On April 18, 2020, there was an incident at the Facility that resulted in an accidental release. On January 7, 2021, the EPA sent Respondent a Notification of Potential Violations and Opportunity to Confer letter. EPA identified the following violations: Failure to maintain records supporting the implementation of refresher training as required by 40 CFR 68.200; Failure to provide refresher training for a greater than three-year period pursuant to 40 CFR 68.7l(b); Failure to prepare records which contain the means used to verify that the employees understood the training pursuant to 40 CFR 68.71 (c); and, Failure to update and revalidate the PHA pursuant to 40 CFR 68.67(f).