On December 14,2010, through December 16, 2010 EPA conducted a partial compliance evaluation inspection of the refinery pursuant to Section 112 of the Clean Air Act, 42 U.S.C. ยง7414 to evaluate the Facility’s compliance with the requirements of 40 CFR Part 68. Respondent uses a standard procedure for inspection of process piping systems titled Mechanical Integrity Examination and Inspection Manual, Piping inspection Procedure (the “Piping Inspection Procedure”), which it prepared to be consistent with an industry standard prepared by the American Petroleum Institute (API): Standard 570-Piping Inspection Code: Inspection, Repair, Alteration, and Rerating of In-Service Piping Systems (“API 570”).