On December 5, 2010, EPA conducted an inspection (EPA inspection) of the Facility to determine compliance with CAA § ll2(r)(7). During the inspection, EPA observed alleged violations of the CAA § 112(r)(7). The alleged violations are described below…
- Process safety information for thirteen process vessels did not include materials of construction. Respondent identified these process vessels as: V-2, V -4, V -6, V -8, V-9, V-10, V-11, V-12, V-13, V-14, V-15, V-16 and V -18. This is a violation of 68.65(d)(1)(i).
- Process safety information did not include design codes and standards employed for thirteen process vessels. These process vessels are listed above. This is a violation of 68.65(d)(1)(vi).
- Respondent did not document that thirteen process vessels, listed above, comply with RAGAGEP. This is a violation of 68.65(d)(2).
- Respondent did not determine and document that thirteen process vessels, listed above, were designed in a safe manner. This is a violation of 68.65(d)(3).
- Deficiencies identified during a 2007 independent inspection were not corrected in a safe and timely manner. For example, V-2, a high-pressure receiver, had eight identified deficiencies that had not been corrected at the time of EPA’s inspection. Four of the eight deficiencies had a risk ranking of the highest priority. The deficiencies included: 1) The tubular sight glass is located at the end of the vessel near a door opening. This is a potential catastrophic release point. and 2) There is no over pressurization for the V -2 pressure receiver. Failure to correct the deficiencies is a violation of 68.73(e).
- The PSM/RMP Compliance Audit Recommendation Tracking Log did not document that audit questions 6.26 and 18.3 had been corrected. The audit questions pertain to the documentation of equipment design codes and process safety information, respectively. This is a violation of 68.79(d).
Respondent consents and agrees to pay a civil penalty in the amount of sixty-one thousand five hundred dollars ($61,500).
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