Respondent is the owner and/or operator of a facility that sells anhydrous ammonia to farmers for use as a fertilizer. At all times relevant to this action, Respondent processed, handled and stored anhydrous ammonia at its facility. On or about May 29, 2013, and April 29, 2014, EPA conducted inspections of Respondent’s facility to determine compliance with Section 112(r) of the CAA and 40 C.F.R. Part 68. Information collected as a result of these inspections revealed that Respondent had greater than 10,000 pounds of anhydrous ammonia in a process at its facility. Respondent failed to develop and implement a risk management program for its facility that complied with all the requirements of 40 C.F.R. Part 68. Specifically: