A cheese manufacturing facility stores and uses anhydrous ammonia in its production process and the facility had present at the facility anhydrous ammonia in quantities exceeding 10,000 pounds during calendar years 1999 through 2011. On September 14, 2010, Respondent’s Risk Management Program, prepared pursuant to 40 C.F.R. ยง 68.12(d), failed to implement mandatory elements required by those provisions. Here is a breakdown of the deficiencies in Respondent’s Risk Management Program at its facility: