EPA has determined that Respondent violated the Risk Management Program (RMP) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Clean Air Act (CAA), as noted on the enclosed Risk Management Plan Inspection Findings and Alleged Violations Summary (“Summary”), which is hereby incorporated by reference. In consideration of the penalty assessment factors and upon consideration of the entire record, the parties enter into the ESA in order to settle the violations described in the enclosed Summary for the total penalty amount of $14,700.
PROCESS/NAICS CODE: 325211
PROGRAM LEVEL: 3
REGULATED SUBSTANCE: Vinyl acetate monomer
MAX. QUANTITY IN PROCESS (lbs.): 280,000
Four EPA representatives and an EPA contractor inspected the Specialty Polymers, Inc. facility on March 22, 2018. Based upon this inspection the Specialty Polymers, Inc. facility Is In violation of the following risk management program elements: