On September 25, 2024, there was an incident at the Facility that resulted in an accidental release (the Incident ). Pursuant to Section 114 of the CAA, 42 U.S.C. ? 7414, EPA sent an informal questionnaire to Respondent on April 17, 2025. Respondent provided documentation and information on June 9, 2025. Based on the response provided on June 9, 2025, EPA conducted an investigation
of the Facility 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 Investigation ). On August 11, 2025, EPA sent Respondent a Notice letter. On September 15, 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 certain provisions of the CAA.