Respondent is a company doing business as a cold storage facility. The Respondent has an RMProgram covered process, ammonia refrigeration, which stores or otherwise uses ammonia, in an amount exceeding its applicable threshold of 10,000 pounds. Based on an RMProgram compliance monitoring investigation initiated on October 29, 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: