Region 5 issued to DPI a Finding of Violation on April 1, 2014, alleging that DPI 1) failed to conduct performance testing of its No. 1 and No. 3 Biofilters on time, 2) failed to maintain required minimum operating temperatures on its No. 1 and No. 3 Biofilters and Regenerative Catalytic Oxidizer (RCO) necessary for achieving required control efficiency, and 3) operated its No. 3 Biofilter with a collapsed roof panel, thereby failing to operate in a manner consistent with good air pollution control practices for minimizing emissions. In addition to the allegations in the FOV, DPI failed to demonstrate it was meeting required control efficiency on its No. 1. Biofilter during a subsequent stack test conducted on April 11, 2014.
This ACO requires DPI to achieve, demonstrate and maintain compliance with 40 C.F.R. Part 63, Subpart DDDD (the National Emissions Standards for Hazardous Air Pollutants) for Plywood and Composite Wood Products), at its Alpena, Michigan facility. The ACO also requires DPI to amend its Preventative Maintenance/Malfunction Abatement Plan (PM/MAP) to include quarterly sorbent tube testing of formaldehyde emissions from the No. 1 and No. 3 Biofilters. The PM/MAP is a federally-enforceable attachment to DPI?s Title V permit. The sorbent tube testing will serve as an early warning system of potential deviations from the control efficiency standards in Subpart DDDD and will allow DPI to take early corrective actions to avoid potential future violations. For t