The Respondent owns and operates a bleach manufacturing facility, which operates a bleach manufacturing process (the Process) and maintains a maximum chlorine inventory greater than the threshold quantity of 2,500 pounds. The Process is subject to OSHA’s process safety management standard, 29 C.F.R. § 1910.119, because the Process involves greater than the threshold quantity of 1,500 pounds of chlorine, a chemical listed in Appendix A to 29 C.F.R. § 1910.119. The Facility is subject to the requirements of CAPP in accordance with 40 C.F.R. § 68.10.
The worst-case release scenario models a distance to end point that has public receptors within its radius, therefore the Facility does not meet the criteria to be classified as Program 1 in accordance with 40 C.F.R. § 68.10(g). The facility is subject to Program 3 because the process is subject to the OSHA process safety management standard, 29 C.F.R. § 1910.119, in accordance with 40 C.F.R. § 68.10(i).
On August 10, 2021, EPA conducted an announced inspection of the Facility, at which time the Facility provided numerous documents for the Inspection. These documents were related to various aspects of its Program 3 RMP, including hazard assessment, the Program 3 prevention program, emergency response, and the RMP.