EPA v. SAUDER WOODWORKING COGENERATION FACILITY

Case summary

A Notice of Violation and Finding of Violation (NOV/FOV) was issued to Sauder Woodworking Company Cogeneration Facility on April 18, 2008 in which Sauder was cited for violating opacity, NOx and CO emission limits, failing to continuously run its continuous opacity monitoring systems (COMS) and continuous emission monitoring systems (CEMS) and not fulfilling all applicable reporting requirements. A FOV was issued to Sauder on February 26, 2009 in which Sauder was cited for violating its VOC emission limit. Sauder demonstrated compliance with their CO limit by using a corrected boiler operating rate to calculate CO emissions. The recalculated CO emissions showed compliance with their limit. The remainder of the alleged violations were resolved in an Administrative Consent Order (ACO) that was mailed to Sauder on August 24, 2009. In the ACO, Sauder agreed to: increase the availability of trained maintenance personnel, maintain spare parts at the facility, take action at emission set points that are lower than emission limits and more. The violations alleged against Sauder warrant a cash penalty of $79,500. Supplemental environmental projects (SEPs), such as wood stove change outs and greenhouse-gas reducing SEPs, were discussed and evaluated. However, Sauder will pay the cash penalty and a SEP will not be implemented.

Defendants (1)

• SAUDER WOODWORKING COGENERATION FACILITYNamed in complaint

Facilities (2)

• SAUDER WOODWORKING COGENERATION FACILITY

  502 MIDDLE ST., ARCHBOLD, OH, 43502

  Registry ID: 110000383399

• SAUDER WOODWORKING COGENERATION FACILITY

  502 MIDDLE ST., ARCHBOLD, OH, 43502

  Registry ID: 110000383399

Statutes cited

• CAA 111 — New Source Performance Standards
• CAA 502 — Operating Permits (Title V)
• CAA 110 — Implementation Plan for National Primary and Secondary Ambient Air Quality Standards

Enforcement conclusions (1)

• SAUDER WOODWORKING COGENERATION FACILITYentered 2009-11-09

  Primary law: CAA

  Federal penalty: $79,500

Timeline (3 milestones)

• 2009-06-30Complaint Filed/Proposed Order
• 2009-07-08Enforcement Action Data Entered
• 2009-11-09Final Order Issued