Respondent is the owner and/or operator of a manufacturing facility located in New York. The Facility uses phosgene in a process for the manufacture of organic chemicals. Respondent filed an RMP for the Facility with EPA on or about May 14, 2009, that, among other things, identified a covered phosgene process at the Facility subject to Program 3 requirements, with a specified quantity of 32,000 pounds of phosgene. EPA conducted an inspection of the Facility on or about June 6 – 7, 2012 to assess compliance with Section 112(r) of the Act and the applicable regulations, including those listed in 40 C.F.R. Part 68. The Inspection Report identified violations of the regulations at 40 C.F.R. Part 68 at the Facility, including failures to fully comply with: