Chlorine and sulfur dioxide have been present at this facility in quantities of at least 10,000 lbs each since prior to June 21, 1999. The containers for both of these substances are stored in the same room and could be involved in a potential release - and thus are considered a single process as defined by 40 CFR Part 68.3. Consequently, this facility was required to comply with Risk Management Program regulations and failed to timely submit a Risk Management Plan by June 21, 1999. Respondent submitted its Risk Management Plan to the EPA on November 21, 2011.