Respondent did not establish written procedures to maintain the on-going integrity of the Pentane High
Pressure Heat Exchanger (PHPHE) in accordance with manufacturers' recommendations. Respondent did not perform inspections and tests on pentane piping at the Facility. Respondent did not perform inspections and tests on the pentane storage vessel at the Facility. Respondent conducted a compliance audit, required by 40 C.F.R. ? 68.79, in December 2008. Three findings from the December 2008 compliance audit were not corrected in a timely
manner.