There were two incidents at the Facility that resulted in accidental releases of 1,3-Butadiene. EPA conducted a desktop investigation of the Facility to determine compliance with Section 112(r) of the CAA, 42 USC 7412(r), and 40 CFR Part 68. On May 18, 2022, the EPA sent the Respondent a Notice of Potential Violation and Opportunity to Confer letter. EPA determined there were 10 violations of Part 68 and the General Duty Clause, Section 112(r)(1).