Ardagh?s violations of their Title V permit include failing to monitor differential pressure in the ductwork for the Line 3 printing and internal baking oven leading to the regenerative thermal oxidizer, and a failure to operate the ductwork for Lines 1 and 2 internal baking ovens at a level above negative differential pressure for 19 and 30 days, respectively.
Injunctive relief for this case includes:
- installation of a magnehelic gauge and monitoring in the ductwork of Line 3,
- implemention of a leak detection regimen,
- maintaining negative pressure in Lines 1, 2, and 3 ductworks,
- performing a stack test for the replacement RTO, and
- updates their Title V permit.
VOC reduction estimates are based on reductions that will occur due to the new LDAR program and the magenhelic gauge on the 3rd process line. EPA estimates that an additional 5% of the current emission rate of 262,077 lbs VOC/yr will be detected, and reduced through repairs.