On November 3, 2019, there was an incident at the Facility that resulted in an accidental release of ethylene oxide. Respondent failed to implement safe operating procedures during startup of a Production Unit, which led to the accidental release. The failure to implement a safe operating procedure for the startup pursuant to 40 CFR 68.69(a)(l)(vii), as required by 40 CFR 68.12(d)(3) is a violation of Section 112(r)(7) of the CAA.