UPDATED/CORRECTED on 9/14/15. Many thanks to Chris Kim Kahn, Attorney at Law @ Frost Brown Todd LLC for her assistance in correct this posting.
Respondent owns and operates a controlled-temperature storage warehouse for food products. The Facility is located on the banks of the Connecticut River, within a quarter mile of residences and other businesses, within a half mile of two Interstate Routes (1-91 and 1-395) and a large shopping center, and less than one mile from several schools, hospitals, and houses of worship. Facility uses anhydrous ammonia in two refrigeration processes, in two series of interconnected vessels at the Facility. The process located in Building Two was constructed sometime between 1996 and 1998 (“Building Two Process”), and the process located in Building Five was installed sometime between 2000 and 2004 (“Building Five Process” and collectively, “Processes”). Respondent’s use, storage, and handling of anhydrous ammonia in the Building Five Process and the Building Two Process is subject to the requirements of RMP Program 3. On December 6, 2012, EPA inspectors visited the facility to assess Respondent’s compliance with Section 112(r) of the CAA and with Sections 302-312 of the Emergency Planning and Community Right-to-Know Act. Here is a breakdown of the citations: