Respondent is a non-profit corporation which uses greater than 10,000 lbs of anhydrous ammonia in a single process at its cold storage warehouse. A June 2006 inspection of the facility disclosed that Respondent failed to implement a risk management program at the facility, violating 40 C.F.R. 68.15, 68.28, 68.39, 68.65, 68.67, 68.69, 68.71, 68.73, 68.75, 68.77, 68.79, and 68.83. As a result of pre-filing negotiations, Respondent has agreed to pay a cash penalty of $17,538 and to spend at least $43,615 on implementing two SEPs within six months. This CAFO will both initiate and conclude the enforcement action pursuant 40 C.F.R. 22.13(b) and 22.18(b) and (c).