EPA v. GRAPHIC PACKAGING INTERNATIONAL LLC - TEXARKANA MILL - CAFO ECDAT

Case summary

On September 7, 2022, EPA Region 6 issued a Consent Decree and Final Order under its authority pursuant to the CAA to Graphic Packaging International, LLC ( GPI ) located in Queen City, Texas. The CAFO was issued in response to the following violations: 1. Failure to control HAP emissions from the digesters in violation of 40 C.F.R. ? 63.443(c) (NESHAPs Subpart S). 2. Failure to visually inspect all components within the closed vent system for evidence of defects in violation of 40 C.F.R. ? 63.453(k)(2) (NESHAPs Subpart S). 3. Failure to include the instances of CMS downtime in violation of 40 C.F.R. ? 63.867(c)(1)(viii) (NESHAPs Subpart MM). 4. Failure to include the exceedance of LK1?s established parameters in August 2018 in violation of 40 C.F.R. ? 63.867(c)(1)(vii) (NESHAPs Subpart MM). The CAFO requires GPI to submit the following: 1. A copy of the digester inspection standard operating procedure and inspection schedule adopted by GPI. 2. Updated Facility LDAR Site-Specific Inspection Plan (?LDAR Plan?). 3. LDAR Training Protocol and Program, which requires initial and annual training for the following employees in the Pulp and Power areas who have duties relevant to LDAR: i. The Environmental Department Air Specialist; ii. The Pulp and Power process area Manufacturing Managers and their superintendents; and iii. The maintenance planners and maintenance superintendents for both areas. 4. Updated reporting protocols to ensure downtime and deviations relating to CMS downtime are timely reported in accordance with 40 C.F.R. ? 63.867(c)(1)(viii) and Lime Kiln excess emission events are timely reported in accordance with ? 63.867(c)(1)(vii). GPI must respond to EPA Region 6 within 90 days. Additionally, GPI must pay a penalty of $192,726 within 30 days.

Defendants (1)

• Graphic Packaging International, LLCNamed in settlement

Facilities (1)

• GRAPHIC PACKAGING INTERNATIONAL TEXARKANA MILL

  9978 FM 3129, QUEEN CITY, TX, 75572

  Registry ID: 110008148496

Statutes cited

• CAA PART63 — MACT Standards (40 CFR Part 63)

Enforcement conclusions (1)

• GRAPHIC PACKAGING INTERNATIONAL LLC - TEXARKANA MILL - CAFO ECDATentered 2022-09-07

  Primary law: CAA

  Federal penalty: $192,726

Timeline (4 milestones)

• 2022-09-07Final Order Issued
• 2022-09-15Enforcement Action Data Entered
• 2022-12-05Air Resolved
• 2022-12-05Enforcement Action Closed