On October 26, 2018, Respondent became the owner and operator of the facility upon the completion of a merger. According to Respondent’s RMP, Respondent handles approximately 22,477 pounds of anhydrous ammonia at the Facility. EPA conducted an inspection of the Facility on April 18, 2018, to evaluate the Facility’s compliance with CAA Section 112(r). On May 24, 2018, EPA sent a post-inspection letter to Respondent’s predecessor, summarizing the deficiencies identified by EPA during the Inspection and subsequent investigation.
SPECIAL NOTE: this case involved a merger and during the merger, it seems that the PHA recommendations from a 2016 PHA lost momentum and during the 2018 EPA inspection EPA found four (4) items still open:
(1) preventative maintenance and inspection items added to daily and annual inspections
(2) replacement of an auto-purger
(3) installation of a relief vent ammonia detector and loading dock detectors, and
(4) installation of a glycol temperature and pressure transmitter on the control panel.
And these four items being open cost the facility $17,000!