Plains LPG Services, L.P., Alto, Michigan, is the subject of a Consent Agreement and Final Order entered on August 2, 2014 between USEPA Region V and Plains (Respondent) for violations of Section 112 (r) of the Clean Air Act. Respondent operates a liquefied petroleum gas manufacturing and storage facility in Alto, Michigan, which according to the RMP submitted to USEPA by the Respondent used butane and propane as process chemicals during its operations, and held at least 10,000 pounds of butane and propane. On July 5, 2012, authorized representatives of USEPA conducted an inspection of the facility to determine its compliance. USEPA alleged that Respondent violated the Hazard Assessment and Program 3 Prevention Program regulations as follows: a) failed to analyze and report the worst-case release scenario that is estimated to create the greatest distance in any direction to an endpoint resulting from an accidental release of a regulated flammable substance from the covered process under worst-case conditions as required under 40CFR 68.25 (a)(2)(ii); b) failed to determine the worst-case release quantity that is, for substances in a vessel, the greatest amount held in a single vessel, taking into account administrative controls that limit the maximum quantity, as required under 40 CFR 68.25(b)(1); c) failed to compile written process safety information including information pertaining to the technology of the process that includes maximum intended inventories, as required u