On or about October 24-26, 2017, representatives of EPA conducted an inspection of the Respondent's facility to determine compliance with the CAA Section 112(r) and applicable requirements of 40 CFR Part 68, Risk Management Program. EPA subsequently identified the following violations: 68.42(a) and 68.195(a), Failure to timely add an incident to the five-year accident history; 68.67(f), Failure to timely revalidate a Process Hazard Analysis; 68.69(a)-(d), Failure to implement an operating procedure; and, Section 112(r)(1) of the CAA, Failure to identify a hazard.