Respondent operates a “stationary source” and has registered an RMPlan with the EPA for its stationary source and has developed an RMProgram accidental release prevention program for the stationary source. Respondent operates an ammonia refrigeration process that has 13,000 pounds of ammonia in onsite storage. Respondent has one RMProgram level 3 covered process. On March 13, 2018, the EPA conducted an onsite 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 for its covered process at its stationary source.
The Respondent could not document that the following equipment complied with recognized and generally accepted good engineering practices…