7/16/16 - CONSENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $121,800. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS.
EPA ALLEGES THAT THE RESPONDENT VIOLATED THE CODIFIED RULES OF 40 CFR PART 68, GOVERNING THE ACT'S CHEMICAL ACCIDENT PREVENTION PROVISIONS WHEN IT:
FAILED TO COMPILE THE CORRECT MAXIMUM INTENDED INVENTORY PERTAINING TO THE TECHNOLOGY OF THE PROCESS AS REQUIRED BY 40 CFR SECTION 68.65(c)(1)(iii);
FAILED TO DOCUMENT THAT THE AMMONIA PROCESS COMPLIES WITH RECOGNIZED AND GENERALLY ACCEPTED GOOD ENGINEERING PRACTICES AS REQUIRED BY 40 CFR SECTION 68.65(d)(2);
FAILED TO ESTABLISHED A SYSTEM TO PROMPTLY ADDRESS PROCESS HAZARD ANALYSIS FINDINGS AND RECOMMENDATIONS AS REQUIRED BY 40 CFR SECTION 68.67(e);
FAILED TO DEVELOP AND IMPLEMENT WRITTEN OPERATING PROCEDURES AS REQUIRED BY 40 CFR SECTION 68.69(a);
FAILED TO DOCUMENT THE MEANS USED TO VERIFY THAT EACH EMPLOYEE INVOLVED IN OPERATING THE COVERED PROCESS UNDERSTOOD THE ANNUAL AMMONIA REFRIGERATION SYSTEM TRAINING AS REQUIRED BY 40 CFR SECTION 68.71(c);
FAILED TO DOCUMENT EACH INSPECTION AND TEST THAT HAD BEEN PERFORMED ON PROCESS EQUIPMENT AS REQUIRED BY 40 CFR SECTION 68.73(d)(4);
FAILED TO CORRECT DEFICIENCIES IN EQUIPMENT THAT WERE DETERMINED TO BE OUTSIDE OF ACCEPATABLE LIMITS AS REQUIRED BY 40 CFR SECTION 68.73(e);
FAILED TO IMPLEMENT WRITTEN PROCEDURES TO MANAGE CHANGES TO PROCESS EQUIPMENT AS REQUIRED BY 40 CFR SECTION 68.75(a);
FAILED TO PERFORM A PRE-STARTUP SAFETY REVIEW AFTE