EPA to Increase Air Enforcement at Scrap Metal Facilities

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The EPA has issued an enforcement alert notifying facilities that operate large shredders that they are priority targets for potential enforcement actions for emission violations. The shredders in question are those typically utilized to shred cars and appliances, and the EPA estimates that there are approximately 250 permitted facilities in the US. The alert was issued in response to both EPA and state findings that emissions violations at several facilities are occurring, some of which are located in densely populated areas. The alert is intended to notify the operators of Clean Air Act requirements that may apply, depending on the level of VOC emissions and other pollutants generated at the shredding facilities. Depending on the size of the shredding operation, they may be found to be major sources of VOCs, and be required to install Best Available Control Technology, as well as other controls to limit the emissions of VOCs and particulate matter. Failure to comply with these requirements is a violation of the Clean Air Act and could lead to substantial enforcement actions and penalties against the violators.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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