The Facility uses, handles, and/or stores more than a threshold quantity of ammonia (anhydrous), ammonia (concentration 20% or greater), and chlorine, which are regulated substances, as specified at 40 C.F.R. §§ 68.115 and 68.130.
The Facility’s Cooling Tower 2 chlorine injection area contains up to 4,000 lbs of chlorine in two (2) 1-ton cylinders, above the chlorine RMP threshold quantity of 2,500 lbs set forth in 40 C.F.R. § 68.115. Respondent did not include the Cooling Tower 2 chlorine injection area as part of an RMP covered process. By failing to include the Cooling Tower 2 chlorine injection area as part of an RMP covered process, Respondent violated 40 C.F.R. § 68.10(a).