The inspection revealed that the Risk Management Plan (RMP) in place at the Slack facility located in Saratoga Springs, New York was deficient in numerous areas. In order to be in compliance with 40 CFR Part 68, the facility must conduct a hazard assessment; have updated process safety information; complete a Process Hazard Analysis (PHA); annually certify their SOPs, have a complete mechanical integrity program; have written management of change procedures, comply with the compliance audit requirements and have a developed and implemented employee participation program. Administrative Order CAA-02-2010-1018 was issued to compel compliance.
Another inspection was conducted at the Slack facility in Carthage, NY on October 26, 2010. Violations were identified at that plant, as well, but an order was not issued to ensure compliance at the Carthage facility.
This action resolves the findings at both Slack facilities in New York.