Document nmbGZZw1Ba11xDV1oGZm6J0y2

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT ASK Chemicals, Cleveland, Ohio FROM: Veronica Fischer, Environmental Engineer AECAB (MI/WI) THRU: Sarah Marshall, Section Supervisor AECAB (MI/WI) TO: File BASIC INFORMATION Facility Name: ASK Chemicals Facility Location: 2191 West 110th Street, Cleveland, OH 44102 Date of Inspection: April 23, 2024 EPA Inspector(s): 1. Veronica Fischer, Environmental Engineer 2. Giles Chickering, Environmental Engineer Other Attendees: 1. Rich Daff, Plant Manager 2. Steven Henson, EHS Manager 3. John Mural, Operations Manager Contact Email Address: Richard.Daff@ask-chemicals.com Purpose of Inspection: To evaluate compliance with the facility's operating permit and the Ohio SIP Facility Type: Chemical and resin manufacturing facility Regulations Central to Inspection: Federally enforceable state operating permit and the Ohio SIP Arrival Time: 9:05 AM EDT Departure Time: 11:30 AM EDT Inspection Type: Unannounced Inspection Announced Inspection Facility Name: ASK Chemicals Facility Location: 2191 West 110th St, Cleveland, OH Date of Inspection: April 23, 2024 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 ASK Chemicals personnel unless otherwise noted. Process Description: ASK Chemicals (ASK) owns and operates a chemical manufacturing facility in Cleveland, Ohio that produces chemicals and resins for use in foundries. ASK primarily produces a two-part resin for the formation of foam molds for metal casting. Part 1 is the phenolic resin base, while part 2 is the isocyanate catalyst. The facility also has another catalyst blending operation for amine-based and vinyl catalysts and has a chemical repackaging operation. The phenolic resin production process is performed in two batch reactors. Emissions from the reactor are controlled by a caustic scrubber. ASK also operates a methanol recovery unit. The methanol recovery unit consists of a vacuum distillation process to remove water from methanol so that it can be recycled to the process. The methanol vacuum distillation column is also controlled by the caustic scrubber. The caustic scrubber is used to control volatile organic chemical (VOC) emissions, including formaldehyde and methanol. In the catalyst blending process, the isocyanate catalyst is blended with various solvents depending on the product. ASK has two blend tanks dedicated to the isocyanate catalyst blending operation. The facility has one other blend tank for blending various amine-based or vinyl catalysts with solvents. The isocyanate blending tanks are not controlled for emissions, however the amine blending tank has a vapor balance system and an acid scrubber. ASK also repackages bulk amines into smaller volume drums and totes. This operation is also controlled by an acid scrubber. Facility Name: ASK Chemicals Facility Location: 2191 West 110th St, Cleveland, OH Date of Inspection: April 23, 2024 Staff Interview: The caustic scrubber is monitored for pH and differential pressure. The pH is monitored by sampling, which is conducted every four hours. The scrubber must maintain an overall control efficiency of 85 percent and the pH is required to be maintained between 11.5 and 14.0, as required by the facility's operating permit. Differential pressure is continuously monitored, is alarmed, and is required to be maintained between 2.0 and 7.0 inches of water. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: EPA inspectors used an optical gas imaging (OGI) camera to monitor equipment for VOC emissions. Emissions were observed from a filter and from the caustic scrubber stack. Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Reports for any engineering study or performance test for the caustic scrubber Emissions calculations (preferably in Excel format) for the last three years Quarterly deviation reports for the last three years PERs for the last three years Batch tickets for April 23, 2024 (day of inspection) to show what was being routed to the caustic scrubber at the time of the inspection Concerns: EPA inspectors reviewed the emissions that were observed with the OGI camera with ASK personnel. DIGITAL SIGNATURES VERONICA Digitally signed by VERONICA FISCHER Report Author: _F_I_S_C__H_E__R________-_05_'0_0' _____________ Date: 2024.06.21 11:22:00 Section Supervisor: SARAH Digitally signed by SARAH MARSHALL MARSHALL Date: 2024.06.21 11:30:25 -05'00' __________________________________ Facility Name: ASK Chemicals Facility Location: 2191 West 110th St, Cleveland, OH Date of Inspection: April 23, 2024 APPENDICES 1. Appendix A: Digital Image Log and Digital Video Log Facility Name: ASK Chemicals Facility Location: 2191 West 110th St, Cleveland, OH Date of Inspection: April 23, 2024 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: Veronica Fischer Archival Record Location: ERC/Enf_ASK Chemicals_OH_24/Inspection/Videos Image Number 1 2 3 4 File Name FLIR0155.mp4 FLIR0156.mp4 FLIR0157.mp4 FLIR0158.mp4 Date and Time (EDT) 9:22 AM 9:37 AM 10:03 AM 10:07 AM Latitude and Longitude - - - Description of Image Filter Connector on R301 Emissions from top of building Emissions from caustic scrubber stack