EPA is issuing the APO concurrently with this CAFO. Per this CAFO/APO, TES must pay a penalty of $24,500. Immediately after the period when TES exceeded the petcoke charge rate limit, it trained its operators so as to assure future exceedances would not occur. When the exceedances occurred, the person responsible for ensuring compliance with the petcoke charge rate limit, Scott Wing, was on vacation, and the conveyor belt delivering wood and tire derived fuel (TDF) to the boilers malfunctioned. Even though TES blends its coal with petcoke in such a way that TES can fully load the coal into the boilers each day and not exceed the petcoke charge limit, keeping the petcoke charge rate below the limit also depends on TES burning wood and TDF in the boilers. TES sets its boilers to operate at their maximum heating capacity, regardless of the type of fuel being burned. Since the boilers did not burn wood or TDF during this period, the boilers had to burn a larger quantity of coal and petcoke to achieve the necessary output, which caused the exceedances. At that time, Mr. Wing was the only person at the facility who knew the petcoke charge rate would exceed the limit if wood and TDF werenÂt also burned in the boilers, along with coal and petcoke. Since then, TESÂs operators have been trained to use TESÂs reserve blend of coal, which contains a lower percentage of petcoke than what TES normally uses, if wood and TDF fail to load into the boilers.
Regarding the VE record