This inspection appears to have begun as an RMP GDC, but when the facility submitted an RMP after the first inspection, they stated the process was a Program 3, and thus it appears EPA paid them another visit. On both visits, EPA seems to have found items of concern.
Respondent is the owner and/or operator of a facility which uses anhydrous ammonia for industrial refrigeration. EPA conducted an inspection of the Facility on August 24, 2016 regarding compliance with the general duty clause provisions of Section 112(r)(1) of the CAA. Following this inspection, Respondent entered into an Administrative Order which addressed violations of the general duty, pursuant to Section 112(r)(1) of the CAA, to maintain a safe facility, regarding part of the anhydrous ammonia equipment at the Facility. EPA conducted a second inspection of the Facility on or about October 27, 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 or about November 8, 2016 that, among other things, identified a covered anhydrous ammonia process at the Facility as a Program 3 process, and that specified a quantity of 13,119 pounds of anhydrous ammonia for this process.