EPA v. Total Logistic Control (Holland) CAFO

Case summary

This enforcement action was filed in response to violations discovered during a CAA 112(r)(7) Risk Management Program (RMP) inspection which was conducted on 5/14/2009. This complaint lists 30 counts of violation related to the RMP Program and PSM standard including 1.) failure to maintain records; 2.) failure to compile written process safety information; 3.) failure to establish a system to promptly address process hazard analysis; 4.) failure to develop and implement written operating and maintenance procedures; 5.) failure to either train or provide refresher training to each employee working with the anhydrous ammonia process; 6.) failure to ensure frequency of inspection and testing of process equipment; 7.) failure to properly investigate potentially hazardous incidents; 8.) failure to develop and implement safe work practices and 9.) failure to develop an adequate emergency response program for protecting public health and the environment.

Defendants (1)

• Ryder (Miami, FL) Parent CompanyNamed in complaintNamed in settlement

Facilities (1)

• TOTAL LOGISTIC CONTROL LLC

  449 HOWARD AVENUE, HOLLAND, MI, 49424

  Registry ID: 110009911970

Statutes cited

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

Enforcement conclusions (1)

• Total Logistic Control (Holland) CAFOentered 2012-01-03

  Primary law: CAA

  Federal penalty: $180,000

Timeline (6 milestones)

• 2012-01-03Final Order Issued
• 2012-01-03Complaint Filed/Proposed Order
• 2012-01-06Enforcement Action Data Entered
• 2013-01-20Demand for Stipulated Penalties
• 2013-01-20Enforcement Action Closed
• 2013-01-20Pipeline Closed