EPA REGION III ISSUED AN ADMINISTRATIVE SETTLEMENT AGREEMENT AND ORDER ON CONSENT ( ORDER ) TO TRANSFLO TERMINAL SERVICES, INC. ( TRANSFLO ), THE OWNER AND OPERATOR OF 14 TRANSLOADING FACILITIES ACROSS REGION III WHERE IT CONDUCTS THE TRANSFERS OF SUBSTANCES BETWEEN RAIL CARS AND TRUCKS. EPA CONDUCTED AN INSPECTION OF TRANSFLO'S BUTLER, PENNSYLVANIA TERMINAL ( FACILITY ) ON APRIL 26, 2011 AND DETERMINED THAT TRANSFLO WAS COVERED BY THE RMP REGULATIONS DUE TO ITS STORAGE OF BUTANE, PROPANE, AND PROPYLENE, BUT THAT IT WAS NOT IN COMPLIANCE WITH THE RMP REQUIREMENTS BECAUSE IT HAD: 1) SUBMITTED ITS RMP TEN MONTHS LATE IN VIOLATION OF 40 C.F.R. SECTION 68.10(a) AND 68.150(A); 2) NOT TIMELY ESTABLISHED AND IMPLEMENTED WRITTEN PROCEDURES TO MAINTAIN THE ONGOING INTEGRITY OF ITS LIQUID PROPANE GAS ( LPG ) TRANSFER EQUIPMENT IN VIOLATIONS OF 40 C.F.R. SECTION 68.73(a) AND (b); AND 3) FAILED TO CONDUCT REQUIRED TRAINING RELATED TO THE MAINTENANCE OF THE INTEGRITY OF THE LPG GAS TRANSFER EQUIPMENT IN VIOLATION OF 40 C.F.R. SECTION 68.73(c). THE ORDER REQUIRES THAT RESPONDENT UNDERTAKE A REVIEW OF ALL ITS 13 OTHER FACILITIES WHICH IT CURRENTLY OWNS OR OPERATES IN EPA REGION III AS OF THE EFFECTIVE DATE OF THE ORDER AND ANY FACILITIES THAT IT BEGINS TO OWN OR OPERATE UP TO ONE YEAR AFTER THE EFFECTIVE DATE OF THE ORDER. IN UNDERTAKING THIS REVIEW, THE RESPONDENT WILL DETERMINE FOR EACH FACILITY WHETHER ANY RMP-REGULATED SUBSTANCES IS PRESENT IN A QUANTITY GREATER THAN ITS THRESHOLD