8/20/2007 - EXPEDITED SETTLEMENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $1,140, DUE WITHIN 15 DAYS. EPA ALLEGES THAT THE RESPONDENT VIOLATED THE CAA'S CHEMICAL ACCIDENT PREVENTION PROGRAM WHEN RESPONDENT DID NOT PROVIDE EVIDENCE THAT IT HAD:
COMPILED (COMPLETE) PIPING AND INSTRUMENTATION DIAGRAMS AS PART OF ITS WRITTEN PROCESS SAFETY INFO AS REQUIRED BY 40 CFR 68.65(d)(1)(ii);
RETAINED ALL PROCESS HAZARD ANALYSES, INCLUDING UPDATES OR REVALIDATIONS, FOR THE LIFE OF HTE COVERED PROCESS AS REQUIRED BY 40 CFR 68.67(g);
DEVELOPED A WRITTEN SCHEDULE OF WHEN PHA ACTION ITEMS WERE TO BE COMPLETED, ASSURED THAT THE ACTION ITEMS WERE RESOLVED IN A TIMELY MANNER AND DOCUMENT SUCH RESOLUTION (DOCUMENTED ACTION ITEM CLOSURE) AS PART OF THE PHA CONDUCTED ON 8/20/2003, AS REQUIRED BY 40 CFR 68.67(e);
INSPECTED AND TESTED PROCESS EQUIPMENT IN ACCORDANCE WITH RECOGNIZED AND GENERALLY ACCEPTED GOOD ENGINEERING PRACTICES FOR INSPECTIONS AND TESTING AS REQUIRED BY 40 CFR 68.73(D)(1) AND (2);
CORRECTED DEFICIENCIES IN PROCESS EQUIPMENT THAT WERE OUTSIDE ACCEPTABLE LIMITS AS REQUIRED BY 40 CFR 68.73(e); AND
EVALUATED ITS COMPLIANCE WITH THE PREVENTION PROGRAM REQUIREMENTS AND CERTIFIED, AT LEAST EVERY 3 YRS, THAT ITS PROCEDURES AND PRACTICES ARE ADEQUATE AND ARE BEING FOLLOWED AS REQUIRED BY 40 CFR 68.79(a).