Based on an RMProgram compliance monitoring investigation initiated on July 25, 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 document that equipment (ammonia alarms) complies with recognized and generally accepted good engineering practices as required by 40 CFR § 68.65(d)(2);
- Failed to establish a system to promptly address the team’s process hazard analysis findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; and document what actions are to be completed as required by 40 CFR § 68.67(e);
- Failed to update and revalidate the process hazard analysis at least every five years after the completion of the initial process hazard analysis as required by 40 CFR § 68.67(f);
- Failed to certify annually that operating procedures are current and accurate as required by 40 CFR § 68.69(c);
- Failed to provide refresher training at least every three years to each employee involved in operating the process as required by 40 CFR § 68.71(b);
- Failed to submit a corrected RMP within one month of any change in the emergency contact information as required by 40 CFR § 68.195(b).
Respondent agrees to pay a civil penalty of FORTY THREE THOUSAND FIVE HUNDRED DOLLARS ($43 ,500), to be pa.id within thirty (30) days of the effective date of this CAFO.
Here is the official notice http://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/461558CC23E3AF9985257CA8001BD2DE/$File/scan0659.pdf