The Consent Agreement and Final Order (CAFO) for Coating Place, Inc. (CPI), Verona, Wisconsin resolves violations regarding the Wisconsin SIP and the National Emission Standards for Hazardous Air Pollutants for Pharmaceuticals Production.
CPI owns and operates a pharmaceutical manufacturing facility in Verona, Wisconsin (Facility) and emits methanol, a hazardous air pollutant.
CPI has failed to:
(1) demonstrate that it had conducted emissions tests at worse-case conditions;
(2) operate its RTO at the temperature established during emissions tests;
(3) conduct pressure tests for the prevention of equipment leaks for the duration required;
(4) properly manage wastewater at its K2 Unit;
(5) identify equipment subject to equipment leak requirements; and
(6) identify wastewater streams and determine whether they required controls.
During negotiations, CPI took the following actions:
a) Modified training documents that require operators to transfer immediately any waste solvent to a closed solvent waste container;
b) Conducted emissions testing to demonstrate compliance with the 98% control requirement for HAPs from process vents from K3 Coating Unit;
c) Conducted wastewater stream group determinations. On December 7 and 8, 2020, CPI conducted wastewater sampling (concentration and flow) of its current wastewater streams to determine group status. The sampling showed that there were no required controls;
d) Modified its plant map to clearly identify equipment