The Respondent owns and operates 14 facilities in Illinois in: Altamont, Arcola, Dieterich, Farina, Gays, Lovington, Marshall, Montrose, Pana, Robinson, Rosamond, Salem, Stewardson and West Liberty. Illinois On August 29, 2014, EPA sent requests to all 14 facilities on their RMP practices. The Respondent confirmed that each of the 14 facilities had failed to submit a revised and updated RMP within five years of the initial submission or most recent update, EPA and Respondent agreed to a CAFO, with a civil penalty of $6,800.00 and a SEP in which Respondent agreed to install a remotely operated shutdown system on ammonia tanks at five locations: Altamont, Dieterich, Greenville, Marshall and Stewardson, Illinois and to spend at least $50,000 for installment of systems at these five facilities.