Two EPA representatives inspected International Seafoods of Alaska, Plant #2 on September 15, 2004. Based upon this inspection, EPA believes ISA Plant #2 is in violation of the following risk management program elements: Management, Hazard Assessment, Process Safety Information, Process Hazard Analysis, Operating Procedures, Training, Management of Change, Pre-startup Review, Incident Investigation, and Emergency Response.
- Specifically, at the time of inspection, ISA Plant #2 did not have a management system in place to oversee the implementation of the Risk Management Program (�68.15(a)).
- ISA Plant #2 had not determined the worst-case release quantity correctly (�68.25(b)), they did not have Hazard Assessment documentation that included an offsite consequence analysis with an estimated population based on a circle with the point of release at the center ((�68.30(a-d)), they had not identified environmental receptors within this same circle (�68.33(a)), they did not have sufficient documentation for EPA to determine the rationale for selection of the worst-case scenario (�68.39(a)), and did not have sufficient documentation for describing the assumptions used for the alternative release scenario (�68.39(b)).
- ISA Plant #2 did not have any documentation that indicated that existing equipment, designed and constructed in accordance with codes, standards or practices that are no longer in general use, is designed, maintained, inspected, tested, and oper