From August 18 - 31, 2020, representatives of EPA conducted a Virtual Partial Compliance Evaluation (VPCE) of the Respondent's facility. Respondent violated the following sections of 40 CFR Part 68: 68.65(d)(2) - failure to properly classify process piping; 68.69(c) - failure to certify operating procedures annually; 68.73(b) - failure to implement pre-inspection activities and field assessment activities, and failure to develop and implement written procedures to maintain the ongoing integrity of piping; 68.73(d)(2) - failure to use the correct recognized and generally accepted good engineering design code; 68.73(d)(3) - failure to conduct the proper frequency of internal inspections; 68.73(e) - failure to correct deficiencies as identified in a Flare Study; 68.75(d) - failure to perform a Management of Change for a process change; and, 68.79(d) - failure to promptly document that a finding had been corrected from a prior compliance audit.