Document vxJRqvqKyGy82GXzyxxzMOjZ

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 VIA ELECTRONIC MAIL Mr. Thomas Evert Engineering Manager Crown Bakeries 1905 Hackworth Street Nashville, Tennessee 37210 tevert@crownbakeries.com Re: Crown Bakeries - Nashville, Tennessee Notice of Potential Violation and Opportunity to Confer Dear Mr. Evert: Information currently available to the U.S. Environmental Protection Agency suggests that Crown Bakeries may have committed violations of Section 112(r)(7) of the Clean Air Act (CAA), 42 U.S.C. 7412(r)(7), and its Risk Management Program (RMP) regulations found at 40 C.F.R. Part 68. By this letter, the EPA is extending to you an opportunity to advise the Agency via a conference call, or in writing, of any further information the EPA should consider with respect to the potential violations. Specifically, on June 23, 2021, an authorized representative of the EPA conducted a compliance monitoring inspection at the facility located at 1905 Hackworth Street, Nashville, Tennessee (the facility) to determine compliance with the CAA and RMP regulations, and observed the following potential violations: 1. The owner or operator did not provide an established training program for employees operating the covered process, or a record of documentation of employee training completion or competency as required by 40 C.F.R. 68.71(a) and 40 C.F.R. 68.71(c); 2. The owner or operator did not document that equipment complies with recognized and generally accepted good engineering practices as required by 40 C.F.R. 68.65(d)(2); 3. The owner or operator did not provide any established written procedures to manage changes that affect the covered process as required by 40 C.F.R. 68.75(a); 4. The owner or operator did not provide documentation of training for employees whose job tasks were affected by the facility expansion in November 2020 as required by 40 C.F.R. 68.75(c); and Internet Address (URL) http://www.epa.gov 5. The owner or operator did not produce records of training of each employee involved in operating the process prior to the facility expansion in November 2020 as part of the pre-startup safety review as required by 40 C.F.R. 68.77(b)(4). The EPA has authority under Section 113 of the CAA, 42 U.S.C. 7413, to pursue enforcement actions for violations of Section 112(r)(7) of the CAA and its RMP regulations found at 40 C.F.R. Part 68, including the issuance of compliance orders, the assessment of administrative penalties and/or the initiation of civil or criminal actions. To resolve the potential violations identified above, the EPA requests that a representative of the facility contact Ms. Bethany Terpin, of my staff at (404) 562-9048, or via email at terpin.bethany@epa.gov, within seven (7) calendar days of receipt of this letter to make arrangements to schedule a teleconference to discuss the potential violations and the EPA's possible enforcement action. Please note that the EPA will have legal representation during these discussions. Please inform Ms. Terpin if you intend to have legal representation present as well. You may voluntarily submit any documentation or information that you would like the EPA to review in advance of any teleconference on the matter as to why you believe the EPA should not take an enforcement action with respect to the above-mentioned potential violations. If you decide to submit such documentation or information, the EPA respectfully requests that you do so two weeks in advance of the teleconference. If you have questions regarding the type of information that should be submitted to the EPA or any other questions regarding this matter, please contact Ms. Bethany Terpin at the contact information identified above. Sincerely, JASON DRESSLER Digitally signed by JASON DRESSLER Date: 2021.11.09 10:16:58 -05'00' Jason Dressler Chief North Air Enforcement Section