EPA v. THE GOODRICH COMPANY

Case summary

NOTICE OF DETERMINATION ISSUED 9/28/05. IN A LETTER TO EPA DATED APRIL 11, 2003, RESPONDENT NOTIFIED EPA OF POTENTIAL VIOLATIONS OF NESHAP STANDARDS UNDER CLEAN AIR ACT AND COMMITTED TO PROVIDING A DETAILED SUMMARY OF VIOLATIONS. IN A FOLLOW-UP LETTER DATED MAY 20, 2003, GOODRICH IDENTIFIED TEN SPECIFIC VIOLATIONS INCLUDING REQUIREMTNS OF ITS CAA TITLE V OPERATING PERMIT, NESHAP REQUIREMENTS, A RCRA REPORTING REQUIREMENT, AND A CLEAN WATER RECORD KEEPING REQUIREMENT. Violation 1: Title V statements of compliance were not timely submitted for years 2001 and 2002, in accordance with Condition II of the facility���s title V permit and the Clean Air Act. Violation 2: Quarterly inspections of the chromium scrubber were not being conducted or documented in accordance with 40 C.F.R. 63.342(f)(3)(B), 63.346(b)(1), and Condition III(C)(2) of the facility���s title V permit during the period beginning on or about January 7, 2000 to May 20, 2003. Violation 3: The chromium scrubber���s magnehellic gauges were not operating as required by 40 C.F.R. 63.343(c)(1)(ii), 63.6(e) and Conditions III(C)(1)-(2) of the facility���s title V permit during the period beginning on or about November 2002 to May 20, 2003. Violation 4: Pressure drop readings from the chromium scrubber���s magnehelic gauges were not being monitored or recorded on a daily basis since November 2002 as required by 40 C.F.R. 63.343(c)(1)(ii), 63.344(d)(5)(v) and Condition III(C)(2) of the facility���s title V permit during the period beginning on or about November 2002 to May 20, 2003. Violation 5: Documentation of weekly measurements of the vapor degreaser���s air blanket temperature was unavailable for the period beginning on or about September 3, 1998 to May 20, 2003. Documentation is required by 40 C.F.R. 63.466(a) and Condition III(A)(3) of the facility���s title V permit. Violation 6: The vapor control device on the degreaser was not operating as required by 40 C.F.R. 63.6(e) and Conditions III(A)(2) and (E)(8) of the facility���s title V permit during the period beginning on or about August 27, 1998 to May 14, 2003. Violation 7: The vapor degreaser���s monthly or quarterly hoist speeds were not measured or documented as required by 40 C.F.R. 63.466(c), 63.467(b)(1), and Condition III(A)(3) of the facility���s title V permit during the period beginning on or about September 25, 1998 to May 20, 2003. Violation 8: The facility had not yet established the vapor degreaser���s initial and baseline reduced room draft parameters or satisfied the periodic monitoring requirements as required by 40 C.F.R. 63.466(d), 63.467(b)(1), and Condition III(A)(3) of the facility���s title V permit, which should have occurred on or about August 27, 1998. Violation 9: An exception report was not submitted to the Florida Department of Environmental Protection (FDEP) for three manifests that were not returned to Goodrich within 45 days as required by 40 C.F.R. 262.42(a)(2). The manifests should have been submitted on or before May 5, 2002; May 19, 2002; and December 22, 2002. Violation 10: The facility did not maintain documentation of daily wastewater treatment operations as required by 40 C.F.R. 403.12(o) and its permit for industrial discharge during the period beginning on or about June 1, 2002 to May 20, 2003.

Defendants (1)

• THE GOODRICH COMPANYNamed in settlement

Facilities (2)

• GOODRICH CORPORATION

  3201 NW 167TH STREET, MIAMI GARDENS, FL, 330564253

  Registry ID: 110000872048

• GOODRICH CORPORATION

  3201 NW 167TH STREET, MIAMI GARDENS, FL, 330564253

  Registry ID: 110000872048

Statutes cited

• CWA 308 — Information Request, Records, Entry
• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste
• CAA 112 — Hazardous Air Pollutants

Enforcement conclusions (1)

• THE GOODRICH COMPANYentered 2005-09-28

  Primary law: CAA

Timeline (3 milestones)

• 2005-09-28Final Order Issued
• 2005-09-28Enforcement Action Closed
• 2005-09-29Enforcement Action Data Entered