EPA conducted an inspection of the Facility from June 4, 2018 through June 7, 2018, to determine Respondent's compliance with Section 112(r) of the CAA, 42 USC 7412(r) and 40 CFR Part 68. EPA determined that Respondent failed to conduct inspections of piping in its covered processes, or to include the piping in the RMP mechanical integrity program, a violation of 40 CFR 68.73(d)(1).