EPA conducted an inspection of the Facility between April 5-7, 2022, to determine compliance with Section 112(r) of the CAA and 40 CFR Part 68. On December 7, 2022, the EPA sent Respondent a Notice of Potential Violation and Opportunity to Confer letter. On March 29, 2023, the EPA responded to the documentation and information received from Respondent as a result of the opportunity to confer. EPA determined 7 findings of violation for process hazard analysis, operating procedures, operator training, mechanical integrity, compliance audits, management of change, and hot work permits.