From the time Respondent first had on site greater than 10,000 pounds of methyl mercaptan, isopropylamine, and/or dimethylamine in a process, and/or greater than 20,000 pounds of aqueous ammonia in a process, Respondent was subject to the requirements of 40 C.F.R. Part 68 because it was an owner and operator of a stationary source that had more than a threshold quantity of a regulated substance in a process. Respondent was subject to Program 3 prevention program requirements because one or more covered processes at its facility did not meet the eligibility requirements of Program 1, are in North American Industry Classification System code 325320, and are subject to the OSHA process safety management standard, 29 C.F .R. § 1910.119.
Allegations of Violations