EPA v. INTERTRADE HOLDINGS, INC.

Case summary

10/25/05 - CONSENT AGREEMENT AND FINAL ORDER ISSUED, ASSESSING A PENALTY OF $21,332, DUE WITHIN 30 DAYS. RESPONDENT ALSO AGREES TO COMPLETE A SEP. ALLEGATIONS: RESPONDENT DID NOT DOCUMENT OTHER PERSONS RESPONSIBLE FOR IMPLEMENTING INDIVIDUAL REQUIREMENTS OF THE RMPROGRAM AND TO DEFINE THE LINES OF AUTHORITY THROUGH AN ORGANIZATION CHART OR SIMILAR DOCUMENT (40 CFR 68.15(c)). RESPONDENT DID NOT ADDRESS STATIONARY SOURCE SITING AS PART OF THE PROCESS HAZARD ANALYSIS (PHA) CONDUCTED IN 1999 (40 CFR 68.67(c)). RESPONDENT DID NOT DEVELOP A WRITTEN SCHEDULE OF WHEN PHA ACTION ITEMS WERE TO BE COMPLETED, AND DID NOT DOCUMENT PHA ACTION ITEM RESOLUTIONS (40 CFR 68.67(e)). RESPONDENT DID NOT UPDATE AND RE-VALIDATE THE PHA AT LEAST EVERY FIVE YEARS (40 CFR 68.67(f)). RESPONDENT DID NOT ANNUALLY CERTIFY THAT THE OPERATING PROCEDURES ARE CURRENT AND ACCURATE, AND THAT PROCEDURES HAVE BEEN REVIEWED AS OFTEN AS NECESSARY (40 CFR 68.69(c)). RESPONDENT DID NOT PROVIDE REFRESHER TRAINING ON OPERATING PROCEDURES AT LEAST EVERY THREE YEARS (40 CFR 68.71(b)). RESPONDENT DID NOT PREPARE AND MAINTAIN A RECORD OF EMPLOYEE TRAINING ON OPERATING PROCEDURES (40 CFR 68.71(c)). RESPONDENT DID NOT IMPLEMENT THE MANAGEMENT OF CHANGE PROCEDURE TO CONTROL THEPROCESS CHANGES ASSOCIATED WITH THE ADDITION OF THE SCRUBBER SYSTEM TO THE SULFUR DIOXIDE PROCESS (40 CFR 68.75(a)). RESPONDENT DID NOT IMPLEMENT AND DOCUMENT A PRE-STARTUP REVIEW FOR THE SULFUR DIOXIDE PROCESS AFTER THE ADDITION OF THE SCRUBBER SYSTEM PRIOR TO THE PROCESS RESTART (40 CFR 68.77(a)). RESPONDENT DID NOT CERTIFY THAT THE STATIONARY SOURCE HAS EVALUATED COMPLIANCE WITH THE PROVISIONS OF THE PREVENTION PROGRAM AT LEAST EVERY THREE YEARS (40 CFR 68.70(a)).

Defendants (1)

• INTERTRADE HOLDINGS, INC. (SB)Named in complaintNamed in settlement

Facilities (1)

• INTERTRADE HOLDINGS, INC.

  HIGHWAY 68, COPPERHILL, TN, 37317

  Registry ID: 110000589934

Statutes cited

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

Enforcement conclusions (1)

• INTERTRADE HOLDINGS, INC.entered 2005-10-25

  Primary law: CAA

  Federal penalty: $21,332 · SEP: $2,209

Timeline (3 milestones)

• 2005-10-25Final Order Issued
• 2005-10-25Complaint Filed/Proposed Order
• 2006-02-06Enforcement Action Data Entered