EPA v. Real Alloy Specification, Inc. (Coldwater MI) ESA

Case summary

On June 25, 2016, an authorized EPA representative conducted a compliance inspection of Real Alloy Specification, 368 Garfield Avenue, Coldwater, Michigan 49306 to determine its compliance with the Risk Management Plan ( RMP ) regulations promulgated pursuant to Section 112(r) of the Act. EPA determined that Respondent violated the following regulations: (1) failed to maintain records on the offsite consequence analyses that included data used to estimate population and environmental receptors potentially affected. 2. Failed to compile process safety information pertaining to the technology of the process that included ventilation system design. 3. Failed to identify engineering and administrative controls applicable to the hazards and their interrelationships, specifically the scrubber system in their 2013 PHA. 4. Failed to identify consequences of failure of engineering and administrative controls, specifically the scrubber system in their 2013 PHA. 5. Failed to document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, description of the inspection or test performed, and the results of the inspection or test.. 6. Failed to promptly determine and document an appropriate response to each of the findings of the 2013 compliance audit and document that deficiencies have been corrected. The parties agreed to a settlement with a civil penalty of $3,300.00

Defendants (1)

• Real Alloy Specification, IncNamed in complaintNamed in settlement

Facilities (1)

• REAL ALLOY SPECIFICATION, INC.

  368 W. GARFIELD, COLDWATER, MI, 49036

  Registry ID: 110050463923

Statutes cited

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

Enforcement conclusions (1)

• Real Alloy Specification, Inc. (Coldwater MI) ESAentered 2017-05-22

  Primary law: CAA

  Federal penalty: $3,300

Timeline (5 milestones)

• 2017-05-22Complaint Filed/Proposed Order
• 2017-05-22Final Order Issued
• 2017-05-23Enforcement Action Data Entered
• 2017-05-24Pipeline Closed
• 2017-05-24Enforcement Action Closed