Respondent has a synthetic rubber manufacturing process at the facility that processes two petrochemicals, butadiene and styrene, and the temperature of the reaction is controlled by anhydrous ammonia. Respondent has greater than a threshold quantity of 1, 3-Butadiene and Ammonia (anhydrous) in a process at the Facility, meeting the “covered process” definition defined by 40 C.F.R. ยง 68.3.
Complainant hereby states and alleges that Respondent has violated the CAA and federal regulations promulgated thereunder as follows: