Document 7R9vXXKEpk9Ome8MdZd0w06bE

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEYARD CHICAGO, ILLINOIS 60604 APR O4 2019 CLEAN AIR ACT INSPECTION REPORT River Metals Recycling, Cincinnati, Ohio Scott Connolly, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC lNFORMATION Facility Name: River Metals Recycling Facility Location: 1951 State Ave, Cincinnati, Ohio Date of Inspection: March 20, 2019 EPA Inspector: 1. Scott Connolly, Environmental Engineer 2. Natalie Topinka, Environmental Scientist Other Attendees 1. Tony Maurits, Facility Supervisor, River Metals Recycling 2. Nate Stroup, Environmental Manager, River Metals Recycling 3. Nick Robertson, Lead Site Manager, River Metals Recycling Contact Email Address: nate.stroup@djj .corn Purpose of Inspection: To determine compliance with the Clean Air Act Facility Type: Metal recycling yard Regulations Central to Inspection: 40 C.F.R. Part 82, Subpart F: Recycling and Emissions Reduction Arrival Time: 9:15 am Departure Time: 9:32 am Inspection Type: IZl Unannounced Inspection Announced Inspection OPENING CONFERENCE IZl Credentials Presented CBI warning to facility provided The following information was obtained verbally from Nate Stroup unless otherwise noted. Company Ownership: River Metals Recycling, is a wholly owned venture of the David J. Joseph Company (DJJ), which is a part of Nucor Corporation. Process Description: River Metals Recycling Cincinnati accepts ferrous and non-ferrous metals for recycling from the general public and industrial suppliers. The facility accepts multiple small appliances daily and accepts whole unprocessed cars. Cars are processed on site to remove fluids, refrigerants and other hazardous components. The facility sorts light iron, aluminum, copper scrap, and other metals into piles of like material for shipping to an appropriate recycling facility. Staff Interview: Facility staff stated that it requires appliances to be drained of refrigerants prior to accepting appliances. No small appliance refrigerant recovery is performed on-site. River Metals Recyling requires that suppliers sign a Scrap Acceptance Agreement stating that suppliers will evacuate refrigerants prior to delivery at the facility. If the computer system that is used to access the Scrap Acceptance Agreements on file is down, the facility uses a paper CFC contract for suppliers to certify that refrigerants have been removed from appliances and cars prior to arriving at the facility. The facility accepts about 10-15 refrigerators per week and about 4-5 cars per day. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: Several appliances were in the ferrous scrap pile, including at least on refrigerator. All appliances observed in the scrap pile were partially or severely crushed. The facility had few cars on site for processmg. Photos: were taken during the inspection. A photo log is contained in Appendix A. Page 2 of 4 Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Requested documents: Scrap Acceptance Agreement (1 copy obtained) Bulk Hauler/Appliance Hauler CFC Contract (1 copy obtained) Compliance Assistance: We gave a short overview of the regulatory requirements and compliance options in 40 C.F.R. Part 82, Subpart F. Concerns: We discussed the need to put a program in place to either recover refrigerant from small appliances and vehicles or to verify the refrigerant's proper recovery prior to delivery. SIGNATURES Page 3 of4 Facility Name: River Metals Recycling Facility Location: 1951 State Ave, Cincinnati, Ohio Date of Inspection: March 20, 2019 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log Page 4 of 4 Facility Name: River Metals Recycling Facility Location: 1951 State Ave, Cincinnati, Ohio Date oflnspection: March 20, 2019 APPENDIX A: DIGITAL IMAGE LOG 1. Photographer Name: Scott Connolly 3. Company/Facility Name: River Metals Recycling 5. Number of Images: 4 2. Date of Inspection: March 20, 2019 4. Street Address, City, State: 1951 State Ave, Cincinnati, Ohio 6. Archival Record Location: Photos are located on the attached CD labelled "River Metals Recycling Cincinnati Inspection Photos" Image Number File Name Date and Time 1 RIMG0045.JPG 3/20/2019 9:11 2 RIMG0046.JPG 3/20/2019 9:21 3 RIMG0047.JPG 3/20/2019 9:22 4 RIMG0048.JPG 3/20/2019 9:22 Latitude and Longitude Data Not Available Data Not Available Data Not Available Data Not Available Description of Image Signs at the entrance of the facility stating appliance acceptance policies Refrigerators in the ferrous scrap pile Vehicle processing station Refrigerant recover equipment at the vehicle processing station Appendices Page 1 of 1