8/3/2011 - COMPLIANCE ORDER ISSUED.
ORDER STATES:
EPA DETERMINED THAT AT THE TIME OF INSPECTION, THE RESPONDENT WAS NOT COMPLIANT WITH THE RMProgram. ON APRIL 12. 2011, THE EPA NOTIFIED THE RESPONDENT OF THE FOLLOWING CAA SECTION 112(r)(1) GENERAL DUTY CLAUSE AND RMProgram VIOLATIONS ASSOCIATED WITH ITS VINYL CHLORIDE/CA/O PROCESS RMP PROCESS 1000002379): THE RESPONDENT FAILED TO COMPILE THE PROCESS SAFETY INFORMATION (SAFETY SYSTEMS) FOR ITS EDC/VINYL AND ETHYLENE UNITS AS REQUIRED BY 40 CFR SECTION 68.65(d)(1)(viii); FAILED TO ADDRESS STATIONARY SOURCE TOXIC EFFECTS AS PART OF ITS PROCESS HAZARD ANALYSIS (PHA) STATIONARY SOURCE SITING EVALUATION AS REQUIRED BY 40 CFR SECTION 68.67(c)(5); FAILED TO ADDRESS PHA HUMAN FACTORS ASSOCIATED WITH INADEQUATE PROCESS EQUIPMENT LABELING AS REQUIRED BY 40 CFR SECTION 68.67(c)(6); FAILED TO ADDRESS PHA HUMAN FACTOR FINDINGS RELATED TO THE NUMBER OF MANUAL ADJUSTMENTS DURING NORMAL OR UPSET CONDITIONS IN THE CHLORINE UNIT AS REQUIRED BY 40 CFR SECTION 68.67(e); FAILED TO PERFORM AND DOCUMENT INSPECTIONS AND TESTS ON ALL PROCESS EQUIPMENT AS REQUIRED BY 40 CFR SECTION 68.73(d)(1) & (4); AND FAILED TO CORRECT ALL UNSAFE ELECTRICAL CONDITIONS, IDENTIFY/LABEL ALL NECESSARY PROCESS PIPING, ELIMINATE ALL EXCESSIVE PIPING CORROSION AND INSULATION ISSUES, AND ELIMINATE ALL GENERAL SAFETY HAZARDS AS REQUIRED BY CAA SECTION 112(r)(1).
ORDER REQUIRES:
RESPONDENT SHALL COMPILE ALL REQUIRED PROCESS SAFETY INFORMATION FOR ITS EDC/VINYL AND ETH