Respondent operates a cold food storage facility and has on-site for use, 14,000 pounds of anhydrous ammonia for cold food storage purposes. The respondent’s process is an RMProgram level 3 covered process. On March 29, 2017, the EPA conducted an onsite 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 stationary source. A review of the piping and instrument diagram, dated February 5, 2016, for the Respondent’s engine room identified a valve labeled HV12NR2 on the piping and instrument diagram that…