3/12/2020-CONSENT AGREEMENT ISSUED, ASSESSING A PENALTY OF $179146, DUE WITHIN 30 DAYS.
ALLEGATIONS:
BASED ON AN INSPECTION, EPA ALLEGES THAT RESPONDENT VIOLATED THE GENERAL DUTY CLAUSE UNDER CAA 112(r)(1) WHEN IT:
A. FAILED TO IDENTIFY HAZARDS BY NOT CONDUCTING A HAZARD ANALYSIS OF THE AMMONIA REFRIGERATION SYSTEM. RESPONDENT'S FAILURE TO IDENTIFY HAZARDS ASSOCIATED WITH AMMONIA REFRIGERANT SYSTEM IS A VIOLATION OF THE GENERAL DUTY CLAUSE UNDER CAA 112(r)(1).
B. FAILED TO DESIGN AND MAINTAIN A SAFE FACILITY BY NOT DEVELOPING WRITTEN PROCEDURES FOR THE OPERATION OF THE AMMONIA REFRIGERATION SYSTEM. RESPONDENT'S FAILURE TO DESIGN AND MAINTAIN A SAFE FACILITY BY NOT DEVELOPING OPERATING PROCEDURES FOR THE AMMONIA REFRIGERANT SYSTEM IS A VIOLATION OF THE GENERAL DUTY CLAUSE UNDER CAA 112(r)(1).
C. FAILED TO DESIGN AND MAINTAIN A SAFE FACILITY BY NOT INSTALLING PROTECTIVE GUARDING OR BARRICADING AROUND AMMONIA CONTAINING AIR COOLERS SUBJECT TO PHYSICAL DAMAGE. RESPONDENT'S FAILURE TO DESIGN AND MAINTAIN A SAFE FACILITY BY NOT INSTALLING PROTECTIVE GUARDING OR BARRICADING AROUND THE AMMONIA CONTAINING AIR COOLERS SUBJECT TO PHYSICAL DAMAGE IS A VIOLATION OF THE GENERAL DUTY CLAUSE UNDER CAA 112(r)(1).