Pursuant to the Blanchard letter of April 3, 2013, and EPA, Region 6 acceptance letter of May 28, 2013, which together comprise the Audit Agreement between EPA, Region 6 and Blanchard (Agreement), Blanchard conducted a comprehensive, multistage audit of the Galveston Bay Refinery. Blanchard had acquired the facility in early 2013 from BP Products North America Inc. The audit focused on substantive areas of the Clean Air Act (CAA). Specifically, Blanchards comprehensive audit covered requirements of the following areas: New Source Review/Prevention of Significant Deterioration (NSP/PSD); Leak Detection and Repair (LDAR); Refinery Maximum Achievable Control Technology (MACT) applicability analysis; Risk Management Plan (RMP); and, Texas State Implementation Plan (Texas SIP).