UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 IN THE MATTER OF: General Iron Industries, Inc. 1909 N. Clifton Avenue, Chicago, Illinois 60614 ATTENTION: Jim Kallas Plant Environmental Engineer Request to Provide Information Pursuant to the Clean Air Act The US. Environmental Protection Agency is requiring General Iron Industries, Inc. (General Iron) to submit certain information about the facility at 1909 N. Clifton Avenue, Chicago Illinois. Appendix A provides the instructions needed to answer this information request, including instructions for electronic submissions. Appendix speci?es the information that you must submit relating to emissions'testing we are requiring you to complete, including the submittal of a test protocol, noti?cation of intent to test, and the completion of a testing report. Appendix speci?es the information that you must submit relating to various permits and operating information. You must send this information to us according to the schedules contained in each appendix. We are issuing this information request under Section 114(a) of the Clean Air Act (the CAA), 42 U.S.C. 7414(a). Section 114(a) authorizes the Administrator of EPA to require the submission of information. The Administrator has delegated this authority to the Director of the Air and Radiation Division, Region 5. General Iron owns and operates an emission source at the Chicago, Illinois facility. We are requesting this information to determine whether your emission source is complying with the Illinois State Implementation Plan. I General Iron must send all required information to: Attn: Compliance Tracker, Air Enforcement and Compliance Assurance Branch US. Environmental Protection Agency Region 5 77 W. Jackson Boulevard Chicago, Illinois 60604 General Iron must submit all required information under an authorized signature with the following certi?cation: I certify under penalty of law that I have examined and am familiar with the information in the enclosed documents, including all attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are, - to the best of my knowledge and belief, true and complete. I am aware that there are significant penalties for knowingly submitting false statements and information, including the possibility of ?nes or imprisonment pursuant to Section 113(c)(2) of the Clean Air Act and 18 U. S. C. 1001 and 1341. As explained more fully in Appendix D, you may assert a claim of business con?dentiality under 40C.F.R. Part 2, Subpart for any part of the information you submit to us. Information subject to a business confidentiality claim is available to the public only to the extent, and by means of the procedures, set forth at 40 C.F.R. Part 2, Subpart B. If you do not assert a business confidentiality claim when you submit the information, EPA may make this information available to the public without further notice. You should be aware, moreover, that pursuant to Section 114(c) of the CAA and 40 GER. 2.301(a) and emissions data, standards and limitations are not entitled to confidential treatment and shall be made available to the public notwithstanding any assertion of a business confidentiality claim. Appendix provides additional information regarding the meaning and scope of the term ?emissions data.? This information request is not subject to the Paperwork Reduction Act, 44 U.S.C. 3501 et seq, because it seeks collection of information from speci?c individuals or entities as part of an administrative action or investigation. We may use any information submitted in response to this request in an administrative, civil or criminal action. I Failure to comply fully with this information request may subject General Iron to an enforcement action under Section 113 of the CAA, 42 U.S.C. 7413. You should direct any questions about this information request to Scott Connolly at 312- 886~1493 or at connollv.scott@enagov. (gay. Date Edward Nam Director Air and Radiation Division Appendix A When providing the information requested in Appendices and C, use the following instructions and de?nitions. Instructions- Provide a separate narrative response to each question and subpart of a question set forth in Appendix C. - Precede each answer with the number of. the question to which it corresponds and, at the end of each answer, identify the person(s) who provided information used or considered in responding to that question, as well as each person consulted in the preparation of that response. - Indicate on each document produced, or in some other reasonable manner, the number of the question to which it corresponds. When a response is provided in the form of a number, specify the units of measure of the number in a precise manner. Where information or documents necessary for a response are neither in your possession nor available to you, indicate in your response why the information or documents are not available or in your possession, and identify any source that either possesses or is likely to possess the documents or information. If information not known or not available to you as of the date of submission later becomes known or available to you, you must supplement your response. Moreover, should you find at any time after the submission of your reSponse that any portion of the submitted information is false or incorrect, you must notify EPA as soOn as possible. Electronic Submissions To aid in our electronic recordkeeping efforts, we request that you provide all documents responsive to this information request in an electronic format according to paragraphs 1 through 6, below. These submissions are in lieu of hard copy. 1. Provide all responsive documents in Portable Document Format (PDF) or'similar format, unless otherwise requested in speci?c questions. If the PDFs are scanned images, perform at least Optical Character Recognition (OCR) for ?image over text? to allow the document to be searchable. Submitters providing secured PDFs should also provide unsecured versions for EPA use in repurposing text. Men speci?c questions request data in electronic spreadsheet form, provide the data and corresponding information in editable Excel or Lotus format, and not in image format. If Excel or Lotus formats are not available, then the format should allow for data to be used in calculations by a standard spreadsheet program such as Excel or Lotus. 3. Provide submission on physical media such as compact disk, ?ash drive or other similar item. - 4. Provide a table of contents for each compact disk or ?ash drive containing electronic documents submitted in response to our request so that each document can be accurately identi?ed in relation to your response to a speci?c question. We recommend the use of electronic ?le folders organized by question number. In addition, each compact disk or ?ash drive should be labeled appropriately Company Name, Disk 1 of 4 for Information Request Response, Date of ReSponse). 5 . Documents claimed as con?dential business information (CB1) must be submitted on separate disks/drives apart from the nonwconfidential information. This will facilitate appropriate records management and appropriate handling and protection of the CBI. Please follow the instructions in Appendix for designating information as CB1. 6. Certify that the attached files have been scanned for viruses and indicate what program was used. De?nitions All terms used in this information request have their ordinary meaning unless such terms are defined in the CAA, 42 U.S.C. 7401 et seq. Appendix Information Yen Are Required to Submit to EPA: Emission-s Testing General Iron Industries (General. Iron) must respond to this information request by performing testing at its facility in Chicago, Illinois (?the facility?) pursuant to Section 114(a) of the CAA, 42 U.S.C. 7414(a). General Iron must submit a test plan, conduct testing, and submit all other information requested. in accordance with the schedule speci?ed below: Submit testing Pr'otocol(s) Not less than 45 days before testing Noti?cation-of Intent to Test Not less than 21 days before testing Complete testing Within 180 days of receipt of this request Submit Testing Report Within 30 days of completion of testing 1. - Within one hundred and eighty (180). calendar days after receipt of this request, General Iron must perform emission testing at the facility to determine: a. The total gaseous organic compound emission rate as volatile organic compounds (VOC) of the hammerrnill shredder using EPA Reference Methods 1-4 and Method 25A. Methane and ethane concentrations shall be determined using Method 18 and subtracted from the total hydrocarbon concentration measured following Method 25A to determine VOC - concentrations; b. Particulate Matter emission rate using EPA Reference Methods 1-4 and Method 5; and c. Metals emission rates of the hammermill shredder using EPA Reference Methods 1-4 and Method 29. 2. During the testing conducted pursuant to Item 1, General Iron shall monitor and record the operating parameters of the shredder, including metal feed rate, water ?ow rates, shredder amperage and autos and non~auto material shredded per run. 3. During all emission testing, General Iron shall Operate under representative conditions. 4. Not less than forty?five 5451 calendar days prior to the planned test(s), General Iron shall submit to EPA a proposed testing protocol that completely describes the methods and procedures for testing at each unit, including all relevant operating parameters. The protocol shall state: a. the proposed level of production during emission testing, as well as b. the maximum and average production rates at processes associated with each emission point; and c. shall state what procedures will be utilized to minimize unmeasured emissions. 5. General Iron shall conduct the testing under a protocol approved, in advance, by EPA. General Iron shall submit the protocol via e-mail to connolly.scott@epa. gov. EPA will . provide approval or comments on the testing protocol via e-mail. 1 At least twenty?one (21 2 calendar days prior to the planned test(s), General Iron shall submit noti?cation to EPA of its intent to perform emission testing. General Iron shall submit this notice via e?mail to connolly.scott@epa. gov. Within thirty 130) calendar days after the Completion of the test(s), General Iron shall Submit a complete report of the emissions testing, including, at minimum, the following: a. Summary i. ii. iv. V. of Results results of the above-specified emission test(s); process and control equipment data recorded during the test(s); discussion of any errors that occurred during testing; discussion of any deviations from the reference test methods or other problems encountered during the test; and data on production rate during testing. b. Facility Operations 1. ii. description of the process and control equipment in operation during the test(s); operating parameters of any control equipment in operation during the test(s); and facility operating parameters and data, including an explanation of how the operating parameters demonstrate that the process units were operating at greater than 95% production capacity at the time of the test. 0. Sampling and Analytical Procedures 1. ii. iv. v. Vi. vii. d. Appendix i. ii. iv. v. vi. vii. sampling port location(s) and dimensions of cross-section; sampling point description, including labeling system; brief description of sampling procedures, includingequipment and diagram; description of sampling procedures (planned or accidental) that deviated from any stande method; brief description of analytical procedures, including calibration; description of analytical procedures (planned or accidental that deviated from any standard method; and quality control/quality assurance procedures, tests, and results. complete results with example calculations; raw ?eld data; laboratory report, with signed chain-of?custody forms; calibration procedures and results; raw process and equipment data, signed by a plant representative; test log(s); and project participants and titles. Appendix Information You Are Required to Submit to EPA: Permits and Operations General Iron must submit the following information about its facility in Chicago, Illinois, pursuant to Section 114(a) of the CAA, 42 U.S.C. 7414(a) Within 30 days of receipt of this request. 1. Provide all construction permits, operating permits and permit applications submitted, received or in use since July 1, 2010. Provide copies of the Operating Program, maintained pursuant to 35 Ill. Adm. Code 212.309, and all revisions, used at the facility since July 1, 2012. Provide copies of all annual emissions reports submitted to the Illinois Environmental Protection Agency from January 1, 2012 to the present. Provide in Microsoft Excel compatible format records of shredder throughput (tons/month) since July 1, 2012. Separate throughput by total tons, light iron (ferrous), and non-ferrous, include amount of auto bodies shredded, in tons. Provide shredder operating hours per day for each day from July 1, 2012 to the present. If no operations were conducted, state Why there were no operations. Provide facility documents discussing volatile organic compound (V 0C) emissions from the shredder since July 1, 2010. Include emissions calculations, applicability studies and correspondence. Appendix Con?dential Business and Personal Privacy Information Assertion Requirements You may assert a business con?dentiality claim covering any parts of the information requested in the attached Appendix and Appendix C, as provided in 40 CPR. Emission data provided under Section 114 of the CAA, 42 U.S.C. 7414, is not entitled to con?dential treatment under 40 C.F.R. Part 2. ?Emission data? means, with reference to any source of emissions of any substance into the air: Information necessary to determine the identity, amount, frequency, concentration or other characteristics (to the extent related to air quality) of any emission which has been emitted by the source (or of any pollutant resulting from any emission by the source), or any combination of the foregoing; Information necessary to determine the identity, amount, frequency, concentration or other characteristics (to the extent related to air quality) of the emissions which, under an applicable standard or. limitation, the source was authorized to emit (including to the extent necessary for such purposes, a description of the manner and rate of operation of the source); and A general description of the location and/or nature of the source to the extent necessary to identify the source and to distinguish it from other sources (including, to the extent necessary for such purposes, a description of the device, installation, or operation constituting the source). 40 C.F.R. (B) and (C). To make a con?dentiality claim, submit the requested information and indicate that you are making a claim of con?dentiality Any document for which you make a claim of con?dentiality should be marked by attaching a cover sheet stamped or typed with a caption or other suitable form of notice to indicate the intent to claim con?dentiality. The stamped or typed caption or other suitable form of notice should employ language such as ?trade secret? or ?proprietary? or ?company con?dential? and indicate a date, if any, when the information should no longer be treated as confidential. Information covered by such a claim Will be disclosed by EPA only to the extent permitted and by means of the procedures set forth at Section 114(0) of the CAA and 40 C.F.R. Part 2. Allegedly con?dential portions of otherwise non-con?dential documents should be clearly identi?ed. EPA will construe the failure to furnish a con?dentiality claim with your response to the information request as a waiver of that claim, and the information may be made available to the public Without further notice to you. Determining Whether the information Is Entitled to Con?dential Treatment All con?dentiality claims are subject to EPA veri?cation and must be made in accordance with 40 C.F.R. 2.208, which provides in part that you must satisfactorily show: that you have taken reasonable measures to protect the con?dentiality of the information and that you intend to continue to do so, that the information is not and has not been reasonably obtainable by legitimate means without your consent and that disclosure of the information is likely to cause substantial harm to your business?s competitive position. Pursuant to 40 C.F.R. Part 2, Subpart B, EPA may at any time send you a letter asking that you support yourcon?dential business information (CB1) claim. If you receive such a letter, you must respond within the number of days speci?ed by EPA. Failure to submit your comments within that time would be regarded as a waiver of your con?dentiality claim or claims, and EPA may release the information. If you receive such a letter, EPA will ask you to specify which portions of the information you consider confidential by page, paragraph and sentence. Any information not speci?cally identi?ed as subject to a con?dentiality claim may be disclosed to the requester without ?irther notice to you. For each item or class of information that you identify as being CB1, EPA will ask that you answer the following questions, giving as much detail as possible: 1. For what period of time do you request that the information be maintained as con?dential, until a certain date, until the occurrence of a special event or permanently? If the occurrence of a speci?c event will eliminate the need for con?dentiality, please specify that event. 2. Information submitted to. EPA becomes stale over time. Why should the information you claim as con?dential be protected for the time period Speci?ed in your answer to question number 1? - 3. What measures have you taken to protect the information claimed as con?dential? Have you disclosed the information to anyone other than a governmental body or someone who is bound by an agreement not to disclose the information further? If so, why should the information still be considered con?dential? 4. Is the information contained in any publicly available databases, promotional publications, annual reports or articles? Is there any means by which a member of the public could obtain access to the information? Is the information of a kind that you Would customarily not release to the public? I 5. Has any governmental body made a determination as to con?dentiality of the information? If so, please attach a copy of the determination. 6. For each category of information claimed as con?dential, explain with specificity why release of the information is likely to cause substantial harm to your competitive position. Explain the speci?c nature of those harmful effects, why they should be viewed as substantial and the causal relationship between disclosure and such harmful effects. How could your competitors make use of this information to your detriment? 7. Do you assert that the information is submitted on a voluntary or a mandatory basis? Please explain the reason for your assertion. If you assert that the information is voluntarily submitted information, explain whether and why disclosure of the information would tend to lessen the availability to EPA of similar information in the future. 8. Is there any other information you deem relevant to determination regarding your claim of business con?dentiality? If you receive a request for a substantiation letter from the EPA, you bear the burden of substantiating your confidentiality claim. Conclusory allegations will be given little or no weight in the determination. In substantiating your CBI claim(s), you must bracket all text so claimed and mark it Information so designated will be disclosed by EPA only to the extent allowed by and by means of the procedures set forth in40 C.F.R. Part 2, Subpart B. If you fail to claim the information as con?dential, it may be made available to the public without further notice to you. Personal Privacy Information Please segregate any personnel, medical and similar files from your responses and include that information on a separate sheet(s) marked as ?Personal Privacy Information.? Disclosure of such information to the general public may constitute an invasion of privacy. CERTIFICATE OF MAILING I certify that I sent a Request to Provide Information Pursuant to the Clean Air Act by I Certi?ed Mail, Return Receipt Requested, to: Jim Kallas Plant Environmental Engineer General Iron Industries 1909 N. Clifton Avenue Chicago, Illinois, 60614 I also certify that I sent a copy of the Request to Provide Information Pursuant to the Clean Air Act by E-mail to: Julie Armitage Chief Bureau of Air Illinois Environmental Protection Agency On the ls??day of Nahum 2017. Kathy Jones, Program Technician AECAB, PAS CERTLFIEDMAILRECEIPTNUMBER: Wool 0330 0166 4,1722,