SPECIAL NOTE: I normally do not post small cases like this; however, this case involves a facility not counting railcars that have been disconnected from their motive power in the Maximum Intended Inventory for the Process Quantaties.
On September 1, 2015 an authorized representative of the EPA conducted a compliance inspection of the Respondent’s facility to determine compliance with the Risk Management Program regulations. The EPA during the inspection and subsequent document review found that the Respondent had violated regulations implementing Section 112(r) of the CAA) by failing to comply with the regulations as noted below.