Document kmj0BEokb1jYn15XZ200DzqQB

SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Smith Foundry, Minneapolis, Minnesota Jacob Herbers, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Smith Foundry Facility Location: 1855 E 28th St, Minneapolis, MN 55407 Dates of Inspection: December 12-13, 2023 EPA Inspector(s): 1. Jacob Herbers, Environmental Engineer 2. Sasha Letuchy, Environmental Engineer Other Attendees: 1. Curt Stock, Minnesota Pollution Control Agency 2. Adolfo Quiroga, President, Smith Foundry 3. Brian David, Maintenance Manager, Smith Foundry 4. Larry Kramer, General Manager, Smith Foundry 5. Paul Tuzi, CEO, Zynik Capital 6. Ben Gliksman, Senior VP and General Counsel, Zynik Capital 7. E.J. Juers, Operations Manager, Alliance Technical Group Contact Email Address: David_Brian@smithfoundry.com Purpose of Inspection: Observe stack testing and investigate compliance with the Clean Air Act and the Minnesota State Implementation Plan. Facility Name: Smith Foundry Facility Location: 1855 E 28th St, Minneapolis, MN 55407 Inspection Dates: December 12-13, 2023 Facility Type: Iron Foundry Regulations Central to Inspection: National Emission Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries Area Sources (40 C.F.R. Part 63, Subpart ZZZZZ), NESHAP General Provisions (40 C.F.R. Part 63, Subpart A), and Minnesota Rules, 7011.0150 - Preventing Particulate Matter from Becoming Airborne. Arrival Times: 08:00 CST Departure Times: 15:30 CST Inspection Type: Unannounced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Did not provided Small Business Resource Information Sheet. Reason: already provided. Provided CBI warning to facility The following information was obtained verbally from Brian David, Adolfo Quiroga, Larry Kramer, and E.J. Juers unless otherwise noted. Company Ownership: Smith Foundry Co. was purchased by Zynik Capital in December 2022. Process Description: The facility produces grey and ductile iron castings. Silica sand is mixed with bentonite and water to form a binding material in the sand muller. A separate facing sand muller prepares sand for use on the cope and drag molding line. The sand gets sent to any of four mold-making stations. In the shell core area, sand is injected in a pattern into a magazine box, then down the line, phenol powder is added to produce cores. Raw "pig iron" is melted in a furnace which has capacity for eight tons of iron. The furnace cycle is usually 24 minutes. The furnace is equipped with a lid. Approximately one quarter of the furnace capacity is tapped into a transfer ladle. After tapping in complete, a lid is placed on top of the transfer ladle. Additives, including flux, silicon carbide, pet coke, and magnesium (for ductile iron only), are added at the furnace, at the transfer ladle (for ductile iron only), or in a tundish ladle. Slag is removed from the process both at the furnace and in the ladles. Molten metal is poured into pouring ladles near the pouring and cooling line. 2 Facility Name: Smith Foundry Facility Location: 1855 E 28th St, Minneapolis, MN 55407 Inspection Dates: December 12-13, 2023 Liquid metal is then poured into the molds and onto cores to form products. After cooling, the metal castings are dumped into the shakeout system, where vibrating ducts and a rotating barrel knock sand off of castings and polish them. A cut-off saw is used to remove any gates that remained attached to the castings during shakeout. Castings are then shot blasted once or twice using chilled iron shot. Imperfections caused by molding are cut off in the grinding area and reused in the furnace. Five baghouses control emissions from the facility, as follows: Baghouse Baghouse Emission Unit(s) Controlled Name Location CE01 Roof Facing Muller and Shakeout CE02 Back wall Cutoff Saws CE03 Roof Shakeout CE04 Back wall Grinding and Shot Blaster CE05 Interior Sand Muller Emissions from the furnace and from the casting & pouring equipment are not controlled. The furnace area has fans in the roof that exhaust to a common duct at the roof. The casting & pouring equipment, which consists of three automatic lines and one manual cope and drag line, has various exhaust systems which exhaust at the roof. Stack testing was conducted on the inlets and outlets of all five baghouses (excluding the inlet of CE02) using EPA Methods 1, 2, 3, 3A, 4, 5, and on the outlets using EPA Method 202. EPA Method 12 was also conducted on the outlet of the five baghouses. Visible emissions observations were taken on the exhaust points of all five baghouses using EPA Method 9. Three runs of testing were conducted for each test, and the testing took three consecutive days. Staff Interview: Holes in ducts were patched in the past few months, and tarps/covers were added to parts of the facility to help reduce uncaptured emissions. Facility personnel have been monitoring and recording pressure drops at the baghouses. The facility hired a 3rd party to change all of the bags on three of their five baghouses in the prior few weeks before the stack test. The facility did not have records of when the bags were changed previously. CE04 had a pressure drop below the acceptable range for two days after the bags were changed, because they had not been "seasoned" yet. The facility hired a 3rd party to measure the concentrations of constituents of the facility's input metal. Smith Foundry also takes daily samples of the metallurgy in the facility's furnace, but stated that the equipment is not calibrated for lead. All recycled metal charged into the furnace is internal rejected parts and internal scrap. 3 Facility Name: Smith Foundry Facility Location: 1855 E 28th St, Minneapolis, MN 55407 Inspection Dates: December 12-13, 2023 TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA observed capture at the emission units routed to baghouses. During Run 1 of CE05 inlet and outlet PM testing on December 12, 2023 at the sand muller, EPA identified a tarp that had fallen off the capture hood, resulting in emissions escaping the capture system, and requested that the facility repair it. Within 10 minutes of identifying the issue, Brian David reported that the issue had been corrected. EPA did not identify any capture issues at the other controlled emissions units. Manometers had readings within their acceptable ranges (see images 3, 5, 25, and 32). EPA observed furnace operations indoors. Tapping duration was approximately three minutes and charging duration was less than one minute. Based on visual observations, tapping produced the largest plume of emissions, followed by charging, and then melting (see video 28). There was a gap between the top of the furnace and the lid which resulted in uncaptured emissions escaping the furnace during melting. Particulate matter and sparks were generated from the pouring of liquid metal at the pouring & cooling lines (see images 12 and 14 and video 13). The furnace area exhaust duct on the roof had increased visible emissions while the furnace was being tapped (see videos 46 and 54). Visible emissions were also observed from the exhaust vent above the casting & pouring area. Some of the shakeout ductwork had gaps (see images 10, 15, and 19). Some ducts on the building envelope were not sealed (see images 36, 38, 51, and 64). Windows and doors were generally closed (see images 1, 6, 24, and 60). A few exceptions were noted (see images 8, 18, 37, 38, 61, 63, and 65). The surfaces inside the facility were generally dusty as shown in many of the images and videos. 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. Reviewed documents: Facility map with manometers highlighted 4 Facility Name: Smith Foundry Facility Location: 1855 E 28th St, Minneapolis, MN 55407 Inspection Dates: December 12-13, 2023 Facility map identifying portions of the shake out that go to CE01 and CE03 Diagram of tundish ladle used for ductile iron production Example semiannual and monthly preventative maintenance work orders Heat sheet for 12/12/2023 Manometer reading logs Metal constituent sampling datasheets - company and third party Compliance Assistance: EPA noted several items such as open doors, unsealed gaps, and fallen covers that could quickly be fixed to reduce emissions. Some of these were fixed while EPA was still onsite. EPA encouraged the facility to continue taking steps to reduce emissions. Concerns: EPA expressed concerns about uncontrolled emissions escaping the facility and complaints from the surrounding Environmental Justice community. DIGITAL SIGNATURES Herbers, Digitally signed by Herbers, Jacob Jacob Date: 2024.01.09 14:02:34 -06'00' Report Author: _________________________________ SARAH Digitally signed by SARAH MARSHALL MARSHALL 14:23:54 -06'00' Date: 2024.01.09 Section Supervisor: __________________________________ 5 Facility Name: Smith Foundry Facility Location: 1855 E 28th St, Minneapolis, MN 55407 Inspection Dates: December 12-13, 2023 APPENDIX A: DIGITAL IMAGE AND VIDEO LOG 1. Inspector Name: Jacob Herbers 2. Archival Record Location: EPA Electronic Records # File Name Date & Time (CST) 1 IMG_0481.JPG 2023:12:12 09:22:43 2 IMG_0482.JPG 2023:12:12 09:22:53 3 IMG_0483.JPG 2023:12:12 09:23:56 4 IMG_0484.JPG 2023:12:12 09:25:58 5 IMG_0485.JPG 2023:12:12 09:26:27 6 IMG_0486.JPG 2023:12:12 09:31:04 7 IMG_0487.JPG 2023:12:12 09:32:05 8 IMG_0488.JPG 9 IMG_0489.JPG 10 IMG_0490.JPG 11 IMG_0491.JPG 2023:12:12 09:34:08 2023:12:12 09:37:18 2023:12:12 09:39:21 2023:12:12 09:43:13 12 IMG_0492.JPG 2023:12:12 09:44:08 13 MVI_0493.MP4 2023:12:12 09:44 14 IMG_0494.JPG 