EPA RMP citations @ Chlor-alkali manufacturer (Cl2 & $87K)

On August 18, 2018, the EPA issued to Respondent a Notice of Potential Violation (“NOPV”), providing notice that the EPA found that Respondent had potentially committed the alleged violations described in Section V of this Agreement and providing Respondent an opportunity to confer with the EPA. On February 14, 2019, representatives of Respondent and the EPA discussed the August 18, 2018, NOPV.  For purposes of this Agreement:

1. At its stationary source, the Respondent operates a chemical manufacturing process;
2. On December 20, 2017, the EPA conducted an onsite 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 stationary source;
3. At its stationary source, the Respondent, at the time of inspection, had 37,680,000 pounds of chlorine on site for manufacturing Chlor-alkali products;
4. At its stationary source, the Respondent, at the time of inspection, had one RMProgram level 3 covered process, which stores or otherwise uses chlorine in an amount exceeding its applicable threshold of 2,500 pounds;

At the time of the inspection: