This enforcement action was filed in response to violations of CAA 112(r)(7) which were discovered during a Risk Management Plan (RMP) inspection conducted on 7/25/2007. Violations included: failure to maintain documentation, failure to meet the requirements for process hazard analysis, failure to develop and implement written operating procedures, failure to obtain and maintain contractors' safety information and failure to include an emergency action plan.
In addition to a penalty of $28,350, Tanner Industries must complete required (non-SEP) work at each of the following Tanner facilities: Inkster MI, Lincoln AL, Belvidere IL, Council Bluffs IA, Neosho MO, Morgantown WV, Mount Hope WV and Fayetteville NC. The required work consists of the installation, operation and maintenance of ammonia leak detection systems that provide continuous leak detection monitoring of the ammonia transfer and storage areas located in the above mentioned facilities. Tanner shall also coordinate with the appropriate local authorities, LEPC and/or fire departments to ensure that they are familiar with the warning and alarm systems installed and are cognizant of the appropriate protective actions which should be taken if any of the alarms are triggered by an ammonia leak.