On January 27, 2010, an RMP was submitted for the Facility which specified that Respondent had 28,560,000 pounds of the Flammable Mixture in the Frozen Earth Storage unit (FES) process at the Facility, and which identified the process as Program 3. The Refinery stores over the threshold amount of a RMP regulated Flammable Mixture in the FES. EPA conducted an inspection of the Facility on December 15 and 16, 201 1, to assess compliance with section 112(r) of the CAA. During EPA's inspection, EPA inspectors utilized a handheld FLIR infrared camera and observed and recorded releases from the FES. The purpose of the RMP is to prevent or minimize risks of accidental releases of a regulated substance. At the time of EPA's inspection, Respondent had not adequately met their obligations under 40 C.P.R. part 68 by failing to prevent releases of the Flammable Mixture, a regulated substance from the FES.