EPA conducted an inspection of the Facility from September 15, 2020 - November 3, 2020, to determine compliance with Section 112(r) of the CAA, 42 USC 7412(r), and 40 CFR Part 68. On December 8, 2021, the EPA sent Respondent a Notice of Potential Violation and Opportunity to Confer letter. On March 1, 2022, the EPA responded to the documentation and information received from Respondent. EPA determined there were violations of Part 68 regarding Process Safety Information, Process Hazard Analysis, Mechanical Integrity, Management of Change, Hot Work Permits, Applicability, and Emergency Response.