EPA conducted an inspection of the Facility between March 29-31, 2022, to determine compliance with 40 CFR Part 68, Risk Management Program rules. On May 11, 2022, the EPA sent Respondent a Notice of Potential Violation and Opportunity to Confer letter. On June 3, 2022, the EPA responded to the documentation and information received from Respondent as a result of the NOPVOC and articulated the EPAs position concerning Respondent's compliance with Section 112(r) of the CAA, 42 USC 7412(r). On June 15, 2022, Respondent informed the EPA of Respondents agreement to evaluate and resolve the following findings of violation: management system, process safety information, process hazard analysis, operating procedures review, documentation of operator refresher training, mechanical integrity inspections and tests, pre-startup safety review, risk management program compliance audits, written employee participation plan, and documentation that it had coordinated with local authorities regarding its emergency response coordination activities.