On March 8, 2016, through March 10, 2016, EPA Region 6 conducted an inspection at the Facility pursuant to Section 112(r) of the CAA, 42 USC 7412(r), and the implementing regulations found at 40 CFR Part 68. EPA Region 6 issued an Inspection Report on April 7, 2016, that identified 9 Areas of Concern relating to compliance with 40 CFR Part 68. On April 19, 2018, 2018, EPA Region 6 issued an Information Request to the Facility pursuant to the Section 114(a)(2) of the CAA, 42 USC 7414(a)(2), and a supplemental Information Request on August 2, 2018. Respondent submitted responses to the Information Requests on June 29, 2018, and August 14, 2018. At the time of the 2018 Information Request, Respondent provided documentation that one of three (3) Process Hazard Analysis (PHA) recommendations had not been resolved pursuant to 40 CFR 68.67. EPA finds Respondent's failure to assure that the PHA recommendations were resolved in accordance with the initial recommended schedule of completion was a violation of 40 CFR 68.67(e).