EPA conducted an inspection of the Facility from August 2-5, 2022, to determine compliance with the CAA Section 112(r)(7) and 40 CFR Part 68. On November 21, 2022, the EPA sent Respondent a Notice of Potential Violation and Opportunity to Confer letter. On December 8, 2022, the EPA responded to the documentation and information received from Respondent as a result of the opportunity to confer. EPA identified 6 findings of violation for process hazard analysis, mechanical integrity, management of change, compliance audits, incident investigation, and emergency response.