Respondent has five RMProgram covered processes. The letdown area process, the urea process, and the high pressure solutions process store or otherwise use ammonia in an amount exceeding its applicable threshold of 10,000 pounds; the chlorine addition process stores or otherwise uses chlorine in an amount exceeding its applicable threshold of 2,500 pounds; and the sulfur dioxide addition process stores or otherwise uses sulfur dioxide in an amount exceeding its applicable threshold of 5,000 pounds. Based on an RMProgram compliance monitoring investigation initiated by EPA on May 20, 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: