The defendant is the operator of a facility that handles, stores, and uses anhydrous ammonia in its industrial refrigeration system.
GENERAL ALLEGATIONS
At all relevant times, Defendant maintained a refrigeration system at the Facility and that system utilized, processed, handled, or stored anhydrous ammonia, a “regulated substance” under CAA Section 112(r)(3). EPA conducted an inspection of the Facility on July 21, 2014 (the “Inspection”). As a result of what was observed at the Inspection or the review of documents provided at the time of the Inspection or thereafter, EPA identified a number of violations of the CAA, as communicated to Defendant in a letter, dated September 23, 2015.