EPA v. H. KRAMER & COMPANY

Case summary

In 2010, an ambient lead monitor was installed on the roof of the Perez Elementary School on the southwest side of Chicago. The school sits in the historic Latino Pilsen neighborhood, which is considered an environmental justice area by the EPA. Between October of 2010 and February of 2011, the monitor measured lead concentrations of above the National Ambient Air Quality Standard (NAAQS). The NAAQS was established to protect the public from health effects of lead exposure. Lead exposure has been shown to cause developmental problems, and other health issues, in children. The U.S. EPA quickly investigated several facilities in the area to determine the cause. A comprehensive technical report by U.S. EPA's National Enforcement Investigation Center confirmed that more than 98 percent of the lead measured at the Perez monitor could be traced back to H. Kramer. After evaluating all available technical data, the U.S. EPA issued a Finding of Violation to H. Kramer on March 11, 2011. With assistance from the Illinois EPA and the Illinois Attorney General's Office, the U.S. EPA required interim measures to immediately protect the Pilsen community from lead exposure. These measures included: high-speed doors to contain lead dust in the cast house building; roof repairs to fix holes which allowed the release of leaded dust; and remediation and clean-up of on-site leaded soils. While these measures were quickly implemented, the U.S. EPA worked with H. Kramer to design a control technology system which would significantly reduce the lead emissions from the facility. The final design included the replacement of antiquated older baghouses with state-of-the-art new baghouses. Any traces of lead dust passing through the new baghouses will be vented to new High Efficiency Particulate Air (HEPA) filters The HEPA filters can achieve an additional lead removal efficiency of more than 99.97 percent. A thorough engineering ventilation study was also conducted to ensure that the new control equipment was large enough to ensure capture of all the the leaded dust emitted from the process. These pollution controls will be in place by September 1, 2013.

Defendants (1)

• H. KRAMER & COMPANYNamed in complaintNamed in settlement

Facilities (1)

• H KRAMER & CO

  1339 W 21ST ST, CHICAGO, IL, 60608-3111

  Registry ID: 110018255831

Statutes cited

• CAA 111 — New Source Performance Standards
• CAA 112K — Area Source MACT
• CAA 110 — Implementation Plan for National Primary and Secondary Ambient Air Quality Standards

Enforcement conclusions (1)

• H. KRAMER & COMPANYentered 2013-03-28

  Primary law: CAA

  Federal penalty: $17,500 · State/local: $17,500 · SEP: $40,000

Timeline (7 milestones)

• 2011-05-25Referred To Dept Of Justice
• 2011-06-07Enforcement Action Data Entered
• 2013-01-31Final Order Lodged
• 2013-01-31Complaint Filed With Court
• 2013-03-28Final Order Entered
• 2016-03-28Air Resolved
• 2022-03-23Enforcement Action Closed