EPA v. FCA US LLC- WRANGLER PAINT FACILITY - APO/CAFO

Case summary

EPA agreed to a Consent Agreement and Final Order (CAFO) commencing and concluding an action against FCA US LLC, Toledo South Paint Facility (FCA) located in Toledo, Ohio, for alleged violations of the Clean Air Act. The CAFO alleges that FCA failed to maintain 100% capture efficiency to control for VOC emissions at its E-coat oven in violation of its Title V Permit. This violation was discovered during an inspection of the Facility where EPA observed visible emissions exiting the E-Coat oven. EPA issued a Finding of Violation (FOV) to FCA on December 21, 2016. Subsequently, FCA indicated that the visible emissions which EPA had observed during its inspection of the Facility originated from the edge of an access door on the E-Coat oven. FCA also indicated that it had subsequently repaired seals and latches on the oven access doors, thereby reducing emissions, and afterwards observed no visible emissions from the E-Coat oven. During continued discussions, FCA recognized that there was minimal outward air flow from the access doors, despite its repairs. On January 30, 2020, Ohio EPA approved an FCA permit application to replace the existing permit language specifying a 100% capture efficiency and minimum 95% control efficiency for the RTO with a requirement for a minimum, overall control efficiency of 95%. The CAFO requires FCA to pay a civil penalty of $29,590.

Defendants (1)

• FCA US LLC- WRANGLER PAINT FACILITYNamed in complaintNamed in settlement

Facilities (2)

• FCA US LLC - TOLEDO SOUTH PAINT FACILITY

  3800 STICKNEY AVENUE, TOLEDO, OH, 43608

  Registry ID: 110022477416

• FCA US LLC - TOLEDO SOUTH PAINT FACILITY

  3800 STICKNEY AVENUE, TOLEDO, OH, 43608

  Registry ID: 110022477416

Statutes cited

• CAA 112D — MACT Standards
• CAA 110 — Implementation Plan for National Primary and Secondary Ambient Air Quality Standards

Enforcement conclusions (1)

• FCA US LLC- WRANGLER PAINT FACILITY - APO/CAFOentered 2020-09-09

  Primary law: CAA

  Federal penalty: $29,590

Timeline (5 milestones)

• 2020-09-09Final Order Issued
• 2020-09-09Complaint Filed/Proposed Order
• 2020-09-18Enforcement Action Data Entered
• 2020-09-23Air Resolved
• 2020-09-23Enforcement Action Closed