The Facility experienced an accidental release of phosgene on December 4, 2023. EPA conducted an inspection of the Facility from April 22 ? 25, 2024 , 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 April 28, 2025, EPA sent Respondent a Notice letter. On May 9, 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 Inspection, EPA determined that Respondent violated certain provisions of the CAA.