Document 9NrYajGNavxx7g22DgwXVJL6

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD .CHICAGO, ILLINOIS 60604 NOV 2 12018 CLEAN AIR ACT INSPECTION REPORT Best American Iron & Metal, Houston, Texas Natalie Topinka, Environmental Scientist AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Best American Iron & Metal Facility Location: 5417 North McCarty Street, Houston, Texas Date ofinspection: November 9, 2018 EPA Inspector(s): 1. Natalie Topinka, Environmental Scientist 2. Scott Connolly, Environmental Engineer Other Attendees 1. Doris Rowell, Manager, Best American Iron & Metal 2. Anthony Powell, Yard Manager, Best American Iron & Metal Contact Email Address: dbabestamerican@aol.com Purpose of Inspection: Assess compliance with the refrigerant disposal requirements Facility Type: Scrap metal recycler Regulations Central to Inspection: 40 C.F.R Part 82, Subpart F Arrival Time: 12:05 pm Departure Time: 12:58 pm Inspection Type: ISi Unannounced Inspection D Announced Inspection OPENING CONFERENCE ISi Credentials Presented ISi CBI warning to facility provided The following information was obtained verbally from Ms. Rowell and Mr. Powell unless otherwise noted. Process Description: Best American Iron & Metal accepts ferrous and non-ferrous metals for recycling from the general public. The facility accepts small appliances at least daily and on the order of 2-3 cars per day. No refrigerant recovery is performed on-site, and Best American does not require documentation of the fate ofrefrigerant in items delivered for recycling that previously contained refrigerant. Staff Interview: Ms. Rowell and Mr. Powell stated that most items arrive at the facility empty ofrefrigerant and separated into their component parts to be sold at different price points for individual grades of metal. Ferrous material is sent to one of the local shredders. For cars, Best American Iron & Metal accept the vehicles as-is and takes responsibility for draining, collecting, and disposing of the fluids from the cars. In the past, they required cars to be empty of fluids but this resulted in customers illegally draining those fluids on the ground immediately prior to delivery of the item for recycling. TOUR lNFORMATION EPA toured the facility: Yes Data Collected and Observations: We observed small appliances and vehicles in the scrap yard. We also observed Best American's vehicles dismantling station, which is under cover. We observed a very old refrigerant recovery machine and tank which Mr. Powell confirmed was not in use. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Page 2 of 4 Compliance Assistance: We gave an overview of the regulatory requirements and compliance options in 40 C.F.R. Part 82, Subpart F, and answered preliminary questions about the requirements and how a refrigerant recovery program might work in practice. Concerns: We discussed with Ms. Rowell and Mr. Powell 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 to Best American. SIGNATURES Page 3 of 4 Facility Name: Best American Iron & Metal Facility Location: 5417 North McCarty Street, Houston, Texas Date of Inspection: November 9, 2018 APPENDICES AND ATTACHMENTS I. Digital Image Log Digital Images attached on CD Page 4 of 4 Facility Name: Best America.Tl. Iron & Metal Facility Location: 5417 North McCarty Street, Houston, Texas Date of Inspection: November 9, 2018 APPENDIX A: DIGITAL IMAGE LoG 1. Inspector Name: Scott Connolly 3. Company/Facility Name: Best American Iron & Metal 5. Number of Images: 5 2. Date(s) of Inspection: November 9, 2018 4. Street Address, City, State: 5417 North McCarty Street, Houston, Texas 6. Archival Record Location: CD-R labeled Best American Iron & Metal Inspection photos, November 9, 2018 Image Number 86 87 88 89 90 File Name PB090086.JPG PB090087.JPG PB090088.JPG PB090089.JPG PB090090.JPG Date and Time (CST) Latitude and Longitude 11/9/2018 14:11 11/9/2018 14:27 11/9/2018 14:30 11/9/2018 14:34 11/9/2018 14:36 29.81, -95.260278 29.810556, -95.260278 29.810833, -95.26 29.810556, -95.26 Description of Image Best American - reference photo of front entrance Best American - appliances on scrap pile Best American - Freon recovery machine (not in use) Best American - scrap vehicles on-site Best American - list of rejected items Appendices Page 1 of 1