2/26/2020 - EXPEDITED SETTLEMENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $6,000 DUE WITHIN 30 DAYS.
ALLEGATIONS:
BASED ON A COMPLIANCE MONITORING INSPECTION CONDUCTED AT RESPONDENT'S FACILITY, EPA ALLEGES THAT THE RESPONDENT VIOLATED THE CAA's SECTION 112(r)(7) CHEMICAL ACCIDENT PREVENTION PROVISIONS, WHEN AT THE TIME OF THE INSPECTION, RESPONDENT DID NOT PROVIDE EVIDENCE THAT:
- IT MAINTAINED RECORDS ON THE WORST-CASE SCENARIO PORTION OF THE OFFSITE CONSEQUENCE 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 68.9(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, PRESSURE RELIEF VALVES WERE NOT REPLACED OR TESTED OR RECERTIFIED EVERY 5 YEAR FROM THE DATE OF INSTALLATION, AND CORROSION WAS OBSERVED IN NUMEROUS AREAS INCLUDING EQUIPMENT IN THE AMMONIA MACHINERY ROOM, PIPING LEADING INTO THE HIGH PRESSURE RECEIVER, PIPING ON AN OIL POT BELOW THE LOW TEMPERATURE ACCUMULATOR, ON THE OIL P