Respondent is the owner of a food transfer and storage facility and according to their risk management plan for the Facility, Respondent uses approximately 25,225 pounds of anhydrous ammonia in its closed-loop industrial ammonia refrigeration system. On October 2, 2018, EPA conducted an inspection of the Facility to determine whether Respondent was in compliance with Section 112(r) of the CAA, and the RMP Regulations (the “CAA Inspection “). EPA’s CAA Inspection revealed the following instances in which Respondent has not complied with Section 112(r)(7) of the CAA, and the RMP Regulations.