Document jGnQ1xzL1npvKzZ7mDGYwBbO

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Rocky Mountain Recycling, Commerce City, CO Valeria Apolinario AECAB (MN/OH) Brian Dickens, Section Supervisor AECAB (MN/OH) File BASIC INFORMATION Facility Name: Rocky Mountain Recycling Facility Location: 6510 Brighton Blvd, Commerce City, CO 80022 Date of Inspection: June 22, 2022 EPA Inspector(s): 1. Valeria Apolinario, Environmental Engineer 2. Brianna Fenzl, Environmental Engineer 3. Laura Steel, Environmental Engineer Other Attendees: 1. Leticia Acosta, Safety Manager 2. Tom Crane, Operations Manager/Assistant Plant Manager Contact Email Address: lacosta@rmrscrap.com Purpose of Inspection: to determine compliance with the Clean Air Act regulations at 40 C.F.R. Part 82 Subpart F: Recycling and Emissions Reduction Facility Type: Recycling Center/Scrapyard Regulations Central to Inspection: 40 C.F.R. Part 82 Subpart F, including 40 C.F.R 82.155 safe disposal of appliances, such as small and motor vehicle air conditioners, and 40 C.F.R 82.156, proper evacuation of refrigerant from appliances. Arrival Time: 3:00 pm Departure Time: 3:50 pm Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet - via email Provided CBI warning to facility The following information was obtained verbally from Leticia Acosta and Tom Crane unless otherwise noted. Process Description: Rocky Mountain Recycling (facility) accepts ferrous and nonferrous material from the general public and commercial vendors. The facility accepts white goods, appliances, motor vehicles, and refrigeration components. When an appliance comes into the facility, personnel inspect the appliance to verify it has been drained of refrigerant. This inspection includes checking if the refrigerant circuitry is not intact within the appliance and if the compressor is removed. If refrigerant is no longer within the appliance, the facility accepts it. The facility accepts vehicles only if upon inspection there are no liquids, such as gasoline and refrigerant, contained within the vehicle. If refrigerant is found intact within an appliance or a vehicle contains liquid, the facility rejects the items. The facility does not recover refrigerant from appliances or motor vehicles. Staff Interview: The facility has 80 employees, including office personnel. Upon acceptance of an appliance, the customer signs a statement either stating that the refrigerant was properly disposed of or had "leaked out" previously. Commercial customers sign the same verification statement as well, but the facility is currently drafting language for a one-year contract. "White Goods" is utilized as a specific code within the inventory of the facility. In an email from August 9th, 2022, the facility stated that this code is utilized to trigger the printing of a CFC verification statement if an appliance is part of a scrap load. Therefore, the use of this code in the facility's inventory indicates that at least one appliance was part of a load. The facility also uses a specific code for air conditioner compressors. The facility accepts approximately 2-3 appliances per day. Approximately 90% of appliances stem from commercial vendors and 10% from the general public. Page 2 of 5 TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: At the entrance to the facility, a sign stated that "air conditioners, refrigerators and freezers must have all refrigerants safely extracted prior to disposals." (Picture 1). At the scale, near the entrance of the scrapyard, a sign stated that "refrigerators with CFCs" were not accepted (Picture 2). A compressor was seen at the main scrap pile with a cut line (Picture 4 and 5). When asked about motor vehicle acceptances, facility personnel stated that there was a separate pile for motor vehicles. Photos and/or Videos: were taken during the inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Copy of a signed CFC form from the past week (6/20-6/24/22), past 2 years (from 2020), and past 3 years (from 2019) Copy of email sent to commercial vendors on acceptance policy/inspections Records of the number of vehicles accepted over the last 3 years (since June 2019) Any records of acceptance of refrigerators, freezers, AC units, radiators, and refrigeration components (compressors, condensers) for the last 3 years, if kept Production records of the amount of scrap shredded over the last 3 years Material acceptance policy Rejection policy, if different from the material acceptance policy During the inspection, Rocky Mountain Recycling stated that there was a CFC contract currently being drafted for commercial vendors. EPA requested the current draft of this contract (as of 6/22/2022). Compliance Assistance: US EPA discussed strategies for not incentivizing customers to vent refrigerant. These include rejecting appliances with cut lines and updating signage to communicate refrigerant recovery requirements. Page 3 of 5 Concerns: US EPA noted to the facility that the current acceptance policy encourages the general public and commercial vendors to cut and vent refrigerant lines. It did not appear that the facility had signage or other notification methods to notify customers that refrigerant must be properly recovered from appliances before delivery to the facility. DIGITAL SIGNATURES VALERIA Digitally signed by VALERIA APOLINARIO Date: 2022.08.11 08:34:02 Report Author: A__P_O__L__IN__A_R__I_O____-_05_'0_0'_____________ Section Supervisor: Digitally signed by Brian Brian Dickens Date: 2022.08.11 10:27:34 Dickens __________________-0_5_'0_0'_____________ Page 4 of 5 Facility Name: Rocky Mountain Recycling Facility Location: 6510 Brighton Blvd, Commerce City, CO 80022 Date of Inspection: June 22, 2022 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log Page 5 of 5 Facility Name: Rocky Mountain Recycling Facility Location: 6510 Brighton Blvd, Commerce City, CO 80022 Date of Inspection: June 22, 2022 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Laura Steel 2. Archival Record Location: Region 5 Electronic Records Center Image Number 1 2 3 4 5 6 File Name IMG_0107.JPG IMG_0108.JPG IMG_0109.JPG IMG_0110.JPG IMG_0111.JPG IMG_0112.JPG Date and Time (incl. Time zone and DST) 2022:06:22 15:30:50 MT 2022:06:22 15:32:12 MT 2022:06:22 15:34:14 MT 2022:06:22 15:35:13 MT 2022:06:22 15:35:43 MT 2022:06:22 15:38:13 MT Description of Image List of Items Not Accepted (at Office Entrance) Signage of Items Not Accepted at Drive-Up Entrance Scrap Pile Compressor on Ground Compressor Cut Line Back of Scrap Pile Appendices Page 1 of 1