Respondent owns and operates a cellophane manufacturing facility that uses Carbon disulfide in excess of the 20,000 pounds RMP TQ. On or about September 11 and 12,2019, EPA conducted an inspection of 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 onsite greater than 20,000 pounds of carbon disulfide in a process, Respondent was subject to the requirements of Section 112(r) of the CAA and 40 C.F.R. Part 68 because it was an owner and operator of a stationary source that had more than a threshold quantity of a regulated substance in a process. From the time Respondent first had onsite greater than 20,000 pounds of carbon disulfide in a process, Respondent was subject to Program 3 prevention program requirements because pursuant to 40 C.F.R. § 68.1O(i), 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.
Allegations of Violations