Respondent does business in the Commonwealth of Kentucky and operates a “stationary source”. Respondent has developed an RMProgram accidental release prevention program for the stationary source. The Respondent, at its stationary source has an RMProgram covered process, ammonia refrigeration, which stores or otherwise uses anhydrous ammonia, in an amount exceeding its applicable threshold of 10,000 pounds. Based on an RMProgram compliance monitoring investigation initiated on March 30, 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: