On April l8, 2012, an authorized representative of the EPA conducted a compliance inspection of Respondent’s facility in Holyoke, Colorado, to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. part 68 under section 112(r)(7) of the Act. The EPA found that the Respondent had violated regulations implementing section 112(r)(7) of the Act by failing to comply with the specific requirements outlined in the attached RMP Program Level 2 Process Checklist-Alleged Violations and issued citations in the total penalty amount of $5,400. The Program Level 2 Checklist states the following:
68.54(a) HAP did not ensure that employees involved with ammonia operations were trained or tested competent in ammonia operating
procedures. General ammonia safety training was provided to employees and documented but no training documentation was
available relating to the operating procedures provided in ยง 68.52 that pertain to their duties. HAP employees operating a process on
or before June 21, 1999, did not have certification that they were qualified to safely perform operating procedures. ($1,500)
68.54(b) Refresher training was not provided at least every three years to ensure employees understand and adhere to the current operating procedures of the process. ($1,500)
68.56(a) HAP has failed to prepare procedures to maintain the on-going mechanical integrity of process equipment. No procedures were available that identify the type and frequency of inspection and/or maintenance necessary to maintain the on-going integrity of process equipment. ($1,200)
- A pressure-relief valve protecting a vapor line on the ” north riser stand” bad a manufacturers’ replacement date of July 1, 2008. The valve was 45+ months expired at the time of EPA’s inspection.
- Load out station hoses were not replaced per manufacturer’s recommendations.
- Several hoses had replacement dates stamped on the hoses of 2010 and 2011.
68.56(b) – Employees were not trained on ammonia pump change-out procedures. ($1,200)
CLICK HERE (pdf) for the 12/19/12 Final Order.