2/6/06 - EXPEDITED SETTLEMENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $3,660, DUE WITHIN 15 DAYS.
ALLEGED VIOLATIONS:
THE SPECIFIC VIOLATIONS CITED BELOW ARE RELEVATN TO THE CHLORINE AND SULFUR DIOXIDE PROCESSES:
1. FAILURE TO DOCUMENT OTHER PERSONS RESPONSIBLE FOR IMPLEMENTING INDIVIDUAL REQUIREMENTS OF THE RISK MANAGEMENT PROGRAM AND DEFINED THE LINES OF AUTHORITY THORUGH AN ORGANIZATION CHART OR SIMILAR DOCUMENT (40 CFR 68.15(c)).
2. FAILURE TO DOCUMENT AND COMPILE AS PART OF THE PROCESS SAFETY INFORMATION:
INFORMATION PERTAINING TO THE TECHNOLOGY OF THE PROCESS:
(a) MAXIMUM INTENDED INVENTORY (40 CFR 68.65(c)(1)(iii);
(b) SAFE UPPER AND LOWER LIMITS FOR PROCESS TEMPERATURES AND PRESSURES (40 CFR 68.65(c)(1)(iv)); AND
(c) AN EVALUATION OF THE CONSEQUENCES OF DEVIATION FROM OPERATING LIMITS (40 CFR 68.65(c)(1)(iv)); AND
INFORMATION PERTAINING TO THE EQUIPMENT IN THE PROCESS:
(a) VENTILATION SYSTEM DESIGN (40 CFR 68.65(d)(1)(v)); AND
(b) DESIGN CODES AND STANDARDS EMPLOYED (40 CFR 68.65(d)(1)(vi)).
3. FAILURE TO PERFORM THE INITIAL PROCESS HAZARD ANALYSIS (40 CFR 68.67(a)).
4. FAILURE TO DEVELOP WRITTEN OPERATING PROCEDURES WHICH ADDRESS THE FOLLOWING:
STEPS FOR EACH OPERATING PHASE:
(a) EMERGENCY SHUTDOWN, INCLUDING THE CONDITIONS UNDER WHICH EMERGENCY SHUTDOWN IS REQUIRED AND THE ASSIGNMENT OF SHUTDOWN RESPONSIBILITY TO QUALIFIED OPERATORS TO ENSURE THAT EMERGENCY SHUTDOWN IS EXECUTED IN A SAFE AND TIMELY MANNER (40 CF