From June 27-28, 2019, an authorized representative of the EPA conducted a compliance inspection of the subject facility (Respondent) to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 CFR Part 68. The Respondent completed their process hazard analysis (PHA) on October 18, 2013, and did not revalidate the PHA until April 12, 2019, which is longer than the five-year update allowed and is in violation of 40 CFR 68.67(f).