4/25/19 - EXPEDITED SETTLEMENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $4,500.
ALLEGATIONS:
BASED ON A COMPLIANCE MONITORING INSPECTION CONDUCTED AT RESPONDENT'S FACILITY ON DEC 13, 2018, EPA ALLEGES THAT THE RESPONDENT VIOLATED THE CAA'S CHEMICAL ACCIDENT PREVENTION PROVISIONS, WHEN AT THE TIME OF INSPECTION, RESPONDENT DID NOT PROVIDE EVIDENCE THAT:
- IT MAINTAINED RECORDS ON THE WORST-CASE SCENARIO PORTION OF THE OFFSITE CONSEQUENT ANALYSES, INCLUDING ASSUMPTIONS AND PARAMETERS USED, AND THE RATIONALE FOR THE SELECTION OF THE SPECIFIC WORST-CASE SCENARIO, AS REQUIRED BY 40 CFR 68.39(a).
- IT MAINTAINED RECORDS ON THE ALTERNATIVE RELEASE SCENARIO PORTION OF THE OFFSITE CONSEQUENCE ANALYSES, INCLUDING ASSUMPTIONS AND PARAMETERS USED, AND THE RATIONALE FOR THE SELECTION OF THE SPECIFIC ALTERNATIVE RELEASE SCENARIO, AS REQUIRED BY 40 CFR 68.39(b).
- IT DEMONSTRATED THAT EQUIPMENT COMPLIES WITH RECOGNIZED AND GENERALLY ACCEPTED GOOD ENGINEERING PRACTICES, AS REQUIRED BY 40 CFR 68.65(d)(2), WHEN AMMONIA PIPING AND VALVES LOCATED ON THE ROOF DID NOT HAVE LABELS AND TAGS INDICATING THE CONTENTS OR DIRECTION OF FLOW.
- IT DEMONSTRATED FOR EXISTING EQUIPMENT DESIGNED AND CONSTRUCTED IN ACCORDANCE WITH CODES, STNADARDS, OR PRACTICES THAT ARE NO LONGER IN GENERAL USE, THAT THE OWNER OR OPERATOR DETERMINED AND DOCUMENTED THAT THE EQUIPMENT IS DESIGNED, MAINTAINED, INSPECTED, TESTED, AND OPERATING IN A SAFE MANNER, AS REQUIRED BY 40 CFR 68.65(d)(3), WHEN DURING THE