7/15/2008 - EXPEDITED SETTLEMENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $2,100. RESPONDENT SHALL MAKE PAYMENT WITHIN FIFTEEN DAYS. AGREEMENT ALLEGES: BASED ON A COMPLIANCE MONITORING INSPECTION CONDUCTED AT THE RESPONDENT'S FACILITY, ON APRIL 4, 2007, EPA ALLEGES THAT THE RESPONDENT VIOLATED THE ACT'S CHEMICAL ACCIDENT PREVENTION PROGRAM WHEN RESPONDENT DID NOT PROVIDE EVIDENCE THAT: AS PART OF THE PROCESS HAZARD ANALYSIS (PHA) CONDUCTED IN THE YEAR 2005, IT HAD DEVELOPED A WRITTEN SCHEDULE OF WHEN PHA ACTION ITEMS WERE TO BE COMPLETED AS REQUIRED BY 40 CFR SECTION 68.67(e); IT HAD DEVELOPED AND IMPLEMENTED WRITTEN OPERATING PROCEDURES THAT ADDRESS THE FOLLOWING ELEMENTS FOUND AT 40 CFR SECTION 68.69(a): (3) SAFETY AND HEALTH CONSIDERATIONS, INCLUDING (ii) CONTROL MEASURES TO BE TAKEN IF PHYSICAL CONTACT OR AIRBORNE EXPOSURE OCCURS; AND IT IMPLEMENTED ITS MANAGEMENT OF CHANGE PROCEDURES WHEN IT ADDED PROCESS INTERLOCKS AS REQUIRED BY 40 CFR SECTION 68.75(a).