UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION5 

SEP 3 0 2010 

CERTIFIED MAIL 

77 WEST JACKSON BOULEVARD 

CHICAGO, IL 60604-3590 

REPLY TO THE ATTENTION OF: 

AE-17J 

RETURN RECEIPT REQUESTED 

Tom Tersine, Manager, EHS 

PPG Industries, Inc. 

1 0800 South 13th Street 

Oak Creek, Wisconsin 53154 

Dear Mr. Tersine: 

Re: Finding ofViolation 

PPG Industries, Inc. 

Oak Creek, Wisconsin 

This is to advise you that the U.S. Environmental Protection Agency finds that PPG 

Industries, Inc.'s (PPG) facility in Oak Creek, Wisconsin is in violation of the Clean Air Act 

(CAA) and associated pollution control requirements. A list of the requirements violated is 

provided below. We are today issuing a Finding of Violation (FOV) to you for these violations. 

The CAA requires EPA to develop National Emission Standards for Hazardous Air 

Pollutants (NESHAP) to protect the public health and welfare. To attain and maintain 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 of the MACT standards that regulate HAP emissions from Miscellaneous Organic 

Chemicals Manufacturing, 40 C.F.R. Part 63, Subpart FFFF (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 of the 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 a judicial 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 on the 

specific findings of violation, 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 management personnel 

to take part in these discussions. You may 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 in this matter is Constantinos Loukeris. You may call him at 

(312) 353-6198 to request a conference. You should make the request within 10 calendar days 

following receipt of this letter. We should hold any conference within 30 calendar days 

following receipt of this letter. 

Sincerely, 

trector 

Air and Radiation Division 

Enclosure 

cc: Daniel Schramm, WDNR 

2 
United States Environmental Protection Agency 

Region 5 

In the Matter of: 

PPG Industries, Inc. 

Oak Creek, Wisconsin 

Proceedings Pursuant to 

the Clean Air Act, 

42 U.S.C. §§ 7401 et seq. 

) 

) 

) Finding of Violation 

) 

) EPA-5-10-WI-12 

) 

) 

) 

) 

Finding of Violation 

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 of Hazardous Air Pollutants 

(HAP). 

The U.S. Environmental Protection Agency is issuing this Finding of Violation (FOV) to 

you to address the alleged violations identified below. The underlying statutory and regulatory 

requirements include provisions of the Clean Air Act (CAA) and its implementing regulations. 

Explanation of Violations 

NESHAP for Miscellaneous Organic Chemicals Manufacturing (Subpart FFFF) 

1. On November 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) of this section. 

3. Table 4 of Subpart FFFF requires that for each Group 1 storage tank you must reduce 

total HAP emissions by 2:95 percent by weight or to S20 ppmv of TOC or organic HAP 

and S20 ppmv of hydrogen halide and halogen HAP by venting emissions through a 

closed vent system to any combination of control devices (excluding a flare). 
4. Subpart FFFF, at 40 C.F.R. § 63.2485(a), states that "you must meet each requirement in 

table 7 to this subpart that applies to your wastewater streams and liquid streams in open 

systems within a miscellaneous organic chemical manufacturing process unit (MCPU), 

except I 

as specified in paragraphs (b) through ( o) of this section." 

5. Subpart FFFF, at 40 C.F.R. § 63.2485(b), states that "[w]here § 63.105 and§§ 63.132 

through 63.148 refer to compounds in table 9 of subpart G of this part 63, the compounds 

in tables 8 and 9 to this subpart apply for the purposes of this subpart." 

6. Table 7 of Subpart FFFF requires each process wastewater stream to 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 or design evaluation for a non-flare control device used to control 

emissions from batch process vents, you must establish emission profiles and conduct the 

test under worst-case conditions according to§ 63.1257(b)(8) instead of under 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) of this section. 

9. Table 6 of Subpart FFFF requires that all equipment in organic HAP service must comply 

with the requirements of either 40 C.F.R. part 63, subpart UU or subpart H, and the 

requirements referenced therein, except as specified in§ 63.2480(b) and (d), or 40 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 subpart that applies to your batch process vents, and you must meet 

each applicable requirement specified in paragraphs (b) and (c) of this section. 

11. Table 2 of Subpart FFFF requires for each process with a Group 1 process vent that you 

must reduce collective uncontrolled organic HAP emissions from the sum of all batch 

process vents within the process by 2:98 percent by weight by venting emissions from a 

sufficient number of the vents through one or more closed-vent systems to any 

combination of control 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 subpart that applies to your 

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transfer racks, and you must meet each applicable requirement in paragraphs (b) and (c) 

of this section. 

13. Table 5 of Subpart FFFF requires for each Group 1 transfer rack that you must reduce 

emissions of total organic HAP by ~98 percent by weight or to an outlet concentration 

:S20 ppmv as organic HAP or TOC by venting emissions through a closed-vent system to 

any combination of control devices (except a flare). 

14. Subpart FFFF, at 40 C.F.R. § 63.2550(i), defmes "Group 1 transfer rack" as a transfer 

rack that loads more than 0.65 million liters/year ofliquids that contain organic HAP 

with a rack-weighted average partial pressure, as defined in § 63.111, greater than 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. On April 22, 1994, EPA promulgated the NESHAP for the Synthetic Grganic Chemical 

Manufacturing Industry for Process Vents, Storage Vessels, Transfer Operations, and 

Wastewater at 40 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 operator to determine 

whether each wastewater stream requires control for Table 9 compounds by complying 

with the requirements in either paragraph (a)(1)(i) or (a)(1)(ii) of this section, and comply 

with the requirements in paragraph (a)(l)(iii) of this section. 

17. Subpart G, at 40 C.F.R. § 63.132(c), provides instructions for determining whether a 

wastewater stream is Group 1 or 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) of this 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 or operator that elects to comply 

with paragraph (a)(1) of this section by measuring the concentration for the relevant 

Table 9 compounds, to determine the annual average concentration for each wastewater 

stream, either at the point of determination, or downstream of the point of determination 

with adjustment for concentration changes made according to paragraph (b)(6) of this 

section. 40 C.F.R. § 63.144(b)(5) requires a minimum of three samples from each 

wastewater stream, which may be grab samples or composite samples. 

19. Subpart G, at 40 C.F.R. § 63.111 defines "Rack-weighted average partial pressure" as the 

throughput weighted average of the average maximum true vapor pressure of liquids 

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containing organic HAP transferred at a transfer rack. The rack-weighted average partial 

pressure shall be calculated using the equation below: 

Where: 

P = Rack-weighted average partial pressure, kilopascals. 

P;= Individual HAP maximum true vapor pressure, kilopascals, = X;*P, where X; is the mole fraction of 

compound i in the liquid. 

G;= Yearly volume of each 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 vapor pressure" as "the 

equilibrium partial pressure exerted by the total organic HAP's in the stored or transferred 

liquid at the temperature equal to the highest calendar-month average of the liquid 

storage or transfer temperature for liquids stored or transferred above or below the 

ambient temperature or at the local maximum monthly average temperature as reported 

by the National Weather Service for liquids stored or transferred at the 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 of subpart A of this part); or 

(2) As obtained from standard reference texts; or 

(3) As determined by the American Society for Testing and Materials Method 02879-83 

or 96 (incorporated by reference as specified in§ 63.14 of subpart A of this part); or 

( 4) Any other method approved by the Administrator." 

NESHAP for Equipment Leaks (Subpart UU) 

21. On June 29, 1999, EPA promulgated the NESHAP for Equipment Leaks- Control Level 

2 Standards at 40 C.F.R. Part 63, Subpart UU (64 Fed. Reg. 34899). 

22. As stated in paragraph 9, among the requirements of 40 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 of 40 C.F.R. 

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Part 63 or 40 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 of the equipment does not require physical tagging of 

the equipment. For example, the equipment may be identified on a plant site plan, in log 

entries, by designation of process unit or affected facility boundaries by some form of 

weatherproof identification." 

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, or a 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 open end at all times except during 

operations requiring process fluid flow through the open-ended valve or line, or during 

maintenance. The operational provisions of paragraphs (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 or line may remain open during operations that 

require venting the line between the block valves but shall comply with paragraph (b)(1) 

of this section at all other times. 

26. Subpart UU, at 40 C.P.R.§ 63.1025(b)(l), requires that valves shall be monitored to 

detect leaks by the 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 of 40 C.P.R. Part 60, Appendix A. 

28. Section 8.3.1 of Method 21 of 40 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 interface periphery while observing the instrument 

readout. If an increased meter reading is observed, slowly sample the interface where 

leakage is indicated until the maximum meter reading is optained. Leave the probe inlet 

at this maximum reading 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) of this section shall meet the applicable 

requirements specified in paragraphs (c)(l) through (c)(5) of this section. 

30. Subpart UU, at 40 C.P.R. § 63.1032(c)(5), requires containers that are part of a closed 

purge system must be covered or closed when not being filled or emptied. 

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NESHAP (Subpart GGG) 

31. As stated in paragraph 7, Subpart FFFF at 40 C.F.R. § 63.2460(c)(2)(ii) requires that 

when you conduct a performance test or design evaluation for a non-flare control device 

used to control emissions from batch process vents, you must establish emission profiles 

and conduct the test under worst-case conditions according to 40 C.F.R. § 63.1257(b)(8) 

instead of under normal operation conditions as specified in§ 63.7(e)(1). Subpart GGG 

at 40 C.F.R. § 63.1257(b)(8), requires testing of emissions on equipment where the flow 

of gaseous emissions is intermittent (batch operations) shall be conducted as specified in 

paragraphs (b)(8)(i) through (iii) of this section, which requires testing at "absolute 

worst-case conditions or hypothetical worst-case conditions." 

General Allegations 

32. PPG owns and operates a resin manufacturing plant at 10800 South 13th Street, Oak 

Creek, Wisconsin (Plant), which is a major source of HAP, as defined in 40 C.F.R. § 63.2 

of Subpart A. 

33. PPG owns or operates miscellaneous organic chemical manufacturing units (MCPU) as 

defined at 40 C.F.R. § 63.2435(b), in the resin manufacturing process at the Plant, which 

are subject to the requirements of 40 C.F.R. Part 63, Subpart FFFF and by reference 

Subpart UU and Subpart GGG. The process 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. From June 1, 2009 through June 5, 2009, EPA conducted a Clean Air Act investigation of 

PPG hereafter referred to as "2009 inspection." 

35. In response to questions raised by EPA during the investigation the week of June 1, 2009 

through June 5, 2009, PPG submitted a written response dated June 25, 2009. 

Alleged Violations 

36. Based on information provided to EPA during the 2009 inspection, EPA found that the 

WTC 1903 wastewater streams receives wastewater from all ofthe reactor systems and 

has several points of determination. PPG elected to determine whether the WTC 1903 

wastewater stream was Group 1 or Group 2 for Table 9 compounds by measuring 

downstream of several points of determination; however PPG failed to adjust for 

concentration changes as required by 40 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). 

3 7. Based on information provided to EPA during the 2009 inspection, EPA determined that 

PPG did not evaluate WTC 1901 and WTC 1902 as wastewater streams. PPG failed to 

6 
determine whether the wastewater streams at WTC I90 I and WTC I902 are Group I or 

Group 2 for Table 9 compounds in violation of 40 C.P.R. §§ 63.2485(a) and 63. 132(a). 

38. During the 2009 inspection, EPA discovered a container that is used by PPG to collect 

residual liquids drained from block and bleed systems at the South Meter Station. PPG 

failed to identify the container as a point of determination and to determine whether the 

wastewater therein is Group 1 or Group 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. During the 2009 inspection, EPA performed monitoring for HAP leaks using Method 2I 

of 40 C.P.R. Part 60, Appendix A and found a significantly higher leak rate on valves 

located in the Resin plant than that reported by PPG on previous and current monitoring 

equipment subject to the MON. EPA found a leak rate 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 of May 2008 through June 20IO. PPG has conducted 

deficient Method 21 leak monitoring of valves subject to Subpart UU at the facility in 

violation of 40 C.P.R.§ 63.1025(b)(I) and Method 21 of 40 C.P.R. Part 60, Appendix A. 

40. Based on the information provided to EPA during the 2009 inspection, EPA found that 

PPG does not monitor for HAP leaks at the component interface where leakage may 

occur for insulated valves located in the Resin plant. PPG failed to perform Method 21 

of 40 C.P.R. Part 60, Appendix A on all valves that are insulated in violation of 40 C.P.R. 

§§ 63.2480(a), 63.1025(b)(l), and Section 8.3.1 of Method 21 of 40 C.P.R. Part 60, 

Appendix A. 

4I. Based on the information provided to EPA during the 2009 inspection, EPA found that 

PPG did not venfy that equipment was in organic HAP service prior to monitoring for 

leaks. PPG failed to determine HAP leaks in conformance with Method 21 of 40 C.P.R. 

Part 60, Appendix A during periods when equipment was in organic HAP service in 

violation of 40 C.P.R. § 63.2480(a) and Table 6 of Subpart PPPP. 

42. During the 2009 inspection, EPA found that a significant number of equipment tags were 

missing on process 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. 

§ 63.1 022( 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 of 40 C.P.R. Part 60, Appendix A on 

such equipment in violation of C.P.R.§§ 63.2480(a), 63.1022(a), and Method 21 of 40 

C.P.R. Part 60, Appendix A. 

