Pursuant to Section 114 of the CAA, 42 U.S.C. ? 7414, EPA conducted an inspection of the Facility from December 11 to 14, 2023, to determine Respondent's compliance with Section 112{r) of the CAA, 42 U.S.C. ? 7412{r), and 40 C.F.R. Part 68 {the Inspection ). On December 31, 2024, EPA sent Respondent a Notice letter. On March 26, 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 on the inspection and documentation provided, EPA identified twelve (12) violations.