Respondent owns and operates an agricultural storage and supply facility. On August 16, 2016, an accidental release of anhydrous ammonia occurred at Respondent’s Facility when filling a storage tank. The release resulted in the hospitalization of an employee. 22. On or about March 12, 2019, representatives of the EPA conducted an inspection of Respondent’s Facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information gathered during the EPA inspection revealed that Respondent had greater than 10,000 pounds of anhydrous ammonia in a process at the Facility. Complainant hereby states and alleges that Respondent has violated the CAA and federal regulations promulgated thereunder as follows: