.INEOS ABS agreed to enter into an Administrative Consent Order (ACO) in which the company is required to ensure compliance with the Hazardous Organic NESHAP at 40 C.F.R. ?? 63.168(c) 63.174(b)(3)(i) and 63.172(m), and the Group IV Polymers and Resin NESHAP at 40 C.F.R. ? 63.1331(a)(9)(iii)(A) and 40 C.F.R. ? 63.1311(d)(7) by, among other things, conducting a third-party leak detection and repair (LDAR)
audit that includes comparative monitoring. INEOS ABS must develop an LDAR Program Plan document based on the LDAR Audit findings as well as a corrective action program plan (CAPP) to address issued identified during the LDAR Audit and comparative monitoring findings, and must implement the corrective actions identified in the CAPP in accordance with the terms of the ACO.