I should point out that this facility was found to be OVER the threshold for 180 days over a three (3) year period. EPA went through paper work to find times the facility had over 10,000 pounds of a NFPA “4” flammable mixture in their process. The process involves dissolving acetylene in acetone in order to suspend the acetylene in a stable condition for transport and use. The mixture of acetylene and acetone contains greater than one percent of acetylene AND has a NFPA rating of 4, and is therefore a flammable mixture as specified in 40 C.F .R. § 68.115(b)(2). As a result, the entire weight of the mixture is treated as a regulated substance for purposes of determining whether the threshold quantity of the regulated substance is present. On or about November 5-6, 2014, EPA conducted an inspection of Respondent’s facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information collected as a result of the inspection and information request revealed that on at least 180 days between January 1, 2012, and January 30, 2015, Respondent had greater than 10,000 pounds of the flammable mixture of acetylene and acetone in a process at the facility. On February 9, 2015, EPA requested additional information from Respondent regarding its compliance with Section 112(r) of the CAA. On or about March 10, 2015, Respondent submitted information including, inter alia, the quantities of acetylene manufactured and dissolved in acetone for each daily order for specific dates. EPA alleges that Respondent has violated the CAA and federal regulations promulgated pursuant to the CAA, as follows: