3/7/17 - CONSENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $40,250. RSPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS.
ORDER ALLEGES:
BASED ON EPA'S COMPLIANCE MONITORING INVESTIGATION, THE EPA ALLEGES THAT THE RESPONDENT VIOLATED THE CODIFIED RULES GOVERNING THE ACT'S CHEMICAL ACCIDENT PREVENTION PROVISIONS, BECAUSE RESPONDENT DID NOT ADEQUATELY IMPLEMENT PROVISIONS OF 40 CFR PART 68 WHEN IT:
FAILED TO INCLUDE INFORMATION PERTAINING TO SAFETY SYSTEMS IN THE PROCESS SAFETY INFORMATION AS REQUIRED BY 40 CFR SECTION 68.65(d)(1)(viii);
FAILED TO DOCUMENT THAT EQUIPMENT COMPLIES WITH RECOGNIZED AND GENERALLY ACCEPTED GOOD ENGINEERING PRACTICES AS REQUIRED BY 40 CFR SECTIN 68.65(d)(2);
FAILED TO ESTABLISH A SYSTEM TO PROMPTLY ADDRESS THE TEAM'S FINDINGS AND RECOMMENDATIONS; ASSURE THAT THE RECOMMENDATIONS ARE RESOLVED IN A TIMELY MANNER AND DOCUMENTED; DOCUMENT WHAT ACTIONS ARE TO BE TAKEN; COMPLETE ACTIONS AS SOON AS POSSIBLE; DEVELOP A WRITTEN SCHEDULED OF WHEN THESE ACTIONS ARE TO BE COMPLETED AS REQUIRED BY 40 CFR SECTION 68.67(e);
FAILED TO ESTABLISH AND IMPLEMENT WRITTEN PROCEDURES TO MAINTAIN THE ON-GOING INTEGRITY OF PROCESS EQUIPMENT AS REQUIRED BY 40 CFR SECTION 68.73(b);
FAILED TO PERFORM INSPECTION AND TESTS ON PROCESS EQUIPMENTAS REQUIRED BY 40 CFR SECTION 68.73(d)(1); AND
FAILED TO SUBMIT THE FIRST RMP NO LATER THAN THE DATE ON WHICH A REGULATED SUBSTANCE IS FIRST PRESENT ABOVE A THRESHOLD QUANTITY AS REQUIRED BY 40 CFR SECTON 68.150(b)(3).