If you ever wondered if the “inventory” in your railcars or tank trucks that are NOT attached to their mode of transportation (i.e. locomotive or tractor) is part of your threshold calculation, here’s your answer, eight railcars of Chlorine sitting on the property was tallied by EPA to establish the amount of the EHS on site.
Respondent is the owner of a ferric chloride manufacturing facility. The regulations (40 C.F.R. 68.3) define “process” as “any activity involving a regulated substance including any use, storage, manufacturing, handling, or on-site movement of such substances, or combination of these activities. For the purposes of this definition, any group of vessels that are interconnected, or separate vessels that are located such that a regulated substance could be involved in a potential release, shall be considered a single process.” The Respondent began operations at the Facility on or about September 6, 2010. The Respondent submitted to EPA its initial RMP for the Facility on or about October 17, 2011.