Following its September 19th-20th, 2024 inspection, EPA alleges Respondent’s failure to:
- Develop a management system to oversee the implementation of the risk management plan elements, in accordance with Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.15(a). (Area of Concern 1 from the US EPA Inspection Report)
- Assign a qualified person or position that has the overall responsibility for the development, implementation, and integration of the risk management program elements, in accordance with Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.15(b). (Area of Concern 1 from the US EPA Inspection Report)
- Maintain documentation of the maximum intended inventory calculations for Isobutane present in Steamboat 2/3, in accordance with in accordance with Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.65(c)(1)(iii). (Area of Concern 2 from the US EPA Inspection Report)
- Maintain documentation of the safe upper limits for specific process segments for Galena 1, Galena 3, and Steamboat 2/3 equipment, in accordance with Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.65(c)(1)(iv). (Area of Concern 3 from the US EPA Inspection Report)
- Maintain accurate piping and instrumentation diagrams for the Galena 2 and Steamboat 2/3, in accordance with Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.65(d)(1)(ii). (Area of Concern 4 from the US EPA Inspection Report)
- Document relief system design and design basis for pressure safety valves (PSVs) at Galena 1, in accordance with Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.65(d)(1)(iv). (Area of Concern 5 from the US EPA Inspection Report)
- Maintain consistent relief valve sizing documentation for PSVs across all process safety information documentation, in accordance with Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.65(d)(1)(iv). (Area of Concern 6 from the US EPA Inspection Report)
- Label motive fluid piping at Galena 2 indicating its contents and direction of flow, in accordance with Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.65(d)(2). (Area of Concern 7 from the US EPA Inspection Report)
- Install adequate bump protection for the n-pentane piping associated with storage tank V-6502 at Galena 2, in accordance with Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.65(d)(2). (Area of Concern 8 from the US EPA Inspection Report)
- Maintain emergency operation standard operating procedures in the control room of Galena 3, in accordance with Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.69(b). (Area of Concern 9 from the US EPA Inspection Report)
- Perform weekly fire pump inspections at Steamboat 2/3 and Galena 2, in accordance with Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.73(d)(3). (Area of Concern 12 from the US EPA Inspection Report)
- Perform the 2023 compliance audit within three years of the completion date of the most recent compliance audit (54 days late), in accordance with Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.79(a). (Area of Concern 16 from the US EPA Inspection Report)
- Submit a correction to their September 29th 2020 RMP Submission within one month of a change in the emergency contact information, in accordance with Section 112(r)(7) of the Clean Air Act and 40 C.F.R. § 68.195(b). (Area of Concern 18 from the US EPA Inspection Report)
SETTLEMENT
The parties enter into this ESA in order to settle the violations described above for the total penalty amount of $12,300.
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