U.S. EPA issued an FOV to Abbott on December 22, 2004 for violations of the National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks at 40 C.F.R. Part 63, Subpart H (Subpart H), the Pharma-MACT, and Method 21. As of October 21, 2002, certain areas at Abbott's North Chicago plant have been subject to the Pharma-MACT, including the LDAR Provisions stated within the rule. Prior to this date, these areas were subject to the LDAR Provisions of Subpart H. Specifically, in the FOV, Abbott was cited for failing to 1) identify equipment subject to the LDAR Provisions such that it can be distinguished from equipment that is not subject; 2) monitor all valves and connectors subject to the LDAR Provisions by October 24, 1994 and October 24, 1995, respectively, under Subpart H, and by October 21, 2003 under the Pharma-MACT; 3) monitor all valves subject to the LDAR Provisions quarterly under Subpart H; 4) check by visual inspection each calendar week all pumps and agitators subject to the LDAR Provisions; 5) monitor LDAR affected equipment per Method 21; 6) inspect vapor suppression equipment per Method 21; 7) establish the correct minimum regeneration steam flow rate for one of its carbon adsorbers per the Pharma-MACT; 8) keep the regeneration frequency of this carbon adsorber above the established minimum value; and 9) keep the pH of one of its scrubbers above the established minimum value.
Per this CAFO/APO, Abbott must pay a penalty of $57,372. In ad