Document x6Lkz6NG3v81gp8r0oOkw6wQ

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 JUN 1 9 2019 CLEAN AIR ACT INSPECTION REPORT Scepter, Inc., Bicknell, Indiana Sarah Clark, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Scepter, Inc. (Scepter) Facility Location: 6467 N Scepter Road, Bicknell, Indiana, 47512 Date of Inspection: April 30, 2019 EPA Inspector(s): 1. Sarah Clark, Environmental Engineer 2. Linda Rosen, Environmental Engineer Other Attendees 1. Tim Venderley, Plant Manager, Scepter 2. Tammy Haug, Senior Environmental Manager, Indiana Department of Environmental Management (IDEM) Contact Email Address: tvenderley@scepterinc.com Purpose of Inspection: Assess compliance with the Clean Air Act Facility Type: Secondary aluminum production facility Regulations Central to Inspection: National Emission Standards for Hazardous Air Pollutants (NESHAP) for Secondary Aluminum Production, Federally Enforceable State Operating Permit (FESOP), Indiana State Implementation Plan Arrival Time: 8:16 AM Departure Time: 11: 15 AM Inspection Type: C:sl Unannounced lnspect10n D Announced Inspection OPENING CONFERENCE l:8l Credentials Presented l:8l CBI warning to facility provided The following information was obtained verbally from Mr. Venderley unless otherwise noted. Process Description: Scepter receives aluminum scrap and dross, consisting of 10-80% aluminum, from commercial customers and processes this aluminum in one of three natural gas-fired rotary furnaces to produce 'recycled melt ingots' or RSIs, also referred to as sows. Aluminum scrap includes turnings, siding, auto shred, and bailed used beverage cans. Salt (sodium chloride) and potash (potassium chloride) solid fluxes and chlorine gaseous flux are added to the melt to remove impurities. The top layer of the melt is skimmed and returned to the process for further processing. Leftover settled impurities or 'salt cake' are cleaned out of the furnace and processed in a salt cake cooling system, a water-cooled rotary barrel device that cools and breaks apart the salt cake. Scepter owns an aluminum can shredder, but Scepter has not operated the shredder since 2017 because Scepter now only accepts bailed cans. Each furnace and the salt cake cooling system are controlled by dedicated baghouses. Ammonia gas is injected into the hood of each furnace to neutralize the pH of the exhaust; then, the exhaust passes through a cooling tower; after the cooling tower, but before the baghouse, lime can be injected into the exhaust stream. Waste salt cake and baghouse dust are sent to a Scepter-owned landfill for disposal. Staff Interview: Scepter operates 24 hours per day, seven days per week. 71 hourly and salaried employees work at this facility. Scepter functions as a toll processor, where, usually, incoming material is returned to the same customer after processing. Scepter may, for example, handle the oily scrap that their customers cannot handle. Scepter currently has approximately 20 regular customers. The following parameters are monitored for each furnace baghouse: inlet temperature, differential pressure (dP) across each module, bag leak detection system (BLDS), ammonia injection rate in standard cubic feet per hour (scfh), and pH. The inlet temperature setpoints, which are based on the latest dioxin/furan (D/F) testing, are 237 degrees Fahrenheit (F) for the Furnace F3 baghouse, 272F for the Furnace F4 baghosue, and 257F for the Furnace F5 baghouse. The baghouses operate under positive pressure. The dP is automatically continuously monitored, automatically recorded every 10 seconds, and manually monitored and recorded once per day. The dP range is 3-10 inches of water column (in H2O). The BLDS system experiences Page 2 of6 some false alarms; there is a 15 minute-delay after an alarm begins sounding before the furnaces are shut down and the cause of the alarm is investigated. The ammonia is injected at 50 scfh. The pH is read upstream of the baghouse and is compared to the city water pH. Lime may be injected intermittently. Lime usage is not monitored, but Scepter can estimate lime usage based on the weight of the lime silo. Hood velocity studies are conducted armually. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: We observed an example RSI (Photo 1) and incoming aluminum materials, including dross, turnings, rims, drive shafts, auto shred, and shredded foil (Photos 2-5). Next, we observed the salt cake cooling system (Photos 6-13). Here, hot salt cake is fed into the right side of the cooling system and cool salt cake exits the left side, sorted by size. This cooling system has two exhaust ventilation pick-up points: a hood with heat resistant curtains on the right (over the inlet) and a duct which draws from the partially enclosed outlet, where the cool salt cake is sorted into three size grades. While the salt cake tumbles inside the system, cool water circulates around the outside without contacting the salt cake. EPA observed particulate emissions which were not captured by the hood on the inlet side. At the time of our inspection, Furnace 3 was down for cleaning. EPA asked Mr. Venderley if any furnaces would be charging soon, and he responded "probably not." We observed Furnace 4 in operation, where Mr. Venderley explained the process was 'almost done,' with 'maybe just a reheat left' (Photos 14-19; contains confidential business information (CBI)). The hood was constructed of both heat resistant curtains and metal. Later we observed Furnace 4 tap (Photos 24-28; CBI). We observed the scale used to weigh aluminum scrap and dross (Photo 20) and the salt/potash blender, where salt and potash are situated on load cells and a hopper is used to dispense precise amounts of potash and salt fluxes (Photo 21). We observed the furnace label for Furnace 3 while it was down for cleaning (Photo 22); however, because Furnace 4 was operating and the area was hot, we observed the furnace label for Furnace 4 from a distance (Photo 23). We observed Furnace 5 as it had just finished tapping (Photo 29; CBI), and, behind the furnace, we observed the furnace label for Furnace 5 (Photos 30). Here, we observed that the area was dusty, and we observed a tear in the heat resistant curtain (Photo 31, CBI). Outside, we observed the salt cake cooling system baghouse, exhaust duct, and steam vent (Photos 32-33). Mr. Venderley informed EPA that the dP gauge was located at the top of the baghouse. We observed two tanks of anhydrous ammonia and the associated ammonia flow meters (Photos 34-35), which read 86 scfh for Furnace 3, 116 scfh for Furnace 4, and 80 for Furnace 5. EPA asked Mr. Venderley why ammonia was injected while Furnace 3 was down for cleaning; he Page 3 of6 later informed EPA that Furnace 3 was undergoing fan balancing work during which the ammonia to was turned on temporarily. He said that safeguards are in place to prevent the injection of ammonia unless the baghouse is drawing exhaust. Inside a control room for Furnaces 3 and 4, we observed a laminated sheet of instructions for checking the pH and reviewed an ammonia system calibration check sheet which had data for April 29 and 30 (Photos 37-39). We observed the followrng values on the pH momtors: city water was measured at 6.93 pH, Furnace 4 was operating at 8.78 pH, and Furnace 3 was operating at 9.04 pH. For the baghouses controlling Furnaces 3 and 4, we observed that the super sacs felt very full. Additionally, we observed that the stacks on the baghouse associated with Furnace 4 appeared corroded compared to the stacks on the baghouse associated with Furnace 3. At the base of the cooling tower, we observed a duct for 'blender air,' which Mr. Venderley explained is used to cool the exhaust stream (Photos 36, 40-47). He said that the damper has a maximum range of 50%, but that the damper only opens to approximately 35%. Inside, we returned to Furnace 4. We were too late to observe flux addition, but, after Mr. Venderley spoke with the operators in the control room, we were able to observe the charging of dross (Photos 48-58). At this time, while inspector Rosen photographed dross charging, inspector Mr. Venderley showed inspector Clark the Furnace 4 and Furnace 5 baghouse dP values, which he had captured on his phone while in the control room. The Furnace 4 baghouse modules were operating at 5.8, 5.6, 3.5, and 4.1 in H2O and the Furnace 5 baghouse modules were operating at 6.1, 6.4, 6.5, 6.4, 6.4, and 6.0 in H2O. Photos and/or Videos: were taken during the inspection. Photos of the furnaces and furnace hoods were claimed as confidential business information (CBI). These photos are identified accordingly in Appendix A. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Anunonia system calibration check sheet CLOSING CONFERENCE Requested documents: Most recent PM/HCl/D/F stack test (full report) for each furnace Most recent D/F stack test (full report) for each furnace (if not included above) From January 1, 2019 until April 30, 2019, for each furnace baghouse: o inlet temperature, 3-hour average; o BLDS, alarms and output; o dP reading, daily and data lot output; o Anunonia flow rate, 3-hour average; and o pH reading, daily Page 4 of6  Copies of corrective actions (e.g., malfunction sheets) from January 1, 2019 to April 30, 2019 Latest operation, monitoring, and maintenance plan (Mr. Venderley confirmed that there is only one plan) Quarterly FESOP reports from January 1, 2018 through April 30, 2019 Semiannual "MACT" reports for 2018 Safety data sheets for all fluxes Most current ventilation study (CBI, will include in mailing) SIGNATURES Report Author: -~"'-'-""""""""'--'~"""'....,L"'=---- Date: ft:ob:--/1,; J/._ /! Se6tion Chief: -"/~""-'"--'~.,_l~---'-,"'4-I-.L'd.../4,,-"'-""-------- Date: {q/f/1 ;;!al'\ i.r,/t1I /201t Page 5 of6 Facility Name: Scepter, Inc. Facility Location: 6467 N Scepter Road, Bicknell, Indiana Date of Inspection: April 30, 2019 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log Page 6 of6 Facility Name: Scepter, Inc. Facility Location: 6467 N Scepter Road, Bicknell, Indiana Date of Inspection: April 30, 2019 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Linda Rosen and Sarah Clark 3. Company/Facility Name: Scepter, Inc. 5. Number of Images: 58 2. Date(s) of Inspection: April 30, 2019 4. Street Address, City, State: 6467 N Scepter Road, Bicknell, Indiana 6. Archival Record Location: CD-R labeled as "Scepter, Inc. Bicknell, IN, Inspection Photos, 4/30/2019" Image Number File Name 1 P4300039.JPG Date aud Time (EDT) 4/30/2019 9:22 2 P4300040.JPG 4/30/2019 9:22 3 P4300041.JPG 4/30/2019 9:23 4 P4300042.JPG 4/30/2019 9:26 5 P4300043.JPG 4/30/2019 9:26 6 P4300044.JPG 4/30/2019 9:31 7 P4300045.JPG 4/30/2019 9:31 8 P4300046.JPG 4/30/2019 9:34 9 P4300047.JPG 4/30/2019 9:35 10 P4300048.JPG 4/30/2019 9:35 11 P4300049.JPG 4/30/2019 9:36 12 P4300050.JPG 4/30/2019 9:37 13 P4300051.MOV 4/30/2019 9:38 14 P4300052.JPG 4/30/2019 9:39 Latitude and Longitude 38.771107, -87.328908 38.771152, -87.32884 38.771152, -87.32884 38.771333, -87.33036 38.771352, -87.330355 38.772218, -87.330203 38.772013, -87.330167 38.771833, -87.330443 38.771833, -87.330443 38.77128, -87.330342 38.771435, -87.330155 38.771462, -87.330345 NIA 38.771462, -87.330345 Appendices Page 1 of 4 Description of Image RSI Incoming dross Incoming turnings Incoming aluminum pipe Incoming siding Salt Cake Cooling System Salt Cake Cooling System Salt Cake Cooling System Salt Cake Cooling System Salt Cake Cooling System Salt Cake Cooling System Salt Calce Cooling System Salt Cake Cooling System Furnace 4 (CBI) Facility Name: Scepter, Inc. Facility Location: 6467 N Scepter Road, Bicknell, Indiana Date of Inspection: April 30, 2019 15 P4300053.JPG 4/30/2019 9:40 16 P4300054.JPG 4/30/2019 9:41 17 P4300055.JPG 4/30/2019 9:41 18 P4300056.JPG 4/30/2019 9:42 19 P4300057.JPG 4/30/2019 9:43 20 P4300058.JPG 4/30/2019 9:45 21 P4300059.JPG 4/30/2019 9:48 22 P4300060.JPG 4/30/2019 9:49 23 P4300061.JPG 4/30/2019 9:50 24 P4300062.JPG 4/30/2019 9:53 25 P4300063.JPG 4/30/2019 9:54 26 P4300064.JPG 4/30/2019 9:54 27 P4300065.JPG 4/30/2019 9:56 28 P4300066.JPG 4/30/2019 9:56 29 P4300067.JPG 4/30/2019 9:58 30 P4300068.JPG 4/30/2019 9:59 31 P4300069.JPG 4/30/2019 10:00 32 P4300070.JPG 4/30/2019 10:01 33 P4300071.JPG 4/30/2019 10:05 34 P4300072.JPG 4/30/2019 10:09 38.771945, -87.33003 38.771992, -87.329982 ,R 77199? -87.329982 38.772112, -87.329832 38.771918, -87.329657 38.771573, -87.33021 38.771637, -87.330273 38.771717, -87.330222 38.771717, -87.330222 38.772038, -87.329847 38.772038, -87.329847 38.772038, -87.329847 38.772038, -87.329847 38.772038, -87.329847 38.772038, -87.329847 38.772038, -87.329847 38.772038, -87.329847 38.772038, -87.329847 38.77186, -87.330535 38.772093, -87.330353 Appendices Page 2 of 4 Furnace 4 (CBI) Furnace 4 (CBI) Furnace 4 (Col) Furnace 4 (CBI) Furnace 4 (CBI) Scale Potash and flux scale loader Furnace 3 label Furnace 4 label Furnace 4 (CBI) Furnace 4 (CBI) Furnace 4 (CBI) Furnaces 3 and 4 (CBI) . Furnaces 3 and 4 (CBI) Furnace 5 (CBI) Furnace 5 label Furnace 5 (CBI) Salt Cake Cooling System baghouse Salt Cake Cooling System exhaust duct and steam vent Anhydrous ammonia tanks Facility Name: Scepter, Inc. Facility Location: 6467 N Scepter Road, Bicknell, Indiana Date of Inspection: April 30, 2019 35 P4300073.JPG 4/30/2019 10:10 38.772085, -87.33037 36 P4300074.JPG 4/30/2019 10:13 38.772068, -87.330473 37 P4300075.JPG 4/30/2019 10:16 38.772107, -87.330355 38 P4300076..TPG 4/30/2019 10:16 38.772107, -87.330355 39 P4300077.JPG 4/30/2019 10:17 38.772107, -87.330355 40 P4300078.JPG 4/30/2019 10:18 38.772165, -87.330198 41 P4300079.JPG 4/30/2019 10: 18 38.77218, -87.33024 42 P4300080.JPG 4/30/2019 10:19 38.772197, -87.330267 43 P4300081 JPG 4/30/2019 10:19 38.772202, -87.330288 44 P4300082.JPG 4/30/2019 10:20 38.772217, -87.330323 45 P4300083.JPG 4/30/2019 10:21 38.772222, -87.33033 46 P4300084.JPG 4/30/2019 10:21 38.772222, -87.330332 47 P4300085.JPG 4/30/2019 10:25 38.772228, -87.330223 48 P4300086.JPG 4/30/2019 10:29 38.77179, -87.32951 49 P4300087.JPG 4/30/2019 10:29 38.771832, -87.329492 50 P4300088.JPG 4/30/2019 10:30 38.77197, -87.329522 51 P4300089.JPG 4/30/2019 10:31 38.771915, -87.329442 52 P4300090.JPG 4/30/2019 10:31 38.77192, -87.329643 53 P4300091.JPG 4/30/2019 10:31 38.77192, -87.329643 54 P4300092.JPG 4/30/2019 10:32 38.771907, -87.329518 Appendices Page 3 of 4 Anhydrous ammonia gauges Furnace 3 baghouse pH procedures pH procedures Ammonia System Calibration Check Sheet Furnace 3 baghouse super sacs Cooling tower for Furnace 4 Baghouse Furnace 4 baghouse Furnace 4 baghouse stacks Furnace 3 baghouse stacks Furnace 3 and 4 baghouses/super sacs Furnace 4 baghouse blender air Furnace 4 baghouse blender air Furnace 4 charging dross (CBI) Furnace 4 charging dross (CBI) Furnace 4 charging dross (CBI) Furnace 4 charging dross (CBI) Furnace 4 charging dross (CBI) Furnace 4 charging dross (CBI) Furnace 4 charging dross (CBI) Facility Name: Scepter, Inc. Facility Location: 6467 N Scepter Road, Bicknell, Indiana Date of Inspection: April 30, 2019 55 P4300093.JPG 4/30/2019 10:32 38.771907, -87.329518 56 P4300094.JPG 4/30/2019 10:35 38.771865, -87.329465 -- :JI ?4300095.JPG 4/30/2019 10:35 38.771865. -87.329465 58 P4300096.JPG 4/30/2019 10:36 38.77186, -87.329473 Furnace 4 charging dross (CBI) Opening to warehouse by Furnace 4 Onen1ng to v,arehonse hy Furnace 4 (CBI) Opening to warehouse by Furnace 4 Appendices Page 4 of 4