At all times relevant to this Complaint, Respondent owned and operated buildings, structures, installations, equipment, pipes or pipelines, and storage containers, located on a single site or on contiguous or adjacent locations, where it deposited, stored, disposed of, or placed, Ammonia CAS# 7664-41-7. Ammonia CAS# 7664-41-7 was a “hazardous substance” as that term was defined under Section 101(14) of CERCLA and had a reportable quantity of 100 pounds.
Between June 21 and July 19, 2013, Respondent spilled, leaked, emitted, discharged, or allowed to escape or leach, into the ambient air, approximately 34,000 pounds of
Ammonia CAS# 7664-41-7.