The Administrative Consent Order (ACO) for Didion Ethanol LLC (Didion), Cambria, Wisconsin addresses violations regarding the Wisconsin SIP and the New Sources Performance Standards (NSPS) for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry (Subpart VVa).
Didion:
Violated its 2014 and 2018 permits by failing to consistently direct all emissions from the fermentation process to the ethanol recovery system by;
o Failing to develop a malfunction prevention and abatement plan (MPAP) that contained sufficient requirements to prevent, detect, and correct malfunctions or equipment failures related to the operation of the loadout flare;
o Failing to develop a MPAP that contained sufficient requirements to effectively route emissions to the regenerative thermal oxidizers (RTOs);
o Failing to operate and maintain the loadout flare in conformance with good engineering practices and manufacturer?s recommendations, to minimize the possibility for the exceedance of any emission limitations; failing to operate and maintain components on top of its fermenters and beer well, and operate and maintain the system that routes emissions from the fermentation process to the ethanol recovery system and from the ethanol recovery system to the RTOs associated with the fermentation process in conformance with good engineering practices to minimize the possibility for the exceedance of any emission limitations.
Violated the NSPS Subpart VVa for at least 2 month