FAILURE TO DO LEAK DETECTION INSPECTION IN COMPLIANCE WITH NSPS. COUNTRYMARK FAILED TO PERFORM THEIR LEAK DETECTION AND RE- PAIR (LDAR) PROGRAM ACCORDING TO THE NSPS REGULATIONS. COUNTRYMARK FAILED TO MAINTAIN A LOG IDENTIFYING AND EACH VALVE WHICH HAD TO BE MONITORED. AT THE TIME OF THE IN- SPECTION, COUNTRYMARK HAD STARTED USING A CONTRACTOR TO PERFORM THE LDAR INSPECTIONS. U.S. EPA AND COUNTRYMARK WENT THROUGH ALTERNATIVE DISPUTE RESOLUTION AND SINCE BOTH SIDES COULD NOT AGREE ON AN AMOUNT, THE JUDGE SUGGESTED THE PENALTY SHOULD BE IN BE- TWEEN BOTH OFFERS. COUNTRYMARK SUGGESTED THE SEP TO PUR- CHASE THE HAZ MAT TRAILER.