On December 2, 2018, Respondent was conducting maintenance on its covered process. During the transfer of anhydrous ammonia, the mechanical seal on a pump cracked as a result of the cold anhydrous ammonia coming into contact with the warm shaft seal in the pump, resulting in a release of 3,407 pounds of anhydrous ammonia. At the time of the incident, Respondent did not have adequate operating procedures for the safe transfer of ammonia during the temporary maintenance on pumps that have been isolated and evacuated for extended periods. Following the incident, Respondent modified its operating procedures and conduct training to prevent recurrence. EPA finds Respondent did not develop and implement written operating procedures that provided clear instructions for safely conducting activities of a covered process during temporary operations in violation of 40 CFR 68.69(a)(1)(iii).