Respondent’s denaturant process contains a mixture with a NFPA rating of 4, and is therefore a flammable mixture as specified in 40 C.F.R. ยง 68.115(b)(2). On or about May 2-3, 2012, EPA conducted an inspection to determine compliance with RMP 40 C.F.R. Part 68. Respondent’s denaturant process stores approximately 715,000 pounds, with the entire weight of the mixture being treated as a regulated substance. Respondent was required under 40 C.F.R. Part 68, to develop and implement a Risk Management Program that includes a hazard assessment, a prevention program, an emergency response program, and to file a Risk Management Plan. Records collected during the inspection showed that Respondent failed to fully comply with 40 C.F.R. Part 68, specifically: