NOTE: this case has some very interesting citations and used RAGAGEPs that may not be the best fit, but when a facility does not adopt a RAGAGEP, EPA (and OSHA) will be more than happy to “suggest” one in their citations!
Respondent is the owner and/or operator of a natural gas processing facility. The Facility uses, handles, and/or stores more than a threshold quantity of a flammable mixture and anhydrous ammonia, both regulated substances, listed under 40 C.F .R. § 68.130. Respondent is required to prepare and implement a RMP to detect and prevent or minimize accidental releases of such substances. Respondent meets the Program 3 eligibility requirements. ‘
On April 27, 2016, an authorized representative of the EPA conducted an inspection of the Facility, with the consent of Respondent, to determine compliance with the CAA section 112(r)(7). During the inspection, the EPA representative observed alleged violations of the CAA section 112(r)(7). The alleged violations are described below:
ALLEGED VIOLATIONS