Document jm4XRkNn9RQJzkvw96ZQmMo8O

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION5 77 WEST JACKSON BOULEVARD CIDCAGO, ILLINOIS 60604 APR O5 2019 CLEAN AIR ACT INSPECTION REPORT WRE/Colortech, Wadsworth, Ohio David Sutlin, Environmental Engineer AECAB (J\AN/OH) Brian Dickens, Section Chief AECAB (J\AN/OH) File BASIC INFORMATION Facility Name: WRE/Colortech Facility Location: 668 Seville Road, Wadsworth, Ohio Date of Inspection: February 5th, 2019 EPA Inspector(s): 1. David Sutlin, Environmental Engineer Other Attendees 1. Dean Ellebruch, Vice President Midwest Operations 2. Pete Bach, Production Manager 3. Tom Codd, Environmental and Maintenance Supervisor Contact Email Address: dellerbruch@wrecolor.com Purpose of Inspection: To determine compliance with the Clean Air Act. Facility Type: Hard chrome plating facility Regulations Central to Inspection: 40 CFR Part 63, Subpart N - National Emission Standards for Hazardous Air Pollutants: Standards for Chromium Electroplating Arrival Time: 8:45 AM Departure Time: 10:30 AM Inspection Type: ~ Unannounced Inspection LJ Announced Inspection OPENING CONFERENCE ~ Credentials Presented ~ CBI warning to facility provided The following information was obtained verbally from Mr. Bach, Mr. Ellebruch, and Mr. Codd unless otherwise noted. Process Description: The facility receives steel cylindrical bases from their customers. New bases are nickel-plated. All bases are then copper-plated, turned, and polished. Next, the printing images are electromechanically engraved into the bases. Finally, hard chrome plating is applied to the cylinders, by rotating them through a 400 gallon bath containing chromic acid and a small amount of sulfuric acid for 45 minutes. The facility operates two such baths, which are controlled by the "P-001 Scrubber." This control device consists of a composite-bed mist eliminator followed by a HEPA filter system. The engraved cylinders are then shipped to packaging printers. Staff Interview: The scrubber was last tested in 1999. Pressure drop across the scrubber is monitored and recorded daily. The facility tracks annual ampere hours and operating hours for each bath. TOUR INFORMATION EPA toured the facility: Yes Photos and/or Videos: were taken during the inspection. CLOSING CONFERENCE Requested documents: Manufacturer's operations and maintenance documents for scrubber Scrubber monitoring records 2nd half 2018 semiannual report Scrubber stack test report Compliance Assistance: I noted that the pressure monitoring daily record sheets listed only the low pressure drop limit, not the high limit. Mr. Codd pointed me to an older version of these sheets which contained both limits and told me that this would be corrected. Page 2 of 4 Page 3 of 4 Facility Name: WRE/Colortech Facility Location: 668 Seville Road, Wadsworth, Ohio Date of Inspection: February 5th, 2019 APPENDICES AND ATTACHMENTS Appenrfrx A: Digital lmage Leg Page 4 of 4 Facility Name: WRE/Colortech Facility Location: 668 Seville Road, Wadsworth, Ohio Date of Inspection: February 5th, 2019 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: David Sutlin 3. Company/Facility Name: WRE/Colortech .. 5. Number of Images: 2 2. Date(s) of Inspection: February 5th, 2019 4. Street Address, City, State: 668 Seville Road, Wadsworth, Ohio 6. Archival Record Location: Images are saved to a CD-R labeled "WRE/Colortech, Wadsworth, OH; 2-5-19 Inspection; Images" Image Number 1 2 File Name P2050009.JPG P2050010.JPG Date and Time (incl. time zone and DST) 2/5/2019 8:50 2/5/2019 8:50 Description of Image Chrome plating baths Control device for chrome plating baths Appendices Page 1 of 1