Document dDMdJ4dDzjm8ye53y00a990dG

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 - NOV 1 5 2018 CLEAN AIR ACT INSPECTION REPORT Alter Trading Corporation, Madison, Wisconsin Scott Connolly, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC l.1\IFORMATION Facility Name: Alter Trading Corporation Facility Location: 4400 Sycamore Ave, Madison, Wisconsin Date of Inspection: October 23, 2018 EPA Inspectors: 1. Scott Connolly, Environmental Engineer 2. Jason Schenandoah, Environmental Engineer Other Attendees 1. Seth Wood, Operations Manager, Alter Trading Corporation 2. Jamie Wilson, Director of Capital Projects, Alter Trading Corporation 3. John Spigel, Vice President of Operations, Alter Trading Corporation 4. Darren Engbring, Regional Environmental Manager, Alter Trading Corporation 5. Chris Barry, Environmental Technician, Alter Trading Corporation 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: 10:30 am Departure Time: 1:00 pm Inspection Type: 12'.J Unannounced Inspection D Announced Inspection OPENING CONFERENCE 12'.J Credentials Presented 12'.J 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 hammermill shredder. The hammermill 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 sent to another facility for further processing. 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 Trading. The facility recently started recovering refrigerants from vehicles and has not sent refrigerants to a reclaimer in the past two years. Facility staff stated that the scale operator sometimes directs incoming intact appliances to a local refrigerant recovery company. The facility operates a 4000-horsepower electric hammermill shredder that process about 30% vehicles TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: Several appliances, including several refrigerators and a freezer, were observed in the scrap pile that had no evidence that refrigerants were recovered properly. At least the refrigerators had Page 2 of 4 evidence that the units still contained refrigerants and two appliances had evidence of improper removal of refrigerants. Smoke and a burning odor were observed originating from the shredder. The facility has four full refrigerant tanks from its vehicle recovery processes. 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) Documentation of Refrigerant Removal verification statement (1 copy obtained) Compliance Assistance: Alter Trading facility staff were informed that several appliances were accepted but showed evidence that proper recovery had not occurred Concerns: Several empty appliances had no evidence of recovery, indicating that verification of proper recovery may not be occurring and that venting of refrigerants is likely occurring during the disposal process. The facility' s verification statement does not contain all of the required information. SIGNATURES Page3 of 4 Facility Name: Alter Trading Corporation Facility Location: 4400 Sycamore Ave, Madison, Wisconsin Date of Inspection: October 23, 2018 APPENDICES AND ATTACHMENTS I. Appendix A: Digital Image Log Page 4 of 4 Fatility Name: Alter Trading Corporation Facility Location: 4400 Sycamore Ave, Madison, Wisconsin Date of Inspection: October 23, 2018 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Scott Connolly 3. Company/Facility Name: Alter Trading Corporation 5. Number of Images: 11 2. Date of Inspection: October 23, 2018 4. Street Address, City, State: 4400 Sycamore Ave, Madison, Wisconsin 6. Archival Record Location: Photos are located on the attached CD labelled "Alter Trading - Madison Inspection Photos 10/23/18 Image Number 1 File Name PA230001.JPG 2 PA230002.JPG 3 P A230003.JPG 4 PA230004.JPG 5 PA230005.JPG 6 PA230006.JPG 7 P A230007.JPG 8 P A230008.JPG 9 PA23 0009.JPG 10 PA230010.JPG 11 PA23001 l.JPG Date and Time 10/23/2018 11:34 10/23/2018 11 :34 10/23/2018 11:39 10/23/2018 11 :41 10/23/2018 11 :42 10/23/2018 11:47 10/23/2018 11:51 10/23/2018 11 :51 10/23/2018 11:53 10/23/2018 11 :56 10/23/2018 12:13 Latitude and Longitude Data Not Available Data Not Available Data Not Available Data Not Available Data Not Available 43.114773, -89.306297 43.114722, -89.306111 43.114747, -89.30605 43.114785, -89.306033 43.115556, -89.305556 43.115278, -89.305833 Description of hnage CFC Sign next to scale Prohibited Material sign next to scale Cut and removed lines on freezer in scrap pile Mini fridge with cut refrigerant lines Black Intact refrigerant (back panel still bolted on) White intact refrigerator (back panel still attached) Vehicle refrigerant recovery equipment Vehicle depollution station Shredder infeed conveyor and tower Smoke exiting the shredder during operations Shredder out feed and steam cloud Appendices Page 1 of 1