Columbus Steel Castings Company, Inc. (CSC), an Ohio corporation, owns and operates a steel foundry in Columbus, Ohio. At this foundry, CSC manufactures steel castings for various industries, including the railroad industry. As part of these operations airborne pollutants are generated. Some of the individual processes at the foundry that generate air pollution are required to have emission control devices.

On or about December 18, 2002, the Ohio Environmental Protection Agency (Ohio EPA) issued a Title V permit for the CSC facility. The permit, in part, requires the following:

1. report control device malfunctions to Ohio EPA in a monthly report,
2. report control device deviations (i.e. emission limit exceedances) to the Ohio EPA in a monthly report,
3. submit an annual compliance certification to the Ohio EPA which summarizes all malfunctions and deviations experienced during the year at the CSC facility,
4. vent all emissions from the green sand core making and arc air turntable processes into a baghouse,
5. conduct daily visual emission readings at the facility,
6. conduct stack testing within six months of the expiration of any portion of the CSC Title V permit.

Following a review of the records from the facility, as well as interviews of CSC employees, it was determined that there have been numerous violations of the Title V permit at the facility. In particular, between 2004 and 2007, there were numerous control device malfunctions and deviations from a number of different permitted processes at the facility. These malfunctions and deviations were neither reported in the monthly nor annual reports. In addition, emissions were not properly vented into a baghouse from the green sand core making and air turntable processes. Also, daily visual emission checks were not conducted at the facility. Lastly, stack tests were not conducted within six months after the expiration of the permits for air arc turntables and the storage silos processes. CSC employees were aware of these permit requirements and were also aware of the violations.

• Clean Air Act (CAA)