EPA v. BAE SYSTEMS ORDNANCE SYSTEMS, INC. (RADFORD ARMY AMMUNITION PLANT)

Case summary

On September 27, 2024, EPA Region 3 issued an Administrative Compliance Order on Consent (Order) to BAE Systems Ordnance Systems Inc., a United States Army contractor and the operator of the Radford Army Ammunition Plant, located in Radford, Virginia. The EPA alleges that BAE failed to follow the requirements of CAA Section 112(r)(7) and its accompanying regulations by failing to follow recognized and generally accepted good engineering practices ( RAGAGEP ) in the areas of process safety, process hazard analysis, mechanical integrity, compliance audits, and training. The EPA also alleges that BAE failed to follow the requirements of CAA Section 112(r)(1) by failing to design and maintain a safe facility related to a process involving ammonia under the threshold quantity and a process involving sulfuric acid. Under the Order, BAE will retain a third-party contractor to perform a compliance audit of the entire facility to determine compliance with CAA Sections 112(r)(1) and 112(r)(7). BAE will also retain a third-party contractor to undertake work to remedy certain conditions at the facility described in the Order. The facility is located in an area of potential EJ concern. This case seeks to ensure that the facility, which stores extremely hazardous substances, safely stores its 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 DEQ has been notified of this action and has not raised any objections.

Defendants (1)

• BAE SYSTEMS ORDNANCE SYSTEMS, INC.Named in settlement

Facilities (4)

• RADFORD ARMY AMMUNITION PLANT

  4050 PEPPERS FERRY ROAD, RADFORD, VA, 24143

  Registry ID: 110000601867

• RADFORD ARMY AMMUNITION PLANT

  4050 PEPPERS FERRY ROAD, RADFORD, VA, 24143

  Registry ID: 110000601867

• RADFORD ARMY AMMUNITION PLANT

  4050 PEPPERS FERRY RD, RADFORD, VA, 24141-0100

  Registry ID: 110000601867

• RADFORD ARMY AMMUNITION PLANT

  4050 PEPPERS FERRY RD, RADFORD, VA, 24141-0100

  Registry ID: 110000601867

Statutes cited

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

Enforcement conclusions (1)

• BAE SYSTEMS ORDNANCE SYSTEMS, INC. (RADFORD ARMY AMMUNITION PLANT)entered 2024-09-27

  Primary law: CAA

Timeline (3 milestones)

• 2024-09-27Final Order Issued
• 2024-10-02Enforcement Action Data Entered
• 2025-09-27Enforcement Action Closed