EPA v. INGREDION

Case summary

Ingredion owns and operates a corn wet mill in Indianapolis, Indiana. In 2016 and 2017, EPA issued information requests to Ingredion to obtain records and require performance testing at the Indianapolis facility. Records provided by Ingredion identified numerous permit violations including the failure to monitor air pollution control equipment and perform corrective actions for parametric monitoring deviations. Performance testing identified particulate matter < 10 ?m (PM10) emission limit exceedances at a dryer series currently controlled only by a regenerative thermal oxidizer (RTO). EPA included these alleged violations in a Notice of Violation, issued on September 21, 2017. In settlement of this case, Ingredion will be required to install, operate, and maintain a mist eliminator to provide additional control of PM10 emissions upstream of the existing RTO. Ingredion will then take a lower PM10 emission limit at the dryers. Ingredion will also be required to implement a compliance management system (CMS). The CMS is an electronic records management system that will aid Ingredion in performing its monitoring requirements and in performing the appropriate corrective actions in response to parametric monitoring deviations. As a part of the settlement, Ingredion will pay a civil penalty of $1,139,600 to be split with the State of Indiana as follows: $850,000 to the United States and $289,600 to the State. Ingredion has also agreed to implement a state-only Supplemental Environmental Project, consisting of a monetary contribution in the amount of $560,400 to the State?s brownfields program to support development in and around Marion County, Indiana. Ingredion is also implementing mitigation projects to further reduce PM emissions. These mitigations projects consist of paving multiple unpaved surfaces at the facility to reduce fugitive dust and the replacement of onsite older model locomotives with modern (Tier 4 engine) locomotives. EPA estimates that Ingredion caused 129 tons of excess PM10 emissions. This settlement, through the installation of the mist eliminator and implementation of the mitigation projects, will yield 100% mitigation of the 129 tons in approximately seven years. Ingredion spent the following: New Emissions Control Equipment - $543,000 CMS Capital Cost - $231,000 Paving Projects - $3,000,000 Engine Lease Costs for Five Years - $3,060,000

Defendants (1)

• INGREDIONNamed in complaintNamed in settlement

Facilities (1)

• INGREDION INCORPORATED INDIANAPOLIS PLANT

  1515 S DROVER ST, INDIANAPOLIS, IN, 46221-1735

  Registry ID: 110000397197

Statutes cited

• CAA 502 — Operating Permits (Title V)

Enforcement conclusions (1)

• INGREDIONentered 2024-02-26

  Primary law: CAA

  Federal penalty: $850,000 · State/local: $850,000

Timeline (5 milestones)

• 2020-08-03Referred To Dept Of Justice
• 2020-09-02Enforcement Action Data Entered
• 2023-11-21Complaint Filed With Court
• 2023-11-21Final Order Lodged
• 2024-02-26Final Order Entered