On February 7, 2017, EPA Region 6 issued a Consent Agreement Final Order (CAFO)under its authority pursuant to violations of the RMP regulations of 40 C.F.R. Part 68. The CAFO cited Formosa for the following violations: (1) failure to maintain data used to estimate population and environmental receptors for the offsite consequence analyses; (2) failure to ensure that PHA findings and recommendations are resolved in a timely manner; (3) failure to update process hazard analysis every five years; (4) failure to conduct an adequate PHA for the VCM process; (5) failure to properly implement certain operating procedures; (6) failure to conduct a management of change; and (7) failure to correct deficiencies in 2008 and 2011 compliance audits. The CAFO requires Formosa to pay a $277,200 civil penalty