I recommend that you approve the attached Administrative Consent Order (ACO) for Fritz Products, Inc., River Rouge, Michigan to address violations regarding the facility's Permit to Install and National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production (Subpart RRR).
Specifically, Fritz Products, Inc. failed to:
(i) comply with the dioxin/furans (D/F) emission limit and the hydrogen chloride (HCl) emission limit;
(ii) have a bag leak detection system on the baghouse controlling the furnace;
(iii) install and operate a device to continuously measure and record the weight of liquid chlorine flux injected into its furnace;
(iv) establish an operating parameter value of range for the total reactive flux injection rate during D/F testing;
(v) obtain approval from the State and the Administrator for an alternative lime addition monitoring procedure for its intermittent lime addition into the facility baghouse furnace;
(vi) retain records of lime injection amounts and baghouse inlet temperature;
(vii) comply with all of the provisions of the facility's operation, maintenance, and monitoring (OM&M) plan;
(viii) operate in accordance with the total reactive chlorine flux injection rate and the lime feed rate established during performance tests
(ix) demonstrate continuous compliance with the D/F emission limit and the HCl emission limit by operating in accordance with the total reactive chlorine flux injection rate, the lime feed rate,