BECAUSE THE RESPONDENT HAD PRESENT AT THE SFI - SHIPPENSBURG FACILITY AN AMOUNT OF ANHYDIOUS AMMONIA GREATER THAN THE THRESHOLD QUANTITY LISTED IN 40 CFR SECTION 68.130, IT WAS REQUIRED TO SUBMIT A RISK MANAGEMENT PLAN BY DECEMBER 3, 2002. THE RESPONDENT FAILED TO SUBMIT A RISK MANAGEMENT PLAN UNTIL JULY 11, 2003 AND VIOLATED THE REQUIREMENTS OF 40 CFR PART 68.
THE RESPONDENT SELF-DISCLOSURE THE POTENTIAL VIOLATION IN A LETTER DATED JULY 11, 2003 AND PROVIDED ADDITIONAL INFORMATION IN A LETTER DATED APRIL 15, 2004. EPA DETERMINED THE SCHREIBER FOODS COMPLIED WITH ALL MINE CRITERIA OF EPA'S AUDIT POLICY.