Document 6jbgQ9Z2xK5Q3gvvJ9n98rJm

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET S.W ATLANTA, GEORGIA 30303-8960 SENT VIA ELECTRONIC MAIL Mr. Alan Gillespie Regional Environmental Manager Commercial Metals Company 16770 Rebar Road Baldwin, Florida 32234 James.gillespie@cmc.com Dear Mr. Gillespie: Enclosed is a copy of the final report generated by the U.S. Environmental Protection Agency's Region 4, South Air Enforcement Section, for the inspection conducted at the Commercial Metals Company (CMC Recycling) facility, located in Baldwin, Florida, on July 21, 2021. If you have any questions, you can contact me at (404) 562-9134, or by email at taylor.kevin@epa.gov. Enclosure Sincerely, KEVIN TAYLOR Date: 2021.10.13 14:23:51 -04'00' Digitally signed by KEVIN TAYLOR Kevin Taylor Environmental Engineer South Air Enforcement Section ENCLOSURE FINAL INSPECTION REPORT United States Environmental Protection Agency (EPA) Region 4 Air Enforcement Branch Draft Inspection Report I. GENERAL INFORMATION Facility Name: CMC Steel US, LLC Location (Address): 16770 Rebar Road, Baldwin, Florida 32234 Inspection Date: July 21, 2021 Type of Inspection (Full or Partial Compliance Evaluation): Partial Compliance Evaluation ICIS-Air Number: FL0000001203100157 EPA Region 4 Investigator(s)/Inspector(s): 1. Kevin Taylor, Environmental Engineer 2. Sydnee Adams, Environmental Engineer 3. Bethany Terpin, Environmental Scientist State/Local Investigator(s)/Inspector(s): 1. Stuart Bartlett, Environmental Consultant, Florida Department of Environmental Protection Person(s) Contacted at Facility (Name and Title): 1. Alan Gillespie, Regional Environmental Manager 2. Brad Bredeson, Director of Environment 3. Peter Pozzo, Area Environmental Manager 4. Abe Boackle, Area Operations Manager 5. Doug Caswell, Plant Manager 6. Kyle Barone, Environmental Specialist 7. Anthony Cinelli, Environmental Manager Report Prepared by: Kevin Taylor Project Name: CMC Steel US, LLC ICIS/Project No.: FL0000001203100157 -2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 1 of 14 II. FACILITY INFORMATION A. Facility and Permit Information Facility and Permit Information Comments 1. Type of facility (e.g., chemical plant, refinery, cement manufacturer, etc.). 2. Air permit number(s) and type of permit (e.g., Title V, PSD, Synthetic Minor, etc.). 3. Air permit issuance date. Recyclable Material Merchant Wholesalers; Automobile and Scrap Metal Shredding Title V permit # 0310157-016-AV 02/11/2020 4. Air permit expiration date. 04/02/2024 5. Facility classification (Major, Synthetic Minor/Conditional Major, Minor). 6. Major source pollutants (if applicable). 7. Applicable regulations (e.g., State Implementation Plan, MACT Subpart FFFF, NSPS Subpart EEEE, etc.). 8. Types of air emission points (e.g., tanks, process vents, boilers, etc.). 9. Types of air pollution control equipment (e.g., baghouse, scrubber, afterburner, etc.). Major Source N/A State Implementation Plan 40 CFR Part 82 Metal Shredder Hammer Mill Water spraying at the hammer mill is used for fire prevention, but also reduces particulate matter. B. Process Description Commercial Metals Company (CMC), Inc. owns and operates a scrap metal recycling facility in Baldwin, Florida. The facility purchases scrap metal materials, including automobiles and white goods, from contracted industrial dealers. After purchase, metal scrap is sorted and prepared for recycling at the facility to be sent to the facility's metal shredder operation. The facility operates a 6,000 horsepower Shredder Company metal Project Name: CMC Steel US, LLC ICIS/Project No.: FL0000001203100157 -2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 2 of 14 shredder that contains a rotor that is 98" wide and about 104-108" tall. The metal shredder has a maximum processing rate of approximately 200 tons of scrap per hour. However, it has been proposed in a draft FDEP permit to limit the metal shredder production rate to 168 tons of scrap per hour.1 The metal shredder is equipped with a water spraying system to minimize heat and prevent fires. Scrap that has been shredded through the metal shredder is separated by downstream processing into ferrous, nonferrous, and automotive shredder residue (ASR). After the metal scrap has been processed it is recycled at the adjacent steel mill. III. INSPECTION ACTIVITIES Activity Opening Meeting 1. Date and time entered the facility. 2. Credentials presented to facility personnel (include name and title). Yes No NA Y Y Comments EPA Region 4 (R4) inspectors arrived at the facility on July 21, 2021 at 1:45 PM EDT. All inspectors presented their credentials to Alan Gillespie, Regional Environmental Manager. 