Kate Brown, Governor

April 29, 2019

CERTIFIED MAIL No. 7016 0750 0000 3470 3777

Carestream Health, Inc. c/o Registered Agent Solutions, Inc., Registered Agent 8130 SW Beaverton-Hillsdale Hwy. Portland, OR 97225

Re: Notice of Civil Penalty Assessment and Order Case No. AQN-WR-2018-129

Department of Environmental Quality Office of Compliance and Enforcement

700 NE Mulh1omah Street, Suite 600

Portland, OR 97232

(503) 229-5382

FAX (503) 229-5100

TTY 711

This letter is to inform you that DEQ has issued you a $19,512 civil penalty for operating degreasers at your facility when a thermal oxidizer was not operating to control emissions, in violation of your Oregon Title V Operating Permit. The violation occurred at your coated paper and film production facility at 8124 Pacific Avenue, White City, Oregon.

DEQ issued this penalty because failure to control emissions from the degreasers is a serious violation. Your facility uses Methyl Ethyl Ketone (MEK) as cleaning solvent in the degreasers which is a volatile organic compound (VOC). VOCs irritate human eyes, nose and throat, cause difficulty breathing, nausea, and can damage the central nervous system as well as other organs. VOCs also contribute to the formation of smog and degradation of the airshed.

DEQ cited, but did not assess penalties for, additional violations in the enclosed Notice. Those violations include: failing to keep complete records, failing to include emissions from the degreasers in monthly VOC calculations, failing to properly calculate solvent capture and control efficiency of the thermal oxidizers, and failing to verify that degreaser covers were in place and functional and that solvent was being correctly drained from the parts.

Included in Section IV of the enclosed Notice is an order requiring you to submit a protocol to DEQ within 30 days of final order, describing the procedure you will use to determine solvent usage in the degreasers to allow you to properly calculate and include emissions from the degreasers in your monthly total VOC emission calculations.

DEQ appreciates your efforts to correct the violation by ducting the degreasers to a second thermal oxidizer and installing an alarm system and interlock devices on the degreaser covers to prevent operation of a degreaser when a thermal oxidizer is not operating. DEQ considered these efforts when determining the amount of civil penalty.