EPA v. HOPEWELL PLANT (ADVANSIX RESINS & CHEMICALS, LLC)

Case summary

On February 22, 2023, EPA Region III issued an Administrative Compliance Order on Consent (Order) to AdvanSix Resins & Chemicals, LLC (AdvanSix), the owner and operator of a caprolactam manufacturing facility located in Hopewell, Virginia. AdvanSix is subject to Section 112(r)(7) of the CAA and the RMP Regulations because it is an owner or operator of a stationary source with more than a threshold quantity of regulated substances oleum (fuming sulfuric acid), ammonia (anhydrous), ammonia (concentration greater than 20%), acetaldehyde, and flammable mixture present in a process at the Facility. EPA alleges that AdvanSix is failing to comply certain mechanical integrity, process hazard analyses and process safety information requirements at the Facility, and therefore is operating in violation of Section 112(r)(7) of the CAA and the RMP Regulations. Specifically, the Order identifies the following compliance issues: failure to properly design oleum storage tank scrubber lines to prevent tank vent obstruction, failure to consider Bathtub Ring Corrosion as a risk for oleum storage tanks, failure to conduct linear UT scans of oleum storage tanks, failure to have proper pipe hangers/supports on piping associated with oleum and ammonia storage tanks, and failure to provide proper insulation on piping associated with ammonia storage tanks. The Order requires AdvanSix to retain a third-party contractor to assess the Facility's compliance with the Risk Management Program and conduct any necessary improvements to ensure compliance. The facility is located in an area of potential EJ concern. This case seeks to ensure that facilities that store extremely hazardous substances safely store their chemicals to reduce the likelihood of accidental chemical releases and the resulting potential harm to neighboring communities and the environment, which is especially important in potential EJ areas. The CAA Section 112(r) program is not delegated to Virginia, but Virginia has been notified of this action and has not raised any objections.

Defendants (1)

• HOPEWELL PLANTNamed in settlement

Facilities (8)

• HOPEWELL PLANT

  905 E RANDOLPH RD, HOPEWELL, VA, 23860

  Registry ID: 110000620221

• HOPEWELL PLANT

  905 E RANDOLPH RD, HOPEWELL, VA, 23860

  Registry ID: 110000620221

• HOPEWELL PLANT

  905 E RANDOLPH RD, HOPEWELL, VA, 23860

  Registry ID: 110000620221

• HOPEWELL PLANT

  905 E RANDOLPH RD, HOPEWELL, VA, 23860

  Registry ID: 110000620221

• HOPEWELL PLANT

  905 E RANDOLPH RD, HOPEWELL, VA, 23860

  Registry ID: 110000620221

• HOPEWELL PLANT

  905 E RANDOLPH RD, HOPEWELL, VA, 23860

  Registry ID: 110000620221

• HOPEWELL PLANT

  905 E RANDOLPH RD, HOPEWELL, VA, 23860

  Registry ID: 110000620221

• HOPEWELL PLANT

  905 E RANDOLPH RD, HOPEWELL, VA, 23860

  Registry ID: 110000620221

Statutes cited

• CAA 112[R][1] — Prevention of Accidental Release/General Duty Clause
• CAA 112[R][7] — Prevention of Accidental Release/Risk Management Plans (RMPs)

Enforcement conclusions (1)

• HOPEWELL PLANT (ADVANSIX RESINS & CHEMICALS, LLC)entered 2023-02-22

  Primary law: CAA

Timeline (3 milestones)

• 2023-02-22Final Order Issued
• 2023-02-23Enforcement Action Data Entered
• 2024-02-22Enforcement Action Closed