It’s never a good sign when the EPA inspector is in the process and the operator’s personnel detector goes into alarm and the worried inspector is told… it was typical for the alarm to sound during sampling. This led the inspector to inquire about this level of exposure for a repeated task such as sampling and that opened the door to three (3) SOP findings!
Respondent operates a pulp bleaching mill that has on–site for use, 19,022 pounds of chlorine dioxide. The process is an RMProgram level 3 covered process, which stores or otherwise uses chlorine dioxide in an amount exceeding its applicable threshold of 1,000 pounds. On August 13, 2019, the EPA conducted an on–site inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and the implemented recognized and generally accepted good engineering practices (RAGAGEP) for its covered process at its Facility.