This CAFO resolves alleged violations of the following NESHAPs:
Subpart ZZZZ for Stationary Reciprocating Internal Combustion Engines.
Subpart ZZZZZ for Iron and Steel Foundries Area Sources.
Subpart XXXXXX for Nine Metal Fabrication and Finishing Source Categories.
Specifically, RBA had taken almost no action to demonstrate compliance with these rules, including no or inadequate notifications, reporting, preparation and implementation of pollution prevention plans, and performance testing. We discovered these violations after notification of possible non-compliance from WDNR, a subsequent on-site inspection on August 31, 2017 and an information request of November 8, 2017. EPA and RBA agreed to a penalty based on the Clean Air Act Stationary Source Penalty Policy of $103,000 and would like to enter into a CAFO to resolve this matter.
RBA has taken corrective action to remedy these violations and return to compliance, including monitoring, submittal of notifications and reports, and upgrading of generators for improved pollution control. RBA has also agreed to implement a supplemental environmental project for improved capture and control of emissions from onsite welding operations.