On September 13, 2023, the EPA conducted an inspection at Respondent?s facility to determine its compliance with Section 112(r) of the CAA and the chemical accident prevention provisions of 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had 27,000 pounds of anhydrous ammonia (greater than the 10,000-pound regulatory threshold) in a process at its
facility. It is subject to Program 3 prevention requirements. During the inspection, the inspector collected information, documents, and photographs Using the collected information the following violations were found Failure to conduct a hazard assessment as required by 40 C.F.R. ? 68.20-42, Failure to implement Program 3 elements including compiling written process safety information before conducting a process hazard analysis, required by 40 C.F.R ?? 68.65-69, and establishing and implementing written procedures to manage changes as required by ?? 68.75-.79, Failure to document emergency response coordination activities, as required by 40 C.F.R. ? 68.93. These deficiencies are violation of C.F.R. ? 68 and Section 112(r) of the CAA, 42 U.S.C. ? 7412(r).