“Minor” LOPC events that are allowed to continue over a weekend can be a COSTLY MISTAKE! Any LOPC event MUST be reported ASAP to that it can be addressed, regardless of how “minor” it may be considered! We have to keep our HHC/EHS’s in their PRIMARY CONTAINMENT and when we have a failure that lets the “tiger out of its cage” we need to address it IMMEDIATELY! This is also a PSM/RMP facility so it could be considered lucky that EPA did not actually seek the cause of the RQ Releases and issue some RMP citations.
Respondent is an engine crankshaft manufacturing facility that uses anhydrous ammonia as a source of Nitrogen in its heat-treating process. On April 19, 2017, EPA conducted an inspection of the Facility to determine Respondent’s compliance with Section 103 or CERCLA and Sections 302-312 of EPCRA. On or about June 16, 2016, beginning at approximately 8:20 PM, approximately 139 pounds of anhydrous ammonia (7664-41-7) was released from the Facility (the “2016 Release”). The 2016 Release lasted until approximately 11:00 AM on June 17, 2016. The facility became aware of the 2016 Release during the morning of July 18, 2016, upon performing calculations required under its Clean Air Act Title V operating permit. At approximately 2:00 PM on July 18, 2016, the facility contacted a contractor to inquire about procedures for reporting an accidental release; the contractor responded at some point prior to 10:00 AM on July 19, 2016. At approximately 12:00 PM on July 19, 2016, the facility notified the LEPC of the 2016 Release and at approximately 2:00 PM on July 19, 2016, the facility notified the NRC of the 2016 Release.
On or about October 3, 2018, beginning at approximately 7:30 PM, and ending at approximately 6:00 AM on October 4, 20 18, approximately 160 pounds of anhydrous ammonia was released from the Facility (“2018 Release”). At approximately 3:00 PM on October 5, 2018, the Facility notified the LEPC of the 2018 Release and at approximately 9:51 AM on October 10, 2018, the Facility notified the NRC of the 2018 Release.
COUNT I (SECTION 103(a) of CERCLA, 2016 RELEASE)