Document 44OgEXDEy5rmMXOKV7909J4XN

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 VIA ELECTRONIC MAIL Mr. Craig Gordinier Plant Manager Lhoist North America of Alabama, LLC 7444 AL-25 Calera, Alabama 35040 craig.gordinier@lhoist.com Dear Mr. Gordinier: Re: Lhoist North America of Alabama, LLC - Calera, Alabama Notice of Potential Violation and Opportunity to Confer Dear Mr. Gordinier: Information currently available to the U.S. Environmental Protection Agency suggests that Lhoist North America of Alabama, LLC (LNA) may have committed violations of the Clean Air Act (CAA) and its implementing regulations. By this letter, the EPA is extending to you an opportunity to advise the Agency, in person, via a conference call, or in writing, of any further information the EPA should consider with respect to the potential violations. Specifically, on December 17, 2020, LNA submitted a request for an extension of the January 20, 2021, compliance date for the National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing Plants, 40 C.F.R. Part 63, Subpart AAAAA, for its Montevallo facility located at 7444 AL-25, Calera, Alabama (the facility) to allow it time to install Continuous Opacity Monitoring Systems (COMS) on Kilns 3 and 4. On May 21, 2021, the EPA issued a letter denying that compliance extension request. It is the EPA's understanding that Kilns 3 and 4 at the facility continue to operate without a COMS. The EPA therefore alleges that LNA may be in violation of Section 112 of the CAA, 42 U.S.C. 7412, and the implementing regulations found at 40 C.F.R. 63.7090(e) and Table 2 of Subpart AAAAA, which require all lime kilns to install, maintain, and operate a COMS to meet a 15% opacity standard during periods of startup and shutdown. The EPA has authority under Section 113 of the CAA, 42 U.S.C. 7413, to pursue enforcement actions, including the issuance of compliance orders, the assessment of administrative penalties and/or the initiation of civil or criminal actions. To resolve the potential violations identified above, the EPA requests that a representative of the facility contact Steve Rieck, of my staff at (404) 562-9177, or via email at rieck.stephen@epa.gov, within seven (7) calendar days of receipt of this letter to make arrangements to discuss the potential violations and the EPA's possible enforcement action. Please note that the EPA will have legal representation during these discussions. Please inform Mr. Rieck if you intend to have legal representation present as well. Internet Address (URL) http://www.epa.gov You may voluntarily submit any documentation or information that you would like the EPA to review in advance of any in person meeting or teleconference on the matter as to why you believe the EPA should not take an enforcement action with respect to the above-mentioned potential violations. If you have questions regarding the type of information that should be submitted to the EPA or any other questions regarding this matter, please contact Mr. Rieck at the contact information identified above. Sincerely, JASON DRESSLER Digitally signed by JASON DRESSLER Date: 2021.06.17 11:03:15 -04'00' Jason Dressler Chief North Air Enforcement Section cc: Doug Carr, ADEM