Document x5K2D0z4XxeD2rD29aQ7k64R6

DATE: SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEYARD CIDCAGO, ILLINOIS 60604 NOV 2 t 2018 CLEAN AIR ACT INSPECTION REPORT Gamtex Recycling, Houston, Texas Natalie Topinka, Environmental Scientist AECAB (IL/IN) Nathan Frank, Section Chief AECAB (IL/IN) File BASIC INFORMATION Facility Name: Gamtex Recycling Facility Location: 3660 Schalk.er Drive, Houston, Texas Date of Inspection: November 9, 2018 EPA Inspector(s): 1. Natalie Topinka, Environmental Scientist 2. Scott Connolly, Environmental Engineer Other Attendees 1. Jeff Davis, Manager, Gamtex Contact Email Address: jeff@gachman.com Purpose of Inspection: Assess compliance with the refrigerant disposal requirements Facility Type: scrap metal recycler Regulations Central to Inspection: 40 C.F.R Part 82, Subpart F Arrival Time: 9:53 am De:piirture Time: 10:48 am Inspection Type: 12'.1 Unannounced Inspection D Announced Inspection QPFNING CONFERENCE 12'.1 Credentials Presented 12'.1 CBI warning to facility provided The following information was obtained verbally from Mr. Davis unless otherwise noted. Process Description: Gamtex Recycling's Houston location is one of five locations in Texas. It accepts scrap metal for recycling from members of the general public ("peddlers") and commercial entities. Among items accepted are appliances, such as refrigerators or window air conditioners. Gamtex does not accept vehicles at this location. Staff Interview: Mr. Davis estimated that items supplied by peddlers comprised a small portion ofGamtex's incoming material, approximately 10%, which included approximately 12 small appliances per week. Mr. Davis stated that Gamtex has one large commercial customer that sends appliances to the facility, and the customer removes the refrigerant properly from the appliances prior to arrival at Gamtex. Ferrous material, including small appliances, is sent to a local shredder. Gamtex does not recover refrigerant from appliances. It accepts items that once contained refrigerant if the compressor has been removed. Gamtex has a statement at the bottom of its scale ticket that states: "Seller certifies that prior to entering Gamtex Industries company facility all CFC's [sic] have been properly removed to allow legal, safe and responsible recycling under Section 608(B)(l) of the Clean Air Act. that had not leaked previously has been recovered from the appliance or shipment of appliances delivered under this sale in accordance with 40 CFR Part 82.155(a). The refrigerant has been recovered by (name)_________ had "leaked out (as defined in 40 CFR Part 82.155(b)(2)(iii) of the appliance or shipment of appliances delivered under this sale prior to delivery and could not possibly be recovered. Acknowledged By:_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _" TOUR INFORMATION EPA toured the facility: Yes Page 2 of 4 Data Collected and Observations: EPA toured the scrap pile that contained items from the general public. We observed several small appliances, including refrigerators, in the pile. At least one refrigerator had intact refrigerant lines and another refrigerator had its back panel nearly entirely intact (indicating that the refrigerant lines had not been accessed). Mr. Davis stated that approximately 5 trucks worth of material from that pile was taken daily to the local shredder, meaning material usually is not on-site more than one day. Photos and/or Videos: were tal(en during the inspection. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Example scale ticket CLOSING CONFERENCE Compliance Assistance: We gave an overview of the regulatory requirements and compliance options in 40 C.F.R. Part 82, Subpart F, including practical elements ofrecovering refrigerant at Gamtex. We left with Mr. Davis a copy of the regulatory text of 40 C.F.R. 82.155 and a U.S. EPA Small Business Resources Information Sheet. Concerns: We discussed with Mr. Davis our concern that Gamtex's statement on its scale ticket did not meet the requirements of 40 C.F.R. 82.155(b)(2), which require inclusion of the name and address of the person who recovered refrigerant and the date the refrigerant was recovered. We also pointed out the intact refrigerator in the scrap pile and the inevitability that the refrigerant was going to be vented to the atmosphere because Gamtex did not have an effective system in place for recovering refrigerant or verifying proper refrigerant recovery from small appliances. SIGNATURES Page 3 of 4 Facility Name: Gamtex Recycling Facility Location: 3660 Schalker Drive, Houston, Texas Date of Inspection: November 9, 2018 APPENDICES AND ATTACHMENTS I. Digital Image Log 2. Digital Images attached on CD 3. Sample scale ticket Page 4 of 4 Faeility Name: Gamtex Recycling Facility Location:- 3660 Schalker Drive, Houston, Texas Date of Inspection: November 9, 2018 APPENDIX A: DIGITAL IMAGE LOG 1. lpspector Name: Scott Connolly 3. Company/Facility Name: Gamtex Recycling 5. Number of Images: 8 2. Date(s) of Inspection: November 9, 2018 4. Street Address, City, State: 3660 Schalker Drive, Houston, Texas 6. Archival Record Location: CD-R labeled Gamtex Recycling Inspection photos, November 9, 2018 Image Number 77 78 79 80 81 82 83 84 File Name PB090077.JPG PB090078.JPG PB090079.JPG PB090080.JPG PB090081.JPG PB090082.JPG PB090083.JPG PB090084.JPG Date and Time (CST) 11/9/2018 12:16 11/9/2018 12:16 11/9/2018 12:18 11/9/2018 12:19 11/9/2018 12:21 11/9/2018 12:21 11/9/2018 12:22 11/9/2018 12:48 Latitude and Longitude 29.79982, -95.344792 29.800023, -95.344957 29.799978, -95.344963 29.799983, -95.344863 29.800013, -95.344855 29.800012, -95.34485 29.799722, -95.345556 Description of Image Gamtex - general view of scale Gqmtex - decommissioned sweat furnace and burning trash barrel Gamtex- refrigerator, back panel nearly all intact Gamtex- appliances on scrap pile from members of the public Ga mtex - intact refrigerant circuitry on a refrigerator in scrap pile Gamtex- intact refrigerant circuitry on a refrigerator in scrap pile Gamtex - refrigerator with cut refrigerant line Gamtex - sign at weigh scale di-recting removal (not recovery) of refrigerant from appliances Appendices Page 1 of 1