A food distribution warehouse in Michigan was cited by EPA for RMP defeciencies. On September 13, 2010, the facility submitted an RMP for the refrigeration process, which indicated the process is subject to the Program 3 eligibility requirements. On March 23, 2011, an authorized representative of U.S. EPA conducted a compliance inspection at the facility to determine compliance with the Risk Management Program regulations. The following is a breakdown of the citations:
Management System
- failed to document the Contractor’s responsibility for implementing individual requirements of the risk management program and define the lines of authority through an organization chart or similar document, in violation of 40 C.F.R. 68.15(c).
Process Safety Information
- failed to document information pertaining to the technology of the process that included safe upper and lower limits for such items as temperatures, pressures, flows or compositions, in violation of 40 C.F.R. 68.36(c)(1)(v).
- failed to document that equipment in the process complies with recognized and generally accepted good engineering practices, in violation of 40 C.F.R. 68.65(a) and 68.65(d)(2).
Process Hazards Analysis
- failed to perform a Process Hazard Analysis that addressed all the requirements under 40 C.F.R. § 68.67(c), in violation of 40 C.F.R. § 68.67(a).
- failed to establish a system to promptly address the process hazard analysis team’s findings and recommendations; assure that the recommendations are resolved in a timely manner and the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; and communicate the actions to operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations or actions, in violation of 40 C.F.R. 68.67(e).
Operating Procedures
- failed to implement written operating procedures that provide instructions or steps for conducting activities associated with the ammonia process consistent with the safety information, in violation of 40 C.F.R. 68.69(a).
- failed to ensure that procedures address initial start-up which includes loading and unloading of ammonia into the process, in violation of 40 C.F.R. 68.69(a)(l)(i).
Training
- failed to provide refresher training at least every three years to each employee involved in operating the anhydrous ammonia process to assure that each employee understands and adheres to the current operating procedures of the process, in violation of 40 68.71(b).
- failed to ascertain that each employee involved with the ammonia covered process had received and understood the initial and refresher training and to create a record with the identity of the employee, the date of training, and the means used to verify that the employee understood the training, in violation of 40 C.F.R. 68.71(c).
Mechanical Integrity
- failed to have and implement written procedures to maintain the on- going integrity of the process equipment, in violation of 40 C.F.R. 68.73(b).
- failed to ensure that the frequency of inspections and tests of process equipment is consistent with applicable manufacturers’ recommendations, good engineering practices, and prior operating experience, in violation of 40 C.F.R. 68.73(d)(3).
- failed to document each inspection and test performed on covered process equipment accordingly, in violation of 40 C.F.R. 68.73(d)(4).
- failed to perform appropriate checks and inspections to assure that equipment was installed properly and consistent with design specifications and manufacturer’s instructions, in violation of 40 C.F.R. 68.73(f)(2).
Management of Change
- failed to implement written procedures to manage changes to process chemicals, technology, equipment, and procedures, and change to stationary sources that affect a covered process, in violation of 40 C.F.R. 68.75(a).
Pre-Start Up Safety Review
- failed to perform a pre-startup safety review prior to significantly modifying an existing source, in violation of 40 C.F.R. 68.77(a).
Compliance Audits
- failed to certify that the stationary source has evaluated compliance with the provisions of the prevention program at least every three years to verify that the developed procedures and practices are adequate and being followed, in violation of 40 C.F.R. 68.79(a).
- failed to document an appropriate response to each of the findings of the compliance audits and document that deficiencies were corrected, in violation of 40 C.F.R. 68.79(d).
Incident Investigation
- failed to include in every investigation report, the date the investigation began, in violation of 40 C.F.R. § 68.81(d)(2).
- failed to establish a system to address and resolve the incident investigation report findings and recommendations, and document resolution and corrective actions, in violation of 40 C.F.R. 68.81(e).
- failed to review incident investigation reports with all affected personnel whose job tasks are relevant to the incident findings including contract employee where applicable, in violation of 40 C.F.R. § 68.81(f).
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