The Administrative Consent Order (ACO) for Liberty Casting Company, LLC (Liberty Casting), Delaware, Ohio addresses violations regarding National Emission Standards for Hazardous Air Pollutants for Iron and Steel Foundries (Foundry NESHAP) at 40 C.F.R. 63.7680 through 63.7765, Subpart EEEEE. Specifically, Liberty Casting is subject to the Foundry NESHAP and failed to demonstrate compliance with all the applicable provisions, including particulate matter (PM) emission and opacity limits, initial notification, monitoring, recordkeeping, and reporting. During negotiations, Liberty Casting, among other things, installed hoods, a baghouse to capture and control PM emissions from its three induction furnaces, and a bag leak detection system in the baghouse. On March 8 and 9, 2017, Liberty Casting demonstrated compliance with all limits by conducting a performance stack test on the baghouse which controls emissions from all three induction furnaces. As part of an accompanying Consent Agreement and Final Order (CAFO), Liberty Casting is required to pay a penalty of $118,190 and spend $350,000 to complete one of two SEPs: changing 20% of their foundry (lake) sand to ceramic sand for use in their molds (which does not break down and does not create particulate matter emissions) or installing additional baghouses (not required by any regulation) within the shop.
This ACO requires Liberty Casting to submit semi-annual deviations reports to EPA, and addresses the violations set forth i