EPA issued a Notice of Violation to Rain CII Carbon on September 9, 2021 alleging that it violated provisions in its CAAPP Permit by failing to maintain and operate its control devices for volatile organic compounds (VOCs) and its control device for particulate matter (PM) in manners consistent with permit provisions. Discussion with Rain CII Carbon concluded that the root cause of violations with the VOC control device was due to feed plugs during operation and the root cause of violations with the PM control device was due to improper baghouse maintenance and operation procedures.
This ACO requires Rain CII Carbon to among other things, install equipment to minimize plugs and maintain proper temperature to control for VOCs and install new equipment to better monitor the baghouse and more efficiently remove fines.