8/23/18 - CONSENT AGREEMENT AND FINAL ORDER ISSUED, ASSESSING A PENALTY OF $6,118 DUE WITHIN 30 DAYS. RESPONDENT AGREES TO COMPLETE A SEP.
ALLEGATIONS:
ON SEPT 15, 2016, EPA CONDUCTED AN ONSITE INSPECTION OF THE RMPROGRAM RELATED RECORDS AND EQUIPMENT FOR THE PURPOSE OF ASSESSING THE RESPONDENT'S COMPLIANCE WITH THE RMPROGRAM REQUIREMENTS AND THE IMPLEMENTED RECOGNIZED AND GENERALLY ACCEPTED GOOD ENGINEERING PRACTICES (RAGAGEP) FOR ITS COVERED PROCESSES AT ITS STATIONARY SOURCE.
THE RESPONDENT DID NOT MAINTAIN RECORDS ON THE OFFSITE CONSEQUENCE ANALYSES THAT CONTAIN DATA USED TO ESTIMATE POPULATION AND ENVIRONMENTL RECEPTORS POTENTIALLY AFFECTED.
THE RESPONDENT FAILED TO DOCUMENT THAT EQUIPMENT COMPLIED WIHT RAGAGEP BY NOT LABELING THE AMMONIA PIPING CONTENTS AND DIRECTION OF FLOW.
THE RESPONDENT DID NOT PROMPTLY DETERMINE AND DOCUMENT AN APPROPRIATE RESPONSE TO EACH OF THE FINDINGS OF THE COMPLIANCE AUDIT DATED JAN 6-9, 2015, AND DOCUMENT THAT DEFICIENCIES HAD BEEN CORRECTED.