43. During the 2009 inspection, EPA found an uncovered container that is part of a closed 

purge system to a sampling connection to Reactor 7. Under 40 C.P.R.§ 63.1032(c)(5), 

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containers that are part of a closed purge system are required to be covered or closed 

when not being filled or emptied. PPG failed to cover a container used in a closed purge 

system during periods when not being filled or emptied in violation of 40 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, or a second valve. At the time of the inspection, 

operations did not require process fluid flow through these open-ended lines, and PPG 

was not conducting maintenance on the lines. PPG failed to properly equip the openended lines listed below in violation of 40 C.F.R. §§ 63.2480(a) and 63.1033(b)(1): 

a. 15418 Valve 

b. 1823 (R4 Reactor Condenser/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 of a visual dripping) 

1. R6 Thin Tank Filter Line Connect to Nitrogen 

J. Two (2) open-ends near tag# 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 off the filling area 

u. R3 Poly Tank near tag# 3392 (evidence of a visual dripping) 

Note: The identification of each 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 of 40 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, or second valves) of 6 open-ended lines (listed below) using Method 21 as 

8 
specified 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 of 40 C.F.R. §§ 63.2480(a) and 63.1033(b)(l). 

47. a. PPG uses a thermal oxidizer unit to reduce HAPs emissions from its storage tanks; 

however PPG did not operate the thermal oxidizer on the following dates: 

1. According to PPG's February 27, 2009 Semi-Annual Compliance Report, 

PPG did not operate the thermal oxidizer unit on the following dates: July 4, 

2008, July 6, 2008, July 7, 2008, July 8, 2008, November 23, 2008, 

November 24,2008, November 25,2008, November 26,2008, November 27, 

2008, November 28, 2008, November 29, 2008, November 30, 2008, 

December 21, 2008, December 22, 2008, December 23,2008, December 24, 

2008, December 25, 2008, December 26, 2008, December 27, 2008, 

December 28, 2008 and December 31, 2008; 

u. According to PPG's August 28, 2009 Semi-Annual Compliance Report, PPG 

did not operate thermal oxidizer on the 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's February 27, 2010 Semi-Annual Compliance Report, 

PPG did not operate thermal oxidizer unit on the following dates: July 1, 

2009, July 2, 2009, July 3, 2009, July 4, 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 of Subpart FFFF 

on the dates that PPG failed to operate the thermal oxidizer. 

48. During the 2009 inspection, EPA found reliefmanways (i.e. PPG's referenced, 

"emergency reliefmanways") on Group 1 storage tanks (e.g. AST 151, AST 136, and 

AST 137) located in the Resin plant bulk storage tank farms to have HAP emissions that 

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

emissions by ~ 95 percent by weight for each Group 1 storage tank in violation of 

40 C.F.R. §§ 63.2470(a) and Table 4 of Subpart FFFF. 

49. Based on information provided to EPA during the 2009 inspection, EPA determined that 

PPG conducted a performance test on the thermal oxidizer unit, which controls HAP 

emissions regulated under Subpart FFFF, in October 2008, without establishing an 

emissions profile to demonstrate testing under worst-case conditions .. PPG failed to 

conduct a valid performance test in violation of 40 C.F.R. §§ 63.2460(c)(2)(ii) and 

63.1257(b)(8). 

50. Based on information provided to EPA during the 2009 inspection, EPA determined that 

PPG supplemented the October 2008 performance test with one individual test run 

conducted in October 2003 that demonstrated a removal efficiency of99.1 at an average 

temperature of 1,342°F. The October 2003 testing was conducted without establishing an 

emissions profile to demonstrate testing under worst-case conditions. PPG failed to 

conduct a valid performance test in violation of 40 C.F.R. §§ 63.2460(c)(2)(ii) and 

63.1257(b )(8). 

51. a PPG uses a thermal oxidizer unit to control emissions from its batch process vents. In 

its Semi-Annual Compliance Report for 2008 (dated February 27, 2009), PPG reported 

the following dates where the thermal oxidizer unit combustion temperature 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 oxidizer unit combustion temperature was< 1,400°F on June 21, 2010; 

c. PPG failed to achieve the combustion temperature in the thermal oxidizer unit 

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 of 40 C.F.R. 

§ 63.2460(a) and Table 2 of Subpart FFFF. 

52. Based on information provided 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 vapor pressure is.the equilibrium partial pressure exerted by the total 

10 
53. 

organic HAP's in the stored or transferred liquid. PPG's improper calculations led to an 

incorrect Group 2 status determination for the transfer racks. EPA determined the rack 

weighted average partial pressure to be greater than 1.5 pounds per square inch absolute. 

PPG failed to comply with the Group 1 transfer rack requirements in violation of 

40 C.F.R. § 63.2475(a) and Table 5 of Subpart FFFF. 

Environmental Impact of Violations 

These violations have caused or can cause excess emissions of HAPs. Violation of the 

NESHAP standards can result in excess HAP emissions that may cause serious health 

effects, such as birth defects and cancer, and harmful environmental and ecological 

effects. 

re 

Ir and Radiation Division 

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