On or about March 30-April 1, 2010, EPA conducted an inspection at one facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. On or about September 27-29, 2010, EPA conducted another inspection of the business but at another facility in a different location to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. EPA alleges that Respondent has violated the CAA and federal regulations promulgated pursuant to the CAA. Respondent is subject to the requirements of Section 112(r) of the CAA and 40 C.F.R. Part 68 because it is an owner and operator of stationary sources that had more than a threshold quantity of a regulated substance in a process. Respondent is subject to Program 3 of the risk management program requirements because, pursuant to 40 C.F.R. ยง 68.10(d), the covered processes at the two facilities did not meet the requirements of Program 1 and were subject to the OSHA process safety management standard. Respondent was required under Section 112(r) of the CAA and 40 C.F.R. 68.12, to develop and implement a risk management program for each stationary source that includes a management system, a hazard assessment, a prevention program and an emergency response program, and to submit an RMP. Information collected during the inspection of Respondent’s two facilities revealed that Respondent failed to develop and implement risk management programs for each facility that complied with all the requirements of 40 C.F.R. Part 68. Specifically: