EPA RMP General Duty Clause citations @ tote recycler/manufacturer (Chemical Reaction & $37K)

Respondent owns and operates a container molding facility where it manufactures and recycles high density polyethylene containers ranging in size from fifty-five to 330 gallons (“containers”). The larger containers are encased in a steel cage for extra support. As part of its recycling operations, the Facility accepts used containers which routinely contain small amounts of residual chemicals, including formaldehyde, a listed or other extremely hazardous substance. These used containers are processed at the return processing area. The return processing area includes a conveyor system and a cut-and-scrape area. At the return processing area, Respondent classifies return containers by chemical type and groups certain containers together to prevent the possibility of a chemical reaction. The return containers are placed on the assembly line, the inner plastic tank is removed and drained of any residue. The plastic is destroyed and the steel cage is washed and used for future containers. On October 7, 2015, Respondent’s employees reported that an unknown chemical reaction had started in the return processing area. The reaction was described as a smoke emitting foaming liquid. Employees attempted to stop the reaction with a fire extinguisher, but were unable to do so. Employees evacuated the area when flames appeared. The fire quickly engulfed the return process area. The fire was eventually extinguished with the help of the local fire department. Two firefighters were hospitalized and later released. Respondent suffered property damage as a result of the fire, including damage to inventory as well as the conveyor system and cut-and-scrape area.

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