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The United States Environmental Protection Agency (“EPA”) issued an October 4th Notice of Violation and Opportunity to Confer (“NOV”) to Metalico Pittsburgh, Inc. (“MPI”) alleging violations of the Clean Air Act and certain regulatory provisions of the Pennsylvania State Implementation Plan (“SIP”). See U.S. EPA Docket No. CAA-003-22-0001.
The NOV describes MPI is the owner or operator of a metal scrap shredding facility (“Facility”) in Pittsburgh, Pennsylvania.
The Facility is stated to have begun operation in November of 2004. Further, it is stated to have been issued a Minor Source Operating Permit (“Permit”) by the Allegheny County Health Department in 2007.
EPA is stated to have conducted a Clean Air Act inspection at the Facility on August 8, 2018.
MPI is stated to have been provided with emissions values used by the agency to evaluate the Facility’s compliance on November 21, 2019. Further, performance test data used to evaluate the Facility’s compliance with applicable Clean Air Act requirements was also provided to the company.
EPA is stated to have collected data from performance test reports from similar metal shredding facilities located across the United States with feedstocks and feed rates comparable to MPI’s Facility.
The NOV states that data from such performance test reports were used by EPA to formulate MPI’s PTE VOC for the metal shredder at its Facility. It further provides that:
Utilizing the emissions data from these performance test reports, along with the maximum throughput of the Facility’s shredder and maximum operational hours, the EPA calculated Metalico’s PTE VOC to be at least 50 TPY.
EPA and the company are stated to have met by conference call. During such meeting MPI presented its analysis of the emissions values and performance test data provided by EPA to MPI.
The NOV contains the following findings of alleged violations:
- Construction of an air contamination source without approval
- Failure to operate without a Title V Operating Permit
- Violation of the Minor Operating Permit
The NOV provides MPI an opportunity to advise the agency of any further information that it should consider with respect to the alleged violations.
A copy of the NOV can be downloaded here.
