The Respondent, a manufacturer, packager and distributer of multiple grades of high-purity solvents, acids, salts and bonded phase products, has four RMProgram covered processes which stores or otherwise uses chloroform, ethyl ether, formaldehyde, and hydrogen fluoride in amounts exceeding their applicable thresholds of 20,000; 10,000; 15,000; and 1,000 pounds respectively. Based on an RMProgram compliance monitoring investigation initiated on February 16, 2012, 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: