Respondent owns and operates a petrochemical facility which manufactures specialty chemicals in a variety of operating units. Respondent produces, processes, handles, or stores one or more regulated substances listed in 40 C.F.R. Part 68 above the threshold quantity. In April 2016, Respondent began work to replace a tube exchanger on the Petro I unit. The replacement tube exchanger was fabricated by a contract vendor off site and then delivered, installed, and insulated on site by contract personnel.  Approximately four weeks after start-up of the process, on August 19, 2016, a leak developed and over a 14-hour period released approximately 235 lbs of 1,3 Butadiene, 8,616 lbs of ethylene, and 4,857 lbs of ethane.  Ethylene, 1,3- Butadiene and Ethane are regulated substances pursuant to Section 112(r) of the CAA and 40 C.F.R. Part 68.

While investigating the cause of the release, Respondent discovered...

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