Respondent has an RMProgram covered process, ammonia storage, which stores or otherwise uses anhydrous ammonia, an amount exceeding its applicable threshold of 10,000 pounds. Respondent has submitted and registered an RMPlan to the EPA. Based on an RMProgram compliance monitoring investigation initiated on January 31, 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: