EPA v. DIDION MILLING-CAMBRIA - ACO

Case summary

The Administrative Consent Order (ACO) for Didion Ethanol LLC (Didion), Cambria, Wisconsin addresses violations regarding the Wisconsin SIP and the New Sources Performance Standards (NSPS) for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry (Subpart VVa). Didion: Violated its 2014 and 2018 permits by failing to consistently direct all emissions from the fermentation process to the ethanol recovery system by; o Failing to develop a malfunction prevention and abatement plan (MPAP) that contained sufficient requirements to prevent, detect, and correct malfunctions or equipment failures related to the operation of the loadout flare; o Failing to develop a MPAP that contained sufficient requirements to effectively route emissions to the regenerative thermal oxidizers (RTOs); o Failing to operate and maintain the loadout flare in conformance with good engineering practices and manufacturer?s recommendations, to minimize the possibility for the exceedance of any emission limitations; failing to operate and maintain components on top of its fermenters and beer well, and operate and maintain the system that routes emissions from the fermentation process to the ethanol recovery system and from the ethanol recovery system to the RTOs associated with the fermentation process in conformance with good engineering practices to minimize the possibility for the exceedance of any emission limitations. Violated the NSPS Subpart VVa for at least 2 months in 2018 by: o Failing to operate the flare with no visible emissions, except as allowed, in violation of 40 C.F.R. ? 60.18(c)(1); o Failing on 50 occasions to weekly check each pump in light liquid service by visual inspection for indications of liquids dripping from the pump seal, in violation of 40 C.F.R. ? 60.482-2a(a)(2). EPA is also issuing a CAFO concurrently with the ACO. Pursuant to the CAFO, Didion will pay a civil penalty of $170,000. This ACO requires Didion to: Conduct monthly or quarterly monitoring of all Covered Components on top of all fermenters and the beer well; Implement visual emission monitoring, recordkeeping, and corrective action at the ethanol railcar and tanker truck loadout areas; Install, operate, and maintain equipment on each fermenter tank and beer well that can detect and prevent venting of emissions from the Covered Components; Update recordkeeping practices for weekly pump inspections; Update and submit a modified MPAP; Submit an application to the state to make the requirements of this settlement federally-enforceable; Conduct Quality Assurance/Quality Control (QA/QC) of LDAR data and correct deficiencies. The ACO addresses the violations set forth in the NOV/FOV issued to Didion Ethanol LLC on February 25, 2019.

Defendants (1)

• DIDION MILLING-CAMBRIANamed in complaintNamed in settlement

Facilities (1)

• DIDION MILLING INC.

  501 S WILLIAMS ST, CAMBRIA, WI, 539239109

  Registry ID: 110016877021

Statutes cited

• CAA 110 — Implementation Plan for National Primary and Secondary Ambient Air Quality Standards
• CAA 111 — New Source Performance Standards

Enforcement conclusions (1)

• DIDION MILLING-CAMBRIA - ACOentered 2023-06-07

  Primary law: CAA

Timeline (2 milestones)

• 2023-06-07Final Order Issued
• 2023-06-23Enforcement Action Data Entered