Document xd1jNqNdr1Eq7zajE5Ry6EmqJ

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Clarios LLC, Geneva, Illinois Dakota Prentice, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Supervisor AECAB (IL/IN) File BASIC INFORMATION Facility Name: Clarios LLC Facility Location: 300 South Glengarry Drive, Geneva, Illinois Date of Inspection: July 25, 2023 EPA Inspector(s): 1. Dakota Prentice, Environmental Engineer 2. Carlo Demma, Physical Scientist (Env.) Other Attendees: 1. Melissa Bitter, Environmental Engineering Manager - Clarios LLC 2. Ernie Gowen, Manufacturing, Engineering, and Maintenance Manager - Clarios LLC 3. Alexandria Kelly, EHS Technician - Clarios LLC 4. Jay Noecker, Supply Chain Manager - Clarios LLC Contact Email Address: melissa.bitter@clarios.com Purpose of Inspection: to determine compliance with operating permits issued by Illinois EPA Facility Type: Lead-Acid Battery Manufacturer Regulations Central to Inspection: National Emission Standards for Hazardous Air Pollutants for Lead Acid Battery Manufacturing Area Sources at 40 C.F.R. Part 63, Subpart PPPPPP (NESHAP PPPPPP) Facility Name: Clarios LLC Facility Location: 300 South Glengarry Drive, Geneva, Illinois Date of Inspection: July 25, 2023 Arrival Time: 10:30 AM Departure Time: 12:30 PM Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Small Business Resource Information Sheet not provided. Reason: Not a Small Business Provided CBI warning to facility The following information was obtained verbally from Clarios personnel unless otherwise noted. Company Ownership: Approximately three years ago there was a "statutory tax conversion" resulting in the facility operating as Clarios LLC. It was previously operated as Johnson Controls Battery Group. Process Description: The Clarios facility manufactures starting, light, and ignition (SLI) lead-acid batteries frequently used in automobiles, boats, and trucks. Manufacturing begins with the production of lead oxide in either a Barton (thermal) process or a tumble milling process. The lead oxide is then conveyed to storage units until needed. Two plates are needed for the batteries, a positive plate and a negative plate. Negative plates are produced onsite from melted lead. Positive plates are provided by another Clarios facility. Paste is then manufactured by mixing the previously produced lead oxide with various additives. The paste is applied to the plates and then moved to a Chemset chamber. At the Chemset chamber, the chemistry of the lead that will be in the final battery is set through a curing process at controlled temperature of 170F and humidity for 36 hours. Assembly of the battery then commences. The positive and negative plates are combined in the plastic battery shell. Lead bearing straps and posts are added and the plastic top of the battery is melted to the existing shell. Acid is then added to the battery, the battery is charged for 5 to 36 hours, depending on the size, and then goes through various testing and decorating processes prior to shipment to customers. Staff Interview: Clarios obtains lead oxide from a third party as needed. Multiple baghouses are used to control emissions from the facility with most having secondary HEPA filtration. Bag leak detection systems are not in use. Baghouse pressure drop is monitored once per day. All baghouses are inspected quarterly. All lead oxide is stored in lead silos inside the plant. TOUR INFORMATION EPA Tour of the Facility: Yes Page 2 of 4 Facility Name: Clarios LLC Facility Location: 300 South Glengarry Drive, Geneva, Illinois Date of Inspection: July 25, 2023 Data Collected and Observations: EPA walked the exterior of the facility and observed two doors propped open. The doors were promptly closed by the Clarios personnel providing the facility tour to EPA. The doors were identified as being in the shipping and acid storage portions of the plant, respectively. EPA also toured portions of the interior of the facility. At the interior of the facility, EPA observed open windows in an area adjacent to truck loading and battery decoration. Photos and/or Videos: were taken during the inspection. See Appendix A: Digital Image Log Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Baghouse operation and maintenance plan Baghouse inspection records for the last month NESHAP PPPPP semi-annual reports for the last two years Documentation on any facility policies regarding open doors or windows Information regarding an incident where dirty baghouse filters were left on the facility roof Performance Test report for testing conducted in 2019 All reporting submitted to Illinois EPA in association with air regulations for the last two years DIGITAL SIGNATURES DAKOTA Digitally signed by DAKOTA PRENTICE Report Author: ______P_R__E_N__T_IC__E____08_:3_4:1_3_-0_5'_00_' _______ Date: 2023.07.28 Section Supervisor: Frank, Digitally signed by Frank, Nathan _N_a_t_h_a_n_______1_6:_34_:2_9 _-05_'0_0'______________ Date: 2023.07.28 Page 3 of 4 Facility Name: Clarios LLC Facility Location: 300 South Glengarry Drive, Geneva, Illinois Date of Inspection: July 25, 2023 APPENDICES AND ATTACHMENTS Appendix A: Digital Image Log Page 4 of 5 Facility Name: Clarios LLC Facility Location: 300 South Glengarry Drive, Geneva, Illinois Date of Inspection: July 25, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: C. Demma 2. Archival Record Location: EPA Region 5 Electronic Records Center Image File Name Date and Time Description of Image Number (incl. Time zone and DST) 1 IMG_5055.JPG 2023:07:25 Open windows adjacent to truck loading and battery 12:02:06 decoration 2 IMG_5056.JPG 2023:07:25 Open windows adjacent to truck loading and battery 12:02:20 decoration Note: All photos claimed as Confidential Business Information Page 5 of 5