This is from a recently posted Consent Decree for a fish processing facility. From all I have seen this facility did NOT have RMP Covered processes using Anhydrous Ammonia, Chlorine or Butane and all of these actions stem from a General Duty Clause agreement, which is by far the most significant GDC agreement I can remember. The facility used the Ammonia as a refrigerant, Chlorine to treat their water, and Butane to power their forklifts. Following a May 2016 inspection of the Facility by EPA and identification of the Clean Air Act Section 112(r) violations alleged in the Complaint, Defendant and EPA entered into an Administrative Compliance Order on Consent (“AOC”) pursuant to Section 113(a) of the Clean Air Act and pursuant to that AOC, Defendant carried out a number of assessments related to its ammonia refrigeration, chlorine, and butane systems.
EPA required actions on all three chemicals: