Prairie AeroSurface Components LLC
1. What this is
Aerospace metal finisher, indirect discharger to POTW under 40 CFR Part 433. Chronic compliance issues on chromium, plus PFAS in surfactants and HCN safety exposure in cyanide-bath line.
- POTW pretreatment audit flagged 7 chromium exceedances in last 18 months.
- Categorical user — subject to local limits plus 40 CFR Part 433 numerics.
- PFAS source-control letter from POTW received Q1; response overdue.
- Operator turnover (3 plant managers in 24 months) — institutional drift on SOPs.
2. What we'd propose
Categorical pretreatment redesign with PFAS polishing step. Lifts Prairie out of categorical non-compliance and pre-empts the next ELG round. ~$2.8–4.2M capex over 18 months.
Cost of alternative — 5-year view
| Dimension | Their path (point-fix) | Our proposal |
|---|---|---|
| Year-1 capex | $650K | $2.8M |
| Annual surcharge exposure | $180K × 5 yr | $0 |
| Forced retrofit (next ELG) | $2.1M (yr 3) | Included |
| Enforcement risk (5-yr expected) | $1.4M | $0 |
| Safety-incident exposure (HCN) | $2.0M+ | Mitigated |
| 5-YEAR TOTAL | $7.05M | $2.8M |
Their $650K point-fix path costs ~$7M over 5 years when surcharges, forced retrofits, and enforcement exposure are priced in. Our proposal is ~$2.8M, risk extinguished.