In February 2001, IPSCO Steel, Inc. (Respondent) notified EPA that it had possible noncompliance with CAA reporting and permitting, CWA (SPCC plan), and RCRA labeling, training, contingency plan, universal waste, and used oil requirements. EPA determined that some of the RCRA violations were similar to those subject to a Notice of Violation (NOV) issued by Region 7 in March 1998 and, therefore, did not qualify for penalty reduction under the Audit Policy (A/P). Also, one CAA violation was not independently discovered as it was revealed through a recent state inspection, and, therefore, did not qualify for penalty relief under the A/P.
CWA Violation
Respondent disclosed that its Spill Prevention Control and Countermeasure (SPCC) plan was inadequate. Although required controls were in place, the plan did not include all of the guidelines codified at 40 C.F.R. �� 112.7
CAA Violations
Respondent disclosed that it had failed to record furnace pressure, fan amps, and damper positions on a once-per-shift basis. The NSPS for EAFs, 40 C.F.R. Part 60, subpart AAa, requires that furnace pressure, fan amps, and damper positions be checked and recorded on a once-per-shift basis. The failure to record these readings during separate shifts is a violation of 40 C.F.R. �� 60.274a(b) and CAA section 111, 42 U.S.C. �� 7411. Respondent disclosed that it failed to maintain a logbook resulting in violations of requirements in its PSD permit no. 94-A-561-S1 to 1) m