Respondent operates a food manufacturing process involving ammonia refrigeration with more than 10,000 pounds of anhydrous ammonia on site. Respondent has an RMProgram level 3 covered process, which stores or otherwise uses anhydrous ammonia in an amount exceeding its applicable threshold of 10,000 pounds. On February 27, 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. At the time of the inspection, EPA observed the following: