EPA v. Covington Waste Water Treatment Plant

Case summary

Expedited Settlement Agreement - 2/3/2005, assessed penalty $1,020. Alleged Violations: Failure to document the hazards of the process as part of the process hazard analysis (40 C.F.R. Section 68.67(c)(1)). Failure to document engineering and administrative controls applicable to process hazards and interrelationships as part of the process hazard analysis (40 C.F.R. Section 68.67(c)(3)). Failure to address stationarysouring siting as part of the process hazard analysis (40 C.F.R. Section 68.67(c)(5)). Failure to document an evaluation of a range of the possible health effects of failure of controls as part of the process hazard analysis (40 C.F.R. Section 68.67(c)(7)). Failure to document written operating procedures which address the following: Emergency shutdown, and Process Startup. Failure to document written operating procedures which address the following: Safety and health considerations, Properties of, and hazards present by the chemicals used in the process; Control measures to be taken if physical contact or airborne exposure occurs; Safety systems and their functions. Failure to certify annually that the operating procedures are current and accurate and that procedures have been reviewed as often as necessary (40 C.F. R. Section 68.69(c)). Failure to certify that the stationary source has evaluated compliance with the provisions of the prevention program at least every three years (40 C.F.R. 68.79(a)).

Defendants (1)

• COVINGTON WASTE WATER TREATMENT PLANT (SB)Named in complaintNamed in settlement

Facilities (4)

• CITY OF COVINGTON

  298 WITHERINGTON DRIVE, COVINGTON, TN, 38019

  Registry ID: 110000531247

• CITY OF COVINGTON

  298 WITHERINGTON DRIVE, COVINGTON, TN, 38019

  Registry ID: 110000531247

• CITY OF COVINGTON

  298 WITHERINGTON DRIVE, COVINGTON, TN, 38019

  Registry ID: 110000531247

• CITY OF COVINGTON

  298 WITHERINGTON DRIVE, COVINGTON, TN, 38019

  Registry ID: 110000531247

Statutes cited

• CAA 112[R][7] — Prevention of Accidental Release/Risk Management Plans (RMPs)

Enforcement conclusions (1)

• Covington Waste Water Treatment Plantentered 2005-02-03

  Primary law: CAA

  Federal penalty: $1,020

Timeline (4 milestones)

• 2005-02-03Enforcement Action Closed
• 2005-02-03Complaint Filed/Proposed Order
• 2005-02-03Final Order Issued
• 2005-02-16Enforcement Action Data Entered