Respondent owns and operates a chemical manufacturing plant that produces oleum, anhydrous sulfur dioxide, sulfuric acid, and ammonium thiosulfate. Respondent re-submitted an RMP for the Facility on February 11, 2022 (2022 RMP) that identifies the following three covered processes that are subject to the Program 3 requirements of the CAPP:
a. Oleum Process, which contains the regulated toxic substance oleum at a quantity of 968,400 pounds;
b. Sulfur Dioxide Process, which contains the regulated toxic substance anhydrous sulfur dioxide at a quantity of 1,614,000 pounds; and
c. Ammonia Thiosulfate Production Process (ATS Process), which contains the regulated toxic substance anhydrous ammonia at a quantity of 907,440 pounds.