EPA v. Crystal Distribution Services, Inc. CAA 113D1 Action For Penalty

Case summary

On September 13, 2023, the EPA conducted an inspection at Respondent?s facility to determine its compliance with Section 112(r) of the CAA and the chemical accident prevention provisions of 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had 27,000 pounds of anhydrous ammonia (greater than the 10,000-pound regulatory threshold) in a process at its facility. It is subject to Program 3 prevention requirements. During the inspection, the inspector collected information, documents, and photographs Using the collected information the following violations were found Failure to conduct a hazard assessment as required by 40 C.F.R. ? 68.20-42, Failure to implement Program 3 elements including compiling written process safety information before conducting a process hazard analysis, required by 40 C.F.R ?? 68.65-69, and establishing and implementing written procedures to manage changes as required by ?? 68.75-.79, Failure to document emergency response coordination activities, as required by 40 C.F.R. ? 68.93. These deficiencies are violation of C.F.R. ? 68 and Section 112(r) of the CAA, 42 U.S.C. ? 7412(r).

Defendants (1)

• Crystal Distribution Services, Inc.Named in complaintNamed in settlement

Facilities (1)

• CRYSTAL DISTRIBUTION SERVICES, INC.

  1442 SYCAMORE STREET, WATERLOO, IA, 50703-4857

  Registry ID: 110000512204

Statutes cited

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

Enforcement conclusions (1)

• Crystal Distribution Services, Inc. CAA 113D1 Action For Penaltyentered 2025-07-24

  Primary law: CAA

  Federal penalty: $85,956

Timeline (4 milestones)

• 2025-07-24Complaint Filed/Proposed Order
• 2025-07-24Enforcement Action Data Entered
• 2025-07-24Final Order Issued
• 2025-08-22Enforcement Action Closed