EPA v. PAUL B. MORRIS, CO. INC.

Case summary

PAUL B. MORRIS COMPANY, INC. OPERATES A METAL PARTS COAT- ING JOB SHOP IN ITS LOS ANGELES, CALIFORNIA FACILITY. IT IS LOCATED IN A NONATTAINMENT AREA FOR OZONE WHICH HAS RECEIVED AN EXTENSION FOR COMPLIANCE UNTIL 1987. PAUL B. MORRIS VIOLATED THE CALIFORNIA STATE IMPLEMENTA- TION PLAN IN THAT THE COATINGS USED ON ITS METAL PARTS CONTAIN MORE VOLATILE ORGANIC COMPOUNDS (VOC) THAN ALLOWED BY SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT (SCAQMD) RULE 1107. MORRIS IS LISTED AS A SIGNIFICANT VIOLATOR BY CDS JOINT EPA/SCAQMD INSPECTION ON 12/4/84, OF THE PAUL B MORRIS FACILITY FOUND THE CORP IN VIOL OF RULE 1107. EPA GAVE NOV, 9/19/85. PAUL B. MORRIS 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. PAUL B. MORRIS COMPANY IS A JOB SHOP ENGAGED IN THE FAB- RICATION AND COATING OF VARIOUS METAL PARTS AT ITS FACILITY AT 1804 E. VERNON AVE., LOS ANGELES, CA, WHERE IT OPERATES THREE COATING LINES. AT PAUL B. MORRIS' LINE #1, METAL PARTS ARE CLEANED AND DRIED, THEN COATED IN ONE OF TWO SPRAY BOOTHS WITH ELECTRO- STATIC SPRAY EQUIPMENT. THE PARTS ARE THEN OVEN DRIED AT 475'F., AND LATER ASSEMBLED OR SHIPPED DIRECTLY TO THE CUS- TOMER. THIS LINE GENERALLY USES HIGH PERFORMANCE ARCHITEC- TURAL COATINGS. AT LINE #2, METAL PARTS ARE CLEANED AND DRIED, THEN COATED EITHER WITH POWDER COATINGS AT THE POWDER SPRAY BOOTH OR COATED WITH METALLIC COATINGS AT ONE OF TWO LIQUID SPRAY BOOTHS. ALL OF THE APPLICATION ON THIS LINE IS DONE ELEC- TROSTATICALLY. PARTS ARE THEN OVEN DRIED AT 400'F., AND ASSEMBLED OR SHIPPED DIRECTLY TO THE CUSTOMER. AT LINE #3, PARTS ARE CLEANED AND DRIED, THEN COATED ELECTROSTATICALLY IN ONE OF TWO SPRAY BOOTHS. THESE BOOTHS ARE NORMALLY USED TO APPLY HIGH SOLIDS GENERAL COATINGS. ONCE COATED, PARTS ARE OVEN DRIED AT 425'F., THEN ASSEMBLED OR SHIPPED DIRECTLY TO THE CUSTOMER. THIS COMPANY CLAIMS THAT ALL OF THE COATINGS IT USES NOW ARE IN FULL COMPLIANCE WITH RULE 1107, ALTHOUGH THIS HAS NOT YET BEEN DEMONSTRATED TO EPA. EPA CONDUCTED AN INSPECTION OF THE FACILITY ON 12/4/84. A COATING SAMPLE TAKEN DURING THE INSPECTION WAS FOUND TO CON- TAIN 480 GRAMS OF VOC PER LITER. THIS WAS IN EXCESS OF THE LIMIT IT WAS REQUIRED TO MEET BY RULE 1107. IDENTIFICATION OF THE VIOLATIONS WAS COMPLICATED IN THIS CASE BY THE APPARENT INABILITY OR UNWILLINGNESS ON THE PART OF THE SOURCE TO PROVIDE INFORMATION CRUCIAL TO THE COMPLI- ANCE DETERMINATION BY EPA. AT THE TIME OF INSPECTION PAUL B. MORRIS CLAIMED TO BE USING COATINGS SUBJECT TO THE GENER- AL, METALLIC, EXTREME PERFORMANCE, AND HIGH PERFORMANCE ARCHITECTURAL COATINGS LIMITS IN RULE 1107. HOWEVER, THE INSPECTOR WAS NOT ABLE TO GET DOCUMENTING EVIDENCE OF THESE SPECIAL CATEGORY CLAIMS FROM THE COMPANY. AT THE TIME OF THE 12/84, INSPECTION, THE COATING SAMPLED WAS REQUIRED TO MEET THE 360 G/L VOC CONTENT LIMIT THEN IN EFFECT FOR OVEN DRIED GENERAL COATINGS. ON 1/1/85, THE FINAL LIMIT OF 275 G/1 FOR OVEN DRIED COATINGS CAME INTO EFFECT. ON 5/1/85, PAUL B. MORRIS STATED IN A LETTER TO EPA THAT IT HAD HAD MARGINAL SUCCESS IN WORKING WITH HIGH SOLID COATINGS. THE 12/84 SAMPLE ESTABLISHES THAT PAUL B. MORRIS WAS IN VIOLATION BEGINNING ON 12/4/84. BASED ON STATEMENTS BY THE COMPANY EPA CONCLUDES THAT PAUL B.

Defendants (1)

• MORRIS, PAUL B.Named in complaintNamed in settlement

Facilities (1)

• MORRIS PAUL B CO INC

  1804 E VERNON AVE, LOS ANGELES, CA, 90058

  Registry ID: 110002650792

Statutes cited

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

Enforcement conclusions (1)

• PAUL B MORRIS CO. INC.entered 1987-03-02

  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
• 1987-03-02Final Order Entered
• 1987-03-02Concluded
• 1987-03-02Final Order Lodged
• 1989-03-02Enforcement Action Closed