CAA ? St. Francis
The complaint alleges that CLCM violated the Clean Air Act at the St. Francis Facility by: 1) failing to control VOC emissions by 85 percent; 2) failing to disclose maximum VOC emissions in its synthetic minor operating permit application; 3) failing to apply for a Title V permit; 4) operating without a Title V permit; 5) failing to determine and record HAP emissions; and, 6) failing to maintain the required exhaust airflow rate from the overspray filter at its spray booth.
At the St. Francis Facility, Defendant has installed and must continuously operate a Regenerative Thermal Oxidizer (RTO) to achieve a VOC destruction efficiency of at least 98 percent. CLCM will also construct additional emissions capture systems within the facility and must conduct performance testing to ensure the capture systems and RTO demonstrate compliance with the requirement to control VOC emissions by at least 85 percent. Defendant is required to limit the St. Francis Facility?s VOC and hazardous air pollutant emissions below major source thresholds. Defendant is also required to install various parametric monitoring equipment to ensure continuous compliance. Finally, Defendant is required to obtain construction and operating permits from Wisconsin DNR to ensure the injunctive relief elements for the St. Francis Facility survive termination of the proposed Consent Decree.
CAA ? Oak Creek
The complaint alleges that CLCM violated the Clean Air Act at the Oak Creek Facility