EPA v. Ingredion Incorporated (Bedford Park IL) CAFO

Case summary

On May 1, 2014, EPA inspected Respondent's facility and conducted an evaluation of the Facility's SPCC plan, last revised in September 2012. At that time, the Facility had not prepared,nor submitted an FRP. On February 4, 2015, EPA issued a Notice of Violation to Respondent alleging violations of certain SPCC and FRP regulations (in the NOV).The regulation requires an owner to prepare an SPCC plan that describes the physical layout of the facility and includes a diagram that identifies the location and contents of all regulated fixed oil storage containers, storage areas where mobile or portable containers are located, transfer stations, and connecting pipes. The Facility's SPCC plan did not completely describe the layout of the Facility including the manufacturing equipment in Building 59, or include a diagram that identifies the location of transfer stations in violation of the regulations. The regulations also require where experience indicates a reasonable potential for equipment failure, the SPCC plan must include a prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the facility as a result of each type of major equipment failure. The Facility's SPCC Plan did not include this in violation of the regulations. The regulations require that the owner any buried metallic storage tank installed on or after January 10, 1974 from corrosion and regularly perform leak tests. The SPCC Plan did not address these requirements in regards to its underground storage tank. The owner must also test each aboveground container for integrirty on a regular schedule, and the SPCC plan did not address this requirement. The regulations also require preparation of an FRP , but no FRP was prepared for the facility.The regulations require the Facility to develop and implement a facility response training program and a drill/exercise program. This was not prepared. In addition, the Facility maintained a C-II form that did not properly indicate that the Facility is located at a distance such that a discharge could cause harm to fish and wildlife and sensitive environments, in violation of the regulations. A civil penalty of $99,500 was imposed.

Defendants (1)

• Ingredion IncorporatedNamed in complaintNamed in settlement

Facilities (1)

• INGREDION INC ARGO PLANT

  6400 SOUTH ARCHER AVENUE, BEDFORD PARK, IL, 60501-1935

  Registry ID: 110017414742

Statutes cited

• CWA 311J — SPCC and/or Federal Response Plan Violations

Enforcement conclusions (1)

• Ingredion Incorporated (Bedford Park IL) CAFOentered 2017-02-07

  Primary law: CWA

  Federal penalty: $99,500 · SEP: $62,590

Timeline (4 milestones)

• 2016-12-07Complaint Filed/Proposed Order
• 2017-02-07Final Order Issued
• 2017-02-13Enforcement Action Data Entered
• 2020-03-03Pipeline Closed