Respondent is the owner and/or operator of the Facility, which operates a chemical storage and distribution facility. The respondent had on-site storage for 50,000 pounds of cyclohexylamine, 1,800,000 pounds of chlorine, 1,500,000 pounds of sulfur dioxide (anhydrous), 265,000 pounds of ammonia (anhydrous), 350,000 pounds of ammonia (concentration 20% or greater), and 17,000 pounds of hydrofluoric acid.
Respondent has five (5) RMProgram level 3 covered processes and one (1) RMProgram level 2 process, which store or otherwise use cyclohexylamine, chlorine, sulfur dioxide (anhydrous}, ammonia (anhydrous}, ammonia (concentration 20% or greater), and hydrofluoric acid in amounts exceeding their applicable thresholds of 15,000 pounds, 2,500 pounds, 5,000 pounds, 10,000 pounds, 20,000 pounds, and 1,000 pounds, respectively.
On August 10, 2023, the EPA conducted an on-site inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and the implemented recognized and generally accepted good engineering practices (RAGAGEP} for its covered process at its Facility.
At the time of the inspection: