EPA issued a Consent Agreement and Final Order (CAFO) commencing and concluding an action against Owens Corning Roofing and Asphalt LLC (Owens Corning) for alleged violations of the Clean Air Act. The CAFO alleges that Owens Corning exceeded emission limits from its Title V permits for hydrogen chloride (HCl) at two asphalt converters. The CAFO requires Owens Corning to pay a penalty of $90,00 and complete a supplemental environmental project (SEP) at the Medina facility. The SEP will result in a unique control unit for the control of HCl and will cost no less than $240,00. On March 27, 2017, EPA and Owens Corning entered into a CAFO to resolve alleged violations of the Ohio State Implementation Plan. The CAFO required Owens Corning to pay a penalty of $90,000 and spend at least $240,000 to implement a Supplemental Environmental Project (SEP) that would reduce HCl emissions from asphalt blow stills that use a ferric chloride catalyst. The CAFO was unique in that it was structured in a way that would require additional penalty payment if the HCl reduction system had a control efficiency less than 80 percent.
Owens Corning contacted EPA in late 2017 to provide an update on the SEP. As no other facility in the industry was known to control HCl at asphalt blow stills, preliminary engineering studies were required. Based on these engineering studies, Owens Corning determined that they could not ensure that the previously proposed HCl reduction systems would effectively red