We don’t see these every day and to be honest, the incidents, the violations, and the compliance plan are too much for me to break down. I have broken out the incidents and the citations that EPA issued for each of these incidents, but you will have to go to the CAFO to get the full scoop. Here are the incidents that led to this:
May 2, 2013 Fire and Explosion
September 13, 2013 Fire
February 19, 2014 Propylene Release
July 17, 2014 Cycle Gas Release
October 7, 2014 Chlorine Release
October 12, 2014 Hydrogen Chloride Release
November 2, 2014 Chlorine Release
October 5, 2016 Chlorine Release
I should make a special note that EPA has developed a “compliance plan” that far exceeds “compliance” matters. For example, EPA is requiring the facility to develop key performance indicators (“KPIs” (i.e., metrics)) to evaluate Defendant’s implementation of 40 C.F.R. Part 68. The KPIs shall evaluate the implementation of the following procedures: