Respondent is the owner and/or operator of a resin manufacturing plant. Respondent has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At all times relevant to the violations, Respondent had on-site for use 1,886,000 pounds of formaldehyde (solution) and 52,000 pounds of anhydrous ammonia. Respondent has six RMProgram level 3 covered processes, which store or otherwise use formaldehyde (solution) and anhydrous ammonia in amounts exceeding their applicable thresholds of 15,000 pounds and 10,000 pounds, respectively.
On April 18 – 20, 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, EPA observed the following: