ON NOVEMBER 19, 2010, EPA REGION III FILED AN ADMINISTRATIVE COMPLAINT ( COMPLAINT ) AGAINST JBS SOUDERTON, INC ( JBS ) FOR ALLEGED VIOLATIONS OF SECTION 112(r)(7) OF THE CLEAN AIR ACT ( CAA ), 42 U.S.C. SECTION 7412(r)(7), AND ITS IMPLEMENTING REGULATIONS, 40 C.F.R. PART 68, IN CONNECTION WITH AN AMMONIA REFRIGERATION SYSTEM AT THE JBS BEEF PROCESSING FACILITY LOCATED AT 249 ALLENTOWN ROAD IN ALLENTOWN, PENNSYLVANIA ( FACILITY ). THE VIOLATIONS WERE ASSERTED AS A RESULT OF JBS's FAILURE OT SUBMIT A FIVE-YEAR UPDATE TO ITS RISK MANAGEMENT PLAN, IN VIOLATION OF 40 C.F.R. SECTION 68.190(b)(1); FAILURE OT DEVELOP AND IMPLEMENT A MANAGEMENT SYSTEM, IN VIOLATION OF 40 C.RF.R. SECTION 68.15(a); FAILURE TO CORRECTLY ANALYZE THE WORST-CASE RELEASE SCENARIO FOR THE AMMONIA REFRIGERATION SYSTEM, IN VIOLATION OF 40 C.F.R. SECTION 68.25(a)(2) AND (b)(1); AND FAILURE TO ANNUALLY CERTIFY THAT IS OPERATING PROCEDURES FOR AMMONIA REFRIGERATION SYSTEM ARE CORRECT, IN VIOLATION OF 68.69(c).