On November 3, 2015, EPA Region 6 filed a Consent Agreement and Final Order (CAFO) with the Regional Hearing Clerk, settling a CAA Section 112(r) case against Eagle US 2 LLC (Eagle) for violations at its Westlake, Louisiana facility. The CAFO alleges the following violations: (1) failure to adequately follow operating procedures; (2) failure to develop and implement operating procedures which include steps required to correct or avoid deviations; (3) failure to inspect pipe in PHH unit; (4) failure to conduct mechanical integrity inspections of certain pipes; (5) failure to conduct mechanical integrity inspections of pressure vessels; and (6) failure to update process hazard analysis every five years.. The CAFO requires Eagle to pay a $877,992 civil penalty. The CAFO also requires Eagle to implement a hydrogen chloride leak detection and repair SEP for a period of three years (cost $108,000) and to donate emergency equipment to the Moss Bluff Fire Department (cost $11,000).