Respondent has an Ethanolamines unit used for chemical manufacturing purposes at the Facility that has greater than a threshold quantity of anhydrous ammonia.
EPA Findings of Violation
Count 1 – Quality Assurance
The regulation at 40 C.F.R. § 68.12(d)(3) requires the owner or operator of a stationary source with a process subject to Program 3 to implement the prevention requirements of 40 C.F.R. §§ 68.65 through 68.87. According to 40 C.F.R. §§ 68.73(f)(2) & (3), appropriate checks and inspections shall be performed to assure that equipment is installed properly and consistent with design specifications and the manufacturer’s instructions. The owner or operator shall assure that maintenance materials, spare parts, and equipment are suitable for the process application for which they will be used.
Respondent’s response to follow-up questions provided on June 16, 2022, regarding the September 17, 2021, incident, which resulted in a release of275 pounds of anhydrous ammonia to the atmosphere, identified the root cause as “poor craftsmanship of pilot PSV (pressure safety valve) assembly at the vendor” and identified a contributing cause as “no quality control plan existed for this external repair.”
Respondent’s failure to conduct quality assurance checks and inspections or establish a quality control plan for the external repair of the PSV described above pursuant to 40 C.F.R. §§ 68.73(f)(2) & (3), as required by 40 C.F.R. § 68.12(d)(3).
CONSENT AGREEMENT
Respondent agrees that, in settlement of the claims alleged herein, Respondent shall pay a civil penalty of thirty-six thousand two hundred and fifty dollars ($36,250).
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