Respondent operates an ammonia refrigeration system which uses 30,345 pounds anhydrous ammonia (ammonia). Respondent has one RMProgram level 3 covered process, which stores or otherwise uses an extremely hazardous substance in an amount exceeding its applicable threshold of 10,000 pounds. On December 21, 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 ammonia refrigeration process at its stationary source.
During a walk-through of the Facility, the EPA inspectors made the following observations: