EPA RMP citations @ refinery (HF & $ under negotiations)

On November 1, 2016 through November 4, 2016, representatives from the U.S. Environmental Protection Agency (EPA) Region IX conducted an inspection of a refinery to determine compliance with the Risk Management Program (RMP). The preliminary findings of the inspection and additional information request were sent to the refinery and several agencies on March 27, 2017. EPA’ s inspection was conducted to determine compliance with the Risk Management Program (“RMP”) promulgated under Section 112(r)(7) of the Clean Air Act (“CAA”‘), and the General Duty Clause under Section 112(r)(l) of the CAA. The inspection primarily focused on three principal elements of the RMP: 

1. the Management System used by the refinery to implement the RMP;
2. the supporting documentation for Off-site Consequence Analyses (“OCA”); and
3. the operation of the Hydrofluoric Acid (“HF”) Alkylation Unit including targeted Piping and Instrumentation Diagram (P&ID) field verifications of process and safety equipment within the unit.