Respondent is the owner and operator of an ammonia and fuel retail business. On or about June 12, 2014 EPA inspected the facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. At the time of the 2014 inspection, Respondent had greater than 10,000 pounds of anhydrous ammonia stored in a process (bulk storage tanks) at the facility. Respondent's storage of ammonia at the facility began in approximately October 2012. Anhydrous ammonia is a regulated substance pursuant to 40 C.F.R. § 68.3. The threshold quantity for anhydrous ammonia, as listed in 40 C.F.R. § 68.130, Table 1, is 10,000 pounds.  As alleged below, information collected as a result of the 2014 Inspection revealed that at the facility Respondent had failed to properly develop and implement the risk management program required by Section 112(r) of the CAA and 40 C.F.R. Part 68.

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