The Facility is a colloidal and polymer blend manufacturing facility. The Facility has used Epichlorohydrin and Dimethylamine to manufacture chemicals on site since at least 1999. The Facility maintains a maximum inventory of 235,000 pounds of the regulated toxic substance Epichlorohydrin, as determined under 40 C.F.R. § 68.115, which exceeds the threshold quantity of 20,000 pounds of Epichlorohydrin as set forth at Table 1 to 40 C.F.R. § 68.130. The Facility maintains a maximum inventory of 52,000 pounds of the regulated flammable substance Dimethylamine in an aqueous solution, as determined under 40 C.F.R. § 68.115, which exceeds the threshold quantity of 10,000 pounds of Dimethylamine as set forth at Table 3 to 40 C.F.R. § 68.130.
At the Facility, NC offloads the regulated substances Epichlorohydrin and Dimethylamine from trucks into one of two storage tanks, then routes them to two reactors for batch production of chemicals. The Respondents’ process for chemical manufacturing that use Epichlorohydrin and Dimethylamine at the Facility was and is a “Covered Process,” and as that term is defined at 40 C.F.R. § 68.3.
On October 25 and 26, 2021, EPA conducted an announced inspection at the Facility (October 2021 inspection). During the October 2021 inspection, EPA inspectors reviewed numerous documents provided by the Respondents. The documents included aspects of the Facility’s RMP involving the management system, PHA, operating procedures, training, mechanical integrity, management of change, hot work, and contractors. Information gathered during the inspection EPA conducted, identified the following violations of CAPP requirements: