Respondent has a Program 3 covered process, as defined in 40 C.F.R. § 68.1O(d), using Anhydrous ammonia. 40 C.F.R. § 68.12(a) and (d) require that, in addition to submitting a single RMP as provided in §§ 68.150 to 68.185, facilities with a Program 3 covered process shall among other things, develop a management system as provided in § 68.15, conduct a hazard assessment as provided in §§ 68.20 to 68.42, and implement the prevention program as required of 68.65 to 68.87. Here are the specifics: