| Cause of Order |
Not having a Risk Management Program in place no later than the date the new engine room construction was completed in 2012, when above the threshold quantity of ammonia was first present in a process; not maintaining all required information pertaining to the worst-case and alternative release scenarios; not having documented a compilation of process safety information related to the regulated substance, process, and equipment ; failing to conduct an initial process hazard analysis on the covered process; not having developed written operating procedures to provide clear instructions or steps for safely conducting activities associated in the covered process; not having documentation that operators presently involved in operating the process, and before being involved in operating a newly assigned process, have received and understood operating procedure training ; not having prepared and implemented procedures to maintain the ongoing mechanical integrity of process equipment; not establishing and implementing written procedures to manage changes to process chemicals, technology, equipment and procedures, and changes to stationary sources that affect a covered process; not performing a pre-startup safety review for new stationary sources or modified stationary sources when the modification is significant enough to require a change in the process safety information; not conducting a compliance audit at least every 3 years; not investigating each incident that resulted in, or could reasonably result in, a catastrophic release; not having a written plan of action regarding the implementation of the employee participation requirements; not having a contractor selection program in place to obtain and evaluate information regarding the contract owner or operator's safety performance and programs; not having submitted a RMP to US EPA by the date on which Ammonia (anhydrous) was first present above a threshold quantity in a process |
EPD Enforcement Orders