Respondent was the owner or operator of a pulp and paperboard manufacturing facility. At all times relevant to this Consent Agreement, Respondent was in charge of the Facility. At all times relevant to this Consent Agreement, Respondent produced, used, or stored chlorine at the Facility. Chlorine is a “hazardous substance” listed in 40 C.F.R. Part 302, Table 302.4, and an “extremely hazardous substance” listed in 40 C.F.R. Part 355, Appendices A and B, with a reportable quantity of 10 pounds over any continuous 24-hour period.
The facility had four (4) reportable Cl2 releases over a 3-year period.