Respondent owns and operates a beef slaughter and packaging facility and has Anhydrous Ammonia in excess of 10,000 pounds. On or about September 9, 2015, EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. From the time Respondent first had onsite greater than 10,000 pounds of ammonia in a process, Respondent was subject to Program 3 prevention program requirements because, pursuant to 40 C.F.R. § 68.1O(d), the covered process at the facility did not meet the eligibility requirements of Program 1 and was subject to the OSHA process safety management standard, 29 C.F.R. § 1910.119. Complainant hereby states and alleges that Respondent has violated the CAA and federal regulations promulgated thereunder as follows: