VIOLATIONS-At the time of the 2018 Information Request, Respondent provided documentation that 3 PHA recommendations have not been resolved. Specifically, Respondent identified three action items from a previous Process Hazard Analysis (PHA) that were not completed timely. EPA finds Respondent's failure to assure that the recommendations were resolved in a timely manner is a violation of 40 CFR 68.67(e). Respondent also identified 4 additional vessels that were overdue for Inspection. Respondent's failure to conduct mechanical integrity inspections as required are in violatfon of 40 CFR 68.73(d).