Document 71rm9yNvrDzjgpQknLvd5NDZa

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Wallach Iron & Metal, Inc., St. Louis, Missouri Natalie Topinka, Environmental Scientist AECAB (IL/IN) Nathan Frank, Section Supervisor AECAB (IL/IN) File BASIC INFORMATION Facility Name: Wallach Iron & Metal, Inc. Facility Location: 6670 Dr. Martin Luther King Drive, St. Louis, Missouri Date of Inspection: September 21, 2023 EPA Inspector(s): 1. Natalie Topinka, Environmental Scientist 2. Karina Kuc, Environmental Scientist 3. Tess Russell, Environmental Engineer Other Attendees: 1. Preston Wilmoth, Manager 2. Robert Wallach, Manager Contact Email Address: robert@wallachironandmetal.com Purpose of Inspection: assess compliance with refrigerant safe disposal regulations Facility Type: scrap metal recycler Regulations Central to Inspection: 40 C.F.R. Part 82 Arrival Time: 11:55 am Departure Time: 12:30 pm Facility Name: Wallach Iron & Metal, Inc. Facility Location: 6670 Dr. Martin Luther King Drive, St. Louis, MO Date of Inspection: September 21, 2023 Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE report Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet - sent via email with inspection Provided CBI warning to facility The following information was obtained verbally from Preston Wilmoth and Robert Wallach unless otherwise noted. Process Description: Wallach Iron & Metal, Inc. (Wallach) has been operating at its current location since 1981 and accepts ferrous and non-ferrous scrap metal for recycling. Its suppliers are commercial accounts, such as other scrap recyclers, manufacturers, and demolition contractors; Wallach does not accept material directly from the general public. Wallach does not accept vehicles for recycling but does accept small appliances. Staff Interview: Mr. Preston and Mr. Wallach explained that the facility does not accept intact small appliances; they are only purchased if they have already been processed (i.e. the refrigerant has been recovered). For its approximately 30 commercial suppliers that may include small appliances in materials delivered for recycling, Wallach requires a signed contract that states the supplier will recover any remaining refrigerant from the appliances or verify that the refrigerant had been properly recovered prior to receipt by the supplier. Facility representatives stated that they have not had historical problems with contracted commercial suppliers dropping off materials that were unacceptable. Mr. Preston stated that several years back, he had attended a half-day presentation by the industry trade group regarding proper handling of refrigerantcontaining appliances and EPA requirements. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: We reviewed Wallach's binder of signed contracts, titled "Appliance/Refrigerant/RTU Recycling guidelines." We toured the scrapyard and observed a window air conditioner marked with an "E" in the ferrous pile. We were not able to inspect the item closely due to its location in the scrap pile. The facility has a small shredder on-site. Facility Name: Wallach Iron & Metal, Inc. Facility Location: 6670 Dr. Martin Luther King Drive, St. Louis, MO Date of Inspection: September 21, 2023 Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Appliance/Refrigerant/RTU Recycling guidelines CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility DIGITAL SIGNATURES T NATALIE Digitally signed by NATALIE TOPINKA TOPINKA Date: 2023.09.26 15:01:24 -05'00' Report Author: _________________________________ Section Supervisor: NATHAN Digitally signed by NATHAN FRANK _F_R__A_N_K_______1_6_:28_:2_3_-0_5'0_0_' _____________ Date: 2023.09.28 Facility Name: Wallach Iron & Metal, Inc. Facility Location: 6670 Dr. Martin Luther King Drive, St. Louis, MO Date of Inspection: September 21, 2023 APPENDICES AND ATTACHMENTS 1. Digital Image Log Facility Name: Wallach Iron & Metal, Inc. Facility Location: 6670 Dr. Martin Luther King Drive, St. Louis, MO Date of Inspection: September 21, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Karina Kuc 2. Archival Record Location: https://usepa.sharepoint.com/sites/R5_Work/r 5erc/ecad/AECAB%20Library/Forms/AllItem s.aspx?id=%2Fsites%2FR5%5FWork%2Fr5e rc%2Fecad%2FAECAB%20Library%2FEnf %5FWallach%20Iron%20%26%20Metal%5 FMO%5F23%2FEnf%5FWallach%20Iron% 20%26%20Metal%5FMO%5F23%5FInspecti on%2FWallach%20inspection%20photos&vi ewid=5f882290%2D049a%2D44b7%2D8ccd %2D595d38b04fcb Image Number 1 File Name IMG_1583.JPG Date and Time (incl. Time zone and DST) 9/21/2023; 12:10 CDT Description of Image Appliance/Refrigerant/RTU Recycling guidelines form IMG_1584.JPG 9/21/2023; 12:17 CDT Window air conditioner in scrap pile 2