EPA Region 5 issued two Findings of Violation (FOVs) for CAA violations to the Facility, in 2005 and 2008. The Consent Decree resolves the violations alleged in the FOVs. The Consent Decree resolves CAA violations of the following NESHAPs: 1) 40 C.F.R. Part 63, Subpart F (the National Emission Standards for Organic Hazardous Air Pollutants from the Synthetic Organic Chemical Manufacturing Industry); 2) 40 C.F.R. Part 63, Subpart G (the National Emission Standards for Organic Hazardous Air Pollutants from the Synthetic Organic Chemical Manufacturing Industry for Process Vents, Storage Vessels, Transfer Operations, and Wastewater); and 3) 40 C.F.R. Part 63, Subpart H (the National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks). The claims included the failure to properly perform EPA Reference Method 21, control emissions from drains and trenches for liquid streams in open systems, control emissions from an oil/water separator, properly equip open-ended valves or lines with a closure device, properly equip each sampling connection system, and conduct a valid EPA Method 2A flow rate test.
TERMS OF THE DECREE
Compliance Requirements
In December 2006, the Facility completed the covering of over 350 drains and 12 trenches with a tightly fitted solid cover (TFSC) in the Phenol process unit. By installing the TFSCs, the Facility addressed the failure to equip the sampling connection systems. The TFSC controls emissions from any purges that