On August 22, 2019, Respondent failed to implement safe operating procedures during activities associated with the startup of a production unit, which led to the accidental release of 260 pounds of butadiene, 90 pounds of butene, and 37 pounds of butane. Respondent's failure to implement a safe operating procedure for the startup of the Olefins Unit 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.