Respondent does business in the State of Alabama. Respondent operates a “stationary source” that has one RMProgram covered process, latex resin manufacturing, which stores or otherwise uses vinyl acetate monomer in an amount exceeding its applicable threshold of 15,000 pounds. Respondent has submitted and registered an RMPlan to the EPA for the stationary source identified in Paragraph 5 of this CAPO. Respondent has developed an RMProgram accidental release prevention program for the stationary source. Based on an RMProgram compliance monitoring investigation initiated by EPA on July 25-26, 2013, the EPA alleges that the Respondent violated the CAA Chemical Accident Prevention Provisions, because Respondent did not adequately implement provisions of 40 CFR Part 68 when it: