Document re1Loo0v007ajGvre7rq6EnDa

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Strong Steel - Ferrous Processing & Trading Co., Detroit, Michigan Brittany Cobb, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Supervisor AECAB (MI/WI) File BASIC INFORMATION Facility Name: Strong Steel - Ferrous Processing & Trading Co. Facility Location: 6464 Strong St, Detroit, MI 48211 Date of Inspection: 8/16/2022 EPA Inspector(s): 1. Brittany Cobb, Environmental Engineer 2. Natalia Vazquez, Environmental Engineer Other Attendees: 1. Nick Milantoni, Manager Contact Email Address: nick.milantoni@fptscrap.com Purpose of Inspection: Determine compliance with the Clean Air Act Facility Type: Recycling center Regulations Central to Inspection: 40 C.F.R. Part 82, Subpart F, Recycling and Emissions Reductions Arrival Time: 8:30 AM CT Departure Time: 10:35 AM CT Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility The following information was obtained verbally from Nick Milantoni unless otherwise noted. Company Ownership: The facility was recently purchase by Cleveland Cliffs. Process Description: Strong Steel - Ferrous Processing & Trading Co. (Strong Steel) is a scrapyard that accepts postconsumer ferrous and non-ferrous metals. The facility accepts white goods/appliances, vehicles, and A/C radiators. Material is weighed and then shredded on site. The facility has one shredder with a water spray control system for dust. Staff Interview: Strong Steel has 27 employees at this location and operates Monday through Friday 6:30 AM to 4:30PM, and occasionally Saturdays. Strong Steel has been accepting white goods/appliances for at least four years. The facility accepts 5 to 40 white goods/appliances per day and typically denies the goods if the lines are cut. The scale operator visually inspects for cut lines. The facility does not accept refrigeration components. Strong Steel mostly accepts white goods/appliances from individuals and other scrapyards, the only regular commercial costumer the facility accepts from is Tristar. Greg Maglocklen, a Strong Steel employee, is responsible for recovering the refrigerant. The facility keeps an inventory of the amount of refrigerant recovered but not the number of white goods/appliances accepted. Strong Steel has been accepting vehicles and A/C radiators for approximately 20 years. The facility accepts 15 to 30 vehicles per day. The facility accepts vehicles from individuals and about 50 different commercial costumers regularly. Most vehicles come in crushed and therefore they don't contain refrigerant. If the vehicles and A/C radiators contain refrigerant, Strong Steel employees recover the refrigerant. The facility keeps a daily inventory of the vehicles accepted and amount of refrigerant recovered. The facility keeps an inventory of the amount of refrigerant recovered from the A/C radiators but not the number of A/C radiators accepted. Page 2 of 5 Strong Steel sends it recovered refrigerant to Golden Refrigerant and keeps a monthly inventory of the amount sent. The facility sends batteries to Earl's Battery & Charging Service and mercury switches to ELVS Mercury Switch Recycling Program. Strong steel has a CFCs agreement form for white goods/appliances accepted from individuals. Strong steel does not have a CFCs agreement form for vehicles or A/C radiators accepted from individuals. Nick Milantoni was unsure if the facility has contracts for companies that bring vehicles or for Tristar. Strong Steel shreds Monday through Friday 7:30 AM to 4:30 PM and occasionally Saturday if need be. The operators manually select a high, medium, or low setting for the water spray control system and then the water flow rate is automatically determined by amps. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA was led on a tour by Nick Milantoni. EPA requested Strong Steel pull refrigerators off the pile of material that was being shredded with a material handler machine. The machine operator pulled 11 refrigerators out of the pile. EPA looked at the condensers on the appliances where the refrigerant is stored. Three of the refrigerators clearly had cut lines. Six of the refrigerators appeared to still contain refrigerant, as the lines were not cut and there was no indication that the refrigerant was recovered. One of the refrigerators had a puncture hole in the condenser lines and a sticker on the refrigerator that indicated the refrigerant was recovered. One of the refrigerators contained refrigerant that Nick Milantoni vented when he broke one of the condenser lines. EPA viewed smoke and steam coming from the shredder. EPA recorded Forward Looking InfraRed (FLIR) videos that show volatile organic compounds (VOCs) being released to the atmosphere. The water spray control system was running 35 gallons of water per minute. Photos and/or Videos: were taken during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Verification form for white goods/appliances CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Page 3 of 5 Requested documents: Copy of the CFCs agreement form for white goods/appliances Amount shredded in 2020 and 2021 (tons/month) Invoices for refrigerant sent to Golden Refrigerant from January 1, 2020 to August 16, 2022 Contractor verification forms Emission calculations Concerns: EPA identified concern with white goods/appliances being shredded that contain refrigerant EPA identified concern with Strong Steel accepting white goods/appliances with condenser lines cut EPA identified concern with Strong Steel's verification statement form for appliances not containing required information from 40 C.F.R. 82.150 - 82.169 EPA identified concern with Strong Steel not having verification statements for vehicles or A/C radiators EPA identified concerns with smoke and VOCs being released to the atmosphere from the shredder DIGITAL SIGNATURES Digitally signed by Brittany Cobb Date: 2022.09.27 Brittany Cobb Report Author: _________________0_9:_00_:5_0 -_05_'0_0'_________ Section Supervisor: SARAH Digitally signed by SARAH MARSHALL MARSHALL 09:07:48 -05'00' Date: 2022.09.27 __________________________________ Page 4 of 5 Facility Name: Strong Steel Facility Location: 6464 Strong St, Detroit, MI Date of Inspection: August 16, 2022 APPENDICES AND ATTACHMENTS A. Digital Image Log B. FLIR Video Log Page 5 of 5 Facility Name: Strong Steel Facility Location: 6464 Strong St, Detroit, MI Date of Inspection: August 16, 2022 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Brittany Cobb Image Number 1 2 3 4 5 6 7 8 9 10 11 File Name IMG_0126.JPG IMG_0127.JPG IMG_0128.JPG IMG_0129.JPG IMG_0130.JPG IMG_0131.JPG IMG_0132.JPG IMG_0133.JPG IMG_0134.JPG IMG_0135.JPG IMG_0136.JPG 12 IMG_0137.JPG 2. Archival Record Location: https://usepa.sharepoint.com/:f:/r/sites/R5_Work/r5erc/ecad/AE CAB%20Library/Enf_Strong%20Steel%20Products_MI_22/Enf _Strong%20Steel_MI_22_Inspection/Photos?csf=1&web=1&e= fUWNLv Date and Time (incl. Time zone and DST) 2022:08:16 08:34:18 2022:08:16 08:45:53 2022:08:16 08:46:12 2022:08:16 08:46:27 2022:08:16 08:47:36 2022:08:16 08:47:46 2022:08:16 08:48:04 2022:08:16 09:16:44 2022:08:16 09:19:48 2022:08:16 09:20:13 2022:08:16 09:31:46 2022:08:16 09:33:01 Description of Image Company sign at entrance Sign at scales stating "All fluids must be drained from vehicles" Signs at scales Sign at scales stating refrigerants (CFCs) must be removed from A/C units Sign at scales stating "All fluids must be drained from vehicles" Signs at scales Sign at scales stating refrigerants (CFCs) must be removed from A/C units Refrigerator with refrigerant that was not recovered Refrigerator with refrigerant that was not recovered Refrigerator with refrigerant that was not recovered Refrigerator with puncture hole where CFCs was properly recovered Sticker on refrigerator (from IMG_0136.JPG) indicating the refrigerant was properly recovered Appendices Page 1 of 3 Facility Name: Strong Steel Facility Location: 6464 Strong St, Detroit, MI Date of Inspection: August 16, 2022 13 IMG_0138.JPG 2022:08:16 09:33:09 14 IMG_0139.JPG 2022:08:16 09:33:20 15 IMG_0140.JPG 2022:08:16 09:34:35 16 IMG_0141.JPG 2022:08:16 09:35:35 17 IMG_0142.JPG 2022:08:16 09:36:14 18 IMG_0143.JPG 2022:08:16 09:36:30 19 IMG_0144.JPG 2022:08:16 09:37:35 20 IMG_0145.JPG 2022:08:16 09:38:50 21 IMG_0146.JPG 2022:08:16 09:39:56 22 IMG_0147.JPG 2022:08:16 09:42:05 23 IMG_0148.JPG 2022:08:16 09:50:55 24 IMG_0149.JPG 2022:08:16 09:54:01 25 IMG_0150.JPG 2022:08:16 09:55:20 26 IMG_0151.JPG 2022:08:16 10:00:24 27 IMG_0152.JPG 2022:08:16 10:05:20 28 IMG_0153.JPG 2022:08:16 10:09:26 29 IMG_0154.JPG 2022:08:16 10:09:47 Refrigerator with lines cut Refrigerator with lines cut Refrigerator with refrigerant that was not recovered Refrigerator with lines intact and refrigerant still in the unit Refrigerator (from IMG_0141.JPG) after Nick Milantoni broke the lines and released refrigerant (white foam can be seen) Refrigerator with lines cut Refrigerator with refrigerant that was not recovered Refrigerator with refrigerant that was not recovered Refrigerator with lines cut Refrigerator with lines cut Shredder with steam and smoke Shredder with steam and smoke ERROR Shredded material pile CFC recovering equipment CFC recovery equipment CFC recovery cylinder Appendices Page 2 of 3 Facility Name: Strong Steel Facility Location: 6464 Strong St, Detroit, MI Date of Inspection: August 16, 2022 APPENDIX B: FLIR VIDEO LOG 1. Inspector Name: Brittany Cobb 2. Archival Record Location: https://usepa.sharepoint.com/:f:/r/sites/R5_Work/r5erc/ecad/AE CAB%20Library/Enf_Strong%20Steel%20Products_MI_22/Enf _Strong%20Steel_MI_22_Inspection/FLIR?csf=1&web=1&e= mpkgy3 Video Number 1 2 3 4 5 File Name MOV_2781.mp4 MOV_2782.mp4 MOV_2783.mp4 MOV_2784.mp4 MOV_2785.mp4 Date and Time (incl. Time zone and DST) 2022:08:16 09:41:06 2022:08:16 09:42:34 2022:08:16 09:49:26 2022:08:16 09:52:50 2022:08:16 09:55:12 Description of Image Shredder behind building Shredder behind building Shredder Shredder Shredder Appendices Page 3 of 3