On May 22-25, 2018, EPA conducted an announced inspection to determine compliance with Section 112(r) of the CAA, 42 USC 7412(r), and 40 CFR Part 68. Respondent's failure to timely inspect and test process equipment at the recommend frequency constitutes a violation of 40 CFR 68.73(d)(3). Respondent's failure to implement written procedures to maintain the on-going integrity of process equipment constitutes a violation of 40 CFR 68.73(b). As provided in the CAFO, Kuraray America will have thirty (30) days from the effective date of the CAFO to pay the civil penalty of $90,640.00.