EPA v. SABIC INNOVATIVE PLASTICS US LLC - 112R7 APO/CAFO

Case summary

This CAFO for SABIC Innovative Plastics US LLC (SABIC), Ottawa, Illinois resolves violations regarding the Chemical Accident Prevention Provisions (CAPP). The CAFO requires SABIC to pay a penalty of $12,569 and resolves the FOV issued to SABIC on December 6, 2023. SABIC owns and operates a plastics material and resin manufacturing plant that uses 1,3-butadiene and acrylonitrile as raw materials, which are regulated substances under the CAPP. 1,3-Butadiene can undergo hazardous reactions that, if not properly identified and managed, create the risk of an accidental release. The CAPP require the owner or operator of a process containing more than 10,000 pounds of 1,3-butadiene to identify, evaluate, and control the hazards involved in the process through a process hazard analysis (PHA), and to update and revalidate that PHA at least every five years. SABIC violated the CAPP by failing to adequately address the hazardous reactions of 1,3-butadiene, and the associated engineering and administrative controls for those hazardous reactions, in the PHA conducted for its 1,3-butadiene process in 2019. SABIC also violated the CAPP by failing to adequately address human factors in the 2019 PHA for safeguards identified in the PHA that require operator response. SABIC provided the EPA with an updated and revalidated PHA on September 9, 2024 that resolved the alleged violations in the 2019 PHA. SABIC receives acrylonitrile at the Facility via rail tank cars and unloads the cars into one of two 500,000-gallon tanks. SABIC stores rail tank cars full of acrylonitrile in the railyard adjacent to the Facility fence line prior to moving the cars to the unloading rack. The railyard storage of acrylonitrile in rail tank cars is a stationary source because the transportation containers are used for storage not incident to transportation. The acrylonitrile rail tank car storage process contained acrylonitrile above the 20,000 pound threshold quantity listed in the CAPP. SABIC?s Risk Management Plan (RMP) for the Facility that it submitted to the EPA on May 7, 2021 did not list acrylonitrile rail tank car storage as a covered process. On June 27, 2024, SABIC signed and certified its updated RMP submission for the Facility that included the acrylonitrile rail tank car storage process as a covered process. By failing to include railyard storage of acrylonitrile as a covered process in its RMP filing from at least May 7, 2021 until June 27, 2024, SABIC violated the CAPP by failing to submit a single RMP that included a registration that reflected all covered processes.

Defendants (1)

• SABIC INNOVATIVE PLASTICS US LLCNamed in complaintNamed in settlement

Facilities (1)

• SABIC INNOVATIVE PLASTICS US LLC

  2148 N 2753RD RD, OTTAWA, IL, 61350-9766

  Registry ID: 110000437661

Statutes cited

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

Enforcement conclusions (1)

• SABIC INNOVATIVE PLASTICS US LLC - 112R7 APO/CAFOentered 2024-09-20

  Primary law: CAA

  Federal penalty: $12,569

Timeline (3 milestones)

• 2024-09-20Final Order Issued
• 2024-09-20Complaint Filed/Proposed Order
• 2024-09-23Enforcement Action Data Entered