Solutia owns and operates a resin manufacturing facility in Trenton, Michigan (facility). At its facility, Solutia processes and emits vinyl acetate, acetaldehyde, and methanol, hazardous air pollutants (HAP) listed in Section 112(b) of the CAA, 42 U.S.C. ? 7412(b), and other volatile organic compounds (VOC).
On December 19, 2018, EPA issued a Notice of Violation and Finding of Violation (NOV/FOV), alleging violation of the NESHAP for Chemical Manufacturing Area Sources at 40 C.F.R. Part 63, Subpart VVVVVV, the Michigan State Implementation Plan, and its Title V Permit. Specifically, among other things, Solutia failed to: (1) limit emissions of vinyl acetate from the facility to less than its Title V permit limit of 9.0 tons per year, as calculated on a 12-month rolling basis, starting in February 2015 through January 2016; (2) limit emissions of volatile organic compounds (VOC) from the facility to less than its Title V permit limit of 221 pounds per day for several days in 2013, 2014, and 2015; and (3) conduct quarterly monitoring for leaks for over 1,200 leak detection and repair (LDAR) components that were part of its LDAR program and for several components that the facility failed to include in its LDAR program. Since issuance of the NOV/FOV, EPA discovered that Solutia failed to accurately quantify fugitive hazardous air pollutants (HAP) emissions from its Subpart VVVVVV components and fugitive VOC emissions from its pumps and connectors.
Solutia has been in