6/29/2017 - CONSENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $66,500. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS.
ORDER ALLEGES:
BASED ON EPA'S COMPLIANCE MONITORING INVESTIGATION, THE EPA ALLEGS THAT THE RESPONDENT VIOLATED THE CODIFIED RULES GOVERNING THE ACT'S CHEMICAL ACT PROVENTION PROVISIONS.WHEN IT:
A) FAILED TO ASSIGN A QUALIFIED PERSON OR POSITION THAT HAS THE OVERALL RESPONSIBILITY FOR THE DEVELOPMENT, IMPLEMENTATION, AND INTEGRATION OF THE RISK MANAGEMENT PROGRAM ELEMENTS AS REQUIRED BY 40 CFR SECTION 68.15(b);
B) FAILED TO DOCUMENT DESIGN CODES AND STANDARDS EMPLOYED AS REQUIRED BY 40 CFR SECTION 68.65(d)(1)(vi);
C) FAILED TO DOCUMENT SAFETY SYSTEMS AS REQUIRED BY 40 CFR SECTION 68.65(d)(1)(viii);
D) FAILED TO DOCUMENT THAT PIPING COMPLIES WITH RECOGNIZED AND GENERALLY ACCEPTED GOOD ENGINEERING PRACTICES AS REQUIRED BY 40 CFR SECTION 68.65(d)(2);
E) FAILED TO PERFORM AN INITIAL PROCESS HAZARD ANALYSIS AS REQUIRED BY 40 CFR SECTION 68.67(a);
F) FAILURE TO CERTIFY ANNUALLY THAT OPERATING PROCEDURES ARE CURRENT AND ACCURATE AS REQUIRED BY 40 CFR SECTION 68.69(c);
G) FAILED TO PROVIDE REFRESHER TRAING AT LEAST EVERY THREE YEARS TO EACH EMPLOYEE INVOLVED IN OPERATING PROCESS AS REQUIRED BY 40 CFR SECTON 68.71(b);
H) FAILED TO CERTIFY EVALUATION OF COMPLIANCE WITH THE RISK MANAGEMENT PROGRAM PROVISIONS AT LEAST EVERY THREE YEARS AS REQUIRED BY 40 CFR SECTION 68.79(a); AND
I) FAILED TO DEVELOP A WRITTEN PLAN OF ACTION REGARD