Two EPA representatives inspected Western Alaska Fisheries, Inc. in Kodiak on September 15, 2004. Based upon this inspection, EPA believes WAF is in violation of the following risk management program elements: Management, Hazard Assessment, Process Hazard Analysis, Training, Mechanical Integrity, Management of Change, Compliance audits, and Emergency Response.
☐ Specifically, at the time of inspection, WAF did not have a management system in place to oversee the implementation of the Risk Management Program (?68.15(a)) nor had they documented the persons responsible for implementing individual program requirements and defined the lines of authority through an organization chart or similar document (?68.15(c)).
☐ WAF did not have Hazard Assessment documentation that included the most recent census data to estimate the population that could be affected to define off-site impacts (?68.30(c)).
☐ WAF did not have sufficient documentation to indicate whether or not the Process Hazard Analysis findings were completed or communicated to system operating staff (?68.67(e)).
☐ WAF?s prevention program training records are insufficient and do not indicate that employees already have the knowledge necessary to carry out operating procedures (?68.71(a)(2), that three year refresher training on operating procedures have been provided (?68.71(b)), and that employees understand the training (?68.71(c)).
☐ WAF did not have any written records to doc