EPA v. METALWORKING LUBRICANTS

Case summary

The U.S. Department of Justice and the State of Indiana, on behalf of the U.S. Environmental Protection Agency (EPA) and the Indiana Department of Environmental Management, respectively, have settled a civil action with Metalworking Lubricants Company (MLC), a used oil processing facility located in Indianapolis, Indiana. The settlement resolves alleged violations of the Clean Air Act and MLC?s Federally Enforceable State Operating Permit (FESOP). Summary of Alleged Violations ? MLC violated its FESOP by emitting more than 24 tons per year of organic hazardous air pollutants from its used oil processing facility. ? MLC violated its FESOP by failing to operate its air pollution control equipment, i.e., a Scrubber, at specific times when its oil processing tanks were in operation. ? MLC violated its FESOP by failing to determine the sulfur, organic compound, and organic hazardous compound content of each shipment of incoming waste oil using the required test methods and procedures. ? MLC violated its FESOP by failing to respond when the pressure drop across its Scrubber deviated from the required pressure drop range. ? MLC violated its FESOP by failing to keep Scrubber pressure drop logs. ? MLC violated federal rules pertaining to off-site waste operations when it began emitting or having the potential to emit 10 tons per year of a single hazardous air pollutant or 25 tons per year of any combination of hazardous air pollutants. ? MLC violated Federally Enforceable State permitting requirements by failing to apply for a major source operating permit known at a Title V permit. Highlights of Settlement ? MLC has agreed to install, operate and maintain a Carbon Adsorption System (CAS) to control organic emissions from its oil and wastewater processing tanks. The CAS will be installed downstream of MLC?s existing Scrubber used to control sulfur dioxide emissions. ? The Scrubber and CAS installed and operating in sequence will constitute MLC?s ?Emission Control System? at the Facility. ? MLC will connect all of its oil and wastewater processing tanks to the Emission Control Device using a closed-vent system that is not open to the atmosphere. ? MLC will test the Emission Control System to ensure that it removes at least 95 percent of the incoming organic emissions and emits no more than 8 pounds per hour of sulfur dioxide. ? MLC will regularly inspect its tanks for defects and monitor the closed-vent system to ensure it is operating with no detectable emissions. ? MLC will continuously monitor the concentration of organic compounds at the outlet of the CAS to know when to replace the carbon filter and measure and record the Scrubber operating parameters to ensure the Scrubber is operating properly. ? MLC will comply with a revised FESOP and keep its emissions of hazardous air pollutants to less than 10 tons per year of a single hazardous air pollutant and less than 25 tons per year of any combination of hazardous air pollutants. ? MLC will pay a penalty of $155,000 to the U.S. EPA and $155,000 to the State of Indiana.

Defendants (1)

• METALWORKING LUBRICANTSNamed in complaintNamed in settlement

Facilities (1)

• METALWORKING LUBRICANTS COMPANY

  1509 S SENATE AVE, INDIANAPOLIS, IN, 46225-1573

  Registry ID: 110072214618

Statutes cited

• CAA 112 — Hazardous Air Pollutants

Enforcement conclusions (1)

• METALWORKING LUBRICANTSentered 2022-09-20

  Primary law: CAA

  Federal penalty: $155,000 · State/local: $155,000

Timeline (5 milestones)

• 2018-03-30Referred To Dept Of Justice
• 2018-04-06Enforcement Action Data Entered
• 2022-08-05Complaint Filed With Court
• 2022-08-05Final Order Lodged
• 2022-09-20Final Order Entered