Document byGp08gooo70XJK6RbXK40bmD

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590 DEC 3 0 2019 REPLY TO THE ATTENTION OF CERTIFIED MAIL RETURN RECEIPT REQUESTED RobeLt Szcz.esny, General Manager Ferrous Processing and Trading - Pontiac Division "500 Collier Road A1.1burn Hii!s, Michigan 48326 Re: Notice of Violation FeITous Processing and Trading - Pontiac Division Auburn Hills, Michigan Dear Mt. Szczesuy: The U.S. Environmental Protection Agency is issuing the enclosed Notice of Violation (NOV) to Ferrous Processing and Trading - Pontiac Division (you) under Section 113(a)(l) of the Clean Air Act, 42 U.S.C. 7413(a)(l). As set forth in the NOV, we find that you are violating the Michigan State Implementation Plan at your Auburn Hills, Michigan facility. Section 113 of tbe Clean Air Act gives us several enforcement options. These options include issuing an administrative compliance order, issuing an administrative penalty order and bringing a judici::.l civil or criminal action. We are offering you an opportunity to confer with us about the violations alleged in the NOV. The conference will give you an opportunity to present information on the specific findings of violation, any efforts you have taken to comply and the steps you will take to prevent future violations. In addition, in order to make the conference more productive, we encourage you to submit to us information responsive to the NOV prior to the conference date. Please plan for your facility's technical and management personnel to attend the conference to Jiscuss compliance measures and commitments. You may have an attorney represent you at this conference. The EPA contact in this matter is Virginia Galinsky. You may call her at (312) 353-2089 to request a conference. You should make the request within 10 calendar days following receipt of this letter. We should hold any conference within 30 calendar days following receipt of this letter. Sincerely, ~M~kP Michael D. Harris Division Director Enforcement and Compliance Assurance Division Enclosure cc: Jenine Camilleri, Enforcement Unit Supervisor, Michigan EGLE Joyce Zhu, Enforcement Unit District Supervisor, Michigan EGLE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS IN THE MATTER OF: Ferrous Processing and Trading - Pontiac Division Auburn Hills, Michigan Proceedings Pursuant to Section 113(a)(l) of the Clean Air Act, 42 U.S.C. 7413(a)(l) ) ) ) NOTICE OF VIOLATION ) ) EPA-5-20-MI-01 ) ) ) ) ) NOTICE OF VIOLATION The U.S. Environmental Protection Agency (EPA) is issuing this Notice of Violation under Section l 13(a)(l) of the Clean Air Act, 42 U.S.C. 7413(a)(l). EPA finds that Ferrous Processing and Trading - Pontiac Division is violating the Michigan State Implementation Plan (SIP), as follows: Background 1. Ferrous Processing and Trading - Pontiac Division (FPT - Pontiac) owns and operates a scrap metal processing facility, which includes a shredder, at 500 Collier Road, Auburn Hills, Michigan (the Facility). 2. On June 27, 1988, the Michigan Department of Environmental Quality issued Permit to Operate No. 120-80 to the Facility. 3. Special Condition 18 of the permit requires: "Applicant shall not operate the car shredder unless all four cyclones and fabric collector are installed and operating properly." 4. Special Condition 19 of the permit requires: Applicant shall not operate this facility unless the program describing the frequency and recording of scheduled maintenance inspections of the collector is maintained. This program shall include the following: a. All fans, ducts and ripple boxes shall be inspected after each 8 hours of operation and cleaned when necessary. b. All cyclones shall be inspected after each 40 hours of operation and cleaned when necessary. c. A log book shall be maintained at the company office in which the hours of operation and all maintenance, repair and pollution control measures taken shall be recorded on a daily basis. Violations 5. On July 9, 2018, EPA conducted an on-site inspection at FPT- Pontiac. During this inspection, the EPA inspector observed that the collection hood located after the shredder, which pulls particulate emissions to the primary fabric filter, was missing its sheet metal sides and was just an open metal frame, in violation of Special Condition 18 of the Facility's Permit (operation without a properly operating fabric collector). 6. On April 10, 2019, EPA sent a Request for Information to FPT- Pontiac pursuant to Section 114 of the Clean Air Act. Among other information requested, EPA requested the records required by Special Condition 19.c of the Facility's permit. 7. On June I, 2019, FPT- Pontiac submitted its response to EPA's Request for Information. 8. \he activity log provided by FPT - Pontiac in response to the request for the records covered January 2016 through March 2019. It does not identify any daily maintenance inspections or hours of operation, in violation of Special Condition 19 of the Facility's Permit. The log identifies causes of breakdowns of the shredder but does not have any record of maintenance on the cyclones or fabric filter and fails to mention the absence of sheet metal sides on the collection hood located after the shredder, in violation of Special Condition 19 of the Facility's Permit. Date I I -M ~ichael 11 D. Harris / ~ c G r Division Director Enforcement and Compliance Assurance Division 2 CERTIFICATE OF MAILING I certify that I sent a Notice of Violation, No. EPA-5-20-Ml-0l, by Certified Mail, Return Receipt Requested, to: Robert Szczesny, General Manager Ferrous Processing and Trading - Pontiac Division 500 Collier Road Auburn Hills, Michigan 48326 I also certify that I sent copies of the Notice of Violation by first-class mail to: Lisa Carrol, Environmental Director Ferrous Processing and Trading 9100 John Kronk Detroit, Michigan 48210 Jenine Camilleri Enforcement Unit Supervisor Air Quality Division Michigan Department of Environment Great Lakes and Energy (EGLE) Camilleri.T@michigan.gov Joyce Zhu Enforcement Unit District Supervisor Air Quality Division, Southeast District Michigan Department of Environment Great Lakes and Energy (EGLE) zhuj@michigan.gov 20!:,i;\l, Kathy Jones Program Technician AECAB, PAS CERTIFIED MAIL RECEIPT NUMBER: l Dl cl D/lf() /JDo b U'1 'l2 4~