Document rkzbQ8jYngkK4bpGNLRLr2y7

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET SW ATLANTA, GEORGIA 30303-8960 SENT VIA ELECTRONIC MAIL Henry Miller General Manager Liberty Recycling 2664 24th St Tuscaloosa, Alabama 35401 Henrymiller1234@yahoo.com Dear Mr. Miller: On May 25, 2022, the U.S. Environmental Protection Agency Region 4 Air Enforcement Branch conducted a partial compliance inspection of Liberty Recycling, located in Tuscaloosa, Alabama. Enclosed is a copy of the final report generated by the U.S. Environmental Protection Agency's Region 4, North Air Enforcement Section. Should you have questions regarding this inspection report, contact me at (404) 562-9177, or by email at Rieck.Stephen@epa.gov. Sincerely, STEPHEN RIECK Digitally signed by STEPHEN RIECK Date: 2022.07.20 07:40:17 -04'00' Stephen Rieck Environmental Scientist North Air Enforcement Section Enclosure cc: Jennifer Youngpeter, Alabama Department of Environmental Mangement United States Environmental Protection Agency (EPA) Region 4 Air Enforcement Branch Inspection Report I. GENERAL INFORMATION Facility Name: Liberty Recycling Location (Address): 2664 24th St., Tuscaloosa, Alabama Inspection Date: May 25, 2022 Type of Inspection (Full or Partial Compliance Evaluation): Partial Compliance Evaluation PROGRAMMATIC ID: 01-125-00122 PERMIT NUMBER: Synthetic Minor Permit #413-0122-X001 EPA Region 4 Investigator(s)/Inspector(s): 1. David Lloyd, Environmental Engineer 2. Steve Rieck, Environmental Scientist 3. Brian Zhong, Environmental Engineer State/Local Investigator(s)/Inspector(s): 1. Jackson Rogers, Environmental Engineer 2. JP Gravitt, Environmental Engineer Person(s) Contacted at Facility (Name and Title): 1. Henry Miller, General Manager Report Prepared by: Stephen Rieck Project Name: Liberty Recycling Tuscaloosa ICIS/Project No.: AL0112500122-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 1 of 13 FACILITY INFORMATION A. Facility and Permit Information Facility and Permit Information Comments 1. Type of facility (e.g., chemical plant, refinery, cement manufacturer, etc.). 2. Air permit number(s) and type of permit (e.g., Title V, PSD, Synthetic Minor, etc.). 3. Air permit issuance date. Metal Service Centers and Other Metal Merchant Wholesalers; Automobile and Scrap Metal Shredding and material recovery processes ADEM SMOP #413-0122-X001 May 27, 2022 4. Air permit expiration date. No Expiration Date 5. Facility classification (Major, Synthetic Minor/Conditional Major, Minor). 6. Major source pollutants (if applicable). 7. Applicable regulations (e.g., State Implementation Plan, MACT Subpart FFFF, NSPS Subpart EEEE, etc.). 8. Types of air emission points (e.g., tanks, process vents, boilers, etc.). 9. Types of air pollution control equipment (e.g., baghouse, scrubber, afterburner, etc.). Synthetic Minor N/A State Implementation Plan 40 C.F.R. Part 82 Metal shredder mill Water spraying at the mill reduces internal temperatures and reduces particulate matter emissions. B. Process Description Liberty Recycling owns and operates a scrap metal recycling facility in Tuscaloosa, Alabama. The facility provides scrap metal recycling services for industrial businesses, small businesses, and individuals. The facility purchases scrap metal materials, including automobiles, appliances, all grades of steel, and industrial metal scrap. Project Name: Liberty Recycling Tuscaloosa ICIS/Project No.: AL0112500122-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 2 of 13 After purchase, metal scrap is sorted and prepared for recycling, which can include cutting or shearing of metal. The facility operates a 6,300-horsepower metal shredder. The metal shredder is equipped with a water spraying system to prevent fires and minimize heat and particulate matter emissions. Scrap that has been shredded through the metal shredder is separated by downstream processing into ferrous, nonferrous, and automotive shredder residue (ASR). After the metal scrap has been processed it will be sold to recycled scrap metal buyers. II. INSPECTION ACTIVITIES Activity Opening Meeting 1. Date and time entered the facility. 2. Credentials presented to facility personnel (include name and title). 3. Conducted an opening meeting to explain the purpose and objectives of the inspection. Yes No NA Y Y Y Comments EPA Region 4 (R4) inspectors arrived at the facility on May 25, 2022, at 8:30 AM CST. All inspectors presented their credentials to Henry Miller, General Manager. Inspectors held an opening meeting during which the purpose and objectives of the inspection were explained. EPA inspectors discussed the EPA July 2021 Enforcement Alert, "Violations at Metal Recycling Facilities Cause Excess Emissions in Nearby Communities." The inspection team discussed intent to observe all accessible process areas at the facility and to understand how scrap was received and inspected to ensure material met facility and federal standards. The facility is planning to re-locate their shredder operation to an area further out of town. The facility is currently seeking authorization to operate at the new location. Project Name: Liberty Recycling Tuscaloosa ICIS/Project No.: AL0112500122-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 3 of 13 Activity 4. Discussed safety issues. Yes No NA Y 5. Discussed which records to be N reviewed. 6. Discussed the facility walk- Y through and the areas to be observed in the facility. 7. Discussed facility policy Y regarding photographs or video (if applicable). 8. Discussed the use of the N/A infrared camera, TVA, PID, and any other equipment. 9. Discussed CBI. Y Records Reviewed at the Facility 10. The types of records reviewed, N and the time period reviewed. Facility Walk-Through Observations Comments Inspectors discussed facility-specific safety and emergency procedures and appropriate protective equipment. The inspection team did not review records during the on-site inspection. The team indicated that records may be requested through use of a Section 114(a) information request. Inspectors were primarily interested in inspection of the metal shredder operation, scrap handling, and refrigerant handling procedures. Region 4 inspectors indicated a digital camera would be used during the inspection. The team discussed facility policy regarding photography and videography. Inspectors indicated that copies of any videos or photographs taken at the facility would be sent to the company. A log of photographs taken at the facility is included in this report. See Appendix A. EPA inspectors indicated that any material claimed to be Confidential Business Information (CBI) would be treated in accordance with regulations. The inspection team did not review records during the inspection. Project Name: Liberty Recycling Tuscaloosa ICIS/Project No.: AL0112500122-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 4 of 13 11. The process equipment Y observed and the associated operational rate observed (e.g., Furnace 1 production rate was 5 lbs/hr on 1/1/15, at 2:00 pm - permit requires max rate at 6 lbs/hr). Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. Project Name: Liberty Recycling Tuscaloosa ICIS/Project No.: AL0112500122-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 5 of 13 EPA Region 4 inspectors conducted an inspection of process areas, including the metal shredder operations and scrap sorting piles, beginning at approximately 9:30 AM CST. Due to heavy rains, some parts of the facility were not accessible. The facility purchases scrap metal materials, including automobiles, appliances, and miscellaneous metal parts from industrial suppliers as well as the general public. The large majority of received scrap comes from commercial suppliers. These suppliers enter into verbal contracts with Liberty Recycling, agreeing that scrap does not contain material prohibited by the facility. The inspection team observed the scrap piles. The scrap consisted of crushed cars and miscellaneous metal parts. The crushed cars did not have any fluid or freoncontaining equipment. The team did not observe any freon-containing appliances in the piles. Signage of materials the facility does not accept is posted in several locations near the facility entrance and adjacent to the scale. The facility loader operators review scrap for prohibited material before loading onto the shredder intake. The facility operates a 6,300-horsepower shredder. The shredder has one active engine and one backup engine. The facility is permitted to process up to 80 tons of scrap per hour but generally operates at 50 tons per hour. The shredder operates each weekday, usually from 8:00 AM - 2:30 PM. Scrap that has been shredded is separated Activity Yes Comments No NA by downstream processing into ferrous materials, nonferrous materials, and ASR. The inspection team observed shredder operations. A small amount of opacity (approximately 5%) was observed from the shredder outlet. The facility is permitted a general 20% opacity standard. Liberty Recycling does not provide ozone depleting substance recovery and recycling services on site, nor does the facility retain a contract with a certified technician. The inspection team went to the maintenance yard where approximately ten 6,300-horsepower engines are stored and maintained. These engines may be used as part of operations at the new shredder location. . Project Name: Liberty Recycling Tuscaloosa ICIS/Project No.: AL0112500122-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 6 of 13 Activity 12. The type of process parametric monitoring observed and the associated value observed (e.g., Furnace 1 flux injection rate was 200 lbs/batch at 1/1/15, at 2:00 pm - permit requires max rate at 225 lbs/batch). Yes No NA N/A Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. 13. If process equipment or N/A parametric monitoring equipment was not operating, state the reason by facility personnel why the equipment was not operating. Comments Project Name: Liberty Recycling Tuscaloosa ICIS/Project No.: AL0112500122-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 7 of 13 Activity 14. The type of air pollution control equipment, the process equipment it is controlling, and the associated parametric monitoring value observed (e.g., baghouse pressure drop, temperature, scrubber flow rate, etc.). Yes No NA Y (For example - RTO 1 controlling furnace 1, 1,500 degrees F on 1/1/15, at 2:00 pm - permit requires 1,400 degree F or higher). Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. Comments The facility operates a water spraying system at the shredder. The primary function is heat reduction and preventing combustion, but it is also used to reduce particulate matter emissions. Project Name: Liberty Recycling Tuscaloosa ICIS/Project No.: AL0112500122-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 8 of 13 Activity 15. Continuous emissions monitoring devices and values observed. (e.g., CEMS, COMs, etc.). Yes No NA N/A Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. 16. If air pollution control N/A equipment was not operating, state the reason by facility personnel why the equipment was not operating. 17. Capture and collection system N/A (enclosures and hoods) observations, if applicable (e.g., the magnitude and duration of emission escaping capture from the hood). Comments Project Name: Liberty Recycling Tuscaloosa ICIS/Project No.: AL0112500122-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 9 of 13 Activity 18. Ductwork transferring the emissions to the air pollution control device observations, if applicable (e.g., the magnitude and duration of emission escaping from the ductwork, holes or deterioration in ductwork, no deterioration observed, etc.). Yes No NA N/A Comments 19. Any existing unpermitted N emission points, new unpermitted emission points, or non-permitted construction activities observed. (if yes, describe in the comments field). 20. Were any visible emissions Y observed? (if yes, identify the location and equipment). 21. Was a Method 9 reading N performed? (if yes, identify the location and equipment). The inspection team discussed the 2021 Enforcement Alert with the facility. The Alert indicates shredding operations may have significant Volatile Organic Compound (VOC) emissions due to the high temperatures in the shredder. The facility has not conducted any testing to determine VOC emissions at the shredder. Approximately 5% opacity was observed at the shredder. The facility is subject to a 20% opacity standard. 22. Was the cause of the visible Y emissions investigated and the information documented? The observed opacity is a result of shredding operations. Project Name: Liberty Recycling Tuscaloosa ICIS/Project No.: AL0112500122-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 10 of 13 Activity 23. Was a Method 22 performed for visible emissions? (if yes, identify the location and equipment). Yes No NA N Comments 24. Identify the cause of the visible N/A emissions as explained by facility personnel, if applicable. 25. Was the infrared camera used? N If so, attach the video log (which includes the equipment ID, and the date and time the video was recorded) and videos to this report. 26. Was the TVA used? If so, N identify the equipment monitored and the results. Provide the date and time the information was recorded by the inspector. Include actual instrument readings for each piece of equipment monitored above the leak definition and/or where the infrared camera identified a release. An attachment may be used for a large amount of information. EPA R4 inspectors did not use an infrared camera at the facility. EPA R4 inspectors did not use a TVA at the facility. Project Name: Liberty Recycling Tuscaloosa ICIS/Project No.: AL0112500122-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 11 of 13 Activity 27. Was the PID used? If so, identify how the PID was used and the results. Yes No NA N Provide the date and time the information was recorded by the inspector. An attachment may be used for a large amount of information. Closing Meeting 28. Conducted a closing meeting. Y 29. Summarize any additional N/A information needed, if applicable? 30. Accept a declaration of CBI, if N/A applicable? 31. Discussed observations. Y 32. Discussed next steps, if Y applicable? 33. Date and time inspection concluded. Miscellaneous 34. Include any additional N/A observations, if applicable. Comments EPA R4 inspectors did not use a PID at the facility. EPA Region 4 inspectors conducted a closing meeting on May 25, 2022, at 10:50 AM CST with Mr. Miller. Inspectors thanked facility personnel for their time and summarized inspection activities. The inspection team did not observe any scrap that appeared to contain refrigerants, petroleum products or other materials that are prohibited by the facility or federal standards. A final inspection report from EPA Region 4 will be sent to the company within a 60day timeframe. The inspection concluded on May 25, 2022, at 11:10 AM CST. Project Name: Liberty Recycling Tuscaloosa ICIS/Project No.: AL0112500122-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 12 of 13 EPA Investigator/Inspector Signature: EPA Supervisor Signature & Title: STEPHEN Digitally signed by STEPHEN RIECK RIECK Date: 2022.07.20 07:40:58 -04'00' ___________________________________ JASON Digitally signed by JASON DRESSLER _D__R_E_S__S_L_E__R________-0_4_'0_0'_____________ Date: 2022.07.20 11:09:24 Chief, North Air Enforcement Section Project Name: Liberty Recycling Tuscaloosa ICIS/Project No.: AL0112500122-2022 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 13 of 13 APPENDICES AND ATTACHMENTS 1. Appendix A. Inspection Photograph log Appendix A: Inspection Photograph Log During the May 25, 2022, inspection, EPA Region 4 staff used a digital camera to take photographs at the Liberty Recycling, located in Tuscaloosa, Alabama. Below is an inventory of the images. Table 1: Photographs taken during the May 25, 2022, inspection. File Number P5250405.jpg P5250406.jpg P5250407.jpg P5250408.jpg P5250409.jpg P5250410.jpg P5250411.jpg P5250412.jpg P5250413.jpg P5250414.jpg P5250415.jpg P5250416.jpg Image Description Scrap piles Car scrap and shredder intake Shredder loading operation Shredder operation Back end of shredder operation Back end of shredder operation Rotary scrap separator Rotary scrap separator Shredder operation Inaccessible area due to heavy rain 6,300-horsepower EMD engine Prohibited material signage