Document wgxQ3GOmJ2KZMR7vzzVB746Rd

COMPLIANCE EVALUATION INSPECTION REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 5 Purpose: NPDES Industrial User Compliance Evaluation Inspection Facility: Continuous Cast Alloys 100 Quarry Rd Rochelle, IL 61068 Date of Inspection: February 2, 2021 EPA Inspectors: Val Dooling, Environmental Engineer, (312) 886-7167 John "Jack" Bajor, Environmental Engineer, (312) 353-4633 Facility Representatives: Jason Fowler, Owner, (630) 768- 1546 Steve Dilling, Foreman, (815) 703- 8813 City of Rochelle Representatives: Sharon Hawkins, Pretreatment and Lab Manager, (815) 561- 2067 Jay Mulholland, Director or Water and Water Reclamation, (815) 562- 2761 Report Prepared By: Val Dooling, Environmental Engineer, (312) 886-7167 EPA Inspector Signature and Date: VALERIE Digitally signed by VALERIE DOOLING _____D__O_O__L_I_N_G_____D1_5a:t4_e4:_:2103_2-1_0.50_'30._02'3____________________ Approver Name and Title: Ryan J. Bahr, Chief, Section 2, Water Enforcement and Compliance Assurance Branch Approver Signature and Date: Digitally signed by RYAN RYAN BAHR BAHR Date: 2021.03.23 ______________________1_5:_55_:4_5 -_05_'0_0'________________ i CONTENTS I. INTRODUCTION ....................................................................................................................... 1 II. BACKGROUND........................................................................................................................ 1 III. OPENING CONFERENCE...................................................................................................... 1 IV. FACILITY PROCESSES AND WASTEWATER INTERVIEW ........................................... 2 V. FACILITY WALKTHROUGH ................................................................................................. 3 VI. CLOSING CONFERENCE...................................................................................................... 4 VII. POST INSPECTION COMMUNICATION ........................................................................... 4 VIII. AREAS OF CONCERN: ....................................................................................................... 5 IV. REFERENCES AND DOCUMENTS RECEIVED ................................................................. 5 LIST OF APPENDICES Appendix A: Photo Log Appendix B: Aerial Facility Image Appendix C: Rochelle Municipal Utilities Discharge Permit 055 to Continuous Cast Alloys Appendix D: Rochelle Municipal Utilities Industrial Survey of Continuous Cast Alloys Appendix E: CCALbsCastedSumm2020.xlsx: Production Data for the year 2020 CONTINUOUS CAST ALLOYS INSPECTION REPORT I. INTRODUCTION The purpose of this announced inspection at the Continuous Cast Alloys facility (CCA) ILP000398, located at 100 Quarry Rd in Rochelle, Illinois was to evaluate and document CCA's compliance with the Clean Water Act (CWA). In particular, the purpose was to determine compliance with general pretreatment and categorical standards and to determine self-monitoring accuracy and the potential for spills. The facility does not have a NPDES permit, or a state pretreatment permit, but does have Utilities Discharge permit #055 with the City of Rochelle (Appendix C). II. BACKGROUND Continuous Cast Alloys is an indirect industrial discharger to the City of Rochelle (Rochelle)'s wastewater plant (NPDES #IL0030741) located at 888 Elliots Way, Rochelle, Illinois 61068, which discharges to the Kyte River. The City of Rochelle sent an industrial user survey to EPA, listing Continuous Cast Alloys as a categorical user under 40 CFR 471.35 Subpart C Nickel Cobalt Forming- New Source and 40 CFR 471.55 Subpart E- Refractory metals Forming - New Source; however, the EPA had not yet received records from the IU. Rochelle does not have an approved pre-treatment program; however, Ms. Hawkins, the City of Rochelle's Pretreatment and Lab Manager, told us she believes Rochelle might be requested to have a pre-treatment program during its next NPDES permit renewal cycle. According to the Rochelle Municipal Utilities pretreatment survey (Appendix D), CCA makes over 300 different products from cobalt, nickel, chromium, molybdenum, carbon, beryllium, tungsten, and boron which are sold as metal ingots, dental metal, dental rods and welding rods. The majority of each metal product is comprised of cobalt or nickel. No products have beryllium concentration at or greater than 0.01%. The company began production at its current site in November 2015 and employs 21 employees and an additional 10 in administrative roles. It operates two shifts from 5 AM - 11 PM. In November 2020, Jason Fowler took over management of CCA as owner and informed EPA that the company is expected to expand. According to Mr Fowler, he expects the company to increase production by 20% over the next 12 months. At the facility, there are four induction furnaces in operation and another furnace is expected to be installed during the year. Mr. Dilling, CCA's Foreman, does not expect any increase in water or wastewater use due to the new furnaces. According to the production numbers of the year 2020 sent by Mr. Fowler, the facility casts between 2,600 and 11,665 lbs of metal a month, averaging 7,555 lbs per month (Appendix E). III. OPENING CONFERENCE At 9:00am on February 2, 2021, Jack Bajor and I arrived Continuous Cast Alloys. I began the opening conference at 9:14 AM when all participants had arrived. Mr. Bajor presented inspector credentials to Jason Fowler and I presented my Temporary Letter of Authorization and explained that my permanent credentials were delayed due to COVID. During the opening conference, I explained the purpose of the inspection, presented Mr. Fowler with small business information, 1 CONTINUOUS CAST ALLOYS INSPECTION REPORT and requested whether any information was Confidential Business Information (CBI). Mr. Fowler replied that nothing discussed during the inspection would be CBI. IV. FACILITY PROCESSES AND WASTEWATER INTERVIEW Weighing raw material to specified alloy ratios, heating and pouring into sand molds are done offsite. According to the RMU Industrial Survey (Appendix D), onsite the pre-made ingot is heated in a furnace and metal rods are horizontal casted, which are then cooled with a closedloop water cistern. The cast metal rods are straightened, and annealed during a waterless process, then cut to size using closed-loop water cooled saws and centerless grinders. The product is then polished in a vibratory bowl using soap, water, EB-543 polish, and corncobs. CCA has a lab onsite with an optical emission spectrometer to evaluate the percentage of the metal. The alloy content of the products are also tested using an x-ray fluorescent Niton analyzer, according to Mr. Dilling. According to Mr. Dilling, CCA uses city water for cooling units, sanitary water, and fire sprinklers. They have both contact and non-contact cooling water onsite. A dry cooler is used at the facility for furnace cooling. The non-contact water has an ethylene glycol additive, and the contact cooling water is city water with no additive. No cooling water is discharged to the sewers, but water does need to be added occasionally, due to evaporation. In a power outage, free flow of city water through the system could occur. CCA has one connection to Rochelle's sewer system that occurs after pretreatment. According to Mr. Dilling, the pretreatment unit consists of one 125-gallon tank in which RM-10 flocculant is added. The solids are pumped to filter paper to air dry. The solid filter cake is collected in barrels and sold to a recycler. The liquid filtrate is sent to the city sewer. Mr. Dilling operates the pretreatment unit as a batch discharge during 2nd shift three days per week and does not have a class K operating certification. CCA creates two waste products, according to Mr. Dilling. In addition to the filter cake, resin from the saw blades and metal sawdust from the centerless grinder and water-cooled saws produces a slurry which air dries to a solid. Both waste products are collected in barrels and sold to a recycler in Belvidere, Wisconsin called Custom Alloys. Mr. Dilling told us that they keep the waste in barrels until they have enough to sell to the recycler, perhaps every six months: however, they try to remelt as much waste product as possible. According to Mr. Dilling there is no hazardous waste at the facility and the facility does not use solvents or degreasers. Any metal with beryllium content is cut with water to minimize dust. The water-cooled saws use a synthetic coolant (Photo 18) and the centerless grinder uses an oilbased coolant which are stored in barrels. The facility does not use steam, alkaline, molten salt or ammonia cleaners. According to Mr. Dilling, a dry dust collection sweeper is used as needed. Additionally, he told us, once, or twice a month a wet sweeper with soap additive cleaner is used. The wet sweeper wasterwater is collected in buckets and dumped into the pretreatment unit. 2 CONTINUOUS CAST ALLOYS INSPECTION REPORT There are two air scrubbers at the facility; however, both are dry scrubbers, and do not use water, Mr Dilling told us. I asked whether the facility took any water samples and Mr. Dilling replied that the resource tank water in the cooling system is tested for salinity and based on the results he will make chemical additions if needed to minimize scale buildup. The last testing was performed four months ago. He informed us that the facility does not test wastewater or any other waters. He also informed us that he does not submit any semi-annual monitoring reports to the EPA. Mr. Dilling told us there is no Toxic Organic Management Plan. V. FACILITY WALKTHROUGH The physical inspection of the facility began at 10:36 AM. Mr. Fowler and Mr. Mulholland left the inspection. Mr. Dilling led Mr. Bajor, Ms. Hawkins and me on a tour of the facility, which involved walking around the laboratory, warehouse, and production areas. An aerial map of the site is included in Appendix B and photos of the facility are included in Appendix A. We walked into the laboratory and Mr. Dilling showed us an example of a "heat sheet" which is used to determine the ratios of the metals used in ingots. In the warehouse and shipping area, Mr. Dilling showed where numerous buckets of different kinds of metals are stored before they are melted. Mr. Dilling also showed aluminum and copper raw metal used in making products. In the warehouse area, he showed us a specially designed automatic saw, called a "Barrett Saw", named after its inventor (Photos 1 & 2). According to Mr. Dilling, the saw is water cooled in a recirculating closed loop system. The cut product is collected in a bucket, which also collects some water, that then has to be manually dumped back into the tank. In the melting production area, we saw employees melting an NP Special ingot in order to horizontally cast a metal rod through a die (Photo 3). At the time, the furnace was registering at 2640 F. Mr. Dilling pointed out the water-cooling on the extruded metal (Photo 5). He showed us the dry cooling tank and five pumps (Photos 4, 6 & 7), one dedicated pump for each furnace. He showed us where the cooling water sample is collected and the storage area for water treatment chemicals. Mr. Dilling pointed out tanks of liquid nitrogen and explained that the facility uses a recirculated argon chiller which is cooled by liquid nitrogen. He also showed us an induction furnace which is offline for repair (Photo 8). In the cutting production area, Mr. Dilling showed us a digital straightener (Photo 10) which has a two-minute cycle and in the process also anneals the metal. The facility has two other analog straighteners that are not timed. Mr. Dilling showed the vibratory bowl (Photo 14) used for polishing and the pre-treatment unit (Photo 11). Next to the pretreatment unit, I saw a 55-gallon barrel of EB-543 polish (Photo 12) with no secondary containment. I saw another barrel currently open with a hose sitting on top that looked like it was recently filled and had some liquid nearby. No employees were currently nearby or actively filling the barrel. When asked about the filled barrel, Mr. Dilling informed us that it was a temporary solution to a problem there were having. These barrels were stored near a floor drain that was partially boarded over. When asked where the floor drains went, Mr. Dilling told me that he thought the floor drain that 3 CONTINUOUS CAST ALLOYS INSPECTION REPORT goes along the production area (northwest to southeast) drains to the sewer and the floor drain that goes across the production area (northeast to southwest) drains to a holding tank between the truck bays. He also mentioned that there is a vent in that area (Photo 15), so he thinks it goes to a holding tank, but he has not seen it open. Mr. Dilling told us that there was a large pile of snow in that area, due to plowing, so we could not access the holding tank at that time. Mr. Dilling showed us where the facility stored oil and synthetic lubricants and hydraulic oil in 55-gallon barrels used for the saws and grinders (Photos 17 & 18). I noted there was no secondary containments for any barrels. Also, in the production area, we saw two pipe cutting saws, and one centerless grinder, which use the lubricants. The saws have a carbon resin saw blade that is used so the cut is flush and does not leave a metal tail. The final area that Mr. Dilling showed us was the warehouse maintenance area, which included the wet and dry sweepers. I noticed a floor drain (Photo 19) and ask Mr. Dilling if it was ever used. He replied that he dumps mop bucket and soap down this drain, and he believes it flows to the grounds outside the building. VI. CLOSING CONFERENCE I began the closing conference at 12:32PM with Mr. Dilling and Ms. Hawkins, by going over the preliminary areas of concern that are highlighted in the next section and told them of the next steps. I noted that additional areas may be identified as EPA developed its inspection report. After concluding the inspection and thanking Mr. Dilling and Ms. Hawkins, Mr. Bajor and I left the facility. VII. POST INSPECTION COMMUNICATION On February 23, 2021, I requested clarifying information from the facility via email. I asked how three different wastestreams were disposed of. I asked for confirmation on where the floor drains went, and I asked for the correct spelling of the automatic saw. I also requested production data for the years 2018-2019, three years of water and sewer bills, three years of waste hauler bills and confirmation whether the facility had submitted baseline monitoring reports to U.S. EPA. Mr. Dilling called me the following day and told me that floor cleaning mop water goes in the pretreatment unit or down the floor drain in the maintenance area. Recirculated saw cooling water goes in the pretreatment unit, while swarf, the solid saw dust, is collected and sold to the recycler. How often the water cooled saw water is replaced depends on the operator and the saw, but could be as frequently as monthly or daily. During that call, Mr. Dilling told me that both floor drains in the production area (the northwest to southeast drain and the northeast to southwest drain) drain to the holding tank and not the sewer. He believes that the floor drain in the maintenance area is a French drain to the exterior. He requested employees only put liquid into the drain, because it will plug up if any solids are discharged. He also told me that he does not have any hauling receipts, city bills or information on a baseline monitoring report, and requested that information from Torrie Mack and Andre Madrigal. As of finalization of this report, I have not received submission of the requested records. 4 CONTINUOUS CAST ALLOYS INSPECTION REPORT VIII. AREAS OF CONCERN: 1. Effluent guideline standards 40 CFR 471.35 regulates nickel cobalt forming subcategory pretreatment standards for new sources (z) sawing or grinding rinse and (ff) miscellaneous wastewater sources. Effluent guideline standards 40 CFR 471.55 regulates refractory metals forming subcategory pretreatment standards for new sources (q) tumbling or burnishing wastewater and (t) sawing or grinding contact cooling water and (w) miscellaneous wastewater sources. Continuous Cast Alloys discharges vibratory bowl wastewater, saw cooling water and floor cleaning wastewater to City of Rochelle sewer and does not monitored its discharges. 2. Floor drains on the production floor and maintenance floor possibly discharge to holding tank or exterior French drain; however, the fate of those discharges is unknown. 3. Oils and lubricants are stored in the vicinity of the floor drains and pretreatment waste is collected in barrels next to the floor drains. I observed unknown liquids draining towards the floor drains. 4. Oils and lubricants are stored in barrels with no secondary containment for spill protection. 5. Facility did not provide records of a baseline monitoring report and has not submitted semi-annual reports to U.S.EPA. 6. Facility intends to significantly increase production and has not given advanced notice to the Control Authority, U.S. EPA. 7. Facility did not provide records of recycling hauling receipts, sewer and water bills for the past 3 years. IV. REFERENCES AND DOCUMENTS RECEIVED Hardcopy Documents Collected during Inspection: 1. Rochelle Municipal Utilities Industrial Survey of Continuous Cast Alloys 2. Rochelle Municipal Utilities Discharge Permit 055 to Continuous Cast Alloys 5 CONTINUOUS CAST ALLOYS INSPECTION REPORT 3. Rochelle Illinois Cde of Ordinances Article III: Water and Article IV: Sewers and Sewage Disposal Digital Documents received via email on 2/24/2021: From Jason Fowler: CCA-000 Rev 2 CCA Quality Management Systems.docx From Jason Fowler: CCALbsCastedSumm2020.xlsx From Sharon Hawkins: 2019 NPDES Permit.pdf From Sharon Hawkins: BW report.pdf Digital Documents received via email on 2/4/2021: From Sharon Hawkins: Cont Cast Alloys Rochelle.pdf 6 CONTINUOUS CAST ALLOYS INSPECTION REPORT APPENDIX A: FACILITY PHOTO LOG Continuous Cast Alloys EPA Inspection February 2, 2021 All photos taken by Val Dooling, Environmental Engineer, U.S. EPA Camera: Pentax WG-1 1: IMGP0023 Description: Back of automatic "Barrett Saw". Recirculated cooling water is collected in white box. Note liquid stored in bucket nearby. Location: CCA Building Warehouse Area Camera Direction: 150 South Date/Time: February 2, 2021 10:56 AM A-1 CONTINUOUS CAST ALLOYS INSPECTION REPORT 2: IMGP0024 Description: Water-cooled automatic "Barrett Saw". Water is collected and recirculated. Product and water slides down metal ramp and is collected in a bucket (outside photo). Location: CCA Building Warehouse Area Camera Direction: East Date/Time: February 2, 2021 11:04 AM A-2 CONTINUOUS CAST ALLOYS INSPECTION REPORT 3: IMGP0025 Description: Metal ingot melted in a furnace. Current temperature logged as 2685F. Location: CCA Building Production Area Camera Direction: South Date/Time: February 2, 2021 11:07 AM A-3 CONTINUOUS CAST ALLOYS INSPECTION REPORT 4: IMGP0026 Description: Cooling water tank and two yellow pumps. Note water softener and buckets of chemicals on right. Location: CCA Building Production Area Camera Direction: East Date/Time: February 2, 2021 11:14 AM A-4 CONTINUOUS CAST ALLOYS INSPECTION REPORT 5: IMGP0027 (redacted) Description: Furnace (from photo 3) on left of photo, producing horizontial cast rod. water on extrusion through die. Note: Photo was redacted to remove peronally identifible information of employee Location: CCA Building Production Area Camera Direction: East Date/Time: February 2, 2021 11:16 AM Cooling A-5 CONTINUOUS CAST ALLOYS INSPECTION REPORT 6: IMGP0028 Description: Four of five cooling water pumps in gallery. Each pump is dedicated to an individual furnance. Location: CCA Building Production Area Camera Direction: West Date/Time: February 2, 2021 11:22 AM A-6 CONTINUOUS CAST ALLOYS INSPECTION REPORT 7: IMGP0029 Description: Cooling water tank on left and pump gallery on right. Liquid nitrogen tank (outside of photo on left) is also used for cooling. Location: CCA Building Production Area Camera Direction: West Date/Time: February 2, 2021 11:22 AM A-7 CONTINUOUS CAST ALLOYS INSPECTION REPORT 8: IMGP0030 Description: Outfall. Offline furnance to be repaired, shows induction and hot water copper rods. Location: CCA Building Production Area Camera Direction: Southeast Date/Time: February 2, 2021 11:31 AM A-8 CONTINUOUS CAST ALLOYS INSPECTION REPORT 9: IMGP0031 Description: Dry air scrubber with six vents. Location: CCA Building Production Area Camera Direction: Northeast Date/Time: February 2, 2021 11:36 AM A-9 CONTINUOUS CAST ALLOYS INSPECTION REPORT 10: IMGP0032 Description: Straightening and annealing operation. Location: CCA Building Production Area Camera Direction: East Date/Time: February 2, 2021 11:41 AM A-10 CONTINUOUS CAST ALLOYS INSPECTION REPORT 11: IMGP0033 Description: Filter paper on pretreatment unit. Dried solid waste "cake" is collected in bin for collection and recycling. Location: CCA Building Production Area Camera Direction: South Date/Time: February 2, 2021 11:49 AM A-11 CONTINUOUS CAST ALLOYS INSPECTION REPORT 12: IMGP0034 Description: Floor drains, some covered with wood. Left to right drain connects to sewer, and fore to background drain is collected in holding tank. Note barrels with no secondary containment. Note unknown liquid on floor around middle barrel flowing to floor drain. Location: CCA Building Production Area Camera Direction: Northeast Date/Time: February 2, 2021 11:49 AM A-12 CONTINUOUS CAST ALLOYS INSPECTION REPORT 13: IMGP0035 Description: Close up of barrell (on right of photo 12). Location: CCA Building Production Area Camera Direction: Down Date/Time: February 2, 2021 11:50 AM A-13 CONTINUOUS CAST ALLOYS INSPECTION REPORT 14: IMGP0036 Description: Vibratory bowl used for polishing dental metals. Location: CCA Building Production Area Camera Direction: West Date/Time: February 2, 2021 11:56 AM A-14 CONTINUOUS CAST ALLOYS INSPECTION REPORT 15: IMGP0037 Description: Floor drain to outside holding tank. Location: CCA Building Production Area Camera Direction: East Date/Time: February 2, 2021 11:57 AM A-15 CONTINUOUS CAST ALLOYS INSPECTION REPORT 16: IMGP0038 Description: Water cooled saw and 15 gallon recirculating water holding tank. Location: CCA Building Production Area Camera Direction: Northwest Date/Time: February 2, 2021 12:01 PM A-16 CONTINUOUS CAST ALLOYS INSPECTION REPORT 17: IMGP0039 Description: Hydraulic oil for saw machinery. Location: CCA Building Production Area Camera Direction: North Date/Time: February 2, 2021 12:05 PM A-17 CONTINUOUS CAST ALLOYS INSPECTION REPORT 18: IMGP0040 Description: Oil storage area. Note no secondary containment. Location: CCA Building Production Area Camera Direction: North Date/Time: February 2, 2021 12:06 PM A-18 CONTINUOUS CAST ALLOYS INSPECTION REPORT 19. IMGP0041 Description: Floor drain in maintenance area. Drains to outside of building. Location: CCA Building Maintenance Area Camera Direction: Northwest Date/Time: February 2, 2021 12:23 PM A-19 CONTINUOUS CAST ALLOYS INSPECTION REPORT APPENDIX B: AERIAL FACILITY IMAGE B-1 CONTINUOUS CAST ALLOYS INSPECTION REPORT APPENDIX C: ROCHELLE MUNICIPAL UTILITES DISCHARGE PERMIT 055 TO CONTINUOUS CAST ALLOYS C-1 CONTINUOUS CAST ALLOYS INSPECTION REPORT C-2 CONTINUOUS CAST ALLOYS INSPECTION REPORT C-3 CONTINUOUS CAST ALLOYS INSPECTION REPORT C-4 CONTINUOUS CAST ALLOYS INSPECTION REPORT C-5 CONTINUOUS CAST ALLOYS INSPECTION REPORT C-6 CONTINUOUS CAST ALLOYS INSPECTION REPORT C-7 CONTINUOUS CAST ALLOYS INSPECTION REPORT C-8 CONTINUOUS CAST ALLOYS INSPECTION REPORT C-9 CONTINUOUS CAST ALLOYS INSPECTION REPORT C-10 CONTINUOUS CAST ALLOYS INSPECTION REPORT C-11 CONTINUOUS CAST ALLOYS INSPECTION REPORT C-12 CONTINUOUS CAST ALLOYS INSPECTION REPORT APPENDIX D: ROCHELLE MUNICIPAL UTILITES INDUSTRIAL SURVEY OF CONTINUOUS CAST ALLOYS D-1 CONTINUOUS CAST ALLOYS INSPECTION REPORT D-2 CONTINUOUS CAST ALLOYS INSPECTION REPORT D-3 CONTINUOUS CAST ALLOYS INSPECTION REPORT D-4 CONTINUOUS CAST ALLOYS INSPECTION REPORT D-5 CONTINUOUS CAST ALLOYS INSPECTION REPORT D-6 CONTINUOUS CAST ALLOYS INSPECTION REPORT D-7 CONTINUOUS CAST ALLOYS INSPECTION REPORT APPENDIX E: CCALbsCastedSumm2020.xlsx: PRODUCTION DATA FOR THE YEAR 2020 CCA Lbs. Casted Summary by Month Lbs. Casted Jan 5,446 Feb 9,241 Mar 7,087 through 3/20. Final log not sent Apr 7,215 May 9,456 Jun 11,276 Jul 6,616 Aug 7,472 Sep 5,034 through 9/22. no final log sent Oct 11,665 Nov 2,601 through 11/11-no logs sent since Dec Total 83,109 7,555 E-1