On March 23, 2023, EPA Region 6 issued a Consent Agreement and Final Order under its authority pursuant to the CAA to International Paper Company - Orange Mill (IP Orange) located in Orange, Texas. The CAFO was issued in response to the following violations:
1. Failure to control chemiwasher gases that contain TRS in excess of 5 ppm by volume on a dry basis, corrected to 10 percent oxygen in violation of 40 C.F.R. ? 60.283(a)(1).\
2. Failure to complete repair prior to resuming operations in violation of 40 C.F.R. ? 63.453(l)(1) (referencing 40 C.F.R. ? 63.964(b)(2)).
3. Failure to conduct a visible inspection 30 days after the previous visible inspection on each of the enclosure openings, closed-vent systems, and valve or closure mechanisms in violation of 40 C.F.R. ? 63.453(k).
4. Failure to conduct a visible inspection within 30 days of the previous visible inspection on pulping process condensate closed collection systems in violation of 40 C.F.R. ? 63.453(l).
5. Failure to record the equipment type and identification of each equipment being inspected in violation of 40 C.F.R. ? 63.454(b).
6. Failure to report opacity exceedances in violation of 40 C.F.R. ? 63.867(c).
The CAFO requires IP Orange to submit the following:
1. A copy of revised Semiannual Excess Emissions Reports.
2. Updated Facility LDAR Site-Specific Inspection Plan (?LDAR Plan?).
3. LDAR Training Protocol and Program, which requires initial and annual training for employees who have duties r