2/25/2010 - EXPEDITED SETTLEMENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $2,640, DUE WITHIN 15 DAYS.
ALLEGED VIOLATIONS:
BASED ON A COMPLIANCE MONITORING INSPECTION CONDUCTED AT THE RESPONDENT'S PAUL B. KREBS WATER TREATMENT PLANT LOCATED AT 1326 BURKHARD DRIVE, ANNISTON, AL, ON JUNE 25, 2008, EPA ALLEGES THAT THE RESPONDENT VIOLATED THE CAA'S CHEMICAL ACCIDENT PREVENTION PROGRAM WHEN RESPONDENT DID NOT PROVIDE EVIDENCE THAT:
IT HAS DEVELOPED AND IMPLEMENTED WRITTEN OPERATING PROCEDURES THAT ADDRESS THE FOLLOWING ELEMENTS FOUND AT 40 CFR 68.52(b): (4) EMERGENCY SHUTDOWN AND OPERATIONS; (5) NORMAL SHUTDOWN; (6) STARTUP FOLLOWING A NORMAL OR EMERGENCY SHUTDOWN OR A MAJOR CHANGE THAT REQUIRES A HAZARD REVIEW; AND (7) CONSEQUENCES OF DEVIATION AND STEPS REQUIRED TO CORRECT OR AVOID DEVIATION;
IT HAS PROVIDED REFRESHER TRAINING FOR ITS EMPLOYEES, AT LEAST EVERY 3 YEARS, TO ENSURE THAT THE EMPLOYEES UNDERSTAND AND ADHERE TO OPERATING PROCEDURES AS REQUIRED BY 40 CFR 68.54(b); AND
IT HAS RETAINED THE TWO MOST RECENT COMPLIANCE AUDIT REPORTS AT THE FACILITY AS REQUIRED BY 40 CFR 68.58(e).