Document KGMzmE1XdLgxxGVRQw5rLabvr

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Metalico Youngstown, Inc., Girard, Ohio FROM: David Sutlin, Environmental Engineer AECAB (MN/OH) THRU: Brian Dickens, Section Supervisor AECAB (MN/OH) TO: File BASIC INFORMATION Facility Name: Metalico Youngstown, Inc. Yard 6 Facility Location: 27 Furnace Lane, Girard, Ohio 44420 Date of Inspection: October 25, 2023 EPA Inspector(s): 1. David Sutlin, Environmental Engineer 2. Carlo Demma, Physical Scientist 3. Valeria Apolinario, Environmental Engineer Other Attendees: 1. Glenda Wehrli, Director of Environmental Compliance and Employee Safety, Metalico 2. Don Fleming, General Manager, Metalico 3. Jim Smith, Metalico 4. Tom Grumley, Metalico Contact Email Address: gwehrli@metalico.com Purpose of Inspection: To investigate emissions of volatile organic compounds (VOC) and particulate matter (PM) from the facility's hammermill shredder, compliance with regulations of ozone depleting substances, and compliance with the facility's air permit Facility Type: Scrap metal shredding and recycling Facility Name: Metalico Youngstown, Inc. Facility Location: 27 Furnace Lane, Girard, Ohio 44420 Date of Inspection: October 25, 2023 Regulations Central to Inspection: Permit-to-Install and Operate, No. P0126925, issued June 8, 2020 Arrival Time: 9:00 AM Departure Time: 12:50 PM 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 The following information was obtained verbally from facility and company personnel unless otherwise noted. Company Ownership: Metalico purchased this facility from Liberty Iron & Metal Inc. in December 2020. Metalico shut down a second facility operating in Youngstown and consolidated the staff at the Girard facility. Process Description: Scrap is brought into the facility on trucks and is weighed at the scale house. Larger scrap metal pieces are broken up using shears or, if required, torch-cut at a single torch cutting station. Small appliances such as refrigerators that contain refrigerant are moved to a designated area to recover the refrigerant. The majority of other scrap is seperated into two staging piles, one for auto bodies and one for light iron such as small appliances. The light iron scrap is inspected for non-conforming materials such as liquids and non-metal items. Rejected items are photographed and put back onto the trucks. Cars received off the street are de-polluted, including recovery of A/C refrigerant, and auto bodies from dealers are spot checked to ensure that they were properly de-polluted by the dealer. All ferrous scrap is then moved to a pile closer to the shredder. Cars and light iron are placed onto the infeed conveyer, which continuously loads scrap into a hammermill shredder. As the scrap is loaded, water is sprayed onto it, as-needed, to suppress dust. The majority of water spray occurs continuously and directly onto the hammermill in order to control for PM. After the shredder, materials are seperated into ferrous, non-ferrous and waste materials. Waste materials are further processed in the automotive shredder residue plant to further extract non-ferrous metals. Staff Interview: The shredder is approximately 20 years old. Page 2 of 6 Facility Name: Metalico Youngstown, Inc. Facility Location: 27 Furnace Lane, Girard, Ohio 44420 Date of Inspection: October 25, 2023 Auto bodies and light iron are continuously fed together into the shredder at a typical ratio of 30% autos to 70% sheet metal. This is done by loading two to three grapples of light iron followed by one auto body. Occasionally the shredder will process material at a rate as high as 50% autos. The maximum shredder infeed rate is approximately 108 gross tons/hr. The shredder runs 7-9 hrs/day, 5 days/week, occasional Saturdays, and typically operates from 7am to 3pm or 4pm. A second shift is reserved for most shredder maintenance. Prolonged maintenance occurs twice yearly for a total of approximately 17 days per year in addition to running minimally the last week of the year. An ampere reader on the shredder is used to track the total hours the shredder operated. Downtime is an ongoing challenge, but this particular shredder, which runs on two D/C motors, experiences less downtime as compared to shedders that run on A/C power. The shredder also processes approximately 200 tons/month of relatively clean mill scrap in batches and separate from the auto bodies/light iron mix. Visible emission (VE) readings are taken daily, as required by the permit. Readings are taken whenever readers are available rather than at a specific time. Scrap suppliers are required to sign waiver for small appliances and motor vehicle air conditioners where refrigerant was recovered or leaked out. Peddlers are put on notice if they have appliances with cut lines and are eventually turned away. The majority of cars received off the street are void of any refrigerant. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: Observed several auto bodies being fed into the shredder while some VEs could be seen coming from the shredder. Several sections of covers over the conveyors downstream of the shredder were missing. A section of rubber flaps closing off the housing of the shredder's infeed roller was missing. EPA toured the designated refrigerant recovery areas and verified proper recovery equipment for both automobiles and small appliances. Photos and/or Videos: were taken during the inspection. Field Measurements: were taken during this inspection. According to the permit, fugitive emissions from the shredder shall not exceed 20% opacity as a 3minute average. Carlo Demma took digital opacity photos of the shredder in accordance with EPA Alternative Method-082 while it was processing light iron and auto bodies. The opacity photos were analyzed post-inspection, and the results are included in the attached opacity report. The 3-minute average opacity, including an assumed 12th reading of 0% as noted in the comments of the opacity report, was 20%. Page 3 of 6 Facility Name: Metalico Youngstown, Inc. Facility Location: 27 Furnace Lane, Girard, Ohio 44420 Date of Inspection: October 25, 2023 CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Photos confirming repair of the flap over the infeed roller Calculation method for scrap infeed rate Daily scrap infeed rate records Shredder motor amperage readings Employee Method 9 certifications VE logs Confirmation if the facility is using refrigerant recovery verification contracts Information on local incentive program to promote proper refrigerant recovery Permit applications for permit #s P0126925 and 02-22999 Daily records of water spray flow rate for past 3 months Past 3 months of records of any deviations including corrective actions when the shredder operated without water application Compliance Assistance: EPA recommended taking readings according to when VEs are expected to occur or are actually observed rather than based on the availability of the reader. Metalico indicated they were open to revising the permit accordingly. EPA advised that appliances should not be accepted where it was obvious that the lines had been knowingly cut. Metalico stated that they reject appliances if they suspect the refrigerant was not properly recovered and that they tour auto body dealers and small appliance dealers to ensure proper draining of fluids and refrigerant. Concerns: EPA voiced concern over the damaged/missing flaps above the infeed roller. Staff addressed this after the inspection and sent photos to EPA for confirmation. EPA voiced concern over the missing cover sections on various conveyors. The permit requires that all conveying operations be controlled by partial and/or total enclosures. DIGITAL SIGNATURES DAVID Digitally signed by DAVID SUTLIN Report Author: _S_U__T_L_IN_______1_4:_25_:3_7 _-0_6'0_0'_____________ Date: 2023.12.21 Section Supervisor: CHARLES Digitally signed by CHARLES HALL _H_A__L_L________0_7:_19_:4_5_-0_6'0_0_' _____________ for Brian Dickens Date: 2023.12.22 Page 4 of 6 Facility Name: Metalico Youngstown, Inc. Facility Location: 27 Furnace Lane, Girard, Ohio 44420 Date of Inspection: October 25, 2023 APPENDICES AND ATTACHMENTS Appendix A: Digital Image and Video Log Attachment: Digital Opacity Report Page 5 of 6 Facility Name: Metalico Youngstown, Inc. Facility Location: 27 Furnace Lane, Girard, Ohio 44420 Date of Inspection: October 25, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Valeria Apolinario 2. Archival Record Location: EPA Region 5 Electronic Records Center Image Number 1 2 3 4 5 File Name IMG_0372.JPG IMG_0373.JPG IMG_0374.JPG IMG_0375.JPG IMG_0376.JPG Date and Time 2023:10:25 11:12:59 2023:10:25 11:13:17 2023:10:25 11:14:37 2023:10:25 11:15:32 2023:10:25 11:23:22 Description of Image Scrap conveyor - missing covers Scrap conveyor - missing covers Scrap conveyor - missing covers Scrap conveyor Missing flaps on back of infeed roller housing 6 MVI_0369.MP4 10/25/2023 10:56 7 MVI_0370.MP4 10/25/2023 10:58 8 MVI_0371.MP4 10/25/2023 11:02 Steam and emissions from shredder Steam and emissions from shredder Steam and emissions from shredder Page 6 of 6 VISIBLE EMISSION OBSERVATION FORM Form Number Page of Method Used Total Average Equipment Owner Start Glenda Wehrli Facility Name Metalico Youngstown, Inc. Yard 6 EO Street Address 27 Furnace Lane EO City EO Region Girard US-OH EO Zip 44420 Process Unit Hammermill Shredder N/A Control Equipment N/A Operating Mode N/A Operating Mode N/A Describe Emission Point Shredder fugitives Height of Emiss. Pt Start 30 End Same Distance to Emiss. Pt Start 122.88 End Same Height of Emiss. Pt. Rel. to Observer Start 26 End Same Direction to Emiss. Pt (Degrees) Start 275.51 End Same Vertical Angle to Obs, Pt. Direction to Obs. Pt Start 0.83 End Same Start 291.09 End Same Distance and Direction to Observation Point from Emission Point Start 33.93 / 14.92 End Same Describe Emissions Start Fugitive Emission Color End Same Water Droplet Plume Start White End Same Attached: ( ) Detached: ( X ) N/A: ( ) Describe Plume Backgroud Start Sky End Same Background Color Sky Conditions Start Gray End Same Start Clear End Same Wind Speed Wind Direction Start 12 End Same Start 225 End Same Ambient Temp. Wet Bulb Temp. RH Percent Start 69 End Same Start 54.72 End Same Start 39 End Same Longitude 080.42.06.695.W Latitude 41.08.43.061.N Notes Declination Continued on VEO Form Number Observation Date 10/25/2023 Time Zone CST Start Time 10:04:45 Opacity 1 45 2 40 3 45 4 20 5 20 6 10 7 10 8 5 9 0 10 0 11 50 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Observers Name (Print) David Sutlin Observers Signature David Sutlin Organization USEPA Region 5 Certified By David Sutlin Comments Avg Opacity = 22.27 Date 10/25/2023 Date 12/21/2023 End Time 10:07:15 DOCS II Web Version 1.1 - Metalico_Shredder_10-25-23 - 10/25/2023 Page 1 of 4 Source Name: Address: City: Region: - Zip: Phone: Local ID: Regulatory Permit ID: Condition: Regulatory Reference: Process Process: Hammermill Shredder Unit: N/A Operating Mode: N/A Complaint Name: Metalico Youngstown, Inc. Yard 6 Address: City: Region: - Zip: Equipment Name: N/A Type of Inspection Type of Inspection: Surveillance Sun Altitude: 35.1 Azimuth: 161 Data Source: Calculated Map Information Map Type: Google Map Width: 502 Analysis Averaging Type: Automatic Method: Total Average Number of Images: 1 Rolling High Count: All Seconds Between Images: N/A Who Created: DOCS II Creation Date: 10/25/2023 Analyis Name: Shawn Dolan Affiliation: Virtual Technology LLC 05 Comments: The actual camera operator for these readings was Carlo Demma, Physical Scientist, EPA. With an assumed 12th reading of 0%, the 3-minute average opacity is 20%. DOCS II Web Version 1.1 - Metalico_Shredder_10-25-23 - 10/25/2023 Page 2 of 4 Image IMG_6877.JPG IMG_6878.JPG IMG_6879.JPG IMG_6880.JPG IMG_6881.JPG IMG_6882.JPG IMG_6883.JPG IMG_6884.JPG Opacity 45 40 45 20 20 10 10 5 Coordinates Foreground Coordinates T L B R 414 2212 465 2273 Background Coordinates T L B R 470 382 521 443 Foreground Coordinates T L B R 332 3288 383 3349 Background Coordinates T L B R 470 382 521 443 Foreground Coordinates T L B R 378 3105 429 3166 Background Coordinates T L B R 470 382 521 443 Foreground Coordinates T L B R 214 1944 265 2005 Background Coordinates T L B R 470 382 521 443 Foreground Coordinates T L B R 224 1154 280 1215 Background Coordinates T L B R 567 230 618 291 Foreground Coordinates T L B R 337 1664 388 1725 Background Coordinates T L B R 801 624 852 685 Foreground Coordinates T L B R 357 1555 408 1616 Background Coordinates T L B R 869 454 920 515 Foreground Coordinates T L B R 803 2157 854 2218 Background Coordinates T L B R 900 613 951 674 Date Taken Camera Information Date Taken: 2023-10-25 10:04:45.000 Camera Mfg/Model: Canon/Canon PowerShot SX70 HS Temperature: 69 Wind Speed/Dir: 12 SW Rel Humidity: 39 Wet Bulb Temp: 54.72 Date Taken: 2023-10-25 10:05:00.000 Camera Mfg/Model: Canon/Canon PowerShot SX70 HS Temperature: 69 Wind Speed/Dir: 12 SW Rel Humidity: 39 Wet Bulb Temp: 54.72 Date Taken: 2023-10-25 10:05:15.000 Camera Mfg/Model: Canon/Canon PowerShot SX70 HS Temperature: 69 Wind Speed/Dir: 12 SW Rel Humidity: 39 Wet Bulb Temp: 54.72 Date Taken: 2023-10-25 10:05:30.000 Camera Mfg/Model: Canon/Canon PowerShot SX70 HS Temperature: 69 Wind Speed/Dir: 12 SW Rel Humidity: 39 Wet Bulb Temp: 54.72 Date Taken: 2023-10-25 10:05:45.000 Camera Mfg/Model: Canon/Canon PowerShot SX70 HS Temperature: 69 Wind Speed/Dir: 12 SW Rel Humidity: 39 Wet Bulb Temp: 54.72 Date Taken: 2023-10-25 10:06:00.000 Camera Mfg/Model: Canon/Canon PowerShot SX70 HS Temperature: 69 Wind Speed/Dir: 12 SW Rel Humidity: 39 Wet Bulb Temp: 54.72 Date Taken: 2023-10-25 10:06:15.000 Camera Mfg/Model: Canon/Canon PowerShot SX70 HS Temperature: 69 Wind Speed/Dir: 12 SW Rel Humidity: 39 Wet Bulb Temp: 54.72 Date Taken: 2023-10-25 10:06:30.000 Camera Mfg/Model: Canon/Canon PowerShot SX70 HS Temperature: 69 Wind Speed/Dir: 12 SW Rel Humidity: 39 Wet Bulb Temp: 54.72 DOCS II Web Version 1.1 - Metalico_Shredder_10-25-23 - 10/25/2023 Page 3 of 4 Image IMG_6885.JPG IMG_6886.JPG IMG_6887.JPG Opacity 0 0 50 Coordinates Foreground Coordinates T L B R 675 2169 726 2230 Background Coordinates T L B R 900 606 951 667 Foreground Coordinates T L B R 582 2163 633 2224 Background Coordinates T L B R 746 570 797 631 Foreground Coordinates T L B R 296 1713 347 1774 Background Coordinates T L B R 214 844 265 905 Date Taken Camera Information Date Taken: 2023-10-25 10:06:45.000 Camera Mfg/Model: Canon/Canon PowerShot SX70 HS Temperature: 69 Wind Speed/Dir: 12 SW Rel Humidity: 39 Wet Bulb Temp: 54.72 Date Taken: 2023-10-25 10:07:00.000 Camera Mfg/Model: Canon/Canon PowerShot SX70 HS Temperature: 69 Wind Speed/Dir: 12 SW Rel Humidity: 39 Wet Bulb Temp: 54.72 Date Taken: 2023-10-25 10:07:15.000 Camera Mfg/Model: Canon/Canon PowerShot SX70 HS Temperature: 69 Wind Speed/Dir: 12 SW Rel Humidity: 39 Wet Bulb Temp: 54.72 DOCS II Web Version 1.1 - Metalico_Shredder_10-25-23 - 10/25/2023 Page 4 of 4