Document jyGMqrJ92MeGv05QxDpjg4NKR

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 APR 1 5 2019 CLEAN AIR ACT INSPECTION REPORT Cohen Recycling - Hamilton, Hamilton, Ohio Natalie Topinka, Enviromnental Scientist AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Cohen Recycling - Hamilton Facility Location: 105 Black Street Hamilton, Ohio Date of Inspection: March 18, 2019 EPA Inspector(s): 1. Natalie Topinka, Environmental Scientist 2. Scott Connolly, Environmental Engineer Other Attendees 1. Ryan Hill, Operations Manager, Cohen 2. Jason DeDario, Director of Safety, Cohen (via phone) Contact Email Address: jdedario@cohenusa.com, rhill@cohenusa.com Purpose of Inspection: Assess compliance with 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: 9:30 am Departure Time: 10:30 am Inspection Type: l:zl Unannounced Inspection D Announced Inspection OPENING CONFERENCE l:zl Credentials Presented l:zl CBI warning to facility provided The following information was obtained verbally from Cohen representatives unless otherwise noted. Process Description: Cohen Recycling- Hamilton accepts ferrous and non-ferrous metals for recycling from the general public and commercial accounts. The facility accepts small appliances and receives approximately 200 cars per month. Although it had previously been done, no fluids removal from cars occurs at the Hamilton location. The cars undergo a "soft crush" before being moved to Cohen's West Carrollton location for fluids processing. Staff Interview: Mr. Hill stated that until this point, Cohen's procedure for accepting appliances is that the compressor must be removed. He was not sure of any local entity to where customers could be referred to have the refrigerant properly recovered. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: A sign at Cohen's front entrance listed items not accepted, which included "Appliances with Compressors." We observed several refrigerators on the scrap pile. One that was accessible had its compressor attached but with cut refrigerant lines and no sign of refrigerant recovery. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Requested documents: Copy of draft policy regarding refrigerant-related scrap (provided via e-mail March 18, 2019) Page 2 of 4 Compliance Assistance: We gave an overview of the regulatory requirements and compliance options in 40 C.F.R. Part 82, Subpart F. Via phone, Mr. DeDario stated that Cohen was in the process of implementing a new company-wide policy regarding the inspection, acceptance and handling of scrap that contains or once contained refrigerants. Cohen undertook this change after receiving a warning letter from EPA in late February regarding refrigerant handling at its Norwood yard. At the time of our visit, the new policy had not yet been rolled out to each of Cohen' s yards. Concerns: We described how requiring the compressor to be out of the appliance, or requiring that the refrigerant lines must be cut, effectively encourages customers to release the refrigerant to the atmosphere prior to bringing the item to Cohen. S IGNATURES Report Author~ ~ 211'lh y-;:?/ / 7 Section Chief: ~ ~ Date: 'f/o/1 1 Date: ~ b Page 3 of 4 Facility Name: Cohen Recycling- Hamilton Facility Location: 105 Black Street, Hamilton, Ohio Date of Inspection: March 18, 2019 APPENDICES AND ATTACHMENTS I. Digital Image Log Page 4 of 4 Facility Name: Cohen Recycling-Hamilton Facility Location: 105 Black Street, Hamilton, Ohio Date of Inspection: March 18, 2019 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Scott Connolly 3. Company/Facility Name: Cohen Recycling - Hamilton 5. Number of Images: 7 2. Date(s) oflnspection: March 18, 2019 4. Street Address, City, State: 105 Black Street, Hamilton, Ohio 6. Archival Record Location: CD-R labeled as Cohen - Hamilton Inspection photos, March 18, 2019 Image Number File Name Date and Time {CST) Latitude and Longitude Description of Image 1 RI MG0001.J PG 3/18/2019 8:50 N/A Cohen Hamilton front entrance and signage 2 RIMG0002.JPG 3/18/2019 8:52 N/A Wide-angle view of appliances on scrap pile 3 RI MG0003.J PG 4 RIMG0004.JPG 5 RI MG000S.J PG 6 RlMG0006.JPG 7 RIMG0007.JPG 3/18/2019 8:52 3/18/2019 8:54 3/18/2019 8:56 3/18/2019 9:00 3/18/2019 9:00 N/A 39.406888, -84.558587 39.4068, -84.558843 39.406173, -84.557662 39.406165, -84.557657 Pallet burning Refrigerator compressor with cut lines and R-134a label Another refrigerator compressor with cut lines and R-134a label Wide angle view of car processing station (fluids removal no longer active) Vehicles on-site Appendices Page 1 of 1