SPECIAL NOTE: This is the first time I have seen a penalty reduction from the COVID-19 impacts on the business.
Respondent operates an ammonia refrigeration process with 15,416 pounds of anhydrous ammonia. The Respondent has one RMProgram level 3 covered process, which stores or otherwise uses a toxic substance in an amount exceeding its applicable threshold of 10,000 pounds. On December 11, 2018, 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 stationary source.
At the time of the inspection: