On January 17, 2020, EPA performed an inspection of the Facility pursuant to Section 112(r) of the CAA, Sections 304-312 of EPCRA, and Section 103 of the Comprehensive Environmental Response, Compensation, and Liability Act. Based upon the information gathered during this inspection and subsequent investigation, EPA asserts that Respondent violated certain provisions of the CAA and EPCRA. At all times relevant to this CA/FO, Respondent has been the “owner or operator” of a stationary source that has a regulated substance in an amount equal to or in excess of the applicable TQ in a “process” as defined by 40 C.F.R. ยง 68.3 and is subject to the Program 3 RMP requirements.