On September 30, 2022, there was an incident at the Facility that resulted in an accidental release of xylene. On March 28, 2023, the EPA sent Respondent a Notice of Potential Violation and Opportunity to Confer letter. At the time of the Incident, Respondent failed to follow the standard grounding operating procedure established for the handling and transfer of xylene between totes, leading to static ignition of the xylene that resulted in a fire and an accidental release of 200 gallons of xylene to the air during the incident. Respondent's failure to follow the standard grounding operating procedure to ensure safe handling and transfer of xylene is a failure to maintain a safe facility by taking such steps as are necessary to prevent releases, in violation of Section 112(r)(1) of the CAA, the General Duty Clause.