Document 71ZNQkOLKxOYZVBgbLL755kmB

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT EMR Northern Metal Recycling - Scrappy's Express, Minneapolis, Minnesota FROM: David Sutlin, Environmental Engineer AECAB (MN/OH) THRU: Brian Dickens, Section Supervisor AECAB (MN/OH) TO: File BASIC INFORMATION Facility Name: EMR Northern Metal Recycling - Scrappy's Express Facility Location: 1803 N 2nd Street, Minneapolis, Minnesota 55411 Date of Inspection: May 6, 2025 EPA Inspector(s): 1. David Sutlin, Environmental Engineer 2. Emma Leeds, Environmental Engineer Other Attendees: 1. Duane Pomerleau, Supervisor, EMR Minneapolis - Scrappy's Express 2. Brad Bryniarski, Lead, EMR Minneapolis - Scrappy's Express 3. Margaret Mosbeck-Morrison, Environmental Specialist, MPCA Contact Email Address: duane.pomerleau@emrgroup.com Purpose of Inspection: To investigate compliance with requirements for the protection of stratospheric ozone Facility Type: Scrapyard Facility Name: EMR Northern Metal Recycling - Scrappy's Express Facility Location: 1803 N 2nd Street, Minneapolis, MN Date of Inspection: May 6, 2025 Regulations Central to Inspection: 40 C.F.R. 82.155 - Safe disposal of appliances, including the requirement to properly recover refrigerants or verify the proper recovery of refrigerants. Arrival Time: 10:15 AM Departure Time: 12:00 PM Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Not a Small Business Provided CBI warning to facility Was any information collected during the inspection claimed as CBI? Yes No. The following information was obtained verbally from Duane Pomerleau or Brad Bryniarski, unless otherwise noted. Process Description: EMR Northern Metal Recycling - Scrappy's Express (Scrappy's) receives ferrous and non-ferrous metal scrap for recycling from the general public and industrial suppliers. The facility accepts small appliances as well as refrigeration components. The scrap is received in trucks that are weighed at the scale house and then unload. Ferrous scrap from the general public is unloaded into one pile and scrap from industrial suppliers is unloaded into a separate pile in the yard. This scrap is checked for non-acceptable material by facility personnel as the scrap is being unloaded to each pile. Non-ferrous scrap is unloaded to a separate building. At the scale house, members of the public that supply appliances are routinely asked to fill out and sign a statement to certify that all the refrigerant from the appliance leaked out prior to delivery (Leaked Out Statement). Staff Interview: The commercial suppliers that deliver to this facility generally do not include suppliers of scrap appliances. The facility is no longer set up to recover refrigerant from appliances although they do maintain their evacuation license in case they decide to resume recovery in the future. Duane Pomerleau could not recall receiving any intact appliances during his tenure at the facility. It is the facility's policy to not accept any appliances that still contain intact compressors. Suppliers routinely remove compressors from appliances and deliver the compressors at the Page 2 of 5 Facility Name: EMR Northern Metal Recycling - Scrappy's Express Facility Location: 1803 N 2nd Street, Minneapolis, MN Date of Inspection: May 6, 2025 non-ferrous building prior to unloading the appliance to the pile in the yard. Compressors command a higher price than the remaining appliance, pound for pound. Any receipt of appliances by the facility is recorded on a ticket (Yard Ticket). At the scale house, personnel showed us the Leaked Out Statement that they regularly give out to suppliers of appliances to fill out and sign. The staff person, Heather, indicated that just one form is filled out per supplier per day, regardless of the number of deliveries with appliances on a given day for a given supplier. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: EPA observed the unloading of ferrous scrap by a member of the general public from their truck, including at least one refrigerator. EPA requested help from Scrappy's to inspect the refrigerator before it was placed in the scrap pile, but they stated they could not tell their customers to stop unloading or to set the refrigerator aside. At the scale house, EPA observed a Leaked Out Statement form being given to a supplier to fill out, with no further explanation given to the supplier. Photos and/or Videos: were taken during the inspection and are listed in Appendix A. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Past 30 days of Yard Tickets that include delivery of any appliances along with any corresponding Leaked Out Statements. Concerns: EPA expressed concern at the number of Leaked Out Statements the facility accepts, and that it is not credible to have so many cases where the refrigerant escaped as a result of some unavoidable occurrence. DIGITAL SIGNATURES DAVID Digitally signed by DAVID SUTLIN SUTLIN Date: 2025.06.27 11:15:15 -05'00' Report Author: _________________________________ Section Supervisor: BRIAN Digitally signed by BRIAN DICKENS _D_I_C_K__E_N__S_____11_:2_6:3_7_-0_5'_00_' _____________ Date: 2025.06.27 Page 3 of 5 Facility Name: EMR Northern Metal Recycling - Scrappy's Express Facility Location: 1803 N 2nd Street, Minneapolis, MN Date of Inspection: May 6, 2025 APPENDICES Appendix A: Digital Image Log and Digital Video Log Page 4 of 5 Facility Name: EMR Northern Metal Recycling - Scrappy's Express Facility Location: 1803 N 2nd Street, Minneapolis, MN Date of Inspection: May 6, 2025 APPENDIX A: DIGITAL IMAGE LOG AND DIGITAL VIDEO LOG Inspector Name: David Sutlin Archival Record Location: ERC:\Enf_EMR NMR Scrappy's_MN_25\Enf_ EMR NMR Scrappy's _MN_25_Inspection\Photos\ Image Number File Name 1 IMG_0731.JPG 2 IMG_0732.JPG 3 IMG_0733.JPG 4 IMG_0734.JPG Date and Time (incl. Time zone and DST) 5/6/2025 10:34 5/6/2025 10:36 5/6/2025 10:41 5/6/2025 10:41 Description of Image Container of isolated refrigerator compressors in non-ferrous building Containers of isolated refrigerator compressors in non-ferrous building Container of copper lines in non-ferrous building Container of copper lines/parts in non-ferrous building Page 5 of 5