THIS COMPLAINT AND EXPEDITED SETTLEMENT AGREEMENT IS ISSUED TO LAS ANIMAS FERTILIZER COMPANY FOR FAILURE TO SUBMIT A RISK MANAGEMENT PLAN (RMP) TO EPA IN A MANNER AND FORMAT AS REQUIRED BY FEDERAL REGULATIONS. EPA ALLEGES THAT RESPONDENT HAS A REGULATED SUBSTANCE, ANHYDROUS AMMONIA, IN PROCESS ON-SITE AT RESPONDENT'S FACILITY. THE TOTAL PENALTY ASSESSED IS $1,798.