EPA v. FEDERAL CARTRIDGE CO - ACO

Case summary

Federal Cartridge Company (FCC) uses lead in the manufacture of centerfire, rimfire, and shotshell ammunition for recreational and military applications. FCC has been operation in Anoka, Minnesota since 1922. EPA issued a Notice of Violation on August 22, 2023 (2023 NOV). EPA alleges that Federal Cartridge violated the Minnesota SIP at Minn. R. 7009.0020 by emitting lead in such an amount or in such a manner to cause or contribute to an exceedance of the MAAQS for lead of 0.15 μg/m3 for the periods of December 2022 through February 2023, March 2023 through May 2023, and April 2023 through June 2023. The 3-month rolling average lead concentrations for these periods are 0.29 μg/m3, 0.17 μg/m3, and 0.22 μg/m3, respectively. EPA issued a second NOV on February 1, 2024 (2024 NOV). EPA alleges that Federal Cartridge violated its federally enforceable state operating permit (FESOP) by failing to meet the minimum particulate matter (PM) and lead control efficiencies at baghouse TREA 7. On November 21 and 22, 2023, Federal Cartridge conducted performance testing at the inlet and outlet of the baghouse. Based on a capture efficiency of 80% determined in accordance with Minn. R. 7011.0072, Subpart 2, and a measured collection efficiency of 88%, the calculated control efficiency of lead at TREA 7 is 70%. The ACO will requires FCC to: (1) continue to operate three existing lead-controlling baghouses, retrofitted with secondary high efficiency particulate air (HEPA) filters recently installed as interim controls; (2) install three replacement lead and PM-controlling baghouses, each with secondary HEPA filters; (3) install scavenger hooding in lead-processing areas to route uncaptured emissions to baghouses with secondary HEPA filters; (4) implement a fugitive dust plan; and (5) investigate and report lead incident investigations for any monitored sample with a 24-hour concentration greater than 0.13 μg/m3 lead.

Defendants (1)

• FEDERAL CARTRIDGE CONamed in settlement

Facilities (1)

• FEDERAL CARTRIDGE COMPANY

  900 BOB EHLEN DR, ANOKA, MN, 553031778

  Registry ID: 110056963727

Statutes cited

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

Enforcement conclusions (1)

• FEDERAL CARTRIDGE CO - ACOentered 2024-08-30

  Primary law: CAA

Timeline (2 milestones)

• 2024-08-30Final Order Issued
• 2024-09-16Enforcement Action Data Entered