On September 4, 2012, EPA issued a Notice of Violation and Finding of Violation to BWAY for violations of the Clean Air Act (CAA or the Act), the Illinois State Implementation Plan (SIP), Title I and V permit requirements, the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Surface Coating of Metal Cans, and the NESHAP for Surface Coating of Miscellaneous Metal Parts and Products (40 C.F.R. Part 63, Subpart MMMM).
The ACO requires BWAY to install permanent total enclosures (PTEs) at the coating lines, utilize the control efficiency/outlet concentration compliance option as sole means of complying with the can coating NESHAP, and to submit an application to amend its Title V Permit to reflect the same.