The Alabama Department of Environmental Management (“ADEM”) and Scotch and Gulf Lumber, LLC (“Scotch”) entered into a December 11th Consent Order (“CO”) addressing an alleged violation of a Clean Air Act Title V Major Source Operating Permit.
Scotch is described as operating a sawmill facility in Mobile, Alabama.
The facility is stated to be operating pursuant to a Major Source Operating Permit (“Permit”). The Permit provisions include authorization of the operation of a 68 MMBTU/hr wood-fired boiler (Unit 001) that is equipped with a wet scrubber to control particulate emissions.
Scotch submitted an email to ADEM in 2021 stating that the oxygen monitor on Unit 001 was out of control from April 5, 2021, to April 7, 2021, due to a calibration failure. A subsequent email submitted to ADEM is stated to have indicated that the cause of the monitor calibration failure was having residue buildup over time in the probe that caused an increase in resistance.
A new probe was stated to have been installed on April 23, 2021, and the oxygen monitor brought back online on April 24, 2021.
On August 2, 2021, A Semiannual Compliance Report as required by 40 CFR Part 63, Subpart DDDDD was submitted. It indicated a deviation from monitoring requirements for the oxygen monitor on Unit 001 from April 5, 2021, to April 24, 2021, due to a dying O2 analyzer probe. The report also indicated that Scotch would maintain a refurbished probe on site as an immediate replacement in case of another failure.
On May 19, 2024, Scotch submitted an email to ADEM stating that the oxygen monitoring Unit 001 had failed its daily calibration on May 16th. Such failure was subsequently determined to be the result of a broken probe. On June 19th, Scotch informed ADEM of the date and time that the connection was restored and that data was again being recorded.
ADEM sent a letter of inquiry on June 20, 2024, to Scotch requesting:
- The cause of the monitor failure.
- Why a backup probe was not maintained on site.
- How the facility was demonstrating compliance with the boiler MACT while the oxygen monitor was offline.
Scotch is stated to have responded that:
- The old probe was returned to the facility in a refurbished state.
- SGLC cannot demonstrate compliance with boiler MACT carbon monoxide standard while the oxygen monitor was offline.
On August 27, 2024, Scotch’s Semiannual Compliance Report indicated a deviation from monitoring requirements for the oxygen monitor on Unit 001 from May 15 to June 19 due to an internal failure caused by the presence of water and oil om the air system.
Scotch neither admits nor denies ADEM’s contentions.
A civil penalty of $30,000.00 is assessed.
A copy of the CO can be downloaded here.
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