On June 28, 2012, an EPA representative conducted a compliance inspection of Respondent to determine compliance with the Risk Management Program (RMP) regulations promulgated pursuant to Section 112 (r) of the Clean Air Act. Based on that inspection, EPA determined that: 1. 40CFR 68.67(e) Respondent failed to establish a system to promptly address the process hazard analysis; 2. 40CFR 68.67(f) Respondent failed to timely revalidate the process hazard analysis five years after the completion of the initial process hazard analysis; 3. 40CFR 68.73 (d)(!) Respondent failed to perform inspections and tests on process equipment; 4. 40CFR 68.79(a) Respondent failed to timely conduct a compliance audit every three years; 5. 40 CFR 68.79(d) Respondent failed to address the deficiencies discovered during the compliance audit; 6. 40CFR 68.87(b) Respondent failed to obtain and evaluate information on contractors' safety performance and programs prior to selecting the contractors, and 7. 40 CFR 68.190(b)(1) Respondent failed to revise and update its risk management plan.