Louis Dreyfus failed to operate its mineral oil control system in the manner in which it was operated during its stack test, in violation of the facility?s Title V permit. Louis Dreyfus has retested to demonstrate compliance and it operating its mineral oil control system in a manner consistent with the most recent test and has thus returned to compliance with this condition of its Title V permit. The ACO requires that Louis Dreyfus continue complying and report any deviations over the next two years to EPA.
Additionally, the ACO requires Louis Dreyfus to submit annual emission reports and, in those reports, to report the temporary boiler separately from the Main Boiler. Lastly, the ACO requires that Louis Dreyfus correct its permit to reflect the actual capacities of the boilers Main Boiler and temporary boiler. Louis Dreyfus will also be entering into a concurrent CAFO with EPA to resolve the penalty liability associated with these violations.
The ACO addresses the violations set forth in the Notice and Finding of Violation issued to Louis Dreyfus on December 19, 2018.