Archer-Daniels-Midland Company (?Respondent?) is the owner or operator of the facility at 1350 Waconia Avenue, SW, Cedar Rapids, Iowa 52404 (?Facility?). The EPA inspected the facility on September 19-21, 2023. The EPA alleges that Respondent violated the following requirements of Section 112(r) of the Clean Air Act, which includes the law and implementing regulations 40 CFR 68, Chemical Accident Prevention Provisions.
1. 40 CFR 68.67(f) requires that a facility review and update PHAs at least every five years. At the time of the inspection, the PHA for denaturant, natural gas pentane, was overdue by 1 year and 7 months; the PHA for anhydrous ammonia was overdue by 3 months.
2. 40 CFR 68.73(d)(3) requires that facilities ensure the frequency of inspections and tests of process equipment is consistent with applicable manufacturer?s recommendations, good engineering practices (specifically, ANSI/ CGA G-2.1-2014 Standard Sections 5.6.8 and 5.8.16), and prior operating experience.
During the inspection, facility personnel stated that they were unsure if piping had been inspected other than the day it was installed and first used to convey anhydrous ammonia. During review of records, the inspector noted that the facility did not include any information regarding testing of the underground anhydrous line from the bulk storage tank area to the point where it is injected into a stream of water to make an aqueous ammonia solution.
1.3. 40 CFR 68.93(a) requires that a facilit