Respondent is the “owner or operator” of the Facility that uses, handles, and/or stores as much as 7,810 pounds of sulfur dioxide (anhydrous). Respondent’s RMP describes a covered process, furnace off-gas handling, that is subject to Program 3 requirements. On July 25, 2022, and July 26, 2022, authorized representatives of the EPA conducted an inspection of the Facility to assess compliance with section 112(r)(7) of the CAA and 40 C.F.R. part 68 (Inspection).
During the Inspection, the EPA representatives observed alleged violations of section of the CAA and 40 C.F.R. part 68. The alleged violations identified by authorized representatives of the EPA during the Inspection are described in Section V of this Agreement, below.