Violation of 40 CFR 68.69(a)(l)(vii) - Failure to implement operating procedures. Facility had an accidental release during a process unit start up on 11/20/2019, due to a failure to close a bleed valve that had been opened during shut down. The bleed valve was inadvertently omitted from the Facility's operating procedures check list operators rely on to confirm such valves are closed prior to unit startup.