Respondent owns and operates a cold storage and fruit packing facility which uses greater than 10,000 lbs of anhydrous ammonia in a single process for refrigeration. 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, 68.25, 68,28, 68.30, 68.33, 68.36, 68.39, 68.67, 68.69, 68.71, 68.73, 68.75, 68.77, 68.79, 68.83, 68.95, and 68.190. This CAFO will both initiate and conclude the enforcement action pursuant to 40 C.F.R. §§ 22.13(b), and 22.18(b) and (c).