Document 9gzEVxb0byz4XxNyZwok10Y6

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Fritz Enterprises, Inc., Taylor, Michigan FROM: Maggie Nutter, Environmental Engineer AECAB (IL/IN) THRU: Nathan Frank, Section Supervisor AECAB (IL/IN) TO: File BASIC INFORMATION Facility Name: Fritz Enterprises, Inc. (Fritz) Facility Location: 23550 Pennsylvania Road, Taylor, Michigan 48180 Date of Inspection: December 9, 2024 EPA Inspector(s): 1. Maggie Nutter, Environmental Engineer 2. Emma Leeds, Environmental Engineer Other Attendees: 1. Bryan Fultz, Plant Manager - Fritz 2. Ed Busch, Plant Superintendent - Fritz 3. Paul Smith, Lower Scale Operator - Fritz 4. David Splan, Vice President - Fritz Contact Email Address: FultzB@Fritzinc.com , DSplan@Fritzinc.com Purpose of Inspection: To investigate compliance with the Clean Air Act Facility Type: Metal recycling facility with shredder Regulations Central to Inspection: 40 C.F.R. Part 82, Subpart F: Recycling and Emissions Reduction Facility Name: Fritz Enterprises, Inc. (Fritz) Facility Location: 23550 Pennsylvania Road, Taylor, Michigan 48180 Date of Inspection: December 9, 2024 Arrival Time: 1:20 PM ET Departure Time: 2:50 PM ET Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Provided CBI warning to facility Was any information collected during the inspection claimed as CBI? Yes No. Process Description: The Fritz Enterprises, Inc. facility in Taylor (Fritz) accepts both ferrous and non-ferrous scraps from contracted vendors and peddlers. Scraps are organized and prepared for shredding and then processed on-site in a 4,000-horsepower shredder. After shredding, a magnet is used to separate ferrous and nonferrous metals. Particulate emissions from the shredder are controlled by a water spray, and particulate emissions from the Z-box are controlled by a cyclone. Staff Interview: The Fritz Taylor facility (the Facility) operates from 8 AM - 4:30 PM Monday - Saturday with 22 employees. The shredder typically operates 8 hours a day and had an average processing rate of approximately 60-70 tons per hour. Fritz will shred one car at a time followed by a load of miscellaneous scraps. The miscellaneous scrap loads are used to cool down the motor which heats up during vehicle shredding. When asked by USEPA if Fritz monitors any parameters at the cyclone or Z-box, Bryan was not aware. The facility mostly receives and processes vehicles from contracted vendors, and mostly receives appliances from peddlers. The facility receives approximately 5 motor vehicles per day. Contracted vendors account for approximately 75% of the motor vehicles received, which have already had their refrigerant recovered and been crushed. Fritz maintains contracts with vendors ensuring all vehicles will have their refrigerant properly recovered prior to arriving at Fritz, which are annually verified. These contracts are kept at the Fritz Trenton facility. The remaining 25% of motor vehicles accepted at the Facility are generated by peddlers selling vehicles to Fritz. These motor vehicles are sent to the prep station located at the northern end of the site to evaluate for the existence of refrigerant and recover if necessary. Page 2 of 6 Facility Name: Fritz Enterprises, Inc. (Fritz) Facility Location: 23550 Pennsylvania Road, Taylor, Michigan 48180 Date of Inspection: December 9, 2024 The facility accepts appliances from peddlers for free. Bryan shared that if a peddler tries to sell appliances to Fritz, they are required to fill out the "Appliances or Shipment of Appliances Certification" (Peddler Refrigerant Sheet). The Peddler Refrigerant Sheet gives peddlers the option to check off that either all refrigerants had been removed from the appliance in accordance with 40 C.F.R. Section 82.156 (Option A), or that all refrigerants had previously leaked out from the appliance (Option B). Paul stated that if a peddler comes in with an appliance that still contains refrigerant, they are instructed by Fritz to check off Option A. When asked by USEPA if Fritz maintains refrigerant recovery certification forms with peddlers regarding proper refrigerant recovery from vehicles, Bryan was not aware. The Fritz Taylor facility has equipment to recover refrigerant from both vehicles and appliances. TOUR INFORMATION EPA Toured the Facility: Yes Data Collected and Observations: A delivery of six crushed motor vehicles (Image PC090030) was accepted from a contracted vendor during the tour. The shredder was observed while in operation to be shredding both motor vehicles and miscellaneous processed scrap. Steam from the water spray was observed to be emitted from the shredder (Image PC090042). The final scrap pile was collected from the northern side of the shredder. The refrigerant evacuation and recovery station used for appliances (Image PC090031) was demonstrated to be operational. An identical station is used for motor vehicles refrigerant evacuation and recovery, but the operator was not on-site during the time of the inspection to demonstrate the process. Motor vehicles accepted from peddlers were stored near this refrigerant recovery "prep" station awaiting evaluation. Photos and/or Videos: were taken during the inspection and are listed in Appendix A. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. "Appliances or Shipment of Appliances Certification" sheets completed by peddlers. Records from last 5 years were collected. 2. Refrigerant evacuation documentation log from 2024 reporting date and serial number associated with the appliance. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Page 3 of 6 Facility Name: Fritz Enterprises, Inc. (Fritz) Facility Location: 23550 Pennsylvania Road, Taylor, Michigan 48180 Date of Inspection: December 9, 2024 Requested documents: Copies of the completed refrigerant recovery contracts used for any motor vehicle or appliance transaction in the past 3 years Copies of the completed verifications forms used when the facility accepts appliances or motor vehicles from peddlers in the past 3 years All emissions testing records for the shredder Refrigerant waste manifests or similar disposal records in the past 3 years. Compliance Assistance: USEPA explained the requirements involving required refrigerant recovery documentation in 40 C.F.R. 82.155(b)(2). Concerns: During the December 9 inspection, USEPA expressed concerns about the possible lack of contracts with vendors ensuring proper refrigerant recovery from vehicles. USEPA also expressed concern regarding the clarity of the "Appliances or Shipment of Appliances Certification" form. Dave stated that they were in the process of updating the forms with their corporate office. DIGITAL SIGNATURES MARY Digitally signed by MARY NUTTER Date: 2025.02.06 Report Author: _N__U_T__T_E_R______1_0:_59_:2_0 -_06_'0_0'____________ Section Supervisor: Frank, Digitally signed by Frank, Nathan Date: 2025.02.07 _N_a_t_h_a_n_______1_5_:56_:2_4_-0_6'0_0_' _____________ APPENDICES 1. Appendix A: Digital Image Log Page 4 of 6 APPENDIX A: DIGITAL IMAGE LOG Facility Name: Fritz Enterprises, Inc. (Fritz) Facility Location: 23550 Pennsylvania Road, Taylor, Michigan 48180 Date of Inspection: December 9, 2024 1. Inspector Name: Maggie Nutter 2. Archival Record Location: Fritz Taylor Inspection Photos Image Number 1 2 3 File Name PC090030 PC090031 PC090032 Date and Time (incl. Time zone and DST) 12/9/24, 12:13 PM ET 12/9/24, 1:10 PM ET 12/9/24, 1:14 PM ET Description of Image Delivery of crushed motor vehicles from contracted vendor Prep station "buckets" for appliances refrigerant evacuation and recovery Scrap piles ready to be shredded 4 PC090033 12/9/24, 1:14 PM ET Motor vehicle staging area 5 PC090034 12/9/24, 1:15 PM ET Motor vehicle staging area 6 PC090035 12/9/24, 1:15 PM ET Shredder loading station with mixed motor vehicles and appliances 7 PC090036 12/9/24, 1:16 PM ET Scrap pile in shredder loading station 8 PC090037 12/9/24, 1:17 PM ET Shredder cyclone 9 PC090038 12/9/24, 1:17 PM ET Shredder output 10 PC090039 12/9/24, 1:20 PM ET Prep station for motor vehicle refrigerant evacuation and recovery 11 PC090040 12/9/24, 1:20 PM ET Prep station for motor vehicle refrigerant evacuation and recovery 12 PC090041 12/9/24, 1:22 PM ET Motor vehicle from peddler with AC unit intact, awaiting evaluation from Fritz 13 PC090042 12/9/24, 1:25 PM ET Shredder and cyclone 14 PC090043 12/9/24, 1:25 PM ET Cyclone and Z-box 15 PC090044 12/9/24, 1:27 PM ET Cyclone 16 PC090045 12/9/24, 1:27 PM ET Shredder 17 PC090046 12/9/24, 1:30 PM ET Shredder (looking north) Image Number File Name Date and Time (incl. Time zone and DST) Description of Image Page 5 of 6 Facility Name: Fritz Enterprises, Inc. (Fritz) Facility Location: 23550 Pennsylvania Road, Taylor, Michigan 48180 Date of Inspection: December 9, 2024 18 PC090047 12/9/24, 1:33 PM ET Scrap pile in shredder loading area Page 6 of 6