Document zdvNeMpmZMXMyx4Zxw3avmk17
United States Environmental Protection Agency Region 7
Enforcement and Compliance Assurance Division Air Branch Inspection Report
Unannounced Full Compliance Evaluation Advantage Metals Recycling 2nd Street Facility
201 N. 2nd Street Kansas City, KS 66105 FRS# 110041672767
Inspection Date(s): June 22, 2023
Luke Rodriguez, Inspector, ECAD, Air Branch
Authorized for Release by:
Tracey Casburn, Air Branch Chief, ECAD
11201 Renner Boulevard Lenexa, Kansas 66219
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CONTENTS INSPECTION OVERVIEW........................................................................................................... 3
INSPECTION OBJECTIVE....................................................................................................... 3 FACILITY CONTACT INFORMATION ................................................................................. 3 FACILITY OVERVIEW ............................................................................................................ 3 FACILITY OPERATIONS SUMMARY................................................................................... 3 FIELD ACTIVITIES SUMMARY............................................................................................. 4 INVESTIGATION OBSERVATIONS AND POTENTIAL FINDINGS.................................. 4 TABLES Table 1. PROJECT TEAM MEMBERS......................................................................................... 3 Table 2. FACILITY CONTACT INFORMATION ....................................................................... 3 APPENDICES A Photo log (6 pages)
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INSPECTION OVERVIEW
INSPECTION OBJECTIVE
The objective of this unannounced full compliance evaluation (FCE) inspection was to determine compliance of the facility with the Clean Air Act (CAA). The inspection was part of the U.S. Environmental Protection Agency's (EPA) Creating Cleaner Air for Communities National Enforcement Compliance Initiative.
Table 1 lists the inspection team members.
Team Member Luke Rodriguez Christina Gallick
Mark Weckwerth
Table 1. PROJECT TEAM MEMBERS
Organization
EPA, Region 7, ECAD, Air Branch EPA, Region 7, ECAD, Air Branch Unified Government of Wyandotte County, Department of Air Quality
Project Role Lead Inspector (Air) Field team member (Air)
Field team member (Air)
FACILITY CONTACT INFORMATION
Table 2 lists the primary facility contacts.
Name, Title
Table 2. FACILITY CONTACT INFORMATION
Phone No.
Email Address
Serena Dehoney, EHS Director Antionee Gladney, Transportation Manager
(816) 804-5258 (913) 201-3432
Serena.dehoney@advantagerecycling.com Antionee.gladney@advantagerecycling.com
FACILITY OVERVIEW
Advantage Metals Recycling owns and operates several scrap metal recycling and shredding facilities in the Kansas City metropolitan area. The 2nd Street facility serves as administrative office and storage space in support of the other operations in the area.
FACILITY OPERATIONS SUMMARY
The Advantage Metals Recycling 2nd Street facility houses administrative staff and serves as parking location for trucks and trailers which are used to transport scrap. Five administrative employees and 12 drivers are based out of the 2nd Street office. Advantage Metals Recycling maintains a contract with a third party to conduct repairs on the tarps which cover the transport trailers.
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FIELD ACTIVITIES SUMMARY I arrived at the facility on June 22, 2023, and completed a drive by surveillance inspection at 2:30 PM. The inspection team made entry at the front gate and I introduced myself and members of the inspection team, presented my credentials, and provided my business card to Ms. Dehoney. The inspection team conducted an opening conference with the facility staff listed in Table 2, during which I explained that the purpose of the visit was to conduct an inspection to determine compliance with the CAA. I explained that after asking for some general business information, I would look for equipment which might be subject to the CAA. I explained to Ms. Dehoney that the facility could make a claim of business confidentiality and provided her with a Confidential Business Information form. I did not request any records from Mrs. Dehoney regarding this facility.
I was given a facility tour by Ms. Dehoney. I entered all buildings on the property and looked for equipment that might be subject to the CAA. I conducted a closing conference with Ms. Dehoney.
INVESTIGATION OBSERVATIONS AND POTENTIAL FINDINGS
Ambient weather, site conditions and activities were documented in field records. All photographs are attached as Appendix A. I made the following observations during the inspection. I discussed all observations with facility representatives during the closeout meeting unless otherwise noted in the observation description.
These observations are not final compliance determinations. The EPA Region 7 Air Branch case review team will make the final compliance determinations based on its review of this report and other technical, regulatory, and facility information.
I entered all buildings on the property. I did not see any equipment or processes that would be subject to a specific regulatory requirement in the CAA. There was a cage that was labeled "Tanks", but it was empty. Ms. Dehoney told me that it had previously housed fuel tanks but that these had been removed several years previously. I saw no evidence that any equipment which might be subject to a specific regulatory requirement of the CAA was present on-site.
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