2023:12:12 09:47:08 15 IMG_0495.JPG 2023:12:12 09:47:59 16 IMG_0496.JPG 2023:12:12 09:50:45 17 IMG_0497.JPG 2023:12:12 09:51:57 18 IMG_0498.JPG 2023:12:12 09:52:42 19 IMG_0499.JPG 2023:12:12 09:53:11 20 IMG_0500.JPG 2023:12:12 09:54:21 21 IMG_0501.JPG 2023:12:12 09:55:33 22 IMG_0502.JPG 2023:12:12 09:55:59 23 MVI_0503.MP4 2023:12:12 09:56 24 IMG_0504.JPG 2023:12:12 09:58:20 25 IMG_0505.JPG 2023:12:12 09:59:23 26 IMG_0506.JPG 2023:12:12 10:01:02 27 MVI_0507.MP4 2023:12:12 10:02 28 MVI_0508.MP4 2023:12:12 10:04 29 IMG_0509.JPG 2023:12:12 10:10:50 30 MVI_0510.MP4 2023:12:12 10:29 31 MVI_0511.MP4 2023:12:12 10:33 32 IMG_0512.JPG 2023:12:12 10:37:54 33 IMG_0513.JPG 2023:12:12 10:38:26 Description "This Window is to remain closed until further notice" Claimed as Confidential Business Information Baghouse pressure drop log Facility blueprint with manometer locations highlighted Manometer #5 reading 2 in. H2O Pile of sand inside the building near the north side Tarp partially blocking PM from leaving equipment area Broken window partially covered with cardboard south side of east end of building Fixed hole on north end of shakeout duct Shakeout ducts in front of garage door with bottom gap Curving duct coming up from shakeout duct Worker pouring molten metal from transfer ladle into pouring ladle Worker pouring molten metal from transfer ladle into pouring ladle Worker pouring molten metal into molds Gap in shakeout ducts under bridge Recipes, including silicon, copper, chrome, nickel, vaxon Cover added over shakeout duct hole Garage door open on south side of building Gaps in shakeout duct panels Rotating drum at end of shakeout Inside of rotating drum at end of shakeout Furnace area with gap between chamber and lid Furnace operating with lid closed Garage door labeled "No Open Door" Manometer #4 reading 1.3 in. H2O Holes in interior wall above furnace Open furnace Furnace tapping into ladle Temporary stack on baghouse 2 Furnace slagging, additions, and tapping Furnace charging Manometer #1 reading 4.4 in. H2O Ventilation fan near CE01 with fallen cardboard partially blocking flow 6 Facility Name: Smith Foundry Facility Location: 1855 E 28th St, Minneapolis, MN 55407 Inspection Dates: December 12-13, 2023 34 IMG_0514.JPG 2023:12:12 10:41:16 35 IMG_0515.JPG 2023:12:12 10:45:07 36 IMG_0516.JPG 2023:12:12 11:15:26 37 IMG_0517.JPG 38 IMG_0518.JPG 39 IMG_0519.JPG 40 IMG_0520.JPG 41 IMG_0521.JPG 2023:12:12 11:21:11 2023:12:12 12:26:07 2023:12:12 12:27:02 2023:12:12 12:28:27 2023:12:12 12:33:05 42 IMG_0522.JPG 2023:12:12 12:33:14 43 IMG_0523.JPG 44 IMG_0524.JPG 45 IMG_0525.JPG 2023:12:12 12:33:37 2023:12:12 12:34:16 2023:12:12 12:35:47 46 MVI_0526.MP4 2023:12:12 12:37 47 IMG_0527.JPG 2023:12:12 12:38:09 48 IMG_0528.JPG 2023:12:12 12:44:34 49 IMG_0529.JPG 2023:12:12 13:40:33 50 IMG_0530.JPG 2023:12:12 14:18:59 51 IMG_0531.JPG 2023:12:12 14:26:49 52 IMG_0532.JPG 2023:12:12 15:20:03 53 IMG_0533.JPG 2023:12:13 09:23:35 54 MVI_0534.MP4 2023:12:13 09:50 55 IMG_0535.JPG 2023:12:13 10:45:59 56 IMG_0536.JPG 2023:12:13 10:46:43 57 IMG_0537.JPG 2023:12:13 10:47:15 58 IMG_0538.JPG 2023:12:13 10:48:04 59 IMG_0539.JPG 2023:12:13 10:48:53 60 IMG_0540.JPG 2023:12:13 10:50:03 61 MVI_0541.MP4 2023:12:13 13:33 62 IMG_0542.JPG 2023:12:13 13:54:07 63 IMG_0543.JPG 2023:12:13 13:59:07 64 IMG_0544.JPG 2023:12:13 14:01:13 65 IMG_0545.JPG 2023:12:13 14:21:06 Piles of dust on process equipment upstairs Claimed as Confidential Business Information Unsealed duct exiting north side of building above windows Garage door on back of building with bottom gap and noticeable odor Gap in shutters on northeast part of roof CE01 stack test configuration Side of Baghouse #1 with duct tape Accidental Photo View of central exhaust fan from roof with interior processes visible View of central exhaust fan from roof with interior processes visible CE05 stack test configuration CE01 inlet stack test configuration Visible emissions from furnace area exhaust duct, with steam in background Furnace area exhaust point on roof Accidental Photo CE01 inlet duct held together with tape CE01 inlet duct stack test configuration Unsealed duct and missing flap on openings in wall atop roof near CE05 CE05 stack test configuration CE03 exhaust stack test configuration Visible emissions from furnace area exhaust duct Flexible cover on hole on north end of shakeout duct Flexible cover on hole on shakeout duct near bridge Chute going into north end of shakeout duct Pouring area exhaust ducts to roof Ceiling ducts connected to pouring area Sand piles and closed windows north side Flapping open door to room on roof, machine sounds coming from inside CE03 stack test configuration Plywood door flapping open on roof near CE05 Open pipe on roof near CE05 Back garage door cracked open 7