U.S. EPA Region 5 issued an Administrative Consent Order (ACO) to American Iron and Metal (AIM) to address violations of the Clean Air Act (CAA). On 1/30/2020, EPA issued to AIM a Finding of Violation (FOV) pertaining to its scrap metal recycling facility in Cleveland, Ohio. The FOV alleged that AIM accepted for recycling motor vehicles and small appliances such as refrigerators and room air conditioners that contained or once contained ozone-depleting and substitute refrigerants without either recovering the refrigerant from the items or verifying that the refrigerant had been properly recovered prior to delivery to AIM, in violation of regulations found at 40 CFR 82.155. The ACO requires AIM to develop a refrigerant management plan which will include proper refrigerant recovery from intact appliances and motor vehicles, verification of proper refrigerant recovery from such items that arrive at both facilities empty of refrigerant, notification to customers about proper refrigerant recovery, and documentation of compliance. AIM's refrigerant recovery program is estimated to recover approximately 803 lbs of ozone-depleting and substitute refrigerants per year per participating facility. There are environmental justice concerns.