EPA v. CSL Behring LLC (Bradley IL) CAFO

Case summary

The Respondent, CSL Behring LLC, is an Illinois company with a plant located at 1201 N. Kinzie Avenue, Bradley, Illinois, 60195, and is engaged in the business of manufacturing biotherapies derived from human plasma. Respondent operates a two-stage refrigeration system which utilizes anhydrous ammonia as a refrigerant. Respondent uses and stores up to 130,000 pounds of anhydrous ammonia in the refrigeration system. The facility is subject to the ?Program 3? eligibility requirements. On May 3, 1999, the Respondent had present at the facility an amount of anhydrous ammonia greater than the threshold quantity listed in 40CFR Section 68.130, and because of this, Respondent was required to submit an RMP no later than June 21, 1999. On June 18, 1999 Respondent?s predecessor Aventis Behring LLC submitted an AMP, with subsequent updates and revisions submitted on October 4, 2000. October 27, 2000, November 23, 2004 and May 17, 2010. On August 11. 2009, an EPA representative inspected the facility under Section 114 of the Clean Air Act. On December 12, 2011 and again on March 8, 2012, EPA requested additional information from Respondent. Based on the inspection and subsequent requests for information, EPA determined that the Facility failed to comply with the RMP regulations for Program 3 requirements by: (1) failing to document the names or positions of people with responsibility under the regulations and the relevant lines of authority; (2) failing to review operating procedures as often as necessary to assure that they reflect current operating practice; (3) failing to certify operating procedures annually; (3) failing to provide refresher training at least every three years; (4) failing to conduct inspection and testing following recognized and generally accepted good engineering practices; (5) failing to replace or test 194 pressure relief valves every 5 years of service; (6) failing to conduct a 5-yesar independent thorough inspection of the ammonia refrigeration system, and (7) failing to inspect all the piping in the refrigeration system. It was determined that an appropriate civil penalty to settle this action was $62,780.00, payable within 30 days after the effective date of this CAFO.

Defendants (1)

• CSL Behring LLCNamed in complaintNamed in settlement

Facilities (2)

• CSL BEHRING LLC

  1201 NORTH KINZIE, BRADLEY, IL, 60915

  Registry ID: 110000557594

• CSL BEHRING LLC

  1201 NORTH KINZIE, BRADLEY, IL, 60915

  Registry ID: 110000557594

Statutes cited

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

Enforcement conclusions (1)

• CSL Behring LLC (Bradley IL) CAFOentered 2015-02-24

  Primary law: CAA

  Federal penalty: $62,780

Timeline (6 milestones)

• 2015-02-24Final Order Issued
• 2015-02-24Complaint Filed/Proposed Order
• 2015-02-24Compliance Achieved
• 2015-03-06Pipeline Closed
• 2015-03-06Enforcement Action Data Entered
• 2015-03-06Enforcement Action Closed