On February 22, 2023, EPA Region III issued an Administrative Compliance Order on Consent (Order) to AdvanSix Resins & Chemicals, LLC (AdvanSix), the owner and operator of a caprolactam manufacturing facility located in Hopewell, Virginia. AdvanSix is subject to Section 112(r)(7) of the CAA and the RMP Regulations because it is an owner or operator of a stationary source with more than a threshold quantity of regulated substances oleum (fuming sulfuric acid), ammonia (anhydrous), ammonia (concentration greater than 20%), acetaldehyde, and flammable mixture present in a process at the Facility. EPA alleges that AdvanSix is failing to comply certain mechanical integrity, process hazard analyses and process safety information requirements at the Facility, and therefore is operating in violation of Section 112(r)(7) of the CAA and the RMP Regulations. Specifically, the Order identifies the following compliance issues: failure to properly design oleum storage tank scrubber lines to prevent tank vent obstruction, failure to consider Bathtub Ring Corrosion as a risk for oleum storage tanks, failure to conduct linear UT scans of oleum storage tanks, failure to have proper pipe hangers/supports on piping associated with oleum and ammonia storage tanks, and failure to provide proper insulation on piping associated with ammonia storage tanks. The Order requires AdvanSix to retain a third-party contractor to assess the Facility's compliance with the Risk Management Program and condu