Respondent owns or operates three (3) fluid milk production facilities located in MI, IL, and MO (until operations ceased in 2014). At each of these facilities, Respondent operates or operated at all times relevant to this CAFO a closed-loop refrigeration system which utilizes or utilized anhydrous ammonia. Each system uses and stores, or used and stored at all times relevant to this CAFO, more than 10,000 lbs. of anhydrous ammonia. Respondent reported in its RMP for each facility that each refrigeration system was subject to the “Program 3” eligibility requirements because the process: (a) does or did not meet the requirements of 40 C.F.R. § 68.10(b), because the distance to a toxic or flammable endpoint for a worst-case release assessment conducted under Subpart Band 40 C.F.R. § 68.25 is or was greater than the distance to any public receptor; and (b) is or was subject to the OSHA process safety management standard set forth at 29 C.F.R. § 1910.119 and 40 C.F.R. § 68.10(d) because the process involves or involved anhydrous ammonia above its threshold quantity.