EPA v. WESLOCK

Case summary

WESLOCK MANUFACTURES LOCKS IN ITS LOS ANGELES, CA FACILI- TY. IT IS LOCATED IN A NONATTAINMENT AREA FOR OZONE WHICH HAS RECEIVED AN EXTENSION FOR COMPLIANCE UNTIL 1987. WESLOCK VIOLATED THE CALIFORNIA STATE IMPLEMENTATION PLAN IN THAT THE COATINGS USED ON ITS LOCKS CONTAIN MORE VOLATILE ORGANIC COMPOUNDS THAN ALLOWED BY SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT (SCAQMD) RULE 1107. A JOINT EPA AND SCAQMD INSPECTION OF THE WESLOCK FACILITY ON 12/6/84 FOUND THE CORP TO BE IN VIOL OF RULE 1107. EPA ISSUED WESLOCK A NOV ON 9/19/85. WESLOCK'S BEEN LISTED BY CDS AS SIGNIF VIOL TOR. WESLOCK HAS SUBMITTED TO REGION 9 A PROPOSED COMPLIANCE PLAN THAT WOULD BRING THE COMPANY'S FACILITY INTO COMPLIANCE BY THE END OF 1986. COMPLIANCE WILL BE ACHIEVED EITHER BY CONVERSION OF THE COMPANY'S COATING PROCESSES TO LOW VOC COATINGS OR BY INSTALLATION OF ADD-ON EMISSIONS CONTROL TECHNOLOGY. WESLOCK FABRICATES, CLEAR COATS, AND ASSEMBLES METAL PARTS FOR DOOR LOCKS AND ASSOCIATED FITTINGS AT ITS FACILITY LOCATED AT 13344 SOUTH MAIN STREET, LOS ANGELES, CA, WHERE IT OPERATES FOUR COATING LINES. METAL PARTS ARE COATED ON THREE CONVEYORIZED LINES USING AUTOMATIC ELECTROSTATIC SPRAY DISCS. THE COATED PARTS ARE CURED IN AN OVEN AT 325' F BEFORE ASSEMBLY. ON A FOURTH MANUAL LINE, PARTS ARE PLACED ON A TRAY AND COATED BY HAND USING AN AIR SPRAY GUN WHICH DOES NOT MEET THE 65% TRANSFER EFFICIENCY REQUIREMENT. THESE PARTS ARE BAKED AT 320'F. METAL PARTS ARE ALSO COATED WITH LACQUERS IN TWO DIP TANK MACHINES. INSIDE THE MACHINES, A BASKET FULL OF METAL PARTS IS DIPPED IN THE LACQUER SOLUTION, THEN SPUN DRY TOWARDS THE TOP OF THE MACHINE AND REMOVED. THESE PARTS ARE ALSO BAKED AT 320'F. WESLOCK USES ONLY CLEAR BAKING ENAMELS AND LACQUERS. WESLOCK IS ATTEMPTING TO REACH FINAL COMPLIANCE WITH RULE 1107 THROUGH THE EQUIVALENCY PROVISION IN THE RULE. THE COMPANY HAS NOT BEEN ABLE TO DEMONSTRATE EQUIVALENCE WITH THE FINAL LIMITS IN THE FEDERALLY APPROVED RULE. EPA CONDUCTED AN INSPECTION OF THE FACILITY ON 12/6/84. INFORMATION SUPPLIED BY THE SOURCE SHOWED THAT THREE COAT- INGS IN USE EXCEEDED THE 420 GRAMS OF VOC PER LITER LIMIT IN EFFECT FOR EXTREME PERFORMANCE COATINGS AT THE TIME OF THE INSPECTION. ACCORDING TO THE COMPANY, TWO OF THESE COATINGS HAD VOC CONTENTS OF 756 AND 749 GRAMS PER LITER RESPECTIVELY A SAMPLE TAKEN OF THE THIRD COATING AND ANALYZED BY THE SCAQMD LABORATORY WAS FOUND TO CONTAIN 670 GRAMS OF VOC PER LITER. IN ADDITION THE HAND HELD AIR SPRAY GUN IS BY DEFINITION IN VIOLATION OF THE 65% TRANSFER EFFICIENCY REQUIREMENT. STEPS TO BE TAKEN BY DEFENDANT TO ACHIEVE COMPLIANCE WESLOCK HAS ALREADY PURCHASED AND INSTALLED A HAND-HELD ELECTROSTATIC SPRAY GUN TO REPLACE THE VIOLATING AIR SPRAY GUN. WESLOCK FEELS THAT IF IT CAN SUBSTANTIALLY REDUCE THE VOC CONTENT OF THE COATING USED ON THIS LINE, IT SHOULD BE ABLE TO COMPLY WITH THE 275 G/L LIMIT THROUGH EQUIVALENCY. ACCORDINGLY, WESLOCK WILL INVESTIGATE FOUR OPTIONS ON THE HAND-HELD LINE: 1) REFORMULATING TO LOWER VOC COATINGS 2) CHANGING TO A DIFFERENT APPLICATION SYSTEM 3) OFF- LOADING A SIGNIFICANT PART OF THE NON-COMPLYING PORTION OF ITS BUSINESS, AND 4) INSTALLING AN AFTERBURNER ON THE LINE. BY 6/1/86 WESLOCK WILL DECIDE ON ONE OF THESE OPTIONS. CONTRACTS FOR PROCESS EQUIPMENT WILL BE ISSUED BY 6/15/86, AND THE EQUIPMENT WILL BE ON LINE BY 10/15/86. FINAL COM- PLIANCE WILL BE ACHIEVED BY 12/31/86.

Defendants (1)

• WESLOCK COMPANY/TRE CORPORATIONNamed in complaintNamed in settlement

Facilities (1)

• TRE ADVANCED STRUCTURES

  13344 SOUTH MAIN STREET, LOS ANGELES, CA, 90061

  Registry ID: 110033144265

Statutes cited

• CAA 113 — Clean Air Act

Enforcement conclusions (1)

• WESLOCK COMPANYentered 1987-10-07

  Primary law: CAA

  Federal penalty: $27,000

Timeline (7 milestones)

• 1986-03-31Referred To Dept Of Justice
• 1986-06-25Referred TO U.S. Attorney
• 1986-06-30Complaint Filed With Court
• 1987-10-07Final Order Lodged
• 1987-10-07Final Order Entered
• 1987-10-07Concluded
• 1989-10-09Enforcement Action Closed