On June 22, 2018, EPA sent an administrative compliance order to the New England Confectionery Company (NECCO), Round Hill Investments LLC (Round Hill), and Atlantic-Revere Realty LLC, requiring them to update their risk management plan (RMP). NECCO operates a candy manufacturing plant in Revere, MA. The landlord is Atlantic-Revere Realty LLC, and Round Hill recently purchased NECCO?s assets in a bankruptcy auction. The facility has a refrigeration system that uses toxic anhydrous ammonia as a refrigerant which is subject to the RMP requirements of 40 C.F.R. Part 68, but had not timely updated its RMP as required by those regulations. EPA informed the MA Department of Environmental Protection about this matter, and DOJ worked with the MA Attorney General?s Office to ensure that the bankruptcy order authorizing the sale of assets did not shield the asset buyer from compliance with state and federal regulatory requirements