EPA v. REPUBLIC ENGINEERED PRODUCTS

Case summary

In response to the NOV/FOVs and continued U.S. EPA pressure on Republic Engineered Products, Inc to bring its steel mill into compliance with environmental regulations, Republic spent a large sum of money upgrading and replacing the primary and secondary pollution control devices controlling emissions from its BOP vessels N and L. The exact amount of all the expenditure submitted to U.S. EPA was over $18 MM. Republic implemented a $6 MM project upgrading the BOP vessel L pollution control device. Another $2 MM was spent by May 2006 on pollution control devices for BOP vessel N, with an additional $4 MM project completed by the end of 2006. Amongst an extensive number of upgrades to the pollution control devices were: 1) Replacement of carbon vessel skirt, trough, and blades with aluminum-bronze. This is because aluminum-bronze is more durable and lasts longer, and is less prone to breakage; 2) installation of relief door panel; 3) installation of new repair door with better seal on the vessel; 4) replacement of various sections of hood system such as C1 panel, G1 East & West panels, and shaft panels; 5) replacement of Section 2 hood system; 6) Change out vessel L Lower G2 panel; 7) replacement of Section 3, Section 1, east and west walls of shafts, north and south heavy walls, C2 panel, G2 East & West panel, B panel, and transition section; 8) New reverse osmosis system for hood system, with a 30,000-gallon storage tank available for both vessels L & N . This system improves the water quality used to cool down vessel tubes to boiler-type quality water. It prevents tubes from blowing due to hot steam and build-up of solvents; 9) re-bagging of all 8 compartments of the AQC baghouse (secondary pollution control device) including removal of existing bags, repair and replacement of bag cages; 10) removing damaged siding sheeting on west & north sides of BOP Shop and replace with new sheets (another secondary pollution control device upgrade). Republic also stated that it now has a Predictive Maintenance Program in place to ensure compliance with the CAA regulations, and to avoid breakdowns of the pollution control devices such that occurred in the past. It was stated by Republic that once all pollution control devices are upgraded and replaced, vessel N would be the primary vessel for day-to-day operations with vessel L to be used as back-up. Republic also spent over $2 MM fixing the #4 blast furnace bell which was causing the VE exceedances.

Defendants (1)

• REPUBLIC ENGINEERED PRODUCTSNamed in complaintNamed in settlement

Facilities (2)

• REPUBLIC STEEL, F/K/A REPUBLIC ENGINEERED PRODUCTS, INC

  1807 E. 28TH STREET, LORAIN, OH, 44055

  Registry ID: 110000385645

• REPUBLIC STEEL, F/K/A REPUBLIC ENGINEERED PRODUCTS, INC

  1807 E. 28TH STREET, LORAIN, OH, 44055

  Registry ID: 110000385645

Statutes cited

• CAA 502 — Operating Permits (Title V)
• CAA 110 — Implementation Plan for National Primary and Secondary Ambient Air Quality Standards

Enforcement conclusions (1)

• REPUBLIC ENGINEERED PRODUCTSentered 2008-07-31

  Primary law: CAA

  Federal penalty: $210,000

Timeline (3 milestones)

• 2008-07-31Complaint Filed/Proposed Order
• 2008-07-31Final Order Issued
• 2008-09-30Enforcement Action Data Entered