8/28/2023 - CONSENT AGREEMENT AND FINAL ORDER ISSUED ASSESSING A PENALTY OF $62,547. PENALTY DUE WITHIN 30 DAYS.
ALLEGED VIOLATIONS:
BASED ON THE ABOVE-REFERENCED FINDINGS OF FACTS, THE EPA ALLEGES THAT THE RESPONDENT VIOLATED THE GENERAL DUTY CLAUSE UNDER SECTION 112(R)(1) OF THE ACT, 42 U.S.C. ? 7412(R)(1), BY:
A. FAILING TO IDENTIFY HAZARDS ASSOCIATED WITH THE ISOLATION VALVES, USING APPROPRIATE HAZARD ASSESSMENT TECHNIQUES; AND,
B. FAILING TO DESIGN AND MAINTAIN A SAFE FACILITY TAKING SUCH STEPS AS ARE NECESSARY TO PREVENT RELEASES BY NOT DEVELOPING WRITTEN PROCEDURES FOR THE ISOLATION VALVE TO ENSURE COMPLETE CLOSURE OF THE VALVE; RELYING ON A VALVE CLOSED/OPEN INDICATOR THAT WAS DIRTY AND MISALIGNED TO DETERMINE CLOSURE OF THE VALVE; AND NOT HAVING SAFEGUARDS IN PLACE SUCH AS SOFTWARE, HARDWARE AND PHYSICAL MEASURES TO PREVENT WASH WATER FROM INTRUDING INTO THE HOT PROCESS TRAIN.