This case arose from an anhydrous ammonia release that occurred on May 23, 2017, at the Big Bend Power Plant (“Big Bend”) in Tampa, Florida (“the worksite”), operated by Tampa Electric Company (“TECO”). The Department of Labor’s Occupational Safety and Health Administration (“OSHA”) conducted an investigation and subsequently issued a two-item citation to TECO for alleged violations of the Occupational Safety and Health Act of 1970 (the Act), 29 U.S.C. §§ 651–678, with proposed penalties of $18,108.00.