DynaChem, Inc. (DynaChem) owns and operates an industrial resins, aromatic sulfonic acids, and specialty chemicals manufacturing facility at 15662 East 980 Road, Westville, Illinois. The U.S. Environmental Protection Agency issued a Finding of Violation to DynaChem on September 23, 2010 for violating Section 112 of the Clean Air Act, 42 U.S.C. § 7412; the National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing, at 40 C.F.R. Part 63, Subpart FFFF (the MON); the National Emissions Standards for Organic Hazardous Air Pollutants for Equipment Leaks, at 40 C.F.R. Part 63, Subpart H; and EPA Reference Method 21, at 40 C.F.R. Part 60, Appendix A, by failing to a) identify each piece of equipment subject to the MON equipment leak standards such that it can be distinguished readily from equipment that is not subject; b) equip each open-ended line with a cap, blind flange, plug, or second valve; and c) monitor valves and connectors subject to the MON equipment leak standards in accordance with Method 21. EPA discovered these violations through an inspection it conducted on July 19-23, 2010.
EPA is issuing the Administrative Penalty Order concurrently with this Consent Agreement and Final Order (CAFO). DynaChem demonstrated compliance by a) revising its isometric drawings to identify completely all components subject to the MON; b) properly blocking each open-ended line, training its staff to reinforce the open-ended line requirement