At its stationary source, the Respondent operates a Polystrene Foam Production facility using butane and has 132,235 pounds of butane in onsite storage. At its stationary source, the Respondent has one RMProgram level 3 covered process, which processes butane in an amount exceeding its applicable threshold of 10,000 pounds. On August 30, 2018, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements, including the, implemented recognized and generally accepted good engineering practices (RAGAGEP) for its covered process at its stationary source.
At the time of the inspection, the Respondent was asked to: