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

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 ~

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