Respondent owns or operates a closed-loop refrigeration facility which utilizes anhydrous ammonia at the Facility. The amount of ammonia is 13,800 pounds. The Facility is subject to the Program 3 eligibility requirements under the Clean Air Act. On August 11. 2011, an EPA representative conducted an inspection at the facility to determine whether the Facility was complying with Section 112(r) of the Act. On July 7, 2015, USEPA sent Respondent an information request to ascertain whether it was complying with the RMP regulations. Based on the inspection and the following information request, EPA determined that the Facility failed to comply with the RMP regulations for Program 3 Requirements as set forth in Paragraphs 35 through 59 of the CAFO, to wit: 1. Respondent failed to consider the greatest amount of anhydrous ammonia held in a single vessel to determine the worst case scenario from the refrigeration system that assumed a release of anhydrous ammonia; 2. Respondent's 2011 Process Hazard Analyses failed to address the components therein; 3. Respondent did not have a written mechanical integrity program; etc as outlined in the paragraphs 35 through 59 of the CAFO. A civil penalty of $43,500 was agreed upon.