Respondent is the owner and/or operator of a facility that uses anhydrous ammonia in its chemical manufacturing process. EPA conducted an inspection of the Facility on April 13, 2016, to assess compliance with Section 112(r)(7) of the CAA (the “Inspection”) and the regulations at 40 C.F.R. Part 68. Respondent filed an RMP for the Facility with EPA on June 20, 2013, that, among other things, identified a covered anhydrous ammonia process at the Facility as a Program 3 process, and that specified a quantity of 44,000 pounds of anhydrous ammonia for this process. Respondent filed an updated RMP for the Facility with EPA on October 30, 2018.
As described in the Order, at the time of the Inspection, EPA identified the following: