ON MARCH 21, 2014, EPA REGION III ISSUED AN ADMINISTRATIVE SETTLEMENT AGREEMENT AND ORDER ON CONSENT ( ORDER ) TO NUPRO INDUSTRIES, INC. ( NUPRO ), THE OWNER AND OPERATOR OF THE NEATSFOOT OIL OPERATION IN PORT RICHMOND AREA OF THE CITY OF PHILADELPHIA, WHERE IT MANUFACTURES OIL LUBRICANTS BY RENDERING ANIMAL FATS. NUPRO UTILIZES AN ANHYDROUS AMMONIA COOLING SYSTEM AS PART OF THAT OPERATION AND, BETWEEN APRIL 6, 2012 AND APRIL 8, 2012, A RELEASE OF APPROXIMATELY 1,400 POUNDS OF AMMONIA OCCURRED. AS A RESULT, EPA CONDUCTED AN INSPECTION OF THE FACILITY ON JUNE 6, 2012 AND DETERMINED THAT NUPRO WAS NOT IN COMPLIANCE WITH THE GENERAL DUTY CLAUSE OF SECTION 112(r) OF THE CLEAN AIR ACT DUE TO: (1)THE LACK OF A FINAL, IMPLEMENTED PROCESS HAZARD ANALYSIS FOR THE AMMONIA SYSTEM; (2)THE ABSENCE OF ADEQUATE OPERATING PROCEDURES FOR THE AMMONIA SYSTEM WHICH INCLUDE SAFE OPERATING LIMITS, SAFETY AND HEALTH CONSIDERATIONS, AND MEASURES RELATED TO SAFETY SYSTEMS; (3)THE LACK OF AN INSPECTION AND MAINTENANCE PROGRAM; (4)INADEQUATE SIGNAGE; (5)INADEQUATE RECORDKEEPING; AND (6)THE ABSENCE OF OIL DRAINING PROCEDURES OR SELF-CLOSING OIL VALVES. THE ORDER REQUIES THAT RESPONDENT DEMONSTRATE THAT THE FACILITY IS IN COMPLIANCE WITH THE GDC, WHICH IS IMPORTANT TO PROTECT THE SURROUNDING POPULATION. RESPONDENT MUST SUBMIT A REPORT TO EPA IN ORDER TO DEMONSTRATE COMPLIANCE WITH THE AMMONIA INDUSTRY STANDARDS. THE REPORT SHALL ALSO IDENTIFY ANY ADDITIONAL ACTIONS NUPRO MUST TAKE TO COME INTO COMP