Hydrite owns and operates a chemical blending and manufacturing facility in Cottage Grove, Wisconsin. The site is also a RCRA Part B treatment, storage, and disposal facility that manages and processes spent solvents from other companies. In June 2017, Region 5 issued a Notice and Finding of Violation (NOV/FOV) to Hydrite following an inspection of the facility on April 3-6, 2017. In the NOV/FOV, Region 5 alleged Hydrite failed to include hazardous air pollutants (HAP) fugitive emissions from sources, including leaking fugitive emission equipment, storage tank venting, open drums, and truck loading operations, in its emissions calculations. Therefore, Hydrite has been underestimating its HAP fugitive emissions, and has been a major source of HAP emissions, subject to requirements in the NESHAPs for Miscellaneous Organic Manufacturing (40 C.F.R. Part 63, Subpart FFFF, or MON), and Organic Liquid Distribution (40 C.F.R. Part 63, Subpart EEEE, or OLD).
Prior to the initial compliance date of the MON, Hydrite applied for and received synthetic minor limits in its operation permit and was no longer considered a major source of HAP with respect to 40 C.F.R. Part 63 standards. In April 2017, Region 5 performed an LDAR-focused inspection at Hydrite, and issued an NOV/FOV in June 2017, finding Hydrite has been underestimating its HAP fugitive emissions, and has been a major source of HAP emissions under the MON as well as the OLD. Region 5 followed up with another site visit in Apr