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 Mulomah Street, Suite 600 Portland, OR 97232 (503) 229-5382 FAX (503) 229-5100 TTY 711 This letter is to inrm you that DEQ has issued you a $19,512 civil penalty r operating degreasers at your cility 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 cility at 8124 Pacific Avenue, White City, Oregon. DEQ issued this penalty because ilure to control emissions om the degreasers is a serious violation. Your cility uses Methyl Ethyl Ketone (MEK) as cleaning solvent in the degreasers which is a volatile organic compound (VOC). VOCs irritate human eyes, nose and toat, cause difficulty breathing, nausea, and can damage the central nervous system as well as other organs. VOCs also contribute to the rmation of smog and degradation of the airshed. DEQ cited, but did not assess penalties r, additional violations in the enclosed Notice. Those violations include: iling to keep complete records, iling to include emissions om the degreasers in monthly VOC calculations, iling to properly calculate solvent capture and control efficiency of the thermal oxidizers, and iling to verify that degreaser covers were in place and nctional and that solvent was being correctly drained om 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 om the degreasers in your monthly total VOC emission calculations. DEQ appreciates your efforts to correct the violation by ducting the degreasers to a second theal oxidizer and installing an alm system and interlock devices on the degreaser covers to prevent operation of a degreaser when a thermal oxidizer is not operating. DEQ considered these efrts when determining the amount of civil penalty.