On March 21, 2022, there was an incident at the Facility that resulted in an accidental release. Pursuant to Section 114 of the CAA, the EPA requested, and Respondent provided, documentation and information concerning the Incident and compliance with Section 112(r) of the CAA, and Part 68 Risk Management Program requirements. On August 8, 2022, the EPA sent Respondent a Notice of Potential Violation and
Opportunity to Confer letter. On August 19, 2022, the EPA responded to the documentation and information received from Respondent as a result of the opportunity to confer. EPA determined five findings of violation for process hazard analysis, operating procedures, mechanical integrity, and emergency response coordination.