On September 23, 2019, EPA Region 6 issued a Consent Agreement and Final Order (CAFO) under its authority pursuant to Section 113(d) of the Clean Air Act to International Paper Company (?IP?) located Mansfield, Louisiana. The CAFO was issued in response to the following violations:
1. Failure to conduct two monthly visual inspections of the Facility's closed collection and closed-vent systems at least 21 calendar-days, in violation of 40 C.F.R. ? 63.453(m) (NESHAPs Subpart S), Specific Requirements 914, 929, and 930 of the Title V Permit, and Section 502(a) of the Act, 42 U.S.C. ? 7661a(a);
2. Failure to perform negative pressure tests at an open standpipe at the Stripped Condensate Tank during calendar years 2015 and 2016, in violation of 40 C.F.R. ? 63.453(k)(4) (NESHAPs Subpart S);
3. Failure to report 9 periods of excess TRS emissions in semiannual reports for the Lime Kiln and No. 2 Recovery Boiler in 2015 and 2016, in violation of 40 C.F.R. ? 60.284(d) (NSPS Subpart BB);
4. Failure to report all emissions of NOx and CO in the annual emissions inventories for reporting years 2014 and 2015 as to the HVLC/LVLC Incinerator, in violation LAC 33:III.919.B.1 of the federally-approved Louisiana SIP.
The CAFO requires IP to:
1. Submit to LDEQ corrected emissions inventories for reporting years 2014 and 2015 and revised semiannual reports to include TRS emissions for 2015 and 2016 within 60 days, and submit documentation to EPA demonstrating the corrections within