9/26/05 - NOTICE OF DETERMINATION ISSUED. IN ITS DISCLOSURE LETTER TO EPA DATED OCTOBER 19, 2001, AIR LIQUIDE DISCLOSED THAT ITS FACILITY LOCATED IN MADISON, MISSISSIPPI MAY HAVE VIOLATED THE CWA BY ALLOWING DISCHARGES WHICH WERE NOT AUTHORIZED BY AN NPDES PERMIT. AIR LIQUIDE OPERATES A SMALL CARBON DIOXIDE PROCESSING FACILITY WITH LESS THAN 10 FULL-TIME EMPLOYEES AT 218 WELSENBERGER ROAD, MADISON, MS 39110. THE FACILITY RECEIVES A CO2-RICH FEED GAS FROM AN OUTSIDE PARTY, COMPRESSES IT, AND USING AMMONIA AS A REFRIGERANT, COOLS THE GAS IN ORDER TO SEPARATE IT INTO ITS MAJOR COMPONENTS. THE GAS STREAM IS THEN SENT THROUGH A PROCESS SEPARATOR AND A CARBON BED ABSORBER, FILTERED THROUGH AN ALUMINA BED DRIER, AND SENT THROUGH A FINAL STRIPPER TO PRODUCE COMMERCIAL GRADE CARBON DIOXIDE.
THE UNAUTHORIZED ACTIVITIES WERE SELF-DESCRIBED AS INTERMITTENT DISCHARGES TO FLOOR DRAINS IN THE MANUFACTURING BUILDING FROM THE FACILITY'S WASTESTREAM AND RINSATE FROM WASHING CUSTOMER'S TRANSPORT CONTAINERS. AIR LIQUIDE REPORTED THAT THE POTENTIAL VIOLATIONS WERE DISCOVERED IN THE COURSE OF A VOLUNTARY, A SYSTEMIC, AND OBJECTIVE ENVIRONMENTAL AUDIT. THE AUDIT WAS CONDUCTED BY ERM-SOUTHWEST, A THIRD PARTY ENVIRONMENTAL CONSULTING FIRM UNDER THE DIRECTION OF OUTSIDE LEGAL COUNSEL