Respondent is an owner and operator of a petroleum refinery. Refining operations at the Facility are currently idled. EPA conducted an inspection of the Facility on September 20 – 26, 2022, to assess compliance with Section 112(r) of the CAA (the “Inspection”). During the Inspection, and in a letter dated October 13, 2022, EPA informed Respondent of observations made during the Inspection. EPA released its report for the Inspection on October 21, 2022. The Inspection included a review of available documentation and equipment at the Facility and an inventory of the contents of various systems and/or process units.
Facility equipment, vessels, and piping contained various materials, including, but not limited to, anhydrous ammonia, liquified (or liquid) petroleum gas (“LPG”), and hydrogen sulfide. Some of these materials are held under pressure.
During the Inspection, EPA inspectors toured and visually inspected the following process units at the Facility: