Respondent owns and operates a refrigerated juice facility. On July 10, 2000, under Section 112(r) of the Act and implementing regulations at 40 C.F.R. Part 68, Respondent submitted to U.S. EPA an RMP for the Facility. According to the RMP submitted to U.S. EPA, the Facility is “frozen fruit, juice, and vegetable manufacturing”. They use anhydrous ammonia as a process chemical during its operations and held at least 10,000 lbs. of anhydrous ammonia. On September 6, 2011, U.S. EPA conducted an inspection at the facility to determine its compliance with 40 C.F.R. Part 68. For purposes of compliance with 40 C.F.R. Part 68 in its RMP, Respondent has acknowledged that it was required to meet Program 3 eligibility requirements. Based on the inspection conducted on September 6, 2011 and a review of additional information received by U.S. EPA subsequent to that date, it has identified the following alleged violations: