EPA conducted a virtual partial compliance evaluation (VPCE) of the Facility on February 25, 2021, to April 19, 2021, to determine compliance with Section 112(r)(7) of the CAA, 40 CFR Part 68. On December 02, 2021, the EPA sent the Respondent a Notice of Potential Violation and Opportunity to Confer (NOPVOC) letter. In a conference call on January 19, 2022, the EPA conferred with the Respondent regarding the violations alleged therein and provided an opportunity for the Respondent to submit additional information or materials. The EPA determined 8 findings of violation of Part 68.