Respondent owned and operated a pesticide and specialty chemical manufacturing facility located in Louisiana. On January 8, 2014, EPA Region 6 conducted an on-site CAA 40 C.F.R. Part 68 and Section 112(r) Partial Compliance Evaluation of the Facility. The facility has 11 regulated substances that are held above the threshold quantities identified in 40 C.F.R.§ 68.130. During a maintenance outage, Respondent installed a blind flange on a column stripper as an intended in-kind replacement. The blind flange corroded, causing a release of2.2 pounds of chlorine and 0.22 pounds of cyanogen chloride. Later analysis showed that the installed blind flange was made of carbon steel rather than titanium, which caused the corrosion and release. Here’s what EPA found: