EPA v. WESTERN ALASKA FISHERIES, INC.

Case summary

Two EPA representatives inspected Western Alaska Fisheries, Inc. in Kodiak on September 15, 2004. Based upon this inspection, EPA believes WAF is in violation of the following risk management program elements: Management, Hazard Assessment, Process Hazard Analysis, Training, Mechanical Integrity, Management of Change, Compliance audits, and Emergency Response. ☐ Specifically, at the time of inspection, WAF did not have a management system in place to oversee the implementation of the Risk Management Program (?68.15(a)) nor had they documented the persons responsible for implementing individual program requirements and defined the lines of authority through an organization chart or similar document (?68.15(c)). ☐ WAF did not have Hazard Assessment documentation that included the most recent census data to estimate the population that could be affected to define off-site impacts (?68.30(c)). ☐ WAF did not have sufficient documentation to indicate whether or not the Process Hazard Analysis findings were completed or communicated to system operating staff (?68.67(e)). ☐ WAF?s prevention program training records are insufficient and do not indicate that employees already have the knowledge necessary to carry out operating procedures (?68.71(a)(2), that three year refresher training on operating procedures have been provided (?68.71(b)), and that employees understand the training (?68.71(c)). ☐ WAF did not have any written records to document inspections or integrity tests performed on process equipment (?68.73(d)(4)). ☐ WAF did not conduct a management of change evaluation, specifically when the screw compressor HPR was upgraded from 8,000 pounds to 16,000 pounds (?68.75(a)). ☐ WAF?s compliance audit report dated 5 May 2003 was not certified by facility management (?68.79(a)) nor had they determined and documented an appropriate response to each of the findings of the audit (?68.79(d)). ☐ WAF?s emergency response program does not clearly identify the person responsible for making a notification to the emergency responder (Kodiak Fire Department) or contain information on what agencies to notify and when they should be notified if a release over 100 pounds occurs (?68.90(b)(3)).

Defendants (1)

• WESTERN ALASKA FISHERIES, INC.Named in complaintNamed in settlement

Facilities (2)

• KODIAK SEAFOOD PROCESSING FACILITY

  521 SHELIKOF AVENUE, KODIAK, AK, 99615

  Registry ID: 110000529599

• KODIAK SEAFOOD PROCESSING FACILITY

  521 SHELIKOF AVENUE, KODIAK, AK, 99615

  Registry ID: 110000529599

Statutes cited

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

Enforcement conclusions (1)

• WESTERN ALASKA FISHERIES, INC.entered 2005-06-09

  Primary law: CAA

  Federal penalty: $2,070

Timeline (5 milestones)

• 2005-04-11Enforcement Action Data Entered
• 2005-06-09Complaint Filed/Proposed Order
• 2005-06-09Expedited Settlement Offered
• 2005-06-09Final Order Issued
• 2005-08-18Enforcement Action Closed