EPA entered into a Consent Agreement and Final Order (CAFO) with Celanese Ltd., in Meredosia, Illinois to resolve violations of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Organic Chemical Manufacturing at 40 C.F.R. Part 63, Subpart FFFF, generally referred to as the ?MON?.
The CAFO alleges that Celanese violated the MON by failing to: timely identify and meet emission control standards for two Group 1 process wastewater streams; equip certain open-ended lines with a cap, blind flange, plug, or second valve in 2008 through 2010; conduct weekly visual inspections for multiple pumps and agitators in 2008, 2009, and 2012; timely conduct an initial Method 21 leak detection inspection and annual visible, audible, or olfactory inspections for the closed-vent systems associated with two process units; operate its two flares with a flame present at all times on multiple occasions between 2009 through 2012, and acting in conformance with its startup, shutdown, and malfunction plan with respect to one flare failure in July 2010.
In 2012, Celanese undertook a redesign of its overall MON Compliance System, which included modifying its wastewater treatment system by routing streams to an aeration basin. This control strategy qualifies as a Group 1 wastewater HAP control option under 40 C.F.R. ? 63.138(f). The project also included installation of an equalization tank to equalize wastewater flows to the aeration basin to sustain and optimiz