Archive for September, 2011

IDEM Public Comment Letter for Steel Dynamics Inc. new copper plant

Tuesday, September 20th, 2011

September 19, 2011

This letter is to be included for the public comment period on SDI LaFarga, LLC’s air permit #003-30250-00384


We believe there is a compliance violation with Steel Dynamics’ operation at Superior Aluminum located on 14214 Edgerton rd. (326 IAC 6-4 Rule on Fugitive Dust).  We can provide video evidence to both the EPA and IDEM to prove the need for an investigation. 


IDEM referred us to information about current and expected air pollution levels at http://www.in.gov/apps/idem/smog/ and directed us towards a map of the air quality monitors around the area. After digging for a time, I was unable to locate a map that showed anything but the monitors around nation. It is difficult to tell if the ones in our area are located in Allen County, IN.  Our area of concern is around Edgerton, Ryan, Dawkins, Bruick, Harper, Roussey, Bremer, Berthauld, Webster, Parent, Slusher Roads, and US 24.

 

In the 326 IAC 2-1.1-5 it reads. The commissioner shall not issue a registration, permit, modification approval, or operating permit revision:


(1)   would allow a source to cause or contribute to a violation of the National Ambient Air Quality Standards;

(2)   would allow a violation of a PSD maximum allowable increase;

(3)   do not assure compliance with all applicable air pollution control rules, except as provided by an enforceable compliance schedule; or

(4)   are not protective of the public

(b) The commissioner may require any source to perform an air quality analysis to demonstrate compliance with the NAAQS (Air Pollution Control Board; 326 IAC 2-1.1-5; filed Nov 25, 1998, 12:13pm:22 IR 990)


We are formally requesting that the commissioner require that an air quality analysis be completed to demonstrate compliance. The current levels of emissions in this area are unknown by the EPA, IDEM, and the general public. This information should encourage the need for an air quality analysis so that EPA and IDEM will have a benchmark number to show current levels before the operation begins with LaFarga.  These numbers can be used in the future to show an upward or downward trend of pollutants and confirm they are complying with NAAQS. We feel as though a new operation downwind from an existing polluter (Superior Aluminum Inc.) will contribute greatly to the current emission levels in the area of concern; this would not be protective of public health.


FESOP (Federally Enforceable State Operating Permit) reads under Source Definition; We are concerned this company only lists the following plants:


(a)    SDI LaFarga, LLC is located at 1640 South Ryan Rd, New Haven, Indiana 46774, Plant ID: 003-00384; and

(b)   Superior Aluminum is located at 14214 Edgerton Road, New Haven, Indiana, 46774, Plant ID: 003-00286


Steel Dynamics also has ownership of Omni Source, which is not listed as being part of the company. I would assume that if it was required for them to include Superior Aluminum as part of the company based on ownership, then Omni Source would also need to be included as being part of the company, listed under Source Definition.

 

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SDI is paying out of pocket to move the Bandelier (#3) Ditch.  The NEW ditch will begin on Dawkins Rd., run north on Ryan Rd. and moves east on Edgerton Rd.   SDI chose to build LaFarga on and around a floodplain. Their watershed will be draining into the extended portion of the new ditch. This non-point source discharge into the ditch will then flow directly into the Maumee. This water is not being monitored.  The Maumee River remains on the 303 (d) list for impaired waterways.

 

Save Maumee Grassroots Organization is concerned about the lack of NPDES permits and that Steel Dynamics Inc. (SDI / LaFarga LLC.)


According to data from EPA’s Permit Compliance System (as of December 2006), there are approximately 1800 major dischargers and 5000 total dischargers that have NPDES permit limits or monitoring requirements for total recoverable copper. There are over 400 major dischargers that have NPDES permit limits or monitoring requirements for dissolved copper.


Steel Dynamics has continually stated they will not be applying for an NPDES or any other straight pipe discharge permits. However, the quality of the water in Bandelier ditch (#3) will be seriously compromised if it is moved along side LaFarga, Superior Aluminum, Casad Depot, Pace Setter Finishing, and Plastics Materials of Indiana Inc. There will still be non-point source pollution and run-off water from all their impervious surfaces which will undoubtedly add trace amounts of toxic chemicals into the ditch which then drains into the Maumee River.
Until these issues are addressed with a formal investigation of Steel Dynamics Inc., to demonstrate compliance with all federal and state regulations and criteria, the company SDI LaFarga, LLC should not be considered for an air permit.


We would like IDEM to take serious reconsideration of the area chosen for this new operation. The ambient wind direction, SDI paying to move Bandelier ditch (#3), the impact of pollutants on the quality of water/air/soil around rural farm land and private wells, the current complaints levied against another SDI company, and the impact on the health of those who live near by and downwind, should all be taken into consideration when your final decision is made. I am requesting that you deny SDI LaFarga, LLC from obtaining an air permit.


SIGNED BY 23 people ~

Citizens’ Questions that NEED to be Answered

Tuesday, September 20th, 2011

On September 15th, 2011 IDEM held a public meeting to address the air permits being issued for Steel Dynamics Inc.
59 people were in attendance and spoke of fear of pollution from Superior Aluminum, and did not want to have air permits approved for the new LaFarga copper plant.

We have included the questions (below are citizens’ questions) that were NOT answered during this 4 hour meeting and we are requesting they are answered for the health of the public OR deny SDI’s air permit request.

 AIR

  • Who will watchdog any monitors that are placed? How often will they be monitored? (heavy metals, particulate matter, )
  • How are we to be assured that SDI will conform to the Federal Clean Air Act?
     
  • If these regulations are not followed, what is the consequence to the business?
  • What fines are associated with non-compliance? public hearing/ legal action / law suit applicable?
  • If a fine were levied, where would the money go?
  • Can we test the air now BEFORE this plant goes up and then AFTER the plant is in operation if air permit is granted? (benchmark)
  • If there is something in existence of what is upwind and downwind to monitor the air quality…so is it better/worse upwind/downwind?
     
  • Where are the other monitors in existence around our area.  The website given by IDEM http://www.in.gov/apps/idem/smog/ does not seem to contain specifics of location.
  • If the current levels downwind exceed the NAAQS, will the permit be issued for the new plant?
     
  • Can the combination of toxins from the SDI LaFarga Copper plant and the SDI Superior Aluminum Plant mix together to create something worse? Like a supertoxin?
  • Were any exemptions awarded for any of the “6 criteria pollutants” or any others reported with IDEM and EPA?
     
  • IF any exemptions were granted, what part of the process of the approval be challenged?
  • What is the AVERAGE limit of air pollution LaFarga Copper plant expect to emit?  How did they get their preliminary findings since this will be the “first copper plant of it’s kind, except for the one in Spain”? Who did the testing and were the tests paid for by SDI?
     
  • If something technical or human error occurs, what backup system (in case of emergency) is in place to ensure no additional harmful pollutants will escape?  What monitor would they have, if any, that would keep track of the number of emissions released during a break down, whether technical or human error?
     
  • Where will the waste from the bag houses be deposited?
  • Will any violations cause the exemptions to be revoked?

WATER

  • How will relocation/expansion of the Bandelier Ditch (#3) affect the storm sewer/sanitary sewer?
  • If any pollutants are being discharged into this ditch, what is being monitored or recorded and reported? Where will this information be available?
  • Will their be a long term control plan for CSO’s where the sanitary /storm sewers are to be installed completely separate per the Clean Water Act and City of Fort Wayne Long Term Control Plan?
     
  • Will SDI be responsible for testing runoff or non-point source pollutants from the two facilities that will be located .6 mile from each other?
  • Will this plant will have a retention pond or a detention pond? CONFIRMING THERE WILL BE NO NPDES PERMIT?
  • Where will the waste water from the bag houses be deposited?
  • Does the pond fall under Rule 5 of the IAC 326 for surface water if there are no chemicals going into it? Where are the reports found for Waterways of the U.S.?
     
  • Please submit the blueprint/schematics for the ditch/direction of the ditch for discharge into New Haven as a straight pipe OR to Fort Wayne Filtration Plant?
     
  • How many gallons of water per month will be used at the new copper plant? Will the water be purchased from City of Fort Wayne or a well be drilled?
     
  • There are 22 who have attended a local community meetings who are on wells within 3 miles of the plant.  How will their well water supply be directly effected?
     
  • Do you know the current levels of heavy metals in these wells?
     
  • Where are the reports or monitoring that will test water quality upstream and downstream?
     
  • How much water is used in the process of making 1 ton (2,000lbs) of steel? 1 ton of copper? 1 ton of aluminum?

SOIL
What are the current levels of Mercury and Lead in the soil surrounding the plant and the properties most affected by current emission.

Farm land and home owners properties must be included.
 

JOIN US for FREE River Loving FUN!

Friday, September 16th, 2011

Upcoming Events:    ALL events are rain or shine ~

SaveMaumeeLogo
SATURDAY ~ September 17, 2011-  Save Maumee’s 4th Annual Canoe Clean Up, Can YOU Clean Up? 
11am- 4pm Free canoes for the day at Fort Wayne Outfitters Bike Depot with ID.  Spend a fun day with family and friends on the river cleaning up and educating yourself! First come first serve Canoe Clean-Up Details HERE

SATURDAY ~ October 22nd, 2011- Save Maumee’s 3rd Annual Seed Harvest at Fox Island Nature Preserve
1pm – 4pm, Come pick seeds that we will plant on our riverbanks for Earth Day 2012  Seed Harvest Details HERE

Friday Sept. 30th and Saturday Oct. 1st.  ~ Northeastern Indiana Sustainable Living Fair and Market held downtown Grabill, IN
Free attendance and if you would like to be a vendor or speaker please contact Julia Gorrell at juliagorrell@gmail.com or 260-418-0071
Friday Sept. 30th, Save Maumee’s Founder will be speaking~exact time will be updated the website here!

Other Recent Events:

**Save Maumee Grassroots Org. appreciates the recreational fun on the St. Joseph and St. Mary’s thanks to Friends of the River!  In 2011 Three Rivers Festival had its first local river event since I attended Northrop High School.  Progress is being made and there are truly reasons to celebrate.  Let us reflect on ways to truly improve our local Three Rivers to benefit all citizens in Fort Wayne.

Save Maumee Grassroots Organization’s 2nd Annual Berlin Music Pub Benefit Show Was VERY FUN! Thank you to all the dedicated people who made this day possible!       
Presented by BMP Pro & TME
The SumMorz – 10pm
Taylor Fredricks – 8:30pm
To The Point – 7pm
Azraels Revenge – 5:30pm
Selenium – 4pm
Corey Rhymez – 12:30am
11M12D – 12am
Twisted Aversion V1.0 – 1am
The 6 Foot Maniac
Count Grootmaniac – 1:30-2am

WHAT ELSE: Featured Pudding Wrestling, Live Music All Day Long, Games, Prizes, Drawings, An Evening Cookout, Acoustic Performances Throughout The Day!  It was interesting that I received an email that said it was vulgar and sexist that we were having pudding wrestling….well, just so you know the only people that got splatted with pudding was Save Maumee’s own Ryan Bailey and Abigail Frost-King! If you missed it…you really missed it! HA HA!

*Fort Wayne Local Bands Come Together For A Great Cause & To Give Back To Its City, With A Mix Of Rock, Metal, HipHop, Alternative, Punk, Acoustic, & Cover Tunes ALL DAY LONG!


THURSDAY – September 15th, 2011 at 5:30pm ~ IDEM (Indiana Dept. of Environmental Management) held a public meeting to discuss air permitting for Steel Dynamics Inc. (SDI) All statements will be considered to make a decision whether to issue or deny the permit. IF you would like to make a comment it NEEDS to be postmarked before Monday night at midnight or email Doug Wagner before midnight at dwagner@idem.in.gov or call him at 317-233-2629

***Concerns from citizens have risen due to  Steel Dynamics Inc. applying for air quality permits for its new copper rod production facility in New Haven that will create 35 jobs.  Remember: What goes up into the air, must come down…into our waterways and land.  Based on equipment capacity, IDEM  permit will allow this one plant to release; 71,703 tons of greenhouse gases, 88 tons of particulate matter, 68 tons of volatile organic chemicals, 66 tons of nitric oxides, 23 tons of sulfur oxides, 9 tons of hydrochloric acid, and nearly 4 tons of formaldehyde and 1.2 tons of hexane. So COME TO THE MEETING (above) (Journal Gazette, “SDI joint venture applies for air permit”)

Fort Wayne Journal Gazette, “Copper plant plans gathering opposition”
EPA-Steel Dynamics on clean-air violations
http://blog.savemaumee.org/category/chemicals-in-your-water/
Full Draft Permit – 143pgs.

~  Save Maumee’s 6th Annual Earth Day 2011 was a GREAT SUCCESS!  ~  CLICK HERE FOR OUR FUNNY VIDEO!

OR   CLICK HERE TO SEE THE STATS FROM EARTH DAY 2011

Watch our Earth Day Video from 2010!

Watch Save Maumee’s 2011 PSA

Thank you for your continued support ~ Help us to speak for your rivers!

Sincerely,

Abigail Frost-King

Save Maumee Grassroots Organization Founder
Watershed Expert
Indiana Master Naturalist

Save Maumee is a 100% citizen driven, volunteer, environmental restoration group that works to improve the Maumee River in Fort Wayne through work and awareness raising; To have a positive impact on the 24 million people who depend on clean water downstream…We all live downstream!

www.savemaumee.org
blog.savemaumee.org
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