Respondent owns and operates a metal parts heat treatment operation and maintains a maximum inventory of 60,000 pounds of anhydrous ammonia, at the Facility, which exceeds the threshold quantity of 10,000 pounds. Respondent uses anhydrous ammonia in its heat treatment process.
EPA inspectors completed an announced CAA 112(r) inspection on June 15 through June 16, 2022 (June 2022 Inspection). Respondent provided records during and after the June 2022 Inspection relating to its implementation of the CAPP, including the Facility’s RMP involving the management system, process safety information, the Process Hazard Analysis (PHA), operating procedures, training, mechanical integrity, management of change, pre-startup safety review, compliance audits, hot work permits, employee participation, and contractors.
Respondent’s RMP was due on July 24, 2020, five years after the RMP was previously submitted on July 24, 2015. The Facility did not submit its RMP until June 20, 2022, 696 days late. On January 23, 2023, EPA issued a Finding of Violation (FOV) to Respondent.