General Iron Industries, Inc. Responds To USEPA Notice And Finding Of Violation

CHICAGO, July 27, 2018 /PRNewswire/ -- General Iron Industries, Inc., an industry-leading metal recycling company located in Chicago for more than 100 years, welcomes the United States Environmental Protection Agency's (USEPA) evaluation of the company's performance against environmental standards, areas where there is room for improvement, and measures the company is taking to ensure compliance with, or exceed, environmental requirements.

On July 19, the USEPA provided us with a Notice of Finding and Violation (NOV) that was signed the day before. Today, the USEPA issued a press release announcing that it has cited General Iron "for excessive air emissions." Here are the facts:

We have been meeting and communicating with USEPA officials and they are aware that we dispute material portions of the NOV. We will avail ourselves of the process afforded to us to correct the record, but because the USEPA has released the NOV, General Iron is providing the following detailed response. We believe it is important that the USEPA provides complete and accurate information to the public, including how General Iron compares to the small group of industry competitors that are capable of providing vital metal recycling services for the Chicago area. 

For the past eight months, we have fully cooperated and complied with the USEPA's requirements for testing our metal shredder because we welcome their scrutiny to ensure that our emissions of metals, particulate matter (PM), and volatile organic compounds (VOCs) meet or exceed federal and state environmental regulations to protect public health and air quality.

We are pleased that the independent testing conducted in May and June showed no emissions of metals or filterable PM that violated any permitted limits or applicable requirements and USEPA acknowledged that fact.  

However, we strongly disagree with the violation alleged in paragraph 49 regarding fugitive PM from the shredder and are confident of demonstrating that this finding was in error. In the last week, USEPA representatives committed to reviewing the finding after they acknowledged that they are not certain whether the emissions observed were actually fugitive PM, or instead, permissible stack emissions, as General Iron asserts. We trust that, after their review, the USEPA will agree that the alleged violation was unfounded.

We also disagree with the USEPA's assessment that the violation alleged in paragraph 49 has caused excessive PM emissions. Further, the USEPA used boilerplate language in paragraph 55 to describe harmful health effects of excessive PM exposure, when the test results conclusively showed no excessive PM emissions.

General Iron is one of only a few metal shredding facilities, among 313 nationwide, that has installed a high-efficiency air filter to control metal and PM emissions and the test results support the filter's effectiveness. In fact, our average PM emissions rate was less than three (3) percent of our permitted PM emission limits. No other metal shredder in Chicago or Illinois even has such a filter.

Significantly, the USEPA required us to test for the presence of 17 different metals. We went beyond the USEPA's requirements by performing an impact assessment, based on air dispersion modeling, of the measured metals emissions on the surrounding community. In the absence of specific Illinois and federal standards, the independent results showed that predicted community impacts from metals emissions were far below the stringent health-based standards that were developed by the State of Wisconsin to protect people from air emissions that are known or suspected causes of serious health problems.

We intend to further dispute the technical violation cited in paragraph 51, alleging our failure to provide the May 24-25 PM and metals emissions test results. Conducted under USEPA and Illinois EPA supervision, the results of the May PM and metals emissions testing were regarded as invalid and, with USEPA's approval, retesting occurred on June 13-14, and those results were submitted on time. The May PM and metals emissions test results were subsequently submitted for USEPA to determine their invalidity, and again, we are confident that this violation will be resolved upon that determination.

Regarding VOC emissions, during the past five years, our maximum actual annual VOC emission rate of 88.68 tons/year (which is below the major source threshold) was a very small fraction – less than one-tenth of one percent – of the 146,000 tons of VOCs emitted in 2015 in the entire Chicago-Naperville, IL-IN-WI Combined Statistical Area. The USEPA recently reclassified this statistical region as a marginal nonattainment area under the current ozone National Ambient Air Quality Standard. 

However, the May 25 testing showed that our VOC emissions triggered state regulations requiring that they be reduced by at least 81 percent. This required reduction in uncontrolled VOC emissions is part of a regulation designed to bring the Chicago area into attainment with the ozone standard by reducing VOC emissions from many area emitters. This rule does not speak to the potential impacts from individual emitters. In fact, there are other VOC emitters in the Chicago area whose controlled VOC emissions under this rule are greater than our current uncontrolled emissions.  

To achieve the required reduction of VOC emissions, General Iron has informed the USEPA and the Illinois EPA that we will be installing a regenerative thermal oxidizer (RTO) that will exceed this requirement. The installation of an RTO will set an example for our industry and make General Iron among the first metal shredding facilities in the country to utilize this highly effective technology to control VOC emissions.

The installation of an RTO will also resolve the violations alleged in paragraphs 47 and 48 of the NOV pertaining to certain permits. It is important to note that those violations are based only on the potential for VOC emissions to exceed a regulatory threshold, but that our actual VOC emissions have never exceeded that level. There is no expectation that we will ever reach this threshold because our actual annual material processing rate has never exceeded 42 percent of our allowable rate. 

We are continuing our active engagement with the USEPA and Illinois EPA to demonstrate that we are meeting or exceeding applicable air quality standards implemented to protect human health and the environment. General Iron is a family-owned and operated business that is committed every day to protecting the health and safety of our employees and suppliers, as well as our neighbors and the community we have called home for more than a half-century.

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SOURCE General Iron Industries, Inc.