EPA v. LIGHTOLIER, INC.

Case summary

LIGHTOLIER, INC. MANUFACTURES LIGHTING FIXTURES IN ITS COMPTON, CA FACTILITY. IT IS LOCATED IN A NONATTAINMENT AREA FOR OZONE WHICH HAS RECEIVED AN EXTENSION FOR COMPLI- ANCE UNTIL 1987. LIGHTOLIER VIOL CA. STATE IMPLEMENTATION PLAN IN THAT COAT USED ON ITS FIXTURES CONTAIN MORE VOLATILE ORGANIC COMPOUNDS THAN ALLOWED BY SO COAST AIR QUAL MGMT DIST RULE 1107. A JOINT EPA/SCAQMD INSPECT OF LIGHTOLIER FACILITY ON 12/5/85, FOUND THE COMPANY YO BE IN VIOL OF RULE 1107. COMP. HAS BEEN LISTED AS A SIGNIFICANT VIOLATOR IN CDS. EPA HAS ISSUED A NOTICE OF VIOLATION ON 9/19/85. LIGHTOLIER 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 COATING PROCESSES TO LOW VOC COATINGS OR BY INSTALLATION OF ADD-ON EMISSIONS CONTROL TECHNOLOGY. LIGHTOLIER MANUFACTURES LIGHTING FIXTURES AND COATS SOME OF THESE FIXTURES IN SIX SPRAY BOOTHS AT ITS FACILITY LOCATED AT 501 WEST WALNUT STREET, LOS ANGELES, CA. LIGHTOLIER IS LISTED WITH THE CA SECRETARY OF STATE AS A CORPORATION DOING BUSINESS IN CA. HOWEVER, LIGHTOLIER IS LISTED IN DUN AND BRADSTREET AS A WHOLLY OWNED SUBSIDIARY OF GENLYTE GROUP, INC., WHICH IN TURN IS A WHOLLY OWNED SUBSID- IARY OF BAIRNCO CORPORATION. LIGHTOLIER WILL BE THE NAMED DEFENDANT IN THIS CASE, SINCE IT IS LISTED AS A CORPORATION DOING BUSINESS IN CA. AT LIGHTOLIER FABRICATED LIGHTING FIXTURES ARE COATED ON A MULTISTAGE CONVEYORIZED COATING LINE. THE LINE INCLUDES A PRE-COATING WASH CYCLE, POST-WASH DRYING OVEN, TWO CIRCULAR SPRAY BOOTHS, A TOUCH-UP BOOTH, AND AN OVEN WHERE THE COATED PARTS ARE CURED AT 350'F. LIGHTOLIER CLAIMS TO USE TWO VARIETIES OF METALLIC COATINGS, ONE HIGH PERFORMANCE ARCHITECTURAL COATING, AND NINETEEN COLORS OF A HIGH SOLID, LOW SOLVENT BAKING ENAMEL. ALL COATINGS ARE APPLIED USING ELECTROSTATIC SPRAY EQUIPMENT EXCEPT FOR THE METALLIC COATINGS, WHICH ARE APPLIED USING A HAND HELD AIR SPRAY GUN WHICH CANNOT MEET THE 65% TRANSFER EFFICIENCY REQUIREMENT. THE METALLIC COATINGS DO NOT MEET THE DEFINITION OF METALLIC COATINGS WHICH ARE EXEMPT FROM THE FEDERALLY APPROVED RULE 1107 AND EXCEED THE VOC CONTENT LIMIT FOR GENERAL COATINGS. EPA CONDUCTED AN INSPECTION ON 12/5/84. INFORMATION SUP- PLIED TO THE INSPECTOR SHOWED THAT THE TWO METALLIC COAT- INGS IN USE DID NOT CONFORM TO THE DEFINITION OF AN EXEMPT METALLIC COATING SPECIFIED. THE AIR SPRAY GUN USED TO APPLY METALLIC COATINGS BY DEFINITION DOES NOT COMPLY WITH THE 65% TRANSFER EFFICIENCY REQUIREMENTS. AS OF 1/1/85, THE FINAL LIMIT OF 275 G/L CAME INTO EFFECT. THE COATING SAMPLE TAKEN IN 12/84 ESTABLISHES THAT THE COM- PANY WAS IN VIOLATION BEGINNING ON 12/5/84. ON 9/26/85, LIGHTOLIER SUBMITTED A DOCUMENT TO THE SCAQMD WHICH STATES THAT THEIR MOST WIDELY USED COATING CONTAINED 300 GRAMS OF VOC PER LITER. BASED ON THESE FACTS EPA CONCLUDES THAT LIGHTOLIER HAS BEEN IN VIOLATION OF THE 1/1/85, FINAL LIMITS SINCE THEY CAME INTO EFFECT. THE COMPLIANCE PLAN SUBMITTED BY LIGHTOLIER PROVIDES FOR THE FOLLOWING: LIGHTOLIER PROPOSES TO MEET THE REQUIREMENTS OF RULE 1107 THROUGH THE USE OF EITHER COMPLYING COATINGS, POWDER COATINGS, OR ADD-ON CONTROLS. THE COMPANY WILL INVESTIGATE THESE COMPLIANCE ALTERNATIVES THROUGH MARCH 1986. BY MARCH 31, 1986 LIGHTOLIER WILL CHOOSE ONE OF THE THREE OPTIONS AND COMMIT TO A SPECIFIED INCREMENTAL SCHEDULE FOR ITS IMPLEMENTATION. THE FINAL COMPLIANCE DATE FOR ALL THREE OPTIONS IS 12/31/86. TO DATE THE COMPANY HAS SUBMITTED NO REPORTS OF ITS PROGRESS TOWARD COMP

Defendants (1)

• LIGHTOLIER,INC.Named in complaintNamed in settlement

Facilities (1)

• LIGHTOLIER INCORPORATED

  501 W. WALNUT STREET, COMPTON, CA, 90220

  Registry ID: 110000902694

Statutes cited

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

Enforcement conclusions (1)

• LIGHTOLIERentered 1987-01-30

  Primary law: CAA

  Federal penalty: $20,000

Timeline (7 milestones)

• 1986-03-31Referred To Dept Of Justice
• 1986-06-25Referred TO U.S. Attorney
• 1986-06-30Complaint Filed With Court
• 1987-01-30Final Order Lodged
• 1987-01-30Final Order Entered
• 1987-01-30Concluded
• 1989-01-30Enforcement Action Closed