The Region alleges that Online Packaging 1) failed to assess a worst case release scenario from additional railcars stored on site; 2) failed to follow Recognized and Generally Accepted Good Engineering Practices (RAGAGEP); 3) failed to properly compile all necessary information regarding process safety information 4) failed to address all of the required hazard categories in the process hazard analysis conducted by Online Packaging; 5) failed to develop a procedure for unloading chlorine railcars; 6) failed to certify that operating procedures were up to date on an annual basis; 7) failed to maintain and document refresher training for all operators; 8) failed to ensure mechanical integrity inspections were conducted according to RAGAGEP; 9) failed to follow all the necessary procedures required by management of change provisions; 10) failed to ensure that compliance audit findings were resolved in a timely manner; and 11) failed to communicate all necessary findings to employees.
This ACO requires Online Packaging to update the process safety information, offsite consequence analyses, operating procedures, and mechanical integrity elements of its risk management plan. The ACO also requires an engineering study to be performed on the facility?s ventilation system design, design an emergency ventilation system, update both ventilation systems to meet current design standards. A new process hazard analysis shall also be conducted. Lastly, coordination with the local emergen