Respondent Ag’s facility includes bulk ammonia storage operations. On or about September 11, 2013, EPA inspected the facility to determine compliance with Section 112(r) of the CAA, 42 U.S.C. § 7412(r), and 40 C.F.R. Part 68. At the time of the September 2013 inspection, Respondent had greater than 10,000 pounds of anhydrous ammonia stored in a process (bulk storage tanks) at the facility. At the time of the September 11, 2013, inspection, a residential dwelling was located at the facility, and in direct proximity to the Syracuse facility’s ammonia bulk storage tanks. As alleged below, information collected as a result of the September 2013 inspection revealed that Respondent had never filed an RMP for the Syracuse facility, and had failed to properly develop and implement a risk management program required by Section 112(r) of the CAA and 40 C.F.R. Part 68 for the Syracuse facility.