EPA conducted an inspection of the Facility on February 25-28, 2020, to determine Respondent's compliance with 40 CFR Part 68. Respondent failed to certify annually that its operating procedures were current and accurate in 2019 pursuant to 40 C.F.R.68.69(c), and failed to properly inform and fully train all affected employees in a change prior to start-up of an affected part of a process as required by 40 C.F.R. 68.12(d)(3).