The Arkansas Department of Energy & Environment – Division of Environmental Quality (“DEQ”) and Alliance Rubber Company (“Alliance”) entered into a March 17th Consent Administrative Order (“CAO”) addressing alleged violations of an air permit. See LIS No. 22-029.
The CAO provides that Alliance owns and operates a mechanical rubber product manufacturing facility (“Facility”) located in Garland County, Arkansas.
The Facility is said to have an air permit.
DEQ personnel are stated to have inspected the Facility on April 6, 2017, and identified the use of the component Colorbond UV RubberBond-Pretreatment Version 2 that contained the Hazardous Air Pollutant (“HAP”) Acetonitrile. Further, CAO (LIS 17-071) is stated to have been executed in 2017 in which Alliance agreed to either immediately cease use of Colorbond UV RubberBond-Pretreatment Version 2 or submit a permit modification application allowing the use of this HAP at the Silk Screening Area.
Alliance is reported to have requested in 2017 an Administrative Amendment to Permit R3 to include this HAP usage at SN-14 insignificant activity. According to DEQ, Alliance was informed by DEQ that an administrative amendment to Permit R3 couldn’t be completed to allow for this HAP to be used at SN-14 as an unimportant activity and that a permit application would be needed.
Alliance has not submitted a permit request to include the use this HAP at SN-14. This is alleged not to be in compliance with Specific Condition 7 of certain air permit.
According to the DEQ, personnel from the Facility were responsible for conducting a compliance inspection on June 9, 2020. According to reports, the inspection covered the reporting period between May 2017 and April 2021.
The inspection is stated to have determined that Alliance failed to provide records of total VOC emissions for the use of 24349 Rubber Adhesion Promoter and Colorbond UV RubberBond-Pretreatment Version 2 at SN-14 for the period of May 2017 through April 2021 violating Special Condition 6 of Permit 3 and Permit 4.
The inspection also found that Alliance used HAP components 24349 Rubber Adhesion Promoter and Colorbond UV rubber Bond-Pretreatment version 2 before obtaining a permit amendment violating Specific Condition 7 and Permit R4. Additionally, the inspection found that Alliance operated three natural gas generators and an emergency diesel firepump without a permit.
Alliance replied to a DEQ question by stating that a permit amendment would be submitted to address Acetonitrile containing parts and the addition of three emergency generators and the emergency fire pumps. Alliance stated that VOC calculations will be updated. In January 20th correspondence Alliance stated that the Facility would be making the necessary permitting modifications to include the unpermitted sources and would be updating recordkeeping methodology to restore the Facility’s compliance status.
Alliance denies or admits to the CAO’s legal and factual allegations.
Within 30 calendar days after the effective date of CAO Alliance, you must:
- Submit a permit modification request to address the alleged violations of paragraphs 16 and 14 of the Findings of Fact
- For six months, submit records that show compliance with Specific Condition 6.
A civil penalty of $22,000 will be assessed.
You can download a copy of the CAO here.