RMP citations @ WWTP

Although the agreement does NOT state the EHS involved, I am going to make a strong assumption that it is Chlorine.  This inspection netted a whopping $980 in fines.  Here are the elements allegedly violated:

68.15 Management.
(c) When responsibility for implementing individual requirements of this part is assigned to persons other than the person identified under paragraph (b) of this section, the names or positions of these people shall be documented and the lines of authority defined through an organization chart or similar document.

§ 68.50 Hazard review.
(d) The review shall be updated at least once every five years. The owner or operator shall also conduct reviews whenever a major change in the process occurs; all issues identified in the review shall be resolved before startup of the changed process.

§ 68.56 Maintenance.
(d) The owner or operator shall perform or cause to be performed inspections and tests on process equipment. Inspection and testing procedures shall follow recognized and generally accepted good engineering practices. The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers’ recommendations, industry standards or codes, good engineering practices, and prior operating experience.

§ 68.58 Compliance audits.
(a) The owner or operator shall certify that they have evaluated compliance with the provisions of this subpart at least every three years to verify that the procedures and practices developed under the rule are adequate and are being followed.

§ 68.195 Required corrections.
(b) Emergency contact information—Beginning June 21, 2004, within one month of any change in the emergency contact information required under § 68.160(b)(6), the owner or operator shall submit a correction of that information.

 

CLICK HERE (pdf) to see the agreement

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