EPA identified emissions escaping a coating line (Litho Line #4) using an infrared camera during an inspection. Litho Line #4 is subject to the requirements of NESHAP KKKK as a permanent total enclosure (PTE). By failing to capture all emissions generated at Litho Line #4, BWAY failed to maintain the PTE, a violation of NESHAP KKKK. This case has a concurrent Consent Agreement and Final Order that includes a penalty of $140,000.
This ACO requires BWAY to add new ductwork to expand ducting to the exit of the oven at Litho Line #4, install a new blower to route emissions from Litho Line #4 to an existing thermal oxidizer, and modify the duct header connection to the existing thermal oxidizer. Following these modifications, BWAY will conduct a performance test to confirm that Litho Line #4 meets the requirements of a PTE. These modifications to Litho Line #4 will reduce emissions by 26 tons per year, and addresses the violations set forth in the FOV issued to BWAY on December 22, 2017.