Rec d Digitally S W M D. West, Tommi AFIN: From: McConnell, Melissa Sent: Thursday, November 01, :56 AM PMT#: 0028-SWTP TO: BL>File

Transcription

1 West, Tommi From: Sent: To: Subject: Attachments: Leamons, Bryan Thursday, November 01, :51 AM West, Tommi FW: Joint Inspection of Kool Metal Recycling Kool Metal.pdf Can you log this in Kool metal? It is an investigation so it will not go with the normal inspections. Bryan Leamons, P.E. Engineer Supervisor Rec d Digitally ADEQ - Solid Waste Management Division AFIN: From: McConnell, Melissa Sent: Thursday, November 01, :56 AM PMT#: 0028-SWTP To: Leamons, Bryan; Hoover, Elizabeth Cc: Meador, Gary By Tommi West at 10:54 am, Nov 01, 2012 Subject: Joint Inspection of Kool Metal Recycling DOC ID#: TO: BL>File S W M D 1

2 Arkansas Department of Environmental Quality Solid Waste Management Division Other Report Form Activity PDS ID Site Name County Location Date COMMENTS Signature of Inspector Date Other Report Form

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6 ADEQ AIR INSPECTION REPORT (PDS Version 2.0) Page 1 of 6 INSPECTOR ID & NAME: Jim Starling AFIN: PERMIT NUMBER: N/A DATE INSPECTED: 9/13/2012 COMPLIANCE ISSUES: YES DISTRICT / COUNTY ID: TIME IN: TIME OUT: TYPE OF PERMIT: ISSUED: EXPIRES: PDS #: 04 / 19 11:43 A.M. 12:45 P.M. N/A ATTENDEES/AFFILIATIONS: Brent Day, Ambrosia Brown & Gary Meador/ADEQ; Chandler Sorrels & Shane Bledsoe/Kool Metal Recycling; Josh Goldwyn, Kool Welding Supply INSPECTION TYPE: PCE REPORTS CURRENT AT TIME OF INSPECTION: N/A STACK TESTING CURRENT AT TIME OF INSPECTION: N/A NSPS SUBPART(s): Unknown NESHAP SUBPART(s): Unknown COMPANY NAME: PHYSICAL ADDRESS: Kool Metal Recycling COMPANY INFORMATION 495 John Brown Road, Wynne, Arkansas GPS Lat COORDINATES: Long POST PROCESSED: YES MAILING ADDRESS: 720 East Murray Avenue CITY: Wynne STATE: AR ZIP: CONTACT: PHONE & EXT: Mr. Timothy MaKool PREVIOUS INSPECTION DATE(s) & STATUS: CAO LIS or CASE ID TITLE: Owner Koolgas@sbcglobal.net FAX: ADDRESS: 3-YEAR COMPLIANCE HISTORY CLOSED DATE CLOSED Unpermitted facility NOTES / COMMENTS: AREAS OF CONCERN /NON-COMPLIANCE ISSUES NOTED Arkansas Code Annotated and Arkansas Pollution Control & Ecology Commission Regulation The facility has constructed and operated a possible source of air contaminant without first obtaining a permit. The facility will need to have the source s emissions and any associated process emissions evaluated by our Department s Air Division Permitting Branch. NOTES & COMMENTS: Referring to Hazardous Waste Division for possible issues related to incineration of gases produced by the tire pyrolysis unit. FAYETTEVILLE SHALE RELATED? NO FAYETTEVILLE SHALE VIOLATIONS? INSPECTOR S SIGNATURE: DATE: SUPERVISOR'S SIGNATURE: DATE: HPV Revised: August 2, /18/2012 9/24/2012

7 Page 2 of 6 ADEQ AIR INSPECTION ADDENDUM PAGE AFIN: On September 13, 2012 I, accompanied by ADEQ Inspector Supervisor Brent Day, ADEQ Engineer Ambrosia Brown and ADEQ Solid Waste Management Inspector Gary Meador, conducted a partial compliance inspection of the Kool Metal Recycling facility located at 495 John Brown Road, Wynne, Arkansas. At this time the facility is not permitted by the Air Division, but it is in the process of obtaining a Waste Tire Disposal General Permit from our Solid Waste Management Division and had recently been approved by our Water Division for an Industrial Stormwater General Permit with an effective date of September 14, The inspection was performed as a result of information forwarded to the Air Division on September 11, 2012 from Solid Waste Management permitting personnel detailing information reported to them by Kool Metal Recycling of their plans of an unannounced tire pyrolysis facility and also of the facility having tested this self-fabricated equipment on tires stored on site. Upon our arrival at the facility we met first with Mr. Chandler Sorrels, employee at the facility. Mr. Sorrels was the only person on site and I suggested he call Mr. Timothy MaKool, owner of the facility. The tire pyrolysis unit in question was on site and being tended to by Mr. Sorrels. (See attached pictures) The front cover had been removed before our arrival and there were visible emission emitting from the front of the unit. I talked with Mr. MaKool on the phone and he described what was occurring on site at that moment. The facility was in the process of testing the unit and had removed the cover for EnSafe, one of their consultants, to obtain a sample of the tire waste being processed and the cover was too hot to put back in place. The process does not burn the waste tires, but decomposes the waste tires with indirect heat. I related to Mr. MaKool that, at the moment, the source was not being operated properly, thus releasing air contaminants, and had not been evaluated by the Air Division s permit branch. I then handed the phone to Ms. Brown to discuss with Mr. MaKool the proper steps in obtaining approval from our Department to operate the tire pyrolysis unit. During our time at the facility we were also joined by Mr. Josh Goldwyn, an associate of Mr. MaKool, and Mr. Shane Bledsoe, co-owner of the facility. The information provided by these two gentlemen supported what Mr. MaKool had stated to this point. A description of the process was given. The facility had equipment on site to cut the tires and separate the sidewalls. They had a baler for the waste tires that would produce 1500 pound bales. They would load a bale in the tire pyrolysis unit and seal the access to the unit with a metal cover. The unit was then heated to around 650 o -700 o F. The heated waste tires would disintegrate into volatile gas, oil and char. The gas could be burned as fuel to operate the unit. They reported that only testing had been performed and the residual material of the tests was all on site. I viewed seven large containers, approximately 3 x3 x5 in size, which contained the solid material and three uncovered containers of residual oil, two were 5 gallon buckets and the other one was the bottom quarter section of a 55 gallon drum. The construction of the unit began approximately ten months earlier with the construction of a small unit using a coffee can and hotplate to test the process. Mr. Bledsoe and Mr. Goldwyn were informed that the matter would be treated as operating an unpermitted source and a letter would be forwarded Mr. MaKool detailing the outcome of the inspection. Compliance Issue(s): Arkansas Code Annotated Unlawful actions. (a) It shall be unlawful and constitute a misdemeanor: (1) To knowingly cause air pollution as defined in ; (2) To construct, install, use, or operate any source capable of emitting air contaminants without having first obtained a permit to do so, if required by the regulations of the Arkansas Pollution Control and Ecology Commission, or to do so contrary to the provisions of any permit issued by the Arkansas Department of Environmental Quality or after any such permit has been suspended or revoked; or (3) To violate any rule, regulation, or order of the commission issued pursuant to this chapter. (b) The liabilities imposed for violation of subdivisions (a)(1)-(3) of this section or any other provision of this chapter shall not apply with respect to any unintended violation caused by war, strike, riot, or other catastrophe, or accidental breakdown of equipment if promptly repaired. & Arkansas Pollution Control and Ecology Commission Regulation No person shall cause or permit the operation, construction, or modification of a stationary source, whose actual emissions are: 75 tons per year or more of carbon monoxide; 40 tons per year or more of nitrogen oxides; 40 tons per year or more of sulfur dioxide; 40 tons per year or more of volatile organic compounds; 15 tons per year or more of PM10; 0.5 tons per year or more of lead; 2.0 ton per year or more of any single hazardous air pollutant; or 5.0 tons per year or more of any combination of hazardous air pollutants, without first obtaining a permit from the Department pursuant to the provisions of this chapter. The facility has constructed and operated a possible source of air contaminant without first obtaining a permit. The facility will need to have the source s emissions and any associated process emissions evaluated by our Department s Air Division Permitting Branch.

8 Page 3 of 6 Arkansas Department of Environmental Quality (ADEQ) Official Photograph Sheet Location: Kool Metal Recycling, Photo # 1 Of 7 Date: 9/13/2012 Time: 11:51 A.M. Description: Homemade tire pyrolysis unit with front cover removed. Photo # 2 Of 7 Date: 9/13/2012 Time: 11:51 A.M. Description: Front cover of tire pyrolysis unit.

9 Page 4 of 6 Arkansas Department of Environmental Quality (ADEQ) Official Photograph Sheet Photo # 3 Of 7 Date: 9/13/2012 Time: 11:44 A.M. Description: View of emissions from opened tire pyrolysis unit. Photo # 4 Of 7 Date: 9/13/2012 Time: P.M. Description: Bale of waste tires produced on site.

10 Page 5 of 6 Arkansas Department of Environmental Quality (ADEQ) Official Photograph Sheet Photo # 5 Of 7 Date: 9/13/2012 Time: 11:53 A.M. Description: One of the boxes of tire residue after processed through tire pyrolysis unit Photo # 6 Of 7 Date: 9/13/2012 Time: 11:53 A.M. Description: Another box of material after being processed through tire pyrolysis unit.

11 Page 6 of 6 Arkansas Department of Environmental Quality (ADEQ) Official Photograph Sheet Photo # 7 Of 7 Date: 9/13/2012 Time: 11:54 A.M. Description: Oil residue from tire pyrolysis process. Photographer: Witness: Photo # Of Date: Time: Description: