6/9/10 - EXPEDITED SETTLEMENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $2,800, DUE WITHIN 15 DAYS.
ALLEGED VIOLATIONS:
EPA ALLEGES THAT RESPONDENT VIOLATED THE CAA'S CHEMICAL ACCIDENT PREVENTION PROGRAM WHEN RESPONDENT DID NOT PROVIDE EVIDENCE THAT:
IT HAS DOCUMENTED AND COMPILED AS PART OF THE PROCESS SAFETY INFO THE FOLLOWING PERTAINING TO THE TECHNOLOGY OF THE PROCESS AS REQUIRED BY 40 CFR 68.65(c)(1); (iv) SAFE UPPER AND LOWER LIMITS FOR SUCH ITEMS AS TEMPERATURE, PRESSURES, FLOWS AND COMPOSITIONS, AND (v) AN EVALUATION OF THE CONSEQUENCES OF DEVIATIONS;
IT HAS DOCUMENTED AND COMPILED AS PART OF THE PROCESS SAFETY INFO THE FOLLOWING PERTAINING TO THE PROCESS EQUIPMENT AS REQUIRED BY 40 CFR 68.65(d)(1): (i) MATERIALS OF CONSTRUCTION, (ii) PIPING AND INSTRUMENT DIAGRAMS, (iii) ELECTRICAL CLASSIFICATION, (iv) RELIEF SYSTEM DESIGN AND DESIGN BASIS, AND (viii) SAFETY SYSTEMS (e.g., INTERLOCKS, DETECTION OR SUPPRESSION SYSTEMS);
IT HAS UPDATED AND REVALIDATED ITS PROCESS HAZARD ANALYSIS AT LEAST EVERY 5 YEARS AS REQUIRED BY 40 CFR 638.67(f);
IT HAS ANNUALLY CERTIFIED THAT ITS OPERATING PROCEDURES ARE CURRENT AND ACCURATE AS REQUIRED BY 40 CFR 68.69(c);
IT HAS PROVIDED REFRESHER TRAINING, AT LEAST EVERY 3 YRS, TO EMPLOYEES INVOLVED WITH THE COVERED PROCESSES TO ENSURE THAT ITS EMPLOYEES UNDERSTAND AND ADHERE TO THE CURRENT OPERATING PROCEDURES AS REQUIRED BY 40 CFR 68.71(b);
IT HAS CONDUCTED COMPLIANCE EVALUATIONS, AT LEAST EVERY 3 YRS, AND BASED ON SUCH