According to the RMP submitted to U.S. EPA, the Facility fell within NAICS Code 48699, as “all other pipeline transportation”, used ethyl mercaptan and other flammable mixtures as process chemicals during its operations and held at least 10,000 lbs. of ethyl mercaptan and other flammable mixtures. Respondent was required to meet Program 3 eligibility requirements at the facility. On March 21, 2011, U.S. EPA conducted an inspection at the facility to determine its compliance with 40 C.F.R. Part 68. Based on the inspection and a review of additional information received by U.S. EPA subsequent to that date, U.S. EPA identified the following alleged violations by Respondent of the Risk Management Program Regulations: