Flint Group violated the NESHAP by monitoring pressure relief devices less frequently than on a monthly basis, failing to have a logbook in the Initial Notification or during the EPA April Inspection containing a list, summary description, or diagram(s) showing the location of all equipment in organic HAP service, failing to record the equipment type and identification number, the nature of the leak, the date the leak was detected, each attempt to repair the leak, methods of repair, any delay of repair, or the date of successful repair of every leak that occurred at the facility, and failing to identify which components are subject to periodic monitoring and describing the types of equipment to be monitored in the Initial Notification. There is a concurrent Administrative Consent Order, requiring Flint Group to produce and submit documents that meet the standards of NESHAP Subpart HHHHH to EPA and the Indiana Department of Environment Management (IDEM), install, operate, maintain, and repair (as necessary) emergency relief valves on process vessels, and get a 3rd party audit of their Leak Detection and Repair program.
This CAFO requires Flint Group to pay a penalty of $75,000 and resolves the FOV issued to Flint Group on September 27, 2018.