10/25/05 - CONSENT AGREEMENT AND FINAL ORDER ISSUED, ASSESSING A PENALTY OF $21,332, DUE WITHIN 30 DAYS. RESPONDENT ALSO AGREES TO COMPLETE A SEP.
ALLEGATIONS:
RESPONDENT DID NOT DOCUMENT OTHER PERSONS RESPONSIBLE FOR IMPLEMENTING INDIVIDUAL REQUIREMENTS OF THE RMPROGRAM AND TO DEFINE THE LINES OF AUTHORITY THROUGH AN ORGANIZATION CHART OR SIMILAR DOCUMENT (40 CFR 68.15(c)).
RESPONDENT DID NOT ADDRESS STATIONARY SOURCE SITING AS PART OF THE PROCESS HAZARD ANALYSIS (PHA) CONDUCTED IN 1999 (40 CFR 68.67(c)).
RESPONDENT DID NOT DEVELOP A WRITTEN SCHEDULE OF WHEN PHA ACTION ITEMS WERE TO BE COMPLETED, AND DID NOT DOCUMENT PHA ACTION ITEM RESOLUTIONS (40 CFR 68.67(e)).
RESPONDENT DID NOT UPDATE AND RE-VALIDATE THE PHA AT LEAST EVERY FIVE YEARS (40 CFR 68.67(f)).
RESPONDENT DID NOT ANNUALLY CERTIFY THAT THE OPERATING PROCEDURES ARE CURRENT AND ACCURATE, AND THAT PROCEDURES HAVE BEEN REVIEWED AS OFTEN AS NECESSARY (40 CFR 68.69(c)).
RESPONDENT DID NOT PROVIDE REFRESHER TRAINING ON OPERATING PROCEDURES AT LEAST EVERY THREE YEARS (40 CFR 68.71(b)).
RESPONDENT DID NOT PREPARE AND MAINTAIN A RECORD OF EMPLOYEE TRAINING ON OPERATING PROCEDURES (40 CFR 68.71(c)).
RESPONDENT DID NOT IMPLEMENT THE MANAGEMENT OF CHANGE PROCEDURE TO CONTROL THEPROCESS CHANGES ASSOCIATED WITH THE ADDITION OF THE SCRUBBER SYSTEM TO THE SULFUR DIOXIDE PROCESS (40 CFR 68.75(a)).
RESPONDENT DID NOT IMPLEMENT AND DOCUMENT A PRE-STARTUP REVIEW FOR THE SULFUR DIOXIDE PROCESS AFTER THE