3. Conducted an opening meeting Y to explain the purpose and objectives of the inspection. 4. Discussed safety issues. Y Inspectors held an opening meeting during which the purpose and objectives of the inspection were explained. Inspectors discussed facility-specific safety and emergency procedures, including procedures for COVID-19 safety during the inspection. 1 Following the inspection, on October 6, 2021, the FDEP issued as final a Title V Air Operation Permit No. 0310157-018-AV, on September 21, 2021. The final permit authorizes operation of the Scrap Metal and Automobile Shredder, Emissions Unit 018, at the Baldwin facility. Specific Condition F.1. of the final Title V defines the permitted capacity as a maximum process rate of the shredder not to exceed 168 tons per hour. Project Name: CMC Steel US, LLC ICIS/Project No.: FL0000001203100157 -2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 3 of 14 Activity 5. Discussed which records to be reviewed. Yes No NA Y 6. Discussed the facility walk- Y through and the areas to be observed in the facility. 7. Discussed facility policy Y regarding photographs or video (if applicable). 8. Discussed the use of the Y infrared camera, TVA, PID, and any other equipment. 9. Discussed CBI. Y Project Name: CMC Steel US, LLC ICIS/Project No.: FL0000001203100157 -2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 4 of 14 Comments Review of facility records was discussed. Due to the EPA Covid 19 protocol, the EPA Region 4 inspectors did not review records at the facility at the time of the inspection. However, the facility personnel volunteered to send, via email, the following additional information: Commercial Supplier Contracts Production data from 2018 to the present, including input and output rates and types of scrap processed. Maximum throughput of tons of scrap shredded per month ASR test results Explosion logs with associated source control letter. Inspectors were primarily interested in observing the metal shredder operation and scrap inspection procedures. Region 4 inspectors discussed facility policy regarding photography and videography. EPA inspectors brought a digital camera to take pictures of the facility and invited facility staff to duplicate pictures during the walk-through. Inspectors indicated that copies of any videos or photographs taken at the facility would be sent to the company. Region 4 inspectors communicated the use of the digital camera. EPA inspectors indicated that any material claimed to be Confidential Business Information (CBI) would be treated in accordance with regulations. Activity Records Reviewed at the Facility 10. The types of records reviewed, and the time period reviewed. Yes No NA Y Facility Walk-Through Observations Comments The following records were requested to be sent to R4 inspectors via email: Commercial Supplier Contracts Production data from 2018 to the present, including input and output rates and types of scrap processed. Maximum throughput of tons of scrap shredded per month ASR test results Explosion logs with associated source control letter. R4 Inspectors ask for these records from 2018 to the present. Project Name: CMC Steel US, LLC ICIS/Project No.: FL0000001203100157 -2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 5 of 14 11. The process equipment Y observed and the associated operational rate observed (e.g., Furnace 1 production rate was 5 lbs/hr on 1/1/15, at 2:00 pm - permit requires max rate at 6 lbs/hr). Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. Project Name: CMC Steel US, LLC ICIS/Project No.: FL0000001203100157 -2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 6 of 14 EPA Region 4 inspectors conducted an inspection of process areas, including the metal shredder operations, scrap inspection process, and scrap intake area. CMC purchases scrap from suppliers and requires the suppliers of scrap that might contain regulated refrigerants to execute an agreement to remove refrigerants from the scrap prior to delivery. Once scrap is received at the facility it is inspected by a dedicated scrap inspector prior to recycling. Scrap inspectors visually inspect the load of scrap for possible quality downgrades and to ensure that prohibited and/or objectionable items are not present. There may be acceptable materials requiring an extra step to size the material appropriately for the shredder. The facility operates a 6,000 horsepower Shredder Company metal shredder that contains a rotor that is 98" wide and about 104-108" tall. The metal shredder has a maximum processing rate of approximately 200 tons of scrap per hour. However, it has been proposed in a draft FDEP permit to limit the metal shredder production rate to 168 tons of scrap per hour.2 The metal shredder is equipped with a water spraying system to minimize heat and prevent fires. Scrap that has been shredded through the metal shredder is separated by downstream processing into ferrous materials, nonferrous materials, and automotive shredder residue (ASR). For a typical month the average purchase volume is between 14,000 to 18,000 tons per month, with product produced of 11,000 to 14,000 tons. Activity 12. The type of process parametric monitoring observed and the associated value observed (e.g., Furnace 1 flux injection rate was 200 lbs/batch at 1/1/15, at 2:00 pm - permit requires max rate at 225 lbs/batch). Yes No NA N/A Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. 13. If process equipment or N/A parametric monitoring equipment was not operating, state the reason by facility personnel why the equipment was not operating. Comments 2 Following the inspection, on October 6, 2021, the FDEP issued as final a Title V Air Operation Permit No. 0310157-018-AV, on September 21, 2021. The final permit authorizes operation of the Scrap Metal and Automobile Shredder, Emissions Unit 018, at the Baldwin facility. Specific Condition F.1. of the final Title V defines the permitted capacity as a maximum process rate of the shredder not to exceed 168 tons per hour. Project Name: CMC Steel US, LLC ICIS/Project No.: FL0000001203100157 -2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 7 of 14 Activity 14. The type of air pollution control equipment, the process equipment it is controlling, and the associated parametric monitoring value observed (e.g., baghouse pressure drop, temperature, scrubber flow rate, etc.). Yes No NA Y (For example - RTO 1 controlling furnace 1, 1,500 degrees F on 1/1/15, at 2:00 pm - permit requires 1,400 degree F or higher). Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. Comments The facility operates a water spraying system at the shredder. The primary function is heat reduction, but it is also used to reduce particulate matter emissions. Water is released at a variable rate, depending on the motor speed of the hammer mill. Project Name: CMC Steel US, LLC ICIS/Project No.: FL0000001203100157 -2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 8 of 14 Activity 15. Continuous emissions monitoring devices and values observed. (e.g., CEMS, COMs, etc.). Yes No NA N/A Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. 16. If air pollution control N/A equipment was not operating, state the reason by facility personnel why the equipment was not operating. 17. Capture and collection system N/A (enclosures and hoods) observations, if applicable (e.g., the magnitude and duration of emission escaping capture from the hood). Comments Project Name: CMC Steel US, LLC ICIS/Project No.: FL0000001203100157 -2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 9 of 14 Activity 18. Ductwork transferring the emissions to the air pollution control device observations, if applicable (e.g., the magnitude and duration of emission escaping from the ductwork, holes or deterioration in ductwork, no deterioration observed, etc.). Yes No NA N/A Comments 19. Any existing unpermitted Y emission points, new unpermitted emission points, or non-permitted construction activities observed. (if yes, describe in the comments field). 20. Were any visible emissions N observed? (if yes, identify the location and equipment). The facility's current permit does not specifically address VOC emissions from the metal shredder. However, following the inspection CMC clarified that the current permit is based upon estimated emissions from the shredder as estimated and understood at the time the permit was issued. At that time, the shredder met the qualifications of an insignificant emissions unit or pollutant-emitting activity per Rule 62-213.430(6), F.A.C., and FDEP permitted the shredder as an Insignificant Activity in Appendix I of Title V Air Operation Permit No. 0310157-016-AV. More recently, FDEP has authorized continued operation of the Shredder (as Emissions Unit 018), based on the current emission factors used for potential VOC emissions, per final Title V Air Operation Permit No. 0310157-018AV, issued on September 21, 2021. Project Name: CMC Steel US, LLC ICIS/Project No.: FL0000001203100157 -2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 10 of 14 Activity 21. Was a Method 9 reading performed? (if yes, identify the location and equipment). Yes No NA N Comments 22. Was the cause of the visible N/A emissions investigated and the information documented? 23. Was a Method 22 performed N for visible emissions? (if yes, identify the location and equipment). 24. Identify the cause of the visible N/A emissions as explained by facility personnel, if applicable. 25. Was the infrared camera used? N If so, attach the video log (which includes the equipment ID, and the date and time the video was recorded) and videos to this report. EPA R4 inspectors did not use an infrared camera at the facility but did use a digital camera to capture photographs of the facility. See Appendix A for the Photograph Log. Project Name: CMC Steel US, LLC ICIS/Project No.: FL0000001203100157 -2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 11 of 14 Activity 26. Was the TVA used? If so, identify the equipment monitored and the results. Yes No NA N Provide the date and time the information was recorded by the inspector. Include actual instrument readings for each piece of equipment monitored above the leak definition and/or where the infrared camera identified a release. An attachment may be used for a large amount of information. 27. Was the PID used? If so, N identify how the PID was used and the results. Provide the date and time the information was recorded by the inspector. An attachment may be used for a large amount of information. Closing Meeting 28. Conducted a closing meeting. Y Comments EPA R4 inspectors did not use a TVA at the facility. EPA R4 inspectors did not use a PID at the facility. EPA Region 4 inspectors conducted a closing meeting on July 21, 2021 at 2:45 PM EDT with CMC employees and the Florida Department of Environmental Protection inspector. Project Name: CMC Steel US, LLC ICIS/Project No.: FL0000001203100157 -2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 12 of 14 Activity 29. Summarize any additional information needed, if applicable? Yes No NA Y 30. Accept a declaration of CBI, if N/A applicable? 31. Discussed observations. Y 32. Discussed next steps, if Y applicable? 33. Date and time inspection concluded. Miscellaneous 34. Include any additional N/A observations, if applicable. Comments Due to the EPA Covid 19 protocol, the EPA Region 4 inspectors did not review records at the facility at the time of the inspection. However, the facility personnel volunteered to send, via email, the following additional information: - Commercial Supplier Contracts - Production data from 2018 to the present, including input and output rates and types of scrap processed. - Maximum throughput of tons of scrap shredded per month. - ASR test results - Explosion logs with associated source control letter. Inspectors thanked facility personnel for their time and summarized inspection activities. The company was informed of the EPA's potential concern for metal shredder VOC emissions. These potential concerns are being researched and analyzed nationwide using emission testing to determine if the current emission factors are reasonable or if they should be modified. A final inspection report from EPA Region 4 will be sent to the company within a 60day timeframe. Document requests were discussed. The inspection concluded on July 21, 2021 at approximately 3:20 PM EDT. Project Name: CMC Steel US, LLC ICIS/Project No.: FL0000001203100157 -2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 13 of 14 Digitally signed by KEVIN TAYLOR EPA Investigator/Inspector Signature:___K_E_V_I_N__T_A_Y_L_O_R___D_ate_: 2_02_1.1_0.1_3 1_4:_24:_57_-04_'0_0' ______ EPA Supervisor Signature & Title ____T_O__D_D____________G_R_O_EN_D_YK_E_________ Digitally signed by TODD GROENDYKE Date: 2021.10.13 14:37:19 -04'00' ___________________________________ Date Report Finalized:___________________________________ Project Name: CMC Steel US, LLC ICIS/Project No.: FL0000001203100157 -2021 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 14 of 14 Appendix A: Inspection Video and Photograph log Table 1: Photographs taken during the July 21, 2021, inspection. Image Number 1 2 3 4 5 6 7 File Name P1010417.JPG P1010418.JPG P1010419.JPG P1010420.JPG P1010421.JPG P1010422.JPG P1010423.JPG Date and Time (incl. time zone and DST) 7/21/2021 14:12 (EDT) 7/21/2021 14:12 (EDT) 7/21/2021 14:17 (EDT) 7/21/2021 14:24 (EDT) 7/21/2021 14:30 (EDT) 7/21/2021 14:30 (EDT) 7/21/2021 14:35 (EDT) Description of Image Signs at Scale for Acceptable Scrap Signs at Scale for Acceptable Scrap Sizing Operation Shredder Separation Operation Separation Operation Steel Shred