Respondent operates a dairy plant and has on-site, 13,000 pounds of anhydrous ammonia which is used in its ammonia refrigeration process. Respondent submitted a single RMPlan that included an accidental release prevention program, to the EPA for its stationary source. At its stationary source, the Respondent has one RMProgram level 3 covered process. On January 27, 2015, the EPA conducted an onsite inspection of the RMProgram related records and equipment to assess the Respondent’s compliance with the RMProgram requirements including the implemented recognized and generally accepted good engineering practices (RAGAGEP) for its covered processes at its stationary source.
During the inspection, the EPA requested and was provided process safety information. The process safety information contained no information with regard to: