On September 30, 2021, EPA, Region 3 entered into an Administrative Order on Consent ( Consent Order ) with S.D. Richman Sons, Inc. ( S.D. Richman ) alleging violations of the CAA and the Pennsylvania SIP at its metal scrap shredder facility ( Facility ) located in Philadelphia, PA. This enforcement action furthers the CAA's goal of protecting and enhancing air quality and supports the National Compliance Initiative for Creating Cleaner Air Communities. The Facility began operating in 2018 and is currently operating under a Natural Minor Operating Permit, issued by Philadelphia Air Management Services ( AMS ). On June 19, 2019, Region 3 conducted an inspection at the Facility and found that the Facility was operating without a Title V permit in violation of the CAA and the Pennsylvania SIP. On January 14, 2021, Region 3 sent S.D. Richman a Notice of Violation describing the alleged violations found during the inspection. Region 3 determined that the Facility has the potential to emit (?PTE?) at least 25 ton/year ( TPY ) of volatile organic compounds (?VOC?) and is, therefore, a major stationary source under the CAA. The Consent Order requires S.D. Richman to comply with operational limitations to keep the Facility?s VOC emissions below the 25 TPY limit while the appropriate terms of a Synthetic Minor Operating Permit are being verified. The Consent Order also includes monitoring and reporting requirements. The Facility is located in an area of potential EJ concern. EPA notifi