1.Evergreen failed to correctly calculate and report VOC emissions from its cleaning chemicals in its records and annual emission reports required by PTI #102-07B, in violation of the Michigan SIP R 336.1702(d) and R 336.1602(1)(a). Finally, Evergreen failed to determine the VOC content of its materials by use of EPA Method 24 or Method 24A or receive written approval by Michigan EGLE to use the manufacturers formulation data to determine the VOC content of their inks, in violation of SIP, R 336.2040(5). EPA discovered these violations through Evergreen?s initial and revised responses to EPA, after a virtual inspection was conducted in March of 2021.
EPA entered into the ACO, which resulted in Pactiv Evergreen to achieve, demonstrate, and maintain compliance with the Michigan SIP at the Facility, including all permits issued by EGLE pursuant to the Michigan SIP. Specifically was required to perform compliance testing pursuant to EPA Method 24 or Method 24A for it new inks and additives being used at the printing presses. EPA required Evergreen to obtain approval from EGLE to use the existing manufacturer (Sun Chemical) Method 24 data relating to inks and key additives used on the Flexographic Printing Presses. Evergreen was further required to update the VOC calculations used in reporting volatile fraction percentage of the inks, and obtain a permit modification to incorporate a new reporting requirement for L-Press to demonstrate ?as applied? compliance. Finally Evergreen