage tank number 152 Emergency vent venting on storage tank number 152 Emergency vent venting on storage tank number 156