EPA v. ROHM & HAAS CHEMICAL LLC - ACO

Case summary

EPA Region 5 will enter into an Administrative Consent Order (ACO) with The Dow Chemical Company in Kankakee, Rohm and Haas Chemicals, LLC (Dow), Kankakee, Illinois to address violations regarding the New Source Performance Standards for Volatile Organic Liquid Storage Vessels (VOL) Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 at 40 C.F.R. Part 60, Subpart Kb (Subpart Kb). Dow violated Subpart Kb by failing to equip its vinyl acetate storage vessel with any of the control systems identified in Subpart Kb. EPA issued to Dow a Finding of Violation (FOV) on December 26, 2019 for failing to comply with Subpart Kb by controlling its vinyl acetate storage vessel emissions as required. In a letter to OAQPS dated June 17, 2020, Dow requested an AMEL consisting of a pressure vessel and vapor balance system, which was approved and published in the Federal Register on July 19, 2021. This ACO sets forth a compliance schedule for the construction of a regulatorily compliant VOL storage vessel at the Facility and requires Dow to also monitor pressure readings on the storage vessel vapor space and conduct quarterly Method 21 monitoring of pressure relief devices and components of the vapor collection system on the tank, as required by the approved AMEL. Dow will also submit semi-annual compliance reports for the two-year duration of the ACO. Dow is concurrently entering into a Consent Agreement and Final Order which requires Dow to pay a penalty of $300,000 and resolves the FOV issued to Dow on December 26, 2019.

Defendants (1)

• ROHM & HAAS CHEMICAL LLCNamed in settlement

Facilities (1)

• ROHM & HAAS CHEMICAL LLC

  1400 HARVARD DR, KANKAKEE, IL, 60901-9462

  Registry ID: 110041020631

Statutes cited

• CAA 111 — New Source Performance Standards

Enforcement conclusions (1)

• ROHM & HAAS CHEMICAL LLC - ACOentered 2023-09-18

  Primary law: CAA

Timeline (2 milestones)

• 2023-09-18Final Order Issued
• 2023-09-19Enforcement Action Data Entered