NOTE: this is the first citation that I am aware of from EPA’s amended RMP Emergency Planning requirements.
At the time of the Inspection, Respondent had not conducted annual coordination activities with local emergency planning and response organizations for the year 2020.
Notice that EPA did not seem to be concerned with the Global Pandemic, which was declared on March 11, 2020, by the World Health Organization (WHO). However, EPA conducted its inspection virtually in April 2021.
EPA conducted a virtual partial compliance evaluation of the Facility from April 14, 2021, to May 11, 2021, to determine the Respondent’s compliance with Section 112(r) of the CAA, 42 U.S.C. § 7412(r), and 40 C.F.R. Part 68. The Respondent separates and processes natural gas and natural gas liquids. The Respondent’s natural gas processes meet the definition of “process” and “covered process”, as defined by 40 C.F.R. § 68.3. The Respondent’s RMP program level 3 covered processes storing or otherwise using a regulated substance in an amount exceeding the applicable threshold.
EPA hereby states and alleges that Respondent has violated the CAA and federal regulations promulgated thereunder as follows: