Document KrdV3O2ad5y71xRQvVD6rjKw

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEYARD CHICAGO, ILLINOIS 60604 NOV 1 5 2018 CLEAN AIR ACT INSPECTION REPORT Alter Metal Recycling, Eau Claire, Wisconsin Scott Connolly, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Alter Metal Recycling Facility Location: 3532 White Ave, Eau Claire, Wisconsin 54703 Date of Inspection: October 23, 2018 EPA Inspectors: 1. Scott Com101ly, Environmental Engineer 2. Jason Schenandoah, Environmental Engineer Other Attendees 1. Greg O'Leary, Regional Director of Operations, Alter Metal Recycling 2. Steve Nockerts, Facility Manager, Alter Metal Recycling 3. Jay Hasart, Operations Supervisor, Alter Metal Recycling 4. Kyle Erikson, Non-Ferrous Facility Manager, Alter Metal Recycling 5. Darren Engbring, Regional Environmental Manager, Alter Metal Recycling (phone) Contact Email Address: Darren.engbring@altertrading.com Purpose of Inspection: To determine compliance with the Clean Air Act Facility Type: Metal Shredding and Recycling Facility Regulations Central to Inspection: 40 C.F.R. Part 82, Subpart F, Recycling and Emissions Reductions Arrival Time: 4:00 pm Departure Time: 5:20 pm Inspection Type: IZI Unannounced Inspection D Announced Inspection OPENING CONFERENCE IZI Credentials Presented IZI CBI warning to facility provided The following information was obtained verbally from inspection attendees unless otherwise noted. Process Description: The facility purchases processes scrap metal received by truck from feeder yards, industrial clients and from the general public. Scrap inspectors check the incoming metal items for nonconforming material during unloading into scrap piles, depending on material and available space. Then the shredder processes the piles postconsumer ferrous and non-ferrous scrap, industrial scrap, and vehicles. Cranes load scrap metal onto a conveyor, which feeds the metal into the harnmermill shredder. The harnmermill is equipped with an automatic water injection system, which sprays water into the shredder to reduce dust and to cool the metal. Shredded metal exits the shredder and is fed through a magnetic separator, which separates non-magnetics from ferrous metal. Fluff, including non-ferrous metals are collected and processed in the nonferrous separation downstream to remove non-metallic components. Staff Interview: Facility staff stated that suppliers bringing appliances and vehicles to the facility must sign a "Material Supplier Certification" contract prior to acceptance by Alter Metal Recycling. The facility typically recovers refrigerants from vehicles and appliances but Alter Metal Recycling will not pay suppliers for items that contain refrigerants. The facility operates a 4000-horsepower electric hammermill shredder that process about 30-40% vehicles. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: At least one intact air conditioner appliance was observed in the scrap pile. Several other appliances were observed that had not evidence of proper recovery. Appliances appeared to be from a roll of container that may have come from a feeder yard and facility staff confirmed this observation. In the refrigerant reclamation area, the facility separates refrigerants into Rl 34a, Page 2 of 4 Rl2 and R22 containers. Several intact appliances were located in the reclamation area, ready for refrigerant recovery. Photos: were taken during the inspection. A photo log is attached in Appendix A. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Requested documents: Material Supplier Certification Contract (1 copy obtained) United Refrigeration Refrigerant Disposal Receipts from May, July and August 2018 (1 copy obtained) Compliance Assistance: Alter Trading was informed that several appliances were accepted but showed evidence that proper recovery had not occurred. Concerns: Several evacuated appliances had evidence that proper recovery did not occur, indicating that verification of proper recovery may not be occurring and the presence of intact appliances in the scrap pile indicates that venting of refrigerants is likely occurring during the disposal process. SIGNATURES Page 3 of 4 Facility Name: Alter Metal Recycling Facility Location: 3532 White Ave, Eau Claire, Wisconsin Date of Inspection: October 23, 2018 APPENDICES AND ATTACHMENTS I. Appendix A: Digital Image Log Page 4 of 4 Facility Name: Alter Metal Recycling Facility Location: 3532 White Ave, Eau Claire, Wisconsin Date of Inspection: October 23, 2018 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Scott Connolly 3. Company/Facility Name: Alter Metal Recycling 5. Number of Images: 9 2. Date of Inspection: October 23, 2018 4. Street Address, City, State: 3532 White Ave, Eau Claire, Wisconsin 6. Archival Record Location: Photos are located on the attached CD labelled "Alter Metal Recycling Eau Claire, WI Inspection Photos 10/23/2018" Image Number 1 2 3 4 File Name PA230012.JPG PA230013.JPG PA230014.JPG PA230015.JPG Date and Time 10/23/2018 16:23 10/23/2018 16:27 10/23/2018 16:31 10/23/2018 16:34 Latitude and Longitude 44.835, 91.474444 44.835, 91.474444 44.835, 91.474444 44.835, 91.474444 5 PA230016.JPG 10/23/2018 16:36 44.835, 91.474444 6 PA230017.JPG 10/23/2018 16:39 44.835, 91.474444 7 PA230018.JPG 10/23/2018 16:39 44.835, 91.474444 8 PA230019.JPG 10/23/2018 16:44 44.835, 91.474444 9 PA230020.JPG 10/23/2018 16:46 44.835, 91.474444 Description of Image Non-accepted materials sign at scale house Intact air conditioning unit found in the scrap pile. Shredder, infeed and outfeed conveyors. Partially crushed freezer unit refrigeration lines that appeared broken and had no evidence ofrefrigerant recovery. Refrigerator with cut lines located in the scrap pile Car depollution rack Refrigerant recovery equipment located at the car depollution area. Appliance refrigerant recovery area Refrigerant tanks next to refrigerant recovery area Appendices Page 1 of 1