The Respondent owns and/or operates a chemical manufacturing facility that uses:
A. Oleum (fuming sulfuric acid) [sulfuric acid, mixture with sulfur trioxide] (“Oleum”);
B. Hydrogen fluoride/hydrofluoric acid (cone 50% or greater) [hydrofluoric acid] (“Hf “).
in a fluoroproducts process and a sulfuric acid process. From August 28 – 31, 2018, EPA conducted an inspection of the Respondent’s facility. In conference calls on May 5, 2020, June 8, 2020, July 21, 2020, and August 5, 2020, the EPA conferred with Respondent regarding the violations alleged herein and provided an opportunity for Respondent to submit additional information or materials, which the Respondent did. Based on Respondent’s submittal, the EPA identified the alleged violations: