EPA v. MONOGRAM ASSEMBLED FOODS, LLC

Case summary

3/13/2023 - EXPEDITED SETTLEMENT AGREEMENT ISSUED ASSESSING A PENALTY OF $1,500. PENALTY DUE WITHIN 15 DAYS. ALLEGED VIOLATIONS: BASED ON A COMPLIANCE MONITORING INSPECTION CONDUCTED AT THE RESPONDENT'S FACILITY IN DICKSON, TE1RNESSEE, ON JULY 28, 2022, THE EPA ALLEGES THAT THE RESPONDENT VIOLATED THE ACT'S SECTION 112(R)(7), CHEMICAL ACCIDENT PREVENTION PROVISIONS, 42 U.S.C. ? 7412(R)(7), WHEN AT THE TIME OF INSPECTION, RESPONDENT DID NOT PROVIDE EVIDENCE THAT: IT DOCUMENTED THAT EQUIPMENT COMPLIES WITH RECOGNIZED AND GENERALLY ACCEPTED GOOD ENGINEERING PRACTICES AS REQUIRED BY 40 C.F.R. ? 68.65(D)(2), BECAUSE THERE WERE FOUR PRESSURE RELIEF VALVES THAT WERE REQUIRED TO BE REPLACED IN APRIL 2021, ACCORDING TO FACILITY RECORDS, BUT WERE STILL IN SERVICE. SECTION 13.1.1 OF AMERICAN NATIONAL STANDARDS INSTITUTE/INTERNATIONAL INSTITUTE OF AMMONIA REFRIGERATION (ANSI/HAR) 6 (2019) STATES, ALL PRESSURE RELIEF VALVES (PRVS) THAT RELIEVE TO ATMOSPHERE SHALL BE RECERTIFIED OR REPLACED ON THE 5-YEAR TIME-BASED FREQUENCY. SECTION 13.1.1.1 OF ANSI/IIAR 6 (2019) STATES, THE SERVICE LIFE OF THE PRV SHALL NOT EXCEED 5 YEARS OF SERVICE AFTER IT IS INSTALLED ON THE SYSTEM.

Defendants (1)

• MONOGRAM ASSEMBLED FOODS, LLCNamed in complaintNamed in settlement

Facilities (2)

• ODOM'S TENNESSEE PRIDE

  1655 OLD COLUMBIA ROAD, DICKSON, TN, 37055

  Registry ID: 110024598933

• ODOM'S TENNESSEE PRIDE

  1655 OLD COLUMBIA ROAD, DICKSON, TN, 37055

  Registry ID: 110024598933

Statutes cited

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

Enforcement conclusions (1)

• MONOGRAM ASSEMBLED FOODS, LLCentered 2023-03-13

  Primary law: CAA

  Federal penalty: $1,500

Timeline (4 milestones)

• 2023-03-13Complaint Filed/Proposed Order
• 2023-03-13Final Order Issued
• 2023-03-16Enforcement Action Closed
• 2023-03-29Enforcement Action Data Entered