November 2-3, 2011, EPA conducted an inspection of fertilizer manufacturing plant (Anhydrous Ammonia) to determine compliance with Section 112(r) of the Clean Air Act and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed the facility had greater than 10,000 pounds of anhydrous ammonia in a process at its facility. From the time Respondent first had onsite greater than 10,000 pounds of anhydrous ammonia in a process in January 2008 until Respondent reduced the quantity of anhydrous ammonia at its facility to less than 10,000 pounds in March 2012, Respondent was subject to the requirements of Section 112(r) ofthe Clean Air Act and 40 C.F.R. Part 68, because it was an owner and operator of a stationary source that had more than a threshold quantity of a regulated substance in a process. Facility was subject to Program 3 of the risk management program requirements because the covered processes did not meet the requirements of Program 1 and were subject to the OSHA’s PSM standard. EPA alleges the facility violated the CAA and federal regulations promulgated pursuant to the CAA, as follows: