EPA v. 3M DETROIT ABRASIVES - ACO

Case summary

3M Company violated its PTI and the Michigan SIP when the performance test of a regenerative thermal oxidizer (RTO) at the Facility indicated an overall control efficiency of 90.2%. The Facility?s PTI requires this RTO to be operated at a minimum VOC control (combined capture and destruction) efficiency of 91.2%. The low control efficiency was due to the RTO?s faulty butterfly valves which were replaced with poppet valves with pneumatic actuation on December 20, 2018. Another performance test was conducted on September 18, 2019 at which point the RTO had an overall VOC control efficiency of 94.4%. The ACO requires 3M Company to update its MAP to require all malfunctions of the RTO?s valves be corrected in a timely manner. The ACO also requires 3M Company to submit a permit amendment application to the Michigan EGLE that provides for performance testing of the RTO every five years under challenging operating conditions, with consideration given to operating with raw materials containing formaldehyde, as applicable. It addresses the violations set forth in the NOV issued to 3M Company on September 22, 2017. The case has a concurrent CAFO requiring 3M Company to pay a penalty of $89,500 and certify that it is in compliance with the Facility?s PTI and with the Michigan SIP. There are Environmental Justice concerns associated with this case, with 8 out of 11 EJ index indicators.

Defendants (1)

• 3M DETROIT ABRASIVESNamed in complaintNamed in settlement

Facilities (1)

• 3M DETROIT ABRASIVES

  11900 E 8 MILE RD, DETROIT, MI, 48205

  Registry ID: 110000593055

Statutes cited

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

Enforcement conclusions (1)

• 3M DETROIT ABRASIVES - ACOentered 2021-03-22

  Primary law: CAA

Timeline (2 milestones)

• 2021-03-22Final Order Issued
• 2021-04-13Enforcement Action Data Entered