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13. Respondent submitted the RMP for the Facility to the Risk Management Plan Reporting <br /> Center in Maryland on November 29, 2007. <br /> D. ALLEGED VIOLATIONS <br /> COUNT <br /> (Failure to Timely Submit a Risk Management Plan) <br /> 14. Paragraphs 1 through 13 above are incorporated herein by this reference as if they were <br /> set forth here in their entirety. <br /> 15. The Facility is, and at all times referred to herein was,a"stationary source"as defined by <br /> Section 112(r)(2)(c) of the CAA,42 U.S.C. § 7412(r)(2)(c),and 40 CFR § 68.3. <br /> 16. At all times relevant to this CAVO,Respondent has been the"owner or operator"of the <br /> Facility as defined by Section 112(a)(9)of the CAA, 42 U.S.C. § 7412(a)(9). <br /> 17. Respondent is, and at all times referred to herein was, a"person" as defined by CAA <br /> Section 302(e),42 U.S.C. §7602(e). <br /> 18. Anhydrous ammonia is a`regulated substance" as defined by 40 CFR§§ 68.3 and <br /> 68.130. <br /> 19. The Facility's refrigeration system is a"covered process," as defined by 40 CFR § 68.3, <br /> because it is an activity that uses a regulated substance in more than a threshold quantity. <br /> The Facility's refrigeration system meets the Program 3 eligibility requirements,as set <br /> forth in 40 CFR § 68.10. <br /> 20. The threshold quantity for andyrdous ammonia is 10,000 pounds. 40 CFR § 130, Table 1. <br /> 21. On or before June 21, 1999,the Facility first took delivery of anhydrous ammonia for use <br /> in its refrigeration system. Between June 21, 1999, and November 29, 2007, Respondent <br /> 4 <br /> CA/FO Provena Foods,dba Swiss American Sausage Co.,Lathrop,CA <br />