Document k6Vpp6G2Y1M3RZb6VxdQLy00E

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Grede, LLC - Iron Mountain, Kingsford, Michigan Dakota Prentice, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Supervisor AECAB (IL/IN) File BASIC INFORMATION Facility Name: Grede, LLC - Iron Mountain (Grede, LLC) Facility Location: 801 South Carpenter Avenue, Kingsford, Michigan Date of Inspection: June 27, 2023 EPA Inspector(s): 1. Dakota Prentice, Environmental Engineer 2. Laura Neudorf, Environmental Engineer Other Attendees: 1. Lauren Luce, Environmental Quality Analyst - Michigan Department of Environment, Great Lakes, and Energy (EGLE) 2. Adam Grunenwald, EHS Manager - Grede, LLC 3. Liz Gutierrez, General Manager - Grede, LLC 4. Mark Trulock, Operations Manager - Grede, LLC 5. Tom White, EHS Lead - Grede, LLC 6. Cody Wolsker, Automation Manager - Grede, LLC Contact Email Address: Adam Grunenwald - adam.grununwald@grede.com Purpose of Inspection: to determine compliance with the Michigan state implementation plan and the Clean Air Act Facility Type: Gray Iron Foundry Facility Name: Grede, LLC - Iron Mountain Facility Location: 801 South Carpenter Avenue, Kingsford, Michigan Date of Inspection: June 27, 2023 Regulations Central to Inspection: Conditions of a Renewable Operating Permit issued by EGLE with an effective date of October 8, 2020, and the National Emission Standards for Hazardous Air Pollutants for Iron and Steel Foundries at 40 C.F.R. Part 63, Subpart EEEEE (NESHAP EEEEE) Arrival Time: 10:00AM CDT Departure Time: 11:30AM CDT 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 Grede, LLC personnel unless otherwise noted. Company Ownership: In December 2019, Gamut Capital Management acquired the facility from American Axle & Manufacturing Holdings, Inc. as a part of a larger acquisition. Process Description: Gray iron production begins at a cupola furnace. Raw material including shredded autos, coke, limestone, ferro-silica, and iron scrap generated internally are fed into the top of the furnace. The cupola generates a continuous stream of molten iron, which is sent to a holding furnace. From the holding furnace, molten iron is transferred to ladles, which are then moved to one of seven mold centers where the molten iron is poured into molds to form castings of various shapes and sizes. The molds are allowed to cool and then taken to a shaker unit to remove sand from the iron casting. The casting then moves through a series of finishing steps to remove risers, sandblast exterior surfaces, and manually remove imperfections at grinders prior to shipping the final casting product. Multiple baghouses are used throughout the facility to control particulate matter emissions generated during gray iron casting production. Module, a separate foundry operation, operates on on-site and has one mold center controlled with a baghouse. Casting molds are produced at a press using sand, clay, and water. Cores, which are placed at interior portions of the mold, are produced in one of three processes: isocure, shell core, or a 3D printer. These processes use a sand and resin mixture to create cores. The isocure process uses the resin dimethylethylamine (DMEA) and is controlled by a wet scrubber. The 3D printer uses Page 2 of 5 Facility Name: Grede, LLC - Iron Mountain Facility Location: 801 South Carpenter Avenue, Kingsford, Michigan Date of Inspection: June 27, 2023 a furan resin. Cores are baked in one of three ovens controlled by a baghouse before they are sent to the press. Staff Interview: The facility has approximately 230 employees. The foundry (sand mold and casting production) currently operates from 6:00AM - 4:30PM Monday through Thursday. The facility is currently operating at 30 to 45 percent capacity, with maximum production most recently occurring in 2017 and 2018. The facility uses a bag leak detection system (BLDS) at three baghouses; however, the BLDS data is used internally, not for environment compliance. Method 9 is performed every six months, and visual emission checks are performed daily. Facility representatives were not aware of a current or historic quality improvement plan in place. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA walked the production process from the cupola to grinding. During the tour, EPA observed uncaptured emissions while molten iron was transferred from the holding furnace to a ladle. Photos and/or Videos: were taken during the inspection. See Appendix A Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Operations and Maintenance Plan(s) Compliance Assurance Monitoring Plan Most recent performance test at each emission unit The preceding six months of visible emission readings Most recent Method 9 (opacity) readings Most recent permit issued by EGLE and the associated permit application DIGITAL SIGNATURES DAKOTA Digitally signed by DAKOTA PRENTICE Date: 2023.07.11 Report Author: ____P__R_E_N__T_I_C_E____10_:1_0:_47_-0_5_'00_' _________ Frank, Digitally signed by Frank, Nathan Section Supervisor: _N_a_t_h_a_n_______1_6_:42_:0_5_-0_5'0_0_' _____________ Date: 2023.07.11 Page 3 of 5 Facility Name: Grede, LLC - Iron Mountain Facility Location: 801 South Carpenter Avenue, Kingsford, Michigan Date of Inspection: June 27, 2023 APPENDICES AND ATTACHMENTS Appendix A: Digital Image Log Appendix B: Digital Video Log Page 4 of 5 Facility Name: Grede, LLC - Iron Mountain Facility Location: 801 South Carpenter Avenue, Kingsford, Michigan Date of Inspection: June 27, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: L. Neudorf Image Number 1 2 3 4 5 6 7 8 9 10 File Name IMG_0515.JPG IMG_0516.JPG IMG_0517.JPG IMG_0519.JPG IMG_0520.JPG IMG_0521.JPG IMG_0522.JPG IMG_0523.JPG IMG_0524.JPG IMG_0525.JPG 2. Archival Record Location: EPA Region 5 Electronic Records Center Date and Time (CDT) 2023:06:27 11:01:41 2023:06:27 11:04:28 2023:06:27 11:04:40 2023:06:27 11:05:35 2023:06:27 11:05:41 2023:06:27 11:08:30 2023:06:27 11:08:48 2023:06:27 11:16:09 2023:06:27 11:17:12 2023:06:27 11:17:25 Description of Image Cupola System Monitoring Screen Pouring into Ladle Pouring into ladle Cupola Cupola Pouring Line Pouring Line Manual Grinding Operations Scrubber System Monitoring Screen Scrubber System Monitoring Screen APPENDIX B: DIGITAL VIDEO LOG 1. Inspector Name: L. Neudorf Video Number File Name 1 MDG_0518 - Trim Grede.MOV 2. Archival Record Location: EPA Region 5 Electronic Records Center Date Description of Video 2023:06:27 Transfer of molten iron from the holding furnace to a ladle Page 5 of 5