Respondent operates a facility located in Vermont, where it makes cheese (the “Facility”). The Facility is located in an industrial section of Swanton, Vermont, within approximately 700 feet (0.13 mile) of Route 78, which runs up to the Canadian border, 590 feet (0.11 mile) of the nearest residence, 1,000 feet (0.19 mile) of the Missisqoui River, and within half a mile of the downtown area, which is located across the river from the Facility. At the time of the violations alleged herein, a worst-case release of ammonia from the largest vessel on site could have seriously injured people within a 1.9-mile perimeter of the Facility. At the time of the violations alleged herein, the Facility had a refrigeration system, which cycled approximately 2,500 pounds of anhydrous ammonia through various physical states to cool Respondents’ products. Accordingly, Respondents “stored” and “handled” anhydrous ammonia. The Facility’s ammonia refrigeration system was installed decades before Respondent, the reality company, acquired the Facility. Respondent, the cheese manufacturer, restarted the defunct plant in 2011.