Respondent is the owner and/or operator of a candy manufacturing facility, which has registered an RMPlan with the EPA for its Facility and has developed an RMProgram accidental release prevention program for the Facility. At its Facility:
a. Respondent produces food products
b. Respondent has on-site for storage, 18,000 pounds of anhydrous ammonia
c. Respondent has one RMProgram level 3 covered process, which stores or otherwise uses a toxic substance in an amount exceeding its applicable threshold of 10,000 pounds
On February 25, 2020, the EPA conducted an on-site 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 Facility.
During a walk-through of the Facility, the EPA inspectors made the following observations: