Eli Lilly and Company (Lilly) owns and operates a chemical manufacturing facility at 1555 Kentucky Avenue, Indianapolis, Indiana. The U.S. Environmental Protection Agency issued two Findings of Violation to Lilly: 1) On March 21, 2007 for violating the National Emissions Standards for Pharmaceuticals Production at 40 C.F.R. Part 63, Subpart GGG (the Pharma-MACT); the National Emissions Standards for Organic Hazardous Air Pollutants (HAPs) for Equipment Leaks at 40 C.F.R. Part 63, Subpart H; and EPA Reference Method 21 at 40 C.F.R. Part 60, Appendix A (Method 21) by, among other things, failing to identify all equipment subject to the equipment leak standards of the Pharma-MACT such that it can be distinguished readily from equipment that is not subject and to perform Method 21 monitoring correctly on connectors; and 2) On March 25, 2008 for violating the Pharma-MACT by exceeding the Pharma-MACT process-based annual mass limits and failing to block each open-ended line. EPA discovered these violations through an inspection it conducted from June 19-23, 2006 and through a letter from the Indianapolis Office of Environmental Services and Lilly's Title V compliance reports. EPA referred the case to the Department of Justice on September 11, 2007 and filed a judicial complaint on February 24, 2011.
Under this Stipulation and Order of Settlement, Lilly must pay a civil penalty of $337,500. No injunctive relief is required because Lilly demonstrated compliance with the proces