Solvay Specialty Polymers LLC (Solvay) owns and operates a specialty plastics manufacturing facility in Marietta, Ohio. At its facility, Solvay manufactures polymers and resins that are formed into high-performance plastics for a wide variety of purposes including aircraft, automotive, and medical devices. Solvay emits monochlorobenzene, methyl chloride, and other hazardous air pollutants (HAPs) in a combined quantity of over 25 tons per year, and is thus a major source of HAPs, as defined in Section 112(a) of the Clean Air Act, 42 U.S.C. ? 7412(a).
On September 28, 2016, EPA issued a Finding of Violation (FOV), alleging violations of the following National Emissions Standards for Hazardous Air Pollutants (NESHAP): Subpart FFFF for Miscellaneous Organic Chemicals Manufacturing (MON); Subpart G for Synthetic Organic Chemical Manufacturing Industry for Process Vents, Storage Vessels, Transfer Operation, and Wastewater (HON); Subpart F for Organic Hazardous Air Pollutants from the Synthetic Organic Chemical Manufacturing Industry; Subpart UU for Equipment Leaks; and Subpart SS for Closed Vent Systems, Control Devices, Recovery Devices and Routing to a Fuel Gas System or a Process. Specifically, among other things, Solvay failed to: (1) perform process condenser uncontrolled HAP emission evaluation and demonstrate proper operation of process condensers used for any boiling operations; (2) properly determine its wastewater streams group status and associated controls; (3) inst