At all times under this CAFO, Respondent FloraCraft Corporation, owned, operated, controlled and supervised a facility located at One Longfellow Place, Ludington, Michigan. The facility manufactures solid craft foam for the floral industry and others. Respoondent uses butane, Difluoroethane and pentane in its manufacturing processes.Repondent's facility had butane since November 2011, difluoroethane since November 2011, and pentane since May 2013, each in quantities exceeding 10,000 pounds through 2013. Respondent's processes at its facility subject it to Program 3 requirements. On July 24, 2013, Respondewnt's Risk Management Program failed to implement certain mandatory elements required by the program's provisions, as itemized in Table A of this CAFO. Based on an analysis of the factors specified by USEPA Region V, Complainant has determined that an appropriate civil penalty to settle this action is $25,464.00, and that Respondent must complete a supplemental environmental project (SEP) designed to protect the environment and public health. Respondent proposed to triple the capacity of deluge fire-suppression systems at its facility to limit any potential releases of regulated materials at the facility from fire or explosion. The SEP will cost at least $55,130.00 to purchase and install the improved deluge system, with completion of work by May 1, 2015.