On September 1, 2016, EPA conducted a compliance inspection of the Respondent’s facility to determine compliance with the Chemical Accident Prevention Provisions (CAPP) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the CAA. The EPA found that the Respondent had violated regulations implementing Section 112(r) of the CAA by failing to comply with the regulations as noted on the enclosed Chemical Accident Prevention Provisions Inspection Findings (CAPP Findings), which is hereby incorporated by reference. In consideration of Respondent’s size of business, its full compliance history, its good faith effort to comply, and other factors as justice may require, and upon consideration of the entire record, the parties enter into the ESA in order to settle the violations, described in the enclosed CAPP Findings, for the total penalty amount of $10,080.