3M Company violated its PTI and the Michigan SIP when the performance test of a regenerative thermal oxidizer (RTO) at the Facility indicated an overall control efficiency of 90.2%. The Facility?s PTI requires this RTO to be operated at a minimum VOC control (combined capture and destruction) efficiency of 91.2%. The low control efficiency was due to the RTO?s faulty butterfly valves which were replaced with poppet valves with pneumatic actuation on December 20, 2018. Another performance test was conducted on September 18, 2019 at which point the RTO had an overall VOC control efficiency of 94.4%. The case has a concurrent ACO [EPA-5-21-113(a)-MI-01] that requires the Facility to submit a permit amendment application to the Michigan EGLE that provides for performance testing of the RTO every five years under challenging operating conditions, with consideration given to operating with raw materials containing formaldhyde, as applicable. The CAFO requires 3M Company to pay a penalty of $89,500, certify that it is in compliance with the Facility?s PTI and with the Michigan SIP, and resolves the NOV issued to 3M Company on September 22, 2017.
There are Environmental Justice concerns associated with this case, with 8 out of 11 EJ index indicators.