Document MGr2ybgbM7bM7qevOJm0Xnb2j
DATE: SUBJECT: FROM: THRU: TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS
77 WEST JACKSON BOULEYARD CHICAGO, ILLINOIS 60604
APR 1 5 2019
CLEAN AIR ACT INSPECTION REPORT Cohen Recycling~ West Carrollton, Miamisburg, Ohio
Natalie Topinka, Environmental Scientist AECAB (IL/IN)
Nathan Frank, Section Chief AECAB (IL/IN)
File
BASIC INFORMATION
Facility Name: Cohen Recycling~ West Carrollton
Facility Location: 5101 Fannersville-West Carrollton Road, Miamisburg, Ohio
Date of Inspection: March 18, 2019
EPA Inspector(s): 1. Natalie Topinka, Environmental Scientist 2. Scott Connolly, Environmental Engineer
Other Attendees 1. Kyle Dean, District Operations Manager, Cohen
Contact Email Address: jdedario@cohenusa.com, kdean@cohenusa.com
Purpose of Inspection: Assess compliance ,,vith the safe disposal regulations for protection of stratospheric ozone
Facility Type: scrap metal recycler
Regulations Central to Inspection: 40 C.F.R. Part 82, Subpart F
Arrival Time: 11 :20 am Departure Time: 12:20 pm
Inspection Type:
IZJ Unannounced Inspection
D Announced Inspection
OPENING CONFERENCE
IZJ Credentials Presented IZJ CBI warning to facility provided
The following information was obtained verbally from Cohen representatives unless otherwise noted.
Process Description: Cohen Recycling - West Carrollton accepts ferrous and non-ferrous metals for recycling from the general public and from commercial accounts. The facility accepts small appliances and vehicles daily. Car processing began at the West Carrollton location approximately 9 months ago, which includes refrigerant recovery. The facility has a shredder, which is a Texas Shredder manufactured by Metso. The shredder is rated at 3000 HP with a capacity of approximately 400500 tons net ferrous output. Cohen operates the shredder typically 7-8 hours per day. The shredder is not equipped with emissions capture or controls. Downstream material sorting occurs at another facility.
Staff Interview: Mr. Dean estimated that 30-50% of the shredder feed is vehicles, about 100 per day. Items including batteries, lead wheel weights, mercury switches, tires, gas tanks, antifreeze, oil, transmission fluid, catalytic converters, and air conditioning refrigerant were removed from the vehicles prior to shredding. Mr. Dean stated that the facility has not yet had to send a full cylinder ofrecovered refrigerant offsite for reclamation or disposal. To date, Cohen does not require documentation regarding the fate of the refrigerant contained in a small appliance delivered to the facility.
TOUR INFORMATION
EPA toured the facility: Yes
Data Collected and Observations: The shredder was not operating at the time of our inspection. We observed crushed vehicles awaiting shredding and appliances on the scrap pile. We were not able to get close enough to the appliances to determine what type they were.
Photos and/or Videos: were taken during the inspection.
Field Measurements: were not taken during this inspection.
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CLOSING CONFERENCE
Compliance Assistance: We gave an overview ofthe regulatory requirements and compliance options in 40 C.F.R. Part 82, Subpart F
Concerns: Cohen should put in place a refrigerant recovery and verification program for small appliances. At our earlier visit to Cohen' s Hamilton facility, we discussed the pending companywide policy regarding the inspection, documentation, and handling of scrap that contains or once contained refrigerants.
SIGNATURES
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Facility Name: Cohen Recycling- West Carrollton Facility Location: 5101 Farmersville-West Carrollton Road, Miamisburg, Ohio Date of Inspection: March 18, 2019
APPENDICES AND ATTACHMENTS
I.
Digital Image Log
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Page 4 of 4
Facility Name: Cohen Recycling- West Carrollton Facility Location: 5101 Farmersville-West Carrollton Road, Miamisburg, Ohio Date of Inspection: March 18, 2019
APPENDIX A: DIGITAL IMAGE LOG
1. Inspector Name: Scott Connolly
3. Company/Facility Name: Cohen Recycling - West Carrollton
5. Number oflmages: 4
2. Date(s) of Inspection:
March 18, 2019 4. Street Address, City, State:
5101 Farmersville-West Carrollton Road, Miamisburg, Ohio
6. Archival Record Location:
CD-R labeled as Cohen - West Carrollton Inspection photos, March 18, 2019
Image Number
File Name
Date and Time (CST)
Description of Image
1
RIMG0008.JPG
3/18/2019 10:42
Facility front entrance
2
RIMG0009.JPG
3/18/2019 10:47
Ferrous scrap pile with shredder in background
3
RIMG0010.JPG
3/18/2019 10:52
Refrigerant recovery equipment used on vehicles
4
RI MG0011.J PG
3/18/2019 10:53
Crushed vehicles awaiting shredding
Appendices Page 1 of 1