7/17/2012 - CONSENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $21,200 DUE WITHIN 30 DAYS.
ALLEGATIONS:
ON OR ABOUT JULY 31, 2008, AN INSPECTION WAS CONDUCTED BY EPA AT THE RESPONDENT'S FACILITY TO DETERMINE COMPLIANCE WITH SPCC REGS. EPA FOUND THE FOLLOWING SPCC VIOLATIONS:
A. RESPONDENT FAILED TO PREPARE A WRITTEN SPCC PLAN FOR THE FACILIYT AS REQUIRED BY 40 CFR 112.3 IN ACCORDANCE WITH THE GUIDELINES FOR PLAN PREPARATION AT 40 CFR 112.7 AND OTHER APPLICABLE SECTIONS IN 40 CFR PART 112.
B. THE PLAN NEITHER FOLLOWED THE SEQUENCE SPECIFIED IN THE SPCC REGS NOR INCLUDED A SECTION PROPERLY CROSS REFERENCING THE REQUIREMENTS IN THE PLAN, AS REUQIRED BY 40 CFR 112.7.
C. THE PLAN DID NOT DISCUSS METHODS OF DISPOSAL FOR RECOVERED MATERIALS IN ACCORDANCE WITH APPLICALBE LEGAL REQUIREMENTS, AS REQUIRED BY 40 CFR 112.7(a)(3)(v).
D. THE PLAN DID NOT DISCUSS DRAINAGE PROCEDURES FOR DIKED AREAS, AS REQUIRED BY 40 CFR 112.9(b)(1).
E. THE PLAN DID NOT DISCUSS OR INDICATE HOW CONTAINERS USED FOR THE STORAGE OF OIL ARE COMPATIBLE WITH THE MATERIAL BEING STORED, AS REQUIRED BY 40 CFR 112.9(c)(1).
F. THE PLAN DID NOT DISCUSS ENGINEERING OR UPDATING NEW AND OLD TANK BATTERY INSTALLATIONS IN ACCORDANCE WITH GOO DENGINEERING PRACTICES TO PREVENT DISCHARGES, AS REQUIRED BY 40 CFR 112.9(c)(4).
G. THE PLAN DID NOT DISCUSS INSPECTION PROCEDURES FOR SALTWATER (OIL FIELD BRINE) DISPOSAL FACILITIES, AS REQUIRED BY 40 CFR 112.9(d)(2).