The Respondent has three RMProgram covered processes, one chlorine dioxide process, which stores or otherwise uses chlorine dioxide in an amount exceeding its applicable threshold of 1,000 pounds, and two chlorine processes, which store or otherwise uses chlorine in amounts exceeding its applicable threshold of 2,500 pounds. Based on an RMProgram compliance monitoring investigation initiated by EPA on July 22-24, 2013, the EPA alleges that the Respondent violated the codified rules governing the CAA Chemical Accident Prevention Provisions, because Respondent did not adequately implement provisions of 40 CFR Part 68 when it: