EPA conducted an inspection of the Facility between August 9 and 12, 2022, to determine compliance with Section 112(r) of the CAA, 40 CFR Part 68, Risk Management Program requirements. On February 1, 2023, the EPA sent Respondent a Notice of Potential Violation and Opportunity to Confer letter. On March 10, 2023, the EPA responded to the documentation and information received from Respondent as a result of the opportunity to confer. EPA determined 5 findings of violation for OCA documentation, five year accident history, process hazard analysis, process safety information, and hot work permits.