Document 6bp3YdyzanLeRYvQXJRJ0QmYR
DATE: SUBJECT: FROM: THRU: TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS
77 WEST JACKSON BOULEYARD CHICAGO, ILLINOIS 60604
JAN O3 2020
CLEAN AIR ACT INSPECTION REPORT GII, LLC. d/b/a General Iron Industries, Chicago, Illinois
Scott Connolly, Environmental Engineer AECAB (IL/IN)
Nathan Frank, Section Chief AECAB (IL/IN)
File
BASIC INFORMATION
Facility Name: GII, LLC. d/b/a General Iron Industries (General Iron)
Facility Location: 1909 North Clifton Ave, Chicago, Illinois 60614
Date of Inspection: November 13-15, 2019
EPA Inspectors: 1. Scott Connolly, Environmental Engineer 2. Karina Kuc, Environmental Scientist 3. Daniel Heins, Environmental Engineer
Other Attendees 1. Jim Kallas, Environmental Manager, General Iron 2. Adam Labkon, Vice President, General Iron 3. John Pinion, Principal Engineer, RK Associates, 4. Rich Sollars, Project Manager, Mostardi Platt 5. Josh Kukla, Engineer, Mostardi Platt 6. Adam, Chemical Engineer, Catalytic Products International
Contact Email Addresses: Jim Kallas, jim@general-iron.com John Pinion. jpinion@rka-inc.com
Purpose of Inspection: To observe performance testing of General Iron's new scrubber and regenerative thermal oxidizer that was installed as required by the August 22, 2019 Administrative Consent Order EPA-5-19-113(a)-IL-08.
Facility Type: Metal Shredding and Recycling Facility
Day 1: Wednesday, November 13. 2019 Arrival Time: 9:05 am Departure Time: Approximately 3:00 pm
Day 2: Thursday. November 14. 2019 Arrival Time: 9:20 am Departure Time: 4:40 pm
Day 3: Friday, November 15. 2019 Arrival Time: 10:00 am Departure Time: 2:15 pm
Inspection Type: D Unannounced Inspection [SJ Announced Inspection
Process Description: General Iron obtains and processes scrap metal received by truck from demolition companies, auto scrappers, peddlers and other recycling services. Generally, loads of scrap metal are unloaded from trucks into large piles, both at the shredder and at other locations onsite. The shredder processes mostly demolition waste and postconsumer scrap, with a smaller portion of auto bodies. Cranes load scrap metal onto a conveyor, which feeds metal into the hanunermill shredder. A water injection system sprays water into the shredder to reduce dust and cool the metal. A capture hood encloses most of the shredder and routes air emissions through a cyclone and roll-fabric filter for particulate matter control. Air is pulled from the fabric filter to a regenerative thermal oxidizer (RTO) and caustic scrubber to control volatile organic compounds (VOC) and combustion byproducts, before air is exhausted to the atmosphere. Shredded metal exits the shredder and is fed through a magnetic separator, which separates non-magnetics from ferrous metal. Additional non-ferrous is removed in a z-box cyclone and stored in piles before front loaders transport it to the non-metallic separation area. Non-ferrous metals are separated from non-metallics through a series of air separators. Some non-ferrous metals are separated and sold as a mixture and some are sold separately. Non-metallic fluff is sent by truck to a landfill. Ferrous metal is transported to steel mills by truck or barge.
Staff Interview: General Iron facility staff stated that shredder amps increase when the hanuners in the mill become worn down. Mr. Kallas stated that new hanuners were installed between days 2 and 3 to replace hanuners that were worn down during normal operations. Percent of the total feed containing autos will be calculated by measuring the total weight of cars stored during onside and calculating an average weight per car. During each test run, the number of cars will be
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counted and multiplied by the average weight of the cars to obtain the weight of cars shredded. General Iron does not operate the yard water sprayer for dust control during the winter, due to freezing conditions. Mr. Sollars ofMostardi Platt stated that the metal samples will be sent to Bureau Veritas, in Ontario for analysis. Prior to the first testing date Mostardi Platt measured the stack diameter used during testing to be 5.617 feet. Because testing was not completed during the dates of the inspection General Iron facility staff stated that testing would be completed on November 18, 2019.
TOUR INFORMATION
EPA toured the facility: Yes
Data Collected aud Observations: To calibrate the Method 25A total hydrocarbon analyzer, Mostardi Platt calibrated with propane using a mid-concentration span and a low concentration span. The mid concentration span included calibrations at 4500 ppm, 902.5 ppm, 604.3 ppm and 301.2 ppm. The low concentration span included calibration gases at 10.07 ppm, 20.59 ppm and 30.03 ppm.
Day 1: On Day 1, Mostardi Platt planned to conduct particulate matter, VOC and visible emissions testing using EPA Methods 5, 202, 25A and 9. The start of Run #1 was delayed because of extended step up operations and the Method 202 impinger train solutions were freezing. During the testing on Day 1, the RTO consistently entered fault conditions and automatically shut down. Pressure drop monitors at the inlet to the RTO triggered the shut downs of the RTO when positive pressure was recorded. Multiple shutdowns of the shredder and RTO resulted in extended downtime during planned Run #1. Prior to its completion Run #1 was cancelled because it was not possible to keep the impinger train solutions in liquid and the probe for carbon monoxide monitoring froze, resulting in inaccurate readings.
Day 2: On Day 2, Mostardi Platt conducted metals and acid gases testing using EPA Methods 29 and 26. Prior to testing, Catalytic Products International (CPI) staff replaced differential pressure probes in the RTO to correct erroneous readings that occurred during Day 1. Three 96-minute test runs were conducted, using 2 separate impinger trains that were cleaned and swapped between test runs. The sample train utilized a flexible tube to connect the sample rode to the impinger train. EPA personnel observed steam exiting the top and side of the shredder enclosure downstream of the hammerrnill, near the exit conveyor. EPA personnel intermittently observed particulate matter smoke and a burning smell past the point where steam dissipated, downwind of the shredder, during Runs #1 and #2.
Run#l Start: 8:45 am End 10:43 am (Run paused from 9:00-9:04 am) Production Rate: 370 tons per hour and 31 % cars
Run#2
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Start: 12:00 pm End: 2:11 pm Production Rate: 408 tons per hour and 34% cars
Run#3 Start: 3:30 pm End: 5:37 pm Production Rate: 378 tons per hour and 29% cars
D~
On Day 3, Mostardi Platt conducted one run of particulate matter, VOC and visible emissions testing using EPA Methods 5, 9, 202 and 25A. Multiple pauses in the test run were caused by shutdowns of the RTO. CPI and facility staff stated that "process push" causes the RTO booster fan to spin faster than the allowable rotation rate, which causes fault conditions and an RTO shutdown. Visible emissions and strong odors were observed exhausting from the RTO make up air vent/bypass every time the RTO shut down. Visible emissions events were observed occuring between 1 and 4 minutes during each RTO fault.
Run#l Start: 10:33 am End: 1:18 pm (Run paused from 11:03 am to 11:17 am, 11:23 am to 12:36 pm, 12:51 pm to 1:15 pm) Production Rate: 366 tons per hour and 67% cars
Photos and/or Videos: were taken during the inspection. A photo and video log is contained in Appendix A.
Field Measurements: were taken during this inspection. Field Measurements were taken by Mostardi Platt stack testers during required on-site emissions testing. o EPA Method 1 - Sample and Velocity Traverses o EPA Method 2 - Velocity Measurement with S-type Pitot o EPA Method 3 - Determination of Molecular Weight o EPA Method 4 - Determination of Moisture Content o EPA Method 5 - Particulate Matter Measurement o EPA Method 9 - Visible Emission Observations o EPA Method 25A - Gaseous Organic Concentration by Flame Ionization o EPA Method 26 - Hydrogen Chloride, Halides, Halogens o EPA Method 29 - Metals Emissions from Stationary Sources o EPA Method 202 - Condensable Particulate Matter
RECORDS REVIEW
1. Production data, including scrap shredding rate and feed percent autos was reviewed at the end of each test run.
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CLOSING CONFERENCE
Requested documents: Finalized test report containing all test run data, including calculations and data sheets.
Compliance Assistance: I recommended that the square RTO bypass duct be rotated so that it does not vent directly onto the truck scale. Concerns: Visible emissions were observed venting out of the RTO bypass duct when RTO faults occurred. Visible emissions from the shredder building were also observed on Day 2.
SIGNATURES
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Facility Name: Gil, LLC. d/bla General Iron Industries Facility Location: 1909 North Clifton Ave, Chicago, Illinois Date oflnspection: November 13-15, 2019
APPENDICES AND A TIACHMENTS
Appendix A: Digital Image Log
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Facility Name: Gil, LLC. d/b/a General Iron Industries Facility Location: 1909 North Clifton Ave, Chicago, Illinois Date oflnspection: November 13-15, 2019
APPENDIX A: DIGITAL IMAGE LOG
1. Photographer Name: Scott Connollv
3. Company/Facility Name: Gil, LLC. d/b/a General Iron Industries
5. Number oflmages: 56
2. Dates ofinspection: November 13-15, 2019
4. Street Address, City, State: 1909 North Clifton Ave, Chicago, Illinois
6. Archival Record Location: Photos are contained on the attached CD labelled "General Iron Inspection Photos 11/15/19"
Image Number 1 2 3 4 5 6 7
File Name
PB 13000 l.JPG PB 130002.JPG PB130003.JPG PB130004.JPG PB 130005.JPG PB130006.JPG PB 130007.JPG
8
PB130008.JPG
9
PB130009.JPG
10
PB130010.JPG
11
PB130011.JPG
12
PB130012.JPG
13
PB130013.JPG
14
PB130014.JPG
15
PB130015.JPG
16
PB130016.JPG
17
PB130017.JPG
18
PB130018.JPG
19
PB130019.JPG
20
PB130020.JPG
21
PB 130021.JPG
22
PB 140022.JPG
23
PB140023.JPG
Date and Time
Description of Image
11/13/2019 8:43 11/13/2019 8:43 11/13/2019 8:44 11/13/2019 8:46 11/13/2019 8:47 11/13/2019 8:47 11/13/2019 8:51
11/13/2019 8:54 11/13/2019 8:54 11/13/2019 8:54 11/13/2019 8:54 11/13/2019 9:27 11/13/2019 9:27 11/13/2019 9:28 11/13/2019 9:30
11/13/2019 9:40 il/13/201910:11
11/13/2019 12:56
11/13/2019 12:56
11/13/2019 13:34 I 1/13/2019 13:34 11/14/2019 10:32
11/14/2019 10:32
RTO Control Box Front Panel RTO Control Panel Temperature readout Shredder Scrubber caustic totes Shredder scrubber recirculation water piping Shredder scrubber recirculation water piping Shredder scrubber recirculation water piping RTO system overview and RTO control panel during testing. RTO and testing contractor location RTO combustion chamber overview Ducting to RTO and make up air intake and bypass Car pile next to shredder at the start of testing. Stack testing equipment next to scrubber Caustic Scrubber vessel and stack Filter building and connecting ducting from shredder Pressure reading set up used by testing contractors during testing Stack sampling location Shredder building, including location where duct oreviously exhausted into the building. Shredded material exit conveyor and roll magnet near new rubber sheeting on shredder building Shredded material exit conveyor and roll magnet near new rubber sheeting on shredder building Impinger weight sheet prior to test runs. Method 202 impinger sample train Emissions exiting the top and side of the shredder building Emissions exiting the top and side of the shredder building after drifting over duct work
Appendices Page 1 of3
Facility Name: Gil, LLC. d/b/a General Iron Industries Facility Location: 1909 North Clifton Ave, Chicago, Illinois Date oflnspection: November 13-15, 2019
24
PBl40024.JPG 11/14/2019 10:32 Emissions exiting the top and side of the shredder
building
25
PB 140025.JPG 11/14/2019 10:33 Emissions exiting the top and side of the shredder
building
26
PB 140026.JPG 11/14/2019 10:33 Emissions exiting the top and side of the shredder
building
27
PB 140027.JPG 11/14/2019 10:36 Open door on UMO to clear an equipment jam
28
PB140028.JPG 11/14/2019 10:39 Stack testing location and stack plume
29
PB 140029.JPG 11/14/2019 11 :38 Emissions exiting the top and side of the shredder
buildim,
30
PB 140030.JPG 11/14/2019 11:38 Emissions exiting the top and side of the shredder
building
31
PB140031.JPG 11/14/2019 11:44 Emissions exiting the top and side of the shredder
building
32
PBI40032.JPG 11/14/2019 12:39 Fabric filter "clean" side
; 33
PBI40033.JPG I 1/14/2019 12:39 Fabric filter "dirty" side
34
PB 140034.JPG 11/14/2019 12:39 Fabric filter overview
35
PB140035.JPG 11/14/2019 14:49 Yard overview and steam exiting top of shredder building
as seen from outside the vard.
36
PB140036.JPG 11/14/2019 14:49 Shredder system overview and steam exiting the top of
the shredder building as seen from outside the yard
37
PB140037.JPG 11 /] 4/2019 14:50 Shredder system overview and steam exiting the top of
the shredder building as seen from outside the vard
38
PB140038.JPG 11/14/2019 15:30 Scrubber control panel and process overview
39
PB140039.JPG 11/14/2019 15:40 Sample probes before metals testing run #3
40
PB J40040.JPG 11/14/2019 15:45 Sample train and purge gas tanks between metals testing
runs #2 and #3
41
PB15004J.JPG 11/15/20I 9 12:20 Day 3 RTO readout panel after pressure gauge was
changed
42
PB150042.JPG 11/15/2019 12:31 Inlet stack sample location for VOC testing
43
PBI50043.JPG 11/15/2019 12:31 Car pile during pause in Run # 1 VOC testing
44
PBI50044.JPG 11/15/2019 12:31 Shred pile during pause in Run #1 testing
45
PB150045.JPG 11/15/2019 13:01 Visible emissions exiting RTO bypass vent
46
PB150046.JPG 11/15/2019 13:01 Car pile during a pause in Run # I voe testing
47
PBI50047.JPG I 1/15/2019 13:18 Visible emissions exiting RTO bypass vent
48
PB150048.JPG 11/15/2019 13:18 Visible emissions exiting RTO bypass vent
49
PB150049.JPG 11/15/2019 13:18 Visible emissions exiting RTO bypass vent
50
PB150050.JPG 11/15/2019 13:18 Visible emissions exiting RTO bypass vent
51
PB 150051.JPG 11/15/201913:18 Visible emissions exiting RTO bypass vent
52
PB150052.JPG I 1/15/2019 13:19 Visible emissions exiting RTO bypass vent
53
PB150053.JPG 11/15/2019 13:19 Visible emissions exiting RTO bypass vent
54
PB150054.JPG 11/15/2019 13:20 Visible emissions exiting RTO bypass vent
Appendices Page 2 of3
Facility Name: GI!, LLC. d/b/a General Iron Industries Facility Location: 1909 North Clifton Ave, Chicago, Illinois Date oflnspection: November 13-15, 2019
55
PB150055.JPG 11/15/2019 13:53 VOC data logger right at time ofRTO failure,
hydrocarbon concentration was at 2500 ppm immediately
before ohoto was taken
56
PB 150056.JPG 11/15/201914:24 Steam off the roll magnets and emissions from the
shredder building after VOC testing Run #1
Appendices Page 3 of 3