This is an Administrative Penalty Order under CAA §113 issued to BEI Hawaii LLC for violations of Risk Management Program requirements required under CAA §112(r)(7) and 40 CFR Part 68. Violations alleged are as follows:
1) Failure to establish a system to address the process hazard analysis teamÂs findings, in violation of CAA § 112(r)(7);
2) Failure to document, develop, and implement written operating procedures, in violation of CAA § 112(r)(7);
3) Failure to implement operatorÂs own written procedures and document inspections and tests on process equipment, in violation of CAA § 112(r)(7); and
4) Failure to include all covered processes in the RMP registration, in violation of CAA § 112(r)(7).
Respondent has corrected the alleged violations and agreed to pay a civil penalty in the amount of $86,500.