Document wKLkaKXa8X3DRVkKRXpGjE4JJ

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET SW ATLANTA, GEORGIA 30303-8960 SENT VIA ELECTRONIC MAIL Bryan Jones Director, EHS Harsco, Inc 933 First Avenue, Suite 200 King of Prussia, PA 19406 bjones@harsco.com Dear Bryan Jones: On March 7, 2023, the U.S. Environmental Protection Agency Region 4 Air Enforcement Branch conducted a partial compliance inspection of Allworth, LLC, located in Birmingham, Alabama. We have enclosed the final report generated for this inspection (Enclosure). If you have any questions, please contact me at (404) 562-9206, or by email at hughesfairley.rosalyn@epa.gov. Enclosure Sincerely, ROSALYN Digitally signed by ROSALYN HUGHES FAIRLEY HUGHES FAIRLEY -04'00' Date: 2023.05.10 07:58:21 Rosalyn Hughes Fairley Environmental Engineer South Air Enforcement Section ENCLOSURE INSPECTION REPORT United States Environmental Protection Agency (EPA) Region 4 Air Enforcement Branch Inspection Report I. GENERAL INFORMATION Facility Name: Allworth, LLC. Location (Address): 500 Medco Rd, Birmingham, AL 35217 Inspection Date: March 7, 2023 Type of Inspection (Full or Partial Compliance Evaluation): Partial Compliance Evaluation PROGRAMMATIC ID: ALJEF0000107300018 PERMIT NUMBER: 4-07-0018-0001-01, 4-07-0018-0053-01; 4-07-0018-0054-01; 4-07-0018-0055-01; 4-07-0018-0061-01; 4-07-0018-0062-01 EPA Region 4 Investigator(s)/Inspector(s): 1. Rosalyn Hughes Fairley, Environmental Engineer 2. Sharron Porter, Environmental Engineer 3. Kevin Taylor, Environmental Engineer State/Local Investigator(s)/Inspector(s): 1. Virnita Ward, Environmental Health Specialist 2. Craig Tucker, Environmental Health Program Supervisor Person(s) Contacted at Facility (Name and Title): 1. Bryan Jones, Director, EHS 2. Terry Thompson, Facility Manager Report Prepared by: Rosalyn Hughes Fairley Project Name: Allworth, LLC. Birmingham ICIS/Project No.: ALJEF0000107300018-2023 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 1 of 13 FACILITY INFORMATION A. Facility and Permit Information Facility and Permit Information Comments 1. Type of facility (e.g., chemical plant, refinery, cement manufacturer, etc.). 2. Air permit number(s) and type of permit (e.g., Title V, PSD, Synthetic Minor, etc.). 3. Air permit issuance date. Off-site Waste Recycling Operations 4-07-0018-0001-01, 4-07-0018-0053-01; 4-07-0018-0054-01; 4-07-0018-0055-01; 4-07-0018-0061-01; 4-07-0018-0062-01 August 1, 2008 4. Air permit expiration date. No Expiration Date 5. Facility classification (Major, Synthetic Minor/Conditional Major, Minor). 6. Major source pollutants (if applicable). 7. Applicable regulations (e.g., State Implementation Plan, MACT Subpart FFFF, NSPS Subpart EEEE, etc.). 8. Types of air emission points (e.g., tanks, process vents, boilers, etc.). 9. Types of air pollution control equipment (e.g., baghouse, scrubber, afterburner, etc.). Minor N/A State Implementation Plan Tanks and process vents NA B. Process Description Allworth, LLC operates a storage, recycling, and reclamation facility for a variety of used solvents. Allworth was acquired approximately 3 years ago by Clean Earth Inc. which is why Clean Earth is referenced in the report. Allworth employs approximately 50 people and operates 3-8-hour shifts, five days a week. Project Name: Allworth, LLC. Birmingham ICIS/Project No.: ALJEF0000107300018-2023 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 2 of 13 Allworth has two waste tank systems (TS-1 and TS-2) and one product tank system. TS2 system is for its incoming waste streams and TS-1 for its outgoing products. TS-2 Tank system (F-tanks) is for the incoming waste solvents and chemicals. Waste solvents and other spent chemicals are received by tanker trucks and pumped into the facility's storage F-tanks, which are as follows: Permit Number 4-07-0018-0053-01 4-07-0018-0054-01 4-07-0018-0055-01 4-07-0018-0061-01 4-07-0018-0062-01 4-07-0018-0064-01 Tank 6,000-Gallon Bulk Storage Tank (Contaminated Wastewater) Tank ID# W-1 (TS-1) 6,000-Gallon Bulk Storage Tank (Contaminated Wastewater) Tank ID# W-2 (TS-1) 6 - 6,000-Gallon Bulk Storage Tanks (Solvent for Recovery) F-Tanks (1 thru 6) TS-2 4,100-Gallon Bulk Storage Tank (Waste Oil) Tank ID# O-1 (TS-1) 18,000-Gallon Bulk Storage Tank (Sludge Tank) Tank ID# B-5 (TS-1) 18,000-Gallon Bulk Storage Tank (Sludge Tank) Tank ID# B-7 (TS-1) Permit Number 4-07-0018-0001-01 regulates 23 final products tanks ranging in size from 10,000-Gallon to 1,500-Gallon in the TS-1 and Product Tank systems at Allworth. The final products at Allworth are the solvents and chemicals that are distilled for reuse and stored in the facility's storage tanks prior to shipment to back to the original customers; the sludge is distilled for use in cement kilns as an alternate fuel. The remainder of the waste streams distilled by Allworth are recycled for a solvent cleaner that Allworth sells. If the waste stream cannot be recycled, it is sent for disposal. During the inspection the facility was in the process of removing 9 tanks (from TS-1 and the Product tank farm) that were previously permitted under 4-07-0018-0001-01, therefore only 14 tanks now remain subject to this permit. II. INSPECTION ACTIVITIES Activity Opening Meeting 1. Date and time entered the facility. Yes No NA Y Comments EPA Region 4 (R4) inspectors arrived at the facility on March 7, 2023, at approximately 9:00 am. Project Name: Allworth, LLC. Birmingham ICIS/Project No.: ALJEF0000107300018-2023 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 3 of 13 Activity Yes No NA 2. Credentials presented to Y facility personnel (include name and title). 3. Conducted an opening Y meeting to explain the purpose and objectives of the inspection. Comments All inspectors presented their credentials to Bryan Jones, Director, EHS for Clean Earth. Inc. Inspectors held an opening meeting with Bryan Jones to discuss the purpose and objectives of the inspection. Terry Thompson, the Facility Manager also joined the discussion. 4. Discussed safety issues. Y 5. Discussed which records to N be reviewed. 6. Discussed the facility walk- Y through and the areas to be observed in the facility. 7. Discussed facility policy Y regarding photographs or video (if applicable). 8. Discussed the use of the N/A infrared camera, TVA, PID, and any other equipment. Inspectors discussed facility-specific safety and emergency procedures and appropriate protective equipment. The inspection team requested the following records: Number of tanks and the size Emissions Calculations Leak Detection Records Inspectors were primarily interested in inspection of the tanks. Region 4 inspectors indicated an Optical Gas Imaging camera would be used during the inspection. The team discussed facility policy regarding videography. Inspectors indicated that copies of any videos taken at the facility would be sent to the company. A log of photographs and videos taken at the facility is included in this report. See Appendix A. TVA/PID were not used during the inspection. Project Name: Allworth, LLC. Birmingham ICIS/Project No.: ALJEF0000107300018-2023 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 4 of 13 Activity 9. Discussed CBI. Yes No NA Y Records Reviewed at the Facility 10. The types of records N reviewed, and the time period reviewed. Facility Walk-Through Observations 11. The process equipment N/A observed and the associated operational rate observed (e.g., Furnace 1 production rate was 5 lbs/hr on 1/1/15, at 2:00 pm - permit requires max rate at 6 lbs/hr). Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. Comments EPA inspectors indicated that any material claimed to be Confidential Business Information (CBI) would be treated in accordance with regulations. 2022 Year End Emissions Summary Disposal Manifests for 9/3/2021 and 11/15/2021. 2022 Calendar year Spill Records 2022 Leak Records for 2022 Project Name: Allworth, LLC. Birmingham ICIS/Project No.: ALJEF0000107300018-2023 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 5 of 13 Activity 12. The type of process parametric monitoring observed and the associated value observed (e.g., Furnace 1 flux injection rate was 200 lbs/batch at 1/1/15, at 2:00 pm - permit requires max rate at 225 lbs/batch). Yes No NA N/A Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. Comments Project Name: Allworth, LLC. Birmingham ICIS/Project No.: ALJEF0000107300018-2023 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 6 of 13 Activity 13. If process equipment or parametric monitoring equipment was not operating, state the reason by facility personnel why the equipment was not operating. Yes No NA N/A Comments Project Name: Allworth, LLC. Birmingham ICIS/Project No.: ALJEF0000107300018-2023 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 7 of 13 Activity 14. The type of air pollution control equipment, the process equipment it is controlling, and the associated parametric monitoring value observed (e.g., baghouse pressure drop, temperature, scrubber flow rate, etc.). Yes No NA N/A (For example - RTO 1 controlling furnace 1, 1,500 degrees F on 1/1/15, at 2:00 pm - permit requires 1,400 degree F or higher). Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. Comments Project Name: Allworth, LLC. Birmingham ICIS/Project No.: ALJEF0000107300018-2023 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 8 of 13 Activity 15. Continuous emissions monitoring devices and values observed. (e.g., CEMS, COMs, etc.). Yes No NA N/A Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. 16. If air pollution control N/A equipment was not operating, state the reason by facility personnel why the equipment was not operating. 17. Capture and collection N/A system (enclosures and hoods) observations, if applicable (e.g., the magnitude and duration of emission escaping capture from the hood). Comments Project Name: Allworth, LLC. Birmingham ICIS/Project No.: ALJEF0000107300018-2023 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 9 of 13 Activity Yes No NA 18. Ductwork transferring the Y emissions to the air pollution control device observations, if applicable (e.g., the magnitude and duration of emission escaping from the ductwork, holes or deterioration in ductwork, no deterioration observed, etc.). 19. Any existing unpermitted N emission points, new unpermitted emission points, or non-permitted construction activities observed. (if yes, describe in the comments field). 20. Were any visible emissions N observed? (if yes, identify the location and equipment). 21. Was a Method 9 reading N performed? (if yes, identify the location and equipment). 22. Was the cause of the visible N/A emissions investigated and the information documented? 23. Was a Method 22 performed N for visible emissions? (if yes, identify the location and equipment). Comments The infrared camera was used to observe the tanks. No emissions were observed from the tanks or ductwork. Project Name: Allworth, LLC. Birmingham ICIS/Project No.: ALJEF0000107300018-2023 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 10 of 13 Activity 24. Identify the cause of the visible emissions as explained by facility personnel, if applicable. Yes No NA N/A 25. Was the infrared camera Y used? If so, attach the video log (which includes the equipment ID, and the date and time the video was recorded) and videos to this report. 26. Was the TVA used? If so, N identify the equipment monitored and the results. Provide the date and time the information was recorded by the inspector. Include actual instrument readings for each piece of equipment monitored above the leak definition and/or where the infrared camera identified a release. An attachment may be used for a large amount of information. Comments The infrared camera videos and the video log are attached. EPA R4 inspectors did not use a TVA at the facility. Project Name: Allworth, LLC. Birmingham ICIS/Project No.: ALJEF0000107300018-2023 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 11 of 13 Activity 27. Was the PID used? If so, identify how the PID was used and the results. Yes No NA N Provide the date and time the information was recorded by the inspector. An attachment may be used for a large amount of information. Closing Meeting 28. Conducted a closing meeting. Y 29. Summarize any additional N/A information needed, if applicable? 30. Accept a declaration of CBI, N/A if applicable? 31. Discussed observations. Y 32. Discussed next steps, if Y applicable? 33. Date and time inspection concluded. Comments EPA R4 inspectors did not use a PID at the facility. EPA Region 4 inspectors conducted a closing meeting on March 7, 2023, at approximately 11:50 am. Inspectors thanked facility personnel for their time and summarized inspection activities. A final inspection report from EPA Region 4 will be sent to the company within a 70day timeframe. The inspection concluded on March 7, 2023, at approximately 12:30 p.m. Project Name: Allworth, LLC. Birmingham ICIS/Project No.: ALJEF0000107300018-2023 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 12 of 13 Activity Miscellaneous 34. Include any additional observations, if applicable. Yes No NA N/A Comments While the inspectors were at the facility, Allworth was removing 10 storage tanks from the TS-1 Tank Systems that were not in use. The crane was physically on site and one tank was removed from the property before the inspectors left. ROSALYN HUGHES Digitally signed by ROSALYN EPA Investigator/Inspector Signature: ______________________H_U_G_H_E_S_FA_I_RL_E_Y___ FAIRLEY Date: 2023.05.10 07:59:44 -04'00' EPA Supervisor Signature & Title: ___________________________________ Groendyke, Digitally signed by Groendyke, Todd ___________________D_at_e:_2_02_3_.0_5._10_0_8_:4_4:_50___ Todd -04'00' Date Report Finalized: ___________________________________ Project Name: Allworth, LLC. Birmingham ICIS/Project No.: ALJEF0000107300018-2023 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 13 of 13 APPENDICES AND ATTACHMENTS 1. Appendix A. Inspection Photograph log Appendix A: Inspection Video Log During the March 7, 2023, inspection, EPA Region 4 staff used an infrared camera at the facility. Below is a list and description of the videos taken during the inspection. Table 1: Videos taken during the March 7, 2023, inspection File Number Media Description MOV_1178 TS2system F tanks MOV_1179 Top of TS2system F tanks MOV_1181 TS1 System tank area MOV_1182 Tank being removed from Product tank farm