Respondent is the owner and/or operator of a Brewery and 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:
- Respondent operates an ammonia refrigeration plant.
- Respondent has on-site for use, 160,300 pounds of anhydrous ammonia.
- Respondent has one RMProgram level 3 covered process, which stores or otherwise uses anhydrous ammonia in an amount exceeding its applicable threshold of 10,000 pounds.
On December 16, 2019, 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. At the time of the inspection, EPA observed the following: