A paint plant was inspected in 2010 by EPA for compliance with the RMP rule. The plant uses flammables such as Propane, Butane, Isobutene, and methyl ether in their covered process. The inspection resulted in the following citations:
- 68.65(d)(1)(iv) – no relief design basis compiled before conducting the PHA.
- 68.67(e) – no system established to promptly address PHA recommendations, document actions taken, complete actions as soon as possible, develop a written schedule as to when these actions will be completed, and communicate the actions to employees whose work assignments are in the covered process or affected by the process.
- 68.67(f) – PHA was not revalidated every five years
- 68.73(b) – no written maintenance procedures.
- 68.73(d)(3) – maintenance inspection/tests frequencies failed to meet the manufacturer’s recommendations, good engineering practices, and operating history.
- 68.73(e) – failed to correct deficiencies that were outside acceptable limits.
- 68.79(a) – not conducting an audit every three years.
- 68.79(d) – did not document an appropriate response to each audit finding and did not document the findings were addressed.