Grainco acquired AccessÂs farmerÂs elevator in Mazon, Illinois on March 1, 2009 when Grainco acquired Access Ag, Inc. through a merger. As part of a post-acquisition audit, Grainco discovered on March 18, 2009 that no Risk Management Plan (RMP) had ever been prepared for the Mazon facility as required by CAA §112(r). Based on meeting all the conditions of the Audit Policy and Interim Approach to New Owners, Grainco qualifies for a waiver of 100% of the gravity-based penalty (GBP). Economic benefit (BEN) for violations is not significant, and collection of BEN is waived in this matter pursuant to the Audit Policy and the Interim Approach to New Owners.