5/12/09 - EXPEDITED SETTLEMENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $1,080, DUE WITHIN 15 DAYS.
VIOLATIONS: EPA ALLEGES THAT THE RESPONDENT VIOLATED THE CAA'S CHEMICAL ACCIDENT PREVENTION PROGRAM WHEN RESPONDENT DID NOT PROVIDE EVIDENCE THAT:
AS PART OF ITS SAFETY INFO DOCUMENTATION, IT HAS COMPILED AND MAINTAINED THE FOLLOWING INFORMATION PERTAINING TO THE TECHNOLOGY OF THE PROCESS AS REQUIRED BY 40 CFR 68.65(c)(1): (iii) MAXIMUM INTENDED INVENTORY; (iv) SAFE UPPER AND LOWER LIMITS FOR SUCH ITEMS AS TEMPERATURES, PRESSURES, FLOWS, OR COMPOSITIONS; AND (v) AN EVALUATION OF THE CONSEQUENCES OF DEVIATION;
AS PART OF ITS SAFETY INFO DOCUMENTATION, IT HAS COMPILED AND MAINTAINED THE FOLLOWING INFO PERTAINING TO THE EQUIPMENT IN THE PROCESS AS REQUIRED BY 40 CFR 68.65(d)(1): (i) MATERIALS OF CONSTRUCTION; (iii) ELECTRICAL CLASSIFICATION; (v) VENTILATION SYSTEM DESIGN; (vi) DESIGN CODES AND STANDARDS EMPLOYED; AND (viii) SAFETY SYSTEMS (E.G., INTERLOCKS, DETECTION OR SUPPRESSION SYSTEMS);
IT HAS UPDATED AND REVALIDATED ITS PROCESS HAZARD ANALYSIS AT LEAST EVERY 5 YRS AS REQUIRED BY 40 CFR 68.67(f);
IT HAS DEVELOPED AND IMPLEMENTED WRITTEN OPERATING PROCEDURES THAT ADDRESS THE FOLLOWING ELEMENTS FOUND AT 40 CFR 68.69(a): (3) SAFETY AND HEALTH CONSIDERATION, INCLUDING (i) PROPERTIES OF, AND HAZARDS PRESENTED BY THE CHEMICALS USED IN THE PROCESS; (ii) PRECAUTIONS NECESSARY TO PREVENT EXPOSURE, INCLUDING ENGINEERING CONTROLS, ADMINISTRATIVE CONTROLS AND PERSONAL PRO