Under the General Duty clause of the CAA, Section 112(r)(1), Respondent did not install a two-inch check valve on one end of the temporary quench line, as designed; Respondent did not develop a Job Note containing detailed instructions for the installation of the temporary quench line; Respondent did not create a Job Plan for the installation of the temporary quench line; Respondent's management of change internal review process failed to determine whether the temporary quench line was properly installed; Respondent did not include key stakeholders affected by the installation of the temporary quench line; Respondent failed to design and maintain a safe facility taking such steps as are necessary to prevent accidental releases, in violation of the General Duty Clause at Section 112(r)(1) of the CAA.