Respondent is the owner and/or operator of a public water treatment facility that uses chlorine in its water treatment process. The amount of chlorine on hand at the facility is up to 9,000 pounds. At all times relevant to this Consent Agreement and Final Order (CAFO), Respondent produced, processed, handled or stored chlorine at its above listed facility. On or about August 27-28, 2013, EPA conducted an inspection of Respondent's facility to determine compliance with the Emergency Planning and Community Right-to-Know Act ("EPCRA"), the release reporting provisions of the Comprehensive Environmental Response, Compensation and Liability Act ("CERCLA"), and Section 112(r) of the CAA and 40 C.F.R. Part 68. Information collected as a result of this inspection revealed that Respondent had greater than 2,500 pounds of chlorine in a process at the Respondent's facility. Chlorine is a regulated substance pursuant to 40 C.F.R. § 68.3. The threshold quantity for chlorine, as listed in 40 C.F .R. § 68.130, Table 1, is 2,500 pounds. EPA alleges that Respondent has violated the CAA and federal regulations, promulgated pursuant to the CAA, as follows:

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