On November 1 through November 4, 2016, representatives from the U.S. Environmental Protection Agency (“EPA”) Region IX conducted an inspection of the XXXXXXXX refinery. EPA’s inspection was conducted to determine compliance with the Risk Management Program (“RMP”) promulgated under Section 112(r)(7) of the Clean Air Act (“CAA”‘), and the General Duty Clause under Section 112(r)(l) of the CAA. The inspection primarily focused on three principal elements of the RMP:
- the Management System used by the facility to implement the RMP;
- the supporting documentation for Off-site Consequence Analyses (“OCA”); and
- the operation of the Hydrofluoric Acid (“HF”) Alkylation Unit including targeted Piping and Instrumentation Diagram (P&ID) field verifications of process and safety equipment within the unit.
A summary of the inspection findings is provided herein for your information and response. These findings describe conditions observed at the facility at the time of the inspection and subsequently provided in the the facility’s document submittals dated November 4 and November 23, 2016, for potential areas of noncompliance with CAA RMP regulations as set forth in 40 C.F.R. Part 68 and the General Duty Clause under Section 112(r)(l) of the CAA. Any omissions in the report shall not be construed as a determination of compliance with those portions of 40 C.F.R. Part 68 or any other applicable regulations.
With this letter and its enclosure (“Findings and Information Request”), EPA seeks additional information and documents concerning compliance with Section 112(r) of the CAA and the regulations thereunder at 40 C.F.R. Part 68. This information Request is authorized pursuant to Section 114 of the CAA, 42 U.S.C. ยง 7414.
Notice of Inspection Findings
This summary of inspection findings describes conditions observed at the Facility at the time of the inspection combined with reviews of documentation and identifies potential areas of noncompliance with CAA RMP regulations as set forth in 40 C.F.R. Part 68 and the General Duty Clause under Section 112(r)(l) of the CAA. Any omissions below shall not be construed as a determination of compliance with those portions of 40 C.F.R. Part 68 or any other applicable regulations.