Document wD37yY00e3rN09gp3qo2Mb9y3

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEYARD CHICAGO, ILLINOIS 60604 OCT 0 7 2019 CLEAN AIR ACT INSPECTION REPORT Rifkin Scrap Iron and Metal, Co., Saginaw, Michigan David Suttin, Environmental Engineer AECAB (MN/OH) Brian Dickens, Section Chief AECAB (MN/OH) File BASIC INFORMATION Facility Name: Rifkin Scrap Iron and Metal, Co. Facility Location: 1011 N. Washington Avenue, Saginaw, Michigan Date of Inspection: August 20, 2019 EPA Inspector(s): 1. David Sutlin, Environmental Engineer 2. Manojkumar Patel, Environmental Engineer Other Attendees 1. Larry Rifkin, Chairman of the Board, Rifkin 2. Jan Hoffman, CFO, Rifkin 3. David Rifkin, CEO/President, Rifkin (by phone) Contact Email Address: Dsrifkin@rifkin-co.com Purpose of Inspection: Torch cutting inspection Facility Type: Scrap metal recycling Regulations Central to Inspection: Michigan SIP Arrival Time: 12:00 PM Departure Time: 12:45 PM Inspection Type: ~ Unannounced Inspection D Announced Inspection OPENING CONFERENCE ~ Credentials Presented ~ CBI warning to facility provided The following information was obtained verbally from Rifkin unless otherwise noted. Process Description: This facility accepts scrap metal including steel pieces, which are cut using shears. The facility uses propaoe/oxygen torches to cut pieces, such as plate steel, that cannot be cut using shears. Once the scrap is cut down to size, it is resold. The facility has less thao 20 employees aod torchcuts less thao 150 tons of metal per year. Staff Interview: To control emissions from torch cutting, the facility has constructed a fixed enclosure, which exhausts to ao emission control system. The enclosure's footprint is approximately 12 feet by 16 feet aod accommodates a single torch-cutter. The enclosure consists of sheet metal covering three sides, aod the forth side is comprised of doors that swing partially open during torch cutting, for safety purposes. To load scrap into the enclosure, the enclosure's roof is temporarily removed using a magnet hung from a craoe. The control system consists of a set of filters, followed by a fao, aod then a stack. The facility had experimented with furnace-like filters which did not work well according to David Rifkin. At the time ofthe inspection, the facility was plaoning to install baffles upstream of the filters in order to knock down heavier particles aod to test new types of filters, which were expected to be more resilient. TOUR INFORMATION EPA toured the facility: Yes Data Collected and Observations: EPA inspected the torch-cutting enclosure aod observed several metal pieces on the ground inside the enclosure, that had appeared to have been torch-cut. EPA did not observe aoy torchcutting taking place during the inspection. Behind the enclosure, EPA observed ductwork leading to the fao and then to the exhaust stack. The original filters referenced by David Rifkin had been removed. Photos and/or Videos: were taken during the inspection. Page 2 of 4 Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Requested documents: Specifications/diagrams for the emission capture and control system ::::::::r: --1-,L-_=;;:C.'--1'..,i.--+.\(i.-\i.-.\i.-\---':1i.-.,.r'-'-}_\i.--=~----Date: - ~ 1 11 1 __~!_l_i_- 1 Section Chief: --''ch~7)_""""1,;'--"#rc::."-""-=)=:;::..:.,1:J"'-'~ ,-' " - = - - - - - - - Date: __[_o_f,_{(_q_ _ Page 3 of 4 Facility Name: Rifkin Scrap Iron and Metal, Co. Facility Location: 1011 N. Washington Avenue, Saginaw, Michigan Date of Inspection: August 20, 2019 APPENDICES AND ATTACHMENTS Appendix A: Digital Image Log Page4 of4 Facility Name: Rifkin Scrap Iron and Metal, Co. Facility Location: 1011 N. Washington Avenue, Saginaw, Michigan Date of Inspection: August 20, 2019 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Manoikumar Patel 3. Company/Facility Name: Rifkin Scrao Iron and Metal, Co. 5. Number of Images: 7 2. Date(s) of Inspection: August 20, 2019 4. Street Address, City, State: 1011 N. Washinoton Avenue, Sa2:inaw, Michigan 6. Archival Record Location: CD-R labeled as "Rifkin, Saginaw, MI; 8-20-19 Insnection; Photos" Image Number 1 2 3 4 5 6 7 File Name P8200072.JPG Date and Time (incl. time zone and DST) 8/20/2019 11:16 P8200073.JPG P8200074.JPG P8200075.JPG P8200076.JPG P8200077.JPG P8200078.JPG 8/20/2019 11:16 8/20/2019 11:16 8/20/2019 11 :18 8/20/2019 11:18 8/20/2019 11:19 8/20/2019 11:19 Descrintion of Image Scrao inside torch-cutting enclosure Exhaust ports and ductwork inside torch-cutting enclosure Close-no of exhaust norts Torch-cutting exhaust stack Torch-cutting exhaust fan Ductwork connecting enclosure to exhaust fan Exterior of torch-cutting enclosure Appendices Page 1 of 1