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 CAFO requires Online Packaging to pay a penalty of $88,383 and resolves the FOV issued to Online Packaging on March 31, 2022. An Administrative Consent Order is being issued concurrently with this CAFO.