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The Arkansas Department of Environmental Quality (“ADEQ”) and Malvern Wood Products, Inc. (“MWPI”) entered into an October 4th Consent Administrative Order (“CAO”) to address alleged violations of an air permit. See LIS No. 17-079.

The CAO provides that MWPI owns and operates a pallet and sticker manufacturing facility (“Facility”) in Malvern, Arkansas.

The MWPI Facility holds an Air Permit issued by ADEQ. Air Permit 2104-A (“Permit”).

ADEQ personnel are stated to have performed a compliance inspection of the Facility on May 2, 2017. The inspection allegedly indicated that the Facility exceeded the sticker production limit for the time period of April 2016 through March 2017. The Facility’s Permit restricted sticker production to 1,386,000 within a consecutive 12-month period. MWPI is stated to have produced 2,500,000 stickers, violating Specific Condition 6 of the Permit.

ADEQ is stated to have informed MWPI in a letter dated May 5, 2017, of the alleged violation of Specific Condition 6. MWPI responded to the letter on June 1, 2017. The letter conveyed additional data and MWPI’s desire to meet future compliance concerns.

The company provided a rundown of figures for sticker production into categories. The sticker production categories for the time period of the inspection included:

• Recycled
• Subcontracted
• Manufactured

ADEQ in a June 6th response to MWPI indicated that a permit modification may be necessary to address growth and production operations.

The CAO provides MWPI an Option A or B:

Option A: MWPI shall immediately comply with Specific Condition 6 of the Permit; or

Option B: Within 30 calendar days of the effective date of the CAO MWPI shall submit a permit modification application requesting the increase of sticker production at the Facility per consecutive 12-month period.

MWPI is required to inform ADEQ within 15 days of the effective date of the CAO which option the company chooses.

The CAO provides that MWPI neither admits nor denies the factual and legal allegations contained in the CAO.

The CAO assesses a civil penalty of $1,200 which could have been reduced by 50 percent if the CAO was signed and returned to the agency by October 6th.

A copy of the CAO can be downloaded here.