Respondent owns a wastewater treatment plant. Chlorine, propane, and sulfur dioxide (anhydrous) are each a ” regulated substance”, as set forth in 40 C.F.R. § 68.130. The Respondent has a wastewater chlorination process at the stationary source. The Respondent’s facility has propane in excess of the 10,000-pound threshold, however, such propane is not used in the wastewater chlorination process. Therefore, the Respondent’s facility is not subject to the ” Program 3″ requirements of the RMP regulations for the regulated substance of propane. The facility must still comply with the Program 3 Prevention Program of 40 C.F.R. Part 68, Subpart D for the Chlorine and sulfur dioxide (anhydrous). On or about June 13, 2019, a representative of EPA conducted an inspection of the Respondents’ facility.
VIOLATIONS
Count One – Failure to Compile Process Safety Information
On or about June 13, 2019, EPA Inspection, the Respondent failed to compile complete information regarding safety systems for the wastewater chlorination process.
Therefore, the Respondent violated 40 C.F.R. § 68.65(a) & (d) by failing to compile the required process safety information.
Count Two – Failure to Maintain Process Hazard Analyses
As of the date of June 13, 2019, EPA Inspection, the Respondent failed to maintain the initial process hazard analysis for the life of the process.
Therefore, the Respondent violated 40 C.F.R. § 68.67(g) by failing to maintain the initial process hazard analysis for the life of the process.
Count Three – Training Violations
The Respondent failed to provide training documentation for certain employees involved in the operation of the wastewater chlorination process.
Therefore, the Respondent violated 40 C.F.R. § 68.71 by failing the train certain employees, or alternatively provide training documentation for certain employees involved in the operation of the wastewater chlorination process.
TERMS OF SETTLEMENT
The Respondent has agreed to pay a civil penalty of THIRTY-NINE THOUSAND, SEVEN HUNDRED SEVENTEEN DOLLARS ($39,717).
CLICK HERE for the CAFO