EPA EPCRA/CERCLA citations for two NH3 Releases from refrigeration process

This is a lesson in reporting your releases! Two releases of anhydrous ammonia from a refrigeration process result in $150,000 in fines ($75K for EPCRA and $75K for CERCLA) and a $425,000 SEP to install detectors and emergency shutdown systems. The Complaint alleges that:

  • Respondent violated Section 103(a) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) by failing to immediately notify the National Response Center of a release which occurred at its facility in Minnesota, between June 21 and July 19, 2013;
  • Respondent violated Section 304(a) of Emergency Planning and Community Right-to-Know Act (EPCRA), by failing to immediately notify the Minnesota State Emergency Response Commission (SERC) of the June 21 – July 19, 2013, release;
  • Respondent violated Section 304(c) of EPCRA by failing to provide a written follow-up emergency notice to the Minnesota SERC as soon as practicable after the June 21 – July 19, 2013 release occurred;
  • Respondent violated Section 103(a) of CERCLA by failing to immediately notify the National Response Center of a release which occurred at its facility in Minnesota, on September 20, 2014;
  • Respondent violated Section 304(a) of EPCRA by failing to immediately notify the Minnesota State Emergency Response Commission (SERC) of the September 20, 2014, release; and
  • Respondent violated Section 304(c) of EPCRA by failing to provide a written follow-up emergency notice to the Minnesota SERC as soon as practicable after the September 20, 2014 release occurred

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