2/5/19 - EXPEDITED SETTLEMENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $3,120, DUE WITHIN 15 DAYS.
ALLEGED VIOLATIONS:
BASED ON A COMPLIANCE MONITORING INSPECTION CONDUCTED AT RESPONDENT'S FACILITY LOCATED AT 6917 KNOXVILLE HWY, OLIVER SPRINGS, TN, ON MAY 31, 2018, EPA ALLEGES THAT THE RESPONDENT VIOLATED THE CAA'S CHEMICAL ACCIDENT PREVENTION PROGRAM, WHEN AT THE TIME OF THE INSPECTION, RESPONDENT DID NOT PROVIDE EVIDENCE THAT:
- IT ESTABLISHED A SYSTEM TO PROMPTLY ADDRESS THE TEAM'S FINDINGS AND RECOMMENDATIONS FOR THE PROCESS HAZARD ANALYSIS; ASSURED THAT THE RECOMMENDATIONS WERE RESOLVED IN A TIMELY MANNER AND THAT THE RESOLUTION IS DOCUMENTED; DOCUMENTED WHAT ACTIONS ARE TO BE TAKEN; COMPLETED ACTIONS AS SOON AS POSSIBLE; DEVELOPED A WRITTEN SCHEDULE OF WHEN THESE ACTIONS ARE TO BE COMPLETED; COMMUNICATED THE ACTIONS TO OPERATING, MAINTENANCE AND OTHER EMPLOYEES WHOSE WORK ASSIGNMENTS ARE IN THE PROCESS AND WHO MAY BE AFFECTED BY THE RECOMMENDATIONS OR ACTIONS AS REQUIRED BY 40 CFR 68.67(c);
- IT REVIEWED THE OPERATING PROCEDURES AS OFTEN AS NECESSARY TO ASSURE THAT THEY REFLECT CURRENT OPERATING PRACTICE, AND CERTIFIED ANNUALLY THAT THE OPERATING PROCEDURES ARE CURRENT AND ACCURATE AS REQUIRED BY 40 CFR 68.69(c);
- IT EVALUATED COMPLIANCE WITH THE PROVISIONS SUBPART D, PROGRAM 3 PREVENTION PROGRAM AT LEAST EVERY 3 YEARS AS REQUIRED BY 40 CFR 68.79(a).