Respondent operated a facility (the “Facility”) to manufacture chlorine, bleach, and hydrochloric acid. Respondent produced, used, or stored more than 2,500 pounds of chlorine at the Facility and was subject to the requirements of CAA § 112(r)(7). Respondent produced, used, or stored hydrogen at the Facility and was subject to the requirements of CAA § 112(r)(1). Respondent was subject to Program 3 requirements because it had public receptors near the endpoint for the worst-case release and was subject to the OSHA process safety management standard set forth in 29 C.F.R. § 1910.119.
Based upon the information gathered during the Investigation, EPA determined that Respondent violated certain provisions of the CAA.