EPA v. CELANESE CORP. (FORMERLY NATIONAL STARCH AND CHEMICAL CO.)

Case summary

EPA entered into a Consent Agreement and Final Order (CAFO) with Celanese Ltd., in Meredosia, Illinois to resolve violations of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Organic Chemical Manufacturing at 40 C.F.R. Part 63, Subpart FFFF, generally referred to as the ?MON?. The CAFO alleges that Celanese violated the MON by failing to: timely identify and meet emission control standards for two Group 1 process wastewater streams; equip certain open-ended lines with a cap, blind flange, plug, or second valve in 2008 through 2010; conduct weekly visual inspections for multiple pumps and agitators in 2008, 2009, and 2012; timely conduct an initial Method 21 leak detection inspection and annual visible, audible, or olfactory inspections for the closed-vent systems associated with two process units; operate its two flares with a flame present at all times on multiple occasions between 2009 through 2012, and acting in conformance with its startup, shutdown, and malfunction plan with respect to one flare failure in July 2010. In 2012, Celanese undertook a redesign of its overall MON Compliance System, which included modifying its wastewater treatment system by routing streams to an aeration basin. This control strategy qualifies as a Group 1 wastewater HAP control option under 40 C.F.R. ? 63.138(f). The project also included installation of an equalization tank to equalize wastewater flows to the aeration basin to sustain and optimize aerobic biological treatment. In addition to the above wastewater violations, Celanese also discovered in December 2011 that effluent from an auxiliary vacuum pump in one of its process units met the criteria for a Group 1 stream. Celanese discontinued use of this pump on December 22, 2011, and did not use the pump until it was tied into the new MON wastewater control system in 2013. These projects will reduce total HAP emissions by 166 tons per year. The CAFO provides for payment of a civil penalty of $380,000 and for Celanese to perform a Supplemental Environmental Project (SEP) valued at $175,000. The SEP consists of the replacement of six conventional gasoline vehicles operated by the City of Springfield, Illinois with plug-in electric vehicles. This SEP will allow the City to introduce plug-in electric vehicles into its fleet for the first time. The conventional vehicles will be scrapped as part of this project. The SEP is expected to reduce pollutants such as volatile organic compounds, carbon monoxide, nitrogen oxides, particulate matter, and greenhouse gases. Of particular note, the SEP is expected to achieve reductions of over 25,000 pounds of greenhouse gas emissions per year.

Defendants (1)

• CELANESE CORP. (FORMERLY NATIONAL STARCH AND CHEMINamed in complaintNamed in settlement

Facilities (1)

• CELANESE LTD

  1989 OLD NAPLES RD, MEREDOSIA, IL, 62665

  Registry ID: 110000548827

Statutes cited

• CAA 112D — MACT Standards

Enforcement conclusions (1)

• CELANESE CORP. (FORMERLY NATIONAL STARCH AND CHEMICAL CO.)entered 2014-09-25

  Primary law: CAA

  Federal penalty: $380,000 · SEP: $175,000

Timeline (4 milestones)

• 2014-09-24Enforcement Action Data Entered
• 2014-09-25Complaint Filed/Proposed Order
• 2014-09-25Final Order Issued
• 2015-06-15Air Resolved