Respondent operates a an unmanned gas processing plant that has on-site for storage, 154,110 pounds of flammable mixture. The process is a RMProgram level 2 covered process, which stores or otherwise uses a flammable mixture in an amount exceeding its applicable threshold of 10,000 pounds. On April 23, 2014, the EPA contractor conducted an on-site inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and the implemented recognized and generally accepted good engineering practices (RAGAGEP) for its covered process at its stationary source.
At the time of the inspection…