Respondent is the owner and/or operator of a gas processing plant that has on-site for use/storage 55,126 pounds of sulfur dioxide, 8,240 pounds of anhydrous ammonia, 130,000 pounds of butane, and over 10,000 pounds of hydrogen. Respondent has three RMProgram level 3 covered processes, which store or otherwise use sulfur dioxide, butane, and hydrogen. Sulfur dioxide, butane, and hydrogen are stored or used in amounts exceeding their applicable thresholds of 5,000 pounds, 10,000 pounds, and 10,000 pounds, respectively. Anhydrous ammonia is stored below the applicable threshold of 10,000 pounds; however, in extreme caution, the Respondent has registered the chemical for RMProgram level 3.
On September 28, 2021, the EPA conducted an on-site inspection of the RMProgram related records and equipment to assess the Respondent’s compliance with the RMProgram requirements and the implemented recognized and generally accepted good engineering practices (RAGAGEP) for its covered processes at its Facility. At the time of the inspection, or as otherwise indicated, EPA observed the following: