On August 20-23, 2018, EPA Region 6 personnel conducted an on-site inspection of the Facility to determine compliance with Section 112(r)(7) of the CAA, 42 USC 7412(r)(7), and 40 CFR 68. During the inspection, EPA determined that the Facility had not conducted inspections and testing on a number of 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).