10/27/16 - CONSENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $67,000, DUE WITHIN 30 DAYS.
ALLEGATIONS:
DURING AN APR 17, 2013 INSPECTION, EPA INSPECTORS OBSERVED THE COVER ON THE NEUTRALIZATION PIT AT THE FACILITY CONTAINED CRACKS, GAPS AND A VENT THRU WHICH HAPs WERE LOST TO THE ATMOSPHERE. THEREFORE, RESPONDENT FAILED TO OPERATE AND MAINTAIN A FIXED ROOF ON THE NEUTRALIZATION PIT.
THE COVER ON THE NEUTRALIZATION PIT WAS OBSERVED TO CONTAIN CRACKS, GAPS AND A VENT THRU WHICH HAPs WERE LOST TO THE ATMOSPHERE EPA INSPECTORS ALSO OBSERVEDA STRONG CHEMICAL ODOR THAT WAS CLEARLY NOTICEABLE AROUND THE NEUTRALIZATION PIT. RESPONDENT'S SEMIANNUAL INSPECTION REPORTS FROM 2011-2014 DO NOT IDENTIFY CONTROL EQUIPMENT FAILURES ASSOCIATED WITH THE COVER ON THE NEUTRALIZATION PIT.
RESPONDENT DID NOT CONDUCT PROPER INSPECTIONS OF THE NEUTRALIZATION PIT FOR CONTROL EQUIPMENT FAILURES AND DID NOT UNDERTAKE TIMELY REPAIRS OF THE CONTROL EQUIPMENT FAILURE IN VIOLATION OF 40 CFR 63.133(g), 63.133(h) AND 63.148(b)(3).
RESPONDENT DID NOT SUBMIT COMPLETE COMPLIANCE REPORTS CONTAINING INFO ON DEVIATIONS SUCH AS CONTROL EQUIPMENT FAILURES, IN VIOLATION OF 40 CFR 63.2520(a), 63.2520(e) AND TABLE 11.
RESPONDENT MEASURED HAP CONCENTRATIONS TO DETERMINE THE RMR DOWNSTREAM OF THE POINT OF DETERMINATION, AFTER LOSSES TO THE ATMOSPHERE OCCURRED, BUT RESPONDENT DID NOT MAAKE ADJUSTMENTS FOR SUCH LOSSES TO THE ATMOSPHERE. RESPONDENT MEASURES HAP LOADS FOR THE RMR IN THE DISCHARGE FROM THE