EPA cited an Ethanol plant in NE for RMP deficiencies for the total penalty amount of $3,780, with estimated cost of correcting the deficiencies at $60,000. The covered chemical was Anhydrous Ammonia. The deficiencies included:
- Safety Information 68.65(c)(1)(iv), (c)(1)(v), (d)(1)(vii) $600 The owner or operator failed to document safe upper and lower limits for temperatures, pressures, flows compositions; consequences of deviation; and material and energy balances.
- Process Hazard Analysis 68.67(e) $1,500 The owner or operator failed to document the results of the analysis and ensure that findings identified are resolved in a timely manner.
- Operating Procedures 68.69(c) $1,200 The owner or operator failed to certify annually that the operating procedures are current and accurate.
- Mechanical Integrity 68.73(b) $1,500 The owner or operator failed to establish and implement written procedures to maintain the ongoing integrity of the process equipment.
- Compliance Audits 68.79(a) $1,200 The owner or operator failed to conduct a compliance audit every three years.
- Pre Start-Up Safety Review 68.77(b)(3) $300 Owner or operator failed to conduct a pre start up safety review to document that the modified stationary source meets the requirements in the management of change.
CLICK HERE to see the agreement, which includes the actions taken by the facility and accepted by EPA for closing the citations.