On June 30, 2008, Region 5 filed a Consent Agreement and Final Order (CAFO) simultaneously commencing and resolving an administrative penalty action against Hercules Incorporated for alleged violations of the National Emission Standards for Hazardous Air Pollutants for Epoxy Resins Production and Non-Nylon Polyamides Production Requirements (MACT Subpart W), found at 40 C.F.R. Part 63, Subpart W, §§ 63.520  63.529, as well as its Federally Enforceable State Operating Permit (FESOP).
Specifically, the facility violated MACT Subpart W and its FESOP by having one open-ended line, improperly tagging components subject to MACT Subpart W, and failing to make a final repair within 15 days on one component. These violations were discovered during an inspection of the facility on July 9Â12, 2007.
Hercules has already remedied the alleged violations and has also improved its leak management system by incorporating new leak repair logs and modifying its maintenance logs to include a notification if the repair has an effect on Subpart W requirements. In addition Hercules has agreed to pay a penalty of $22,500 in settlement of all allegations in this matter. (Contact: Shannon Downey, 312-353-2151)