According to the RMP submitted to U.S. EPA by the facility, it fell within North American Industry Classification System Code 32599 as “all other chemical product and preparation manufacturing” and used flammables including butane, difluoroethane, isobutane, methyl ether and propane as process chemicals and held at least 10,000 lbs. As of July 6, 2004, the facility exceeded the applicability threshold established by 40 C.F.R § 68. 130, and was subject to 40 C.F.R. Part 68. For purposes of compliance with 40 C.F.R. Part 68, in its RMP, the facility has acknowledged that it was required to meet Program 3 eligibility requirements at the processes within the facility that are the subject of the violations alleged in this CAFO. On August 18, 2015, an authorized representative of U.S. EPA conducted an inspection at the facility to determine compliance with 40 C.F.R. Part 68. Based on the inspection and a review of additional information received by U.S. EPA subsequent to that date, U.S. EPA alleged the following violations of the Risk Management Program Regulations at the facility: