UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION5



## SEP 30 2010

CERTIFIED MAIL 77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590

REPLYTO THE ATTENTION OF: AE-17J 

### RETURN RECEIPTREQUESTED Tom Tersine, Manager, EHS PPG Industries, Inc. 1

0800 South 13th Street Oak Creek, Wisconsin 53154

DearMr. Tersine: Re: Finding ofViolation PPG Industries, Inc. Oak Creek, Wisconsin

This is to advise youthat the U.S. Environmental Protection Agencyfinds that PPG Industries, Inc.'s (PPG) facility in Oak Creek, Wisconsin is in violation ofthe CleanAirAct (CAA) and associated pollution control requirements. A list ofthe requirements violated is providedbelow. We are today issuing a Finding ofViolation (FOV) to you for these violations. The CAArequires EPA to develop National Emission Standards for Hazardous Air Pollutants (NESHAP) to protect the public health and welfare. To attain andmaintain these standards, EPA promulgated Maximum Achievable Control Technology (MACT) standards to address Hazardous Air Pollutant (HAP) emissions from various source categories. PPG is in violation ofthe MACT standards thatregulate HAP emissions from Miscellaneous Organic Chemicals Manufacturing, 40 C.F.R. Part 63, SubpartFFFF (Subpart FFFF), the MACT standards that regulate HAP emissions from the Synthetic Organic Chemical Manufacturing Industry for Process Vents, Storage Vessels, Transfer Operations, and Wastewater (Subpart G), and the MACT standards that regulate HAP emissions from Equipment Leaks (Subpart UU). Section 113 ofthe CAA gives us several enforcement options to resolve these violations. The options include issuing an administrative compliance order, issuing an administrative penalty order, and bringing ajudicial civil action. We are offering you the opportunity to request a conference with us about the violations alleged in the FOV. The conference will give you the opportunity to present information onthe specific findings ofviolation, any efforts you have taken to comply, and the steps you will take to prevent future violations. Please plan for your facility's technical and managementpersonnel to take part in these discussions. Youmay have an attorney represent you at this conference.
Recycled/Recycllblt • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (50% Postconsumer)The EPA contact inthis matter is Constantinos Loukeris. Youmay call him at (312) 353-6198 to request a conference. You should make the request within 10 calendardays following receipt ofthis letter. We should hold any conference within 30 calendardays following receipt ofthis letter. Sincerely,

trector Airand Radiation Division Enclosure

cc: Daniel Schramm, WDNR

2United States Environmental Protection Agency Region 5 In the Matter of: PPG Industries, Inc. Oak Creek, Wisconsin Proceedings Pursuant to the Clean AirAct, 42 U.S.C. §§ 7401 et seq. ) ) ) Finding ofViolation ) ) EPA-5-10-WI-12 ) ) ) )

Finding ofViolation PPG Industries, Inc. (PPG) owns and operates a resin manufacturing plant at 10800 South 13th Street, Oak Creek, Wisconsin. This facility is a major source ofHazardous AirPollutants (HAP).The U.S. Environmental Protection Agency is issuing this Finding ofViolation (FOV) to youto address the alleged violations identified below. The underlying statutory and regulatory requirements include provisions ofthe Clean AirAct (CAA) and its implementing regulations. Explanation ofViolations NESHAP for Miscellaneous Organic Chemicals Manufacturing (Subpart FFFF) 1. OnNovember 10, 2003, EPA promulgated the National Emission Standards for Miscellaneous Organic Chemicals Manufacturing at 40 C.F.R. Part 63, Subpart FFFF (68 Fed. Reg. 63888). 2. Subpart FFFF, at 40 C.F.R. 

### § 63.2470(a), requires that you must meet each emission limit in Table 4 to this subpart that applies to your storage tanks, and you must meet each applicable requirement specified in paragraphs (b) through (e) ofthis section. 3. Table 4 ofSubpart FFFF requires that for each Group 1storage tank you must reduce total HAP emissions by 2:95 percent by weight orto S20 ppmv ofTOC ororganic HAP and S20 ppmv ofhydrogen halide and halogen HAP by venting emissions through a closed vent system to any combination ofcontrol devices (excluding a flare).4. Subpart FFFF, at 40 C.F.R. 

### § 63.2485(a), states that "youmust meet eachrequirement in table 7 to this subpartthat applies to yourwastewater streams and liquid streams in open systems within a miscellaneous organic chemical manufacturing process unit (MCPU), except as specified in paragraphs (b) through (o) ofthis section."

I 5. Subpart FFFF, at 40 C.F.R. 

### §63.2485(b), states that "[w]here 

### § 63.105 and§§ 63.132 through 63.148 referto compounds in table 9 ofsubpart G ofthis part 63, the compounds in tables 8 and 9 to this subpart apply for the purposes ofthis subpart." 6. Table 7 ofSubpart FFFF requires each process wastewater streamto comply with the requirements in§§ 63.132 through 63.148 and the requirements referenced therein, except as specified in§ 63.2485. 7. Subpart FFFF, at 40 C.F.R. 

### § 63.2460(c)(2)(ii), requires that when you conduct a performance test ordesign evaluation for a non-flare control device used to control emissions from batchprocess vents, you must establish emissionprofiles and conductthe test under worst-case conditions according to§ 63.1257(b)(8) instead ofunder normal operating conditions as specified in§ 63.7(e)(1). 8. Subpart FFFF, at 40 C.F.R. §63.2480(a), requires that you must meet each requirement in Table 6 to this subpart that applies to your equipment leaks, except as specified in paragraphs (b) through (d) ofthis section. 9. Table 6 ofSubpart FFFF requires that all equipment in organic HAP service must comply with the requirements ofeither40 C.F.R. part 63, subpart UU or subpart H, and the requirements referenced therein, except as specified in§ 63.2480(b) and (d), or40 C.F.R

.. part 65, subpart F, and the requirements referenced therein, except as specified in§ 63.2480(c) and (d). 10. Subpart FFFF, at 40 C.F.R. §63.2460(a), requires that you must meet each emission limit in Table 2 to this subpartthat applies to your batchprocess vents, and you must meet each applicable requirement specified in paragraphs (b) and (c) ofthis section. 11. Table 2 ofSubpart FFFF requires for eachprocess with a Group 1process vent that you must reduce collective uncontrolled organic HAP emissions from the sum ofall batch process vents within the process by 2:98 percent by weight by venting emissions from a sufficient number ofthe vents through one ormore closed-vent systems to any combination ofcontrol devices (except a flare). 12. Subpart FFFF, at 40 C.F.R. 

### § 63.2475(a), requires that you must comply with each emission limit and work practice standard in table 5 to this subpartthat applies to your 

### 2transferracks, and youmustmeet each applicable requirement inparagraphs (b) and (c) ofthis section. 13. Table 5 ofSubpart FFFF requires for each Group 1transfer rack that you must reduce emissions oftotal organic HAP by

**~98** percentby weight orto an outlet concentration :S20 ppmv as organic HAP orTOC by venting emissions through a closed-vent system to anycombination ofcontrol devices (except a flare). 14. Subpart FFFF, at 40 C.F.R. § 63.2550(i), defmes "Group 1transfer rack" as a transfer rack that loads more than 0.65 million liters/year ofliquidsthat containorganic HAP with a rack-weighted average partial pressure, as defined in § 63.111, greaterthan or equal to 1.5 pound per square inch absolute. NESHAP for the Synthetic Organic Chemical Manufacturing Industry for Process Vents, Storage Vessels, Transfer Operations, and Wastewater (Subpart G) 15. OnApril 22, 1994, EPA promulgatedthe NESHAP for the Synthetic Grganic Chemical Manufacturing Industry for Process Vents, Storage Vessels, Transfer Operations, and Wastewaterat40 C.F.R. Part 63, Subpart G (59 Fed. Reg. 19468). 16. Subpart G, at 40 C.F.R. § 63.132(a)(l), requires an owner or operatorto determine whether each wastewater stream requires control for Table 9 compounds by complying with the requirements in eitherparagraph (a)(1)(i) or (a)(1)(ii) ofthis section, and comply with the requirements in paragraph (a)(l)(iii) ofthis section. 17. Subpart G, at 40 C.F.R. § 63.132(c), provides instructions for determining whether a wastewater stream is Group 1or Group 2 for Table 9 compounds. This section states, "Total annual average concentration shall be determined according to the procedures specified in § 63.144(b) ofthis subpart. Annual average flow rate shall be determined according to the procedures specified in§ 63.144(c) ofthis subpart." 18. Subpart G, at 40 C.F.R. § 63.144(b ), requires an owner oroperatorthat elects to comply withparagraph (a)(1) ofthis sectionbymeasuring the concentration for the relevant Table 9 compounds, to determine the annual average concentration for eachwastewater stream, either at the point ofdetermination, or downstream ofthe point ofdetermination with adjustment for concentration changes made according to paragraph (b)(6) ofthis section. 40 C.F.R. § 63.144(b)(5) requires a minimum ofthree samples from each wastewater stream, which may be grab samples orcomposite samples. 19. Subpart G, at 40 C.F.R. § 63.111 defines "Rack-weighted average partial pressure" as the throughput weighted average ofthe average maximumtrue vapor pressure ofliquids
3containing organic HAP transferred at a transferrack. The rack-weighted average partial pressure shall be calculatedusingthe equationbelow: Where: P = Rack-weighted average partial pressure, kilopascals.

P;= Individual HAP maximum true vaporpressure, kilopascals, = X;*P, where X; is the mole fraction of compound i in the liquid. G;= Yearly volume ofeach liquid that contains organic HAP that is transferred at the rack, liters. i = Each liquid that contains HAP that is transferred at the rack. 20. Subpart G, at 40 C.F.R. § 63.111 defines "Maximum true vaporpressure" as "the equilibrium partial pressure exerted bythe total organic HAP's in the stored ortransferred liquid at the temperature equal to the highest calendar-month average ofthe liquid storage ortransfer temperature for liquids stored ortransferred above orbelowthe ambient temperature or at the local maximum monthly average temperature as reported by the National Weather Service for liquids stored ortransferred atthe ambient temperature, as determined: (1) In accordance with methods described in American Petroleum Institute Publication 2517, Evaporative Loss From External Floating-RoofTanks (incorporated by reference as specified in § 63.14 ofsubpart A ofthis part); or (2) As obtained from standard reference texts; or (3) As determined by the American Society for Testing and Materials Method 02879-83 or96 (incorporated by reference as specified in§ 63.14 ofsubpart A ofthis part); or (4) Any othermethod approved bythe Administrator." NESHAP for Equipment Leaks (Subpart UU) 21. OnJune 29, 1999, EPA promulgated the NESHAP for Equipment Leaks- Control Level 2 Standards at40 C.F.R. Part 63, Subpart UU (64 Fed. Reg. 34899). 22. As stated in paragraph 9, among the requirements of40 C.F.R. Part 63, Subpart FFFF is 40 C.F.R. § 63.2480(a) and Table 6, which require that organic manufacturing facilities comply with the NESHAP for Equipment Leaks at Subpart UU or Subpart H of40 C.F.R. 4Part 63 or40 C.P.R. Part 65, Subpart F. PPG elected the NESHAP for Equipment Leaks 40 C.P.R. Part 63, Subpart UU. 23. Subpart UU, at 40 C.P.R.§ 63.1022(a), states that "equipment subject to this subpart shall be identified. Identification ofthe equipment does not require physical tagging of the equipment. For example, the equipmentmay be identified on a plant site plan, in log entries, bydesignation ofprocess unit or affected facility boundaries by some form of weatherproofidentification." 24. Subpart UU, at 40 C.P.R. 

### §63.1033(b)(l), requires that each open-ended valve or line shall be equipped with a cap, blind flange, plug, ora second valve, except as provided in 

### §§ 63.1021(b), 63.1036, 63.1037, and paragraphs (c) and (d) ofthis section. The cap, blind flange, plug, or second valve shall seal the openend at all times except during operations requiring process fluid flow through the open-ended valve or line, orduring maintenance. The operational provisions ofparagraphs (b)(2) and (b)(3) ofthis section also apply. 25. Subpart UU, at 40 C.P.R.§ 63.1033(b)(3), requires that when a double block and bleed system is being used, the bleed valve orline may remain open during operations that require venting the line betweenthe block valves but shall comply with paragraph (b)(1) ofthis section at all othertimes. 26. SubpartUU, at40 C.P.R.§ 63.1025(b)(l), requires that valves shall be monitored to detect leaks bythe method specified in§ 63.1023(b) and, as applicable,§ 63.1023(c). 27. Subpart UU, at 40 C.P.R.§ 63.1023(b)(l), requires that instrument monitoring shall comply with Method 21 of40 C.P.R. Part 60, Appendix A. 28. Section 8.3.1 ofMethod 21 of40 C.P.R. Part 60, Appendix A states that you must "[p]lace the probe inlet at the surface ofthe component interface where leakage could occur. Move the probe along the interfaceperiphery while observing the instrument readout. Ifan increased meterreading is observed, slowly sample the interface where leakage is indicateduntil the maximum meterreading is optained. Leave the probe inlet at this maximumreading location for approximately two times the instrument response time." 29. Subpart UU, at 40 C.P.R. 

### §63.1032(c), requires that each closed-purge, closed-loop, or closed vent system as required in paragraph (b) ofthis section shall meet the applicable requirements specified in paragraphs (c)(l) through (c)(5) ofthis section. 30. Subpart UU, at 40 C.P.R. §63.1032(c)(5), requires containers that are part ofa closed purge system must be covered orclosed when not being filled oremptied. 5NESHAP (Subpart GGG) 31. As stated inparagraph 7, Subpart FFFF at 40 C.F.R. § 63.2460(c)(2)(ii) requires that when you conduct a performance test ordesign evaluationfor a non-flare control device used to control emissions from batchprocess vents, you must establish emissionprofiles and conduct the test underworst-case conditions according to 40 C.F.R. § 63.1257(b)(8) instead ofunder normal operation conditions as specified in§ 63.7(e)(1). Subpart GGG at 40 C.F.R. § 63.1257(b)(8), requires testing ofemissions onequipment where the flow ofgaseous emissions is intermittent (batch operations) shall be conducted as specified in paragraphs (b)(8)(i) through (iii) ofthis section, whichrequires testing at "absolute worst-case conditions orhypothetical worst-case conditions." General Allegations 32. PPGowns and operates a resin manufacturing plant at 10800 South 13th Street, Oak Creek, Wisconsin (Plant), which is a major source ofHAP, as defined in 40 C.F.R. § 63.2 ofSubpart A. 33. PPG owns or operates miscellaneous organic chemical manufacturing units (MCPU) as defined at 40 C.F.R. § 63.2435(b), in the resinmanufacturingprocess atthe Plant, which are subjectto the requirements of40 C.F.R. Part 63, Subpart FFFF and byreference SubpartUU and Subpart GGG. Theprocess vents, storage vessels, transfer operations, and wastewater at the Plant are also subject to the requirements at 40 C.F.R. Part 63, Subpart G. 34. FromJune 1, 2009 through June 5, 2009, EPA conducted a Clean AirAct investigation of PPGhereafterreferred to as "2009 inspection." 35. Inresponse to questions raised by EPA during the investigation the week ofJune 1, 2009 through June 5, 2009, PPG submitted a written response datedJune 25, 2009. Alleged Violations 36. Based oninformationprovided to EPA duringthe 2009 inspection, EPA found that the WTC 1903 wastewater streams receives wastewater from all ofthereactor systems and has several points ofdetermination. PPG elected to determine whether the WTC 1903 wastewater stream was Group 1 orGroup 2 for Table 9 compounds by measuring downstream ofseveral points ofdetermination; however PPG failed to adjust for concentration changes as required by40 C.F.R. § 63.144(6). This is a violation of 40 C.F.R. §§ 63.2485(a), 63.132(c), and 63.144(b)(5). 37. Based oninformationprovided to EPA during the 2009 inspection, EPAdetermined that PPGdid not evaluate WTC 1901 and WTC 1902 as wastewater streams. PPG failed to 6determine whether the wastewater streams at WTC I90I and WTC I902 are Group I or Group 2 for Table 9 compounds in violation of40 C.P.R. §§ 63.2485(a) and 63. 132(a). 38. During the 2009 inspection, EPA discovered a containerthat is used by PPGto collect residual liquids drained from block and bleed systems atthe South Meter Station. PPG failed to identify the container as a point ofdetermination and to determine whether the wastewatertherein is Group 1 orGroup 2 for Table 9 compounds in violation of 40 C.P.R.§§ 63.2485(a), 63.132(a) and by reference 63.144(b). 39. Duringthe 2009 inspection, EPAperformed monitoring for HAP leaks using Method 2I of40 C.P.R. Part 60, Appendix A and found a significantlyhigher leak rate on valves located in the Resin plantthan that reported by PPGonprevious and current monitoring equipment subjectto the MON. EPA found a leakrate of0.4 percent whereas PPG's historical monitoring indicates the previous quarterly monitoring (i.e. January 2009 through March 2009) events to have a 0 percent(%) leak rate with an average quarterly leak rate of0.04%for the period ofMay 2008 through June 20IO. PPGhas conducted deficient Method 21 leak monitoring ofvalves subjectto Subpart UU at the facility in violation of40 C.P.R.§ 63.1025(b)(I) and Method 21 of40 C.P.R. Part 60, Appendix A. 40. Based on the information providedto EPA during the 2009 inspection, EPA found that PPG does not monitor for HAP leaks atthe component interface where leakage may occurfor insulated valves located in the Resin plant. PPG failed to perform Method 21 of40 C.P.R. Part 60, Appendix A onall valves that are insulated inviolation of40 C.P.R. §§ 63.2480(a), 63.1025(b)(l), and Section 8.3.1 ofMethod 21 of40 C.P.R. Part 60, Appendix A. 4I. Based onthe informationprovidedto EPA during the 2009 inspection, EPA found that PPG did not venfy that equipment was in organic HAP servicepriorto monitoring for leaks. PPG failed to determine HAP leaks inconformance with Method 21 of40 C.P.R. Part 60, Appendix A during periods when equipment was in organic HAP service in violation of40 C.P.R. §63.2480(a) and Table 6 ofSubpart PPPP. 42. Duringthe 2009 inspection, EPA found that a significant number ofequipmenttags were missing onprocess equipment, including but not limited to the RI thin tank and R6 reactor located at the Resin plant, which were in HAP service. Although 40 C.P.R. 

### §63.1022(a) does not require physical tagging, PPG uses physical tags in conjunction with log sheets to identify equipment in service. PPG failed to identify all equipment subject to Subpart UU and to perform Method 21 of40 C.P.R. Part 60, Appendix A on suchequipment in violation ofC.P.R.§§ 63.2480(a), 63.1022(a), and Method 21 of40 C.P.R. Part 60, Appendix A. 43. During the 2009 inspection, EPA found an uncovered containerthat is part ofa closed purge system to a sampling connectionto Reactor 7. Under 40 C.P.R.§ 63.1032(c)(5), 7containers that are part ofa closed purge system are required to be covered orclosed when not being filled oremptied. PPG failed to cover a containerused in a closed purge system during periods when not being filled oremptied in violation of40 C.F.R. 

### §§ 63.2480(a), 63.1032(c), and 63.1032(c)(5). 44. During the 2009 inspection, EPA found that the open-ended lines listed below were not equipped with a cap, blind flange, plug, ora second valve. At the time ofthe inspection, operations did not require process fluid flow through these open-ended lines, and PPG was not conductingmaintenance onthe lines. PPG failed to properly equip the openended lines listed belowin violation of40 C.F.R. 

### §§ 63.2480(a) and 63.1033(b)(1):
a. 15418 Valve b. 1823 (R4 ReactorCondenser/Decanter) c. 2338 Valve d. 338 Valve (To R6 Decanter) e. R4 Reflux Sample Line f. R4 Misc. Tank g. 2853;}4 h. Valve below 3173 (evidence ofa visual dripping) 1. R6 Thin Tank FilterLine Connect to Nitrogen J. Two (2) open-ends neartag# 9340 k. 9350 Valve 1. 9357 Valve m. R2 Thin Tank Filter Line for sampling/draining the filter n. R 7 Reactor Reflux Line o. 9010 (pressure gauge valve) p. Solvent Recovery Area, Organic Waste Line near SZB-803 q. OEL between AST 125 and AST 127 r. R6 Thin Tank Drain Line s. R3 Thin Tank t. Two (2) open ends at R4 Thin Tank offthe filling area u. R3 Poly Tank near tag# 3392 (evidence ofa visual dripping) Note: The identification ofeach open-ended line may have a reference to a component nearby, if there wasn't a tag on a valve associated with the open-ended line. 45. During the EPA inspection in 2009, EPA identified 29 block and bleed open-ended systems (9 in the North Meter Station and 20 in the South Meter Station) that were not in use and did not have a cap, blind flange, plug or second valve in violation of40 C.F.R. 

### §§ 63.2480(a), 63.1033(b)(3) and 63.1033(b)(l). 46. a. During the 2009 inspection, EPA monitored closure devices (i.e. caps, blind flanges, plugs, orsecond valves) of6 open-ended lines (listed below) using Method 21 as 8specified in 40 C.F.R. Part 60, Appendix A and detected emissions at concentrations greater than 500 parts per million (ppm) as follows: 1. 2334 V Cam Lock- 2,600 ppm, u. To R6 Cam Lock- 2,200 ppm, m. 2762.26 Cam Lock- 1,200 ppm, iv. To R2 Decanter (South Meter Station)- 666 ppm, v. To R3 Thin Tank (South Meter Station)- 561 ppm, and v1. To R2 Acid/Oil (South Meter Station)- 840 ppm (evidence ofvisual dripping). b. PPG's closure devices failed to seal the open-ended lines identified in this paragraph at all times in violation of40 C.F.R. §§ 63.2480(a) and 63.1033(b)(l). 47. a. PPG uses a thermal oxidizerunit to reduce HAPs emissions from its storage tanks; howeverPPG did not operate the thermal oxidizeronthe following dates:
1. Accordingto PPG's February 27, 2009 Semi-Annual Compliance Report, PPG did not operate the thermal oxidizerunit onthe following dates: July 4, 2008, July 6, 2008, July 7, 2008, July 8, 2008, November 23, 2008, November 24,2008, November 25,2008,November26,2008,November 27, 2008, November28, 2008, November 29, 2008, November 30, 2008, December 21, 2008, December22, 2008, December 23,2008, December 24, 2008, December 25, 2008, December26, 2008, December 27, 2008, December 28, 2008 and December 31, 2008;
u. Accordingto PPG'sAugust 28, 2009 Semi-Annual Compliance Report, PPG did not operate thermal oxidizer onthe following dates: January 1, 2009, February 9, 2009, February 15, 2009, February 16, 2009, February 21, 2009, February 23, 2009, February 23, 2009, February 24, 2009 and June 29, 2009; m. According to PPG'sFebruary 27, 2010 Semi-Annual Compliance Report, PPG did not operate thermal oxidizerunit onthe following dates: July 1, 2009, July 2, 2009, July 3, 2009, July4, 2009, July 5, 2009, July 18, 2009, July 31,2009, September 7, 2009. b. PPG failed to comply with the HAP emission limits applicable to PPG's Group 1 storage tanks in violation of 40 C.F.R. §§ 63.2470(a) and Table 4 ofSubpart FFFF on the dates that PPG failed to operate the thermal oxidizer. 48. During the 2009 inspection, EPA found reliefmanways (i.e. PPG'sreferenced, "emergencyreliefmanways") on Group 1storage tanks (e.g. AST 151, AST 136, and AST 137) located in the Resin plant bulk storage tank farms to have HAP emissions that 

### 9were released to the atmosphere during normal operations. PPG failed to reduce HAP emissions by

**~** 95 percent by weight for each Group 1storage tank in violation of 40 C.F.R. 

### §§ 63.2470(a) and Table 4 ofSubpart FFFF. 49. Based on informationprovided to EPA during the 2009 inspection, EPA determined that PPG conducted a performance test on the thermal oxidizerunit, which controls HAP emissions regulated under SubpartFFFF, in October2008, without establishing an emissions profile to demonstrate testing underworst-case conditions

..PPG failed to conduct a validperformance test in violation of40 C.F.R. 

### §§ 63.2460(c)(2)(ii) and 63.1257(b)(8). 50. Based on informationprovided to EPA during the 2009 inspection, EPA determined that PPG supplementedthe October2008 performance test with one individual test run conducted in October2003 that demonstrated a removal efficiency of99.1 at an average temperature of 1,342°F. The October2003 testing was conducted without establishing an emissions profile to demonstrate testing underworst-case conditions. PPG failed to conduct a valid performance test in violation of40 C.F.R. 

### §§ 63.2460(c)(2)(ii) and 63.1257(b)(8). 51. a PPG uses a thermal oxidizerunit to control emissions from its batchprocess vents. In its Semi-Annual Compliance Report for 2008 (datedFebruary 27, 2009), PPG reported the following dates where the thermal oxidizerunit combustiontemperature was < 1,400°F: 1. May 10-13, 18-23, 26-29; 

### u. June 3-4, 8, 11-12, 16, 17, 19-24, 28-30; 

### m. July 3, 9-11, 15,23-24, 27-29; tv. August 1-4,6-7, 10-16, 18-19,22, 26-31; v. September 1-22, 25-30; and v1. October 1. b. In its Semi-Annual Report for 2010 (dated August 13, 2010), PPG reported that the thermal oxidizerunit combustion temperature was< 1,400°F on June 21, 2010; c. PPG failed to achieve the combustiontemperature in the thermal oxidizerunit necessary for the batch process vents to meet emission limits (reduce HAP emissions

**by~** 98 by weight) for the periods noted in this paragraph in violation of40 C.F.R. §63.2460(a) and Table 2 ofSubpart FFFF. 52. Based on informationprovided to EPA during the 2009 inspection, EPA determined that PPG has improperly calculated the rack weighted average partial pressure by using mole fractions based on the total organic liquids (HAP and non HAP) present in a stream. The maximum true vaporpressure is.the equilibrium partial pressure exerted by the total 1053. organic HAP's inthe stored ortransferred liquid. PPG's impropercalculations led to an incorrect Group 2 status determination for the transferracks. EPA determined the rack weighted average partial pressure to be greaterthan 1.5 pounds per square inch absolute. PPG failed to complywiththe Group 1transferrack requirements inviolation of 40 C.F.R. 

### §63.2475(a) and Table 5 ofSubpart FFFF. Environmental Impact ofViolations These violations have caused orcan cause excess emissions ofHAPs. Violation ofthe NESHAP standards canresult inexcess HAP emissions thatmaycause serious health effects, such as birth defects and cancer, andharmful environmental and ecological effects.

re Ir and RadiationDivision

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