EPA ISSUED A NOTICE OF VIOLATIONS, ADMINISTRATIE ORDER AND REQUEST FOR INFORMATION PURSUANT TO SECTION 112(r) OF THE CLEAN AIR ACT TO MANN CHEMICAL, LLC, A CHEMICAL MANUFACTURING AND DISTRIBUTOR FACILITY LOCATED IN WARWICK, RI. MANN EMPLOYS APPROXIMATELY TEN EMPOLYEES AT THE FACILITY, WHICH INCLUDES A 35,000 SQUARE FOOT CHEMICAL STORAGE WAREHOUSE. THE FACILITY STORES AND PROCESSES HYDROFLUORIC ACID, HYDROCHLORIC ACID, NITRIC ACID, ACETIC ACID, FORMIC ACID, PHOSPHORIC ACID, HYDROGEN PEROXIDE, SODIUM HYPOCHLORITE, SODIUM HYDROXIDE, POTASSIUM HYDROXIDE, PROPYLENE GLYCOL, POTASSIUM PERMANGANATE, AMMONIUM BIFLUORIDE, ACETONITRILE, TETRAHYDROFURAN, METHANOL, PENTANE, HEXANE, HEPTANE, AND OTHER CHEMICALS.
THE TWO VIOLATIONS IDENTIFIED ARE, FIRST, THE FAILURE TO IDENTIFY, EVALUATE AND CONTROL HAZARDS AT THE FACILITY, IN VIOLAITON OF THE RISK MANAGEMENT PROGRAM REQUIREMENTS AND GENERAL DUTY CLAUSE OFSECTION 112(r) OF THE CAA. THE SECOND VIOLATION IS THE FAILURE TO SUBMIT AN RMP DOCUMENTING COMPLIANCE WITH THE ELEMENTS OF A PROGRAM 2 RISK MANAGEMENT PROGRAM FOR ITS HYDROFLUORIC ACID (CONCENTRATION 70%). SPECIFICALLY, MANN DID NOT DEVELOP MANAGEMENT SYSTEMS FOR THE HYDROFLUORIC ACID; CONDUCT A HAZARD REVIEW FOR THE HYDROFLUORIC ACID; IMPLEMENT THE PROGRAM 2 PREVENTION REQUIREMENTS; OR DEVELOP AND IMPLEMENT AN EMERGENCY RESPONSE PROGRAM. THE ADMINISTRATIVE ORDER REQUIRES THE FACILITY TO ADDRESS PROBLEMS INVOLVING SECONDARY CONTAINMENT, LACK OF SEPARATION OF INCOMPATIBLE PRODUCTSS, AND