EPA has cited a “chemical distributor” $3,600 with RMP General Duty Clause citations using the International Fire Code as the RAGAGEP. EPA took issue with the facility’s storage of nitric acid (Chemical Abstract Services (“CAS”) Number 7697-37-2), sulfuric acid (CAS No. 7664-93-9), and hydrochloric acid (CAS No. 7647-01-0), all of which are extremely hazardous substances (EHS) pursuant to Section 112(r)(1) of the CAA. EPA found that the facility failed to satisfy the requirements of the General Duty Clause with respect to the storage and handling of its extremely hazardous substances by failing to design and maintain a safe facility in accordance with industry codes and standards (i.e. International Fire Code). Specifically, the facility failed to comply with the General Duty Clause as follows: