Respondent operates a chemical manufacturing facility which has on-site for use, 25,299,678 pounds of anhydrous ammonia and 355,094 pounds of ammonia (concentration 20% or greater). Respondent has two RMProgram level 3 covered processes, that store or otherwise use anhydrous ammonia and ammonia (concentration 20% or greater) in amounts exceeding their applicable thresholds of 10,000 pounds and 20,000 pounds, respectively.
On August 30 through September 1, 2022, 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: