Respondent owns and operates an ammonia refrigeration system at its meat processing facility which began operation in February 2019. The ammonia refrigeration system had an initial charge of 17,000 pounds of anhydrous ammonia when operations began, making the facility subject to requirements of Chemical Accident Prevention Provisions in accordance with 40 C.F.R. § 68.10(a) and the requirements of Program 3 in accordance with 40 C.F.R. § 68.10(i).
On November 11, 2019, EPA conducted an announced inspection of the facility. The facility provided numerous documents prior to and during the November 11, 2019 inspection. These documents were related to various aspects of its RMP including management system, process hazard analysis, operating procedures, training, mechanical integrity, management of change, hot work, and contractors.