On January 24, 2018 CLCM sent a letter to residents near our facility in St. Francis announcing our plans to install an RTO:
To: St. Francis Resident
From: Container Life Cycle Management (CLCM) LLC
Subj: Announcement Regarding Enhanced Response to Community Concerns
Date: January 24, 2018
As members of the St. Francis community, we are contacting you to provide an update on progress to address concerns about the Mid-America reconditioning facility on Pennsylvania Avenue. We have been listening to neighbors’ complaints and working with regulators to identify solutions that go beyond continued compliance with our existing air emissions permit.
We share the community's interest in an expeditious resolution of neighbors’ concerns. As a result, we are accelerating a solution by installing a piece of control equipment called a regenerative thermal oxidizer (RTO) at the St. Francis plant, which represents a multi-million dollar investment in the St. Francis community. We will submit the applications for appropriate permits within the next couple of weeks.
What is an RTO?
An RTO is a piece of emissions control equipment that uses thermal oxidation to reduce air emissions from industrial operations. Thermal oxidation is widely recognized as the most effective way to destroy odor-causing compounds and is commonly used throughout the United States for a wide variety of processes. CLCM will be among the first companies to implement this technology in the drum reconditioning field. The RTO will resolve odors by converting related compounds into water and usable heat.
When will the RTO be ready for use?
The RTO will be custom-manufactured for CLCM. Following installation and testing, and once the appropriate permits are issued, we anticipate that the RTO should be operational by late September. Our timeline is contingent on timely construction of the equipment and permit approvals granted by regulators. We are doing, and will do, everything we can on our end to expedite this schedule.
What will be done to address the odors in the meantime?
While awaiting RTO start up, we have worked towards minimizing odors – and will continue to do so – by maintaining strict compliance with our existing air permit and further adjusting production to reduce emissions. To date, we have also taken other steps to reduce smells, including raising the primary stack by 20 feet. We are aware these measures have not resolved all concerns and are committed to examining further strategies.
Do these odors create a health risk?
Although we hear the complaints that the odors emitted from our facility are unpleasant, all available test data and studies indicate that these odors do not represent a health threat. We will continue to monitor the data and review the latest studies to protect the health of our workers and neighbors.
We have not taken the overall situation at St. Francis lightly. In addition to our efforts to eliminate odors, we have addressed the MMSD’s water discharge compliance issue. The facility continues to operate within permitted pretreatment limits and we intend to maintain that status. Remember, all our discharge water has to meet pre-treatment limits and is regulated by MMSD, which further treats the discharge at their plant.
It is important to keep in mind that reconditioning companies like CLCM perform a valuable environmental service. CLCM and other reconditioners clean, refurbish and repaint millions of containers every year so that they can be reused multiple times before being recycled. Without the industry, these containers would otherwise be landfilled or discarded, and other raw materials would be consumed in the manufacture of millions of new, single-use containers every year.
We are committed to being a good neighbor in your community. Although we would have liked to communicate with you more, we are limited on the information we can share while active litigation and regulatory activities are ongoing. We will continue to be limited as we finalize discussions with regulators. Please know that our lack of communication at times does not equate to inaction.
To keep you updated on the RTO progress at St. Francis, as well as on other matters regarding the facility, we have established a website where you can access information, provide feedback or submit questions. The website is available at www.clcmwi.com. Or, if you prefer, you can send feedback or ask questions via our hotline at 414-502-7358 or email email@example.com.
Our highest priority has been — and will continue to be — the health and safety of our employees and the communities in which we operate. We will continue to work to address issues in cooperation with regulators, state officials and area residents.