United States v. ALTIVIA Petrochemicals, LLC

CourtDistrict Court, S.D. Ohio
DecidedFebruary 15, 2022
Docket1:21-cv-00640
StatusUnknown

This text of United States v. ALTIVIA Petrochemicals, LLC (United States v. ALTIVIA Petrochemicals, LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. ALTIVIA Petrochemicals, LLC, (S.D. Ohio 2022).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

UNITED STATES OF AMERICA, : Case No. 1:21-cv-640 Plaintiff, : : Judge Timothy S. Black vs. : : ALTIVIA PETROCHEMICALS, LLC, : Defendant. : :

ORDER DENYING DEFENDANT’S PARTIAL MOTION TO DISMISS (Doc. 7) This civil action is before the Court upon Defendant’s partial motion to dismiss (Doc. 7), an exhibit in support of the motion. (Docs. 6, 6-1), and the parties’ responsive memoranda. (Docs. 8 and 10) I. FACTS AS ALLEGED BY THE PLAINTIFF For purposes of this motion to dismiss, the Court must: (1) view the complaint in the light most favorable to the Plaintiff; and (2) take all well-pleaded factual allegations as true. Tackett v. M&G Polymers, 561 F.3d 478, 488 (6th Cir. 2009). A. General Background The Plaintiff here is the United States of America (“the Government” unless another sub-entity is explicitly referenced), which brings a civil action, pursuant to 42 U.S.C. § 7413, to enforce the Clean Air Act (“CAA”) and compliance with an applicable permit. (Doc. 1). Defendant is Altivia Petrochemicals LLC (“Altivia”), a limited liability company that owns and operates a petrochemical manufacturing facility in Haverhill, Ohio (the “Haverhill facility”). (Id. at ¶¶6, 45). In 2015, Altivia acquired the Haverhill facility out of bankruptcy and assumed liabilities under the permits assigned to it through an asset purchase agreement. (Id. at ¶7). Altivia restarted operations at the Haverhill facility in 2015. (Id. at ¶8). At the Haverhill facility, Altivia makes an organic compound called “phenol.” (Id.

at ¶47). The phenol-making process also produces hazardous air pollutants (“HAPs”), including, as is notable here, a by-product HAP called “cumene.” (Id. at ¶49). The cumene emissions subject the Haverhill facility to several regulations promulgated under the CAA. (Id. at ¶¶45, 46). Specifically, the Haverhill facility must comply with the regulations known as the “National Emission Standards for Organic Hazardous Air

Pollutants from the Synthetic Organic Chemical Manufacturing Industry” (customarily reduced to “HON”). (Id. ¶¶19, 47-48).1 Altivia has designated certain Haverhill facility equipment as “chemical manufacturing process units” (CMPU). (Id. at ¶48). These CMPUs must comply with HON. (Id.). HON imposes obligations on Alitiva to, inter alia, monitor and maintain its CMPU. (Id. ¶¶20-32).

Importantly, Altivia operates the Haverhill facility under a Title V permit. (Id. at ¶40). The Environmental Protection Agency (EPA) approves state-level permitting

1 HON is codified at 40 C.F.R. §63, Subparts F, G, H, and I. programs for Title V permits. (Id. at ¶39). Alitiva’s permit was issued by the Ohio permitting program pursuant to Ohio’s State Implementation Plan (“SIP”)—state regulations that guide permitting and generally track the CAA. (Id. at ¶40). Altivia’s permit states “that the permittee is subject to the applicable emission limitation(s) and/or control measures, operational restrictions, monitoring and/or record keeping requirements, reporting requirements, testing requirements, and the general and/or other

requirements specified in 40 C.F.R. Part 63, Subparts F, G, and H, which are incorporated into the Title V permit as if fully written.” (Id. at ¶41). In 2017, the EPA inspected the Haverhill facility. (Id. at ¶50). The EPA found the facility allegedly out-of-compliance with several regulations incorporated into its permit. These compliance issues set the framework for the Government’s complaint. The Court

reviews the factual allegations claim by claim. B. Failure to Control Tank 202-F as a Process Vent (Claim 1) The Government’s first claim centers on the function of a piece of equipment called “tank 202-f.” (Id. at ¶¶51-64). Simplifying things for clarity, the Government alleges the “tank” is properly considered a “vent,” because it emits HAPs directly to the

atmosphere. (Id.). Altivia has failed to regulate the tank as if it were a vent. (Id.). Specifically, Altivia has not reduced the emissions from tank 202-f by 98 percent or reduced the HAP concentration to 20 parts per million. (Id. at ¶53). Tank 202-F, among other seeming functions, “decants” cumene, a HAP, from other chemical compounds. (Id. at ¶41). Tank 202-f then recycles the cumene for further use in the chemical process. (Id.). For this reason, the Government describes tank 202-f as a “recovery device.” (Id. at ¶55; see also 40 C.F.R. §63.107(c)). Because of the observed capacity to vent HAPs directly to the atmosphere after passing through a recovery device, the Government alleges that tank 202-f is a Group 1 process vent, subject to subpart F of the HON (id. at ¶¶59-62), and that Altivia has failed to take steps to control tank 202-f as a process vent.

C. Failure to Perform Proper Method 21 Monitoring at Affected Valves (Claim 2)

This claim centers on allegations regarding the rate at which CMPU valves leak. The regulatory backdrop is relatively straightforward. (Id. at ¶¶65-75). HON establishes the valve leak rate as a determinant of monitoring frequency. (Id. at ¶70). A valve leak rate of 0.5% requires monitoring once a year (or, specifically, once every “four quarters.”). (Id.). A valve leak rate of 2.0% of greater requires monthly monitoring. (Id., see also 40 C.F.R. § 63.168(b)(1)). The Government alleges that Altivia and its predecessor reported a leak rate 0.5% or less from 2013 to 2017. (Doc 1 at ¶68). When the Government inspected in May 2017, it measured a 2.2% leak rate. (Id. at ¶69). The Government states that its “identification of a valve leak rate more than four-times larger than the leak rate reported by ALTIVIA shows that ALTIVIA improperly performed its Method 21 monitoring in

violation of 40 C.F.R. §§ 63.168(b)(1) and 63.180 and failed to identify a significant number of leaks.” (Id. at ¶71). D. Failure to Monitor Each Valve in Gas/Vapor Service or Light Liquid Service Once Per Year (Claim 3)

The Government alleges that Altivia failed to perform yearly monitoring of valves in “gas/vapor service” and “in liquid light service,” as required by HON. (Id. at ¶¶75-85). The Government bases this claim on Altivia’s own reporting in its Leak Detection and Repair Database (“LDAR”). (Id. at ¶80). The LDAR “shows that ALTIVIA missed annual monitoring at affected valves.” (Id. at ¶81). “Specifically, the LDAR Database (through 2016) shows that ALTIVIA missed monitoring at least 1,467 valves in 2015 and 178 valves in 2016.” (Id.). E. Failure to Monitor Each Connector in Gas/Vapor Service or Light Liquid Service Once Per Year (Claim 4)

Replacing “valves” with “connectors,” the gist of the allegations in Claim 4 are the same as those in Claim 3. (Id. at ¶¶86-95). Specifically, Altivia failed to perform annual monitoring of several connectors, as regulated under 40 C.F.R. §63.174. (Id.). As the Government specifically puts it, “the LDAR Database shows that in 2015 ALTIVIA missed monitoring at least 3,442 connectors and it missed monitoring at least 1,932 connectors in 2016.” (Id. at ¶91). F.

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United States v. ALTIVIA Petrochemicals, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-altivia-petrochemicals-llc-ohsd-2022.