On August 28, 2020, the Regional Judicial Officer ratified a combined Complaint and Consent Agreement between EPA Region III and Arkema, Inc. ( Responden ), the owner and operator of a chemical manufacturing plant located at 601 Tightsqueeze Industrial Road, Chatham, Virginia (the Facility ). The Respondent produces specialty chemicals (acrylate and methacrylate monomers and oligomers) at the Facility that are used in various manufacturing applications including coatings, graphic arts, electronics, adhesives and sealants. While not a not a Title V major source , the Facility engages in the production of chemicals whose uncontrolled HAP emissions would be greater than major source threshold ( MST ) restrictions. As a result, the Facility is subject to the Chemical Manufacturing Process Units NESHAP for its oligomers production, which requires it to obtain a Title V permit and to use federally enforceable control devices to maintain Facility HAP emissions below MST restrictions. The Respondent is also subject to a State-issued Stationary Source Permit to Modify and Operate (the Minor NSR Permit ) for its monomers production activities.
Upon review of Respondent's 2015 through 2017 Title V Permit compliance certification reports for the Facility and is subsequent (2018 and 2019) responses to information requests issued pursuant to CAA Section 114, the Region alleged that Respondent violated: (a) oligomers process equipment VOC emission control requirements of the Facil