THE VIOLATIONS DESCRIBED IN THE REFERRAL WERE IDENTIFIED DURING AN EPA FULL AIR COMPLIANCE EVALUATION AT THE SOUTHWIRE FACILITY ON STATE ROUTE 271 NORTH IN HAWESVILLE, KY. A FULL AIR COMPLIANCE INSPECTION MUST INCLUDE PHYSICALLY VISITING A FACILITY AND REVIEWING ALL REQUIRED REPORTS AND UNDERLYING REPORTS, THE TITLE V ANNUAL COMPLIANCE CERTIFICATIONS, AND THE PROCESS PARAMETERS AND COMPLIANCE TESTS. THE FULL COMPLIANCE EVALUATION WAS CONDUCTED ON JULY 12/13 12, 2004. AS A RESULT OF THAT FULL COMPLIANCE EVALUATION, EPA HAS DETERMINED THAT SOUTHWIRE HAS VIOLATED VARIOUS PROVISIONS OF THE CAA.
A. SPECIFICALLY, SOUTHWIRE HAS VIOLATED THE HAZAROUS AIR POLLUTANT PROVISION OF SECTION 112 OF CAA, AS IMPLEMENTED BY REGULATIONS AT 40 CFR PART 63, SUBPART A (GENERAL PROVISIONS), AND SUBPART RRR (NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR SECONDARY ALUMINUM PRODUCTION). THESE VIOLATIONS INCLUDE:
1. SOUTHWIRE FAILED TO CALCULATE THE EMISSION LIMITS OF PARTICULATE MATTER (PM) AND HYDROGEN CHLORINE (HCI) FOR THE EXISTING SECONDARY ALUMINUM PROCESSING UNIT (IN-LINE FLUXER LOCATED IN MILL 3, MELTING FURNACES #1, #2, AND #3, HOLDING FURNACES #1, #2, #3, AND #4, AND COMBINATION FURNACES #5 AND #6) AS REQUIRED BY 40 CFR SECTION 63.1505(k), TO MAINTAIN THE OPERATION, MAINTENANCE AND MONITORING PLAN AS REQUIRED BY 40 CFR 63.1510(b), SECTION 63.1510(s), AND SECTION 63.1513(e) AND TO CALCULATE AND RECORD THE 3-DAY, 24-HOUR ROLLING EMISSIONS FOR PM AND HCI FOR THE EXISTING