Respondent owned and operated a chemical manufacturing facility that produces anhydrous ammonia at a quantity of approximately 1,500 tons per day. The produced ammonia is used on site for the production of granulated fertilizers. Ammonia (anhydrous) is identified at 40 C.F.R. Part 68.130 as a toxic regulated substance with a threshold quantity of 10,000 pounds. Based on the quantity of regulated substances present at the facility, the facility’s NAICS code, and an evaluation of off-site receptors, the covered processes at Respondent’s facility are subject to Program 3 of the RMP regulations, 40 C.P.R.§§ 68.65-87. On November 5, 2015, Respondent reported a release of 5,995 pounds of anhydrous ammonia to the National Response Center, the XXXXXX Parish EOC, and the Louisiana State Police. The release occurred during an emergency shutdown process of a section of the ammonia plant during a plant upset caused by the mechanical failure of an upstream pump. Delay in initiating written emergency shutdown procedures caused the pressure to increase in the 116-P refrigeration vessel, which vented ammonia into the atmosphere through a pressure relief valve.