EPA conducted an inspection of the Facility on December 4, 2012. The Inspection was conducted to determine the Facility’s compliance with Sections 112(r)(7) and 112(r)(1) of the CAA, the RMP accident prevention program and the General Duty Clause, respectively. At the time of the Inspection, Respondent had designated the Facility as an RMP Program Level 3 facility. Respondent stored its chlorine gas in one-ton and 150-pound cylinders. At the time of the Inspection, Respondent stored up to a maximum of 11,750 pounds of chlorine gas at the Facility in the chlorine tank room. In February 2014, the WWTP modified its operations by removing all chlorine gas from the Facility and substituting the gas with sodium hypochlorite, a much less hazardous chemical. Accordingly, the WWTP is no longer required to maintain an RMP. Respondent spent in excess of seventeen million dollars to complete the chlorine gas removal project. But before they went with sodium hypochlorite, here are the EPA citations: