Document vV6QwBVLwnLEXg1nwZ4kqrbmw
DATE: SUBJECT: FROM: THRU: TO:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS
77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604
OCT O8 2019
CLEAN AIR ACT INSPECTION REPORT Sims Metal Management, Chicago, Illinois
Vicky Mei, Environmental Engineer AECAB (IL/IN)
Nathan Frank, Section Chief AECAB (IL/IN)
File
BASIC INFORMATION
Facility Name: Sims Metal Management
Facility Location: 2500 S. Paulina Street, Chicago, Illinois
Date of Inspection: September 20, 2019
EPA Inspector: 1. Vicky Mei, Environmental Engineer
Other Attendees 1. Debbie Hays, Central Region SHEC Director, Sims Metal Management (Sims) 2. Richard Trzupek, Principal Consultant, Trinity Consultants 3. David Dempsy, Managing Consultant, Trinity Consultants 4. George Malamis, General Manager, Sims 5. Sam Flores, Plant Manager, Sims 6. Eric Ehlers, Director of Field Operations, Mostardi-Platt 7. Jeremy Carlson, Mostardi-Platt 8. Dan Kossack, Mostardi-Platt 9. Jeff Gross, Mostardi-Platt 10. Rick Sollars, Mostardi-Platt
Contact Email Address: Debbie.Hays@simsmm.com
Purpose of Inspection: Emissions Test Observation
Facility Type: Metal Shredding and Recycling
Arrival Time: 7:45 AM Departure Time: 3:30 PM
Inspection Type:
D Unannounced Inspection
l3l Announced Inspection
OPENING CONFERENCE
l3l Credentials Presented l3l CBI warning to facility provided
The following information was obtained verbally from Sims, Trinity Consultants, or MostardiPlatt staff unless otherwise noted.
Process Description: Sims utilizes a harnmerrnill shredder to shred sheet iron and end-of-life vehicles (ELV) and sort the shredded metals for recycling. For the purposes of the stack test required by Sims Administrative Compliance Order, dated December 17, 2018, Sims installed a temporary enclosure around the under-mill oscillator (UMO) with overlapping rubber sheeting around the UMO, metal sheeting above the mill, and vacuum pulling emissions through the enclosure to ducting with emission testing probes for sample collection and monitoring of particulate matter, volatile organic compounds (VOC), and metals from the mill. Since the initial test on September 5, 2019, Sims added sheeting to an opening along the foundation wall on the south side of the shredder. Any captured particles and objects in the air were discharged through the ducting to a pod with openings that were covered by expanded metal, a mesh filter, and water from a misting hose on the outside of the exhaust point. The fan was operated at 50 hertz during all three stack test runs.
Staff Inten,iew: Sampling and testing occasionally stopped between about zero to three times per run to clean out and/or replace the probes when particles clogged the probes. 300 tons of ELV and sheet metal were consumed during each run. The total hydrocarbon (THC) ranges were very rough estimates, provided at a glance by Mostardi-Platt staff.
Page 2 of 4
Run Estimated start time Estimated end time Estimated THC range
Estimated flow rate
#1 8:54 AM 10:37 AM 20 - 200 ppm, with a I000+ ppm spike near the end of the run 40,000 - 45,000 standard cubic feet ner minute (scfm)
#2 11:27AM 1:14 PM 17 - 180 ppm
47,000 scfm
#3 1:45 PM 3:29PM Sporadic spikes in emissions occurred during run.
47,000 scfm
TOUR INFORMATION
EPA toured the facility: Yes
Data Collected aud Ohservatious: Visible emissions and emissions imaged via the FLIR camera were seen during all three runs. A significant spike in THC concentration occurred near the end of Run #1, as seen in Video #12 (see Appendix A). During Run #2, significantly more emissions were uncaptured, as seen via FLIR camera, (see Videos #13-21 of Appendix A). Videos captured during Run #3 showed sporadic spikes in emissions imaged via the FLIR camera. During Run #3, the wind was blowing west, and the southeast view of the mill provided a better vantage point for observations.
Photos and/or Videos: were taken during the inspection.
Field Measurements: were taken during this inspection. Field Measurements, using EPA Methods 1, 2, 3, 4, 5, 25, and 29 were performed by Mostardi Platt technicians during the course of the emissions testing.
SIGNATURES
Report Author: Section Chief:
Page 3 of 4
Facility Name: Sims Metal Management Facility Location: 2500 S. Paulina Street, Chicago, Illinois Date of Inspection: September 20, 2019
APPENDICES AND ATTACHMENTS
1.
Appendix A: Digital Image Log
Page 4 of 4
Facility Name: Sims Metal Management Facility Location: 2500 S. Paulina Street, Chicago, Illinois Date of Inspection: September 20, 2019
APPENDIX A: DIGITAL IMAGE LOG
l. Inspector Name: Vickv Mei
3. Company/Facility Name:
Sims Metal Management 5. Number of Images:
38
2. Date(s) oflnspection: Seotember 20, 2019
4. Address, City, State: 2500 S. Paulina Street, Chicago, Illinois
6. Archival Record Location: Two USBs, labelled "Sims 09/20/2019 FLIR videos(]) and photos" and "Sims 09/20/2019 FLIR videos(2)"
Digital Photos
Image Number
File Name
Date and
Time
(CST)
Run
9/20/2019
1
P920000 l .JPG 9:32AM #1
9/20/2019
2
P9200002.JPG 9:33 AM #1
9/20/2019
3
P9200003.JPG 9:33 AM #1
9/20/2019
4
P9200004.JPG 9:33 AM #1
Descriotion of Image Visible emissions from top of mill (northwest view); photo taken in between FLIR camera
videos #5 and #6. Visible emission from the middle sorter chute
(northwest view). Visible emission from the middle sorter chute
(northwest view). Visible emissions from top of mill (northwest
view).
FLIR Videos
Incorrect date and ti.me camera settuw but accurate reIali.ve time increments*
Image Number
1
2
File Name MOV 2558.mn4 MOV 2559.mo4
3
MOV 2560.mo4
4
MOV 2561.mn4
5
MOV 2562.mn4
Date and
Time (CST)
*
Run
Descriotion of lma!le
12/31/1999
23:42
#1
Prematurelv ended video (east view).
1/1/2000
0:37
#1
Entire orocess (east view).
Prematurely ended video; digital video only; inlet
1/1/2000
feed to mill (east view); some emissions and
0:41
#1
oeriodic VOC olumes.
1/1/2000
Inlet feed to mill (east view); some emissions and
0:45
#1
oeriodic VOC olumes.
1/1/2000
Inlet feed to mill (east view); some emissions and
0:56
#1
neriodic VOC nlumes.
Appendices Page 1 of 3
Facility Name: Sims Metal Management Facility Location: 2500 S. Paulina Street, Chicago, Illinois Date of Inspection: September 20, 2019
Top of mill enclosure (northwest view); periodic
1/112000
VOC plumes from mill; visible steam from middle
6
MOV 2563.mn4
1 :04
#1
sorter chute onening.
1/1/2000
7
MOV 2564.mn4
1 :13
#1
Ton of mill enclosure (northwest view).
1/1/2000
8
MOV 2565.mn4
1:26
#]
Ton of mill enclosure (northwest view).
Top of mill enclosure (northwest view); with
1/1/2000
inverted polarity auto camera mode and high-
9
MOV 2566.mn4
1:29
#1
sensitivity mode.
1/1/2000
10
MOV 2567.mn4
1:31
#1
Ton of mill enclosure <northwest view).
Top of mill enclosure (northwest view);
1/1/2000
alternating between auto camera mode and high-
11
MOV 2568.mn4
1:37
#1
sensitivitv mode.
End of sorter chute; emissions seen; during near
1/1/2000
the end of Run #1 and may be during the 1000+
12
MOV 2569.mn4
1:47
#1
nnm THC snike.
1/1/2000
Top of mill (northeast view); significants amounts
13
MOV 2570.mn4
3:12
#2
of emissions seen.
1/1/2000
Top of mill (northeast view); significants amounts
14
MOV 2571.mn4
3:29
#2
of emissions seen.
1/1/2000
Top of mill (northeast view); significants amounts
15
MOV 2572.mn4
3:37
#2
of emissions seen.
1/1/2000
16
MOV 2573.mn4
3:47
#2
Top of mill (northwest view).
1/1/2000
Top of mill (northwest view); significant amounts
17
MOV 2574.mn4
3:51
#2
of emissions seen.
1/1/2000
18
MOV 2575.mn4
4:02
#2
Top of mill (northwest view); emissions seen.
1/1/2000
19
MOV 2576.mn4
4:15
#2
Ton of mill (northeast view); emissions seen.
1/1/2000
20
MOV 2577.mn4
4:20
#2
Ton of mill (northeast view); emissions seen.
1/1/2000
21
MOV 2578.mn4
4:26
#2
Ton of mill (northeast view); emissions seen.
1/1/2000
Pod discharge point, sorter chutes, top of mill (east
22
MOV 2579.mn4
4:29
#2
view).
1/1/2000
23
MOV 2580.mn4
4:39
#2 Inlet feed to mill (east view); neriodic emissions.
1/1/2000
24
MOV 2581.mn4
5:38
#3
Inlet feed to mill (east view).
1/1/2000
25
MOV 2582.mn4
5:42
#3
Ton of mill and sorter chutes (northeast view).
Appendices Page 2 of 3
Facility Name: Sims Metal Management Facility Location: 2500 S. Paulina Street, Chicago, Illinois Date of Inspection: September 20, 2019
26 27 28
29 30 . 31 32 33 34
MOV 2583.mn4 MOV 2584.mo4 MOV 2585.mn4
MOV 2586.mn4 MOV 2587.mo4 MOV 2588.mn4 MOV 2589.mo4 MOV 2590.mn4 MOY 2591.mn4
1/1/2000 5:44
1/1/2000 5:52
1/1/2000 5:58
1/1/2000 6:03
1/1/2000 6:10
1/1/2000 6:13
1/1/2000 6:17
1/1/2000 6:24
1/1/2000 6:29
Top of mill and sorter chutes (northeast view from
#3
further south).
#3
Too of mill (northwest view).
Top of mill (northwest view); wind was blowing
#3
west; noor view.
Top of mill, sorter chutes, sorted metals outlets
(northwest view); wind was blowing west; poor
#3
view.
#3
Accidental blank video with lens cao on.
#3
Too of mill and sorter chutes (northeast view).
Pod discharge point, sorter chutes, top of mill (east
#3
view).
Inlet chute to mill (southeast view); wind blowing
#3
west; emissions seen.
Inlet chute to mill (southeast view); wind blowing
#3
west; emissions seen.
Appendices Page 3 of 3