Respondent owns and operates a potato processing facility which is located, according to the U.S. Census data from 2010, from a few thousand people who live near the Facility. The Facility is located within 0.25 miles of Route 1 and 0.5 miles from the downtown area. Respondent uses anhydrous ammonia in a refrigeration process (“the Process”). On June 25, 2004, Respondent completed its first Process Hazard Analysis (“PHA”) for the Facility and on July 2, 2004, Respondent filed a Program 3 RMP for the Process (“the 2004 RMP”). In the 2004 RMP, Respondent reported that it used 11,500 pounds of anhydrous ammonia and the largest vessel at Facility contained 7,800 pounds of ammonia. On October 15, 2014, EPA inspectors visited the Facility and performed an inspection (“the Inspection”) to assess Respondent’s compliance with Section 112(r) of the CAA. The Inspection and EPA’s review of subsequently submitted information, including the 2004 RMP and the 2014 RMP submissions, revealed some potentially dangerous conditions relating to the Process beginning in July 2004 and continuing until at least the time of the Inspection, including: