12/9/08 - EXPEDITED SETTLEMENT AGMT ISSUED, ASSESSING A PENALTY OF $1,170, DUE WITHIN 15 DAYS. ALLEGED VIOLATIONS: EPA ALLEGES THAT RESPONDENT VIOLATED THE ACT'S CHEMICAL ACCIDENT PREVENTION PROGRAM WHEN RESPONDENT DID NOT PROVIDE EVIDENCE THAT:
IT HAD DEVELOPED AND IMPLEMENTED WRITTEN OPERATING PROCEDURES THAT ADDRESS THE FOLLOWING ELEMENTS FOUND AT 40 CFR 68.69(a): (3) SAFETY AND HEALTH CONSIDERATION, INCLUDING, (ii) PRECAUTION NECESSARY TO PREVENT EXPOSURE, INCLUDING PERSONAL PROTECTIVE EQUIPMENT;
IT HAS ANNUALLY CERTIFIED THAT THE OPERATING PROCEDURES ARE CURRENT AND ACCURATE AND THAT PROCEDURES HAVE BEEN REVIEWED AS OFTEN AS NECESSARY BY 40 CFR 68.69(c); AND
IT IMPLEMENTED ITS MANAGEMENT OF CHANGE PROCEDURES WHEN IT ADDED PROCESS ALARMS AS REQUIRED BY 40 CFR 68.75(a).