EPA v. INTERNATIONAL SEAFOODS OF ALASKA PLANT #2

Case summary

Two EPA representatives inspected International Seafoods of Alaska, Plant #2 on September 15, 2004. Based upon this inspection, EPA believes ISA Plant #2 is in violation of the following risk management program elements: Management, Hazard Assessment, Process Safety Information, Process Hazard Analysis, Operating Procedures, Training, Management of Change, Pre-startup Review, Incident Investigation, and Emergency Response. - Specifically, at the time of inspection, ISA Plant #2 did not have a management system in place to oversee the implementation of the Risk Management Program (�68.15(a)). - ISA Plant #2 had not determined the worst-case release quantity correctly (�68.25(b)), they did not have Hazard Assessment documentation that included an offsite consequence analysis with an estimated population based on a circle with the point of release at the center ((�68.30(a-d)), they had not identified environmental receptors within this same circle (�68.33(a)), they did not have sufficient documentation for EPA to determine the rationale for selection of the worst-case scenario (�68.39(a)), and did not have sufficient documentation for describing the assumptions used for the alternative release scenario (�68.39(b)). - ISA Plant #2 did not have any documentation that indicated that existing equipment, designed and constructed in accordance with codes, standards or practices that are no longer in general use, is designed, maintained, inspected, tested, and operating in a safe manner (�68.65(d)(3)). - ISA Plant #2 was unable to produce any documentation of the initial Process Hazard Analysis (�68.67(g)), the Process Hazard Analysis dated 6/17/04 does not document the priority order for conducting the PHA�s (�68.67(a)), and they have not established a system to promptly address the PHA team�s findings (68.67(e)). - ISA Plant #2 has not developed and implemented written operating procedures that meet the regulatory requirements (�68.69(a)) and they do not have operating procedures that are readily accessible to employees who are involved in a process (�68.69(b)). - ISA�s Plant #2 training records are insufficient and do not indicate employees understand the training (�68.71(c)). - ISA Plant #2 had not fully established and implemented written procedures to manage changes to the covered process (�68.75). - ISA Plant #2 did not conduct a pre-startup safety review (�68.77). - ISA Plant #2 did not have an adequate incident investigation system in place to document incidents and resolve the recommended findings (�68.81(e)). ISA�s Plant #2 emergency response plan does not contain procedures for informing the public of a release and does not contain procedures for notifying the NRC in the event of a release (�68.95(a)(1)(i)), they did not have the necessary training for employees responsible for emergency response (�68.95(a)(3)) nor are there procedures in place to update the emergency response plan (�68.95(a)(4)).

Defendants (1)

• Tateo SatoNamed in complaintNamed in settlement

Facilities (1)

• I S A PLANT #2

  517 SHELIKOF STREET, KODIAK, AK, 99615

  Registry ID: 110010780976

Statutes cited

• CAA 112[R][7] — Prevention of Accidental Release/Risk Management Plans (RMPs)

Enforcement conclusions (1)

• INTERNATIONAL SEAFOODS OF ALASKA PLANT #2entered 2005-06-28

  Primary law: CAA

  Federal penalty: $7,380

Timeline (5 milestones)

• 2005-03-21Enforcement Action Data Entered
• 2005-06-28Complaint Filed/Proposed Order
• 2005-06-28Final Order Issued
• 2005-06-28Expedited Settlement Offered
• 2005-10-20Enforcement Action Closed