Penske operated a logistics facility owned by Kroger at the time that EPA inspected the Shelbyville facility (the Facility). Penske failed to design a ventilation system that is met design code standards. Penske also failed to address all the necessary hazard categories required in its process hazard analysis (PHA), failed to include someone knowledgeable in the ammonia refrigeration process in the PHA team, and failed to timely address recommendations from the PHA. Finally, Penske was late to complete a compliance audit that is due every three years.