EPA v. REPUBLIC ENGINEERED PRODUCTS

Case summary

U.S. EPA is issuing this Order to Republic Engineered Products, Inc. ( Republic ) under Sections 113(a)(1) and (a)(3), and 114(a)(1) of the Clean Air Act (Act), 42 U.S.C. § 7413(a)(1) and (a)(3), and 7314(a)(1). U.S. EPA inspectors conducted visible emissions observations at the Facility on March 21 and 22, 2005; April 1, 2005; and October 12 and 18, 2005. OEPA inspectors conducted visible emissions observations at the Facility on September 1 and 8, 2005. Republic has conducted visible emissions observations at the Facility from at least December 23, 2003 until the present. Based on observations of opacity by U.S. EPA inspectors, OEPA inspectors, or Republic, U.S. EPA alleges that visible particulate emissions of fugitive dust from BOP vessel L exceeded twenty percent opacity in violation of the visible particulate emission limitations in OAC 3745-17-07(B)(1) of the Ohio SIP and the Title V permit on the following dates: February 12 and 26, 2004; May 13 and 25, 2004; June 29, 2004; August 12 and 24, 2004; September 2, 9, 16 and 27, 2004; November 15, 2004; December 8, 2004; January 18, 2005; February 10 and 15, 2005; March 10, 18, 21, 22 and 23, 2005; April 1, 7 and 30, 2005; June 2, 2005; January 25, 2006; February 2, 2006; August 22, 2006; February 1, 2007; April 19, 2007; June 9, 2007 and October 4, 2007. Based on observations of opacity by U.S. EPA inspectors, OEPA inspectors, or Republic, U.S. EPA alleges that visible particulate emissions of fugitive dust from BOP vessel N exceeded twenty percent opacity in violation of the visible particulate emission limitations in OAC 3745-17-07(B)(1) of the Ohio SIP and the Title V permit on the following dates: December 23, 2003; January 14, 2004; March 10, 18 and 25, 2004; April 28, 2004; July 14, 2004; August 17 and27, 2005; September 1, 8, 22 and 28, 2005; October 12, 14 and 18, 2005; and December 16 and 30, 2005; June 29, 2006; July 13, 2006; August 5, 2006; April 12, 2007; and May 5 and 19, 2007. By no later than the date on which Republic resumes operation of either BOP vessel L or N, Republic must complete the following projects to enhance the secondary control and capture system for BOP vessels L and N: a. inspect 16 dampers (also known as butterfly valves) within each of the 16 vertical ducts extending from the 16 uptakes to the AQC main duct, which dampers are opened and closed to optimize air flow through the AQC main duct to the baghouse and thereby maximize control of emissions, and repair or replace those dampers that do not open and close properly; b. clean out any accumulated solids present in any of the 16 vertical ducts from the damper to the entry into the main duct; c. inspect all augmentation fans and their respective motors located in the wall along the southern side of the BOP Shop building above the vessels (repair floor, batch floor, lance floor and flux floor), which fans induce pressure from outside into the building in order to force fugitive emissions upward to the pickup points in the BOP Shop roof, and repair or replace those fans and/or motors that do not operate properly; d. inspect all doors present on the lance floor, flux floor and batch floor providing access to staircases, the quencher room and onto the roof, which doors prevent the escape of fugitive emissions from the building when properly closed, and repair or replace those doors that do not close properly; and e. install a computerized Programmable Logical Controller (PLC) system that automatically checks the operation of the augmentation fans and automatically controls the opening and closing of the dampers.

Defendants (1)

• REPUBLIC ENGINEERED PRODUCTSNamed 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 113A — Violation of Existing Administrative Order
• CAA 110 — Implementation Plan for National Primary and Secondary Ambient Air Quality Standards

Enforcement conclusions (1)

• REPUBLIC ENGINEERED PRODUCTSentered 2009-04-29

  Primary law: CAA

Timeline (2 milestones)

• 2009-04-29Final Order Issued
• 2009-07-06Enforcement Action Data Entered