On or about September 14, 2016, representatives of the EPA conducted an inspection (the 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’s Facility had greater than 10,000 pounds of anhydrous ammonia in a process. From the time Respondent first had onsite greater than 10,000 pounds of anhydrous ammonia in a process, Respondent was subject to Program 2 prevention program requirements pursuant to 40 C.F.R. § 68.10(c), because the process does not meet the eligibility requirements of either Program 1 or Program 3, as described in 40 C.F.R. § 68.10(b) and (d), respectively. Complainant hereby states and alleges that Respondent has violated the CAA and federal regulations promulgated thereunder as follows: