Document O39z9wB9KyR4LO23e8Vq7ybjj

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 DATE: SUBJECT: FROM: THRU: TO: August 11, 2021 CLEAN AIR ACT INSPECTION REPORT Alter Metal Recycling, Racine, WI Tess Russell, Environmental Engineer AECAB (MN/OH) Brian Dickens, Section Chief AECAB (MN/OH) File BASIC INFORMATION Facility Name: Alter Metal Recycling Facility Location: 1339 17th Street, Racine, WI 53403 Date of Inspection: 06/18/2021 EPA Inspector(s): 1. Tess Russell, Environmental Engineer 2. Shilpa Patel, Environmental Engineer 3. Emma Leeds, Environmental Engineer Other Attendees: 1. Damon Hassell, Facility Manager 2. Darren Engbring, Regional Environmental Director (by phone) Contact Email Address: Damon.Hassell@altertrading.com Purpose of Inspection: Determine compliance with safe disposal regulations at 40 C.F.R Part 82, Subpart F. Facility Type: Scrap metal recycler Regulations Central to Inspection: 40 C.F.R. Part 82, Subpart F: Recycling and Emissions Reduction Arrival Time: 9:30 AM Departure Time: 12:00 PM Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Not a small business. Provided CBI warning to facility The following information was obtained verbally from Damon Hassell and/or Darren Engbring unless otherwise noted. Process Description: Alter Metal Recycling (Racine) accepts ferrous and non-ferrous metals for recycling from members of the general public and commercial suppliers in the form of white goods/appliances and cars. On-site recovery equipment for both white goods/appliances and motor vehicle air conditioning (MVAC) units is used to properly recover any materials accepted that still contain refrigerant. A third-party company, Refrigerant Recovery, Inc., is contracted to occasionally assist the facility with large loads of on-site refrigerant recovery. Staff Interview: The Alter Metal Recycling facility in Racine, WI has 7 employees. The employees go through training to ensure proper inspections are conducted when materials arrive on-site and unacceptable materials are rejected. Alter accepts white goods/appliances without refrigerant from those who have a contract with the scrapyard. Alter accepts white goods/appliances with refrigerant when the customer is not under contract and the lines have not been tampered. The facility will automatically reject any cut lines, or reject materials from entities not under contract with the scrapyard that arrive without refrigerant. While the scrapyard has the choice of accepting material without refrigerant if the uncontacted entity or peddler can sign a verification statement verifying proper recovery, it is a rare occurrence for the facility to utilize such onetime, per-load, verification statements. The facility has done it only once before and did so only after contacting the recoverer directly. Overall, the facility accepts more "processed" or properly recovered material from contracted entities than "unprocessed" material. The facility accepts approximately 10 cars per day under contract. Page 2 of 5 While Alter will accept white goods/appliances and cars containing refrigerant with no signs of being tampered with, the facility does not compensate the customer for these materials. There is no shredder, crusher, torch cutter, or baler at the facility. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA viewed the scrap pile containing recovered white goods/appliances in which appliances that had the refrigerant recovered before arriving at the facility were marked with a "D," and those with refrigerant recovered on-site were marked with an "A". EPA viewed the drop-off area for cars. EPA viewed the area designated for intact materials containing refrigerant, along with the equipment used to recover the refrigerant. EPA viewed the signage posted at the entrance to the facility near the weigh station, which indicates to customers what materials are not accepted. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. On-site Appliance Refrigerant Evacuation Record (copies obtained) 2. Daily Vehicle Dismantling Log (copies obtained) 3. Material Rejection Log (copy obtained) 4. CFC Spot Check (copy obtained) 5. Material Supplier Certification, FEMS 33 (examples obtained) 6. Refrigerant Scrap Management Program (copy obtained) 7. Summary of Proposed Changes to Refrigerant Scrap Management Program (copy obtained) 8. Receipt from Refrigerant Recovery, Inc. (copy obtained) CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Concerns: The inspectors did not identify any areas of concern. Page 3 of 5 SIGNATURES X TESS RUSSELL Tess Russell Report Author Digitally signed by TESS RUSSELL Date: 2021.08.11 11:49:13 -05'00' X Digitally signed by Brian Brian Dickens Dickens Date: 2021.08.11 12:42:09 -05'00' Brian Dickens Section Chief Page 4 of 5 Facility Name: Alter Metal Recycling Facility Location: 1339 17th Street, Racine, WI 53403 Date of Inspection: June 18, 2021 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log Page 5 of 5 Facility Name: Alter Metal Recycling Facility Location: 1339 17th Street, Racine, WI 53403 Date of Inspection: June 18, 2021 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Emma Leeds 2. Archival Record Location: C:\Users\trussell\OneDrive - Environmental Protection Agency (EPA)\Alter Metals\Inspections\Racine\Inspection Photos Image Number 1 2 3 4 5 6 File Name P6180006.JPG P6180007.JPG P6180008.JPG P6180009.JPG P6180010.JPG P6180011.JPG Date and Time (incl. Time zone and DST) Friday, June 18, 2021, 11:11:18 AM Friday, June 18, 2021, 11:11:44 AM Latitude and Longitude Friday, June 18, 2021, 11:11:58 AM Friday, June 18, 2021, 11:29:58 AM Friday, June 18, 2021, 11:30:54 AM Friday, June 18, 2021, 11:37:24 AM Description of Image Customers notification about CFC removal Customers/Haulers/ Contractors/Visitors sign Prohibited Materials sign Refrigerator in pile with "A" Refrigerator in pile with "D" Recovery Equipment Appendices Page 1 of 1