The Respondent operates a wastewater treatment plant where Chlorine, propane, and sulfur dioxide (anhydrous) are present above their thresholds. The Respondent operates a wastewater chlorination process at the stationary source. 40 C.F.R. § 68.130 specifies a 2,500-pound threshold for chlorine, a 10,000-pound threshold for propane, and a 5,000-pound threshold for sulfur dioxide (anhydrous). The Respondent’s facility has propane in exceed of the 10,000-pound threshold, however, such propane is not used in the wastewater chlorination process. Therefore, the Respondent’s facility is not subject to the “Program 3” requirements of the RMP regulations for the regulated substance of propane. The facility must still comply with the Program 3 Prevention Program of 40 C.F.R. Part 68, Subpart D for the Cl2 and SO2. The wastewater chlorination process is subject to the “Program 3” requirements of the RMP regulations and must, among other things, comply with the Program 3 Prevention Program of 40 C.F.R. Part 68, Subpart D.
On or about June 13, 2019, a representative of EPA conducted an inspection of the Respondent’s facility.
VIOLATIONS