On August 20-23, 2018, EPA Region 6 personnel conducted an on-site inspection of the Facility to determine compliance with the CAA section 112(r)(7), 42 USC 7412(r)(7) and 40 CFR Part 68. During the inspection, EPA determined that the Facility had not conducted inspection and testing on several piping segments in the covered process. Respondent's failure to inspect and test these piping segments constitutes a violation of 40 CFR 68.73(d).