On September 7, 2022, EPA Region 6 issued a Consent Decree and Final Order under its authority pursuant to the CAA to Graphic Packaging International, LLC ( GPI ) located in Queen City, Texas. The CAFO was issued in response to the following violations:
1. Failure to control HAP emissions from the digesters in violation of 40 C.F.R. ? 63.443(c) (NESHAPs Subpart S).
2. Failure to visually inspect all components within the closed vent system for evidence of defects in violation of 40 C.F.R. ? 63.453(k)(2) (NESHAPs Subpart S).
3. Failure to include the instances of CMS downtime in violation of 40 C.F.R. ? 63.867(c)(1)(viii) (NESHAPs Subpart MM).
4. Failure to include the exceedance of LK1?s established parameters in August 2018 in violation of 40 C.F.R. ? 63.867(c)(1)(vii) (NESHAPs Subpart MM).
The CAFO requires GPI to submit the following:
1. A copy of the digester inspection standard operating procedure and inspection schedule adopted by GPI.
2. Updated Facility LDAR Site-Specific Inspection Plan (?LDAR Plan?).
3. LDAR Training Protocol and Program, which requires initial and annual training for the following employees in the Pulp and Power areas who have duties relevant to LDAR:
i. The Environmental Department Air Specialist;
ii. The Pulp and Power process area Manufacturing Managers and their superintendents; and
iii. The maintenance planners and maintenance superintendents for both areas.
4. Updated reporting protocols to ensure downtime and deviation