Document zbz8pMm0Z0ERqZm4ma6zrDqkn

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 DEC 19 2019 CLEAN AIR ACT INSPECTION REPORT Mono Ceramics, Inc., Benton Harbor, Michigan Gina Harrison, Environmental Scientist AECAB (MN/OH) Brian Dickens, Section Chief AECAB (MN/OH) File BASIC INFORMATION Facility Name: Mono Ceran1ics, Inc. Facility Location: 2235 Pipestone Road, Benton Harbor, Michigan 49022 Date of Inspection: November 26, 2019 Lead Inspector(s): 1. Gina Harrison, Envirom11cntal Scientist Other Attendees L .Anil E. Gaikwad, Vice President Technology, Mono Ceramics, Inc. 2. Eric R. Nelson, Principal, Prism Science and Technology Environmental Services Contact email address: anil.gaikwad(cvmonoceramics.com Purpose of Inspection: Determine compliance with the National Emission Standards for Hazardous Air Pollutants, Refractory Manufacturing (NESHAP Subpart SSSSS). Facility Type: Refractory lance, foundry nozzle, and pre-cast metal shape production facility Regulations Central to Inspection: NESHAP Subpart SSSSS. Arrival Time: 9:02 AM EST Departure Time: 11 :25 AM EST Page 1 ofS Inspection Type: ISJ Unannounced Inspection D Announced Inspection OPENING CONFERENCE [SJ Credentials Presented [SJ CBI warning to facility provided The following infornmtion was obtained verbally from Mr. Anil Gaikwad. Company Ownership: The facility bas been operating since the late 1980s and used to be part of a company named Clark Equipment, and later Monocon Group. Currently Mono Ceramics, Inc. (Mono Ceramics) is owned by IFGL Refractories, Ltd., a manufacturer of specialized refractories and operating systems for the steel industry. The facility employs 30 people and operates in five-day eight-hour shifts, with one shift per day. Process Description: Mono Ceramics operates a refractory lance and pre-cast shape manufacturing facility and primarily desi6'1ls and creates refractory lances for blast furnaces and electric arc furnaces, and also makes skimmer blades, foundry nozzles, and tundish impact pads. The facility creates products using alumina-based raw materials and other additives, all of which are pH-neutral. Mono Ceramics operates one production line with a continuous caster that rotates use of different core shapes depending on the product. In addition to the continuous caster the facility operates 2 kilns (Kilns B and C) and one mixer. The general process flow is: Raw materials>> mixer>> continuous caster (50-60 kg/min)>> kiln(s) >> steel fabrication>> inspection>> shipping Staff Interview: According to Mr. Gaikwad, no clay is used at this facility. Raw materials include bauxite, tabular alumina, mullite, flint, kyanite, and other alumina blends. The facility makes about 72 skimmer blades per year, 1200 tundish impact pads per year, and 300-500 nozzles per year. At some point Mr. Gaikwad's predecessor looked at potential applicability of the NESHAP Subpart SSSSS and determined that it did not apply to the facility. Mr. Gaikwad also noted that a Notice of Compliance Status Report for NESHAP Subpart SSSSS may have been submitted. and that be would look for it. Ms. Harrison asked if there have been any process changes since Mr. Gaikwad began employment at the facility, and Mr. Gaikwad noted that Kiln A is no longer operating, Kiln B is still operating per its original design with 16 burners, and Kiln C is brand new and operates with one 2.5 mmBtu010ur burner. Page 2 of5 TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: Mr. Gaikwad took Ms. Harrison and Mr. Nelson through the facility and pointed out the different areas, which were divided by function: raw material handling, caster area, core manufacturing/fabrication, kilns, and machining. In raw material handling, Ms. Harrison observed the mixer, which mixes each manually-weighed ingredient together before delivery to the caster. Ms. Harrison observed Kiln C in operation and its datalogger monitor, which was displaying temperature over the drying period. Mr. Gaikwad led the group outside to observe the exhaust header that receives gas from Kilns B and C and exhausts directly to atmosphere. Ms. HaJTison also observed the plasma cutter and the machining area, which makes extensions and cores for use in the continuous caster. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW Records were reviewed on site during the inspection. Ms. Harrison reviewed NESHAP Subpart SSSSS and asked questions regarding the use of ce1tain raw materials listed in the NESHAP Subpart SSSSS. CLOSING CONFERENCE Ms. Harrison thanked Mr. Gaikwad and Mr. Nelson for their time and told them she would send a copy afthe inspection report by email when it was completed. We confirmed that nothing we had discussed was Confidential Business Information. Ms. Hanison stated that EPA may potentially issue a Section 114 Information Request or follow up with questions via phone or email if further questions or concerns arise. Requested documents: Ms. Harrison requested a copy of the Notification of Compliance Status Report for NESHAP Subpart SSSSS and supporting documents, including stack testing. Compliance Assistance: General compliance assistance was provided by discussing requirements within the NESHAP Subpart SSSSS, the New Source Performance Standards for Nonmetallic Minerals at Subpart 000 (NSPS Subpart 000), the Michigan SIP, and the facility's operating permit. Concerns: Ms. HaJTison explained one of the main pnrposes of the inspection was to evaluate compliance with NESHAP Subpart SSSSS, and also noted that she would review the facility's Page 3 of5 use of kyanite and potentially follow up with qnestions to evaluate potential applicability of the NSPS Subpart 000. SIGNATURES 1 1 1 Report Author: ~~--__-~L_:_c;c._."_~_-"-___'____ _ _ _ _ _ Date: _!_,_'_1__i_J_'1__1_1_- Section Chief: ---=U=/"";C<Ll/j,..J)""--LL'<M,.,.,~"..-~' =------Date: _i_c~(_r~q_~/(~'!-~ Page 4 of5 APPENDICES AND ATTACHMENTS Amachment A: Photo and Video Log from November 26, 2019 Inspection of Mono Ceramics, Benton Harbor, Ml. Image Number 1 2 File Name IMG 20191126 100325.jpg IMG 20191126 100330.jpg Date and Time (incl. time zone and DST) 2019:11:26 10:03:25 2019:11:26 10:03:31 3 IMG 20191126 100915.jpg 2019:11:2 10:09:16 4 IMG 20191126 101521.jpg 2019:11:26 10:15:21 5 IMG 20191126 101543.jpg 2019:11:26 10:15:44 6 IMG 20191126 101717.jpg 2019:11:26 10:17:18 Latitude and Longitude Description of Image caster 1 caster 2 Control panel for Kiln B Photo of Kiln B stack Photo of Kiln C stack Photo of Kilns Band C and where Kiln A used to be Attachment B: DVD with Photos and Videos from November 26, 2019 lnspection of Mono Ceramics, Benton Harbor, MI. Page S ofS