On February 26, 2019, an authorized representative of the EPA conducted an inspection of the International Paper Company facility located at 34040 Union Camp Drive in Franklin, VA, to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Clean Air Act (the Act or CAA). EPA found that the Respondent had violated regulations implementing Section 112(r) of the Act, specifically: ( 1) The facility failed to compile process safety information specifically for the relief system design and design basis for the process [68.65(d)(1 )(iv)]; and, (2) The facility failed to certify that the stationary source has
evaluated compliance with the provisions of the prevention program a least every three years to verify that the developed procedures and practices are adequate and being followed [68.79(a)).