EPA v. FRITZ PRODUCTS - APO/CAFO

Case summary

I recommend that you approve the attached Administrative Consent Order (ACO) for Fritz Products, Inc., River Rouge, Michigan to address violations regarding the facility's Permit to Install and National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production (Subpart RRR). Specifically, Fritz Products, Inc. failed to: (i) comply with the dioxin/furans (D/F) emission limit and the hydrogen chloride (HCl) emission limit; (ii) have a bag leak detection system on the baghouse controlling the furnace; (iii) install and operate a device to continuously measure and record the weight of liquid chlorine flux injected into its furnace; (iv) establish an operating parameter value of range for the total reactive flux injection rate during D/F testing; (v) obtain approval from the State and the Administrator for an alternative lime addition monitoring procedure for its intermittent lime addition into the facility baghouse furnace; (vi) retain records of lime injection amounts and baghouse inlet temperature; (vii) comply with all of the provisions of the facility?s operation, maintenance, and monitoring (OM&M) plan; (viii) operate in accordance with the total reactive chlorine flux injection rate and the lime feed rate established during performance tests (ix) demonstrate continuous compliance with the D/F emission limit and the HCl emission limit by operating in accordance with the total reactive chlorine flux injection rate, the lime feed rate, and activated carbon feed rate established during performance tests (x) prepare and implement a written OM&M Plan that contain all required procedures (xi) install and operate a device to measure and record the total weight of feed/charge to, or the aluminum production from, the affected source or emission unit over the same operating cycle or time period used in the performance (xii) submit Subpart RRR semiannual compliance reports. This ACO requires Fritz Products, Inc. to: (i) comply with the D/F and HCl limits; (ii) operate its baghouse temperature monitoring system, chlorine flux injection system, lime feed system, and activated carbon system at the temperature and rates established during its most recent compliant performance test; (iii) operate its device for measuring aluminum production; (iv) submit a permit application to incorporate practicably enforceable limits into its PTI; and (v) submit semiannual reports. These actions, among others that have been completed to date, address the violations set forth in the FOV issued to Fritz Products, Inc. on September 27, 2010 and the NOV/FOVs issued to Fritz Products, Inc. on December 20, 2013 and June 20, 2019. This ACO will be issued concurrently with a Consent Agreement and Final Order (CAFO) which requires that Fritz Products, Inc. pay a penalty of $125,000 and resolves the violations in the FOV and NOV/FOVs.

Defendants (1)

• FRITZ PRODUCTSNamed in complaintNamed in settlement

Facilities (1)

• FRITZ PRODUCTS

  255 MARION AVENUE, RIVER ROUGE, MI, 48218

  Registry ID: 110000406926

Statutes cited

• CAA 112D — MACT Standards
• CAA 110 — Implementation Plan for National Primary and Secondary Ambient Air Quality Standards

Enforcement conclusions (1)

• FRITZ PRODUCTS - APO/CAFOentered 2020-09-02

  Primary law: CAA

  Federal penalty: $125,000

Timeline (3 milestones)

• 2020-09-02Complaint Filed/Proposed Order
• 2020-09-02Final Order Issued
• 2020-09-16Enforcement Action Data Entered