EPA conducted an inspection at the Facility Sept 25-26, 2018. On Oct 18, 2019, Respondent provided additional information regarding areas of concern identified during the inspection. EPA determined there were the following violations: failure to timely revalidate PHAs, 68.67(f); failure to annually certify operating procedures 68.69(c); failure to provide refresher training 68.71(b); and, failure to conduct mechanical integrity inspections 68.73(d).