BRAD SUTEK Plant Manager 2701 E. 114TH STREET WWW.AZR.NET P 773-933-9263 CHICAGO, IL 60617
[email protected] F 773-933-9272 June 13, 2018 VIA EMAIL Department of Public Health Attn: Environmental Permitting and Inspection 333 South State St., Room 200 Chicago, IL 60604 Re: AZR’s Comments Regarding the Department of Public Health’s April 18, 2018 Proposed Amendments to the Bulk Solid Materials Rules Dear Sir or Madam: American Zinc Recycling Corp. (“AZR”)1 respectfully submits the following comments on the City of Chicago Department of Public Health’s (the “Department”) proposed April 18, 2018 amendments (the “Amendments”) to the Rules and Regulations for Control of Emissions from the Handling and Storage of Bulk Solid Materials (the “BSM Rules”). The Amendments primarily address additional requirements relating to the defined term of “Manganese-Bearing Materials.” AZR has invested approximately $2 million to comply with the existing BSM Rules. The Amendments threaten to impose even more costs upon AZR without justification considering that AZR’s operations do not contribute to the public health risks which the Amendments are intended to address. AZR has been a good neighbor within its community. It has not caused fugitive dust problems. It has not created threats to the public health due to manganese or any other toxic substances. What it does do is provide good jobs to its employees and provides an environmentally beneficial operation that uses waste material which would otherwise go to a landfill and turns that material into useful products. AZR appreciates that at other locations within the City of Chicago, there have been developments that warranted regulating certain businesses to address identified problems that presented a risk to the public health or environment.