On January 6, 2018, there was a release of chlorine from the MDI-3 Process Unit.The chlorine/carbon-steel fire allowed approximately 200 pounds of chlorine.to be released to the atmosphere and secondary containment. The release of chlorine at the Facility on January 6, 2018, constituted an accidental release as that term is defined by Section 112(r)(2)(A) of the CAA, 42 USC 7412(r)(2)(A). Respondent's failure to operate at appropriate upper temperature limits related to the MDI-3 process was a violation of 40 CFR 68.65.