ON JANUARY 30, 2015, EPA REGION III APPROVED A SUPER-CONSENT AGREEMENT AND FINAL ORDER ( SCAFO ) RESOLVING A VIOLATION OF SECTION 112(r) OF THE CAA AND A VIOLATION OF SECTION 304(a) AND (b) OF EPCRA WITH NUPRO INDUSTRIES CORPORATION ( NUPRO ). NUPRO IS THE OWNER AND OPERATOR OF THE NEATSFOOT OIL OPERATION IN THE PORT RICHMOND AREA OF THE CITY OF PHILADELPHIA, WHERE IT MANUFACTURES OIL LUBRICANTS BY RENDERING ANIMAL FATS. NUPRO UTILIZED AN ANHYDROUS AMMONIA COOLING SYSTEM AS PART OF THAT OPERATIONS 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.
THE SCAFO RESOLVES A VIOLATION OF CAA SECTION 112(r)(1), THE GENERAL DUTY CLAUSE, FOR THE FAILURE TO TIMELY DEVELOP AND IMPLEMENT THE SAFETY RECOMMENDATIONS SET FORTH IN A PROCESS HAZARD ANALYSIS FOR THE AMMONIA SYSTEM. IN ADDITION, THE SCAFO RESOLVES A VIOLATION OF EPCRA FOR THE FAILURE TO IMMEDIATELY NOTIFY THE LOCAL EMERGENCY PLANNING COMMITTEE THAT THE RELEASE OF AMMONIA EXCEEDED ITS REPORTABLE QUANTITY (100 POUNDS) IN VIOLATION OF SECTION 304(a) AND (b) OF EPCRA. THE SCAFO REQUIRES THAT RESPONDENT PAY A TOTAL CASH PENALTY OF $13,685 AND IMPLEMENT A SUPPLEMENT ENVIRONMENTAL PROJECT ( SEP ) COSTING NOT LESS THAN $81,300. THE SEP REQUIRES THAT NUPRO REMOVE THE FACILITY'S AMMONIA REFRIGERATION SYSTEM AND REPLACE IT WITH HYDRO-CHLORORFLUOROCARBON REFERATION SYSTEM WHICH WILL USE A PROPYLENE GL