On July 26, 2021, there was an incident at the Facility that resulted in an accidental release of chlorine. Subsequent to EPA's review, on December 3, 2021, the EPA sent Respondent a Notice of Potential Violation and Opportunity to Confer letter. EPA determined Respondent failed to perform inspections and tests on process equipment at a frequency consistent with applicable good engineering practices pursuant to 40 CFR 68.73(d)(2), and as required by 40 CFR 68.12(d)(3).