1/8/2020 - ADMINISTRATIVE COMPLIANCE ORDER ISSUED.
FINDINGS:
MONUMENT IS THE OWNER AND OPERATOR OF A MISCELLANEOUS ORGANIC CHEMICAL MANUFACTURING FACLIITY LOCATED IN BRANDENBURG, MEADE COUNTY, KY, AIR QUALITY PERMIT V-16-039, ISSUED FEB 24, 2017.
ACCORDING TO MONUMENT'S TITLE V PERMIT AND NOTICE OF COMPLIANCE STATUS REPORT (NOCSR), MONUMENT'S MCPU IS AN AFFECTED SOURCE SUBJECT TO 40 CFR PART 63, SUBPART FFFF, AND MONUMENT'S MCPU INCLUDES STORAGE TANKS M-200B AND M-129.
MONUMENT'S MCPU - INCLUDING TANKS M-200B AND M-129 -- IS AN AFFECTED SOURCE BECAUSE IT PRODUCES MATERIALS IDENTIFIED AT 40 CFR 63.2435(b)(1)(i) AND (ii) AND IT OTHERWISE SATISFIES THE CRITERIA FOR AN AFFECTED SOURCE.
TANKS M-200B AND M-129 ARE GROUP 1 STORAGE TANKS BECAUSE THEY HAVE A CAPACITY GREATER THAN 10,000 GALLONS OF A HAP AT GREATER THAN OR EQUAL TO 6.9 KILOPASCALS.
ACCORDING TO MONUMENT'S NOCSR AND FACILITY OPERATIONAL SPECIFICATIONS, MONUMENT SELECTED THE SECOND COMPLIANCE OPTION PROVIDED BY 40 CFR PART 63, SUBPART FFFF, TABLE 4, WHICH REQUIRES THE OWNER OR OPERATOR TOO REDUCE TOTAL HAP EMISSIONS BY GREATER THAN 95 PERCENT BY WEIGHT OR TO LESS THAN 20 PPMV OF TOTAL ORGANIC CARBON (TOC) OR ORGANIC HAP BY VENTING EMISSIONS THROUGH A CLOSED VENT SYSTEM TO ANY COMBINATION OF CONTROL DEVICES (EXCLUDING A FLARE).
ON NOV 5-8, 2018, EPA INSPECTORS CONDUCTED AN AIR COMPLIANCE EVALUATION AT THE MONUMENT FACILITY UTILIZING A FORWARD LOOKING INFRARED GAS FINDER (FLIR) CAMERA.
THE FLIR CA