EPA v. Mennel Milling Company (Dowagiac) ESA

Case summary

This enforcement action was filed in response to violations discovered during a Risk Management Plan (RMP) compliance inspection conducted on 5/31/2012. Violations of CAA 112(r)(7) include: 1.) failure to review and update the offsite consequences analysis at least once every five years; 2.) failure to conduct process hazard analyses that address stationary source siting and human factors; 3.) failure to annually certify that operating procedures are current and accurate; 4.) failure to establish written operating procedures to maintain the integrity of process equipment such as the crane and the chlorine sensors; 5.) failure to perform inspections and tests on the crane at a frequency consistent with the manufacturer's recommendations and good engineering practices; 6.) failure to determine and document responses to each of the findings in their compliance audit including correction of the deficiencies.

Defendants (1)

• The Mennel Milling Company (Dowagiac, MI)Named in complaintNamed in settlement

Facilities (1)

• MENNEL MILLING COMPANY

  301 SOUTH MILL STREET, DOWAGIAC, MI, 49047

  Registry ID: 110000754504

Statutes cited

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

Enforcement conclusions (1)

• Mennel Milling Company (Dowagiac) ESAentered 2013-04-09

  Primary law: CAA

  Federal penalty: $3,780

Timeline (5 milestones)

• 2013-04-09Final Order Issued
• 2013-04-09Complaint Filed/Proposed Order
• 2013-04-09Enforcement Action Closed
• 2013-04-09Pipeline Closed
• 2013-04-12Enforcement Action Data Entered