Alliance Castings owns and operates a steel foundry in Alliance, Ohio. The foundry is subject to the NESHAP for Iron and Steel Foundries as well as a Permit-to-Install and a Title V Permit. In a March 24, 2015 Notice and Finding of Violation, EPA alleged that Alliance Castings had violated several applicable requirements from each of these, including:
1. NESHAP for Iron and Steel Foundries
a. Failure to install a properly sized baghouse to control EAF emissions during tapping and charging (the canopy baghouse);
b. Failure to conduct opacity observations of foundry operations concurrently with the particulate matter performance test;
c. Poor operation and maintenance of the baghouse;
d. Failure to have a complete Operation and Maintenance Plan;
e. Late installation of a bag leak detection system on the canopy baghouse; and
f. Failure of the bag leak detection system to detect broken bags.
2. Title V Permit
a. Significant deviations from the baghouse pressure drop limits.
3. Permit-to-Install 15-01570
a. Failed PM10 performance test for EUs (emission unit) P040, P041, P042, P043, and P044;
b. Failure to achieve 99.9% control of PM emissions for EUs P040, P041, P042, P043, and P044;
c. Failed VOC performance test for EUs P047, P048 and P049;
d. Failure to achieve 99.9% control of VOC emissions for EUs P047, P048 and P049; and
e. Significant deviations from the baghouse pressure drop limits.
4. Permit-to-Install P0116125, issued September 4, 2014
a. Incomplete pe