Based on an RMProgram compliance monitoring investigation initiated on April 10, 2012, the EPA alleges that the Respondent violated the codified rules governing the CAA Chemical Accident Prevention Provisions, because Respondent did not adequately implement provisions of 40 CFR Part 68 when it:
- Failed to perform the 2009 process hazard analysis revalidation by a team with expertise in engineering and process operations as required by 40 CFR § 68.67(f);
- Failed to retain documented resolutions of the 2009 process hazard analysis revalidation as required by 40 CFR § 68.67(g);
- Failed to certify annually that operating procedures are current and accurate as required by 40 CFR § 68.69(c);
- Failed to implement safe work practices to provide for the control of hazards during ammonia line opening operations as required by 40 CFR § 68.69(d).
Respondent certifies that as of the date of execution of this CAFO, to the best of the Respondent’s knowledge after a good faith inquiry, it is compliant with the applicable requirements of Section 112(r) of the CAA. Respondent agrees to pay a civil penalty of $20,973.
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