8/19/2020- EXPEDITED SETTLEMENT AGREEMENT ISSUED ASSESSING A PENALTY OF $3,300. PENALTY DUE WITHIN 15 DAYS.
ALLEGED VIOLATIONS:
BASED ON A COMPLIANCE MONITORING INSPECTION CONDUCTED AT THE RESPONDENT?S FACILITY LOCATED AT 4801 NORTHPARK DRIVE, OPELIKA, ALABAMA ON MARCH 26, 2019, THE EPA ALLEGES THAT THE RESPONDENT VIOLATED THE ACT?S CHEMICAL ACCIDENT PREVENTION PROVISIONS, WHEN AT THE TIME OF INSPECTION, RESPONDENT DID NOT PROVIDE EVIDENCE THAT:
IT DOCUMENTED THAT EQUIPMENT COMPLIES WITH RECOGNIZED AND GENERALLY ACCEPTED GOOD ENGINEERING PRACTICES AS REQUIRED BY 40 C.F.R. ? 68.65(D)(2) WHEN THE KING VALVE ON THE HIGH-PRESSURE RECEIVER WAS NOT LABELED; THE DOORS TO THE CONTROL ROOM AND THE MAINTENANCE ROOM FROM THE MACHINERY ROOM WERE NOT TIGHT FITTING; ONLY ONE EXIT DOOR IN THE MACHINERY ROOM WAS EQUIPPED WITH PANIC TYPE HARDWARE; CARDBOARD, WOOD PALLETS, AND OTHER COMBUSTIBLE MATERIALS WERE FOUND IN THE MACHINERY ROOM;
IT ADDRESSED A QUALITATIVE EVALUATION OF A RANGE OF THE POSSIBLE SAFETY AND HEALTH EFFECTS OF FAILURE CONTROLS IN THE PROCESS HAZARD ANALYSIS (PHA) AS REQUIRED BY 40 C.F.R. ? 68.67(C)(7) WHEN ITEM 5.16 OF THE PHA IDENTIFIED LIQUID HAMMER OR SLUGGING IN AMMONIA COIL RESULTING IN ?THREAT OF DEATH.? THIS ITEM WAS ASSIGNED A RISK-RANKING OF ?1.? PER PHA POLICY, LEVEL 1 IS RESTRICTED TO LOCAL VICINITY WITH POTENTIAL INJURIES REQUIRING NO MORE THAN FIRST AID. IN ADDITION, ITEM 18.6 OF THE PHA IDENTIFIES INADEQUATE COMMUNICATION DURING AN EMERGENCY WITH THE CO