Respondent is the owner and/or operator of two facilities, the “Saratoga Springs Facility” and the “Carthage Facility”. On or about May 22, 2009, Respondent submitted an RMP to EPA for the Saratoga Springs Facility; which identified the process chemical as chlorine, specified a quantity of 24,000 pounds, and identified this process as subject to Program 3 requirements. On May 13, 2010, EPA conducted an inspection at the Saratoga Springs Facility to determine compliance with Section 112(r) of the CAA, 42 U.S.C. ยง 7412(r), and the applicable regulations listed in 40 C.F.R. Part 68. EPA issued a compliance order to Respondent on September 28, 2010, Index No. CAA-02-20 10-1018, pursuant to Section 113 of the CAA regarding the Saratoga Springs Facility. The Order required Respondent to perform certain activities at the Saratoga Springs Facility to come into compliance with the requirements of Section 112(r) of the CAA and 40 C.F.R. Part 68. On March 28, 2011, Respondent submitted a final report to EPA documenting compliance with the Order (“Final Report”). Deficiencies in the Final Report were found by EPA, which Respondent corrected in subsequent submissions to EPA on July 7, 2011, and October 23, 2011.