Respondent operates an ammonia refrigeration plant with 50,629 pounds of anhydrous ammonia which is an RMProgram level 3 covered process. On March 27, 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 stationary source. During the inspection, EPA conducted a walkthrough of the Facility and found the following occurrences where the Respondent failed to document that equipment complies with RAGAGEP: