'Countrymark failed to perform their leak Detection and Repair (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 inspection, Countrymark had started using a contractor to perform 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 between both offers. Countrymark suggested the SEP to purchase the haz mat trailer.'