EPA entered into a Consent Agreement and Final Order (CAFO) with Cincinnati Renewable Fuels LLC (CRF) located in Cincinnati, Ohio to resolve violations of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Chemical Manufacturing (MON) at 40 C.F.R. Part 63, Subpart FFFF, Standards of Performance (NSPS) for Equipment Leaks of Volatile Organic Compounds (VOC) in the Synthetic Organic Chemicals Manufacturing Industry (SOCMI) for Which Construction, Reconstruction, or Modification Commenced After November 7, 2006 at 40 C.F.R. Part 60, Subpart VV; NSPS for VOCs from SOCMI Distillation Operations at 40 C.F.R. Part 63, Subpart NNN; and NSPS for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 at 40 C.F.R. Part 63, Subpart Kb.
Specifically, CRF failed to comply with the following: NSPS Subpart Kb for a methanol tank; NSPS Subpart NNN for its distillation operations; NSPS Subpart VV for all equipment that is in VOC service; and with all applicable requirements of the MON. CRF has also agreed to the terms of an Administrative Consent Order that will be entered contemporaneously with the CAFO, and will require CRF to implement an enhanced leak detection and repair program that includes a facility-wide LDAR document, quarterly quality-assurance/quality-control of its LDAR program, and a one-time third-party LDAR audit. In addit