EPA v. SPECIALTY SALES LLC (APO) (CAA 112r)

Case summary

On May 6, 2026, Region 10 filed a Consent Agreement Final Order with Specialty Sales LLC for violations of CAA 112(r) Risk Management Program and EPCRA 312 requirements at their facility in Jerome, Idaho that stores and uses the regulated substance, formaldehyde. Region 10 alleges Specialty Sales LLC violated the risk management provisions of Section 112(r)(7) of the CAA, 42 U.S.C. 7412(r)(7), and the Risk Management Program regulations at 40 C.F.R. Part 68, and EPCRA 312. The violations included failures to: Submit a Risk Management Plan when the regulated substance, formaldehyde, was first present on site above the threshold quantity of 15,000 pounds, since February 2017; assign responsible roles for a management system in developing, implementing and integrating risk management program elements; complete a hazard assessment for the worst-case release scenario analysis and alternative release scenario that meets programmatic requirements; complete the process safety information; track and document actions taken to resolve process hazard analysis findings and recommendations; have written operating procedures for temporary and emergency operations; document refresher training for their operators; document inspection and testing of process equipment following recognized and generally accepted good engineering practices (RAGAGEP); conduct and document compliance audits at least every three years after February 2017; document the implementation of the employee participation plan since 2021; conduct emergency response coordination with local emergency planning and response organizations; and correctly identify the emergency response agency in their Risk Management Plan. Under EPCRA 312, Specialty Sales LLC failed to timely submit their Emergency and Hazardous Chemical Inventory Form (Tier I or Tier II as described in 40 C.F.R. Part 370) to the State Emergency Response Commission, the Local Emergency Planning Committee, and the fire department for 2022 and 2021 calendar years. Under the terms of the agreement the company paid a penalty of $382,398 consisting of a $295,149 penalty for CAA 112(r) violations and a $87,249 penalty for EPCRA 312 violations. The company has returned to compliance.

Defendants (1)

• SPECIALTY SALES LLC DBA HOOFIN-IT LLCNamed in complaintNamed in settlement

Facilities (1)

• SPECIALTY SALES, LLC

  2341 SOUTH DAVIS STREET, JEROME, ID, 83338

  Registry ID: 110071449407

Statutes cited

• EPCRA 312 — Emergency and Hazardous Chemical Inventory Forms
• CAA 112[R][7] — Prevention of Accidental Release/Risk Management Plans (RMPs)

Enforcement conclusions (1)

• SPECIALTY SALES LLC (APO) (CAA 112r)entered 2026-05-07

  Primary law: CAA

  Federal penalty: $382,398

Timeline (4 milestones)

• 2026-03-09Enforcement Action Data Entered
• 2026-05-07Final Order Issued
• 2026-05-07Complaint Filed/Proposed Order
• 2026-06-03Enforcement Action Closed