Respondent is a plastics material and resin manufacturing plant that produces polyvinyl alcohol from the vinyl acetate process. EPA conducted an inspection of the Facility on May 15 through 17, 20 I8, to determine Respondent’s compliance with 40 C.F.R. Part 68 (the Inspection).
Count 1 – Hazard Assessment Documentation
Respondent failed to maintain documentation for the worst-case scenario. This was not correctly documented to illustrate the rationale and accuracy of the scenario. The document was unclear as to which vessel containing vinyl acetate was worst-case.
Respondent’s failure to maintain documentation for the worst-case scenario is a violation of 40 C.F.R. § 68.39(a).
Count 2 – Mechanical Integrity
Respondent failed to perform inspection and tests on process equipment on eighteen (18) piping circuits and eighty (80) vessels including fifteen (15) tanks. Inspections and tests on process equipment were not at a frequency consistent with applicable recognized and generally accepted good engineering practices.
Moreover, the uncompleted inspections and past due inspections were beyond frequency timelines set by Respondent’s mechanical integrity written procedures.
Respondent’s failure to implement its written procedures to maintain the ongoing integrity of process equipment pursuant to 40 C.F.R. § 68.73(b), failure to perform inspections and tests on process equipment, and failure to perform inspections and tests on process equipment at a frequency consistent with applicable good engineering practices pursuant to 40 C.F.R. §§ 68.73(d)(2)-(3), as required by 40 C.F.R. § 68.12(d)(3).
Respondent agrees that, in settlement of the claims alleged herein, Respondent shall pay a civil penalty of forty-two thousand dollars ($42,000)as set forth below.
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