I recommend that you approve the attached Administrative Consent Order (ACO) for Tate & Lyle Sagamore Lafayette, Indiana to address violations regarding the Chemical Accident Prevention Provisions (CAPP), codified at 40 C.F.R. Part 68, as well as Section 112(r)(7)(E) of the Clean Air Act, 42 U.S.C. ? 7412(r)(7)(E).
Specifically, the Tate & Lyle failed to comply with regulatory requirements related to their Risk Management Plan, Process Safety Information, Process Hazard Analysis, Management of Change Procedures, Incident Investigation, Contractors, and Emergency Response Program as required by the CAPP under 40 C.F.R. Part 68. We discovered these violations during an on-site inspection of the facility on October 25, 2023. Tate & Lyle has taken some actions to correct the deficiencies identified during th inspection. A concurrent Administrative Consent Order will be issued to order Tate & Lyle to correct the remaining deficiencies that were identified.
This ACO requires Tate & Lyle to address all recommendations from the 2017 ABS Consulting relief system, compiling and maintaining the associated design information. Tate & Lyle must also compile and maintain the ventilation system design information for the process, ensuring that the facility's relief system, sulfur dioxide ventilation system, and piping labeling comply with RAGAGEP. Additionally, all open recommendations from the 2018 Process Hazard Analysis (PHA) need to be resolved. The ACO emphasizes enhancing Managem