MULTI-YEAR NOTICE OF VIOLATION ISSUED BY THE SCAQMD -- RESOLVED!

The Curtiss-Wright Corporation was issued a notice of violation for failing to meet volatile organic carbon (VOC) destruction efficiency required by the facility’s permit to operate. The facility, located in the Los Angeles Basin, provides metal finishing and improvement services to major aerospace assembly lines. It is considered a major source and is subject to Title V requirements under the EPA Clean Air Act.

Curtiss-Wright contracted Alta to provide recommendations to improve the VOC destruction efficiency of the existing VOC destruction unit. A VOC destruction expert was brought to the team to analyze the system. The system consisted of an adsorption/desorption concentrator with an afterburner. Several measures were recommended and followed by the client. However, after two rounds of repairs and source tests, the system was still not meeting the permit requirements.

Once it became evident that the existing unit was not going the meet the permit requirement, Alta reached out to South Coast Air Quality Management District’s (SCAQMD) Counsel to start the Order of Abatement process. Under a Stipulated Order of Abatement, Alta requested legal coverage for the facility to operate while installing a new VOC control system. As the case was being studied by SCAQMD, Alta helped the client to select a proper VOC destruction system and prepared the Permit to Operate application. The permit was issued in record time for a Title V facility.

Subsequently, Alta represented the client before the Hearing Board. By the time the case was presented to the Hearing Board, the client was a few weeks away from installing the new system and achieving compliance. The Hearing Board ruled to allow the plant to operate for the duration of the VOC destruction system upgrade. In addition to representing the client before the Hearing Board, Alta negotiated a Settlement Agreement with SCAQMD’s Counsel. The facility was able to reach compliance before the Order of Abatement deadline. The case was recently closed by SCAQMD.