EPA v. CORRY-JAMESTOWN CORPORATION

Case summary

CORRY JAMESTOWN MANUFACTURES OFFICE FURNITURE IN ITS VAN NUYS, CA FACILITY. IT IS LOCATED IN A NONATTAINMENT AREA FOR OZONE WHICH HAS RECEIVED AN EXTENSION FOR COMPLIANCE UNTIL 1987. CORRY JAMESTOWN IS AN IOWA CORPORATION REGIS- TERED AS DOING BUSINESS IN CA WITH CORPORATE HEADQUARTERS IN MUSCATINE, IOWA. CORRY JAMESTOWN VIOLATED THE CA STATE IMPLEMENTATION PLAN IN THAT THE COATINGS USED ON ITS OFFICE FURNITURE CONTAIN MORE VOLATILE ORGANIC COMPOUNDS THAN ALLOWED BY SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT (SCAQMD) RULE 1107. THE COMPANY HAS BEEN DESIGNATED A SIGNIFICANT VIOLATOR AS DEFINED IN SPMS. A JOINT EPA AND SCAQMD INSPECTION OF THE CORRY JAMESTOWN FACILITY ON 12/5/84 FOUND THE COMPANY TO BE IN VIOLATION OF ITS APPROVED COMPLIANCE PLAN. EPA ISSUED A NOV ON 9/19/85. CORRY JAMESTOWN HAS SUBMITTED TO REGION 9 A PROPOSED COM- PLIANCE PLAN THAT WOULD BRING THE COMPANY'S FACILITY INTO COMPLIANCE WITH SCAQMD RULE 1107 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. DESCRIPTION OF VIOLATIONS LARGE METAL PARTS AT CORRY JAMESTOWN ARE COATED ON A SPRAY COATING LINE, WHERE THEY ARE SPRAYED WITH HAND HELD ELECTRO- STATIC SPRAY GUNS. THESE PARTS ARE MOVED TO A OVEN WHERE THEY ARE CURED AT 375 F. SOME SMALLER INTERIOR PARTS, SUCH AS DRAWER DIVIDERS, ARE COATED ON A DIP LINE WHICH CONSISTS OF THREE DIP TANKS. AT THE TIME OF THE INSPECTION, CORRY JAMESTOWN WAS ATTEMPT ING TO REACH COMPLIANCE THROUGH THE EQUIVALENCY PROVISION IN RULE 1107 WHICH ALLOWED THE COMPANY TO OFFSET EMISSIONS FROM COATINGS WHICH EXCEEDED THE VOC CONTENT LIMIT WITH EMISSION CREDITS GAINED BY THE USE OF WATERBASE COATINGS IN THEIR DIP TANKS. CORRY JAMESTOWN HAD AN APPROVED EQUIVAL- ENCY PLAN FILED WITH THE SCAQMD. ON JANUARY 22, 1985, THE SCAQMD FOUND THE COMPANY TO BE IN VIOLATION OF THE TERMS OF ITS EQUIVALENCY PLAN. THE COMPANY HAS BEEN DESIGNATED A SIG NIFICANT VIOLATOR AS DEFINED IN SPMS. EPA CONDUCTED AN INSPECTION OF THE FACILITY ON DECEMBER 5, 1984. DURING THE INSPECTION THE COMPANY REPORTED THAT IT HAD BEEN HAVING PROBLEMS WITH APPLYING THE HIGH SOLIDS COAT- ING WHICH WAS SPECIFIED IN ITS EQUIVALENCY PLAN, AND HAD BEEN USING A COVENTIONAL COATING IN ITS PLACE. BECAUSE OF THE AMOUNT OF CONVENTIONAL COATING BEING USED AT THE TIME OF THE INSPECTION, CORRY JAMESTOWN BELIEVED THAT IT HAD NOT BEEN IN COMPLIANCE WITH ITS EQUIVALENCY PLAN SINCE SEPTEMBER 1984. THEY HAD NOT MAINTAINED COATING USAGE RECORDS ON A DAILY BASIS, AS THE EQUIVALENCY PROVISION IN THE RULE REQUIRES. COATING SAMPLES WERE FOUND TO CONTAIN 350 AND 570 GRAMS OF VOC PER LITER RESPECTIVELY, WHICH IS IN EXCESS OF THE LIMIT IN RULE 1107. IN ADDITION , A SAMPLE OF THE WATERBASE COATING WAS FOUND TO EXCEED THE VOC CONTENT REPORTED TO THE SCAQMD IN ORDER TO OBTAIN CREDIT UNDER THE EQUIVALENCY PROVISION. METALLIC COATINGS USED BY CORRY JAMESTOWN MUST MEET THE VOC CONTENT LIMIT FOR GENERAL COATINGS, SINCE THEY DO NOT MEET THE DEFINITION OF EXEMPT METALLICS. EPA REQUESTS AN INJUNCTION REQUIRING CORRY-JAMESTOWN TO COME INTO COMPLIANCE WITH FULE 1107. CORRY-JAMESTOWN HAS SUBMITTED AN APPROVABLE COMPLIANCE SCHEDULE WHICH SHOULD BE EMBODIED IN A CONSENT DECREE. PURSUANT TO THE 1984 EPA CIVIL PENALTY POLICY, THE APPROPRIATE CIVIL PENALTY IS $28,492.

Defendants (1)

• CORRY-JAMESTOWN CORPORATIONNamed in complaintNamed in settlement

Facilities (1)

• HOLGA INCORPORATED

  7901 WOODLEY AVENUE, VAN NUYS, CA, 91409

  Registry ID: 110000887755

Statutes cited

• CAA 110 — Implementation Plan for National Primary and Secondary Ambient Air Quality Standards
• CAA 113 — Clean Air Act

Enforcement conclusions (1)

• CORRY JAMESTOWN CORPORATIONentered 1987-03-31

  Primary law: CAA

  Federal penalty: $30,000

Timeline (7 milestones)

• 1986-03-31Referred To Dept Of Justice
• 1986-06-25Referred TO U.S. Attorney
• 1986-06-30Complaint Filed With Court
• 1987-03-31Final Order Lodged
• 1987-03-31Final Order Entered
• 1987-03-31Concluded
• 1989-03-27Enforcement Action Closed