Document nNpjR5e8gGaZDkKaxNK21xL0m

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY New England Regional Laboratory Laboratory Services and Applied Science Division 11 Technology Drive, North Chelmsford, MA 01863 Report Memorandum Drafted Date: 12/05/2021 Finalized Date: 12/17/2021 Subject: Observation Report - Trelleborg Coated Systems US, Inc. From: William Osbahr, Stack Testing Coordinator, Field Services Branch (FSB) /WAO/ Tyler Kotsifas, Environmental Scientist, FSB /TLK/ Through: Jerry Keefe, Team Leader, FSB /JCK/ To: Christine Sansevero, Chief, Air Compliance Section Enforcement and Compliance Assurance Division Facility Information A. Facility Name: Trelleborg Coated Systems US B. Facility Location: 30 Lenox Street, New Haven, CT 06513 C. Facility Contact: Brian Franco, General Manager D. ICIS-Air #: CT0000000900903003 Background Information A. Date of test: 12/2/21 B. US EPA Representative: William Osbahr, Jerry Keefe, Tyler Kotsifas Disclaimer Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. Page 1 of 5 Observation Notes Investigation Participants: Name William Osbahr Tyler Kotsifas Jerry Keefe Mike Kelley Chris Durante Nick Garber Brendan Kelley Brian Franco Eric Turner David Moore Wesley Badorek Title Stack Testing Coordinator Environmental Scientist Environmental Engineer Stack Tester Stack Tester Stack Tester Stack Tester Plant Manager EH&S Manager Maintenance Manager Maintenance Manager Organization US EPA US EPA US EPA CK Environmental CK Environmental CK Environmental CK Environmental Trelleborg Trelleborg Trelleborg Trelleborg EPA representatives Mr. Osbahr, Mr. Kotsifas, and Mr. Keefe (EPA Team) attended a Volatile Organic Compounds (VOC) Capture Efficiency (CE) and Destruction Efficiency (DE) test at Trelleborg Coated Systems US, Inc. (Trelleborg) on December 2, 2021. The EPA team arrived at 8:00 am and met with Mr. Turner. Opening conference: The EPA Team held a brief opening conference to discuss the day's testing plan. The EPA Team stated that the purpose was to observe CE/DE testing activities which were expected to be performed throughout the day. Mr. Turner had explained in a phone call to EPA Team on the afternoon of December 1, 2021, that the facility was having difficulty meeting 100% CE with more than 2 enclosures in operation. In response to this deficiency, Mr. Turner explained that Trelleborg would only conduct low load operations while performing DE testing. Trelleborg would only operate 2 coating machines during the testing. Coaters 1 and 4 were chosen since they were the only coaters that Trelleborg could attempt to meet Method 204 criteria with. Observations: Before testing began, the EPA Team went up to the flat roof of the facility to see if all bypass vents which EPA had documented to be leaking during its previous visit of October 28, 2021, had been properly closed off. The EPA Team witnessed the work that had been done on the subject bypass vents. Each of the bypass vents cited on October 28, 2021, had been closed, capped, and sealed off in with sheet metal components. Mr. Moore stated further that the exhaust stack on the side of the building designated as M8 is used to remove and vent hot room air and not oven VOC laden air. This was a question that was also brought up during the previous visit. After assessing the bypass vents, Mr. Franco, Mr. Turner and the EPA Team agreed that a low load test should commence. Coaters #1 and #4 were run throughout the day to achieve low level conditions in order for CK Environmental to perform DE testing.. Page 2 of 5 The first test run took place from 10:05 AM -11:05 AM. A series of FLIR videos were recorded by EPA during the first test run that demonstrated the main bypass stack connected to the oxidizer's ventilation was leaking uncontrolled VOC emissions to the environment. Screenshots from these FLIR videos can be found in Attachment A of this report. FLIR videos clearly demonstrating emissions will be retained by the EPA team and will be available upon request. The second test run took place from 11:28 AM-12:28 PM. The third run took place from 12:53 PM-1:53 PM. Closing Conference: The EPA Team held a closing conference with Mr. Franco, Mr. Turner, Mr. Moore, and Mr. Kelley to discuss the results of the testing. The EPA Team explained that the FLIR videos demonstrated VOC fugitive/uncontrolled emissions from the main bypass stack. Mr. Kelley informed EPA Team of the initial results of the stack test. He summarized that Trelleborg's thermal oxidizer averaged 95.6% DE for the three test runs. The EPA Team requested that Mr. Turner and Mr. Kelley send copies of all continuous parameter monitoring data and all relevant field data sheets to them. The EPA Team informed Mr. Turner that they would follow up with them at a further date. Mr. Osbahr recommended that Trelleborg contact Mr. McCusker and/or Ms. Sansevero of EPA regarding the preliminary results. EPA representatives Osbahr and Kotsifas left the facility at approximately 2:45 PM, Mr. Keefe departed earlier at 1200 PM. Attachment A: FLIR Camera Videos Photo 1: Main Bypass Stack Demonstrating Leaks on Camera's High Sensitivity Mode Page 3 of 5 Photo 2: Main Bypass Stack Demonstrating Leaks on Camera's Auto Mode Photo 3: Main Bypass Stack Demonstrating Leaks on Visible Light Mode Page 4 of 5 Page 5 of 5