EPA agreed to a Consent Agreement and Final Order (CAFO) commencing and concluding an action against FCA US LLC, Toledo South Paint Facility (FCA) located in Toledo, Ohio, for alleged violations of the Clean Air Act. The CAFO alleges that FCA failed to maintain 100% capture efficiency to control for VOC emissions at its E-coat oven in violation of its Title V Permit.
This violation was discovered during an inspection of the Facility where EPA observed visible emissions exiting the E-Coat oven. EPA issued a Finding of Violation (FOV) to FCA on December 21, 2016. Subsequently, FCA indicated that the visible emissions which EPA had observed during its inspection of the Facility originated from the edge of an access door on the E-Coat oven. FCA also indicated that it had subsequently repaired seals and latches on the oven access doors, thereby reducing emissions, and afterwards observed no visible emissions from the E-Coat oven. During continued discussions, FCA recognized that there was minimal outward air flow from the access doors, despite its repairs. On January 30, 2020, Ohio EPA approved an FCA permit application to replace the existing permit language specifying a 100% capture efficiency and minimum 95% control efficiency for the RTO with a requirement for a minimum, overall control efficiency of 95%.
The CAFO requires FCA to pay a civil penalty of $29,590.