Field Office Compliance - Assistance

Assistance ID - 105358
Bayer Cropscience Lp - 6909 - 310203151
2500 Wiggens Rd Muscatine, IA 52761
Muscatine County

FO 6

Report
File Name File Type File Date Note
Comments
2/18/2019 Mark Mathias and Mae Thomas called for two reasons: 1. explain a situation regarding MACT standards that they just realized and 2. ask my recommendation on how to deal with the situation. An emission unit they have is subject to the MON MACT and they just realized it's also subject to the Pesticide MACT....they didn't realize it until just before they called. They think they're barely out of compliance with the emission limit, but they've already got a plan of how to get into compliance with it next time they run a batch. Their question was, can they run for the next two days without shutting down. They said they've been running it this way for years. I explained that while I don't have the authority to tell them to keep running, in violation of federal rule, without knowing for sure that they're in violation, i don't really feel comfortable with being the one to tell them they have to shut down (since often times shutting down a major process involves many steps that takes time) and ultimately, i don't want to take on the liability that could result from malfunctions that an unplanned shutdown could cause. I told them they'd want to report it on their TV Compliance Certification report, and they said they would. They also said they'd have to report it on their MACT reports. KURT LEVETZOW
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