Document vLN7yQVym5ZkvdZ4QdBeQ3jm

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Seeler Industries Inc., Joliet, Illinois Natalia Vazquez, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Seeler Industries Inc. Facility Location: 1 Genstar Drive, Joliet, Illinois Date of Inspection: March 28, 2023 EPA Inspector(s): 1. Natalia Vazquez, Environmental Engineer 2. Manojkumar Patel, Environmental Engineer Other Attendees: 1. Glenn J Gibisch, President 2. Joe Norris, Financial Officer Contact Email Address: ggibisch@seeler.com Purpose of Inspection: applicability of Part 68 Facility Type: bulk chemical distribution facility Regulations Central to Inspection: 40 C.F.R. Part 68 and CAA 112r(1) Arrival Time: 9:00 am Departure Time: 11:30 am Inspection Type: Unannounced Inspection Announced Inspection Facility Name: Seeler Industries Inc. Facility Location: 1 Genstar Drive Joliet, Illinois 60435 Date of Inspection: March 28, 2023 OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Provided CBI warning to facility The following information was obtained verbally from Glenn Gibisch unless otherwise noted. Process Description: Seeler Industries Inc. ("Seeler" or "Facility") is a bulk chemical distribution facility. Seeler handles uses or stores formic acid, hydrochloric acid (32% concentration), and hydrogen peroxide. The Facility blends chemicals to customers' specifications. Staff Interview: The Facility has been under the same ownership and in operation since 1984. The Facility has one shift Monday through Friday, 6:00 am to 4:00 pm. There are approximately 60 employees spread among warehouse, production area, maintenance, logistic trucking, bag filling and office. Formic acid and hydrochloric acid are stored in 275 gallon totes or 55 gallon drums. Hydrogen peroxide is mostly stored and handled in railcars and tank trucks. Seeler has only had one accident involving an employee being exposed to hydrogen peroxide within the past five years. The Facility has an Emergency Response Plan. Seeler has a contractor that assist the facility with training, and regulatory forms and permits. Joe Norris, financial officer, provided records that showed how much quantity was present on-site of hydrochloric acid and formic acid (See Confidential Business Information section) TOUR INFORMATION EPA Tour of the Facility: Yes Photos and/or Videos: were not taken during the inspection. Field Measurements: were not taken during this inspection. Page 2 of 4 RECORDS REVIEW Facility Name: Seeler Industries Inc. Facility Location: 1 Genstar Drive Joliet, Illinois 60435 Date of Inspection: March 28, 2023 1. Hydrochloric acid (32% concentration) Inventory - CBI 2. Formic acid Inventory - CBI 3. Certificate of Analysis for hydrochloric acid (32% concentration) 4. Reagent Chemical & Research Certificate of Analysis hydrochloric acid (3/9/2023, 2/22/2023, 2/7/20231/13/2023, 11/22/2022, 8/15/2022) 5. Hydrochloric acid Safety Data Sheet (from Reagent Chemical & Research and Seeler Industries, Inc. 6. Emergency Response Plan - didn't keep a copy CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility DIGITAL SIGNATURES NATALIA Digitally signed by NATALIA VAZQUEZ RIVERA VAZQUEZ RIVERA Date: 2023.04.12 09:27:36 -05'00' Report Author: _________________________________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL _M__A_R_S__H_A__L_L_______D_at_e:_20_2_3.0_4_.13_1_3_:54_:5_5_-0_5'_00_' Page 3 of 4 Facility Name: Seeler Industries Inc. Facility Location: 1 Genstar Drive Joliet, Illinois 60435 Date of Inspection: March 28, 2023 APPENDICES AND ATTACHMENTS 1. Confidential Business Information Attachment Page 4 of 5 Facility Name: Facility Name Facility Location: Facility Address Date of Inspection: Select date by clicking on the arrow CONFIDENTIAL BUSINESS INFORMATION ATTACHMENT Facility Name: Seeler Industries Inc. Facility Location: 1 Genstar Drive, Joliet, Illinois 60435 Date of Inspection: March 28, 2023 The facility provided its inventory Valuation Report for formic acid and hydrochloric acid and claimed it as Confidential Business Information (CBI) due to the chemical compounds' costs. As the amounts are part of the same record, this information was be kept in this section. Formic acid comes to the Facility as 55 drum gallons or as 275 gallon totes. The Facility stores formic acid on site two to three days or up to a month, before it gets shipped to its customer. Seeler provided the monthly quantity in pounds for formic acid from April 2022 to March 2023. The greatest amount of formic acid was 8,400 pounds. Formic acid threshold under 40 C.F.R. Part 68 is 10,000 pounds. Hydrochloric acid (32% concentration) comes to the Facility as 55 drum gallons or as 275 gallon totes. The Facility provided its inventory record of the amount on site of hydrochloric acid (32%) - 30,118 pounds. Hydrochloric acid is subject to 40 C.F.R. Part 68 when it has a concentration of 37% or greater. During the walkthrough, EPA observed 5 totes and 5 drums of hydrochloric acid (32% concentration) at the warehouse and none at the production area. EPA did not see any totes or drums of formic acid during the walkthrough. Page 5 of 5