The Facility violated various aspects of its Program 3 CAPP program including: process safety information, process hazard analysis, operating procedures, training, mechanical integrity, compliance audits, and incident investigation. A concurrent ACO will require MCSD to comply with the deficient aspects of its Program 3 CAPP program.
This CAFO requires MCSD to pay a penalty of $6,600 and resolves the FOV that was listed in an Expedited Settlement Agreement issued to MCSD on March 1, 2022 and that EPA and MCSD agreed to resolve through an ACO and this CAFO.