Respondent owns and operates a chemical manufacturing facility that has a chlorine (Cl2) process at the stationary source in excess of the applicable threshold quantity. The chlorine-covered process is subject to the “Program 3” requirements of the Risk Management Plan (RMP) regulations and must, among other things, to comply with the Program 3 Prevention Program of 40 C.F.R. Part 68, Subpart D.
On or about August 13 – 15, 2018, representatives of EPA conducted an inspection of the facility and found the following:
- PHA did not consider Hurricanes and Flooding (the facility is 25 miles west of New Orleans)
- SOPs referenced a plant-wide PPE HAZARD ASSESSMENT document that was not specific to the SOP chlorine task(s)
- SOPs annual certification(s) done 2 months and 8 months past their due dates
- Piping inspections were not evaluated and accepted by the authorized API 570 inspector (my guess is these were annual inspections done in-house)