# R-SQUARED-PUCKETT, INC.
> **Administrative - Formal** · FY2016 · — · Unilateral Administrative Order Without Adjudication
## Case
- **Activity ID:** `3600857923`
- **Case Number:** 04-2016-4750
- **Type:** Administrative - Formal
- **Lead:** EPA
- **Outcome:** Unilateral Administrative Order Without Adjudication
- **Penalty assessed:** —
- **Cost recovery:** —
- **Compliance action $:** —
- **Multimedia (multi-env):** —
## Defendants
- R-SQUARED-PUCKETT, INC. (settlement)
## Summary

10/25/16-ADMIN COMPLIANCE ORDER ISSUED.
ALLEGATIONS:
RESPONDENT IS AN INDUSTRIAL USER AND ITS PROCESS INCLUDES METAL PARTS CLEANING, COATING AND CONTACT COOLING WATER OF ALUMINUM PARTS.  

ON APR 22 -23, 2014, EPA'S NATL ENFORCEMENT INVESTIGATIONS CENTER AND R4, EPA CONDUCTED A CWA COMPLIANCE INVESTIGATION OF THE FACILITY TO EVALUATE RESPONDENT'S COMPLIANCE WITH THE REQUIREMENTS OF CWA 301, 307, AND 402; THE REGS PROMULGATED THEREUNDER AT 40 CFR PARTS 403 AND 433; SECTION 49-17-1 ET SEQ, MISSISSIPPI CODE OF 1972 AND RESPONDENT'S PRETREATMENT PERMIT.

AS A RESULT, EPA IDENTIFIED THE FOLLOWING VIOLATIONS OF THE PRETREATMENT STANDARDS AND REQUIREMENTS:
 - RESPONDENTS PROCEDURES FOR OPERATING THE ONSITE WWTP DID NOT REFLECT ACTUAL OPERATIONS. SEVERAL PROCESS UNITES DESCRIBED FOR THE WWTP WERE NOT BEING OPERATED, OR WERE REMOVED FROM SERVICE; THESE INCLUDE THE pH ADJUSTMENT TANK (T-6) AND CLARIFIER TANK #2 IN VIOLATION OF THE PERMIT.
 - SEVERAL COMPONENTS WERE ADDED TO THE FACILITY'S SYSTEM(S) THAT WERE NOT IN THE ORIGINAL PERMIT APPLICATION. THESE ADDED COMPONENTS INCLUDE 3 WASTEWATER STORAGE TANKS AND A STORMWATER STORAGE TANK. THERE WERE ALSO OBSERVED  OUT OF SERVICE  TREATMENT TANK MIXERS; THERE WAS NO AVAILABLE RETURN TO SERVICE SCHEDULE FOR THE MIXERS AS REQUIRED BY PERMIT.
 - RESPONDENT IS INCORRECTLY COLLECTING GRAB SAMPLES TO MANUALLY COMPOSITE. FOR OTHER PARAMETERS, COMPOSITE-EFFLUENT SAMPLES ARE BEING COLLECTED USING A SEVERELY DAMAGED AUTOMATIC SAMPLER. BECAUS

---
*Source: [EPA ECHO](https://echo.epa.gov/) · AI Analytics · CC0 1.0*