Document oKLQobge7q0MQ57QqNbrpVr
DATE:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS
77 WEST JACKSON BOULEYARD CHICAGO, lL 60604
JUN 2 1 2019
SUBJECT: FROM:
CLEAN AIR ACT INSPECTION REPORT Ross Incineration Services, Inc., Grafton, Ohio
Charles Hall, Environmental Engineer C ~
AECAB (MN/OH)
THRU:
Dakota Prentice, Acting Section Chief AECAB (MN/OH)
TO:
File, Ross Incineration Services, Inc., Grafton, Ohio
BASIC INFORMATION
Facility Name: Ross Incineration Services, Inc.
Facility Location: 36790 Giles Road, Grafton. Ohio
Date oflnspection: 07 May 2019
EPA lnspector(s): 1. Charles Hall, Environmental Engineer 2. Kosta Loukeris, Environmental Engineer
Other Attendees: 1. Debbie Bishop, Compliance Supervisor 2. Steve Goldman, Vice President of Technology 3. Zac Johnson, Environmental Technician II 4. Susan Kaiser, Director of Corporate Environmental, Health, & Safety (closing conference only) 5. Pat Lawson, Vice President, Corporate Compliance and Risk Management (closing conference only)
Contact Email Address: sgoldman@rossenvironmental.com
Purpose of Inspection: tanks inspection
Facility Type: Off-site waste and recovery operations and hazardous waste incinerator
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Regulations Central to Inspection: National Emission Standards for Hazardous Air Pollutants from Off-Site Waste and Recovery Operations, 40 C.F.R. Part 63, Subpart DD (OSWRO), National Emission Standard for Benzene Waste Operations (BWON), at 40 C.F.R. Part 61, Subpart FF
Arrival Time: 10:35 a..m. EDT
Departure Time: 4:35 p.m. EDT
Inspection Type: ~ Unannounced Inspection D Announced Inspection
OPENING CONFERENCE
[gJ Credentials Presented ~ CBI warning to facility provided
The following information was obtained verbally from Bishop, Goldman, Johnson, Kaiser, or Lawson unless otherwise noted.
Process Description:
Ross Incineration Services (Ross) receives solid and liquid hazardous and non-hazardous wastes. Ross either stores bulk liquids in a 10,000-gallon storage tank before incineration or feeds the liquid waste directly from a tank trailer into the incinerator. Wastes that Ross feeds directly from a tank trailer include reactive wastes, alcohols, and ketones. Each tank in Tank Farms 1, 2, and 3 is connected to a header vent which exhausts to a carbon bed system. Tanks 73 and 74, which are located at the process dock, are not connected to a carbon bed system. All hazardous waste tanks are subject to the Level 2 controls per the OSWRO standard. Ross introduces nitrogen into the header to maintain a blanket across all the hazardous and non-hazardous waste tanks.
TOUR INFORMATION
EPA toured the facility: Yes
Photos and/or Videos were taken during this inspection.
Field Measurements were taken during this inspection.
The inspectors used a forward-looking infrared camera to identify potentially leaking components on hazardous waste storage tanks and a total hydrocarbon analyzer, Toxic Vapor Analyzer 2020, to measure the hazardous air pollutant emission concentration in parts per million by volume (ppmV) from equipment components. The following tables summarize the calibration of the analyzer and concentrations detected from each component monitored.
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Cal1brat10n of.EPA TOXJ.C Vapor Analyzer (CleveIand Offiice)
Calibration Gas Standard Confirmation Reading -11 :46 am
500 ppm
50 I PPm
10,000 ppm
9,951 ppm
Ta11kNumber
37 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 51 52 53 54 55 59 60 61 62 63 64 73
73
73
73 74 74
Location agitator tank cover tank cover tank cover tank cover tank cover not in service tank cover tank cover tank cover tank cover tank cover tank cover tank cover tank cover agitator tank cover tank cover tank cover tank cover tank cover tank cover not in service tank cover tank cover tank cover tank cover agitator lower cover seal tank cover upper rupture disk agitator lower rupture disk
Highest Measurement, ppmV
1,287 <3 <3 <5 98 < 10
not in service
<3 30 47 <5 140 142 <5 <3 6,300 25 4,700 44 24 390 <5
not in service
388 4,500
<5 <5 < 10 7,800 (visible leak also) <3 15,000
<5
1,303
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Tank Number Location
74
tank cover
Highest Measurement, ppmV <5
RECORDS REVIEW
EPA reviewed the weekly visual inspection records Ross maintains for pumps and agitators. The records observed do not include the identification of each pump and agitator that needs to be
monitored weekly. In addition, the observation of the agitators does not specify that the
individual performing the visual observation needs to look at the agitator seal for a visible liquid leak.
CLOSING CONFERENCE
Requested Documents: Benzene TAB Report for 201 7 and 2018; and Semiannual Title V OSWRO Reports for 2017 and 2018 with the Benzene Monitoring Logs.
Concerns: Hall and Loukeris reviewed their measurements greater than 5 ppmV for each component listed in the table above.
SJGNATURES
Lead Inspector: - - - " - ~_,;;,,------'S;-=------c--'------- Date:
Section Chief: ___!_.J.L..!.~~ ~========:___ _ Date:
0 <z3 .J ...._ l 1 2 0 l q
7 / ?'f/ /Cf
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APPENDICES AND ATTACHMENTS
1.
Digital image/video log
2.
Digital images and videos on CD
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APPENDIX A: DIGITAL IMAGE LOG
1. Inspector Name: Constantinos Loukeris
3. Company/Facility Name: Ross Jncineratjrm
5. Number of Images:
7
2. Date(s) of Inspection:
May 7, 2019
4. Street Address, City, State:
. "~''" '36790 Giles Road. Grafton. Ohio ----~-------6. Archival Record Location: CD-R labeled "Ross Incineration, Grafton, OH, Inspection videos 51712019"
Image Number 1 2 3 4 5 6 7
File Name MOV 0047.mp4 MOV 0048.mp4 MOV 0050.mp4 MOV 0051.mp4 MOV 0052.mp4 MOV 0053.mp4 MOV 0054.mp4
Date 5/7/2019 5/7/2019 5/7/2019 5/7/2019 5/7/2019 5/7/2019 5/7/2019
Description of Image Hydrocarbon emissions were imaged
from the tank cover on tank 52. Hydrocarbon emissions were imaged
from the agitator on tank 51. Hydrocarbon emissions were imaged
from the tank cover on tank 62. Hydrocarbon emissions were imaged from the rupture disc vent of tank 32. Hydrocarbon emissions were imaged from the unner rupture disc on tank 73. Hydrocarbon emissions were imaged from the lower rupture disc on tank 74. Hydrocarbon emissions were imaged from the lower cover seal on tank 73.
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