EPA v. COATING PLACE INC - APO/CAFO

Case summary

The Consent Agreement and Final Order (CAFO) for Coating Place, Inc. (CPI), Verona, Wisconsin resolves violations regarding the Wisconsin SIP and the National Emission Standards for Hazardous Air Pollutants for Pharmaceuticals Production. CPI owns and operates a pharmaceutical manufacturing facility in Verona, Wisconsin (Facility) and emits methanol, a hazardous air pollutant. CPI has failed to: (1) demonstrate that it had conducted emissions tests at worse-case conditions; (2) operate its RTO at the temperature established during emissions tests; (3) conduct pressure tests for the prevention of equipment leaks for the duration required; (4) properly manage wastewater at its K2 Unit; (5) identify equipment subject to equipment leak requirements; and (6) identify wastewater streams and determine whether they required controls. During negotiations, CPI took the following actions: a) Modified training documents that require operators to transfer immediately any waste solvent to a closed solvent waste container; b) Conducted emissions testing to demonstrate compliance with the 98% control requirement for HAPs from process vents from K3 Coating Unit; c) Conducted wastewater stream group determinations. On December 7 and 8, 2020, CPI conducted wastewater sampling (concentration and flow) of its current wastewater streams to determine group status. The sampling showed that there were no required controls; d) Modified its plant map to clearly identify equipment subject to equipment leak requirements of Subpart H and Subpart GGG; e) Modified training documents that require operators to conduct leak testing (to look for auditory, visual, and olfactory evidence of fluid loss) and modified standard operating procedures to require a leak test duration of a minimum of one hour; and 5 f) Provided a description of the facility?s worst-case operating conditions for its RTO operation in its latest emissions test protocol and demonstrated that it had conducted emissions tests at worse-case operating conditions. This CAFO requires CPI to pay a penalty of $50,000 and resolves the NOV/FOV issued to CPI on September 24, 2019.

Defendants (1)

• COATING PLACE INCNamed in complaintNamed in settlement

Facilities (1)

• COATING PLACE LLC

  200 PAOLI ST, VERONA, WI, 535938702

  Registry ID: 110000420107

Statutes cited

• CAA 112D — MACT Standards

Enforcement conclusions (1)

• COATING PLACE INC - APO/CAFOentered 2022-03-09

  Primary law: CAA

  Federal penalty: $50,000

Timeline (3 milestones)

• 2022-03-09Final Order Issued
• 2022-03-09Complaint Filed/Proposed Order
• 2022-03-15Enforcement Action Data Entered