Respondent is the owner and/or operator of facilities that use a proprietary fluorination technology to treat plastic containers and other articles. At all times relevant to this action, Respondent processed, handled and stored hydrogen fluoride (HF) at its facilities. HF is a regulated substance pursuant to 40 C.F.R. § 68.3 with a threshold of 1,000 pounds. From 2010 – December 2011 EPA inspected four (4) facilities, of which respondent failed to develop and implement a risk management program or submit an RMP for its Mt. Pleasant, Iowa; Kansas City, Missouri; St. Louis, Missouri; and Centerville, Iowa, facilities, as required by Section 112(r)(7) ofthe CAA, 40 C.F.R. §§ 68.12 and 68.150(a).