Document RG18M2DB1pKpyLjV38y27ZYa
DATE: SUBJECT: FROM: THRU: TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS
77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604
OCT 0 7 2019
CLEAN AIR ACT INSPECTION REPORT OmniSource, Jackson, Michigan
David Sutlin, Environmental Engineer AECAB (MN/OH)
Brian Dickens, Section Chief AECAB (MN/OH)
File
BASIC INFORMATION
Facility Name: OmniSource
Facility Location: 711 Lewis Street, Jackson, Michigan
Date of Inspection: August 19, 20 I9
EPA Inspector(s): 1. David Sutlin, Environmental Engineer 2. Manojkumar Patel, Environmental Engineer
Other Attendees 1. Kevin Gross, Safety/Environmental Manager, OmniSource 2. Douglas McDonald, OmniSource 3. Mike Kovalchick, Senior Environmental Engineer, EGLE 4. Stephanie Weems, Environmental Quality Analyst, EGLE
Contact Email Address: Kevin.Gross@omnisource.com
Purpose of Inspection: To determine compliance with the CAA and the Michigan SIP
Facility Type: Scrap metal recycling
Regulations Central to Inspection: Michigan SIP
Arrival Time: 1:00 PM Departure Time: 3:15 PM
Inspection Type: 12:1 Unannounced Inspection U Announced Inspection
OPENING CONFERENCE
12:1 Credentials Presented 12:1 CBI warning to facility provided
The following information was obtained verbally from OmniSource unless otherwise noted.
Process Description: This facility accepts scrap metal including cast iron and carbon steel items, which are cut using shears and/or torches and then resold. Torch cutting operations take place under an enclosure, and emissions are routed to a cartridge-style fabric filter.
Staff Interview: Torch cutting is performed by contractors who are employees of RJ Industrial, LLC. The torch cutting enclosure and fabric filter have been in operation for approximately two months. The fabric filter contains 96 fire-retardant cartridge filters. Performance of the capture and control system is currently suboptimal, and OmniSource has contracted a third party to test and measure flow rates at various points within the system. To mitigate fire risk from sparks entering the fabric filter, OmniSource had considered installing a spark arrestor, but had determined that this would lead to poor emission capture. Instead, OmniSource is considering installing " screening over the exhaust vents in order to keep larger particles out of the ductwork.
TOUR INFORMATION
EPA toured the facility: Yes
Data Collected and Observations: While entering the facility, EPA observed some visible emissions exiting the side of the torchcutting enclosure. EPA later toured the facility and observed fewer visible emissions while inspecting the enclosure. The enclosure features a pitched roof, two sides made of sheet metal, and two open ends covered by rubber flaps. Fumes are exhausted through slots in a cylindrical duct positioned above the torch cutters. The duct extends out through the front of the enclosure and mates up with one of two exhaust branch ducts attached to the fixed fabric filter. The enclosure moves along railroad tracks, back-and-forth over two torching areas such that scrap can be loaded to one area while torch cutting occurs in the other area. Fixed interior walls made of thick metal shield the thin outer walls and rubber flaps of the enclosure from sparks. The fabric filter is stationary.
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Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection.
CLOSING CONFERENCE
Requested documents: Diagram of ventilation system Flow testing scope and results Fabric filter operations manual Fabric filter pressure drop measurement points Third party torch cutting contract
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Facility Name: OmniSource Facility Location: 711 Lewis Street, Jackson, Michigan Date of Inspection: August 19, 2019
APPENDICES AND ATTACHMENTS
Appendix A: Digital Image Log
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Facility Name: OmniSource Facility Location: 711 Lewis Street, Jackson, Michigan Date of Inspection: August 19, 2019
APPENDIX A: DIGITAL IMAGE LOG
1. Inspector Name: Manoikurnar Patel
3. Company/Facility Name:
OmniSource
5. Number of Images:
21
2. Date(s) of Inspection:
Au011st 19, 2019
4. Street Address, City, State:
711 Lewis Street, Jackson, Michigan 6. Archival Record Location:
CD-R labeled as "OmniSource, Jackson, Ml; 8-19-19 Inspection; Photos & Videos"
Image Number
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
16 17 18 19 20 21
File Name P8 l 9000 l.JPG P8190002.JPG P8190003.JPG P8190004.JPG P8190005.JPG P8190006.JPG P8 l 90007 .JPG P8 l 90008.JPG P8190009.JPG P8190010.JPG P819001 l.JPG P8190012.JPG P8190013.JPG P8190014.JPG P8190015.JPG
Date and Time (incl. time zone
and DST) 8/19/2019 13:05 8/19/201913:06 8/19/2019 13:06 8/19/2019 13:06 8/19/2019 13:07 8/19/2019 13:07 8/19/2019 13:08 8/19/2019 13:08 8/19/2019 13:09 8/19/2019 13:09 8/19/2019 13: 11 8/19/2019 13: 12 8/19/2019 13:12 8/19/2019 13:12 8/19/2019 13:12
P8190016.JPG P8190017.MOV P8190018.MOV P8190019.JPG P8190020.MOV P8190021.JPG
8/19/2019 13:14 8/19/2019 13: 16 8/19/2019 13:18 8/19/2019 13:18 8/19/2019 13:20 8/19/2019 13:20
Descrintion of Image Scrap Scrap Scrap Scrap Scrap
Back side of torching enclosure Side panels on enclosure
Torching enclosure wheel stop Fabric filter and air ducts Fabric filter with cartridges
Fabric filter pressure drop readout Fabric filter manufacturer's website label
Fabric filter Pulse iet oressure 2:auge Fabric filter label
Induced draft fan motor Conveyor material flaps over opening to
enclosure Video of torch cutting: under enclosure Video oftorch cutting under enclosure
Cut scrap inside the enclosure Video of torch cutting under enclosure
FlaPs covering oPening to enclosure
Appendices Page 1 of 1