August 2019 Update
On August 22, 2019, General Iron Industries agreed to an Administrative Consent Order (ACO), that requires General Iron to install additional pollution controls to reduce air emissions at the company’s Chicago facility. The ACO was in response to EPA's Notice of Violation and Finding of Violation (NOV/FOV), issued to the company on July 18, 2018, due to excessive air emissions and failure to obtain a correct operating permit.
EPA’s Order requires General Iron to operate a pollution control device called a regenerative thermal oxidizer (RTO) to control volatile organic compound (VOC) emissions from the shredder. VOCs include a variety of organic chemicals, some of which may have harmful health effects and contribute to the formation of ground level ozone. The RTO breaks down VOCs and other pollutants into carbon dioxide and water by heating them to very high temperatures. The company is also installing a wet scrubber and new emission stack downstream of the RTO. General Iron must ensure through testing that VOC emissions from its shredder are reduced by at least 98% from current levels. The company must also apply for a permit from the State of Illinois detailing the correct equipment operating conditions needed to ensure this continued high level of emissions reduction. General Iron is required to start operating the RTO within 60 days of the effective date of the ACO.
General Iron will be required to operate the RTO even if the company moves its facility to another location. The company may also face a fine for excessive air emissions prior to installing the new pollution controls.
General Iron Industries Inc. owns and operates a metal shredding and recycling operation at 1909 N. Clifton Ave., Chicago, Ill. General Iron operates a capture hood and fabric filter to control and reduce PM and metals emissions from its shredder. EPA has received numerous complaints about air emissions from the facility. Since 2016, EPA has conducted several inspections and visits to the facility to investigate complaints and quantify air emissions from the facility. Historically, EPA has been involved in compliance actions at the facility and in the past General Iron agreed to two settlements with EPA, in 2006 and 2012, involving its refrigerant recovery program and fugitive dust escaping the facility.
Air Emissions Testing
Additional complaints, compliance inspections, and higher than expected emissions data at similar facilities prompted EPA to issue a Clean Air Act Section 114 information request to General Iron in in November 2017 requiring it to test emissions of volatile organic compounds (VOCs), metal hazardous air pollutants (HAPs), and particulate matter (PM) Third-party contractors hired by General Iron conducted the tests on May 24, May 25, June 12 and June 13 in accordance with EPA's testing request.
Initially, General Iron conducted emissions testing for PM and metal HAPs on May 24, 2018, but soon after the samples were collected General Iron's testing contractor alerted EPA that sample contamination may have occurred. In concurrence with EPA, General Iron conducted a retest for PM and metal HAPs on June 12 and 13, 2018. EPA was provided with the test results for the June retest on July 23, 2018 and General Iron provided EPA with the initial test results on August 21, 2018.
After review of the test results, EPA determined that VOC emissions from General Iron's shredder exceeded the allowable limits and General Iron failed to install adequate air pollution controls and obtain the correct air pollution permit. EPA has determined that the metals sampling results from the May 24, 2018 testing is invalid, due to contamination from an unknown outside source and lack of adherence to EPA test methods. EPA will use the results of the June 2018 PM and metal HAPS testing to determine the facility's compliance with the Clean Air Act.
The results of the metals emissions test from June 2018 indicate that several metal HAPs are present in the exhaust gases in detectable levels. The three highest metals measured were zinc, mercury and lead and were measured at emission rates of approximately 171 pounds per year, 50 pounds per year and 3 pounds per year, respectively. These emission rates are low compared to EPA emission limits.
The June 2018 PM emission testing resulted in emissions of 2.3 tons in 2016 and verify that General Iron is in compliance with the emission limit in its state operating permit and with applicable regulations.