Document om8pqMKLj6p9m4y2zvObYjdzX

Region 6 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 09/15/2020 - 09/30/2020 Air Clean Air Act Section 112(r) and 40 C.F.R. Part 68 Chemical Accident Prevention Provisions - Risk Management Program (RMP) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Koch Fertilizer Holding Company, LLC Koch Fertilizer Enid, LLC 1619 South 78th Street Enid, Oklahoma 73701 Same as above Same as above Garfield Andrew M. Meyer PSM Manager Andrew.Meyer@kochind.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000536714 2016-1295-TVR2 (M-5) RMP 1000 0002 6107 325311 Nitrogenous Fertilizer Manufacturing 2873 Nitrogenous Fertilizers Personnel participating in inspection: Tony Robledo U.S. EPA Charese Simpson U.S. EPA Mike Kleis Koch Fertilizer Enid, LLC Bo Uhrmacher Koch Fertilizer Enid, LLC Eric Dohmen Koch Fertilizer Enid, LLC John Coffey Koch Fertilizer Enid, LLC Andrew Meyer Koch Fertilizer Enid, LLC Sarah Jantzen Koch Fertilizer Enid, LLC Mike Walter Koch Fertilizer Enid, LLC Inspector/Enforcement Officer Inspector/Enforcement Officer VP Operations & Plant Manager EHS Leader Technical Capability Leader Senior PSM Leader PSM Manager EHS Administrative Specialist Environmental Engineer EPA Lead Inspector Signature/Date Digitally signed by ANTHONY ROBLEDO ANTHONY ROBLEDO DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=ANTHONY ROBLEDO, 0.9.2342.19200300.100.1.1=68001003655529 Date: 2020.11.04 16:02:57 -06'00' Tony Robledo Supervisor Signature/Date SAMUEL TATES Samuel Tates Digitally signed by SAMUEL TATES DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=SAMUEL TATES, 0.9.2342.19200300.100.1.1=68001003655433 Date: 2020.11.05 16:33:50 -06'00' 6ENFORM-020-R8.2 (02/12/2020) Section I - INTRODUCTION PURPOSE OF THE INSPECTION Koch Fertilizer Holding Company, LLC Koch Fertilizer Enid LLC Inspection Date: 09/15/2020 - 09/30/2020 On September 8, 2020, the United States Environmental Protection Agency (EPA) Region 6 sent an email to Mike Walter, the Environmental Engineer (Air), Koch Fertilizer Holding Company LLC (Koch), at the Koch Fertilizer Enid LLC Plant, located in Enid, Oklahoma, to announce the initiation of a Clean Air Act Risk Management Plan (RMP) Virtual Partial Compliance Evaluation (VPCE). The e-mail informed Koch of the VPCE process using Microsoft Teams video for an opening conference scheduled on September 15, 2020. During the video opening conference Region 6 inspectors, Tony Robledo and Charese Simpson, met with Koch personnel as identified above. I presented my credentials and informed Koch facility personnel that this was an EPA inspection to determine compliance with the federal Chemical Accident Prevention Program. The scope of the inspection was a VPCE, which included an evaluation of the facility's compliance with the Clean Air Act (CAA) Section 112(r) and the Chemical Accident Prevention Provisions in 40 C.F.R. Part 68, as well as the General Duty Clause. EPA inspectors discussed general VPCE procedural questions, confidential business information (CBI) procedures, interview schedules, proposed timelines, the exit conference, and the final report. The VPCE is a new compliance monitoring tool that EPA Region 6 is utilizing during the public health emergency generated by COVID-d inspection included reviewing and obtaining copies of documents and records, conducting interviews, and taking statements via video conference. FACILITY DESCRIPTION The Koch facility produces anhydrous ammonia, urea fertilizer, and urea-ammonium nitrate (UAN), which are loaded on truck and railcar for distribution. Anhydrous ammonia is also injected into a pipeline to be transported to distribution terminals. The manufacturing portion of the facility consists of two ammonia units, two urea production units, and a UAN unit. The ammonia unit uses natural gas, air, and water to produce ammonia. Ammonia is used along with carbon dioxide to produce solid urea fertilizer in the urea production units. Urea formaldehyde is injected into the process to produce granulated urea. UAN solution is produced by manufacturing urea in liquid form and combining it with liquid ammonium nitrate, which is made by neutralizing nitric acid and ammonia. Anhydrous ammonia and chlorine (chlorine is used as a water treatment chemical in cooling towers and a tertiary water treatment unit) are present at the Koch facility in amounts above threshold quantity. RMP-regulated flammables mixture consisting of methane and hydrogen is found in the ammonia production process in amounts greater than threshold quantity. As such, the Koch facility is classified as a Program 3 RMP facility for toxics and flammables. The Koch facility employs 282 full-time employees at this non-union plant. The plant operates 24 hours a day, seven days a week. Section II - OBSERVATIONS EPA Region 6 documented its observations on the Program Level 3 Checklist (Appendix #1). Section III - AREAS OF CONCERN Closing Meeting - A virtual closing meeting was conducted on October 7, 2020, to discuss Areas of Concern 2 Koch Fertilizer Holding Company, LLC Koch Fertilizer Enid LLC Inspection Date: 09/15/2020 - 09/30/2020 (AOC), the inspection report completion process, and next steps. AOC 1 - 40 C.F.R. 68.67(c)(3) Process Hazard Analysis (PHA) "Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases." Koch failed to have the proper alarm setting to alert the console operator of a decreased condensing capability which resulted in releasing 15.76 - 140 pounds of anhydrous ammonia in the Urea #2 C-801 unit on September 23, 2017 (Incident No. 39091). Koch noted in its Incident 39031 summary that, "An action item has been completed to raise the lo[w] alarm of the cooling water dT from 5 degF to 10 degF to alert the console operator of a decreased condensing capability." AOC 2 - 40 C.F.R. 68.67(e) PHA "The owner or operator shall establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions." Koch failed to promptly address PHA findings and recommendations for the following PHA's: 2018 PHA Ammonia Loading and Storage Unit - one action item pending; 2019 PHA UR2 Unit - one action item pending; 2020 PHA UR1 Unit - four action items pending; 2020 PHA UAN Unit - one action item pending. Koch provided its Process Hazard Analysis Procedure (PRC KAES PSM 99 001) which states on page 14, Section 5.9 that, "Risk ranking for each recommendation will be populated into LYNX within the `Priority' field and will align directly with the risk ranking of the recommendation as per the PHA report. The LYNX recommendation must remain open until the final action is completed." AOC 3 - 40 C.F.R. 68.69(a)(1)(i) Operating Procedures "The owner or operator shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements. Steps for each operating phase: Initial startup." Koch failed to properly conduct startup for the Ammonia Unit 2 by leaving a vent valve open in error which resulted in a 0.55-ton anhydrous ammonia release on August 2, 2019 (Incident No. 43756). 3 Koch Fertilizer Holding Company, LLC Koch Fertilizer Enid LLC Inspection Date: 09/15/2020 - 09/30/2020 AOC 4 - 40 C.F.R. 68.69(a)(3)(ii) Operating Procedures "Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment." Koch failed to implement a written operation procedure for precautions to prevent exposure including personal protective equipment, which caused an operator to suffer an arm burn from hot process water condensate located in an RMP covered process on July 22, 2018 (Case No. 4210). Koch noted that the specific procedure for the use of personal protective equipment is outlined in SDP OK01 03 60 001 Flush Evaporation Section, and the individual error's in the execution of this procedure. Koch failed to implement a written operation procedure for precautions to prevent exposure including personal protective equipment, which caused an operator to suffer a chest burn from hot process water condensate located in an RMP covered process on August 24, 2020 (Case No. 4444). Koch noted that the specific procedure for the use of personal protective equipment is outlined in CMP PRC KNC01 99 004 First Line Break. AOC 5 - 40 C.F.R. 68.69(c) Operating Procedures "The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to stationary sources. The owner or operator shall certify annually that these operating procedures are current and accurate." Koch failed to certify annually operating procedures for the ammonia loading and storage unit for 2016 and 2017. AOC 6 - 40 C.F.R. 68.69(d) Operating Procedures "The owner or operator shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a stationary source by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees." Koch failed to implement proper lockout/tagout procedures at the Loading and Storage 1 303-C Unit that resulted in a 90-pound release of anhydrous ammonia that caused a plant evacuation and an incident command to be initiated on October 31, 2019 (Incident No. 44458). Koch failed to implement safe work practices to provide for the control of hazards by failing to use a manual block valve during troubleshooting of PIC-155B vent which caused the release of 173 pounds of anhydrous ammonia on December 1, 2019 (Incident No. 44671). Koch provided its lockout/tagout procedure NOP OK01 99 01 001 Energy Control and Commissioning and noted individual errors in the execution of this procedure during the October and December 2019 incidents. 4 Koch Fertilizer Holding Company, LLC Koch Fertilizer Enid LLC Inspection Date: 09/15/2020 - 09/30/2020 AOC 7 - 40 C.F.R. 68.71(b) Training "Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process. The owner or operator, in consultation with the employees involved in operating the process, shall determine the appropriate frequency of refresher training." Koch failed to provide refresher training at least every three years for one operator. Koch noted that the expiration of the operator refresher training occurred during the onset of the COVID19 pandemic in March 2020, and that the operator completed refresher training on April 27, 2020. AOC 8 - 40 C.F.R. 68.73(e) Mechanical Integrity "Equipment deficiencies. The owner or operator shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in 68.65) before further use or in a safe and timely manner when necessary means are taken to assure safe operation." Koch failed to correct deficiencies in equipment in a safe and timely manner to assure safe operations which caused release incidents on the following dates: November 6, 2017 (Incident No. 39441) Koch noted that a shutdown of the ammonia unit was initiated upon discovery of the deficiency, and that the equipment was not restored to operation until the deficiency was corrected. January 6, 2018 (Incident No. 39803) Koch noted that a shutdown of the ammonia unit was initiated upon discovery of the deficiency, and that the equipment was not restored to operation until the deficiency was corrected. January 2, 2019 (Incident No. 42265) Koch noted the equipment deficiency posed no risk to personnel; associated equipment was operated safely while a repair plan was developed; and the deficiency was corrected on January 5, 2019. March 8, 2019 (Incident No. 42721) Koch noted that it discovered the equipment deficiency; associated equipment was operated safely while a repair plan was developed; and the deficiency was corrected on March 8, 2019 (bolts were torqued to stop leak). March 25, 2019 (Incident No. 42814) Koch noted that it initiated a shutdown of Urea 1 unit upon discovery of the deficiency to enable safe maintenance conditions; associated equipment was shutdown safely; deficiency was corrected on March 26, 2019 (scaffolding built, piping de-pressured, flange unbolted, gasket re-centered, flange bolted). April 18, 2019 (Incident No. 42966) Koch noted that it initiated shutdown of A2 unit upon discovery of the deficiency to enable safe maintenance conditions; associated equipment was shutdown safely while a repair plan was developed; deficiency was corrected on April 18, 2019 (piping de-pressured, thermowell removed, affected nozzle blind flanged). May 26, 2019 (Incident No. 43185) Koch noted that it initiated a shutdown of UAN unit upon discovery of deficiency to enable safe maintenance conditions; associated equipment was shutdown safely while repair plan was developed; did not begin operations of this equipment until deficiencies were complete (pump was removed, unit connection was blinded flanged, pump was repaired prior to reinstallation). June 9, 2019 (Incident No. 43336) Koch noted that its corrective response was executed in a timely manner 5 Koch Fertilizer Holding Company, LLC Koch Fertilizer Enid LLC Inspection Date: 09/15/2020 - 09/30/2020 and operated associated equipment within safe operating limits; associated equipment was operated safely while a repair plan was developed; deficiency was corrected on June 12, 2019 (welded patch over affected area). July 31, 2019 (Incident No. 43729) Koch noted that it initiated a shutdown on P-102B pump upon discovery of equipment deficiency; assessed deficiency identified in the UR1 unit and determined that the unit could be safely operated while the deficiency repair plan was established for P-102B; deficiency was corrected on July 31, 2019 (tubing was replaced). September 26, 2019 (Incident No. 44196) Koch noted that it stopped production of A2 unit upon discovery of deficiency on 105-J to enable safe maintenance conditions; A-2 equipment upstream of 105-J continued safe operations while deficiency was assessed; deficiency was corrected on September 26, 2019 (105-J was depressurized, and 1" connection to compressor was replaced). November 12, 2019 (Incident No. 44531) Koch noted that it initiated an investigation of the ammonia source upon discovery of the deficiency; misaligned valve was discovered and placed into proper position; all units remained in safe operation during the event; deficiency was corrected on November 12, 2019 (after valve position was corrected, and steady flaring was required to evaporate liquid ammonia in the flare line). January 1, 2020 (Incident No. 44856) Koch noted it assessed the deficiency and determined that Loading and Storage equipment could be safely operated as repair was completed; deficiency was corrected on January 8, 2020 (pressure regulator setting was adjusted to restore proper gas flow). July 11, 2020 (Incident No. 45908) Koch noted that it initiated a shutdown of A2 unit upon discovery of the deficiency; associated equipment was safely shutdown while repair plan was developed; deficiency was corrected on July 11,2020 (Pressure Safety Valve (PSV) was removed and blind flanges after addition system PSV's and safety equipment was assessed prior to restarting the unit). AOC 9 - 40 C.F.R. 68.79(d) Compliance Audits "The owner or operator shall promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected." Koch failed to document that deficiencies had been corrected for the following Compliance Audits: 2016 Compliance Audit - one action item pending; 2019 Compliance Audit - two action items pending. Koch provided it's PSM Compliance Audit protocol (PRG KNTX PSM 013 PSM) which states on page 4, Section 4.5.7 that, "PSM Compliance Audit findings will be managed and documented in the LYNX system for tracking purposes and for maintaining a schedule for the completion of the corrections to the deficiencies." Koch noted that the two 2019 Audit action items (Finding 173091 and 173100) were completed on September 24, 2020, and October 19, 2020, respectively. Koch further noted that the one action item remains open from the 2016 Audit, at or before November 15, 2021, and that Koch will not document closure of the 2016 action item until the deficiency is corrected. AOC 10 - 40 C.F.R. 68.81(b) Incident Investigation "An incident investigation shall be initiated as promptly as possible, but not later than 48 hours following the incident." 6 Koch Fertilizer Holding Company, LLC Koch Fertilizer Enid LLC Inspection Date: 09/15/2020 - 09/30/2020 Koch failed to initiate as promptly as possible and within 48 hours the following incidents: Incident No. 39010; Incident No. 45797. Section IV - FOLLOW UP None. Section V - LIST OF APPENDICES Appendix 1 - RMP Program Level 3 Process Checklist - Inspection Symbol Key: Y - Yes, N - No, N/A - Not Applicable, S - Satisfactory, M - Marginal, U - Unsatisfactory. 7 RMP Program Level 3 Process Checklist Appendix 1 Facility Name: Koch Fertilizer Enid LLC Facility Section A - Management [68.15] Management system developed and implemented as provided in 40 CFR 68.15? N/A Comments: S M Has the owner or operator: 1. Developed a management system to oversee the implementation of the risk management program elements? Y [68.15(a)] 2. Assigned a qualified person or position that has the overall responsibility for the development, implementation, and Y integration of the risk management program elements? [68.15(b)] 3. Documented other persons responsible for implementing individual requirements of the risk management program Y and defined the lines of authority through an organization chart or similar document? [68.15(c)] Section B: Hazard Assessment [68.20-68.42] Hazard assessment conducted and documented as provided in 40 CFR 68.20-68.42? N/A Comments: S M Hazard Assessment: Offsite consequence analysis parameters [68.22] 1. Used the following endpoints for offsite consequence analysis for a worst-case scenario: [68.22(a)] Y For toxics: the endpoints provided in Appendix A of 40 CFR Part 68? [68.22(a)(1)] For flammables: an explosion resulting in an overpressure of 1 psi? [68.22(a)(2)(i)]; or For flammables: a fire resulting in a radiant heat/exposure of 5 kw/m2 for 40 seconds? [68.22(a)(2)(ii)] For flammables: a concentration resulting in a lower flammability limit, as provided in NFPA documents or other generally recognized sources? [68.22(a)(2)(iii)] 2. Used the following endpoints for offsite consequence analysis for an alternative release scenario: [68.22(a)] Y For toxics: the endpoints provided in Appendix A of 40 CFR Part 68? [68.22(a)(1)] For flammables: an explosion resulting in an overpressure of 1 psi? [68.22(a)(2)(i)] For flammables: a fire resulting in a radiant heat/exposure of 5 kw/m2 for 40 seconds? [68.22(a)(2)(ii)] For flammables: a concentration resulting in a lower flammability limit, as provided in NFPA documents or other generally recognized sources? [68.22(a)(2)(iii)] 3. Used appropriate wind speeds and stability classes for the release analysis? [68.22(b)] Y 4. Used appropriate ambient temperature and humidity values for the release analysis? [68.22(c)] Y 5. Used appropriate values for the height of the release for the release analysis? [68.22(d)] Y 6. Used appropriate surface roughness values for the release analysis? [68.22(e)] Y 7. Do tables and models, used for dispersion analysis of toxic substances, appropriately account for dense or neutrally Y buoyant gases? [68.22(f)] 8. Were liquids, other than gases liquefied by refrigeration only, considered to be released at the highest daily Y maximum temperature, based on data for the previous three years appropriate for a stationary source, or at process temperature, whichever is higher? [68.22(g)] U N N/A N N/A N N/A U N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A Page 1 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Koch Fertilizer Enid LLC Facility Hazard Assessment: Worst-case release scenario analysis [68.25] 9. Analyzed and reported in the RMP one worst-case release scenario estimated to create the greatest distance to an endpoint resulting from an accidental release of a regulated toxic substance from covered processes under worstcase conditions? [68.25(a)(2)(i)] 10. Analyzed and reported in the RMP one worst-case release scenario estimated to create the greatest distance to an endpoint resulting from an accidental release of a regulated flammable substance from covered processes under worst-case conditions? [68.25(a)(2)(ii)] 11. Analyzed and reported in the RMP additional worst-case release scenarios for a hazard class if the worst-case release from another covered process at the stationary source potentially affects public receptors different from those potentially affected by the worst-case release scenario developed under 68.25(a)(2)(i) or 68.25(a)(2)(ii)? [68.25(a)(2)(iii)] 12. Has the owner or operator determined the worst-case release quantity to be the greater of the following: [68.25(b)] Y N N/A Y N N/A Y N N/A Y N N/A If released from a vessel, the greatest amount held in a single vessel, taking into account administrative controls that limit the maximum quantity? [68.25(b)(1)] If released from a pipe, the greatest amount held in the pipe, taking into account administrative controls that limit the maximum quantity? [68.25(b)(2)] 13.a. Has the owner or operator for toxic substances that are normally gases at ambient temperature and handled as a gas or liquid under pressure: 13.a.(1) Assumed the whole quantity in the vessel or pipe would be released as a gas over 10 minutes? [68.25(c)(1)] Y N N/A 13.a.(2) Assumed the release rate to be the total quantity divided by 10, if there are no passive mitigation systems in place? [68.25(c)(1)] Y N N/A 13.b. Has the owner or operator for toxic gases handled as refrigerated liquids at ambient pressure: 13.b.(1) Assumed the substance would be released as a gas in 10 minutes, if not contained by passive mitigation systems Y N N/A or if the contained pool would have a depth of 1 cm or less? [68.25(c)(2)(i)] 13.b.(2) If released substance would be contained by passive mitigation systems in a pool with a depth > 1 cm; Assumed the quantity in the vessel or pipe (as determined per 68.25(b)) would be spilled instantaneously to form a liquid pool? [68.25(c)(2)(ii)] Calculated the volatility rate at the boiling point of the substance and at the conditions specified in 68.25(d)? [68.25(c)(2)(ii)] Y N N/A 13.c. Has the owner or operator for toxic substances that are normally liquids at ambient temperature: 13.c.(1) Assumed the quantity in the vessel or pipe would be spilled instantaneously to form a liquid pool? [68.25(d)(1)] Y N N/A 13.c.(2) Determined the surface area of the pool by assuming that the liquid spreads to 1 cm deep, if there is no passive mitigation system in place that would serve to contain the spill and limit the surface area, or if passive mitigation is in place, was the surface area of the contained liquid used to calculate the volatilization rate? [68.25(d)(1)(i)] 13.c.(3) Taken into account the actual surface characteristics, if the release would occur onto a surface that is not paved or smooth? [68.25(d)(1)(ii)] Y N N/A Y N N/A Page 2 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Koch Fertilizer Enid LLC Facility 13.c.(4) Determined the volatilization rate by accounting for the highest daily maximum temperature in the past three years, the temperature of the substance in the vessel, and the concentration of the substance if the liquid spilled is a mixture or solution? [68.25(d)(2)] Y N N/A 13.c.(5) Determined the rate of release to air from the volatilization rate of the liquid pool? [68.25(d)(3)] Y N N/A 13.c.(6) Determined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis Guidance, any other publicly available techniques that account for the modeling conditions and are recognized by industry as applicable as part of current practices, or proprietary models that account for the modeling conditions may be used provided the owner or operator allows the implementing agency access to the model and describes model features and differences from publicly available models to local emergency planners upon request? [68.25(d)(3)] What modeling technique did the owner or operator use? [68.25(g)] RMP*Comp Y N N/A 13.d. Has the owner or operator for flammables: 13.d.(1) Assumed the quantity in a vessel(s) of flammable gas held as a gas or liquid under pressure or refrigerated gas released to an undiked area vaporizes resulting in a vapor cloud explosion? [68.25(e)] Y N N/A 13.d.(2) For refrigerated gas released to a contained area or liquids released below their atmospheric boiling point, assumed the quantity volatilized in 10 minutes results in a vapor cloud? [68.25(f)] Y N N/A 13.d.(3) Assumed a yield factor of 10% of the available energy is released in the explosion for determining the distance to the explosion endpoint, if the model used is based on TNT-equivalent methods? [68.25(e)] Y N N/A 14. Used the parameters defined in 68.22 to determine distance to the endpoints? [68.25(g)] Y N N/A 15. Determined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis Guidance, Y N N/A any other publicly available techniques that account for the modeling conditions and are recognized by industry as applicable as part of current practices, or proprietary models that account for the modeling conditions may be used provided the owner or operator allows the implementing agency access to the model and describes model features and differences from publicly available models to local emergency planners upon request? [68.25(g)] What modeling technique did the owner or operator use? [68.25(g)] RMP*Comp 16. Ensured that the passive mitigation system, if considered, is capable of withstanding the release event triggering the scenario and will still function as intended? [68.25(h)] Y N N/A 17. Considered also the following factors in selecting the worst-case release scenarios: [68.25(i)] Smaller quantities handled at higher process temperature or pressure? [68.25(i)(1)] Proximity to the boundary of the stationary source? [68.25(i)(2)] Y N N/A Hazard Assessment: Alternative release scenario analysis [68.28] 18. Identified and analyzed at least one alternative release scenario for each regulated toxic substance held in a covered process(es) and at least one alternative release scenario to represent all flammable substances held in covered processes? [68.28(a)] Y N N/A 19. Selected a scenario: [68.28(b)] That is more likely to occur than the worst-case release scenario under 68.25? [68.28(b)(1)(i)] That will reach an endpoint off-site, unless no such scenario exists? [68.28(b)(1)(ii)] Y N N/A Page 3 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Koch Fertilizer Enid LLC Facility 20. Considered release scenarios which included, but are not limited to, the following: [68.28(b)(2)] Transfer hose releases due to splits or sudden hose uncoupling? [68.28(b)(2)(i)] Process piping releases from failures at flanges, joints, welds, valves and valve seals, and drains or bleeds? [68.28(b)(2)(ii)] Process vessel or pump releases due to cracks, seal failure, or drain, bleed, or plug failure? [68.28(b)(2)(iii)] Y N N/A Vessel overfilling and spill, or overpressurization and venting through relief valves or rupture disks? [68.28(b)(2)(iv)] Shipping container mishandling and breakage or puncturing leading to a spill? [68.28(b)(2)(v)] 21. Used the parameters defined in 68.22 to determine distance to the endpoints? [68.28(c)] Y N N/A 22. Determined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis Guidance, Y N N/A any other publicly available techniques that account for the modeling conditions and are recognized by industry as applicable as part of current practices, or proprietary models that account for the modeling conditions may be used provided the owner or operator allows the implementing agency access to the model and describes model features and differences from publicly available models to local emergency planners upon request? [68.28(c)] What modeling technique did the owner or operator use? [68.25(g)] RMP*Comp 23. Ensured that the passive and active mitigation systems, if considered, are capable of withstanding the release event triggering the scenario and will be functional? [68.28(d)] Y N N/A 24. Considered the following factors in selecting the alternative release scenarios: [68.28(e)] The five-year accident history provided in 68.42? [68.28(e)(1)] Failure scenarios identified under 68.50? [68.28(e)(2)] Y N N/A Hazard Assessment: Defining off-site impacts-Population [68.30] 25. Estimated population that would be included in the distance to the endpoint in the RMP based on a circle with the point of release at the center? [68.30(a)] Y N N/A 26. Identified the presence of institutions, parks and recreational areas, major commercial, office, and industrial buildings in the RMP? [68.30(b)] Y N N/A 27. Used most recent Census data, or other updated information to estimate the population? [68.30(c)] Y N N/A 28. Estimated the population to two significant digits? [68.30(d)] Y N N/A Hazard Assessment: Defining off-site impacts-Environment [68.33] 29. Identified environmental receptors that would be included in the distance to the endpoint based on a circle with the point of release at the center? [68.33(a)] Y N N/A 30. Relied on information provided on local U.S.G.S. maps, or on any data source containing U.S.G.S. data to identify environmental receptors? [Source may have used LandView to obtain information] [68.33(b)] Y N N/A Hazard Assessment: Review and update [68.36] 31. Reviewed and updated the off-site consequence analyses at least once every five years? [68.36(a)] Y N N/A 32. Completed a revised analysis and submit a revised RMP within six months of a change in processes, quantities stored or handled, or any other aspect that might reasonably be expected to increase or decrease the distance to the endpoint by a factor of two or more? [68.36(b)] Y N N/A Page 4 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Koch Fertilizer Enid LLC Facility Hazard Assessment: Documentation [68.39] 33. For worst-case scenarios: a description of the vessel or pipeline and substance selected, assumptions and parameters Y used, the rationale for selection, and anticipated effect of the administrative controls and passive mitigation on the release quantity and rate? [68.39(a)] 34. For alternative release scenarios: a description of the scenarios identified, assumptions and parameters used, the Y rationale for the selection of specific scenarios, and anticipated effect of the administrative controls and mitigation on the release quantity and rate? [68.39(b)] 35. Documentation of estimated quantity released, release rate, and duration of release? [68.39(c)] Y 36. Methodology used to determine distance to endpoints? [68.39(d)] Y 37. Data used to estimate population and environmental receptors potentially affected? [68.39(e)] Y Hazard Assessment: Five-year accident history [68.42] 38. Has the owner or operator included all accidental releases from covered processes that resulted in deaths, injuries, or Y significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage? [68.42(a)] 39. Has the owner or operator reported the following information for each accidental release: [68.42(b)] Y Date, time, and approximate duration of the release? [68.42(b)(1)] Chemical(s) released? [68.42(b)(2)] Estimated quantity released in pounds and percentage weight in a mixture (toxics)? [68.42(b)(3)] NAICS code for the process? [68.42(b)(4)] The type of release event and its source? [68.42(b)(5)] Weather conditions (if known)? [68.42(b)(6)] On-site impacts? [68.42(b)(7)] Known offsite impacts? [68.42(b)(8)] Initiating event and contributing factors (if known)? [68.42(b)(9)] Whether offsite responders were notified (if known)? [68.42(b)(10)] Operational or process changes that resulted from investigation of the release? [68.42(b)(11)] Section C: Prevention Program Implemented the Program 3 prevention requirements as provided in 40 CFR 68.65 - 68.87? N/A S M N N/A N N/A N N/A N N/A N N/A N N/A N N/A U Page 5 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Koch Fertilizer Enid LLC Facility Prevention Program- Safety information [68.65] 1. Has the owner or operator compiled written process safety information, which includes information pertaining to the Y N N/A hazards of the regulated substances used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process, before conducting any process hazard analysis required by the rule? [68.65(a)] Does the process safety information contain the following for hazards of the substances: [68.65(b)] Material Safety Data Sheets (MSDS) that meet the requirements of the OSHA Hazard Communication Standard [29 CFR 1910.1200(g)]? [68.48(a)(1)] Toxicity information? [68.65(b)(1)] Permissible exposure limits? [68.65(b)(2)] Physical data? [68.65(b)(3)] Reactivity data? [68.65(b)(4)] Corrosivity data? [68.65(b)(5)] Thermal and chemical stability data? [68.65(b)(6)] Hazardous effects of inadvertent mixing of materials that could foreseeably occur? [68.65(b)(7)] 2. Has the owner documented information pertaining to technology of the process? Y N N/A A block flow diagram or simplified process flow diagram? [68.65(c)(1)(i)] Process chemistry? [68.65(c)(1)(ii)] Maximum intended inventory? [68.65(c)(1)(iii)] Safe upper and lower limits for such items as temperatures, pressures, flows, or compositions? [68.65(c)(1)(iv)] An evaluation of the consequences of deviation? [68.65(c)(1)(iv)] 3. Does the process safety information contain the following for the equipment in the process: [68.65(d)(1)] Materials of construction? 68.65(d)(1)(i)] Piping and instrumentation diagrams [68.65(d)(1)(ii)] Electrical classification? [68.65(d)(1)(iii)] Relief system design and design basis? [68.65(d)(1)(iv)] Ventilation system design? [68.65(d)(1)(v)] Design codes and standards employed? [68.65(d)(1)(vi)] Material and energy balances for processes built after June 21, 1999? [68.65(d)(1)(vii)] Safety systems? [68.65(d)(1)(viii)] 4. Has the owner or operator documented that equipment complies with recognized and generally accepted good engineering practices? [68.65(d)(2)] 5. Has the owner or operator determined and documented that existing equipment, designed and constructed in accordance with codes, standards, or practices that are no longer in general use, is designed, maintained, inspected, tested, and operating in a safe manner? [68.65(d)(3)] Prevention Program- Process Hazard Analysis [68.67] 6. Has the owner or operator performed an initial process hazard analysis (PHA), and has this analysis identified, evaluated, and controlled the hazards involved in the process? [68.67(a)] Y N N/A Y N N/A Y N N/A Y N N/A Page 6 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Koch Fertilizer Enid LLC Facility 7. Has the owner or operator determined and documented the priority order for conducting PHAs, and was it based on an appropriate rationale? [68.67(a)] Y N N/A 8. Has the owner used one or more of the following technologies to conduct process PHA: [68.67(b)] What-if? [68.67(b)(1)] Checklist? [68.67(b)(2)] What-if/Checklist? [68.67(b)(3)] Hazard and Operability Study (HAZOP) [68.67(b)(4)] Failure Mode and Effects Analysis (FMEA) [68.67(b)(5)] Fault Tree Analysis? [68.67(b)(6)] An appropriate equivalent methodology? [68.67(b)(7)] Y N N/A 9. Did the PHA address: The hazards of the process? [68.67(c)(1)] Identification of any incident that had a likely potential for catastrophic consequences? [68.67(c)(2)] Engineering and administrative controls applicable to hazards and interrelationships?[68.67(c)(3)] Consequences of failure of engineering and administrative controls? [68.67(c)(4)] Stationary source siting? [68.67(c)(5)] Human factors? [68.67(c)(6)] An evaluation of a range of the possible safety and health effects of failure of controls? [68.67(c)(7)] Y N N/A 10. Was the PHA performed by a team with expertise in engineering and process operations and did the team include appropriate personnel? [68.67(d)] Y N N/A 11. Has the owner or operator established a system to promptly address the team's findings and recommendations; Y N N/A assured that the recommendations are resolved in a timely manner and documented; documented what actions are to be taken; completed actions as soon as possible; developed a written schedule of when these actions are to be completed; and communicated the actions to operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations? [68.67(e)] 12. Has the PHA been updated and revalidated by a team every five years after the completion of the initial PHA to assure that the PHA is consistent with the current process? [68.67(f)] Y N N/A 13. Has the owner or operator retained PHAs and updates or revalidations for each process covered, as well as the resolution of recommendations for the life of the process? [68.67(g)] Y N N/A Prevention Program- Operating procedures [68.69] 14. Has the owner or operator developed and implemented written operating procedures that provide instructions or steps for conducting activities associated with each covered process consistent with the safety information? [68.69(a)] Y N N/A Page 7 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Koch Fertilizer Enid LLC Facility 15 Do the procedures address the following: [68.69(a)] Steps for each operating phase: [68.69(a)(1)] Initial Startup? [68.69(a)(1)(i)] Normal operations? [68.69(a)(1)(ii)] Temporary operations? [68.69((a)(1)(iii)] Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner? [68.69(a)(1)(iv)] Emergency operations? [68.69(a)(1)(v)] Normal shutdown? [68.68(a)(1)(vi)] Startup following a turnaround, or after emergency shutdown? [68.69(a)(1)(vii)] Operating limits: [68.69(a)(2)] Consequences of deviations [68.69(a)(2)(i)] Steps required to correct or avoid deviation? [68.69(a)(2)(ii)] Safety and health considerations: [68.69(a)(3)] Properties of, and physical hazards presented by, the chemicals used in the process [68.69(a)(3)(i)] Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment? [68.69(a)(3)(ii)] Control measures to be taken if physical contact or airborne exposure occurs? [68.69(a)(3)(iii)] Quality control for raw materials and control of hazardous chemical inventory levels? [68.69(a)(3)(iv)] Y N N/A Any special or unique hazards? [68.69(a)(3)(v)] Safety systems and their functions? [68.69(a)(4)] 16. Are operating procedures readily accessible to employees who are involved in a process? [68.69(b)] 17. Has the owner or operator certified annually that the operating procedures are current and accurate and that procedures have been reviewed as often as necessary? [68.69(c)] 18. Has the owner or operator developed and implemented safe work practices to provide for the control of hazards during specific operations, such as lockout/tagout? [68.69(d)] Prevention Program - Training [68.71] 19 Has each employee involved in operating a process, and each employee before being involved in operating a newly assigned process, been initially trained in an overview of the process and in the operating procedures? [68.71(a)(1)] Y N N/A Y N N/A Y N N/A Y N N/A 20. Did initial training include emphasis on safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks? [68.71(a)(1)] Y N N/A 21. In lieu of initial training for those employees already involved in operating a process on June 21, 1999, an owner or Y N N/A operator may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures [68.71(a)(2)] 22. Has refresher training been provided at least every three years, or more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process? [68.71(b)] Y N N/A Page 8 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Koch Fertilizer Enid LLC Facility 23, Has owner or operator ascertained and documented in record that each employee involved in operating a process has Y N N/A received and understood the training required? [68.71(c)] 24. Does the prepared record contain the identity of the employee, the date of the training, and the means used to verify that the employee understood the training? [68.71(c)] Y N N/A Prevention Program - Mechanical Integrity [68.73] 25. Has the owner or operator established and implemented written procedures to maintain the on-going integrity of the process equipment listed in 68.73(a)? [68.73(b)] Y N N/A 26. Has the owner or operator trained each employee involved in maintaining the on-going integrity of process equipment? [68.73(c)] Y N N/A 27. Performed inspections and tests on process equipment? [68.73(d)(1)] Y N N/A 28. Followed recognized and generally accepted good engineering practices for inspections and testing procedures? [68.73(d)(2)] Y N N/A 29. Ensured the frequency of inspections and tests of process equipment is consistent with applicable manufacturers' recommendations, good engineering practices, and prior operating experience? [68.73(d)(3)] Y N N/A 30. Documented each inspection and test that had been performed on process equipment, which identifies the date of the Y N N/A inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test? [68.73(d)(4)] 31. Corrected deficiencies in equipment that were outside acceptable limits defined by the process safety information before further use or in a safe and timely manner when necessary means were taken to assure safe operation? [68.73(e)] Y N N/A 32. Assured that equipment as it was fabricated is suitable for the process application for which it will be used in the construction of new plants and equipment? [68.73(f)(1)] Y N N/A 33. Performed appropriate checks and inspections to assure that equipment was installed properly and consistent with design specifications and the manufacturer's instructions? [68.73(f)(2)] Y N N/A 34. Assured that maintenance materials, spare parts and equipment were suitable for the process application for which they would be used? [68.73(f)(3)] Y N N/A Prevention Program - Management Of Change [68.75] 35. Has the owner or operator established and implemented written procedures to manage changes to process chemicals, Y N N/A technology, equipment, and procedures, and changes to stationary sources that affect a covered process? [68.75(a)] 36. Do procedures assure that the following considerations are addressed prior to any change: [68.75(b)] The technical basis for the proposed change? [68.75(b)(1)] Impact of change on safety and health? [68.75(b)(2)] Modifications to operating procedures? [68.75(b)(3)] Necessary time period for the change? [68.75(b)(4)] Authorization requirements for the proposed change? [68.75(b)(5)] 37. Were employees, involved in operating a process and maintenance, and contract employees, whose job tasks would be affected by a change in the process, informed of, and trained in, the change prior to start-up of the process or affected parts of the process? [68.75(c)] Y N N/A Y N N/A Page 9 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Koch Fertilizer Enid LLC Facility 38. If a change resulted in a change in the process safety information, was such information updated accordingly? [68.75(d)] 39. If a change resulted in a change in the operating procedures or practices, had such procedures or practices been updated accordingly? [68.75(e)] Prevention Program - Pre-startup Safety Review [68.77] 40. If the facility installed a new stationary source, or significantly modified an existing source, (as discussed at 68.77(a)) did it perform a pre-startup safety review prior to the introduction of a regulated substance to a process to confirm: [68.77(b)] Construction and equipment was in accordance with design specifications? [68.77(b)(1)] Safety, operating, maintenance, and emergency procedures were in place and were adequate? [68.77(b)(2)] Y N N/A Y N N/A Y N N/A For new stationary sources, a process hazard analysis had been performed and recommendations had been resolved or implemented before startup? [68.77(b)(3)] Modified stationary sources meet the requirements contained in management of change? [68.77(b)(3)] Training of each employee involved in operating a process had been completed? [68.77(b)(4)] Prevention Program - Compliance audits [68.79] 41. Has the owner or operator certified that the stationary source has evaluated compliance with the provisions of the prevention program at least every three years to verify that the developed procedures and practices are adequate and being followed? [68.79(a)] Y N N/A 42. Has the audit been conducted by at least one person knowledgeable in the process? [68.79(b)] Y N N/A 43. Are the audit findings documented in a report? [68.79(c)] Y N N/A 44. Has the owner or operator promptly determined and documented an appropriate response to each of the findings of the audit and documented that deficiencies had been corrected? [68.79(d)] Y N N/A 45. Has the owner or operator retained the two most recent compliance reports? [68.79(e)] Y N N/A Prevention Program - Incident investigation [68.81] 46. Has the owner or operator investigated each incident that resulted in, or could reasonably have resulted in a catastrophic release of a regulated substance? [68.81(a)] Y N N/A 47. Were all incident investigations initiated not later than 48 hours following the incident? [68.81(b)] Y N N/A 48. Was an accident investigation team established and did it consist of at least one person knowledgeable in the process Y N N/A involved, including a contract employee if the incident involved work of a contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident? [68.81(c)] 49. Was a report prepared at the conclusion of every investigation? [68.81(d)] Y N N/A 50. Does every report include: [68.81(d)] Date of incident? [68.81(d)(1)] Date investigation began? [68.81(d)(2)] A description of the incident? [68.81(d)(3)] The factors that contributed to the incident? [68.81(d)(4)] Any recommendations resulting from the investigation? [68.81(d)(5)] Y N N/A Page 10 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Koch Fertilizer Enid LLC Facility 51. Has the owner or operator established a system to address and resolve the report findings and recommendations, and Y are the resolutions and corrective actions documented? [68.81(e)] 52. Was the report reviewed with all affected personnel whose job tasks are relevant to the incident findings including Y contract employees where applicable? [68.81(f)] 53. Has the owner or operator retained incident investigation reports for at least five years? [68.81(g)] Y Section D - Employee Participation [68.83] 1. Has the owner or operator developed a written plan of action regarding the implementation of the employee Y participation required by this section? [68.83(a)] 2. Has the owner or operator consulted with employees and their representatives on the conduct and development of Y process hazards analyses and on the development of the other elements of process safety management in chemical accident prevention provisions? [68.83(b)] 3. Has the owner or operator provided to employees and their representatives access to process hazards analyses and to Y all other information required to be developed under the chemical accident prevention rule? [68.83(c)] Section E - Hot Work Permit [68.85] 1. Has the owner or operator issued a hot work permit for each hot work operation conducted on or near a covered Y process? [68.85(a)] 2. Does the permit document that the fire prevention and protection requirements in 29CFR 1910.252(a) have been Y implemented prior to beginning the hot work operations? [68.85(b)] 3. Does the permit indicate the date(s) authorized for hot work and the object(s) upon which hot work is to be Y performed? [68.85(b] 4. Are the permits being kept on file until completion of the hot work operations? [68.85(b)] Y Section F - Contractors [68.87] 1. Has the owner or operator obtained and evaluated information regarding the contract owner or operator's safety Y performance and programs when selecting a contractor? [68.87(b)(1)] 2. Informed contract owner or operator of the known potential fire, explosion, or toxic release hazards related to the Y contractor's work and the process? [68.87(b)(2)] 3. Explained to the contract owner or operator the applicable provisions of the emergency response or the emergency Y action program? [68.87(b)(3)] 4. Developed and implemented safe work practices consistent with 68.69(d), to control the entrance, presence, and Y exit of the contract owner or operator and contract employees in the covered process areas? [68.87(b)(4)] 5. Periodically evaluated the performance of the contract owner or operator in fulfilling their obligations (as described Y at 68.87(c)(1) - (c)(5))? [68.87(b)(5)] Section G - Emergency Response [68.90 - 68.95] Developed and implemented an emergency response program as provided in 40 CFR 68.90-68.95? N/A Comments: S M 1. Is the facility designated as a "first responder" in case of an accidental release of regulated substances" Y 1.a. If the facility is not a first responder: N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A U N N/A Page 11 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Koch Fertilizer Enid LLC Facility 1.a.(1) For stationary sources with any regulated substances held in a process above threshold quantities, is the source included in the community emergency response plan developed under 42 U.S.C. 11003? [68.90(b)(1)] 1.a.(2) For stationary sources with only regulated flammable substances held in a process above threshold quantities, has the owner or operator coordinated response actions with the local fire department? [68.90(b)(2)] 1.a.(3) Are appropriate mechanisms in place to notify emergency responders when there is need for a response? [68.90(b)(3)] 2. An emergency response plan is maintained at the stationary source and contains the following? [68.95(a)(1)] Procedures for informing the public and local emergency response agencies about accidental releases? [68.95(a)(1)(i)] Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures? [68.95(a)(1)(ii)] Procedures and measures for emergency response after an accidental release of a regulated substance? [68.95(a)(1)(iii)] 3. The emergency response plan contains procedures for the use of emergency response equipment and for its inspection, testing, and maintenance? [68.95(a)(2)] 4. The emergency response plan requires, and there is documentation of, training for all employees in relevant procedures? [68.95(a)(3)] 5. The owner or operator has developed and implemented procedures to review and update, as appropriate, the emergency response plan to reflect changes at the stationary source and ensure that employees are informed of changes? [68.95(a)(4)] 6. Did the owner or operator use a written plan that complies with other Federal contingency plan regulations or is consistent with the approach in the National Response Team's Integrated Contingency Plan Guidance (``One Plan'')? If so, does the plan include the elements provided in paragraph (a) of 68.95, and also complies with paragraph (c) of 68.95? [68.95(b)] 7. Has the emergency response plan been coordinated with the community emergency response plan developed under EPCRA? [68.95(c)] Section H - Risk Management Plan [40 CFR 68.190 - 68.195] 1. Does the single registration form include, for each covered process, the name and CAS number of each regulated substance held above the threshold quantity in the process, the maximum quantity of each regulated substance or mixture in the process (in pounds) to two significant digits, the five- or six-digit NAICS code that most closely corresponds to the process and the Program level of the process? [68.160(b)(7)] 2. Did the facility assign the correct program level(s) to its covered process(es)? [68.160(b)(7)] Y N N/A Y N N/A Y N N/A Y N N/A Y N N/A Y N N/A Y N N/A Y N N/A Y N N/A Y N N/A Y N N/A Page 12 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Koch Fertilizer Enid LLC Facility 3. Has the owner or operator reviewed and updated the RMP and submitted it to EPA [68.190(a)]? Reason for update: Y N N/A Five-year update. [68.190(b)(1)] Within three years of a newly regulated substance listing. [68.190(b)(2)] At the time a new regulated substance is first present in an already regulated process above threshold quantities. [68.190(b)(3)] At the time a regulated substance is first present in an new process above threshold quantities. [68.190(b)(4)] Within six months of a change requiring revised PHA or hazard review. [68.190(b)(5)] Within six months of a change requiring a revised OCA as provided in 68.36. [68.190(b)(6)] Within six months of a change that alters the Program level that applies to any covered process. [68.190(b)(7)] 4. If the owner or operator experienced an accidental release that met the five-year accident history reporting criteria (as described at 68.42) subsequent to April 9, 2004, did the owner or operator submit the information required at 68.168, 68.170(j) and 68.175(l) within six months of the release or by the time the RMP was updated as required at 68.190, whichever was earlier. [68.195(a)] 5. If the emergency contact information required at 68.160(b)(6) has changed since June 21, 2004, did the owner or operator submit corrected information within thirty days of the change? [68.195(b)] Y N N/A Y N N/A Page 13 of 13 Rev 01/31/2011