On September 20, 2024, there was an incident at the Facility that resulted in an accidental release (the Incident ). On February 5, 2025, EPA requested follow-up information and Respondent provided a response on February 19, 2025, regarding the Incident and
Respondent's compliance with Section 112(r) of the CAA, 42 U.S.C. ? 7412(r), and 40 C.F.R. Part 68 (the Investigation ). On April 8, 2025, EPA sent Respondent a Notice Letter. On April 14, 2025, and on various other occasions, EPA conferred with Respondent regarding the violations alleged herein and provided an opportunity for Respondent to submit additional information or materials.Based upon the information gathered during the Investigation, EPA determined
that Respondent violated a provision of the CAA.