Document YDXY57BDQVG4d7MwkeObJpqKy

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 6 1201 Elm Street, Suite 500 Dallas, Texas 75270 February 23, 2022 VIA EMAIL: Shawn.Ward@cornerstonchemco.com Shawn Ward Director, Corporate HSSE and Sustainability Cornerstone Chemical Co. - Energy Park 10800 River Road Waggaman, LA 70094 Re: Clean Air Act Notice of Violation Dear Mr. Ward: The United States Environmental Protection Agency ("EPA") has identified Cornerstone Chemical Company ("Cornerstone") as having violated the Clean Air Act ("CAA"), 42 U.S.C. 7401 et seq., and the regulations promulgated thereunder. This Notice of Violation ("Notice") is issued to Cornerstone for violations of the CAA at its Energy Park facility located at 10800 River Road, Waggaman, Louisiana ("the Facility"). Specifically, EPA believes that Cornerstone1 has violated the Louisiana State Implementation Plan ("SIP"). The Notice is issued pursuant to Section 113(a)(1) of the CAA, 42 U.S.C. 7413(a)(1), which requires the Administrator of EPA to notify any person in violation of a SIP or permit of the violation(s). The authority to issue this Notice has been delegated to the Director of the Enforcement and Compliance Assurance Division, EPA Region 6. On October 22, 2021 we sent Cornerstone a letter regarding our Emission Inventory Permit Consistency Review, in which we reviewed the Facility's emission inventory for criteria pollutant and hazardous air pollutant (HAP) emission totals for calendar year 2019, as reported to the Louisiana Department of Environmental Quality ("LDEQ"). As noted in our letter, the Facility's reported annual emission totals exceeded its permit authorization limits. Cornerstone responded via email dated November 8, 2021 and provided information regarding the annual emission totals. 1 Please be advised that some companies may qualify as a "small business" under the Small Business Regulatory Enforcement and Fairness Act (SBREFA). The U.S. Small Business Administration has established a Table of Small Business Size Standards, which can be found at: https://www.sba.gov/sites/default/files/Size_Standards_Table.pdf. The SBREFA Information Sheet provides information on compliance assistance to entities that may qualify as small businesses as well as to inform them of their right to comment to the SBREFA Ombudsman concerning EPA enforcement activities. The SBREFA Information Sheet can be found at: http://nepis.epa.gov/Exe/ZyPDF.cgi/P100BYAV.PDF?Dockey=P100BYAV.PDF. CAA Violation Cornerstone Chemical Company Notice of Violation We are sending this letter to inform Cornerstone of violations of Louisiana's federally approved SIP at the Facility. LAC 33:III.919.B.1 of the Louisiana SIP, approved at 76 Fed. Reg. 38,977 (July 5, 2011), requires that Cornerstone submit an Annual Emissions Statement to LDEQ consisting of an inventory of the Facility's actual emissions and the permitted emissions limits of volatile organic compounds (VOCs), nitrous oxides (NOX), carbon monoxide (CO), sulfur dioxide (SO2), lead (Pb), particulate matter of 10 microns or less (PM10) and 2.5 microns or less (PM2.5), and ammonia. Actual emissions must be reported for all sources of emissions at the Facility, including fugitive emissions, flash gas emissions, insignificant sources, and excess emissions occurring during maintenance, start-ups, shutdowns, upsets, and downtime. Based on its review, EPA finds that Cornerstone violated LAC 33:III.919.B.1 of the Louisiana SIP by failing to report the Facility's actual emissions in the annual emissions inventory for ammonia for reporting year 2019. Permit 1981-V6 1981-V6 Subject Item Parameter Type Melamine Flare (FS-1) Melamine Central Flare (VH-3) Ammonia Ammonia Permitted Limit (tpy) 4.94 22.65 ERIC Reported Emissions (tpy) 9.56 42.39 Reported Emissions Over Permitted Limit (tpy) 4.62 19.74 Opportunity to Confer We appreciate Cornerstone working with us regarding this matter. Please contact Carlos Zequeira, Assistant Regional Counsel, at Zequeira.C@epa.gov or (214) 665-8053, within ten (10) business days of receipt of this Notice to discuss an administrative path for quick resolution. Sincerely, Digitally signed by Seager, Cheryl DN: cn=Seager, Cheryl, email=Seager.Cheryl@epa.gov Date: 2022.02.23 14:55:30 -06'00' Cheryl T. Seager Director, Enforcement and Compliance Assurance Division ec: Celena Cage, LDEQ (Celena.Cage@la.gov) Jamie Williams, Cornerstone Chemical Co. (Jamie.Williams@cornerstonechemco.com) Page 2 of 2