Respondent is the owner and/or operator of the Facility, which is a “stationary source” and has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At its Facility:
(a) Respondent operates an ammonia refrigeration plant.
(b) At all times relevant to the violations alleged, Respondent had on-site for use 15,000 pounds of anhydrous ammonia.
(c) Respondent has one (1) RMProgram level 3 covered process
On July 16, 2024, 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: