Respondent owns and operates a controlled-temperature storage warehouse for food products. The Facility is located adjacent to Interstate 91 and east of the Quinnipiac River, within a mile of numerous shops and business and approximately 1 mile from several schools. Respondent uses anhydrous ammonia in a refrigeration “process”. In 2009, Respondent filed a Program 3 RMP for the Process and reported that it used 22,600 pounds of anhydrous ammonia. Respondent’s most recent RMP re-submission, in 2013, again reported that one Program 3 process uses 22,600 pounds of ammonia. Accordingly, the Process is a “covered process” subject to the provisions of Part 68 because Respondent “uses,” “stores,” and “handles” the RMP chemical anhydrous ammonia at the Facility in an amount greater than 10,000 pounds. According to Respondent’s RMP, there are public receptors within the distance to the endpoint for a worst case release of the amount of anhydrous ammonia used in the Process. Likewise, modeling performed by EPA indicates that the endpoint for a worst case release from each Process is greater than the distance to a public receptor. Additionally, the Process is subject to OSHA’s PSM requirements at 29 C.F.R. § 1910.119 because it uses anhydrous ammonia in an amount over the threshold quantity of 10,000 pounds. Therefore, in accordance with 40 C.F.R. § 68.10(a}-(d), Respondent’s use, storage, and handling of anhydrous ammonia in its Process is subject to the requirements of RMP Program 3. On October 18, 2012, EPA inspectors visited the Facility (“Inspection”) to assess Respondent’s compliance with Section 112(r) of the CAA and with Sections 302-312 of the Emergency Planning and Community Right-to-Know Act. Here is a breakdown of the citations: