The Defendant violated the applicable National Emission Standards for Hazardous Air Pollutants (NESHAP) general duty requirement to operate and maintain its facility flare in a manner consistent with safety and good air pollution control practices for minimizing emissions,40 C.F.R. 63.6(e)(1). In addition, the Defendant violated numerous conditions in its facility Title V operating permit, including a minimum flare destruction efficiency requirement and emission limits for total hazardous air pollutants (HAPs) and volatile organic compounds (VOCs). These violations resulted from the Defendant's operation of its steam-assisted flare with excessive amounts of steam (over-steaming), which diluted the flare flame, reduced the flare's combustion and destruction efficiency, and caused excess HAP and VOC emissions.
In this case, EPA seeks injunctive relief to enhance flare monitoring and operation, to ensure that a proper amount of steam is added at all times. The injunctive relief sought will prevent over-steaming, optimize the flare's combustion and destruction efficiencies, and minimize HAP and VOC emissions.