Respondent is a municipality which owns and operates a Water Treatment Plant. On or about May 16-17, 2016, EPA inspected the Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. From the time Respondent first had on site greater than 2,500 pounds of Chlorine in a process, Respondent was subject to Program 3 prevention program requirements because pursuant to 40 C.F.R. § 68.10(d), the covered process at its facility did not meet the eligibility requirements of Program 1 and was subject to the OSHA process safety management standard, 29 C.F.R.§ 1910.119.
NOTE: this is a significant case, as the SEP requires the WTP to end their use of elemental Cl2 and convert their system over to sodium hypochlorite (e.g., “Bleach”)
Allegations of Violation