The Respondent has two RMProgram covered processes which stores or otherwise uses chlorine and methyl chloride in amounts exceeding its applicable respective thresholds of 2,500 and 10,000 pounds. Based on an RMProgram compliance monitoring investigation initiated on January 15-16, 2013, the EPA alleges that the Respondent violated the codified rules governing the CAA Chemical Accident Prevention Provisions, because Respondent did not adequately implement provisions of 40 CFR Part 68 when it: