Chase violated Section 112(r) of the CAA and Part 68 by failing to adequately perform process hazard analyses (PHAs), validate the PHA every five years, implement operating procedures that provide clear instructions, and implement an operating procedure for startup following an emergency shutdown. There is a concurrent Consent Agreement and Final Order associated with this ACO.
This ACO requires Chase to revise and implement its PHA procedure, perform an annual review of operating procedures and piping and instrumentation diagrams, train employees, and review its contractors annually, and addresses the violations set forth in the FOV issued to Chase on December 17, 2021.
There are Environmental Justice concerns associated with this action.