Respondent has submitted and registered an RMPlan to the EPA for its Stationary Source and has developed an RMProgram accidental release prevention program for the Stationary Source. At its Stationary Source, the Respondent operates a river barge terminal. The facility stores anhydrous ammonia and blends fertilizers for sale to farmers and cooperatives. Anhydrous ammonia is received via barge and rail, stored, and distributed for both direct application and for blending into mixed-grade fertilizers for crop production nutrients. Approximately, a maximum of 18,940,000 pounds of ammonia are on-site at any given time.  At its Stationary Source, the Respondent has one RMProgram level 3 covered process which stores or otherwise uses anhydrous ammonia in amounts exceeding its applicable threshold of 10,000 pounds. During calendar year 2014, EPA opened an RMProgram compliance monitoring investigation to determine Respondent's compliance with 40 C.F.R. Part 68 at its Stationary Source. As part of this investigation, EPA conducted an onsite inspection of RMProgram related records and equipment on July 24, 2014. The focus of the onsite inspection was to assess the Respondent's compliance with RMProgram requirements for its covered process.

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