EPA conducted and inspection at the facility from July 12-15, 1999. This was follwed up with another site inspection from August 8-10, 2000. Based on these inspections, it was determined that the facility was in violation of the NSPS and the NESHAPS for not complying with the requisite LDAR requirements. The order requires them to comply with the rule. It also requires them to submit and inventory of all the components in the LDAR program and copies of all semi-annual reports for the past two years.