The attached Administrative Consent Order (ACO) for McGean-Rohco, Inc., (McGean) Cleveland, Ohio addresses violations of the National Emission Standards for Hazardous Air Pollutants for Chemical Manufacturing Area Sources at 40 C.F.R. Part 63, Subpart VVVVVV (NESHAP VVVVVV).
McGean failed to comply with NESHAP VVVVVV?s requirements, including: leak detection monitoring and repair (LDAR) requirements; emissions standard for the process vent provisions of batch and continuous process vents; identification of all wastewater streams and all applicable requirements; and the recordkeeping and reporting requirements.
McGean will simultaneously execute a consent agreement and final order to resolve this matter.
This ACO requires McGean to develop a facility-wide LDAR document, limit hazardous air pollutant (HAP) to less than 10 tons per year (tpy) of a single HAP and less than 25 tpy of combined HAPs, perform EPA Reference Method 21 for any LDAR equipment in organic HAP service to ensure that it is properly monitoring its equipment, and comply with the applicable requirements of NESHAP VVVVVV. This program addresses the violations set forth in the Finding of Violations issued to McGean on September 25, 2019.