This enforcement action began as a voluntary disclosure under the EPA's Audit Policy. The facility used both anhydrous ammonia and pentane in its process in quantities that exceed the RMP thresholds. The facility began operation in 2006 and did not prepare a Risk Management Plan (CAA 112(r)(7) Part 68) until September 2009. The self disclosure did not meet the second criterion of the Audit Policy (voluntary discovery) and is consequently ineligible for penalty mitigation under section G(2) of the policy.