Document 6RvopyKEV1nDV4bpKw73Rw5Oo

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 NOV 1 9 2018 CLEAN AIR ACT INSPECTION REPORT Recycling Services of Indiana, Bedford, Indiana Gina Harrison, Environmental Scientist AECAB (MN/OH) Brian Dickens, Section Chief AECAB (MN/OH) File BASIC lNFORMATION Facility Name: Recycling Services ofindiana (RSI) Facility Location: 4635 Peerless Road, Bedford, IN 47421 Date of Inspection: September 18, 2018 EPA Inspectors: 1. Gina Harrison, Environmental Scientist 2. Sarah Clark, Environmental Engineer Other Attendees: 1. Susan Raisor, Air Compliance Inspector, IDEM Southeast Regional Office 2. Robert (Bob) Meadows, Operations Manager, RSI 3. Glenn Hoskins, Lead Maintenance Supervisor, RSI Contact Email Address: Rmeadows(ciJ,rsionline.org Purpose of Inspection: CAA inspection of emission units subject to NESHAP RRR and Title V Facility Type: Secondary aluminum recycling and smelting facility Arrival Time: 8:32 AM EDT Departure Time: 11 :35 AM EDT Inspection Type: ISi Unannounced Inspection D Announced Inspection OPENING CONFERENCE ISi Credentials Presented ISi CBI warning to facility provided The following information was obtained verbally from Mr. Meadows unless otherwise noted. Company Ownership: RSI was purchased (and named RSI) in 2010 with ownership divided between Mr. Gary Wayde and Mr. Paul Boening. Mr. Meadows informed us that Mr. Boening is leaving, so Mr. Wayde will soon assume full ownership. Process Description: RSI is an aluminum recycling and smelting facility located in a residential neighborhood in Bedford, Indiana. RSI receives, sorts, melts, refines, alloys, and casts aluminum scrap and dross to make aluminum sows for customers, including GM auto, Ryobi, and scrap brokers. Typically, the facility receives a few truckloads of aluminum material per day; materials received mainly include "380"-cast aluminum scrap (i.e., off-specification castings of transmissions and engine blocks from the manufacturer, and turnings/borings) and dross. RSI uses two 20,000 lb capacity furnaces to melt, alloy, refine, and cast sows, which are formed by pouring metal from furnaces to fill troughs. Production occurs 24 hours per day, 7 days per week in three shifts, and each production cycle, or heat, lasts around one hour. The tap to tap time, including charging, is approximately 40-50 minutes, and each furnace operates separately at a rate of 20,000 lbs/hour. Material is brought into the facility by truck and immediately sorted in two storage bays located near the entrance to the facility. Front-end loaders take aluminum scrap from the sorted areas within the bays to one of two furnaces. After the scrap is loaded into the furnace, the front-end loaders add flux into the charge bucket and then charge the flux into the furnace. The flux contains salt, pot ash, and cryolite, which removes magnesium from the aluminum. RSI may add silicon and/or copper to the melt to meet customer specifications. When the heat is finished, the furnace is tilted in order to pour melted aluminum into troughs directly from the furnace. Skim from the top of the freshly poured sows is returned directly to the furnace. Dross, the undesirable portion of the melt, is skimmed from the top layer of the molten aluminum during pouring and is collected in a bucket. The dross is then moved to another area near the back of the building to cool for 2-3 days. When it is sufficiently cooled, the dross is moved to the jaw crushers to be reprocessed to reclaim the residual aluminum. Jaw crushers, along with an eddy current system, break down and separate the residual aluminum from impurities within the dross. The aluminumcontaining dross is fed back into the furnaces in varying volumes while the remaining highimpurity dross is sent to a landfill. Page 2 of6 Staff Interview: According to Mr. Meadows, the facility has been operating as an aluminum recycling and processing operation since the 1970s and was a stone mill in the early 1900s. RSI cunently employs 34 people. The facility does not currently operate a hammermill, but management is looking to possibly procure one. The hammermill would replace the facility's existing jaw crushers. The facility has recently replaced outdoor building siding with fiberglass reinforced plastic to protect the building against corrosion. RSI does not perform scrap pretreatment. Scrap management procedures include visual inspection for moisture, iron, and zinc content. RSI personnel screens material and rejects anything with visible high free iron or zinc content. The material processed in each furnace is generally the same. The "380" aluminum scrap comes from die casting materials and molds, and typically contains around 1.1 % iron and has a high silicon content. In accordance with its permit and the resnlts of a May 2017 stack test, the facility adds lime to the baghouse at a rate of30 lbs/hour, at minimum. The May 2017 stack test was performed with old hoods that have since been redesigned. All air compliance services are performed by August Mack. At the time of our inspection, Furnace A was being relined, so the facility was currently only using Furnace B. The two baghouses associated with both furnaces are Donaldson/Torit units, and contains 484 bags in each compartment. RSI replaces the bags as needed and has replaced five hags over the last two years. The jaw crusher was not currently running. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: Inspectors entered the smelting shop and observed the scrap selection area, including the eddy current system. Furnace B was running, and inspectors observed high opacity smoke, generated from the furnace, that appeared to escape the hood and emit to the atmosphere through large holes in the wall near the furnace. Mr. Meadows explained that sometimes the baghouse will shut down if it gets too hot. Inspectors observed a charge into Furnace B with which a lot of high opacity smoke escaped the hood, and Mr. Meadows described the charge as containing borings. The borings were provided by a customer that typically provides borings, and the facility frequently experiences problems with opacity when it runs this material, which is about once every six months. Mr. Meadows stated that the facility experiences similar issues with smoke from the furnaces when they process plastic-containing parts from auto scrap, which he estimates are processed quarterly. When asked whether RSI uses a scale to weigh materials before they are added to the furnace, Mr. Meadow stated that there is a small scale used for weighing copper, but there is no scale for weighing metal or flux. Inspectors then observed the dross cooling areas. At the time, dross was stored at the south end of the facility, within a partially enclosed shed, and piled along the west side of the facility. Inspectors noted a strong ammonia smell emanating from the outdoor dross piles. Mr. Meadows Page 3 of6 explained this smell occurs when the dross reacts with rainwater, and it had rained the night before. Mr. Meadows showed inspectors an aluminum/sand separator system at the south end of the property. He stated that it was intended to separate sand from casting molds, but that it was not currently running. Ivfr. 1\/icadovv's indicated that there n1ay be a proble:m -with the baghouse intake ductVv'ork, and the inspectors followed him to the baghouse control room. Upon entry, inspectors observed a "NESHAP Alarm" flashing red on the control interface. During this alarm event inspectors recorded differential pressure at 3" water for baghouse I and 2.6" water for baghouse 2, and temperatures of 201 F for baghouse 1 and 257 F for baghouse 2. Three-hour temperature averages were I 30.9 F for baghouse I, and 133.8 F for baghouse 2, and the inlet temperature to the baghouse system was 134.4 F. Lime feed rate was 37 lbs/hour, and opacity was recorded as 14.3 and 18.5, respectively, as a 15-minute average. Mr. Meadows called Glenn Hoskins into the control room, and Mr. Hoskins explained that the lime feed rate listed on the control panel is divided between the two baghouscs because the lime goes through the spark arrester first. Mr. Hoskins also explained that there may be a problem with the damper position in the inlet. The Furnace A damper setting on the control interface shows 102% open, and the Furnace B damper setting shows 0%. However, when Mr. Hoskins clicked the unit on the PID, it showed that both dampers are open and drawing air from both Furnace hoods. As inspectors walked back through the furnace area to the office, inspectors asked whether RSI had any furnace labels. Mr. Meadows stated that they did not. Inspectors ended the tour at 11: 13 AM. Inspectors reviewed the most recent 2nd quarter 2018 preventative maintenance checklists for rotary furnaces and the baghouse. Photos and/or Videos: were taken during the inspection. Field Measnrements: were not taken during this inspection. RECORDS REVIEW During the opening conference, we reviewed preventative maintenance lists for the rotary furnaces and the furnace baghouse. CLOSING CONFERENCE We asked Mr. Meadows to define what conditions were used for the most recent stack test. He stated that when the test was run, only one furnace operated at a time, and only one damper was open at a time. We asked Mr. Meadows how RSI tracks metal input. He said that the throughput can be calculated based on material specifications, percent recovery associated with each material, and RSI' s output. Regarding the flux used per load, Mr. Meadows stated that the amount of flux used is based on the material processed. We reviewed photos and Mr. Meadows claimed the photos as Confidential Business Information. Page 4 of6 SIGNATURES Page 5 of6 Facility Name: Recycling Services ofindiana Facility Location: 4635 Peerless Road, Bedford, Indiana Date of Inspection: September 18, 2018 APPENDICES AND ATTACHMENTS I. Appendix A: Digital Media Log Pa"o'." ti of 6 Facility Name: Recycling Services of Indiana Facility Location: 4635 Peerless Road, Bedford, Indiana Date of Inspection: September 18, 2018 APPENDIX A: DIGITAL MEDIA LOG 1. Inspector Name: Sarah Clark 3. Company/Facility Name: Recvcling Services of Indiana 5. Number of Images: 23 2. Date of Inspection: September 18, 2018 4. Street Address, City, State: 4635 Peerless Road, Bedford, Indiana 6. Archival Record Location: CD-R labeled as "Recycling Services of Indiana, 4635 Peerless Rd, Bedford, IN, Inspection Photos 9-18-2018" Media No. 1 2 3 4 5 6 7 8 9 10 11 12 13 File Name P9180022.JPG P9180023.MOV P9180024.JPG P9180025.JPG P9180026.MOV P9180027.MOV P9180028.JPG P9l 80029.JPG P9180030.MOV P9180031.JPG P9180032.JPG P9180033.JPG P9180034.JPG Date and Time (EDT) 911812018 10:07 9/18/2018 10:07 9/18/2018 10:11 911812018 10:11 911812018 10:12 Latitude and Longitude 38.921389, -86.520833 NIA 38.921389, -86.520833 38.921389, -86.520833 NIA 9/1812018 10:13 NIA 911812018 10:13 911812018 10:13 38.921389, -86.520833 38.921389, -86.520833 9118/2018 10:14 NIA 9/1812018 10:15 9/1812018 10:15 9118/2018 10:15 38.921389, -86.520833 38.921389, -86.520833 38.921389, -86.520833 9118/2018 10:22 38.921389, -86.520833 Appendices Page 1 of 2 Description of Image Furnace B operating Furnace B operating Furnace B operating, door opemng Furnace B operating, door open Furnace B operating, door open Furnace B charging borings Furnace B charging borings Furnace B charging borings Furnace B charging borings Furnace B charging borings Furnace B charging borings Furnace B post charge Dross cooling area at south end of facility, view from the north Facility Name: Recycling Services of Indiana Facility Location: 4635 Peerless Road, Bedford, Indiana Date of Inspection: September 18, 2018 14 P9180035.JPG 9/1812018 10:23 38.921389, Furnace A and B ductwork -86.520833 15 P9180036.JPG 9/1812018 9:25* .38.920705, Furnace B operating, view -86.519008 from outside, east side 16 P9180037.JPG .. 91i&i1ois 9:26* 38;920715; Furnace B opernting, view -86.518998 from outside, east side 17 P9180038.MOV 9118/2018 9:27* NIA Furnace B operating, view from outside, east side 38.920145, Dross cooling area at south 18 P9180039.JPG 911812018 9:34* -86.519872 end of facility, view from the south 19 P9180040.JPG 9/1812018 9:34* 38.92013, Dross piles at west side of -86.51986 facility 20 P918004 l .JPG 9/1812018 9:37* 38.92014, -86.520132 Furnace baghouses 21 P9180042.JPG 9/1812018 9:37* 38.92014, -86.520132 Furnace baghouses 22 P9180043.JPG 911812018 10:06* 38.920278, Furnace A and B ductwork -86.520278 23 P9180044.MOV 911812018 10:06* NIA Furnace B operating *Camera Error: wrong time zone (CDT instead ofEDT) Appendices Page 2 of2