3/11/2020 - CONSENT AGREEMENT ASSESSING A PENALTY $14,929 DUE WITHIN 30 DAYS.
ALLEGED VIOLATIONS:
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 C.F.R. Part 68 when it:
a. Failed to compile written process safety information for the equipment in the process which includes piping and instrument diagrams as required by 40 C.F .R. ? 68.65( d)(l )(ii);
b. Failed to update and revalidate the process hazard analysis by a team every five years after the initial process hazard analysis to assure the process hazard analysis is consistent with the current process as required by 40 C.F.R. ? 68.67(f);
c. Failed to develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and to address operating limits as required by 40 C.F.R. ? 68.69(a);
d. Failed to implement written procedures relating to mechanical integrity as required by 40 C.F.R. ? 68. 73(b ); and
e. Failed to document each inspection and test performed on covered RMP process equipment, including: date of inspection, the name of the person performing inspection or test, serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspecti