Document qdD2rG1260p24m52pxNXL2bVR

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Chromium Industries LLC Brittany Cobb, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Chromium Industries LLC Facility Location: 4645 W Chicago Ave, Chicago, IL 60651 Date of Inspection: 11/9/2021 EPA Inspector(s): 1. Brittany Cobb, Environmental Engineer 2. Emma Leeds, Environmental Engineer Other Attendees: 1. Keith Summers, Maintenance/Environmental Coordinator Contact Email Address: ksummers@chromiumind.com Purpose of Inspection: To determine compliance with the Clean Air Act Facility Type: Hard chromium electroplating facility Regulations Central to Inspection: 40 CFR Part 63 Subpart N: National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks (NESHAP Subpart N) and any other applicable regulations and permits. Arrival Time: 1:30 PM CT Departure Time: 4:00 PM CT Page 1 of 5 Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet via email Provided CBI warning to facility The following information was obtained verbally from Keith Summers unless otherwise noted. Process Description: Chromium Industries LLC ("Chromium Industries" or "Facility") performs hard chrome plating on steel rolls of various sizes and occasionally cast iron. There are eight hard chrome tanks at the Facility. The large tanks are in building #1 and are the following sizes (gallons): 2678, 2860, 2505, and 11000. The small tanks are in building #3 and are the following sizes (gallons): 735, 475, 1700, 745. All of the tanks use hexavalent chrome as the plating solution. The Facility also performs blasting/polishing. There are four composite mesh pad (CMP) scrubbers to control emissions. Three of the CMP scrubbers (scrubber #1, #2, and #3) are connected through a plenum in building #1 to control the emissions from the large tanks. The fourth composite mesh pad scrubber (scrubber #4) is in building #3 and controls all four small tanks. There are six pads in each composite scrubber, and scrubber #2 has an additional HEPA filter. There is also one baghouse/dust collector to control emissions from blasting/polishing. Staff Interview: Chromium Industries had a performance test conducted on all four composite mesh pad scrubbers in 1998. The required pressure drop from this study for scrubber #1 was 1.7 inches of water column (" WC), #2 was 1.9" WC, #3 was 2.2" WC. According to Keith, the pressure drop can be plus or minus 2" WC for each. In 2015 a four stage HEPA filter was added to scrubber #2. Then a USEPA Method 306A Stack Test was performed on scrubber #2 to increase the allowable pressure drop from 1.9 to 3.3" WC. Chromium Industries records pressure drop daily and performs semiannual cleanings of the composite mesh pads. Acetone and mineral spirits are used as cleaners. The chrome tanks are at least 20 years old. They are occasionally emptied and replenished with fresh chrome. The emptied chrome is treated as hazardous waste and is stored in waste and holding tanks and covered. Page 2 of 5 TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA Inspectors were led on a tour of the Facility by Keith Summers, starting in building 2 and moving to building 3. Composite mesh pad scrubbers #1, #2, and #3 were operational and EPA observed the pressure drop for scrubber #1 was 2.7" WC, #2 was 3.8" WC, #3 was 3.8" WC. EPA also noticed the small chrome tanks were not well maintained and there was debris and wood in and around the tanks (IMG_1361.JPG, IMG_1362.JPG, IMG_1363.JPG). EPA was informed that these tanks had not been turned on for months and scrubber #4 was not running. The chrome solution would be emptied into the hazardous waste tanks and replaced before the Facility starts electroplating in these tanks again. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. SDS for chromic acid 2. SDS for sulfuric acid 3. 2015 Performance test for composite mesh pad scrubber #2 4. 40 CFR Part 63, Subpart N MACT Ongoing compliance status reports for area sources (40 C.F.R. 63. 63.347(h)) for 2020 5. Record of the sizes and contents of all the tanks CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: 1. Registration of Smaller Sources (ROSS) Permit 2. 1998 performance test 3. 40 CFR Part 63, Subpart N MACT Ongoing compliance status reports for area sources (40 C.F.R. 63. 63.347(h)) for 2018 - 2021 4. Daily pressure drop data for October 2021 5. Daily amp hour summary 6. Description and frequency of inspections/maintenance 7. Annual emission calculation for 2018 - 2021 Page 3 of 5 DIGITAL SIGNATURES Digitally signed by Brittany Cobb Date: 2022.01.07 Brittany Cobb 08:00:02 -06'00' Report Author: _________________________________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL MARSHALL 09:37:47 -06'00' Date: 2022.01.07 __________________________________ Page 4 of 5 APPENDICES AND ATTACHMENTS A. Digital Image Log Page 5 of 5 Facility Name: Chromium Industries LLC Facility Location: 4645 W Chicago Av, Chicago, IL 60651 Date of Inspection: November 9, 2021 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Emma Leeds Image Number 1 2 3 4 5 File Name IMG_1360.JPG IMG_1361.JPG IMG_1362.JPG IMG_1363.JPG IMG_1364.JPG 2. Archival Record Location: https://usepa.sharepoint.com/:f:/r/sites/R5_Work/r5er c/ecad/AECAB%20Library/Enf_Chromium%20Indust ries_IL_21_Inspection/Photos?csf=1&web=1&e=8II ts0 Date and Time (incl. Time zone and DST) 11/9/2021 2:52 PM CT Description of Image Large chrome electroplating tank 11/9/2021 3:12 PM CT Small chrome electroplating tank 11/9/2021 3:12 PM CT Small chrome electroplating tank 11/9/2021 3:13 PM CT Small chrome electroplating tank 11/9/2021 3:16 PM CT Dust collector for polishing Appendices Page 1 of 1