PLEASE NOTE this entire inspection citation is based on the facility not having their piping labeled per ASME A13.1 – A13.1-2015, Scheme for the Identification of Piping Systems
Respondent is the owner of a polymer manufacturing plant and based on the observations of EPA inspectors during the Inspection, EPA has determined that Respondent has handled and handles a maximum of approximately 70,000 pounds of ethylenediamine, 210,000 pounds of ethylene oxide, 400,000 pounds of propylene oxide, and 6,900,000 pounds of toluene diisocyanate at the Facility. Each of the substances, ethylenediamine, ethylene oxide, propylene oxide and toluene diisocyanate, is a regulated toxic substance for purposes of Section 112(r)(7) of the CAA because each is listed pursuant to Section 112(r)(3) of the CAA, at 40 C.F.R. § 68.130. The threshold quantity for each of the four regulated toxic substances is 10,000 pounds for ethylene oxide, propylene oxide and toluene diisocyanate and 20,000 pounds for ethylenediamine pursuant to 40 C.F.R. § 68.130, Table 1. More than a threshold quantity of a regulated substance is present in a process at the Facility.
On March 13, 2019, EPA conducted an inspection of the Facility to determine whether Respondent was in compliance with Section 112(r) of the CAA and the RMP Regulations.