EPA conducted an inspection of the facility in May 2017 and issued a Finding of Violation in September 2017. After almost four years of responding to Defendant?s requests to meeting with EPA political leadership and ultimately unsuccessful negotiations, the United States filed a complaint in the United States District Court for the Southern District of Ohio on October 5, 2021. In the complaint, the U.S. alleged violations of: 1) the HON; 2) EPA?s Reference Method 21 monitoring requirements; and 3) Altivia?s Title V permit. In the Complaint, the United States alleges that Altivia:
1. failed to install and operate controls on a process vent in violation of 40 C.F.R. ? 63.113(a);
2. failed to properly perform Method 21 monitoring at valves in violation of 40 C.F.R. ?? 63.168(b) and 63.180(b);
3. failed to monitor valves in light liquid service or gas/vapor service in violation of 40 C.F.R. ? 63.168;
4. failed to monitor connectors in light liquid service or gas/vapor service in violation of 40 C.F.R. ? 63.174;
5. failed to control emissions from individual drain systems in violation of 40 C.F.R. ? 63.136(a);
6. failed to control emissions from liquid streams in open systems in violation of 40 C.F.R. ? 63.136(a);
7. failed to control wastewater streams at the facility?s open biological wastewater treatment unit, in violation of 40 C.F.R. ? 63.138(b)-(f); and
8. violated provisions of the facility?s Title V permit which corresponded to the above provisions.
Under